&EPA
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
Washington DC 20460
EPA 530 SW-84-004
May 1984
Solid Waste
Permit Applicants'
Guidance Manual
for Hazardous Waste
Land Treatment, Storage,
and Disposal Facilities
Final Draft
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FINAL DRAFT
PERMIT APPLICANTS' GUIDANCE MANUAL FOR
HAZARDOUS WASTE LAND TREATMENT, STORAGE,
AND DISPOSAL FACILITIES
ttS.
For sale by the Superintendent of Documents, U.S. Government Printing Office
Washington, D.C. 20402
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TABLE OF CONTENTS
Preface
Acknowledgments
Executive Summary
Section 1.0 - Introduction 1-1
Section 2.0 - Administrative Procedures in the 2-1
Permitting Process
2.1 - Coordination with States 2-2
2.2 - Submitting RCRA Part A Permit Applications 2-2
2.3 - Submitting RCRA Part B Permit Applications 2-3
2.4 - Claims of Confidentiality 2-5
2.5 - EPA's Review of Part A and Part B Applications 2-7
2.6 - Draft RCRA Permits and Permit Denials 2-9
2.7 - Public Notice, Comments, Informal 2-11
Public Hearings, Panel Hearings
2.8 - Final Permits 2-11
2.9 - Appeal to the EPA Administrator 2-12
^ Section 3.0 - Permitting Standards and EPA Guidance 3-1
and Technical Manuals
D
3.1 - Overview of Part 264 and 270 Regulations 3-1
3.1.1 - General Applicability and Format 3-1
3.1.2 - General Facility Standards 3-4
3.1.3 - Ground-Water Protection 3-5
3.1.4 - Specific Facility Standards 3-8
3.1.5 - Permit Application Regulations 3-9
3.2 - Determining Which Facility Standards Apply 3-11
3.2.1 - Hazardous Waste Confirmation 3-11
3.2.2 - Determining if the Facility is a 3-13
Land Treatment, Storage or Disposal
Facility Subject to All the Part 264
and Part 270 Requirements
3.2.3 Terminology Associated with Facilities 3-15
3.3 - Unit Types and Applicable Standards 3-18
3.3.1 - Types of Units 3-18
3.3.2 - Standards Applicable to Specific 3-26
Unit Types
3.4 - RCRA Technical Guidance Documents, 3-32
Technical Resource Documents, and
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3.4.1 - RCRA Technical Guidance Documents 3-32
3.4.2 - Technical Resource Documents (TRDs) 3-41
3.4.3 - Other Guidance Manuals 3-45
3.4.4 - Other Reference Matrial 3-50
Section 4.0 - General Guidance for Preparing RCRA 4-1
Land Treatment, Storage, or Disposal
Permit Application
4.1 - Suggested Permit Application Format 4-1
4.1.1 - Purpose 4-1
4.1.2 - Part A Permit Application Format 4-2
4.1.3 - Part B Permit Application Format 4-2
4.1.4 - Format Suggestions 4-5
4.1.5 - Term of Permit 4-8
4.2 - Technical Assistance 4-8
4.2.1 - Engineers 4-8
4.2.2 - Geologists, Hydrogeologists, and 4-11
Soil Scientists
Section 5.0 - Surface Impoundment Permit Application 5-1
Guidance
5.1 - Waste Description 5-2
5.1.1 - The Federal Requirement 5-2
5.1.2 - Guidance to Achieve the Part 264 Standards 5-3
5.1.3 - Guidance to Address the Application 5-3
Information Requirement
5.2 - Design and Operating Requirements 5-4
5.2.1 - Liner System Design 5-5
5.2.2 - Liner Exemption Variance (Not 5-23
Applicable to Existing Portions)
5.2.3 - Prevention of Overtopping 5-24
5.2.4 - Structural Integrity of Dikes 5-27
5.2.5 - Ground-Water Protection Exemption 5-32
for Double-Liner Surface Impoundments
5.3 - Monitoring and Inspection 5-37
5.3.1 - Monitoring and Inspection During 5-37
Construction and Installation
5.3.2 - Monitoring and Inspection During Operation 5-42
5.4 - Dike Certification by a Oualified Engineer 5-45
5.4.1 - The Federal Requirement 5-45
5.4.2 - Guidance to Achieve to Part 264 Standards 5-46
5.4.3 - Guidance to Address the Application 5-46
Information Requirement
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5.5- Removal of Impoundment from Service 5-48
5.5.1 - The Federal Requirement 5-48
5.5.2 - Guidance to Achieve the Part 264 Standard 5-49
5.5.3 - Guidance to Address the Permit Application 5-50
Requirement
5 .6 - Closure and Post-Closure Care 5-51
5.6.1 - Closure of Storage Impoundments 5-51
5.6.2 - Closure of Disposal Impoundments 5-56
5.6.3 - Post-Closure Care of Disposal Impoundments 5-62
5.7 - Special Requirements for Ignitable or Reactive 5-63
Waste
5.7.1 - The Federal Requirement 5-63
5.7.2 - Guidance to Achieve the Part 264 Standards 5-64
5.7.3 - Guidance to Address the Application 5-64
Information Requirement
5.8 - Special Requirements for Incompatible Wastes 5-65
5.8.1 - The Federal Requirement 5-65
5.8.2 - Guidance to Achieve the Part 264 Standards 5-65
5.8.3 - Guidance to Address the Application 5-68
Information Requirement
5 .9 - References 5-69
5.10 - Checklist 5-70
Section 6.0 - Waste Pile Permit Application Guidance 6-1
6.1 - Waste Description 6-2
6.1.1 - The Federal Requirement 6-2
6.1.2 - Guidance to Achieve the Part 264 Standards 6-2
6.1.3 - Guidance to Address the Application 6-4
Information Requirement
6.2 - Design and Operating Requirements 6-5
6.2.1 - Liner Performance Standards 6-5
6.2.2 ,- Leachate Collection and Removal System 6-26
6.2.3 - Liner and Leachate Collection System 6-33
Exemption
6.2.4 - Control of Run-on 6-35
6.2.5 - Control of Run-off 6-36
6.2.6 - Management of Units Associated with Run-on 6-40
and Run-off Control System
6.2.7 - Control of Wind Dispersal 6-42
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6.2.8 - Ground-Water Protection Exemption for 6-45
Double-Lined Piles
6.2.9 - Ground-Water Protection Exemption for 6-51
Piles with Inspectable Liners
6-3 - Monitoring and Inspection 6-53
6.3.1 - Monitoring and Inspection During 6-53
Construction, Installation, and Operation
6.3.2 - Monitoring and Inspection of Liner if 6-59
Exemption from Ground-Water Protection
Requirements is Sought
6.4 - Exemption to Liner Standard and Ground-Water 6-61
Protection Standard
6.4.1 - The Federal Requirement 6-61
6.4.2 - Guidance to Achieve the 264 Standard 6-62
6.4.3 - Guidance to Address the Application 6-63
Information Requirement
6.5 - Treatment of Waste 6-63
6.5.1 - The Federal Requirement 6-63
6.5.2 - Guidance to Achieve the 264 Standard 6-63
6.5.3 - Guidance to Address the Application 6-63
Information Requirement
6.6 - Special Requirements for Ignitable or Reactive 6-65
Wastes
6.6.1 - The Federal Requirement 6-65
6.6.2 - Guidance to Achieve the 264 Standard 6-65
6.6.3 - Guidance to Address the Application 6-66
Information Requirement
6.7 - Special Requirements for Incompatible Waste 6-66
6.7.1 - The Federal Requirement 6-66
6.7.2 - Guidance to Achieve the 264 Standard 6-67
6.7.3 - Guidance to Address the Application 6-67
Information Requirement
6.8 - Closure 6-68
6.8.1 - The Federal Requirement 6-68
6.8.2 - Guidance to Achieve the 264 Standard 6-69
6.8.3 - Guidance to Address the Application 6-72
Information Requirement
6.9- References 6-73
6.10 - Checklist 6-74
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Section 7.0 - Land Treatment Unit Permit Application 7-1
Guidance
7.1 - Scope and Format 7-1
7.2 - Special Permitting Procedures 7-2
7.3 - Treatment Demonstration 7-7
7.3.1 - The Federal Requirement 7-7
7.3.2 - Guidance to Achieve the 264 Standard 7-9
7.3.3 - Guidance to Address the Application 7-14
Information Requirement
7.4 - Land Treatment Program 7-29
7.4.1 - The Federal Requirement 7-29
7.4.2 - Guidance to Achieve the 264 Standard 7-36
7.4.3 - Guidance to Address the Application 7-36
Information Requirement
7.5 - Design, Construction, Operation, and Maintenance 7-46
7.5.1 - The Federal Requirement 7-46
7.5.2 - Guidance to Achieve the 264 Standard 7-48
7.5.3 - Guidance to Address the Application 7-50
Information Requirement
7.6 - Food-Chain Crops 7-52
7.6.1 - The Federal Requirement 7-52
7.6.2 - Guidance to Achieve the 264 Standard 7-55
7.6.3 - Guidance to Address the Application 7-57
Information Requirement
7.7 - Establishment of Vegetative Cover at Closure 7-60
7.7.1 - The Federal Requirement 7-60
7.7.2 - Guidance to Achieve the 264 Standard 7-61
7.7.3 - Guidance to Address the Application 7-61
Information Requirement
7.8 - Ignitable or Reactive Wastes 7-62
7.8.1 - The Federal Requirement 7-62
7.8.2 - Guidance to Achieve the 264 Standard 7-64
7.8.3 - Guidance to Address the Application 7-64
Information Requirement
7.9 - Incompatible Wastes 7-65
7.9.1 - The Federal Requirement 7-65
7.9.2 - Guidance to Achieve the 264 Standard 7-66
7.9.3 - Guidance to Address the Application 7-70
Information Requirement
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7.10 - References 7-70
7.11 - Checklist 7-71
Section 8 .0 - Landfill Permit Application Guidance 8-1
8.1 - Waste Description 8-2
8.1.1 - The Federal Requirement 8-2
8.1.2 - Guidance to Achieve the 264 Standard 8-2
8.1.3 - Guidance to Address the Application 8-2
Information Requirement
8.2 - Design and Operating Requirements 8-4
8.2.1 - Liner Performance Standards 8-4
8.2.2 - Leachate Collection and Removal System 8-21
8.2.3 - Liner and Leachate Collection and Removal 8-29
System Exemption Variance (Not Appl-icable
to Existing Portions)
8.2.4 - Control of Run-on 8-31
8.2.5 - Control of Run-off 8-33
8.2.6 - Management of Units Associated with Run-on 8-37
and Run-off Control Systems
8.2.7 - Management of Wind Dispersal 8-39
8.2.8 - Ground-Water Protection Exemption for 8-41
Double-Liner Landfills
8.2.9 - Inspections 8-44
8.3 - Closure 8-50
8.3.1 - The Federal Requirement 8-50
8.3.2 - Guidance to Achieve the 264 Standard 8-51
8.3.3 - Guidance to Address the Application 8-53
Information Requirement
8.4 - Post-Closure 8-57
8.4.1 - The Federal Requirement 8-57
8.4.2 - Guidance to Achieve the 264 Standard 8-58
8.4.3 - Guidance to Address the Application 8-58
Information Requirement
8.5 - Special Requirements for Ignitable or 8-59
Reactive Wastes
8.5.1 - The Federal Requirement 8-59
8.5.2 - Guidance to Achieve the 264 Standard 8-59
8.5.3 - Guidance to Address the Application 8-60
Information Requirement
8 .6 - Special Requirements for Incompatible Wastes 8-61
8.6.1 - The Federal Requirement 8-61
8.6.2 - Guidance to Achieve the 264 Standard 8-61
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8.6.3 - Guidance to Address the Application 8-62
Information Requirement
8.7 - Special Requirements for Liquid Wastes 8-62
8.7.1 - The Federal Requirement 8-62
8.7.2 - Guidance to Achieve the 264 Standard 8-63
8.7.3 - Guidance to Address the Application 8-65
Information Requirement
8.8 - Special Requirements for Containers 8-66
8.8.1 - The Federal Requirement 8-66
8.8.2 - Guidance to Achieve the 264 Standard 8-67
8.8.3 - Guidance to Address the Application 8-67
Information Requirement
8.9 - Disposal of Small Containers in Overpacked Drums 8-68
(Lab Packs)
8.9.1 - The Federal Requirement 8-68
8.9.2 - Guidance to Achieve the 264 Standard 8-69
8.9.3 - Guidance to Address the Application 8-70
Information Requirement
8.10 - References 8-70
8.11 - Checklist 8-72
Section 9.0 - Ground-Water Protection 9-1
9.1 - Introduction 9-1
9.1.1 - Applicability 9-1
9.1.2 - Summary of the Regulations 9-2
9.1.3 - Permit Application Information Requirements 9-4
9.1.4 - Facilities Without Interim Status 9-5
Monitoring Data
9.2 - Summary of Interim Status Monitoring Data 9-6
9.2.1 - The Federal Requirement 9-6
9.2.2 - Guidance to Achieve the Part 264 Standard 9-6
9.2.3 - Guidance to Address the Application 9-7
Information Requirement
9.3 - Identification of Uppermost Aquifer and 9-24
Its Characteristics
9.3.1 - The Federal Requirement 9-24
9.3.2 - Guidance to Achieve the Part 264 Standard 9-24
9.3.3 - Guidance on Addressing the Application 9-25
Information Requirement
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9.4 - Waste Management Area, Point of Compliance, 9-31
and Well Locations
9.4.1 - The Federal Requirement 9-31
9.4.2 - Guidance to Achieve the Part 264 Standard 9-32
9.4.3 - Guidance to Address the Application 9-34
Information Requirement
9.5 - Description of any Ground-Water Contamination 9-39
9.5.1 - The Federal Requirement 9-39
9.5.2 - Guidance to Achieve the Part 264 Standard 9-40
9.5.3 - Guidance to Address the Application 9-41
Information Requirement
9.6 - Detection Monitoring Program 9-43
9.6.1 - The Federal Requirement 9-43
9.6.2 - Guidance to Achieve the Part 264 Standard 9-44
9.6.3 - Guidance to Address the Application 9-46
Information Requirement
9.7 - Compliance Monitoring Program 9-54
9.7.1 - The Federal Requirement 9-54
9.7.2 - Guidance to Achieve the Part 264 Standard 9-55
9.7.3 - Guidance to Address the Application 9-63
Information Requirement
9.8 - Corrective Action Program 9-69
9.8.1 - The Federal Requirement 9-69
9.8.2 - Guidance to Achieve the Part 264 9-70
Standard
9.8.3 - Guidance to Address the Application 9-75
Information Requirement
9.9 - References 9-78
Appendix A - RCRA Part A Permit Application Forms A-l
and Instructions
Appendix B - Cross-Reference of Part 122 Regulations B-l
to Part 270
Appendix C - List of Recommended Permit Application C-l
Attachments
Appendix D - Guide Specifications for Construction of D-l
Flexible Membrane Liners for Hazardous
Waste Disposal Facilities
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Figures
2-1 - Flow Diagram of the RCRA Permitting Process 2-8
3-1 - Illustration of Permitting and Regulatory 3-16
Terminology
3-2 - Concept of Existing Portions of Hazardous 3-28
Waste Management Units
3-3 - Determining Facility and Unit Type 3-33
3-4 - Subpart F and K Requirements for 3-34
Surface Impoundments
3-4a - Continuation 3-35
3-5 - Subpart F and L Requirements for Waste 3-36
Piles
3-6 - Subpart F and M Requirements for Land 3-37
Treatment
3-7 - Subpart F and M Requirements for Landfills 3-39
4-1 - Concept of 10-Year Permits 4-9
8-1 - Generalized Liner and Leachate Collection 8-24
System
9-1 - Basic Elements of Ground-Water Protection 9-3
Program
9-2 - Results of First Year's Ground-Water 9-9
Monitoring
9-3 - Results of Ground-Water Monitoring After 9-19
First Year
9-4 - Concept of Expanding Waste Management Area and 9-36
Compliance Points.
9-5 - Concept of Separate Waste Management Compliance 9-37
Points, and Monitoring Wells for Remote Areas
Within Same Permit Boundary
9-6 - Recommended Operational Approach - First Phase 9-38
Operations at Compliance Point
9-7 - Detection Monitoring Program Requirements 9-47
9-8 - Compliance Monitoring Program Requirements 9-56
9-9 - Corrective Action Program Requirements 9-72
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Tables
5-1 - Recommended Minimum Values of Factor of Safety 5-33
for Slope Stability Analyses
5-2 - Permit Application Checklist for Surface 5-73
Impoundments
6-1 - Permit Application Checklist for Waste Piles 6-76
7-1 - Land Treatment Permits 7-3
7-2 - Permit Application Content 7-5
7-3 - Typical Laboratory Tests for Assessing Degreda- 7-11
tion, Toxicity, Transformation, Volatility, and
Mobility of Hazardous Waste Constituents
7-4 - Format for Listing Wastes That will be Managed 7-15
in The Land Treatment Unit
7-5 - General Information to be Included in Field 7-21
Test Descriptions
7-6 - Format for Reporting Application, Rate, and 7-37
Capacity Limits
7-7 - Format for Identifying Limiting Constituents 7-39
7-8 - Example Waste Application Schedule 7-40
7-9 - Format for Reporting the Results of Soil Sampling 7-47
and Analysis
7-10 - Allowable Annual Cadmium Loading Rates 7-54
7-11 - Example Cadmium Loading Rate Table 7-59
7-12 - Permit Application Checklist for Land Treatment 7-73
8-1 - Permit Application Checklist for Landfills 8-74
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PREFACE TO THE FINAL DRAFT
This final draft of the Permit Applicants' Guidance Manual
for Hazardous Waste Land Treatment, Storage, and Disposal
Facilities provides permit applicants with detailed information
on what a RCRA Part B permit application should contain. It
presents recommended methods for collecting and presenting
information that responds to the application information
requirements in 40 CFR Part 270. Guidance is also provided
on facility designs that EPA believes satisfies the permitting
standards in Part 264 for surface impoundments, waste piles,
land treatment units, and landfills. This guidance is identical
to that provided in the (draft) RCRA Technical Guidance
Documents, which have been made available for public comment.
However, this guidance is not intended to mean that other
designs might not also satisfy the standards.
This manual and other EPA guidance and resource documents
do not supersede the regulations promulgated under RCRA and
published in the Code of Federal Regulations. They provide
guidance, interpretations, suggestions, and references to
additional information. Regulations will always take precedence
to these manuals.
This manual is identified as a Final Draft due to the
likely imminent reauthorization of RCRA by Congress. The
manual contains regulations and recommendations related to
regulations in effect in March 1984. Subsequent to
reauthorization, this manual will be revised.
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ACKNOWLEDGEMENTS
This manual was prepared by the Land Disposal Branch of
the Office of Solid Waste. The principal editor was Arthur Day,
Other EPA personnel providing major contributions were
Michael Flynn, Paul Cassidy, and Laurel Kasaoka.
Consultants played major roles in the preparation of the
manual. Gary L. Mitchell of SCS Engineers compiled comments
on the Draft version of the manual, incorporated them into
this Final Draft, and provided editing and production support.
The section on surface impoundments, waste piles, and
landfills were initially prepared by Joe Kulikowski and others
from Ertec, Inc. and Douglas Hazelwood and others with
A.T. Kearney, Inc. The land treatment section was initially
developed by Gordon Evans and others of K.W. Brown, Inc.
GCA, inc. and TRW, Inc. prepared the checklists. The diagrams
in Section 9.0 concerning ground-water protection were based
on concepts develope'd by David Hupe of Michael Baker, Inc.
Appendix D was prepared by Dr. Jean-Pierre Giroud.
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EXECUTIVE SUMMARY
Don't panic. This is a "user friendly" manual. It is
written for persons who must file applications with EPA for
Federal permits to operate facilities that treat, store, or
dispose of hazardous waste in surface impoundments, waste
piles, land treatment units, and landfills. Authorized
States that administer their own programs may have different
permitting procedures not covered in this manual.
The manual explains the EPA permitting process, the
facility standards, and the application information requirements,
It describes the level of detail needed in a permit application
to show how the facility design complies with specific standards,
Useful references to other EPA manuals and to the professional
engineering and hydrogeologic literature are provided.
The Introduction describes the overall organization of
the manual. Section 2.0 describes the EPA administrative
procedures. Section 3.0 reviews the permitting standards in
40 CFR Part 264. It shows how an applicant can decide which
standards apply to his own facility, and describes related
EPA technical guidance and resource documents.
Section 4.0 provides general guidance for the preparation
of a RCRA permit application. It includes suggested formats for
applications and information applicable to all facilities
covered in this manual.
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Sections 5.0 through 9.0 provide detailed guidance on
permit applications. One section is devoted to each type of
facility and a separate section to ground-water protection.
Guidance is based upon the permitting standards in Part 264,
information from the Preamble in the Federal Register, and the
RCRA Technical Guidance Documents. It includes guidance on
general designs that EPA believes satisfy the permitting standards.
Recommendations on how to address each application information
requirement from 40 CFR Part 270 are then presented, showing
the type of information and level of detail EPA needs. Applicants
should thoroughly review the section applicable to the type of
facility proposed and also review Section 9.0 concerning ground-water
protection prior to beginning preparation of a permit application.
Sections 5.0 through 8.0 contain checklists of all the
information requirements and associated permitting standards
that an applicant for a land treatment, storage, or disposal
facility may need to address, depending on facility type,
exclusions, and variances. These checklists can be used to
review the completeness of the application by both applicants
and EPA reviewers.
EPA encourages applicants to make thorough use of this
manual; it will help minimize the effort and time spent in filing
permit applications. Applicants are also encouraged to direct
questions not answered by this manual to EPA Regional Office
personnel.
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SECTION 1.0
INTRODUCTION
The U.S. Environmental Protection Agency (EPA) has issued
regulations to ensure the protection of human health and the
environment through the proper management of hazardous wastes
under Subtitle C of the Resource Conservation and Recovery Act
of 1976 (RCRA). These regulations require the owners and
operators of facilities that treat, store, or dispose of hazardous
wastes to obtain RCRA permits for their activities. The permit
application must contain sufficient information to assure EPA
that the facility design, operation, closure, and post-closure
care satisfy the permitting standards. This Guidance Manual is
intended to minimize the effort and time expended by persons
applying for RCRA permits.
This manual was written to help preparers and reviewers of
permit applications better understand the application infor-
mation requirements for facilities that treat, store, or dispose
of hazardous waste directly in or on the land. Such facilites
are classified under one of the following categories.
Surface Impoundment
Waste Pile
Land Treatment Unit
- Landfill
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Although not mandatory, the use of this Guidance Manual in
preparing a permit application should enable the applicant to
efficiently organize and present information needed by EPA to
evaluate the application in a knowledgeable and expeditious
manner. For a more detailed explanation of EPA objectives and
strategy to promote safe hazardous waste management practices,
the applicant is strongly urged to read the preamble to the 40
CFR Part 264 land disposal regulations published in the Federal
Register, Volume 47, No. 143, page 32274, on July 26, 1982.
The guidance in this manual is applicable to Federal
programs. States are encouraged to develop and administer their
own programs under RCRA section 3006. Approved State programs
may differ in substance, style, and procedure, thereby limiting
the utility of this manual in those States. Applicants should
consult their EPA Regional Administrator or State authority if
they are uncertain about the status of a particular State program.
The remainder of this Manual is organized as follows.
Section 2.0 - Administrative Procedures in the Permitting Process.
This section presents the administrative and
confidentiality procedures used by EPA in the RCRA
permitting process.
Section 3.0 - Permitting Standards and EPA Guidance and Technical
Guidance Manuals.
This section presents the general subject areas
covered under 40 CFR Part 264 and associated Part 270
regulations; methods to determine what standards
apply to a particular facility; RCRA relationship to
1-2
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other Federal statutes; and a description of documents
that may be useful to permit applicants.
Section 4.0 - General Guidance for Preparing a RCRA Land Disposal
Permit Application.
This section provides general guidance for the
preparation of a RCRA permit application. It includes
suggested format for applications and information
applicable to all facilities covered in this Manual.
Section 5.0 through 9.0 - Permit Application Guidance.
Individual sections providing detailed guidance on
permit applications related to:
- Surface Impoundments
- Waste Piles
- Land Treatment Units
- Landfills
- Ground-Water Protection
The format for elements of Sections 5.0 through 9.0
is as follows:
Statement of the Federal permitting requirement as it
appears in Part 270, and the corresponding Part 264
standard;
Guidance to achieve the Part 264 standard drawn from the
preamble to the Part 264 regulations published on July
26, 1982, and from the RCRA Technical Guidance Documents
and other guidance manuals supplementing these regula-
tions; and
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Detailed guidance to address the application information
requirement. This includes a step by step explanation
of what data should be presented for each information
requirement, and how these data should be presented.
List of references helpful in resolving technical and
administrative questions
Checklist of general and specific requirements for
permit applications. It is strongly recommended that
applicants use the checklists to insure that all
application requirements are met.
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SECTION 2.0
ADMINISTRATIVE PROCEDURES IN THE PERMITTING PROCESS
This section outlines the activities entailed in applying
for and obtaining a RCRA permit for a hazardous waste management
facility. An understanding of these procedures will enable
applicants to expedite the permitting process.
Most facilities that treat, store, or dispose of hazardous
waste on or in the land must obtain a RCRA permit. Facilities
subject to all the Part 264 and 270 requirements and discussed
in this manual are surface impoundments, waste piles, land treat-
ment units, and landfills. Other types of facilities are governed
by other regulations. These include storage and treatment in
tanks and containers and treatment by incineration. If your
situation involves only one of these other facilities, contact the
EPA Regional Office personnel for guidance regarding permits.
Further discussion of facility types and regulations is presented
in Section 3.0.
For the four types of facilities discussed in thi« manual,
the application for a RCRA permit consists of two parts, Part A
and Part B. Owners and operators of certain facilities (i.e.,
those in existence before November 19, 1980), were required to
submit Part A application by November 19, 1980, upon which they
automatically gained interim status that allows them to continue
to operate the facility until final administrative action is
taken on the Part B permit. In order to complete permit processing,
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owners or operators of facilities with interim status must submit
a Part B application after notification from EPA. The EPA
Regional Administrators are required to give at least six months
notice to owners and operators of existing, interim status,
facilities as to when the Part B application is due. Until the
final RCRA permit (Part B permit) is granted, compliance with
Part 265 regulations is required under the conditions of interim
status.
Owners and operators of new facilities must submit both
Part A and Part B at least 180 days before the planned initiation
of physical construction. Construction cannot commence until a
permit is issued.
2.1 COORDINATION WITH STATES
An applicant for a RCRA permit should be aware that the EPA
and the States generally share responsibilities for the admin-
istration of the RCRA permit program. Each State's role in the
permitting process varies according to the status of its authori-
zation to administer the Federal hazardous waste permit program.
Applicants should familiarize themselves with the State's per-
mitting process and be aware that EPA permit writers will be
communicating with the State Agency at appropriate stages in the
permit process.
2.2 SUBMITTING RCRA PART A PERMIT APPLICATIONS
A RCRA Part A permit application must be filed for new
facilities along with the Part B permit application. Information
to be included in the Part A application is described in §270.10(d)
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and §270.13. Forms used for Part A applications are included
in Appendix A. Instructions for completing the Part A
application are printed on the forms. The remainder of this
manual generally applies only to Part B applications.
2.3 SUBMITTING RCRA PART B PERMIT APPLICATIONS
Applicants should contact their EPA Regional Offices to
obtain the forms and other applicable information prior to com-
pleting the permit applications. These include:
- Part A application forms (see Section 4.0 and Appendix A)
- Copy of Part 264 and Part 270 regulations
- Notice of applicants' right to claim confidentiality
- Notice of right to question EPA Regional staff about
application requirements
- Names and phone numbers of appropriate contacts including
State authorities
- Information on the number of copies of the applications
required and location where application should be filed.
The EPA Regional Office may request submission of Part P of
the RCRA permit application from an existing interim status
facility, or such a facility may voluntarily submit Part B at any
time. The letter of request will generally include a list of the
items in Part B that pertain to the permit applicant's facility
type and the above information. This letter will include a due
date for the Part B permit application. Owners and operators of
interim status sites will be given at least six months from the
date of the letter to the application due date. It is important
that this due date be met. Failure to do so can lead to
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enforcement action by the Agency or to termination of interim
status through permit denial.
The Agency strongly recommends that the applicant contact
the EPA Regional Office in the early stages of preparing the
application to ensure a clear understanding of what information
is required. The Agency will schedule a combined inspection and
permit writer visit to the facility shortly after the Part B
application is requested. Consultants or staff responsible for
application preparation should participate in these joint
meetings and visits. These will be opportunities to discuss
application requirements and improvements necessary for the
facility to be permitted. Depending on the depth and complexity
of the issues, the EPA or the applicant may find it useful to
schedule conferences or periodic meetings. These preliminary
contacts can facilitate the permitting process by identifying
problems early and enabling the applicant to resolve them.
Applicants should pay particular attention to their status
(e.g., detection or compliance monitoring or corrective action)
under the ground-water protection standards at an early stage in
the permitting process. Applicants will be advised, at the time
of the combined inspection and permit writer visit, of the ground
water information required in the permit application. Applications
subsequently received which are lacking the necessary information
will be referred for enforcement. The Introduction to the Ground-
Water Protection section of Section 9.0 describes several important
ground-water considerations.
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2.4 CLAIMS OF CONFIDENTIALITY
At the time of submittal, applicants for a RCRA permit may
assert a claim of business confidentiality for proprietary
information included in the application. General EPA regulations
governing claims of confidentiality are found in Title 40 of the
Code of Federal Regulations (40 CFR), Part 2. Specific provi-
sions for claims of confidentiality submitted with permit appli-
cations are found in 40 CFR 270.12.
Under 40 CFR 2.201 (Definitions) "business information"
means "...any information which pertains to the interest of any
business, which was developed or acquired by that business, and
(except where the context otherwise requires) which is possessed
by EPA in recorded form".
"Reasons of business confidentiality" include "the concept
of trade secrecy and other related legal concepts which give (or
may give) a business the right to preserve the confidentiality
of business information and to limit its use or disclosure by
others in order that the business may obtain or retain business
advantages it derives from its rights in the information".
Applicants should limit their requests for confidential
treatment to such material that, if released, is likely to cause
substantial harm to the competitive position of their respective
companies. Claims of confidentiality should not be asserted for
information that is reasonably obtainable without the applicant's
consent (for example, standard engineering designs). A claim of
confidentiality for the entire permit application is likely
not justifiable and such claims may be rejected.
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Claims of confidentiality must be asserted when the permit
application is submitted. If no claim is asserted at that time,
the EPA may make the information available to the public without
further notice to the applicant.
Prior to releasing any information for which a claim of
confidentiality has been made, the Agency will give the applicant
an opportunity to substantiate its claim, and will then determine
whether the information warrants confidential treatment. If
considered confidential by the Agency, information will not be
released to the public under the Freedom of Information Act. To
assert a claim, the applicant must attach a cover sheet to the
information, or stamp or type a notice on each page of the infor-
mation, or otherwise identify the confidential portions of the
application. Words such as "trade secret", "confidential business
information", "proprietary", or "company confidential" should be
used. Such words of warning should be placed as hollow-letter
stamps across the center of each applicable page. The notice
should also state whether the applicant desires confidential
treatment only until a certain date or a certain event.
The use of loose-leaf binders for permit applications is
highly recommended. This format facilitates review and revision.
If the loose-leaf format is used, confidential materials should
be kept together in a separate binder(s), the cover of which is
so identified. To aid in review, complete cross-reference nota-
tion should be included in the non-confidential portions of the
applicaton to direct the reviewer to specific pages in the
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confidential binders. Likewise in the confidential binder(s),
notation should be made as to the portions of the application to
which each page or group of pages apply.
2.5 EPA'S REVIEW OF PART A AND PART B APPLICATIONS
When the EPA Regional Office receives a RCRA permit appli-
cation, it reviews the application for administrative and technical
completeness (see Figure 2-1). The completeness review takes 60
days for existing facilities and 30 days for new ones. If the
application is incomplete, the EPA will request the missing
information through a "Notice of Deficiency" (NOD) letter. This
letter details the information needed to complete the application
and specifies the date for submission of these data. The Agency
will issue a warning letter to accompany the NOD requiring
submission of the necessary information within a specified
additional period of time. If the applicant receives a Notice of
Deficiency and responds with additional information, each page of
this response should fully identify the portion of the original
application to which it applies. The checklists in Section 5.0
through 8.0 will be used for the completeness review. When the
EPA has received all the necessary information, it will notify the
applicant in writing that the application is complete.
The use of the loose-leaf format will aid in application
review. Likewise, drawings should be either 8 1/2" x 11" and
included in the binder(s) or standard size engineering drawings
should be submitted. Engineering drawings (30" x 42" or equiv-
alent) are preferred. Drawings should be identified by a unique
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REQUEST FOR RCRA
PART B FOR EXISTING
FACILITY
EPA REGIONAL
OFFICE RECEIVES
AND LOGS IN
APPLICATION
IF OMISSIONS
OR DEFICIENCIES
ARE NOTED ISSUE
NOTICE OF DEFICIENCY,
OTHERWISE APPLICANT
NOTIFIED APPLICATION
IS COMPLETE
ADMINISTRATIVE
COMPLETENESS
CHECK
TECHNICAL EVALUATION
IF APPLICATION
NEEDS CLARIFICATION
NOTIFY APPLICANT
PREPARATION OF
DRAFT PERMIT
ro
i
oo
STATEMENT OF BASIS
OR FACT SHEET
ADMINISTRATIVE
RECORD
PUBLIC NOTICE OF
DRAFT PERMIT, COMMENT
PERIOD. HEARING
NOTICE OPTIONAL
PUBLIC COMMENTS,
REQUESTS FOR PUBLIC
HEARING
NEW STATEMENT OF BASIS; FACT SHEET; OR DRAFT PERMIT
ADMINISTRATIVE
RECORD
POSSIBLE APPEALS
TO EPA
ADMINISTRATOR
CLOSE OF
COMMENT
PERIOD
(UNLESS
HEARING TO
BE HELD
PUBLIC NOTICE
OF HEARING;
EXTENSION OF
COMMENT PERIOD
DECISION
ON REQUEST
FOR HEARING
Figure 2-1. Flow diagram of the RCRA permitting process
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drawing or sheet number; that number should be used in the text
of the application when referring to the drawing.
The EPA then performs a technical review of the application
to determine whether the facility has satisfied the requirements
of the standards promulgated under Title 40 of the Code of Federal
Regulations (40 CFR), Part 264, and should be granted a RCRA
permit. A site inspection may be conducted during this technical
review process to verify the information contained in the appli-
cation. The technical review may generate the need for
clarification from the applicant because the completeness review
cannot identify and assess all detailed technical issues in the
short time allowed.
The Agency may choose to use State officials or a contractor
for technical expertise and assistance in reviewing permit appli-
cations or conducting on-site visits to verify information
pertinent to the issuance or denial of a RCRA permit. EPA
Headquarters has established Permit Assistance Teams composed of
policy and technical specialists to assist personnel in the EPA
Regional Offices. The purpose of these teams is to promote
national policy consistency in the permit review process. The
teams may be used to review permit applications.
2.6 DRAFT RCRA PERMITS AND PERMIT DENIALS
Upon completion of the technical review, the EPA Regional
Administrator tentatively decides whether to issue or deny a RCRA
permit. If the tentative decision is to issue the permit, the
EPA regional staff prepares a draft permit for public review.
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The draft RCRA permit specifies all the limitations, requirements,
and conditions the facility must meet. The Regional Office also
prepares a fact sheet or a statement of basis, which explains
in simple language each condition included in the draft permit
and the reasons for each condition.
When writing a RCRA permit, the EPA may specify a schedule
for compliance (§270.33) at the time of permit issuance. A
compliance schedule allows an existing facility to operate
while the permittee upgrades the operations to meet all the
regulatory requirements. In its decision regarding a schedule
for compliance, the Agency also considers such factors as
availability of any materials required to upgrade the facility,
construction time, and the time required to contract for such
services.
A permit may be denied for the following reasons.
- The facility cannot meet the requirements of the standards
set forth in 40 CFR 264.
- Activities at the facility would endanger human health
or the environment.
An applicant is believed to have not fully disclosed all
relevant facts in the application or during the RCRA
permit issuance process.
- An applicant has misrepresented relevant facts at any
time.
The application did not fully meet the requirements of
40 CFR 270 (e.g. did not have the signature(s) of both
the owner and the operator).
If the Regional Administrator tentatively decides to deny a
RCRA permit, a notice of intent to deny a permit is prepared.
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This notice is considered a type of draft permit and follows the
same procedures as any draft permit. These procedures include
preparation of a statement of basis or fact sheet containing
reasons supporting the tentative decision to deny the permit,
public notices of the denial, acceptance of comments, a possible
hearing, preparation of a final decision, and possible receipt of
a request for appeal.
2.7 PUBLIC NOTICE, COMMENTS, INFORMAL PUBLIC HEARINGS, PANEL
HEARINGS
All draft RCRA permits are subject to public notice, public
comments, and public hearing. Public notice provides interested
persons a minimum of 45 days to comment on the draft permit. If
written opposition to the Agency's intent to issue a permit and
a request for a hearing are received during the comment period,
a public hearing may be held. Notification of the hearing is
issued at least 30 days prior to the scheduled date, and the public
comment period is extended until the close of the public hearing.
2.8 FINAL PERMITS
After the close of the public comment period (which includes
the public hearing period), the Regional Office either prepares
and issues a final RCRA permit or denies the permit application.
In either case, the applicant and those submitting questions and
those requesting notification will be so notified, including
information regarding appeal procedures. Final RCRA permits
become effective 30 days after the date of the public notice of
decision to issue a final permit unless a later date is specified
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in the permit or the conditions of §124.15(b) are met. At the
time the final RCRA permit is issued, the Regional Office also
issues a response to any significant public comments received
and indicates any provisions of the draft permit that have been
changed and the reasons for the changes. The response to comments
becomes part of the administrative record.
2.9 APPEAL TO THE EPA ADMINISTRATOR
Persons who submitted comments on the draft RCRA permit or
participated in any public hearing are allowed 30 days after the
final permit decision to file a notice of appeal and a petition
for review with the EPA Administrator in Washington, D.C., who will
review and then grant or deny the petition within a reasonable
time. If the Administrator decides to conduct a review, the
parties are given the opportunity to file briefs in support of
their positions. Within the 30 day period, the Administrator
may, on his/her own motion, decide to review the decision to
grant or deny a hearing. The Administrator then notifies the
parties and schedules a hearing. On review, the Administrator
has several options regarding the final decision. It may be
summarily affirmed without opinion, modified, set aside, or
remanded for further proceedings. This petition for review
is a prerequisite for judicial review of the Administrator's
final decision. Details of appeals of RCRA permit are found in
§124.19.
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SECTION 3.0
PERMITTING STANDARDS AND EPA GUIDANCE AND TECHNICAL MANUALS
This section discusses the facility and permitting standards
related to land-based hazardous waste treatment, storage, and
disposal facilities. It also contains lists and descriptions of
documents developed by EPA to assist in the design and operation
of such facilities and in the preparation of permit applications.
Subsections are as follows:
- Section 3.1 provides a general look at Part 264 and 270
regulations.
- Section 3.2 provides assistance in determining if the
wastes involved are hazardous and if the facility con-
templated is land-based and thus included in this manual.
- Section 3.3 defines the types of land-based units assisting
the applicant to identify the specific kind of unit(s)
planned and the related facility and permit requirements.
- Section 3.4 provides titles, descriptions and sources of
EPA documents helpful to permit applicants.
3.1 OVERVIEW OF PART 264 AND 270 REGULATIONS
3.1.1 General Applicability and Format
Subtitle C of the Resource Conservation and Recovery Act
(RCRA) requires the Environmental Protection Agency (EPA) to
establish a Federal hazardous waste management program. This
program must ensure that hazardous wastes are handled safely from
generation until final disposition.
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Regulations related to hazardous wastes are initially
published in the Federal Register. Subsequent references in this
manual to the Federal Register will be of the form 47 FR 32353
which is Volume 47 of the Federal Register, page 32353. Publica-
tion date may also be shown. Federal Registers are available at
law libraries, many major libraries, and at EPA Regional Offices.
They may also be purchased from the Superintendent of Documents,
U.S. Government Printing Office, Washington, D.C. (202) 783-3238.
EPA has issued a series of hazardous waste regulations
under Subtitle C of RCRA that are published in 40 Code of Federal
Regulations (CFR) Parts 260 to 271 and 122 to 124. Subsequent
reference in this Manual to specific parts of 40 CFR will be of
the form Part xxx. Reference to particular sections within a part
will be shown as §264.19, which is Section 19 of Part 264. The
applicant should have copies of those parts applicable to his
situation. Copies are available at EPA Regional Offices.
The parts of 40 CFR related to hazardous wastes are:
Part 260 - Hazardous Waste Management System: General
Part 261 - Identification and Listing of Hazardous Wastes
Part 262 - Standards Applicable to Generators of Hazardous
Wastes.
Part 263 - Standards Applicable to Transporters of Hazardous
Wastes.
Part 264 - Standards for Owners and Operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities.
Part 265 - Interim Status Standards for Owners and Operators
of Hazardous Waste Treatment, Storage,and Disposal
Facilities.
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Part 266 - Reserved.
Part 267 - Interim Standards for Owners and Operators of New
Hazardous Waste Land Disposal Facilities.
Part 270 - EPA Administered Permit Programs: the National
Pollutant Discharge Elimination System; the
Hazardous Waste Permit Program; and the Under-
ground Injection Control Program.
Part 271 - State Program Requirements.
Part 124 - Procedures for Decision-making.
Parts 264 and 265 contain standards applicable to owners
and operators of all facilities (unless specifically exempted)
that treat, store, or dispose of hazardous wastes. The Part
264 standards are implemented through permits issued by
authorized States or the EPA in accordance with Part 270 and
Part 124 regulations.
Until comprehensive standards could be established in
Part 264, owners and operators of existing hazardous waste
treatment, storage, and disposal facilities were allowed to
apply for interim status under the requirements of Part 265.
Permittees of such facilities are treated as having been issued
a permit, until an authorized State or the EPA takes final
administrative action on their permit applications using the
permitting standards under Part 264. The Part 264 standards and
the corresponding permitting procedures of Part 270 apply to
both new and existing hazardous waste management facilities of
all types, except as subsequently noted.
The Part 264 standards are made site-specific through the
permit. The permit specifies the designs, operating procedures,
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hazardous constituent concentrations, and other factors that allow
the facility to meet the Part 264 standards. With reference to a
Federally-issued permit, the permit also provides a shield for the
permittee. Compliance with the permit requirements is compliance
with the Federal laws associated with hazardous waste management
at the permitted facility. However, EPA may modify a permit if
conditions at the facility change after the permit is issued or as
otherwise noted in §270.41.
3.1.2 General Facility Standards
Part 264 is organized into several Subparts that deal with
specific subjects or areas. This manual covers those Subparts
that apply to hazardous waste land treatment, storage, and
disposal facilities (i.e., surface impoundments, waste piles,
land treatment units, and landfills).
Subparts A through E, G and H of Part 264 are described as
the General Facility Standards, and are applicable to all
hazardous waste management facilities.
- Subpart A - Presents the purpose, scope, and applicability
(including exemptions) of Part 264.
Subpart B - Delineates general procedures for facility
operation, identification number, mandatory
notice, waste analyses, location, security,
inspections, and personnel training.
Subpart C - Outlines the basic measures needed to prevent
any unplanned release of hazardous wastes
from the facility.
Subpart D - Calls for preparation of a contingency plan
with steps to be taken in an emergency.
Subpart E - Specifies manifest, recordkeeping, and
reporting requirements.
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Subpart G - Establishes closure and post-closure
performance standards along with requirements
for drawing up closure and post-closure
care plans.
Subpart H - Requires measures to ensure financial
responsiblity for the life of the facility,
including the post-closure care period.
The remaining Subparts of Part 264 contain standards for
specific classes of facilities.
The EPA permitting process must include attention to
§270.3 which concern consistency with other Federal laws.
The following statutes are listed.
- Wild and Scenic Rivers Act
- National Historic Preservation Act of 1966
- Endangered Species Act
- Coastal Zone Management Act
- Fish and Wildlife Coordination Act
3.1.3 Ground-Water Protection
Ground-water protection has been one of EPA's central
concerns in devising a regulatory strategy for hazardous waste
land storage and disposal. The strategy developed by EPA for
ground-water protection at land treatment, storage, and
disposal facilities has two basic elements described in the
preamble of 47 FR 32284. One element is a liquids management
strategy for the disposal units at the facility that is
intended to minimize leachate generation in the waste
management units and to remove leachate from the waste
management units before it enters the subsurface environment.
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This is the first line of defense in the sense that it seeks
to prevent ground-water contamination by controlling the
source of the contamination. Performance standards for
implementing this liquids management strategy are delin-
eated for each type of land treatment, storage, and disposal
unit under Subparts K-N of Part 264. The other element of
the general strategy is a ground-water monitoring and
response program that is designed to remove leachate from
the ground water if it is detected. The monitoring and
response program serves as a backup to the liquids management
strategy. Performance standards for implementing the monitoring
and response program are found in Subpart F of Part 264.
Subpart F establishes a three-stage program to detect,
evaluate, and, if necessary, correct ground-water contamination
caused by a waste management unit. The first stage is a
detection monitoring program requiring the installation of
wells (both up-and downgradient of the unit) to monitor
the ground water for parameters that would indicate whether
leachate is migrating from the unit. Data collected during
a year of monitoring at the upgradient well(s) is used to
determine the background level of constituents. Subsequent
monitoring data at downgradient wells are then compared
statistically to this background data of indicator parameters
to ascertain whether contamination is present. If contamination
is detected, analyses for all of the hazardous waste constituents
on the list in Appendix VIII of Part 261 is required to
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identify those present in the ground water and to help
establish concentration limits that then serve as part of
the ground-water protection standard for the facility.
Once hazardous constituents are detected and their
concentration limits set, the second stage, a compliance
monitoring program is initiated. The purpose of this program
is to monitor for the possibility that the concentrations of
hazardous constituents may exceed the established concentration
limits at the downgradient wells. For facilities seeking a
permit in areas where ground water is already contaminated
with hazardous constituents, this compliance monitoring
program (or a corrective action program) would be used initially,
instead of a detection monitoring program. The standard for
satisfactory ground-water protection in these cases is generally
"no increase above background level". Thus, a facility
owner or operator would not be required to clean up contamination
for which he was not responsible, but his facility must not
contribute further to the level of ground-water contamination.
Alternate concentration limits (above background level)
for a given hazardous constituent may be justified under
some circumstances. Applicants desiring to establish
alternative concentration limits for their facilities must
fully justify the requested alternate limit.
Permitted concentrations limits may exceed background
levels for 14 specific hazardous constituents without specific
justification. These constituents and their respective maximum
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concentration levels (MCLs) are listed in Table 1 of S264.94.
Permit applications must include a request for these levels if
they are desired in lieu of background levels.
When the ground-water protection standard for a unit is
violated, the third stage, a corrective action program, is ini-
tiated. This program must be designed to either remove waste
constituents from the ground water, or treat (detoxify) them in
place. Corrective action continues until compliance with the
standard for that unit is achieved.
Subpart F of Part 264 applies to new and existing
regulated units. A "regulated unit" is defined in §264.90(a)
as any waste management unit (surface impoundment, waste
pile, land treatment unit, or landfill) that receives hazardous
waste after January 26, 1983, the effective date of this
regulation. Waste management units that were receiving
hazardous waste prior to this date, but that have not and
will not receive any additional hazardous waste since January
26, 1983, are not required to meet the ground-water standards
established in Subpart F. Some exclusions to Subpart F
are provided for particular unit types with certain design
features. Details of these features and a more complete discus-
sion of ground-water protection are discussed in Section 9.0.
3.1.4 Specific Facility Standards
The primary element in EPA's regulatory strategy is to
minimize migration of hazardous waste constituents from land
management units into the environment. To a great extent, this
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can be accomplished by controlling liquids. The principal
technical requirements to control liquids in each type of land
management unit have been established under Subparts K-N of Part
264. As discussed in the preamble, 47 £R 32284, there are two
avenues for controlling liquids. One is to minimize leachate
generation by keeping liquids out of the unit, and the other is
to prevent any liquids present in the unit from escaping into the
surrounding environment. Technical requirements vary depending on
the unit type, but they fall into a few general categories as
noted in the preamble to (47 FR 32284). To avoid the generation
of leachate, the owner or operator of some types of units will be
required to control run-on to the unit, to substantially restrict
the placement of liquid waste or waste containing free liquids, or
to place a cap on the unit at closure. To prevent the migration
of liquids into the environment, the owner or operator may be
required to place underliners below the waste, to install leachate
collection and removal systems, to assure the structural integrity
of any dikes used at the unit, to control run-off from the unit,
to treat hazardous constituents, or to remove free liquids at
closure. Specific technical performance standards for controlling
liquids and the design and operating procedures capable of meeting
these standards for each unit type are discussed in Sections 5.0
through 8.0 of this manual.
3.1.5 Permit Application Regulations
Procedures for issuing and modifying hazardous waste permits
are contained in Parts 270 and 124. These procedures apply to
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permitting hazardous waste management facilities covered by the
Part 264 technical standards. Part 270 specifies a two-part
hazardous waste permit application, Part A and Part B. Forms for
a Part A permit application are shown in Appendix A. A Part B
permit application is more complex, detailed, and facility-
specific. Development of a standard format for the Part B appli-
cation is difficult. This manual provides an acceptable Part B
outline format for land treatment, storage, and disposal facility
applications. EPA technical resource and guidance manuals are
available that present permit application formats for hazardous
waste management practices other than land treatment, storage, and
disposal.
Part 270 describes the EPA's hazardous waste permitting
program. It is a renumbering of the program described previously
in Part 122. Part 270 was introduced in 48 JFR 14228. A cross-
reference from Part 122 section numbers to the Part 270 numbers is
included in Appendix B.
The permitting procedures in Parts 270 and 124 allow for
changes to permits. As discussed in the preamble, 47 FR 32282, the
ground-water protection program contains several types of require-
ments that may need to be specified or modified after the permit
has been issued. In these cases, the Part 124 procedures will be
used to modify the permit.
There are exceptions to the Part 270 and Part 264 requirements
The applicant should be cautious to not include more information
than is needed. For example, existing portions of existing units
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do not require liners. Thus applications need not address these
situations. To aid in this area, a matrix is included in each
subsequent section identifying required and optional inclusions
for permit applications. Separate matrices are provided for
surface impoundments, waste piles, land treatment units, and
landfills.
3.2 DETERMINING WHICH FACILITY STANDARDS APPLY
This section provides tests that the applicant can use to
determine the applicability of this manual to his particular
situation. The first test is the determination of whether or not
the wastes involved are hazardous. If not, the wastes are not
subject to RCRA Subtitle C. Rather, facilities at which these
non-hazardous solid wastes are disposed are subject to applicable
standards under RCRA Subtitle D.
If the wastes are hazardous, the applicant must confirm that
the anticipated method(s) of waste management are land-based.
Definitions are included for this assssment. If the method is
land-based, this manual applies, if not, other publications will
be helpful.
3.2.1 Hazardous Waste Confirmation
The first step in determining which RCRA standards apply to
a particular facility is a confirmation that the facility handles
"hazardous waste" (and is thus subject to the RCRA Subtitle C
standards). The applicant should review the definition of a
hazardous waste provided in §261.3. Generally, a waste is a
hazardous waste if it is listed (or contains a waste that is
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listed) in Part 261, Subpart D or if it exhibits any of the
characteristics of a hazardous waste described in Part 261,
Subpart C. Certain solid wastes identified in §261.4(b), however,
are specifically excluded from regulation as hazardous wastes.
The flow chart below will assist in determining if a solid
waste is hazardous.
Is the solid waste excluded
from regulation under
§261.4(b)?
NO
Is the solid waste listed In
Part 261, Subpart D, or Is It
a mixture that contains a
waste listed 1n Subpart D?
I
YES
Has the waste or mixture been
excluded from the lists In
Subpart D or §261.3 In accord-
ance with '§§260.20 and 260.22?
T
NO
i
THE WASTE IS A
HAZARDOUS WASTE
YES
NO
YES
1
Does the waste exhibit any
of the characteristics
specified 1n Part 261,
Subpart C?
YES
NO
,
THE WASTE IS SUBJECT TO
CONTROL UNDER RCRA SUB-
TITLE 0 (1f land disposed)
Moreover, certain hazardous wastes are subject to special
requirements as defined in §261.5, §261.6, and §261.7. These
sections apply to hazardous wastes that are (1) generated by small
quantity generators, (2) used, reused, recycled or reclaimed, or
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(3) present only as residues in empty containers, respectively.
The applicant should consult these sections if he believes that
the hazardous waste handled may be subject to these special
requirements.
It is important to point out that leachate from a hazardous
waste management unit is assumed to be a hazardous waste under
§261.3(c)(2) unless the permittee proves otherwise. Precipita-
tion run-off from a hazardous waste management unit is not assumed
to be hazardous; however, if the run-off meets the criteria of a
hazardous waste defined in Part 261, or has mixed with leachate
it must be handled as a hazardous waste.
3.2.2 Determining if the Facility is a Land Treatment,Storage
or Disposal Facility Subject to All the Part 264 and Part
270 Requirements
3.2.2.1 General Applicability of Parts 264 and 270 —
The applicant should confirm that the facility is not excluded
from regulation under Part 264 or Part 270. Part 264 is applicable
to owners and operators of all (existing and new) facilities that
treat, store, or dispose of hazardous waste, except as specifically
exempted in Part 264 or Part 261. The Part 261 exemptions are dis-
cussed above (see Section 3.1). Section 264.1 provides several
exemptions that are applicable to land treatment, storage or
disposal facilities. These include special exemptions for (1)
owners or operators of publically-owned treatment works [§264.1
(e)], (2) persons who treat, store, or dispose of hazardous waste
in an "authorized" State [§264. l(f)], (3) owners or operators
handling hazardous wastes excluded under $261.5 and §261.6
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[§264.1 (g)], (4) generators accumulating waste in tanks or
containers on site for 90 days or less in compliance with §264.34
[§264.Kg)], and (5) farmers disposing of waste pesticides from
their own use in compliance with §262.51 [§264.Kg)]. Any applicant
who believes the facility may qualify for any of the above exemptions,
or any of the other exemptions listed in §264.1, should refer to
the applicable Part 264 section or contact the Regional Office.
3.2.2.2 Facility Type Determination —
After it is confirmed that the handled waste is hazardous
the applicant should determine if the facility is a land treatment,
storage or disposal facility. A land treatment, storage or
disposal facility is a facility containing one or more units in
which hazardous waste is placed in or on the land for the purpose
of treatment, or storage, or disposal, and which is supported by or
constructed primarily of earthen materials. Land-based facilities
may (and probably will) include some synthetic materials such as
liners and leachate collection pipes. These facilities may include
one or more of the following units: surface impoundments, waste
piles, land treatment units, landfills, and underground injection
wells. Although each of these units differ in its objective,
design, and operation, each utilizes the land as an integral part
of unit design and/or operation. For example, the land forms the
basic structural support for landfills, surface impoundments,
waste piles, and underground injection wells. In land treatment
units, the land provides not only the design components, but also
comprises the treatment capability of the system.
3-14
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Certain land treatment, storage, or disposal facilities are
also exempt from the Part 270 permitting requirements. These
exemptions are defined in §270.1.
Tanks (above or below ground), containers, incinerators,
and hazardous wastewater treatment systems are not considered
to be land treatment, storage or disposal units. Unlike the above
units, these are constructed primarily of non-earthen materials
which provide structural support. In addition, hazardous waste
is not placed in or on the land.
3.2.2.3 Relationship to Interim Status Standards —
Section 264.3 states that a facility owner or operator who
has fully complied with the requirements for interim status
(i.e., an existing facility covered under the Interim Status
Standards specified in §270.71 and Part 265) must comply with
the regulations specified in Part 265 in lieu of the regulations
in Part 264, until final administrative disposition of his permit
application is made. Therefore interim status facilities will
continue to follow the Part 265 regulations until they are issued
a Part 264 permit.
3.2.3 Terminology Associated with Facilities
Terminology used in this manual is generally consistent with
that used in Parts 264 and 270. Hazardous waste management
facilities include a waste management area(s) and areas not
directly related to waste management such as buffer areas, offices,
and equipment sheds. The following terms are illustrated in
Figure 3-1.
3-15
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U)
cr>
UPGRADIENT MONITORING WELLS
LIMIT OF WASTE MANAGEMENT AREA
PERMIT APPLIES TO AREA
f WITHIN FACILITY BOUNDARY
EQUIP. SHED
DOWNGRADIENT MONITORING WELLS
EXISTING
LANDFILL
CELL +2
'EXISTING
SURFACE
IMPOUNDMENT *1
EXISTING
LANDFILL
CELL *3
EXISTING
SURFACE
IMPOUNDMENT
+ 2
POINT OF COMPLIANCE ' //////
(EXTENDS FROM SURFACE TO TOP
OF UPPERMOST AQUIFER)
c / y/////
GENERALIZED HAZARDOUS WASTE MANAGEMENT FACILITY WITH SIX~UNITS (NO SCALE)
-------
The "waste management area" is described by the collection
of "regulated units" at the facility. A regulated unit is any
"waste management unit" that has or will receive hazardous wastes
after January 26, 1983 (the effective date of the Part 264 Land
Disposal Permitting Standards). A waste management unit is
generally synonymous with a surface impoundment, waste pile, land
treatment unit, or landfill cell. It is a contiguous area of
land on or in which waste is placed. Landfills may present an
exception to this general rule. A landfill can be designed as a
collection of separately lined trenches with each individual
trench considered to be a separate waste management unit. A
waste management unit can be a regulated unit even though it
contains predominantly non-hazardous waste or hazardous waste
which was disposed prior to January 26, 1983.
The waste management area is made up of one or more waste
management units that have received hazardous wastes after
January 26, 1983 (i.e., regulated units). The waste management
area is the area on which waste will be placed during the active
life of the regulated unit. It includes any horizontal space
taken up by barriers, such as dikes, designed to contain waste.
Where there are more than one regulatd units, the waste management
area is described by an imaginary line circumscribing these
regulated units.
The "point of compliance" is a vertical surface located at
the hydraulically downgradient limit of the waste management area,
extending from the Earth's surface down into the uppermost aquifer,
3-17
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The point of compliance is, in fact, a set of points (or surface).
It is the location along which the Ground Water Protection Standard
(see §264.92) must be met, and at which detection monitoring
wells are located. The Regional Administrator will specify the
location of the point of compliance in the permit after evaluation
of the description of the waste management area and the nature of the
hydrogeology of the site.
3.3 UNIT TYPES AND APPLICABLE STANDARDS
3.3.1 Types of Units
Once the applicant has determined that the proposed facility
is a hazardous waste land treatment, storage, or disposal facility
that is subject to the Part 264 and 270 standards, he should
determine exactly what type of unit(s) is present at the facility.
This determination is necessary in order to evaluate which specific
Part 264 and 270 requirements apply, and to clearly identify the
units to be included in the permit application.
The first step is the determination of whether the unit will
be used for treatment, storage, or disposal. Treatment and storage
units are considered to be temporary. After such units have served
the purpose for which they were constructed, any remaining hazardous
waste, liner or other contaminated material must either be decontam-
inated or removed and disposed at a permitted hazardous waste
disposal site. If a permittee cannot decontaminate or remove
hazardous wastes from a treatment or storage unit, the unit must
be managed as a disposal unit and eventually closed as such in
accordance with the applicable regulations.
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EPA can issue or deny a Part B permit to one or more units
at an existing facility without affecting the interim status of
any remaining units for which a final permit has not been issued
or denied. EPA will normally permit all the hazardous waste
units at a facility simultaneously, but there may be circumstances
under which this would be impossible or undesirable. Section
270.41(a)(5) provides that any permit issued to a facility for
less than all of the units at the facility may be modified to
include conditions applicable to units that are permitted later.
The five common land treatment, storage or disposal unit
types identified above include surface impoundments, waste piles,
land treatment units, underground injection wells, and landfills.
Surface impoundments may be further divided into three types:
treatment, storage, and disposal. The characteristics of each
of these common unit types as well as certain variants are discussed
below.
3.3.1.1 Surface Impoundment
A surface impoundment is defined in §260.10 as "a facility or
part of a facility which is a natural topographic depression, man-
made excavation, or diked area formed primarily of earthen materials
(although it may be lined with man-made materials), which is
designed to hold an accumulation of liquid wastes or wastes
containing free liquid, and which is not an injection well.
Examples of surface impoundments are holding, storage, settling,
and aeration pits, ponds, and lagoons." The Agency interprets
this definition to mean that a surface impoundment will normally
3-19
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have a fluid surface, and will contain non-containerized bulk
liquids.
Some basic requirements for surface impoundments are: a
liner system; a design that prevents overtopping; and dikes that
are designed, constructed, and maintained to prevent massive
failure.
A disposal surface impoundment is an impoundment in which
hazardous wastes or residues will remain after closure, while a
storage impoundment is one in which hazardous wastes and residues
are held for a temporary period and removed at closure. A treatment
surface impoundment is one in which activity has taken place to
modify the waste physically or chemically to render it less
toxic, less mobile, or otherwise less hazardous (for purposes of
regulation). It may be classified as either a storage (temporary)
or a disposal (permanent) unit. According to the Part 264 standards,
permittees of surface impoundments must, at closure, either
remove or decontaminate all waste residues and soils (i.e., for
storage impoundments), or solidify all remaining wastes and
apply a final cover (i.e., for disposal impoundments).
3.3.1.3 Land Treatment Unit —
A land treatment unit is defined §260.10 as "a facility or
part of a facility at which hazardous waste is applied onto or
incorporated into the soil surface". As provided in Subpart M,
Part 264, a waste must not be land treated unless the hazardous
constituents in the waste can be degraded, transformed or immobilized
in a treatment zone located above the ground-water table.
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Therefore, treatment of hazardous constituents within the treatment
zone must be the primary focus of a land treatment unit. Units
designed primarily for the purpose of dewatering without treatment
are not considered land treatment units; such units should be
considered surface impoundments and evaluated as such.
In addition, land treatment units are dissimilar to other
land disposal units in that they are not designed and operated to
minimize liquid release to ground water (e.g., through the use of
liners). On the contrary, they are open systems that allow
liquids to move out of the unit. Control of the moisture content
within the treatment zone is essential to maintain adequate
treatment. Units for which the design and operation do not allow
for this may be more appropriately evaluated as surface impoundments
3.3.1.3 Waste Piles —
A waste pile is defined in §260.10 as "any non-containerized
accumulation of solid, nonflowing hazardous waste that is used
for treatment or storage." Waste piles may not be used to
intentionally dispose of wastes. If the permittee of a pile
wishes to dispose of wastes, he must apply for a landfill permit
and manage the pile as a landfill. Waste piles are generally
small, and many are in buildings or maintained outside on concrete
or other pads. They are frequently used to accumulate waste
before shipment, treatment, or disposal, and are typically composed
of a single, dry material. The basic requirements (in the Part
264 regulations) for waste piles are: (1) a liner to prevent
migration of wastes out of the pile during the pile's active
3-21
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life (with an exemption for existing portions); (2) leachate
collection and removal; (3) control of run-on and run-off; and
(4) removal of wastes at closure.
3.3.1.4 Underground Injection Unit —
Underground injection is defined in §260.10 as "the subsurface
emplacement of fluids through a bored, drilled, or driven well,
or through a dug well, where the depth of the dug well is greater
than the largest surface dimension." Injection well means a
well into which fluids are injected. Septic tanks or cesspools
used to dispose of hazardous waste have been specifically included
in the definition of injection well (See §144.1).
Underground injection wells are regulated under both
RCRA and the Safe Drinking Water Act (through the Underground
Injection Control (UIC) Program). EPA intends to continue
the RCRA Part 267 requirements and the Part 265 interim
status standards for injection wells only until each State
implements its own UIC program or one is implemented for it by
EPA under the Safe Drinking Water Act. Underground injection
wells are not regulated under Part 264. Thus, they will not
be addressed in this manual.
3.3.1.5 Landfill —
A landfill is defined in §260.10 as "a disposal facility or
part of a facility where hazardous waste is placed in or on land
and which is not a land treatment unit, surface impoundment, or
an injection well". Landfills can be readily differentiated
from land treatment units, waste piles and injection wells using
3-22
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the descriptions provided above. However, differentiating between
landfills and surface impoundments may be difficult in certain
cases. Although surface impoundments are designed intentionally
to hold liquid wastes, landfills may also accept bulk liquids
under certain conditions. Section 264.314 currently states that
bulk or non-containerized liquid waste or waste containing
free liquids must not be placed in a landfill unless: (1) the
landfill has a liner and leachate collection and removal system
that meet the requirements of §264.301(a), or (2) before disposal,
the liquid waste is solidified. Therefore, distinguishing between
a landfill and surface impoundment based on types of waste may
be difficult in certain cases.
However, a determination can be made based on design
distinctions. First, new (or new portions of) landfills must
have leachate collection and removal systems. This requirement
does not apply to surface impoundments, or to existing portions
of a landfill. Second, the liner requirements differ somewhat
for certain types of new (or new portions of) surface impoundments
and landfills. (The liner requirements do not apply to existing
portions of surface impoundments and landfills). Disposal units
(all landfills and designated surface impoundments) where wastes
remain at closure must have impermeable (no migration of waste
constituents into or through the liner material) liners. Given
the state of current liner technology, synthetic liners are the
only common type that qualify as impermeable in the evaluation
of permit applications. Storage surface impoundments where
3-23
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wastes (including contaminated liners) are removed at closure
may use liner materials that allow waste constituents to migrate
into, but not through, the liner itself. Clays or compacted
soils will often meet this requirement. New (and new portions
of) landfills must comply with the leachate collection and removal
standard which requires that the system be designed to achieve a
maximum one-foot head of fluid above the liner. Such units
would not have a fluid surface.
Differentiating between an existing portion of a landfill
and an existing portion of a surface impoundment may, in rare
circumstances, be difficult because such portions are exempt
from both the liner and leachate collection and removal system
requirements. If uncertain, the applicant should consult the EPA
Regional Office in making this classification decision.
3.3.1.6 Seepage Facilities
The new Part 264 standards do not incorporate the "seepage
facilities" concept for which standards were proposed (but never
promulgated) on February 5, 1981 (46 FR 11216). Seepage facilities
are lagoons that are designed intentionally to leak. Depending
upon design, they may also be considered as underground injection
units or land treatment units. EPA has concluded that land
disposal facilities should be designed not to leak at all during
their active lives, except in rare cases (see §264.221(b)) .
Therefore, impoundments must be lined in accordance with these
standards, and new and existing land treatment units must prevent
release of hazardous constituents by treating them within the
3-24
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treatment zone. Thus, new and existing seepage facilities
(other than existing portions of surface impoundments that
may comply with the Subpart F ground-water protection
requirements and other applicable requirements) cannot be
permitted under these regulations.
3.3.1.7 Undefined Unit Types —
It is possible that some hazardous waste land treatment,
storage or disposal practice is currently used, or may be
developed in the future, that does not fit the description
of any of the above units. EPA is considering promulgating
regulations in a separate Subpart to address waste management
units that are covered generally, but do not fit precisely
into any of the existing categories. Such regulations will
probably include general environmental performance standards
similar to those contained in §267.10.
3.3.1.8 Monofills
Monofills are generally considered to be landfills,
surface impoundments, or waste piles used to treat, store or
dispose of one or more of a small group of inorganic wastes.
The Agency has not developed a formal definition of monofills.
Additional action regarding monofills depends on the content
of RCRA reauthorization legislation. Any regulations associated
with monofills should not be anticipated until four years
subsequent to RCRA reauthorization.
3-25
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3.3.2 Standards Applicable to Specific Unit Types
3.3.2.1 Important Definitions: "Existing" and "New"
Hazardous Waste Management Facilities, "Existing
Portion", "Regulated Unit" —
There are several definitions that will be important in
determining which standards are applicable to a specific unit.
These include "existing" and "new" hazardous waste management
facilities, "existing portion" of an existing unit, and "regulated
unit". The applicant should evaluate whether the facility contains
existing or new units, whether the units within the facility are
"regulated units", and if the existing units contain "existing
portions".
An existing hazardous waste management facility means a
facility which was in operation or for which construction commenced
on or before November 19, 1980. A facility commenced construction
on or before November 19, 1980, if: (1) the owner or operator
obtained the Federal, State, and local approvals or permits necessary
to begin physical construction by that date; and (2) a continuous
on-site, physical construction program was begun by that date,
or the owner or operator entered into contractual obligations,
which cannot be cancelled or modified without substantial loss,
for physical construction of the facility to be completed within a
reasonable time. Any facilities that do not meet these criteria
for existing facilities are considered new facilities. (Existing
facilities must comply with the Interim Status Standards (Part
265) while they await issuance of the Part 264 Permit.) Although
the Part 264 standards apply to both new and existing facilities,
3-26
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some of the information requirements provided in Part 270
differentiate between new and existing facilities.
An existing facility may contain existing and new units. A
unit is an identifiable area in which only one type of land-based
hazardous waste management takes place (e.g., an individual surface
impoundment or a trench at a landfill) . An existing unit is one
which is covered by the Interim Status requirements (see §265.1
and RCRA §3005(e) .
The applicant should determine if any of the existing waste
management units within the facility contain "existing portions".
An existing portion is any land surface area of an existing waste
management unit, included in the original Part A application, on
which wastes have been placed prior to issuance of a Part B permit.
For example, this may be one cell or trench or portion of a cell
or trench of a landfill or a section of a pile. Figure 3-2 illustrates
the concept of existing portions. It is important to note that
the critical date is the date of permit issuance, not the effective
date of the Part 264 regulations (January 26, 1983). In order to
avoid retrofitting, existing portions of landfills, surface
impoundments, and waste piles are exempt from the requirements to
install liners and leachate collection systems. New units (units
not included in the original Part A application) of existing facilties
are not entitled to the exemption; they would not experience the
retrofitting problems pertaining to existing portions.
The term "regulated unit" is used in defining the portion of
the facility that is subject to the ground-water monitoring and
3-27
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1982
1983
Y7777.
1984 \'////.
Working Face
when Part B
(Part 264)
permit issued
y////////,
y////////,
Y///////,
Legend:
Existing portions, thus exempt from liner standards
and leachate collection system
New portions subject to standards
Figure 3-2. Concept of existing portions of hazardous waste
management units.
3-28
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response requirements provided in Subpart F. A regulated unit is
any waste management unit of the types described in Section
3.2.3.1 above that received hazardous waste after January 26,
1983, the effective date of the Part 264 regulations (see §264.90)
The Preamble to the Part 264 land disposal regulations provides
additional rationale for requiring ground-water monitoring at
regulated units (See 47 FR 32274).
Because of its definition, the term "regulated unit" not only
defines what facility portions will be subject to Subpart F, but
it also indirectly delineates those portions of the facility that
will be actively operating under a Part 264 permit. Facility
portions that do not receive wastes after January 26, 1983 (i.e.,
are not regulated units), must be closed or in the process of
closing. Otherwise, EPA assumes that the unit will receive
hazardous waste at some future time, thereby establishing the unit
as a regulated unit.
3.3.2.2 Standards Applicable to All Units —
The Part 264 and 270 regulations contain requirements in
certain Subparts that are generally applicable to all land
treatment, storage, or disposal units (except those defined in
§264.1 described above). These Part 264 requirements include
the following:
Subpart B - General Facility Standards;
- Subpart C - Preparedness and Prevention;
Subpart D - Contingency Plan and Emergency Procedures;
3-29
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Subpart E - Manifest System, Recordkeeping and
Reporting (certain sections are not applicable to
owners and operators of on-site facilities that do not
receive any hazardous waste from off-site sources).
- Subpart G - Closure and Post-Closure (the post-
closure requirements do not apply to storage or
treatment facilities).
Subpart H - Financial Requirements (§264.144,
§264.145 and §264.146 apply only to disposal
facilities).
The Part 270 information requirements that correspond to the
above general standards are provided in §270.14 - "General
Information Requirements".
The ground-water monitoring and response requirements, defined
in Subpart F of Part 264, also apply to all land treatment, storage,
or disposal units - with several notable exceptions. First, as with
the above requirements, any of the general exclusions in §264.1
exempt certain facilities from Subpart F as well.
Second, double-lined surface impoundments, waste piles, and
landfills (described in §264.222, §264.252, and §264.302, respec-
tively) are excluded as are waste piles complying with §264.250(c)
and §264.253. The reason that most of these provisions provide a
basis for an exclusion from Subpart F is that they involve some
ongoing method for detecting whether the unit's liner has failed.
The exclusion for a waste pile designed to satisfy §264.250(c)
is based on the premise that the specified conditions reduce the
3-30
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possibility of leachate generation to such a degree that ground-
water contamination is not likely to occur.
Third, the permittee of a land treatment unit may suspend
compliance with Subpart F requirements if he can demonstrate
to the Regional Administrator under §264.280(d) that the hazardous
constituents in the waste have been effectively treated. This
exclusion relieves the permittee from Subpart F responsibilities
only during the post-closure care period.
Fourth, the permittee of a regulated unit may be excluded
from Subpart F if the Regional Administrator finds that there is
no potential for migration of liquids from the regulated unit to
the uppermost aquifer during the active life of the unit (including
the closure period) and the post-closure care period specified
under §264.117. This exclusion is designed for units located in
hydrogeologic settings that prevent leachate migration to the
uppermost aquifer for very long periods. The flowcharts described
in Section 3.3.2.3 below will assist the applicant in defining the
applicability of Subpart F to his particular unit.
The Part 270 information requirements corresponding to the
Subpart F, Part 264 ground-water standards are provided in
§270.14(c) - Additional Information Requirements.
3.3.2.3 Specific Unit Standards --
In addition to the above described general requirements
applicable (generally) to all unit types, Part 264 and 270 contain
specific requirements applicable to specific land treatment,
storage, or disposal unit types. These requirements are written
3-31
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in Part 264 Subpart K (Surface Impoundments), Subpart L (Waste
Piles), Subpart M (Land Treatment Units), and Subpart N (Land-
fills) . The corresponding Part 270 information requirements are
defined in §270.15-270.21 - Specific Information Requirements.
To assist the applicant in integrating all facility and unit
information (e.g., regarding existing portions, etc.) and deter-
mining the requirements that apply to his specific unit, flow-
charts are presented for each unit type (Figures 3-3 through 3-7).
These charts will assist in making the decisions essential in
arriving at a clear understanding of the specific requirements
that apply in a particular situation. (Note: In addition to
the specific requirements defined in the figures, all permittees
must comply with the general Subpart provisions delineated in
Section 3.2.4.2 above.)
3.4 RCRA TECHNICAL GUIDANCE DOCUMENTS, TECHNICAL RESOURCE
DOCUMENTS, AND OTHER GUIDANCE MANUALS
To assist permit applicants and permit writers, EPA has
prepared several publications related to land-based hazardous
waste management units. The following publications contain
guidance regarding the design of specific aspects of units,
provide general guidance regarding operations, and discuss diverse
topics such as test methods and financial assurance.
3.4.1 RCRA Technical Guidance Documents
3.4 .1.1 List —
Four Technical Guidance Documents (TGDs) are being made avail-
able that are directly related to the Part 264 regulations for land
3-32
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Is facility a hazardous waste land treat-
ment, storage, or disposal facility?
YES
Is facility exempt for all the Part 264 and
Part 270 requirements? (See §264.1 and
§270.1)
Part 264, Subparts K through
N do not apply
Part 264 and/or Part 270 do
not apply
NO
What type of land treatment, storage, or
disposal units are present at the proposed
facility?
CO
i
CO
co
If
Landfill
• disposal
• liner and 1 ea-
chate col lec-
tion and re-
moval system
except exist-
i ng port i on)
• no free li-
quids unless
1 iner and lea-
chate collec-
tion and re-
moval
*
Surface Impoundment
• depression, excava-
tion, diked area
• designed to hold li-
quids
• storage, treatment or
disposal
• no leachate collec-
tion removal system
• liner (except exist-
ing portions)
»
Land Treatment Unit
• waste applied to
soi 1 surface
• treatment is primary
goal
• noli ner
• liquids move freely
through system
^*
Waste Pile
• non-containerized
solid non-flowing
waste
• treatment or
storage
• liner (except
existing portion)
t leachate col 1 ec-
tion and removal
(except existing
port i on )
Underground Injection Well
• subsurface emplacement of fluids
through we!1
• depth of well is greater than larg-
est surface dimension
• septic tanks and cesspools included
Other Unit Types
• seepage units - lagoons designed
to leak
• variations of the above
Figure 3-3, Oatermining facility and unit type.
-------
Is surface impoundment a "regulated unit"? (i.e., has or
will it receive hazardous waste after January 26, 1983?)
I
YES
NO
Unit must move to closure; consult
Regional Administrator
Is impoundment double-lined according to §264.222?
Can be exempt from Subpart F; all
Subpart K applies (stop here in
flowchart)
,YES
NO
Mill demonstration be made to show no potential for
liquid migration from unit to uppermost aquifer dur-
ing active life and post-closure care period? (see
§264.90(b)(4))
co
i
cx>
YES
NO
Go to Figure 3-3a
Will demonstration be made to show alternative design
and operating practices, and location will prevent
migration of hazardous constituents into ground and
surface water at any future time? (see §264.221(b))
Can be exempt from Subpart F; can
be exempt from §264.221(a); all
remaining Subpart K applies
-YES
1
NO
Does impoundment have an "existing portion"?
YES
n 5u
I
NO
Can be exempt from "Subpart F; is exempt
from §264.221(a) and §264.226(a) for
existing portions; all remaining Sub-
part 1C applies
Can be exempt from Subpart F; all
Subpart K applies
Figure 3-4. Subpart F and K requirements for surface impoundments.
-------
Continued from Figure 3
E]
Will wastes remain at closure?
disposal impoundment?)
(Is
It a
YES
NO
co
I
Oo
Will demonstration be made to show alterna-
tive design, operating practices, and loca-
tion will prevent migration of hazardous
constituents into ground and surface water
at any future time? (see §264.221(5))
YES
NO
Will demonstration be made to show alterna-
tive design, operating practices, and lo-
cation will prevent migration of hazardous
constituents into ground and surface water
at any future time? (see §264.221(b))
YES
NO
Subpart F applies; can be
exempt from §264.221(a);
all remaining Subpart K
appl i es
YES
Subpart F applies; is ex-
empt from §264.221(a) and
§264.226(a) for existing
portions; all remaining
Subpart K applies
Does impoundment have
an "existing portion"?
NO
Subpart F applies; all
Subpart K applies
Subject to Subpart F during
active and closure periods; can
be exempt from §264.221(a); all
remaining Subpart K applies
YES
r
Subject to Subpart F during
active and closure periods; is
exempt from §264.221(a) and
§264.226(a) for existing por-
tions; all remaining Subpart K
applies
Does impoundment have an
"existing portion"?
NO
Subject to "Subpart F dur-
ing active and closure
periods; all Subpart K
applies
Figure 3-4A • Subpart F and K requirements for surface impoundments
(continued from Figure 3-33).
-------
Is waste pile used to store or treat solid hazardous waste,
and will wastes be removed or decontaminated at closure?
YES
HO
It i s not a waste pile,
and is subject to land-
fill requi rements
(Subpart N)
Is waste
recei ve
pile a "
hazardous
regulated unit"? (i .e
waste after January
. , has or will
26, 1983?)
YES
NO fc
it
Pi le
Pile must move to clo-
sure; consult Regional
Admini strator
Is the waste pile inside or under a structure that pro-
vides protection from precipitation so that neither run-
off nor leachate is generated, and other requirements in
§264.250(c) are met?
YES
NO
Is waste pile double-lined according to §264.252?
NO
YES
Can be exempt from Subpart F; all Subpart
L applies (stop here in flowchart)
Will liner of waste pile be inspected and meet other
requirements of §254.253?
YES
NO
Will demonstration be made to show no potential for li-
quid migration from pile to uppermost aquifer during ac-
tive life and post-closure care period (§264.90(b) (4 )) ?
YES
NO
Will demonstration be made to show al-
ternative design, operating practice,
and location will prevent migration of
hazardous constituents into ground and
surface water at any future time
(see §264.251?)
"1
jr
Will demonstration be made to show al-
ternative design, operating practices,
and location will prevent migration of
hazardous constituents into ground and
surface water at any future time
(see §264.251?)
YES
r
Can be exempt from
Subpart F; can be
exempt from §264.251(a);
all remaining Subpart
L applies
NO
YES
Can be exempt from Sub-
part F; is exempt from
§264.251 (a) for exist-
i ng portions; all re-
maining Subpart L ap-
plies
Does the waste pile have
an "existing portion"?
mp
Can be exem
part F; all
applies
NO
t from Sub-
Subpart L
YES
Subpart F app1i es
can be exempt from
§264.251{a); all
remaining Subpart
L. appli es
YES
Subpart F applies ;
is exempt from
§264.251(a) for
existing port i ons;
al1 remai ni ng Sub-
part L app1i es
NO
Does the waste pile have
an "existing portion"?
NO
Subpart F appl ies; all
Subpart L applies
Figure 3-5. Subpart F and L requirements for waste piles
3-36
-------
Is land treatment unit a "regulated unit"? (i.e.,
has it received hazardous waste after January 26,
1983?)
YES
NO ,
Unit must move to closure; con-
sult Regional Administrator
YES
CO
Will demonstration be made during closure or post-
closure periods to show hazardous constituents in
the treatment zone are not statistically signifi-
cantly increased over background? (see §264.280
(d))
1
Will demonstration be made to show no potential for
liquid migration from unit to uppermost aquifer
during active life and post-closure care period?
(see §264.90(b)(4J)
f
YES
NO
YES
NO
Unit can be exempt from
Subpart F during post-
closure period; all Sub-
part M applies
Al 1 Subpart "f and
Subpart M applies
Unit can be exempt from
Subpart F, all Subpart M
app! tes
Al1 Subpart
applies
F and Su bpa rt M
Figure 3-6. Subpart F and M requirements for land treatment.
-------
Is landfill a "regulated unit"? (i.e., has or will
it receive hazardous waste after January 26, 1983?)
YES
Unit must move to closure; consult
Regional Administrator
Is landfill double-lined according to §264.302?
Landfill can be exempt from Sub-
part F, all Subpart N applies
(stop here in flowchart)
.YES
NO
Will demonstration be made to show no potential for
liquid migration from unit to uppermost aquifer dur-
ing active life and post-closure care period? (see
§264.90(b)(4))
YES
NO
CO
CO
00
Will demonstration be made to show alternative
design and operating practices, and location
will prevent migration of hazardous constitu-
ents into ground and surface water at any fu-
ture time? (see §264.301(b))
YES
Can be exempt
from Subpart F;
can be exempt
from §264.301(a);
all remaining
Subpart N applies
YES
Can be exempt from
Subpart F; is exempt
from §264.301(a)
for existing portions,
all remai ni ng
Subpart N applies
NO
Does the landfill
have an "existing
portion"?
^ NO
Can be exempt from
Subpart F; all
Subpart N applies
Mill demonstration be made to show alternative
design and operating practices, and location
will prevent migration of hazardous constitu-
ents into ground and surface waters at any fu-
ture time? (see §264.301(b))
YES
NO
Subpart F applies;
can be exempt from
§264.301 (a); all
remaining Subpart
N appl ies
Does the landfill
have an "existing
porti on"?
YES
f
NO
Subpart F applies; is
exempt from §264.301(a)
for all existing por-
ti ons ; all remai ni ng
Subpart N applies
Subpart f7 appl i es ;
all Subpart N
appl< es
Figure 3-6. Subpart F and N requirement for landfills .
-------
treatment, storage, and disposal facilities. The purpose of these
documents is to provide details of design and operating procedures
that contribute to the satisfactory performance of a facility. The
current editions contain a few unit design examples. More models
will be included as EPA acquires additional information.
Applicants are urged to obtain and review the TGDs applicable
to their situations. The documents contain guidance, not
regulations or requirements. However, the Agency feels that
units designed in accordance with the specifications contained in
the TGDs will meet associated Part 264 requirements. Thus designs
consistent with the TGDs will likely be granted a draft Part B
pe rm i t.
The RCRA Technical Guidance Document titles are:
(1) "Surface Impoundments-Liner Systems, Final Cover, and
Freeboard Control"
(2) "Waste Pile Design-Liner Systems"
(3) "Land Treatment Units"
(4) "Landfill Design-Liner Systems and Final Cover"
Drafts of volumes issued in July 1982, are available in the
EPA Headquarter's and Regional Offices' libraries, and the Head-
quarter's Subtitle C docket room. Final editions will be issued
for purchase from the Government Printing Office.
3.4.1.2 Synopsis —
Surface Impoundments-Liner Systems, Final Cover, and Free-
board Control discusses design specifications for the principal
components of surface impoundments (i.e., liner systems, monitoring
3-39
-------
methods, overtopping controls, and closure caps). Appendices
are included in the July 1982 edition that provide laboratory
and field testing protocols for obtaining necessary data
elements. These Appendices (Methods 9090 and 9100) will be
printed separately in SW-846, Test Methods for Evaluation
of Solid Waste.
Waste Pile Design - Liner Systems describes liner designs
that provide an essentially impermeable base with sufficient
strength to allow periodic removal of all wastes in order to
physically inspect the liner. Details on suitable liner
materials, liner thickness, and leachate processing are
discussed. Appendices with useful test procedures are
included.
Land Treatment Units identifies specific designs and
various operating procedures to: maximize waste treatment;
control water run-on/run-off and wind dispersal; monitor for
waste constituent escape; close facility; and maintain the
site after closure. Methods to demonstrate waste treatability
in soil are provided along with appendices containing testing
protocols.
Landfill Design - Liner Systems and Final Cover presents
various liner specifications, leachate processing methods,
and final cover designs that would give satisfactory performance
in a given environmental setting. Appendices containing
relevant testing procedures are included.
3-40
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3.4.2 Technical Resource Documents (TRDs)
3.4.2.1 List —
Eight Technical Resource Documents providing design, operation,
and evaluation information related to hazardous waste disposal
facilities have been published to assist the regulated community
and the permitting authorities. These documents describe current
technologies and methods for evaluating the performance of a
disposal facility design; they are not directly related to the
regulations. As new information is developed, the Agency intends
to update each of these documents so that they reflect the latest
state-of-the-art information. TRDs are available for reading at
EPA Headquarters (Library or Subtitle C Docket Room), 401 M Street,
S.W., Washington, D.C., during the hours of 9 A.M. - 4:30 P.M.,
Monday through Friday. Copies may be purchased according to the
following list from the Superintendent of Documents, U.S. Government
Printing Office, Washington, D.C. 20402, (202) 783-3238.
1. Evaluating Cover Systems for Solid
and Hazardous Waste (SW-867).
2 . Hydrologic Simulation on Solid Waste
Disposal Sites (SW-868).
3. Landfill and Surface Impoundments
Performance Evaluation (SW-869).
4 . Lining of Waste Impoundment and
Disposal Facilities (SW-870).
5 . Management of Hazardous Waste
Leachate (SW-871).
GPO GPO
Stock No. Price
055-000-00228-2 $4.75
055-000-00225-8 $6.00
055-000-00233-9 $5.00
055-000-00231-2 $11.00
055-000-00224-0 $11.00
3-41
-------
GPO GPO
(con't) Stock No. price
6. Guide to the Disposal of Chemically 055-000-00226-6 $6.00
Stabilized and Solidified Waste
(SW-872).
7. Closure of Hazardous Waste Surface 055-000-00227-4 $5.50
Impoundments (SW-873).
8. Hazardous Waste Land Treatment 055-000-00232-1 $11.00
(SW-874).
3.4.2.2 Synopsis —
Evaluating Cover Systems for Solid and Hazardous Waste
(SW-867) presents a procedure for evaluating final cover engineering
plans proposed for solid and hazardous waste land disposal facilities.
Aspects of cover design are addressed in sufficient detail
to allow an evaluation of the entire cover system.
Hydrologic Simulation on Solid Waste Disposal Sites (SW-868)
describes the use of a computer-based model for simulating the
percolation of water through cover material at a solid waste
disposal site. This model is a tool for evaluating present
cover materials, and the design of new landfill covers. Previous
computer experience by the program user is not necessary.
Landfill and Surface Impoundment Performance Evaluation
(SW-869) provides techniques for determining the adequacy of
design features such as liners, drain layers, slope, and position
of drains in controlling liquid waste escape from surface
impoundments and landfills into the environment.
Lining of Waste Impoundment and Disposal Facilities (SW-870)
discusses performance evaluation, selection, installation, and
maintenance of specific liner and cover materials for certain
3-42
-------
containment situations based upon the latest technology. It
includes a description of several industrial waste streams, and
indicates several testing procedures for evaluating the waste/liner
interaction.
Management of Hazardous Waste Leachate (SW-871) presents
options for controlling, treating, and disposing of hazardous
waste leachates generated by surface impoundments and landfills.
Discussion includes factors that influence leachate generation,
data on leachate characteristics, alternative technologies for
processing leachates, and data on treatment costs and byproducts.
A systematic approach is provided for selecting an appropriate
leachate management method.
Guide to the Disposal of Chemically Stabilized and Solidified
Waste (SW-872) describes current treatment technology, and design
of long-term storage and disposal systems using stabilization/
solidification of wastes. It includes data on the properties of
treated wastes, and a listing of major technology suppliers with
a summary of each process. Sufficient information is provided to
determine relative cost/effectivness of stabilization/solidifica-
tion for a particular waste and disposal system.
Closure of Hazardous Waste Surface Impoundments (SW-873)
discusses the important details to consider in evaluating closure
and post-closure plans for hazardous waste surface impoundments.
Methodologies are presented for site specific assessments.
Hazardous Waste Land Treatment (SW-874) describes current
technology and provides methods for evaluating the design and
3-43
-------
performance of hazardous waste land treatment facilities. All
aspects of land treatment are discussed from initial site selection
through final closure.
3.4.2.3 Future Technical Resource Documents
Evaluation of Closure and Post-Closure Care Plans for
Hazardous Waste Landfills presents an overview of the current
state-of-the-art technologies for closing landfill facilities.
Soil Properties, Classification, and Hydraulic Conductivity
Testing is a compilation of available laboratory and field
testing methods for the measurement of hydraulic conductivity of
soils along with background information on relevant soil properties
and classification systems. However, Method 9100 published in
Test Methods for Evaluating Solid Waste (SW-846) presents the
official EPA test methods for hydraulic conductivity
determinations.
Solid Waste Leaching Procedure Manual provides laboratory
batch procedures for extracting a leachate sample from solid
waste that is similar to the composition of leachate from the
waste under field conditions.
Methods for the Prediction of Leachate Plume Migration and
Mixing includes a variety of programs for micro-computers and
hand-held calculators. The programs can be used to predict
leachate plume migration and ground-water recharge. The TRD will
also include related case histories and field studies.
3-44
-------
Hydrologic Evaluation of Landfill Performance (HELP) Model
is an update of an earlier TRD, Hydrologic Simulation on Solid
Waste Disposal Sites.
3.4.3 Other Guidance Manuals
3.4.3.1 Title and Availability —
Several other publications are available that cover specific
topics related to land disposal. The following list contains the
title, source, and price of these publications. Publications
with source shown as NTIS can be ordered from the National
Technical Information Service in Springfield, VA at (703) 487-4650.
Publications from the Government Printing Office (GPO) may be
ordered by calling (202) 783-3238. The RCRA Docket is located in
the EPA Headquarters, Washington, D.C. and may be contacted by
calling (202) 382-4672.
Title Source Price
1. Test Methods for Evaluating GPO $55.00
Solid Wastes (SW-846) [055-002-81001-21 (Subscription
for 2 years)
2. A Method for Determining the NTIS
Compatibility of Hazardous [PB80-221005] $15.00
Wastes (EPA-600/2-80-076)
3. Financial Assurance for NTIS $21.00
Closure and Post-Closure Care: [PB82-237595]
Requirements for Owners and
Operators of Hazardous Waste
Treatment, Storage, and Disposal
Facilities-A Guidance Manual (SW-955)
4. Liability Coverage: Requirements NTIS $11.50
for Owners or Operators of Haz- [PB82-144675]
ardous Waste Treatment, Storage,
and Disposal Facilities - A
Guidance Manual (SW-961)
3-45
-------
(con't)
5,
Title
10
11
12
13
14
15
16
17
18
Handbook for Remedial Action
at Waste Disposal Sites
(EPA-625/6-82-006)
Permit Writers' Guidance Manual for
Subpart F (being drafted)
Permit Writer's Guidance Manual for
General Facility Standards (being drafted)
Source
NTIS
[PB82-239054]
Price
$37.00
N/A
N/A
Ground-Water Monitoring Guidance for
Owners and Operators of Interim
Status Facilities (SW-963)
NTIS
[PB83-209445]
RCRA Personnel Training Guidance RCRA
Manual September 1980 Docket
Regional Guidance Manual for Selected RCRA
Interim Status Requirements- Docket
September 22, 1980
Draft Guidance for Subpart G of the RCRA
Interim Status Standards October 6, Docket
1981
Draft Guidance for Subpart H of the RCRA
Interim Status Standards August 29, Docket
1980
Guidance Manual for the Closure of RCRA
Hazardous Waste Surface Impoundments Docket
May 1980
Guidance Manual for Evaluating Permit RCRA
Applications for the Operation of Docket
Hazardous Waste Incinerator Units
Guidance Document for Subpart F; Air RCRA
Emission Monitoring; Land Disposal Docket
Toxic Air Emissions Evaluation Guideline.
RCRA Inspection Manual RCRA
Docket
Characterization of Hazardous Waste
Sites—A Methods Manual, Volume II N/A
Land Disposal of Hazardous Waste, NTIS
Proceedings of the Ninth Annual [PB84-118-777]
Research Symposium (EPA-600/9-83-018) ,
Sept. 1983.
N/A
N/A
$17.50
$15.00
$30.00
$29.00
$19.00
$15.00
$15.00
$24.00
$28.20
N/A
$35.50
3-46
-------
(con't) Title Source Price
19. Soil Properties, Classification, RCRA Hotline Free, while
and Hydraulic Conductivity (800)424-9346 supply lasts
Testing, Draft Technical Resource
Document, SW-925, 1984.
20. Solid Waste Leaching Procedure, RCRA Hotline Free, while
Draft Technical Resource Document, (800)424-9346 supply lasts
SW-924, 1984.
21. Procedures for Modeling Flow RCRA Hotline Free, while
Through Clay Liners, Draft (800)424-9346 supply lasts
Document, EPA/530-SW-84-001,
April 1, 1984.
3.4.3.2 Synopsis —
Test Methods for Evaluating Solid Wastes (SW-846)'provides
standardized laboratory procedures for determining whether a
waste is hazardous as defined in Section 3001 of the Resource
Conservation and Recovery Act (PL94-580), and for obtaining data
to satisfy the requirement of 40 CFR Part 261, Identification and
Listing of Hazardous Waste. These methods will generate data of
acceptable quality to support waste evaluation and listing/delisting
petitions. Included are protocols for collecting representative
waste samples, determining pH, flash point, leachability,
reactivity, corrosivity, ignitability, mobility of toxic
constituents, and general composition of the waste. These
procedures are current state-of-the-art techniques and will be
periodically updated and expanded as new information is developed.
The late 1983 supplement will include Methods 9100 (Methods for
Determining Saturated Hydraulic Conductivity, Leachate Conductivity,
and intrinsic Permeability) and Method 9090 (Compatibility Test
for Wastes and Membranes Liners). Draft versions of these methods
3-47
-------
were presented as Appendices to the July 1982 edition of the
RCRA Technical Guidance Documents.
A Method for Determining the Compatibility of Hazardous
Wastes (EPA-600/2-80-076) presents a procedure for determining
the compatibility of combinations of two wastes or waste streams.
The manual includes a chart of 41 reactivity groups. Wastes to
be combined are first subjected to the analysis procedure for
identification and classification into a reactive group. The
chart may be used to indicate the compatibility of the classified
wastes on mixing, but does not ensure compatability. Distribution
of this manual by NTIS is on hold.
Copies of the previously distributed manual may be used.
However, the manual does not contain assessments of compatibility
for all waste types. In actual practice it is suggested that,
if the manual does not address a waste type or indicates that two
waste types are compatible, only small quantities of the wastes
be mixed initially to assess compatibility of the specific wastes
being managed. This caution is particularly applicable to wastes
listed in the Hazardous Waste Compatibility Chart in Section 5
of the publication. This chart (matrix) appears to indicate that
many pairs of reactivity groups are compatible. This is shown by
a blank space in the matrix. If the applicant contemplates the
mixing of any such pairs, test mixing of small quantities is
recommended prior to co-disposal of large quantities.
The American Society for Testing and Materials (ASTM) is
considering the adoption of an updated version of the document as
3-48
-------
an ASTM Standard. It is expected that ASTM will adopt a Standard
for waste compatibility which will be available from the ASTM
Customer Service Office, 1916 Race Street, Philadelphia, PA
19103, (215) 299-5400. Reference should be made to Committee D-34
when inquiring about the status of this ASTM Standard.
Financial Assurance for Closure and Post-Closure Care;
Requirements for Owners and Operators of Hazardous Waste Treatment,
Storage, and Disposal Facilities - A Guidance Manual (SW-955)
describes the responsibilities of the regulated community in
fulfilling the financial assurance requirements of the regula-
tions. Tasks that must be performed by the Regional Office, and
possible contingencies that may arise are discussed. A checklist
of required information and sample application forms are provided.
NTIS No. PB82-237595.
Liability Coverage; Requirements for Owners or Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities - A
Guidance Manual (SW-961) describes the responsibilities of the
regulated community in providing liability coverage for facil-
ities, and discusses the role of the Regional Office. Included
are a checklist of required information and sample application
forms. NTIS No. PB83-144675
Handbook for Remedial Action at Waste Disposal Sites (EPA-
625/6-82-006) describes available remedial action technologies
and how they may be applied for the clean-up of hazardous waste
disposal sites. A general approach to selecting an appropriate
clean-up technique for a specific site is provided. NTIS No.
PB82-239054.
3-49
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Permit Writer's Guidance Manual for Subpart F (being drafted)
provides a comprehensive examination of items covering ground-
water protection requirements for permit writers to examine when
reviewing Part B applications.
Permit Writer's Guidance Manual for General Facility
Standards (being drafted) will discuss the information needed
from all applicants from hazardous waste management facility
permits (i.e., Part 264 Subparts B, C, D, E.)
Ground-Water Monitoring Guidance for Owners and Operators
of Interim Status Facilties (SW-963) provides guidance for
compliance with the Interim Status requirements for ground-water
quality monitoring in Subpart F of 40 CFR 265. NTIS No.
PB83-209445.
Characterization of Hazardous Waste Sites — A Methods
Manual, Volume II, Available Sampling Methods (being drafted) will
describe 30 methods of sampling solids, liquids, and gases. The
methods are applicable to sampling during routine waste site
visits and hazardous spill investigations.
3.4.4 Other Reference Material
3.4.4.1 OSW Publication Inventory, July 1982 —
This inventory is a listing of solid waste information
materials and reprints available from the Office of Solid Waste.
Single copies may be obtained by calling the RCRA Hotline, 800-
424-9346, or by writing to the U.S.EPA, Office of Solid Waste
(WH-562), Program Support Branch, 401 M Street, S.W., Washington,
D.C. 20460.
3-50
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3.4.4.2 Future Resource Manuals —
Work is in progress on technical resource manuals in the
following subject areas:
numerical simulation techniques for design of soil liners
for storage impoundments and waste piles
further information on clay liner design
characteristics of hazardous waste streams
corrective actions
The availability of these manuals will be announced in
the Federal Register, and in future editions of this Manual.
3-51
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SECTION 4.0
GENERAL GUIDANCE FOR PREPARING A RCRA LAND
TREATMENT, STORAGE, OR DISPOSAL PERMIT APPLICATION
Section 4.1 describes a recommended permit application
format. Section 4.2 discusses technical assistance needs of
permit applicants. In addition to this manual, other guidance
documents are (or soon will be) available to assist permit
applicants in addressing these topics. Rather than repeating
this information, the user is referred to the appropriate
publications for these details.
Sections 5.0 through 9.0 provide a thorough discussion of
the specific requirements for particular types of land treatment,
storage, and disposal units and the ground-water monitoring and
response standards.
4.1 SUGGESTED PERMIT APPLICATION FORMAT
4.1.1 Purpose
Section 4.0 is designed to facilitate preparation of RCRA
land treatment, storage, and disposal permit applications.
Guidance is provided for the requirements for a Part A permit
application under §270.13 and for a Part B permit application
under §270.14 through §270.21, and the corresponding technical
standards in Part 264. Recommended formats for the permit
applications are presented below. Following these general
formats should help the applicant prepare the permit application
4-1
-------
in a timely manner. When submitting an application, the
applicant should be sure that the document's binding (e.g., a
three-ring binder) allows for revisions during the subsequent
review by EPA.
4.1.2 Part A Permit Application Format
Part A of the permit application is to be presented on EPA
Forms 3510-1 (Form 1) and 3510-3 (Form 3). Copies of these
forms and related instructions are shown in Appendix A. The
applicant may copy these forms or obtain them from the Regional
Office.
4.1.3 Part B Permit Application Format
There are no EPA forms for a Part B permit application
because the detailed information required is site specific and
may be presented in several different manners. The actual
application format is left to the discretion of the applicant.
However the EPA will use the checklists presented in Sections
5.0 through 8.0 to determine the completeness of the application,
A simplified version of these lists is shown below. EPA's
Analysis of the application and ability to efficiently communi-
cate with the applicant will be aided if the applicant provides
the information in the order shown.
A. General Information Requirements
Part A permit application if not previously
submitted or if information has changed
since submitted.
General description of the facility.
4-2
-------
The process code(s) (from the Part A
permit application) that identify the type(s)
of unit(s) for which permits are requested.
Chemical and physical analysis of hazardous
wastes to be handled.
Waste analysis plan.
Security description for the active portion of the
facility.
General inspection schedule and description of
procedures (including specific requirements for
particular unit types).
Preparedness and prevention documentation or
justification of waiver request.
Contingency plan documentation (including specific
requirements for particular unit types).
Preventive procedures, structures, and equipment
documentation for control of unloading hazards,
waste run-off, water supply contamination, effects
of equipment failure and power outages, and
undue personnel exposure to wastes.
Prevention of accidental ignition or reaction
documentation (including specific requirements
for particular unit types).
Traffic documentation.
Facility location documentation.
Personnel training program documentation.
Closure plan documentation (including specific
requirements for particular unit types).
Post-closure care plan (when applicable)
(including specific requirements for particular
unit types).
Documentation of deed notice (applicable to
existing facilities only),
Closure cost estimate and documentation of
financial assurance mechanism.
4-3
-------
Post-closure cost estimate and documentation of
financial assurance mechanism.
Documentation of insurance.
Documentation of coverage by a state financial
mechanism (if applicable).
Topographic map showing contours with 0.5-2.0 m
(2-6 ft) intervals, map scale and date, 100-year
flood plain area, surface waters including
intermittent streams, surrounding land uses,
wind rose, north orientation, legal boundaries
of facility, access control, injection and
withdrawal wells, buildings and other structures,
utility areas, barriers for drainage or flood
control, and location of operating units including
equipment cleaning area. Each hazardous waste
management unit should be shown on the map with
a unique identifier (number, etc.) and the associated
process code from the Part A application.
B. Specific Information Requirements
See sections 5.0 through 9.0 for specific
information requirements for each type of facility.
Also refer to Subparts K, L, M, and N of Part 264.
C. Additional Information Requirements
Summary of ground-water monitoring data obtained
during the interim status period.
- Identification of aquifers beneath the facility.
Delineation of waste management area and "point
of compliance" for ground-water monitoring on
topographic map.
- Description of any existing plume of contamination
in ground water.
- Detailed ground-water monitoring program
description. (This section can be combined
with # 6, 7, or 8, as appropriate.)
- Detection monitoring program description, if
applicable.
Compliance monitoring program description, if
applicable.
4-4
-------
- Corrective action program description, if
applicable.
Justification for any proposed waiver to the
Part 264 Subpart F Ground-Water Protection
Standards
4.1.4 Format Suggestions
It is suggested that the permit application be prepared and
presented in two distinct portions - a basic or general applica-
tion and a series of specific attachments. The basic application
should include the requirements of the General Facility Standards
such as general identification information, purpose of the
application and general remarks. It should address (but not
necessarily contain) all specific, technical information necessary
to obtain a permit.
For example, for a proposed liner system the basic applica-
tion might include a statement that a single, synthetic liner
will be used at the proposed unit and that the liner system
design including, specifications, plans, installation procedures,
etc. are attached as Attachment . Thus the basic application
could be reviewed during the Administrative Completeness Check
to assess the completeness of the application. Later, both
parts of the application would be reviewed for technical aspects.
Specific technical portions of the permit application should
be presented in the form of self-contained attachments. Each
attachment should contain the information, data, maps, calcula-
tions, logs, etc. to fulfill the permit application requirements
for a specific feature of the proposed facility; e.g. liner system
4-5
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design or detection monitoring plan. The basic application
should refer to the attachments such that the permit writer can
easily relate the general discussions to the attachments.
The concept of attachments to a permit application is
included in Sections 5.0 through 9.0. An attachment is suggested
for each major technical aspect of a permit application (e.g.
run-off control system, cover design, management plan for
incompatible wastes, etc.). Suggested attachments are in the
sections of the text entitled "Guidance to Address the Application
Information Requirement". A list of all suggested attachments
is included in Appendix C.
The attachments will greatly facilitate the review of permit
applications and the subsequent writing of the permit. Reviewers
and permit writers will, in turn, assess these attachments and
incorporate them into the permit. Thus the permit may contain
the attachments prepared by the applicant, either as originally
written or as modified by EPA. The attachments essentially
describe how a requirement will be fulfilled. The applicant
proposes and justifies why his approach fulfills the requirements
in either the attachment or in the general application as
appropriate. The EPA assesses the material and permits construc-
tion and operation as described in the permit. The use of
attachments facilitates the review and the revision of permit
applications and permits themselves. If several attachments are
acceptable as proposed by the applicant, they may be incorporated
into the permit unchanged. If some require additional information
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EPA or returned to the applicant instead of returning the entire
permit application.
Attachments should be clearly identified. An identification
such as Attachment A and a title should be used consistently, in
both the basic permit application and on the attachments.
Attachments should have page numbers, figure numbers, etc., that
relate to the attachment identifier (e.g., Figure A-l or Table
C-3). Enough applicant and facility information should be
provided on the first page of each attachment to uniquely identify
the application of which it is a part.
Again, the loose-leaf binding(s) format is encouraged for
both attachments and any confidential business information.
Checklist matricies are included for each unit type at the
end of Sections 5.0 through 8.0 respectively. They identify the
permit application and associated facility standard requirements
as related to the unit types. Applicants are encouraged to use
these checklists to insure that a complete application is sub-
mitted. Space is provided for the applicant to indicate the
location of each required item in the application (e.g. page 13,
Appendix C, etc.). This information should be typed or printed
in the space provided.
It is suggested that applicants include in the application
a copy of the checklist(s) for each type of unit proposed. The
checklists(s) should be an early part of the basic portion of
the application. It will be used by EPA to assess completeness
and will facilitate technical review.
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4.1.5 Term of Permit
Applicants should be aware that RCRA permits are issued for a
fixed term that cannot exceed 10 years (see $270.50). If the
permittee wishes to continue the operation of the facility
beyond the expiration of the permit, he must apply for a second
(third, etc.) permit before the expiration of the current permit
(see S270.51). This means that applicants may wish to design
facilities in discrete, 10 year (maximum) parcels. This concept
is described in Figure 4-1.
4.2 TECHNICAL ASSISTANCE
Most applicants will require technical assistance in the
preparation of a permit application. Assistance will likely be
needed from specialists including: engineers, geologists, hydro-
geologists, and soil scientists (particularly for land treatment
units). These specialists may be part of the applicant's staff
or outside consultants. The Agency feels that applicants will
get the best service (designs, plans, etc.) and thus the most
complete application if they use only fully qualified technical
expertise. Especially important is experience in hazardous
waste management closely related to the proposed facility.
4.2.1 Engineers
Section 264.115 requires certification by a registered,
professional engineer that a facility has been closed in
accordance with an approved closure plan. Part 264 and other
regulations and documents related to land-based hazardous waste
management refer to the involvement of engineers or qualified
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FIRST 10-YEAR PERIMETER (PERMIT
PROPERTY BOUNDARY
Figure 4-1. Concept of 10-year permits
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engineers in facility design and the preparation of permit
applications.
Engineers are registered by all 50 states. Registration is
based on combinations of education, experience, and examinations.
It licenses engineers to practice their profession and includes
legal and ethical restrictions regarding the technical extent to
which services may be offered. Registered engineers may not
practice beyond their areas of expertise. Additionally, regis-
tered engineers are required by law to place public health,
safety, and welfare preeminent to other aspects of their assign-
ments .
The prudent applicant should get the best help possible in
the preparation of a permit application. EPA recommends that
engineers experienced in hazardous waste management be involved
with preparation of permit applications. Additionally, it
strongly recommends that registered, professional engineers
(registered in the State in which the facility is located)
be utilized in the development of necessary designs, specifica-
tions, certifications, etc. The combination of applicable
experience and registration on the part of engineers involved
should result in an application (and resultant facility) that
meets the technical requirements of the regulations. This manual
refers to qualified or to registered engineers in several sections
Proper qualifications are most important; however, professional
registration is also considered an important credential. If
the regulations require a registered engineer, even the best
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qualified, non-registered engineer will not meet the requirements.
4.2.2 Geologists, Hydrogeologists, and Soil Scientists
Experience related to land-based hazardous waste management
is again the most important credential for these technical
specialists. Some states register geologists (and thus hydro-
geologists) in a manner similar to engineers. If your state
registers geologists, it is recommended that experienced, regis-
tered geologists be involved with the permit application.
In lieu of registration, several national organizations
certify geologists, hydrogeologists, and soil scientists. Certi-
fication generally indicates that an individual has the basic
educational requirement and (usually) experience to be considered
a member of that profession.
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SECTION 5.0
SURFACE IMPOUNDMENT PERMIT APPLICATION GUIDANCE
Two important distinctions are introduced here to alert the
user of this manual to the alternatives available for permitting
surface impoundments. The regulations distinguish between storage
and disposal surface impoundments based on the manner in which
the impoundment is closed. Permittees are offered two alternatives
for closing their impoundments. The first is to remove or
decontaminate all wastes, waste residues and contaminated soils
and liners at closure. If this alternative is selected the
impoundment is considered a storage impoundment. The second is
to leave wastes, residues, or contaminated soils and liners
in place, eliminate free liquids, stabilize the wastes, place a
cap (final cover) on top of the waste, and conduct post-closure
monitoring and maintenance. An impoundment closed in this manner
is considered a disposal impoundment.
The regulations further provide that, in the case of a storage
impoundment, the liner may be constructed of materials that may
allow wastes to migrate into the liner (but not into the adjacent
subsurface soil or ground water or surface water) during the
active life of the unit, provided that the liner is removed at
closure. Thus, in appropriate situations, clay or admixed
impervious materials may be acceptable liner materials. However,
in the case of a disposal impoundment, the liner must be constructed
of materials that prevent wastes from passing into the liner.
Synthetic liners, although not specifically required, are viewed
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by EPA as the only commonly used materials that would meet
this standard. These important distinctions are introduced
here to alert the user of this manual to the alternatives
available for permitting surface impoundment. Further technical
guidance is provided in in the appropriate parts of this section
The regulations promulgated in Part 264 apply to both exist-
ing and new surface impoundments. Part 264, Subpart K contains
the design and operating standards. This section of the manual
is subdivided into ten subsections:
5.1 Waste Description
5.2 Design and Operating Requirements
5.3 Monitoring and Inspection
5.4 Dike Certification by a Qualified Engineer
5.5 Removal of Impoundment from Service
5.6 Closure and Post-Closure Care
5.7 Special Requirements for Ignitable or Reactive Wastes
5.8 Special Requirements for Incompatible Wastes
5.9 References
5.10 Checklist
A list of suggested attachments to permit applications for
surface impoundments is shown in Appendix C.
5.1 WASTE DESCRIPTION
5.1.1 The Federal Requirement
Section 270.17(a) requires that the Part B application
include:
A list of the hazardous wastes placed or to be
placed in each surface impoundment;
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The above Part 270 requirement does not apply to any one
specific Part 264 standard for impoundments. The required
information is necessary to comply with all the surface
impoundment requirements.
5.1.2 Guidance to Achieve the Part 264 Standard
The general facility standards [specifically, Section
264.13(a)] require the applicant to complete waste analyses as
necessary to treat, store, or dispose of wastes in accordance
with all of the Part 264 standards. The Permit Applicant's
Guidance Manual for General Facility Standards (1), provides
guidance on waste analysis and waste analysis plans.
5.1.3 Guidance to Address the Application Information Requirement
The applicant should submit a list of all hazardous wastes
that will be disposed of in the surface impoundment. A suggested
attachment to the permit application is List of Hazardous Wastes.
The following information on each waste should be reported:
- Common name of the waste
- EPA hazardous waste ID number
Location(s) where the waste is or will be placed (e.g.,
surface impoundment number)
- Volume of waste received per month, including actual
or estimated averages, maximums and minimums
Form of the waste when disposed (e.g., liquid, sludge,
etc.)
- Approximate moisture or solids content and other
significant features
- Special handling requirements.
The applicant should submit data on the form or physical
classification of the waste. The following is a brief description
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of the physical classes of waste. Aqueous-inorganic (AI) and
aqueous-organic (AO) are classes of waste in which water is the
solvent (predominant liquid), and the solutes are mostly inorganic
and organic, respectively. Organic (O) is the class of waste
in which the predominant liquids are organic, and the solutes
are mostly other organic chemicals dissolved in the organic
solvent. Solids, sludges, and slurries (S) are wastes high in
solids such as tailings, settled matter, or filter cakes.
The sampling and analytical methods applicable to identifying
the characteristics of hazardous waste placed in surface
impoundments are described in Part 261 of the regulations and
in EPA Publication Number SW-846, "Test Method for the Evaluation
of Solid Waste, Physical/Chemical Properties" (2) .
The applicant is advised that additional waste analysis
information must be included in Part A of the application and
in the general facility description. Part A must include a
specification of the hazardous wastes to be treated, stored
or disposed of at the facility, an estimate of the quantity of
such wastes to be treated, stored or disposed of annually, and
a general description of the processes to be used for such
wastes. Reference 1 includes guidance on the general information
requirements (i.e., $270.14) on waste analyses.
5.2 DESIGN AND OPERATING REQUIREMENTS
This section provides guidance on the permit application
information requirements related to the design and operating
requirements in §264.221. This section addresses the Part 270
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and Part 264 standards in the order in which they appear. Topics
addressed include the following:
5.2.1 Liner System Design
5.2.2 Liner Exemption Variance
5.2.3 Prevention of Overtopping
5.2.4 Structural Integrity of Dikes
5.2.5 Ground-Water Protection Exemption
5.2.1 Liner System Design
5.2.1.1 The Federal Requirements —
Section 270.17(b) requires that the Part B application
include:
Detailed plans and an engineering report
describing how the surface impoundment is or
will be designed, constructed, operated, and
maintained to meet the requirements of §264.221.
This submission must address the following
items as specified in §264.221:
(A) The liner system (except for an existing portion of a
surface impoundments)....
Section 264.221(a)(1)-(3) states:
A surface impoundment (except for an existing portion
of a surface impoundment) must have a liner that is
designed, constructed, and installed to prevent any
migration of wastes out of the impoundment to the
adjacent subsurface soil or ground water at any time
during the active life (including the closure period)
of the impoundment. The liner may be constructed of
materials that may allow wastes to migrate into the
liner (but not into the adjacent subsurface soil or
ground water or surface water) during the active life
of the facility, provided that the impoundment is
closed in accordance with §264.228(a)(1). For
impoundments that will be closed in accordance with
§264.228(a)(2), the liner must be constructed of materials
that can prevent wastes from migrating into the liner
during the active life of the facility.
The liner must be:
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(1) Constructed of materials that have appropriate chemical
properties and sufficient strength and thickness to
prevent failure due to pressure gradients (including
static head and external hydrogeologic forces), physical
contact with the waste or leachate to which they are
exposed, climatic conditions, the stress of installation,
and the stress of daily operation;
(2) Placed upon a foundation or base capable of providing
support to the liner and resistance to pressure gradients
above and below the liner to prevent failure of the
liner due to settlement, compression, or uplift.
(3) Installed to cover all surrounding earth likely to be
in contact with the waste or leachate.
5.2.1.2 Guidance to Achieve the Part 264 Standard —
Section 264.221(a) contains these key points:
It does not require the installation (retrofitting)
of a liner for existing portions of existing
surface impoundments;
It distinguishes between the performance required
of liners at disposal impoundments versus storage
impoundments; and -
It establishes general performance standards for liners,
(i.e., a disposal impoundment must have a liner that
prevents wastes from passing into the liner during the
life of the facility, while a storage impoundment
can use a liner that allows seepage into the liner
but not out of the liner during the life of the facility)
An "existing portion" means that land surface area of an
existing waste management unit, included in the original Part A
permit application, on which wastes have been placed prior to
issuance of a Part B permit. Existing portions are exempt
from the requirements to install liners. However, they
remain subject to the remainder of the design and operating
requirements in §264.221, as well as the ground-water
protection requirements.
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The regulations allow two distinct types of surface
impoundments. These are: impoundments used for storage and
treatment, and impoundments used for disposal. In both cases
the liner system is required to function through scheduled
closure and to consist of at least one liner. The key distinction
between the design of storage versus disposal impoundments
lies in the type of liner(s) used. EPA recommends that:
Liner systems for storage or treatment impoundments
where the waste will be removed at closure should
consist of a single soil (clay) or synthetic liner,
as a minimum; and
- Liner systems for disposal impoundments where the
waste will remain at closure should consist of a
single synthetic liner, as a minimum.
For storage and treatment impoundments, the waste must be
removed at closure; liquids can enter the liner but can not
migrate through it. For disposal impoundments, the waste
will be left in place at closure; liquids must be prevented
from passing into the liner.
EPA interprets the general performance standard for
disposal impoundments to mean that only synthetic liners
comply with §264.221(a). Synthetics are essentially 100
percent effective, when undamaged, in rejecting leachate
reaching the liner surface. The Agency realizes that very
small amounts of liquid may enter the structure of synthetic
membranes causing them to swell, but the amount is considered
negligible. The Agency believes that clay liners are valuable
as a backup to synthetic liners and recommends their use as
an extra measure of protection in all cases. Where final
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cover will not be applied for more than 30 years, however, the
Agency does not discourage a secondary clay liner as a backup,
should the synthetic primary liner deteriorate.
There are several different types of synthetic liners; each
compatible with certain types of wastes, but incompatible with
other types. No one liner material can be used with all wastes.
The following generic types of liners are available:
- High-density polyethylne
- Hypalon (chlorosulfonated polyethylene)
Polyvinyl chloride
- Chlorinated polyethylene
Some soil materials, typically those classified as clays, can be
placed and compacted to produce a liner system of very low
permeability for use in storage impoundments. Movement of liquids
through well constructed clay liners is very slow, as long as the
soil fabric of the liner is not adversely affected by the waste
materials or is not otherwise damaged. As a result the release
of liquid-containing hazardous constituents to the ground water
and surrounding soils is effectively minimized.
In addition to the general liner performance standards,
§264 .221(a)(l)-(3) includes several subsidiary performance
standards intended to assure that liners will meet their per-
formance goals. These subsidiary standards consist of general,
common-sense engineering goals addressing:
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- Chemical characteristics of liners;
- Liner strength and thickness
- Liner foundations
- Liner lateral extent
Detailed guidance on how to comply with these standards is
provided in RCRA Guidance Document Surface impoundment Liner
Systems and Final Cover, and Freeboard Control, Reference 3 and
Lining of Waste Impoundments and Disposal Facilities/ EPA
publication SW-870, Reference 4.
5.2.1.3 Guidance to Address the Application Information
Requirement —
Liner selection and design is one of the most difficult
aspects of surface impoundment design. The liner serves as a
primary barrier to leachate migration. It must be chemically
compatible with this leachate, and strong enough to resist
tearing during installation and operation. The nature of the
liner foundation is an integral part of liner design. To address
the application information requirements for liner design, the
applicant is advised to submit information on the following three
areas:
- Liner Specifications
Foundation Analysis
Liner Integrity Analysis
A suggested attachment to the permit application is Liner
System Design. The attachment should contain detailed specifica-
tions, raw data, calculations, drawings, assumptions, and so
forth, supporting the proposed design. A discussion of the
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rationale supporting the overall design should be included in the
basic portion of the application. The discussion should present
the reasons why and how the design meets the specific requirements.
5.2.1.3.1 Liner Specifications — The applicant should
identify the materials of construction, specifications of strength
and thickness, and chemical properties of the proposed liner. The
applicant should also submit design plans that show the method of
liner placement in the surface impoundment unit(s); this should
demonstrate that the liner will cover all areas of the unit that
will be exposed to wastes and leachate.
The applicant is responsible for all aspects of the applica-
tion including material and installation specifications. Material
specifications can be taken from the specifications provided by
the manufacturer, as long as the applicant proposes these as the
minimum acceptable specifications. The Liner Integrity Analysis
section describes the nature of engineering reports to justify
the selected liner strength, thickness, and chemical compatibility.
Appendix VIII of Reference 4 can be used to obtain minimum values
of properties of a synthetic liner that are necessary to specify
a quality liner material. The liner design plans should be in
standard construction drawing format. The plans should show the
extent of areal coverage for each unit. The plan should also
present cross-sectional views. Details of seaming methods,
anchoring, techniques to avoid physical stress concentrations,
and other special features should be provided in the plans and
in narrative form. Guide specifications for the construction of
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synthetic liners are included in Appendix D. These specifications
are not endorsed by the Agency, but do contain elements considered
important to the construction of a quality liner.
5.2.1.3.2 Foundation Analysis — The soils beneath a liner
support the liner, waste, and cover. If these soils settle,
shear, or uplift, the liner may be damaged. Hydrostatic and
gas pressure can also impact on liner performance. The potential
for these situations to occur at a given location can be reliably
assessed by a qualified, registered geotechnical engineer. In
many cases, standard engineering practices can be implemented to
alleviate potential liner deflection due to unnecessary stress
concentrations.
The foundation analysis should be reported in the Liner
System Design attachment. The analysis should assess the
potential for liner deflection due to settlement, compressive,
shear forces, or uplift of the foundation soils, and due to
hydraulic and gas pressures on the underside of the liner.
The following items should be considered in this report:
Geologic Data. A description should be provided of
regional and site geology, including:
— geologic setting
— soil types and characteristics (including boring logs)
— bedrock types and depths (including boring logs)
— subsidence history
— sinkhole potential
[Note that much of this information is also recommended in
Section 9.O.]
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Geotechnical Data. A subsurface investigation
should be conducted and a description provided of
the engineering characteristics of the foundation
soils. Data on soil index properties, shear strength,
hydraulic conductivity, and compressibility should
be provided.
Hydrogeologic Data. A description should be provided
of the characteristics of the saturated zone of the
site, including its relationship to surface water.
Section 9.0 can be used for further guidance on this
topic.
Seismic Setting. A description should be provided
on the potential for ground shaking and surface
rupture at the site. While the facility may not be
in a jurisdiction in which the seismic location
standard [§264.18 (a)] is applicable, it is advisable
to design a facility to withstand a design earthquake.
Information on the frequency and magnitude of earthquake
activity may have been established and local standards
adopted for design of structures. Generally, earth
structures can be easily designed to withstand the
vertical and horizontal accelerations experienced
during such design earthquakes.
The report should summarize the foundation investigation
and analysis. It should include all data collected during the
investigation, all calculations performed in the analysis, and
a description of the methods used in the investigation and
analysis. Total and differential settlements that can occur
during the active and closure period of the unit should be
estimated, including immediate settlement, primary and secondary
consolidation, creep, and liquefaction. Also, the bearing
capacity and stability of the foundation should be evaluated.
The subsurface investigation should thoroughly characterize
the in situ properties of the subsurface materials. The sub-
surface exploration should consist of test borings and test pits,
and may also include geophysical surveys.
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Test borings should be performed to adequate depths and
at a sufficient number of locations to define the subsurface
conditions. The method of drilling should be based on a
preliminary subsurface investigation. Test pits should be
excavated to identify near-surface conditions. Geophysical
surveys may be performed to more accurately identify bedrock
depths and fractured zones. Other types of geotechnical tests
(i.e., cone penetrometer, standard penetration) may be performed
as required for the specific conditions at the site. Many
standard techniques for geotechnical investigations are available
in the following publications:
American Society for Testing and Materials
(ASTM). Sampling of Soil and Rock. Special
Technical Publication 483, June 1970.
Hvorslev, M. Juul. Subsurface Exploration
and Sampling of Soils for Civil Engineering
Purposes. Army Corps of Engineers, Waterways
Experiment Station, 1965.
The subsurface investigation program can be combined with the
investigations undertaken in response to the ground-water
monitoring and aquifer identification requirements in Part 264,
Subpart F.
Laboratory testing of subsurface materials should be con-
ducted to determine index properties and engineering parameters.
Index property testing should include:
Grain size distribution curves
Atterberg limits
Consolidation tests for cohesive materials
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Shear strength
- Moisture content and dry density
Shear strength of soils may be determined using direct
shear or triaxial testing with triaxial tests preferred.
The methods for saturated hydraulic conductivity determination
described in Reference 5 (Method 9100) should be used; in
most cases, hydraulic conductivity (often referred to as
permeability) should be determined using field methods,
rather than laboratory techniques. The compressibility
characteristics should be determined by performing a sufficient
number of consolidation tests.
5.2.1.3.3 Liner Integrity Analysis — The integrity of
a liner is a function of several factors. Incompatible
chemicals can dissolve the liner. Excessive stress during
either installation or operation can cause tears or failed
seams. Climate can also adversely affect liners exposed to the
elements. It is critical that a liner be carefully selected
to be compatible with the wastes that it must contain. The
liner must also have adequate strength to resist tearing during
installation. It may be protected from puncturing during
installation and operation by underlying and overlying bedding
layers. Seaming techniques are extremely important as well.
Finally, the liner should have sufficient strength to resist
failure from any anticipated or likely settlement or movement
of the foundation.
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The applicant should submit a detailed report presenting
site-specific test data demonstrating integrity against:
Liner contact with waste (i.e., waste-liner compatibility)
Internal and external pressure gradients
- Climatic conditions
- Installation stresses
Daily operational stresses
Waste/Liner Compatibility
The applicant should submit results of compatibility
testing. These results should demonstrate the acceptability
of the selected synthetic liner. The following information
should be provided on the tests used to make the compatibility
demonstrations:
The name of test method that was used.
The procedure and details of the test method (e.g.,
number of test specimens, length of the test, and
the nature of leachate used).
Chemical and physical characteristics of the waste(s)
tested, including the EPA hazardous waste number,
physical class (e.g., aqueous-inorganic, aqueous-
organic; organic, solid, sludge, etc.), and waste
sources (including description of production and
waste treatment processes from which the waste stream
is generated).
The raw test results.
An explanation of how the raw test results were inter-
preted to lead to the selection of the synthetic liner
proposed as the primary liner for the surface impoundment.
An acceptable test method for examining the compatibility
of wastes/leachate and synthetic liners is the "Immersion Test
of Membrane Liner Materials for Compatibility with Wastes," and
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is referred to as Method 9090 in Test Methods for Evaluating
Solid Waste (Reference 2). An earlier form of this test was
published as Appendix A in the July 1982 RCRA Technical
Guidance Document entitled Landfill Design; Liner Systems
and Final Cover (Reference 5).
Liner manufacturers commonly provide information on the
compatibility of their liners with single chemical compounds.
This information is, generally, in the form of qualitative
rankings (e.g., resistant, poor), rather than in quantitative
form. These types of data may be supportive, but will not
be accepted as definitive proof of compatibility. In most
actual situations, a liner will be exposed to a combination
of waste types, rather than to a single chemical compound.
Consequently, the manufacturers' tests do not adequately
simulate field exposure conditions. Also, EPA is not aware
of the numerical bases used by manufacturers in establishing
their qualitative rankings. EPA must examine the raw data
from each exposure test.
Waste compatibility tests should be conducted using
representative samples of the wastes and leachates to which
the liner is, or will be, exposed. Several methods for
obtaining samples of hazardous wastes are discussed in Section
1 of Test Methods for Evaluating Solid Waste (2). Reference
8 also provides information on collecting leachate samples
(at existing facilities). For new facilities, applicants
should use leachate from an existing facility similar to the
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one proposed and/or the procedures described in Reference 11,
Solid Waste Leaching Procedure. Selection of a method depends
on the ambient physical state of the waste to be sampled (liquid,
slurry, solid). If the waste is a liquid or has a free liquid
component, this liquid is called the primary leachate and must
be included in the sample. If the waste is a solid or slurry
that does not have a free liquid component, then the procedures
given below for extracting primary and secondary leachates should
be ;employed.
The primary leachate is the liquid that can be extracted
from the waste by vacuum filtration at 25° C and 15.3 kg/cm2
(15 bars) of vacuum. It should be measured as a percentage of
the total waste on a wet weight basis. If there is one distinct
immiscible phase in the primary leachate, collect enough of each
phase (approximately 5 liters) to perform the compatibility
testing with each phase. The secondary leachate is a fluid
extracted by vacuum filtration after mixing the waste thoroughly
with just enough water to make a saturated paste (waste barely
flows together into a hole in the paste made with a spatula).
The Agency encourages applicants to include the use of
liner samples (coupons) in the liner system design. The coupons
should be separate pieces of liner material at least one foot
square, and include one field seam. The coupons are placed in
the waste management unit and later retrieved and tested to
assess liner integrity. Testing of the coupons can forewarn
permittees of liner deterioration far enough in advance so that
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remedial action may be taken before failure results in catastropic
contamination and immense costs for corrective action. The
Agency also hopes to obtain data from sites using coupons to
further the knowledge of liner integrity. See Section 5.4.7 of
Reference 4 for more details on the use of coupons.
Climatic Conditions
During the liner system design, the applicant should consider
the impacts of the local climate on the material(s) selected.
Data supporting the liner selection with regard to climate should
be submitted in the application, including:
Extremes of air temperatures at the units' location.
Depth of soil freezing including local building codes
regarding subsurface foundation construction.
Average monthly temperatures and relative humidity readings.
Maximum depth to permafrost (applicable only to sites in
Alaska).
Data regarding the proposed liners' reactions (cracking,
loss of strength, etc.) to the above conditions.
- Wind data shown as a wind rose.
The above climatic data should be available from the nearest
office of the National Weather Service. These offices are often
located at airports. Building codes can be obtained from local
county offices issuing building permits.
Liner manufacturers' data concerning the responses of the
proposed liner to the local climatic conditions should be included.
Quantitative data should be provided where available. These should
include liner strength; and resistance to tearing, puncture,
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and other failures at the range of conditions likely to be encoun-
tered. Cracking tendency is of critical importance for liners that
are to be installed in cold climates and exposed to a seasonal
freeze-thaw cycle. Manufacturers and other data should be
submitted indicating the materials' resistance to cracking.
Applicants may be able to reduce negative effects of local
climate through proper design techniques and/or selection of
materials. A liner installed entirely below the local freeze line
will not be subjected to the freeze-thaw cycle and resulting
stresses. Materials for the upper (above freeze line) portion of
a liner may be selected of one material and the lower portion of
another. However, caution should be exercised concerning waste-
liner compatibility and the ability to join dissimilar materials.
Installation Stresses
Stresses during installation can come from both below and
above the liner. The subgrade or bedding material on which the
liner is placed can exert pressure if rocks, roots, or similar
materials remain near the surface. Placement of the liner itself
and seaming techniques can stress the liner. Similarly, wind
conditions can stress the liner during installation. Action of
earthmoving equipment spreading any bedding layer above the
liner can also stress or damage a liner. The liner system design
should take into account these considerations and include the
following information:
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Whether a bedding material will be placed above or
below the synthetic liner. The thickness of this
bedding layer, the type of material used in the
bedding layer and a drawing of this layer in relation
to the placement of the synthetic layer should be
provided. Methods to prepare the bedding material
surface (discing, compaction, rolling, etc.) should
be described. An explanation of how the synthetic
liner will be protected from punctures or tears
during installation and operation should be provided
if a protective bedding layer is not proposed in the
design.
Treatment of bedding material to prevent plant growth
(sterilization) should be described.
Slope of the sides of the unit and the ability of the
sides to resist creep or slumping during installation.
Methods to be used to place bedding material over
liners, as well as specifications for the bedding
material.
The Liner System Design should thoroughly address the above
items. The application should include engineering drawings,
detailed construction specifications, and technical reports,
as necessary. More details are available in Chapter 5 of
Reference 4.
Operational Stresses
Daily operation of a surface impoundment may apply
stresses to the liner(s). The Liner System Design should
account for these stresses and minimize them. Information
in the application should include the following:
- Soils data indicating that adequate protection will
be provided to minimize operational stress.
Design considerations that will minimize liner stress.
This is particularly important for high-traffic areas
around fill points, monitoring stations, and discharge
points. Liner stress due to wind and wave action should
also be considered.
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Traffic patterns at the site, particularly near the
edges of the liner(s).
Depending on the soils, climate, and operations, the
bedding layer, surface roadways and other features may have
to be periodically thickened, regraded, compacted, or otherwise
maintained to reduce liner stress. Applicants should consider
these possibilities and include them, as appropriate.
Pressure Gradients
Pressure gradients caused by soil movement, liquids above
and below the liner(s), and gases above or below the liner(s),
may be sources of liner stress. These situations should be
considered and a liner with adequate strength and thickness
should be selected. Information in the application should
include:
Potential for the foundation to be partially lost or
deformed due to piping, sinkholes, decomposition of
organic matter, slumping, differential settlement
associated with concrete structures, and the ability
of the liner to withstand resulting stresses.
Impact of unexpected changes in water level above or
below the liner(s).
Potential for gas to be generated below or around
the liner.
In addressing information regarding internal and external
pressure gradients, the applicant should submit detailed engi-
neering reports demonstrating that the liner system will
withstand the various predicted physical stresses throughout
the active life of the surface impoundment. Geotechnical
information may be obtained from the foundation analysis.
The soils factors listed above should be considered during
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site selection and design, and applied to liner selection.
The impact of unusual water conditions should be analyzed.
Often, soil-related problems are caused by unusual water
situations (often associated with leaks through the liner).
It may be wise to assess both together in a near worst-case
scenario in the development of the Liner System Design. This
worst-case scenario should assume that there will be a leak
in the liner.
The applicant should consider potential gas pressure when
designing the liner(s). Gas may be present or generated beneath
impoundment liner(s). Sites founded on soils containing
significant amounts of organic matter have potential gas problems,
Existing units may be releasing gas to the subsurface. New
units built near existing units might be affected by this gas.
This is especially true of new hazardous waste impoundments
adjacent to sanitary landfills, either active or closed.
Surface impoundments may be susceptible to a condition known
as "whale backs." This occurs when a liner becomes buoyant
from accumulating gas or ground-water uplife and partially
floats to the surface of the impoundment. The Liner System
Design should assess the potential for such a situation
and include design features to prevent it. These may
include a series of gas vents below the liner and venting
along the impoundment sides.
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5.2.2 Liner Exemption Variance (Not Applicable to Existing
Portions)
5.2.2.1 The Federal Requirement —
Section 270.17(b)(l) contains the following:
If an exemption from the requirement for a liner
is sought as provided by §264.221(b), submit
detailed plans and engineering and hydrogeologic
reports as appropriate, describing alternate
design and operating practices that will, in
conjunction with location aspects, prevent the
migration of any hazardous constituents into the
ground water or surface water at any future time;
Section 264.221(b) states:
(b) The owner or operator will be exempted from the
requirements of paragraph (a) of this section if
the Regional Administrator finds, based on a
demonstration by the owner or operator, that
alternate design and operating practices, together
with location characteristics, will prevent the
migration of any hazardous constituents (see
§264.93) into the ground water or surface water
at any future time. In deciding whether to grant
an exemption, the Regional Administrator will
consider:
(1) The nature and quantity of the wastes;
(2) The proposed alternate design and operation;
(3) The hydrogeologic setting of the facility, including
the attenuative capacity and thickness of the
liners and soils present between the impoundment
and ground water or surface water, and
(4) All other factors which would influence the quality
and mobility of the leachate produced and the
potential for it to migrate to ground water or
surface water.
5.2.2.2 Guidance to Achieve the Part 264 Standard —
The applicant may request a variance from the requirement to
install a liner system on new units or new portions of existing
units by providing a thorough and convincing demonstration that
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the performance goals described in this section will be achieved
without an installed liner system.
5.2.2.3 Guidance to Address the Application Information
Requirement —
If an exemption from the liner requirement is being requested
for a new unit, the application should include:
- Locational determinations relevant to assessing the
potential for leachate migration, such as soil
permeability and attenuative capacities, site geology
and geohydrology.
A demonstration that facility design, locational
aspects, operating practices, closure and post-
closure care plans will prevent the contamination
of surface water and groundwater at any future time.
A suggested attachment to the permit application is Report
Supporting Request for Exemption from Liner Requirement.
5.2.3 Prevention of Overtopping
5.2.3.1 The Federal Requirement —
Section 270.17(b) requires that the Part B application
include:
Detailed plans and an engineering report describing
how the surface impoundment is or will be designed,
constructed, operated, and maintained to meet the
requirements of $264.221. This submission must
address the following items as specified in §264.221:
...(B) Prevention of overtopping:
Section 264.221(c) states:
A surface impoundment must be designed, constructed,
maintained, and operated to prevent overtopping
resulting from normal or abnormal operations,
overfilling, wind and wave action; rainfall;
run-on; malfunctions of level controllers, alarms,
and other equipment; and human error.
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5.2.3.2 Guidance to Achieve the Part 264 Standard —
The regulating language reflects the variety of potential
causes of overtopping. Constructing dikes to provide a specified
amount of freeboard above expected levels in the impoundment is
one means of controlling overtopping. Operating practices such
as adjusting inflows and outflows to regulate the impoundment
level, or using automatic level controllers or alarms, will also
help prevent overtopping when potential problems, such as
unusually large storms, occur.
The term "prevent" is absolute, reflecting the Agency's
view that outflow of liguid hazardous wastes over the top of an
impoundment, poses a serious threat to human health and the
environment. For additonal guidance, the applicant should refer
to Reference 3. Reference 3 includes discussions of "fool proof"
methods of preventing overtopping instead of reliance on an
assumed balance between evaporation and precipitation plus inflow,
5.2.3.3 Guidance to Address the Application Information
Requirements —
The application should provide design, installation and
operational data in sufficient detail to demonstrate that over-
topping will be prevented. Where practices are utilized which
differ from the guidance recommendations in Reference 3, it will
be necessary to demonstrate that the alternative practices will
provide adequate protection to prevent overtopping. A suggested
attachment to the permit application is Design of System to
Prevent Overtopping.
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Unless fool-proof controls such as weirs are employed, it
will be necessary to perform water balance studies of inflow and
outflow volumes to show that adequate freeboard is available
following a 100-year, 24-hour storm, considering normal variations
in seasonal inflow and outflow. Changes in reservoir storage
should be correlated with water level elevations in the
impoundment.
Rainfall amounts for the 100-year recurrence interval storm
are available from publications by the National Oceanic and
Atmosphere Administration. Other analyses of precipitation,
depth, duration and frequency may be available from the U.S.
Geological Survey, and state and local governmental agencies.
Methods for estimating storm and seasonal runoff volumes
from watershed areas have been developed by the U.S.D.A. Soil
Conservation Service (National Engineering Handbook 4) and the
U.S. Geological Survey in local and regional studies described
in water-supply papers, professional papers, and open-file reports.
Seasonal evaporation rates should be estimated using local
measurements of pond or lake evaporation, or accepted methods
for calculating these losses. These include methods such as
Blaney-Criddle, Thornthwaite, or Jensen-Haise, which are found
in Comparison of Methods for Estimating Potential Evapotranspir-
ation, Water Resources Series No. 59, Water Research Institute,
University of Wyoming (Laramie) 1976. The flow from diversions,
and normal and abnormal facility operations, should be documented
and considered in the water budget analysis.
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Freeboard requirements associated with waves generated by
normal and extreme wind activity should be determined if
freeboard could possibly fall to less than 60 cm. (2 ft). A
method for evaluating wave height has been presented by the
U.S. Bureau of Reclamation in Design of Small Dams (Chapter VI,
1977) .
At no time may outflow from the surface impoundment be
intentionally released into the environment. Methods for
controlling human error or equipment malfunctions should be
described. The use of emergency spillways and overflow piping,
emergency collection devices, automatic control devices, and
alarm systems is outlined in Reference 3.
5.2.4 Structural Integrity of Dikes
5.2.4.1 The Federal Requirement —
Section 270.17(b) requires that the Part B Permit Application
include:
Detailed plans and an engineering report describing
how the surface impoundment is or will be designed,
constructed, operated, and maintained to meet the
requirements of §264.221. This submission must
address the following items as specified in
§264.221: ...(C) Structural integrity of dikes:
Section 264.221(d) states:
A surface impoundment must have dikes that are
designed, constructed, and maintained with sufficient
structural integrity to prevent massive failure of the
dikes. In ensuring structural integrity, it must not be
presumed that the liner system will function without
leakage during the active life of the unit.
5.2.4.2 Guidance to Achieve the Part 264 Standard —
Dikes must be safe and stable during all phases of
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construction and operation of a surface impoundment. Dikes
are used as parts of surface impoundment facilities that are
partially or completely above ground. Similarly, surface
impoundments essentially dug into native soil are considered
to include a dike-like structure subject to the above regulations
The embankment of the impoundment serves the same purpose as a
dike (i.e., provides lateral structural support for the liner
and prevents the impounded waste from migrating over the land
surface. Therefore, these embankments should be analyzed for
structural stability at least against possible failure into
the impoundment, and also against external failure if the
impoundment is near or along a sloping surface over which the
waste could migrate after a failure. Of particular interest
is the stability of the dike to preclude failures of (1) the
end of construction (2) during steady-state seepage, (3) during
rapid drawdown, and (4) during seismic ecvents. Evaluations,
surveillance, and maintenance of dike stability are necessary
to avoid environmental, property and human damage due to
failure of the impounding structure.
5.2.4.3 Guidance to Address the Application Information
Requirement —
Elements to be considered in the design and evaluation of
dikes for stability and addressed in the application include
foundation conditions, embankment materials, liner type and
waste material, all of which are part of the dike system.
Long-term effects of various external factors such as frost,
wind, rain, and temperature, as well as man, animals, and
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vegetation should be considered. A suggested attachment to
the permit application is a Report of Structural Integrity
of Dikes.
The design and evaluation of the dikes of a surface
impoundment will require the review of the results of the
field and laboratory investigation programs, geologic evaluation
and hydrogeologic parameters for stability analyses. The
accuracy and results of analyses and evaluation of the stability
of the dikes will depend mainly on the accuracy with which
shear strength and slope conditions can be quantified.
Stability assessments should utilize in situ properties
of the dikes and foundations, and pertinent geologic information.
Foundations may present problems where they contain adversely
oriented joints, slickensided or fissured material, faults,
seams of soft materials, or weak layers.
Liquefaction of loose, saturated sands and silts may occur
under conditions of cyclic to shear deformation by earthquake
shocks (or nearby heavy construction activity). The possibility
of liquefaction of dike foundation soils must be evaluated
on the basis of empirical knowledge supplemented by special
laboratory tests and engineering calculations.
Slope failure of the dike system, in which a portion of
the dike or of an embankment and foundation moves by sliding
or rotating relative to the remainder of the mass, is the major
consideration in stability analyses. The most common methods of
analyzing slope stability include the circular arc or the sliding
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wedge methods of analysis. Other methods of analysis such as
those analyzing complex or non-circular failure surfaces may be
appropriate, depending on the type of materials, dike configuration,
subsurface conditions, and the geometry of the foundation. Many
of these methods are found in the references listed below.
Several computer programs for slope stability analysis are
available. These include "STARR" and "SLOPE8R" which are
available from the Civil Engineering Department of the University
of California, Berkeley. Slope stability may also be analyzed
using manual calculations or using slope stability charts
such as those in the first reference listed below.
The discussion and references presented in Section 5.2.4
for the liner foundation are also applicable for dike foundations,
including the subsurface exploration and laboratory testing pro-
cedures. Other references for design and evaluation and main-
tenance of small dams and dikes for surface impoundment include
the following with the first two publications considered
particularly helpful.
Design Manual: Soil Mechanics, NAVFAC DM-7.1, Naval
Facilities Engineering Command, Washington, D.C.,
May 1982.
- An Engineering Manual for Slope Stability Studies.
Duncan, J.M., and Buchignani, A.L., Department of
Civil Engineering, University of California, Berkeley,
California, 1975.
Soil Engineering, Spangler, M.G. and Handy, R.L., Harper
and Row, 1982.
- Design of Small Dams. 2nd Edition Revised, Reprinted.
U.S. Bureau of Reclamation, Washington, D.C., 1977.
GPO Stock No. 024-003-0119-8.
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- Foundation Engineering Handbook, Winterhorn, H.F., and
Fang, H.V., Van Nostrant Reinhold Co., 1975.
Closure of Hazardous Waste Surface Impoundments.
SW-873, U.S. Environmental Protection Agency, Washington,
D. C. GPA Stock No. 024-003-0119-8.
- Recommended Guidelines for Safety Inspection of Dams,
Department of the Army, Office of the Chief of Engineers,
Washington, D.C., Appendix D.
Soil Mechanics, Lambe, T.W. and Whitman, R.V., John Wiley
and Sons Inc., 1969.
The information that the applicant should develop and present
includes the following:
Topography and site conditions as required by Section
270.14(b)(19);
Subsurface soil conditions, including ground-water
levels, bedrock conditions and seismic setting of the
site as discussed in Sections 5.2.4 and 9.0 of this
manual.
— Soil borings should be made in at least two locations
along the long axis of each dike and include both dike
and foundation materials. More locations should be
sampled if soil conditions change markedly along the
dike.
— Soil borings should be made into the foundation at
least as deep as the base of the dike is wide. For
existing dikes, borings should be located along the
centerline of the crest if possible. Borings generally
need not penetrate bedrock.
— Drilling logs should be maintained and soil samples
taken at depths indicated by changes in soil type.
Field and laboratory tests should be conducted.
Field tests should include at least visual
classification and standard penetration or cone
penetration tests. Laboratory tests should include
at least density, moisture content, grain size
distribution, permeability, and shear strength tests.
Shear strength tests should be conducted to simulate
the various potential slope failure modes (e.g.,
U-U, C-U, and D tests) . Triaxial tests are recommended
rather than direct shear tests.
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Design layout, sections and details of the impoundment
and its components, including cover, dike, liner,
drainage, leak detection system, slope protection, etc.
- A description of, and the results of, stability analyses
for the following conditions:
— Foundation bearing capacity failure.
Seepage induced failure (piping).
— Slope failures
Minimum factors of safety (F.S.) should be reported
from slope stability analyses conducted for the following
failure modes.
— End of construction (proposed dikes only).
— Steady-state seepage.
Rapid drawdown.
Seismic conditions.
No single, specific, minimum Factor of Safety for slope
stability has been recommended. An acceptable Factor of Safety
depends on the confidence with which soil data are known and
the consequences of a dike failure. The matrix shown in Table
5-1 is provided as general guidance. Applicants should note
that high confidence with soil data (adequate number and depth
of soil borings, detailed soil sampling and analysis, and
high-quality shear strength tests) may result in a lower acceptable
Factor of Safety.
5.2.5 Ground-Water Protection Exemption for Double-Lined Surface
Impoundments
5.2.5.1 The Federal Requirement—
If the applicant desires exemptions from the ground-water
protection standards because he proposes a double-lined surface
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TABLE 5-1. RECOMMENDED MINIMUM VALUES OF FACTOR OF SAFETY
FOR SLOPE STABILITY ANALYSES
Consequences of
Slope Failure
Uncertainty of Strength Measurements
Small-
Large"
No imminent danger
to human life or
major environmental
impact if slope
fails.
Imminent danger to
human life or major
environmental impact
if slope fails.
1.25
(1.2) 3
1.5
(1.3)
1.5
{1.3)
2.0
or greater
(1.7
or greater)
The uncertainty of the strength measurements is smallest
when the soil conditions are uniform and high quality
strength test data provide a consistent, complete, and
logical picture of the strength characteristics.
The uncertainty of the strength measurements is greatest
when the soil conditions are complex and when the avialable
strength data do not provide a consistent, complete, or
logical picture of the strength characteristics.
Numbers without parentheses apply for static conditions and
those within the parentheses apply to seismic conditions.
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impoundment, as discussed in §§264 .222(a) , Section 270.17(c)
requires that the Part B Permit Application include:
If an exemption from Subpart F of Part 264 is sought,
as provided by §264.222(a), detailed plans and an
engineering report explaining the location of the
saturated zone in relation to the surface impoundment,
and the design of a double-liner system that incor-
porate a leak detection system between the liners;
Section 264.222(a) states:
The owner or operator of a double-lined surface
impoundment is not subject to regulation under
Subpart F of this part if the following conditions
are met:
(1) The impoundment (including its underlying liners)
must be located entirely above the seasonal high
water table.
(2) The impoundment must be underlain by two liners
which are designed and constructed in a manner
that prevents the migration of liquids into or
out of the space between the liners. Roth liners
must meet all the specifications of 264.221(a).
(3) A leak detection system must be designed, con-
structed, maintained, and operated between the
liners to detect any migration of liquids into the
space between the liners.
5.2.5.2 Guidance to Achieve the Part 264 Standard --
The design and operating standards contain special sets
of standards for surface impoundments with double liners and a
leak detection system. These standards are not mandatory.
However, if an applicant voluntarily applies for and is issued a
permit to comply with these special standards (in addition to
the other standards generally applicable to these units), then
he is not subject to the ground-water protection regulations
contained in Subpart F of Part 264. To be eligible for exemption
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from the ground-water protection requirements, a double-lined
unit (including the liner and leak detection system) must be
placed entirely above the seasonal high water table.
A leak detection system is any system (a drain and pump
or appropriate instrumentation) that enables the permittee to
detect whether any liquid has entered into the space between
the liners. This is the means by which it can be determined
if the liner has failed or is leaking. Some water may enter
the space between the liners at the time of installation.
This would occur only once, at the time of unit start-up. A
prudent permittee should remove this water immediately, since
the presence of water in the leak detection system after the
unit has begun to receive waste will be assumed to indicate
that one of the liners is leaking. Failure or leakage of the
liner requires the permittee to notify the Regional Administrator,
initiate the site contingency plan, and to either repair the
primary liner or institute ground-water monitoring pursuant to
§264 .98.
Ordinarily, a permit written for a double-lined unit seeking
an exemption from the ground-water protection requirements would
not contain any detection monitoring requirements. In that
case, if the permittee discovers a leak in the leak detection
system, he will have to repair or replace the leaking liner or
be in violation of the permit. Therefore, EPA recommends that
those who anticipate retrofitting problems in attempting to
repair or replace leaking liners should request that detection
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monitoring programs be established in their permits, in accordance
with the requirements of §264.98, as contingent requirements.
Such requirements would be automatically triggered in the event
of a leak, but would not have to complied with unless such a leak
occurred. The contingency plan within the permit would specify
monitoring well placement, detection parameters to be monitored,
and the frequency of sampling. If a leak in the top liner occurred,
the permittee would then install the wells and begin a ground-water
monitoring program in accordance with a schedule set forth in
the permit. See Reference (3) for further discussion of this
issue.
5.2.8.3 Guidance to Address the Application Information
Requirement —
A surface impoundment must not be located within the satur-
ated zone in order to qualify for this exemption. Many
fine-grained geologic formations may not meet the characteristics
of an aquifer, but may be nonetheless saturated. An impoundment
constructed in such a formation would be below the ground-water
table, and could not qualify for the exemption.
The applicant should submit the following information if he
is applying for the ground-water exemption for double-lined units.
A demonstration that the impoundment and its underlying
liners will be located entirely above the seasonal high
ground-water table. The applicant should refer to Section
9.3 of the manual for guidance on how to describe the
hydrogeologic characteristics of the facility's location.
- A demonstration that both liners satisfy the requirements
of §264 .221(a)(1). The applicant should refer to Section
5.2.1 for guidance on how to demonstrate compliance with
this standard for each liner. For those cases in which
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two different types of liner materials are to be used, a
liner integrity analysis (i.e., waste-liner capability
test) for both liners must be submitted.
- A demonstration that the leak detection system between the
two liners will be designed, constructed, maintained, and
operated to detect any migration of liquid into the space
between the liners. EPA recommends that the leak detection
system resemble a leachate collection and removal system.
If the top liner leaks, a leachate collection and removal
system will be present beneath it for immediate operation.
The applicant can refer to Section 8.2.2 for guidance on
leachate collection and and removal system design.
A suggested attachment to the permit application is a Report
Supporting Request for Exemption from Ground-Water Protection
Requirements for Double-lined Surface Impoundments.
5.3 MONITORING AND INSPECTION
5.3.1 Monitoring and Inspection During Construction and
Installation
5.3.1.1 The Federal Requirement —
Section 270.17(d) requires that the Part B Application
include:
A description of how each surface impoundment, including
the liner and cover systems and appurtenances for control
of overtopping, will be inspected in order to meet the
requirements of §264.226(a) and (b). This information
should be included in the inspection plan submitted
under §270 .14(b) (5) ;
Section 264.226(a) states:
construction and installation, liners (except in
case of existing portions of surface impoundments
r\m S 0£ A O "5 1 I a ^ ^ anH r-nvtir- cwc:t- e>m<3 ( a _n . .
(e.g
During
the
exempt from §264.221(a)) and cover systems . .„.,
membranes, sheets, or coatings) must be inspected for
uniformity, damage, and imperfections (e.g., holes,
cracks, thin spots, or foreign materials). Immediately
after construction or installation:
(1) Synthetic liners and covers must be inspected
to ensure tight seams and joints and the absence
of tears, punctures, or blisters; and
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(2) Soil-based and admixed liners and covers must be inspected
for imperfections including lenses, cracks, channels,
root holes, or other structural non-uniformities that
may cause an increase in the permeability of the liner
or cover.
5.3.1.2 Guidance to Achieve the Part 264 Standard —
Synthetic liner and cover systems must be inspected during
construction and installation for uniformity, damage and
imperfections, and after installation to insure tightness of
seams and joints, and absence of tears, punctures, or blisters.
Soil-based and admixed liners and covers must be inspected for
imperfections including lenses, cracks, channels, and root holes
or other structural non-uniformities that may adversely affect
the permeability, strength, or other engineering properties of
the liner or cover. The applicant should consult the EPA
publication on liners (Reference 3) for information on specific
inspection needs and objectives for various liners. Information
on evaluating cover systems is also available in Reference 5.
An effective quality control program will form the basis
for the inspection plan for the installation and construction of
liners. The applicant should propose a Liner Installation Quality
Control Program (QC) that addresses the proposed methods of liner
inspection, testing, and documentation. This OC Program should
be indued in the construction Inspection Plan, noted in Section
5.3.1.3. The OC Program may be developed, in part, from
manufacturer's standard inspection procedures. For example, for
a synthetic liner, it should include, but not be limited to, the
following specific provisions:
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The permittee will designate a field representative
(OC Manager) with sole responsibility for inspection
and approval of liner work. For large projects, the
permittee should provide a sufficient number of personnel
to assist the QC Manager to achieve the objectives of
the OC Program.
OC Program should include assurance that the following
objectives are met:
— The construction specifications required in the permit
are fully implemented.
— Subgrade preparation is consistent with requirements
for synthetic liner membranes.
— Handling of liner materials is performed in accordance
with manufacturer's recommended procedures.
— Manufactured liner panels, upon arrival at the project
site, are free of product defects and damage resulting
from shipping.
— Fabricated seams of prefabricated sheet membranes are
tested by airlance, vacuum, or other suitable means to
determine location of defects.
-- Liquid-applied membranes, adhesives, and solvents are
delivered in sealed containers and are used in
accordance with the manufacturer's recommendations.
— Contractor's tools are consistent with manufacturer's
recommendations; sharp instruments such as pointed
scissors are not allowed.
Field seams constructed by adhesive, heat, welding or other
means are tested by airlance, vacuum, ultrasonic or by any
combination of methods to determine the location of defects,
Placement of soil and protective cover is accomplished
so that the soil is free of deleterious materials, and
in a manner such that damage is not caused to the liner
membrane by disposal operations.
Samples of liner material, fabrication seams, and field
seams are taken routinely in sufficient number to verify
the quality of workmanship of the completed work.
Laboratory testing of field samples is conducted in
accordance with ASTM standards and procedures for synthetic
liner membranes. Results should be reviewed by the OC
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Manager and corrective action taken if materials and seams
do not meet minimum specified strengths. The permittee
should notify the Regional Administrator of such corrective
action and make all test results available for review upon
request.
- Documentation of all phases of the OC Program should be
prepared by the permittee for record purposes. Daily
reports should be maintained by the OC Manager describing
observations, activities, weather, production, contractor's
equipment, and work force specific problems. Deviations
from standard construction procedures by the contractor,
and corrective measures and changes in design should be
fully documented. Location of field samples and laboratory
test results should be made a part of program documentation.
Soil-based and admixed liners and covers must be inspected.
As-built conditions of each day's work should be recorded.
Soil-based and admixed liners and covers must be inspected
and tested to ensure that they are properly constructed according
to the approved design. The test data should consist of strength,
permeability, and other material properties of samples representa-
tive of the liner or cover to be used in construction. Actual
waste fluid or the equivalent should be used whenever appropriate
in the tests.
To ensure that the liner and cover system are constructed
according to the approved design and specifications, and to
ensure uniformity, absence of damage and imperfections, an
independent test lab and inspector supervised by a qualified,
registered engineer should be present at all phases of construc-
tion and installation to monitor and test the materials as they
are placed. Non-destructive or destructive sampling and testing
should be performed on a random basis in accordance with
established, acceptable standards. In destructive sampling and
testing, the areas sampled or tested should be restored to original
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condition immediately following the procedure. All test results
and other pertinent data, such as location, elevation, date,
climatic conditions, personnel, etc., should be documented and
kept on record.
The applicant is advised that additional general inspection
requirements are delineated in §264.15(b) of the general facility
standards. The corresponding permit information requirements
for these requirements are provided in §270,14(b)(5) . Guidance
on these overall inspection requirements will be provided in the
permit applicants' Guidance Manual for General Facility Standards,
Reference (1).
5.3.1.3 Guidance to Address the Application Information
Requirement —
The following information on inspections should be submitted
with the permit application. The applicant should include this
information in the overall facility inspection plan as required
under the General Facility Requirements. A suggested attachment
to the permit application is Construction Inspection Plan.
Describe procedures, including a quality control program,
for inspecting synthetic liners and covers during
construction and installation. The applicant should
address all inspection needs discussed above for synthetic
liners and covers.
Describe procedures, including a quality control program,
for inspecting soil-based and admixed liners and covers
during construction and installation. The applicant
should address all inspection needs discussed above for
soil-based and admixed liners and covers.
Describe procedures for assuring that dike construction
specifications are met (e.g., lift thickness, compaction,
and moisture content of dike materials).
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5.3.2 Monitoring and Inspection During Operation
5.3.2.1 The Federal Requirement
Section 264.226(b) states:
While a surface impoundment is in operation, it
must be inspected weekly and after storms to detect
evidence of any of the following:
(1) Deterioration, malfunctions, or improper operation
of overtopping control systems;
(2) Sudden drops in the level of the impoundment's
contents; and
(3) The presence of liquids in leak detection system,
where installed to comply with §264.222; and
(4) Severe erosion or other signs of deterioration in
dikes or other containment devices.
5.3.2.2 Guidance to Achieve the Part 264 Standard —
Qualified personnel must make weekly inspections of the
surface impoundment while it is in operation. Inspectiooons
should also be made after storms and earthquakes. A detailed
written inspection schedule should be developed and submitted to
the EPA for evaluation with the permit application. Detailed
guidance on inspections are provided in the Permit Applicant's
Guidance Manual for the General Facility Standards.
5.3.2.3 Guidance to Address the Application Information
Requirement —
A suggested attachment to the permit application is Operating
Inspection Plans. The following issues must be addressed to
meet the requirements for inspection [$264 .15(b)] :
(1) The owner or operator must develop and follow a written
schedule for inspection monitoring equipment, safety
and emergency equipment, security devices, and operating
and structural equipment (such as dikes and sump pumps)
that are important to preventing, detecting, or responding
to environmental or human health hazards.
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(2) The schedule must identify the types of problems
(e.g., malfunctions or deteriation) which are the
subject of the inspection (e.g., inoperative sump pump,
leaking fittings, eroding dikes, etc.).
(3) The frequency of inspection may vary for the items
on the schedule. However, it should be based on the
rate of possible deterioration of the equipment and
the probability of an environmental or human health
incident if the deterioration or malfucntion of any
operator error goes undetected between inspections.
At a minimum, the inspection schedule must include
the terms and frequencies called for in §264.226.
In addition to an overall assessment of the surface impound-
ment, the inspection records should include the maintenance and
calibration records of any control systems and leak detection
systems. All information from each inspection should be
documented and kept on record for Agency review. Some form of
checklist is recommended. It should provide for narrative com-
ments that can fully describe unusual or unexpected observations,
The inspection plan should provide for thorough examination
of the dike embankment for any signs that indicate potential
instability, maintenance deficiencies, or other conditions that
are either the result of or may lead to adverse dike performance,
Generally, the following items should be considered:
- Cracks in the crest, embankment slopes, or abutment and
toe areas.
Settlement, depressions or sink holes on the embankment
or downstream toe area.
Movement resulting in irregularities in alignment or
non-uniformity of slopes, such as slides, sloughs, or
bulges.
- Erosion by surface run-off, seepage, or irrigation on
the crest, slope abutment contact and downstream toe
area, and erosion by wave action on the upstream slope.
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Seepage on the embankment slopes, abutment and foundation
contacts, and downstream area, including boils.
Damp areas on the downstream slope, abutments and
downstream toe area.
Animal burrows, trees, and brush growth on crest, slopes,
abutment and toe areas that could cause detrimental
seepage or obstruct areas from inspection.
Conditions of upstream slope and crest paving, including
weed growth and signs of distress.
Condition of surface drainage facilities and their ability
to prevent erosion or ponding.
The spillway(s) should be inspected for the following:
Condition of the approach channel, crest, and downstream
channel areas.
Obstruction and debris at the spillway crest, or anywhere
in the channel.
- Condition of slopes above the channel that could slide
or slough, particularly during rain or spillway flow,
and deposit debris in the channel.
Signs of seepage or damp areas in the channel.
Instrumentation and monitoring points associated with the
surface impoundment should be included in the plan and the
following examined.
- Condition and accessibility of piezometers or observation
wells at the surface.
- Condition and accessibility of surface survey monuments.
Condition and accessibility of the leak detection monitor-
ing points, particularly their ability to flow freely
and to function properly. The clarity of the discharge
water should be observed to detect any material being
carried with the flow.
The inspection plan should include preparation of a report
summarizing the observations made on the condition and performance
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of the dike system, and listing those items requiring maintenance
or remedial work. This report should become part of the
operating record of the facility. Items that require special
examination in future inspections must be described. Information
on major adverse conditions, potentially adverse conditions, or
questionable conditions should be properly documented.
5.4 Dike Certification by a Qualified Engineer
5.4.1 The Federal Requirement —
Section 270.17(e) requires that the permit application
include:
A certification by a qualified engineer which
attests to the structural integrity of each dike,
as required under S264.225(c). For new units,
the owner or operator must submit a statement by
a qualified engineer that he will provide such a
certification upon completion of construction in
accordance with plans and specifications;
Section 264.226(c) states:
Prior to the issuance of a permit, and after any
extended period of time (at least six months)
during which the impoundment was not in service,
the owner or operator must obtain a certifcation
from a qualified engineer that the impoundment's
dike, including that portions of any dike which
provides freeboard, has structural integrity.
The certification must establish, in particular,
that the dike:
(1) Will withstand the stress of the pressure exerted
by the types and amounts of wastes to be placed
in the impoundment; and
(2) Will not fail due to scouring or piping, without
dependence on any liner system included in the
surface impoundment construction.
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5.4.2 Guidance to Achieve to Part 264 Standards
The certification must, at a minimum, cover two aspects
of structural integrity: (1) the force exerted on the dike by
the contents of the impoundment, and (2) the dike's resistance
to scouring and piping in the event that the liner leaks. The
former ensures that the dike will not collapse or be swept
away simply as a result of the pressure exerted against it by
its contents. The latter assures that the dike will not collapse
or be washed away if liquid begins to seep through it. While
seepage through a dike is important from the standpoint of its
inherent pollution potential, it also can cause the dike's
constituents (usually soil) to become more fluid, to move, and
to flush through, creating a hole and massive collapse. Although
evaluations of structural integrity are not foolproof, the
Agency believes that an evaluation and certification provides
an important measure of protection.
5 .4 .3 Guidance to Address the Application Information
Requirement
To demonstrate the structural integrity of the dike, the
following analyses, tests and inspections should be performed
by the qualified, registered engineer and presented in a certifi-
cation of the dike's stability. A suggested attachment to the
permit application is Dike Certification.
A review of all the geologic, geotechnical, geohydrologic
and other pertinent design, construction and service
data.
A review of all climatic data, and special geologic
events, such as earthquakes, which occur during the
entire period the impoundment was in service.
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A field inspection to detect signs of settlement,
subsidence, cracks, scouring, erosion, slides, holes,
piping, seepage, sloughing, condition of vegetation, etc.
Field measurements, including fluid levels in monitoring
wells leak detection systems, and a horizontal and verti-
cal movement survey;
Samples should be taken from monitoring wells, leak
detection systems for testing and analysis. Any electri-
cal system, pumping and all monitoring systems, leachate
collection and detection systems should be tested for
their proper functioning; any corrosion or malfunctions
should be noted and repaired;
Comparison of the measurements, inspection and testing
results to the original design; a determination of the
causes of any potentially adverse observations and
measurements. These may be supplemented with a field
investigation program such as sampling through cover,
waste, liner, and foundation soil and rocks, if
necessary; and
A determination if the original design was adequate and
a review of possible changes from parameters used in the
original design. A re-analysis based on revised parameters
and re-estimation of the remaining useful life of the
impoundment may be necessary.
Cracks, slumps, slides and other movement in the dike and at
its foundation and abutment contacts are all evidence of in-
stability. Their location, extent, pattern, and direction indi-
cate the likelihood of actual instability. Their occurrence on
the crest or slopes may warn of impending failure and signal the
engineer. Further guidance concerning appropriate inspection
activities to be conducted as part of the dike certification
procedure may be found in Section 5.3.2.3.
In addition to the field evaluations and inspections of a
dike, several other phases are involved in the evaluation and
certification of dike stability. The initial phase is the compi-
lation and review of available geotechnical and construction
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data. Depending upon the results of the data review and field
inspection, additional technical investigations may be necessary.
An evaluation of the stability of the dike system is then made
from the compiled data. If the dike is considered to be unstable,
recommendations should be made to repair or modify the structure.
If the dike is considered to be stable, a plan for future
surveillance and monitoring should be developed and included
in the application. Guidelines for the data review, reconnaissance,
investigations, engineering analysis, and continued surveillance
of dikes for stability are contained in Section 5.2.4.
The application should include all technical data and
calculations in addition to the qualified, registered engineer's
statement attesting to the stability of the dike. in the case
of new units, a statement from a qualified, registered engineer
should be provided stating that the unit will be certified upon
completion of construction.
5.5 REMOVAL OF IMPOUNDMENT FROM SERVICE
5.5.1 The Federal Requirement
Section 270.17(f) requires that the permit application
include:
A description of the procedure to be used for removing
a surface impoundment from service, as required under
§264.227(b) and (c). This information should be included
in the contingency plan submitted under paragraph (a)(7)
Section §264.227(a) through (c) state:
(a) A surface impoundment must be removed from service
in accordance with paragraph (b) of this section when:
(1) The level of liquids in the impoundment suddenly
drops and the drop is not known to be caused by
changes in the flows or into or out of the
impoundment; or
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(2) The dike leaks.
(b) When a surface impoundment must be removed from
service as required by paragraph (a) of this
section, the owner or operator must:
(1) Immediately shut off the flow or stop the addition
of wastes into the impoundment;
(2) Immediately contain any surface leakage which has
occurred or is occurring;
(3) Immediately stop the leak;
(4) Take any other necessary steps to stop or prevent
catastrophic failure;
(5) If a leak cannot be stopped by any other means,
empty the impoundment; and
(6) Notify the Regional Administrator of the problem
in writing within seven days after detecting the
problem.
(c) As part of the contingency plan required in Subpart
D of this part, the owner or operator must specify
a procedure for complying with the requirements
of paragraph (b) of this section.
5.5.2 Guidance to Achieve the Part 264 Standard
Section 264 .227(a) requires removal of an impoundment from
service when the level of liquids in the impoundment drops
suddenly and the drop is known to not be caused by changes in the
flows into or out of the impoundment. In such a case, rapid
discharge through the liner must be presumed. For example, it
may be that the liner is leaking and that channels in the under-
lying have been formed and soils are permitting rapid migration
of wastes out of the impoundment. EPA anticipates that these
circumstances will occur infrequently.
A second and probably more likely situation requiring removal
from service is a leaking dike. This indicates the potential for
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massive dike failure. The Agency believes immediate action is
necessary in the event active leakage is discovered. Minor
deterioration of the dike (e.g., erosion) which can be easily
repaired would not require the removal of the impoundment from
service.
If a surface impoundment must be partially or completely
emptied, caution should be taken in order that the dike does not
experience a rapid drawdown failure. It is recommended that the
level of the liquid generally not be lowered by more than one
foot per day; more rapid drawdown could induce a failure with
catastrophic results.
If an existing impoundment which is exempted from the liner
requirements, has experienced a sudden drop in liquid level,
then a liner that complies with §264.221 or §264.222 must be
installed prior to its return to service. Due to the possibility
of failure of the impoundment, installing a liner is absolutely
essential to ensure that substantial leakage and contact with
ground water will not occur in the future.
If the impoundment is not returned to service, §264.227(e)
requires that it must be closed in accordance with the provisions
of §264.228. This requirement is necessary to assure that the
failed impoundment is not left with liquid wastes in it for an
unnecessary period of time.
5.5.3 Guidance to Address the Permit Application Requirement
A suggested attachment to the permit application is
Contingency Plan to Remove Surface Impoundment from Service.
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The applicant should submit the following information, as a
minimum.
A description of how the wastes will be stopped from
being placed in the impoundment.
A description of emergency plans and equipment that will
be employed in order to contain any surface leakage and
stop the leak.
A description of how the impoundment will be emptied, if
necessary. This should also include an estimate of how
long it will take to empty the impoundment, where the
impounded wastes will be placed and the capacities of
on-site units that will be used for containing the
impoundment's contents. Note that on-site units that
are used only to store hazardous wastes under emergency
conditions need not be permitted under RCRA;' however, it
is recommended that they be designed, installed, and
operated in accordance with Part 264 standards.
5.6 CLOSURE AND POST-CLOSURE CARE
5.6.1 Closure of Storage Impoundments
5.6.1.1 The Federal Requirement —
Section 270.17(g) requires that the application include:
A description of how hazardous waste residues and
contaminanted materials will be removed from the
unit at closure, as required under $264.228(a)(1) .
Section 264 .228(a)(1) states:
At closure, the owner or operator must:
(1) Remove or decontaminate all waste residues,
contaminated containment system components (liners,
etc.) contaminated sub-soils, and structures and
equipment contaminated with waste and leachate,
and manage them as hazardous waste unless §261.3(d)
of this chapter applies;...
5.6.1.2 Guidance to Achieve the Part 264 Standard —
In order to close a storage impoundment, all wastes, waste
residues, contaminated system components such as liners,
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contaminated subsoils, and contaminated structures and equipment
must be removed or decontaminated. This is necessary because
no post-closure care or monitoring is required. All the removed
residues, subsoils; and equipment must be managed as hazardous
wastes unless the provisions of §261.3(d) are complied with.
If the permittee makes all reasonable efforts to comply with
the regulations (e.g., he removes or decontaminates all waste and
waste residue above the liner as well as some contaminated subsoil)
and then finds that he cannot comply with his closure plan because
he is unable to remove or decontaminate all of the remaining subsoil
he must close the unit as a disposal impoundment and perform
post-closure care. This situation is likely to occur in the case
of existing portions that do not have liners or adequate liners.
Contamination may have migrated a considerable distance from the
impoundment and possibly even entered the ground water. This
situation necessitates closure under the second alternative to
minimize the rate of migration and monitor for potential ground-
water contamination. In contrast, facilities with good liners that
do not fail will be able to avoid post-closure responsibilities.
The applicant should refer to Reference 3 and 6.
The regulations cited above establish two sets (1) things
that are hazardous wastes and (2) things that are only contaminated.
Hazardous wastes must be removed and managed as hazardous wastes.
Contaminated materials may not be polluted to such a degree as to
constitute hazardous wastes, but must be managed as such unless
they can be shown to be exempt via §261.3(d).
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The Agency has considered the degree to which a permittee
must remove or decontaminate subsoils, and so forth from storage
impoundments. It considers that the requirements of §264 .228(a)(1)
will be complied with when the remaining subsoil contains hazardous
constituents at concentrations no greater than those of the same
subsoil prior to installation of the impoundment, i.e., not
greater than background levels.
If the applicant anticipates attempts to demonstrate
compliance, he should include plans to sample and analyze subsoil
and report the results in the permit application. These plans
should indicate the location, depth, and methods to be used in
sample acquisition. The analytical results may be accepted as
the background levels that must be met as a criteria for closure
of a storage impoundment.
The Agency believes that a three-layer final cover (cap) will
adequately minimize infiltration of precipitation, which is the
primary purpose of the final cover. The final cover acts to
minimize infiltration by causing precipitation to run off through
use of slopes, drainage layers, and impermeable and slightly
permeable barriers. Other functions of the final cover include
prevention of: contamination of surface run-off, wind dispersal
of hazardous wastes, and direct contact with hazardous wastes by
people and animals straying onto the site. For guidance on an
acceptable final cover, the applicant should refer to Reference 5.
To prevent the "bathtub effect," i.e., to prevent the impound-
ment from filling with leachate after closure, the final cover
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must be no more permeable than the most impermeable component of
the liner system (or of the underlying soils). In this way, no
more precipitation is allowed to infiltrate the impoundment than
can escape through the bottom liner. Prevention of the "bathtub
effect" is important so as to eliminate the possibility of surface
overflow or migration through porous surface strata.
The final cover should be designed to accommodate pressures
resulting from gas generated within the wastes. The cover should
either withstand these pressures and retain the gases; or prefer-
ably, the gases should be safely vented to the atmosphere. The
design shall include a discussion of the potential for gas gener-
ation and include features to manage the gas. (See the discussion
about gas in Section 8.2.1.2.)
5.6.1.3 Guidance to Address the Application Information
Requirement —
A suggested attachment to the permit application is Closure
Plan for Storage Impoundment. The applicant should submit for
review a description of the fate of the hazardous wastes, contam-
inated sludges, soils, liners, and equipment at the time of closure
Such materials must either be treated or decontaminated to render
them nonhazardous, or transferred to a permitted hazardous waste
management facility capable of properly managing those materials.
The applicant should describe the specific testing that will be
used to determine if the soil liner or other components are
hazardous. The applicant should state how he is going to deter-
mine the depth to which the hazardous constituents have migrated
into any liner.
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The application should include a description of methods
to be used to remove wastes and contaminated materials, treat
hazardous waste and residues at the site, and decontaminate
equipment as appropriate. This description may include:
Methods for removing liquids, sludges, liners and
contaminated soils (e.g., excavation of soil liners
with a backhoe).
- Equipment requiring decontamination and decontamination
methods to be used (e.g., steam cleaning of backhoes).
Listings of equipment and supplies required to conduct
closure (e.g., specific chemicals, bulldozers, and vacuum
trucks) indicating those supplies and equipment currently
available at the facility.
For an existing facility, the applicant should submit a
contingency closure plan (i.e., the information that is needed
for closure of a disposal impoundment Section 5.6.2). This
requirement is for impoundments not designed in accordance with
§264.221(a) nor exempted by §264.221(b). The regulations
anticipated that some existing surface impoundments without
adequate liners will not be able to meet (economically meet) the
closure requirements for a storage facility. Such units will
then have to be closed as disposal surface impoundments with the
associated cover, ground-water monitoring, post-closure care,
etc. requirements. Therefore, applicants for existing storage
units should plan (as a contingency) how the unit will be closed
as a disposal unit. Also note that the financial assurance
requirements of the General Facilities Standards requires the
cost estimate for the contingent closure plan, not the anticipated,
normal closure plan. It was assumed that closure as a disposal
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unit would cost more than closure as a storage unit;
therefore, the higher cost is to be included for financial
assurance considerations.
5.6.2 Closure of Disposal Impoundments
5.6.2.1 The Federal Requirement —
Section 122 ,25(b)(3)(vii) requires that:
....For any wastes not to be removed from the unit
upon closure, the owner or operator must submit
detailed plans and an engineering report describing
how §264.228(a) and (b) will be complied with.
This information should be included in the closure
plan and, where applicable, the post-closure plan
submitted under §270 ,14(b)(13):
Section 264 .228(a)(2) requires the facility to:
(2)(i) Eliminate free liquids by removing liquid
wastes or solidifying the remaining waste residues;
ii) Stabilize remaining wastes to increase bearing capacity
to a sufficient degree to support final cover; and
(iii) Cover the surface impoundment with a final cover
designed and constructed to:
(A) Provide long-term minimization of the migration
of liquids through the closed impoundment;
(B) Function with minimum maintenance;
(C) Promote drainage and minimize erosion or abrasion
of the final cover;
(D) Accommodate settling and subsidence so that the
cover's integrity is maintained; and
(E) Have a permeability less than or equal to the
permeability of any bottom liner system or natural
subsoils present.
5.6.2.2 Guidance to Achieve the Part 264 Standard —
Closure of a disposal surface impoundment requires several
steps. First, free liquids must be eliminated by removing liquid
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wastes and/or solidifying the remaining waste residues. This
is an important step in minimizing the rate of leachate
migration.
Second, the remaining wastes must be stabilized to such
a bearing capacity as will support final cover, including
the top liner and earth materials placed above that liner to
protect the liner, allow the growth of shallow-rooted vegetation,
and promote drainage. Failure to do so is likely to result
in substantial differential settlement of the final cover
over time, thereby creating channels through which liquids
can enter the impoundment and eventually leach the waste
constituents into the ground water. Stabilization does not
necessarily refer to patented or other commercial processes
to fix or stabilize wastes.
Third, a final cover must be placed over the closed
impoundment. The cover must be designed and constructed to
provide long-term minimization of the migration of liquids
into the closed impoundment. In addition, the cover must
have a barrier layer with hydraulic conductivity no greater
than that of the bottom liner.
The final cover must also be designed to minimize erosion,
since erosion would result in exposure of the covered wastes
and increased infiltration. Such protection is provided by
proper sloping, cover with appropriate vegetation, and other
construction techniques. Finally, the cover must accommodate
settling and subsidence so that its integrity is maintained.
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For additional guidance the applicant should see Guide to
the Disposal of Chemical Stabilized and Solidified Wastes
(Reference 7).
5.6.2.3 Guidance to Address the Application Information
Requirement —
A suggested attachment to the permit application is Closure
Plan for Disposal Surface Impoundment. The application should
include specific information concerning free liquids and waste
stabilization as follows:
Detailed information on how free liquids will be removed
or solidified.
- Detailed plans describing how the wastes will be
stabilized.
- Results from analyses showing that the stabilized wastes
will provide sufficient, permanent support for the cover
and other expected loadings. Representative samples of
the waste, obtained as described in Reference 2 and in
Section 5.2.2.3 of this manual, should be subjected to
the stabilization/solidification technique chosen and
the product analyzed to determine its bearing strength.
The bearing strength should be shown, through engineering
calculations and supporting laboratory tests, to be
sufficent to support the maximum anticipated loadings
that could result from other wastes, the cover, and
construction equipment that will be employed to close
the facility.
- The unconfined compressive strength and consolidation
charaateristics of the stabilized waste should be
determined using ARTM method D2116-66 or the U.S.
Army's method presented in Appendix VII of Engineering
and Design - Laboratory Soils Testing, publication
number EM 1110-2-1906, or an equivalent method.
The applicant should also submit the following information:
If a design other than that defined by EPA in Reference 5
is used, submit engineering calculations to show that the
proposed cover will provide long-term minimization of
migration of liquids through the closed impoundment.
The applicant should demonstrate that infiltration is
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equivalent to or less than the cover design provided
in Reference 5. The use of the HELP model is suggested
(See Reference 9).
Demonstrate that the cover system will function
effectively with minimum maintenance. For example,
data should be provided showing that the vegetative
cover crop is adapted to regional conditions and is
able to thrive with minimal irrigation or fertilization.
Provide the following information concerning drainage
and erosion:
— Data demonstrating that the proposed slopes will
not cause significant erosion of the final cover.
(The USDA Universal Soil Loss Equation may be
used in this demonstration.) This equation is
described in Reference 5 and should be used when
proposed slopes do not conform to the Reference 5
policy.
— Description of the material in the drainage layer
of the final cover that will be used, including
the type and permeability of the material.
— Engineering calculations and designs showing that
precipitation will drain freely to the side.
— Data addressing the potential for clogging of the
drainage layer. The use of the Army Corps of
Engineers clogging criteria formulas described in
Reference 4 is recommended.
Submit the following information concerning settlement
and subsidence:
— Data addressing the potential for settlement due
to consolidation of the foundation. This analysis
should consider immediate settlement, primary
consolidation, secondary consolidation and creep,
and liquefaction. The immediate (compression)
settlement should consider the strength and elastic
properties of the foundation soils. The primary
and secondary consolidation should be estimated
based on consolidation tests performed on undisturbed
soil samples. Settlement due to creep or liquefaction
should also be estimated for the slopes and bottom
of a landfill, if the subsurface soils are susceptible
to creep or if there is a potential for liquefaction
of the foundation soils.
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— Data addressing the potential for settlement due to
consolidation of the soil-type liner. This analysis
should consider the same factors as described
above for foundation consolidation. Analysis of
settlement due to consolidation of the soil-type
liner may be similar to that for the foundation,
except that liquefaction potential for the filter
and drain materials above or underlying the liner
should also be considered in the analysis.
— Analysis of settlement due to the compression of
the impounded waste material should consider the
following conditions: dewatering of waste material,
biological oxidation of organics, and chemical
conversion of solid to dissolved waste.
— Analysis of settlement due to any further dewatering
of waste material should consider the evaporation,
drainage conditions, and fluidity and homogeneity
of the waste material. The settlement due to
consolidation under the weight of the waste and
the cover may be analyzed based on consolidation
test results performed on undisturbed representative
waste sediment samples in the impoundment. Both
primary and secondary consolidation settlement
shall be estimated. For nonhomogeneous, unsaturated,
compacted or uncompacted waste sediments, the
settlement analysis should take into consideration
stress-induced collapse of voids within the waste
material. To accommodate the amount of settlement,
the placement of the cover should be scheduled
accordingly.
— Settlement due to biological oxidation of organics
may be calculated by assuming that one (1) pound of
organic matter will be destroyed for each two (2)
pounds of oxygen consumed in the BOD test. Settlement
potential for dissolution of waste due to chemical
conversion should be tested by performing chemical
leaching on the waste materials.
— Information addressing the effects of freeze/thaw on
the integrity of the proposed cover.
— Data on the effects of subsidence/settlement on the
ability of the final cover to minimize infiltration.
Clearly document that the final cover has a permeability
less than or equal to the permeability of any bottom
liner system or natural subsoils present. This item
can simply point out permeability data for the liner
and cover systems attached to the application.
5-60
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Discussion of the effects on the final cover due to
freeze/thaw. The applicant should demonstrate that the
synthetic liner in the final cover is located wholly
below the average depth of the frost penetration in the
specific area.
The attached Closure Plan should contain the raw data,
assumptions, calculations, drawings, and specifications necessary
to support the analysis of the final cover's ability to meet the
requirements. Specifically, the design of the cover should
include:
Detailed drawing(s) of the proposed layers in the final
cover, including such items as the thickness of each
layer, and the dimensions of the cover system.
The common name, species, and variety of the cover crop
to be established.
A description of the synthetic liner that will be used
in the final cover, including the type of synthetic
liner, its chemical properties, and the manufacturer's
specifications of its physical strength and thickness.
An explanation of why the synthetic liner was selectd
should also be provided.
- Descriptions of any protective materials placed above
and below the synthetic liner and specification of the
type of material.
- Characteristics of any clay layer placed beneath the
liner in the final cover (including thickness and
permeability).
The construction plans for the clay layer.
Analysis of surface drainage and discussion of erosion
control.
Installation procedures for each layer of the cover
with emphasis on installation of the synthetic
membrane.
Specifications for the drainage layer including hydraulic
conduct ivity.
5-61
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5.6.3 Post-Closure Care of Disposal Impoundments
5.6.3.1 The Federal Requirement —
Section 264.228(b) states:
(b) if some waste residues or contaminated materials
are left in place at final closure, the owner or
operator must comply with all post-closure require-
ments contained in §§264.117 - 264.120, including
maintenance and monitoring throughout the post-
closure care period (specified in the permit under
§264.117). The owner or operator must:
(1) Maintain the integrity and effectiveness of the
final cover including making repairs to the cap
as necessary to correct the effects of settling,
subsidence, erosion, or other events;
(2) Maintain and monitor the leak detection system in
accordance with §264.222, where such a system is
present between double liner systems;
(3) Maintain and monitor the ground-water monitoring
system and comply with all other applicable
requirements of Subpart F of this part; and
(4) Prevent run-off from eroding or otherwise damaging
the final cover.
5.6.3.2 Guidance to Achieve the Part 264 Standard —
Post-closure care must be continued for 30 years after the
date of completing closure unless the Regional Administrator
establishes a different period. Post closure care consists of
maintaining the final cover and performing monitoring, and
response, as necessary, to prevent adverse impacts on human
health and on the environment. The frequency of monitoring and
maintenance activities should be balanced with the specific
factors considered in the initial closure design (i.e., climate,
waste type, soil, vegetation, etc.).
5-62
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5.6.3.3 Guidance to Address the Application Information
Requirements —
The applicant should submit a list of planned activities that
will be conducted in order to comply with the post-closure care
requirements. A suggested attachment to the permit application
is Post-Closure Care Plan. At a minimum, the plan should include
the following:
Frequency of inspection of the closed facility and what
will be inspected.
Remedial action plans describing how deterioration of
the final cover will be remedied (e.g., reestablishing
the vegetated layer).
- Frequency with which the monitoring devices will be
sampled and constituents monitored.
The design of run-on controls and the inspection of
these controls in order to prevent erosion of the
final cover.
For further guidance, the applicant is referred to EPA
Publication No. SW-867, Evaluating Cover Systems for Solid and
Hazardous Waste, September 1982, Chapter 4.
5.7 SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTE
5.7.1 The Federal Requirement
Section 270.17(h) requires that the Part B permit application
include:
If ignitable or reactive wastes are to be placed
in a surface impoundment, an explanation of how
§264.229 will be complied with;
Section 264.229 states:
Ignitable or reactive waste must not be placed in
a surface impoundment, unless:
(a) The waste is treated, rendered, or mixed before or
immediately after placement in the impoundment so
that:
5-63
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(1) The resulting waste, mixture, or dissolution of
material no longer meets the definition of ignitable
or reactive waste under §261.21 or 261.23 of this
chapter; and
(2) Section 264.17(b) is complied with; or
(b) The waste is managed in such a way that it is
protected from any material or conditions which
may cause it to ignite or react; or
(c) The surface impoundment is used solely for
emergencies.
5.7.2 Guidance to Achieve the Part 264 Standard
The regulations require the permittee to take precautions
to prevent accidental ignition or reaction of ignitable or
reactive wastes and to protect the waste from sources of ignition.
5.7.3 Guidance to Address the Application Information
Requirement
Suggested attachment(s) to the permit application are
Ignitable and/or Reactive Waste Management Plan(s). The applicant
should provide at least the following information:
Description of how ignitable or reactive wastes will
be identified when received at the site (should also
be included in the Waste Analysis Plan).
Description of the procedure for treating or mixing
the ignitable or reactive wastes before or immediately
after placement in the impoundment.
- Results of laboratory or field experiments that demon-
strate that after treatment or mixing and placement
in the impoundment, the reactive or ignitable waste
will be rendered non-reactive or non-ignitable.
Description of how §264.17(b) will be complied with
(i.e., describe what precautions will be taken to
prevent reactions which: (1) generate extreme heat
or pressure, fire or explosions, or violent reactions;
(2) produce uncontrolled toxic mists, fumes, dusts,
or gases in sufficient quantities to threaten human
health or the environment; (3) produce uncontrolled,
5-64
-------
flammable fumes or gases in sufficient quantities to
pose a risk of fire or explosion; (4) damage the
structural integrity of the device or facility, and
(5) through other like means threaten human health
or the environment).
Additional guidance on the ignitable and reactive waste
information needs is provided in Reference 1.
5.8 SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES
5.8.1 The Federal Requirement
Section 270.17(1) required that the Part B application
include:
(ix) If compatible wastes, or incompatible wastes and
materials will be placed in a surface impoundment,
an explanation of how $264.17 will be complied
with.
Section 264.230 states:
Incompatible wastes, or incompatible wastes and
materials, (see Appendix V of this part examples)
must not be placed in a surface impoundment,
unless $264.17(b) is complied with.
5.8.2 Guidance to Achieve the Part 264 Standard
The permittee must not place incompatible wastes or
incompatible wastes and materials in the same hazardous
waste facility. The purpose of this is to prevent fires,
explosions, gaseous emissions, leaching, or other discharges
which could result.
It is possible for potentially incompatible wastes to be
mixed in a way that precludes a reaction (e.g., adding acid
to water rather than water to acid) or that neutralizes them
(e.g., a strong acid mixed with a strong base), or by generating
flammable gases in a closed tank equipped so that ignition
5-65
-------
cannot occur, and burning the gases in an incinerator. If an
applicant plans to use any of these or other techniques, they
should be fully described.
The following lists are examples of potentially incompatible
wastes, waste components, and materials, along with the harmful
consequences that result from mixing materials in one group
with materials in another group. The list is intended to
indicate the need for special precautions when managing these
potentially incompatible waste materials or components. This
list is not intended to be exhaustive. A permittee must, as
the regulations require, adequately analyze his wastes so that
he can avoid creating uncontrolled substances or reactions of
the type listed below, whether they are listed below or not.
In the lists below, the mixing of a Group A material with a
Group B material may have the potential consequences as noted.
Group 1-A
Acetylene sludge
Alkaline caustic liquids
Alkaline cleaner
Alkaline corrosive liquids
Alkaline corrosive battery fluid
Caustic wastewater
Lime sludge and other corrosive
alkaklies
Lime wastewater
Lime and water
Spent caustic
Group 1-B
Acid sludge
Acid and water
Battery acid
Chemical cleaners
Electrolyte acid
Etching aciddiquid
or solvent)
Pickling liquor and
other corrosive acids
Spent acid
Spent mixed acid
Spent sulfuric acid
Potential Consequences; Heat generation; violent reaction
5-66
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Group 2-A
Group 2-B
Aluminum
Beryllium
Calcium
Lithium
Magnesium
Potassium
Sodium
Zinc powder
Other reactive metals and
metal hydrides
Potential Consequences:
Any waste in Group 1-A
or 1-B
Fire or explosion; generation of
flammable hydrogen gas.
Group 3-A
Alcohols
Water
Potential Consequences;
Group 3-B
Any concentrated waste in
Groups 1-A or 1-B
Calcium
Lithium
Metal hydrides
Potassium
So2Cl2, SOC12, PC13, CH3SiCl3
Other water-reactive waste
Fire, explosion, or heat generation;
generation of flammable toxic gases.
Group 4-A Group 4-B
Alcohols Concentrated Group 1-A or
Aldehydes 1-B wastes
Halogenated hydrocarbons Group 2-A wastes
Nitrated hydrocarbons
Unsaturated hydrocarbons
Other reactive organic compounds
and solvents
Potential Consequences; Fire, explosion, or violent reaction,
Group 5-A
Spent cyanide and sulfide
solutions
Group 5-B
Group 1-B wastes
Potential Consequences; Generation of toxic hydrogen cyanide
or hydrogen sulfide gas.
5-67
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Group 6-A Group 6-R
Chlorates Acetic acid and other
Chlorine organic acids
Chorites Concentrated mineral acids
Chromic acid Group 2-A wastes
Hypochlorites Group 4-A wastes
Nitrates Other flammable and
Nitric acid, fuming combustible wastes
Perchlorates
Permanganates
Peroxides
Other strong oxidizers
Potential Consequences; Fire, explosion, or violent
reaction.
5.8.3 Guidance to Address the Application Information
Requirement —
A suggested attachment to the permit application is Manage-
ment Plan for Incompatible Wastes. The applicant should first
determine whether incompatible wastes and/or materials will be
placed in surface impoundments by following the subsequent
steps and providing the information in the permit application:
Review the lists of incompatible wastes above and identify
any that may be received.
Identify other wastes to be disposed that are not shown
in the above lists.
Determine if any mixture of these wastes or materials
is incompatible and identify the wastes and nature
of the incompatibility. (Note: if available, the
applicant may use Reference 10, A Method for Determining
Compatibility of Waste, as an aid in determining
compatibility of wastes; however, this document should
be used with the cautions noted in Section 3.4.3.2 of
this Manual.)
If incompatible wastes and/or materials will be stored or
disposed together, the applicant must describe:
Methods for identifying these wastes as they are received
at the site.
5-68
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Step-by-step procedures for managing incompatible wastes
or material to prevent undesirable reactions or effects
defined in §264.17(b).
Laboratory or field data demonstrating that incompatible
wastes can be safely managed at the impoundment using the
proposed procedures.
5.9 REFERENCES
1. U.S. Environmental Protection Agency. Permit Applicants'
Guidance Manual for General Facility Standards. Washington,
D.C., 1984 (being drafted).
2. U.S. Environmental Protection Agency. Test Methods for the
Evaluation of Solid Waste. Physical/Chemical Properties.
SW-846. Washington, D.C., 1982. GPO Stock No. 055-002-8100-2
3. U.S. Environmental Protection Agency. Draft RCRA Guidance
Document, Surface Impoundments: Liner Systems, Final Cover,
and Freeboard Control. Washington, D.C., July 1982.
4. U.S. Environmental Protection Agency. Lining of Waste
Impoundments and Disposal Facilities. SW-870, Washington,
D.C., 1980. GPO Stock No. 055-000-00231-2.
5. U.S. Environmental Protection Agency. Draft RCRA Guidance
Document, Landfill Design: Liner Systems and Final Cover.
Washington, D.C., July 1982.
6. U.S. Environmental Protection Agency. Technical Resource
Document. Closure of Hazardous Waste Surface Impoundments.
SW-873. Washington, D.C., 1982. GPO Stock No. 055-000-00227-4
7. U.S. Environmental Protection Agency. Technical Resource
Document. Guide to the Disposal of Chemically Stabilized and
Solidified Wastes. WS-872. Washington, D.C., 1982.
GPO Stock No. 005-000-00226-6.
8. U.S. Environmental Protection Agency. Draft Solid Waste
Leaching Procedure Manual. Washington, D.C. 1983.
9. U.S. Environmental Protection Agency. User Guide for the
Hydrologic Evaluation of Landfill Performance (HELP) Model.
Washington, D.C. (to be released in 1984).
10. Hatayama, H.K. et al. A Method for Determining the Compati-
bility of Hazardous Wastes. EPA-600/2-80-076. U.S. Environ-
mental Protection Agency, Washington, D.C., April 1980.
NTIS No. PB80-221005.
5-69
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11. U.S. Environmental Protection Agency. Draft Technical
Resource Document. Solid Waste Leaching Procedure.
SW-924. Washington, D.C., 1984.
5.10 CHECKLIST
Table 5-2 is a checklist of permit application requirements
for surface impoundments. Both storage and disposal impoundments
are included. These two types are further subdivided to identify
new versus existing units and the varying reguirements, depending
on liner configuration.
The applicant is encouraged to use the checklist and to
incorporate it into the permit application. The checklist identi-
fies the application reguirements and provides references to Parts
264 and 270. The applicant should identify the location in the
application of the material addressing each requirement. Space is
provided for this. This will ensure that the application is com-
plete. As noted in Section 4.0, it is suggested that a copy of
this checklist be included as part of the permit application to aid
the reviewers. This will help them to more readily locate specific
aspects of the application and communications between reviewers and
applicants will be facilitated.
Definitions of terms used in the checklist are provided below.
Footnotes included in the checklist are explained on the last page
of the checklist.
Storage SI: Storage Surface Impoundment
Existing: A surface impoundment that was in operation
or for which construction had commenced on
or before issuance of Part B permit and which
has or will receive hazardous wastes after
January 26, 1983.
5-70
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New, Type 1: Single liner (synthetic or soil). Ground-
water monitoring reguired (g-w).
New, Type 2: Double liner, leak detection system, and above
ground water. Ground-water monitoring not
reguired.
New, Type 3: Exempt from liner reguirement. Ground-water
monitoring may not be reguired.
Disposal SI: Disposal Surface Impoundment
Existing: A surface impoundment that was in operation
or for which construction had commenced on
or before issuance of Part B permit and
which has or will receive hazardous wastes
after January 26, 1983.
New, Type 1: Single synthetic liner, ground-water monitoring
reguired (g-w).
New, Type 2: Double liner, leak detection system, and above
ground water. Ground-water monitoring not
reguired.
New, Type 3: Exempt from liner reguirement. Ground-water
monitoring may not be reguired.
An "X" in the checklist indicates that the applicant for that type
of unit must address the specific item or an eguivalent optional
item (if available) in the permit application.
An "O" in the checklist indicates that the item is optional in the
permit application. Response to an optional item may eliminate
the necessity of responding to certain items that might otherwise
be reguired.
An "e" in the checklist indicates that the item does not apply to
"existing portions" of existing units, but does apply to new por-
tions of existing units.
5-71
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A blank space in the checklist means that either the subject
requirement is general, with specific requirements listed below
it - the general subject requirement serves as a heading for
subordinates, or that the subject requirement does not
apply to that type of management unit.
5-72
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TABLE 5-2
PERMIT APPLICATION CHECKLIST FOR SURFACE IMPOUNDMENTS
co
Part 270 Part 264 Subject Requirement
270.14(b) Part B General Information Requirements
270.14(b)(l) - Genera) description of the facility
270.14(b)(2) 264.13(a) - Chemical and physical analysis of hazardous
wastes to be handled
270.14(b)(3) - Waste analysis plan
264.13(b)(l) - Analysis parameters with rationale
through (5)
- Test methods for analyzing parameters
- Procedure for collecting representative samples
- Frequency of analyses
- List and description of waste analyses to be
generator supplied
264.13(b)(6) - Waste analysis procedures for ignitable,
and 264.17(c) reactive, incompatible wastes
264.13(c) - For off-site facilities, procedures to identify
each waste movement, and
- Procedures for collecting representative
samples
270.14(b)(4) - Security description for active portion of
facility
Existing
X
X
X
X
X
X
X
X
X
X
New, Type 1^1 liner, q-w STORAGE
X
X
X
X
X
X
X
X
X
X
New, Type 2, 2 liners SI
X
X
X
X
X
X
X
X
X
X
New, Type 3. 0 liners
X
X
X
X
X
X
X
X
X
X
Existing
X
X
X
X
X
X
X
X
X
X
New^TypeJj 1 liner, g-w DISPOSAL
X
X
X
X
X
X
X
X
X
X
New, Typ_e 2, 2 liners SI
X
X
X
X
X
X
X
X
X
X
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
X
X
Location in
Application Comments
-------
Page_2
SURFACE IMPOUNDMENTS (Continued)
en
i
Part 270 Part 264 Subject Requirement
264.14(a) - Security procedures waiver justification
- Unknowing/unauthorized contact with waste
not harmful
- Unknowing/unauthorized disturbance of waste
or equipment cannot cause violation of
Part 264
264.14(b) - Description of 24-hour surveillance system, or
- Description of artificial or natural barriers,
and
- Description of controlled entry/egress
procedures , and
264.14(c) - Description of warning signs
- List of languages on signs
- Statement of 25-foot legibility
- Description of sign locations and numbers
of signs
270. 14(b)(5) - General Inspection Schedule and Procedures
Description
264.15(b)(l) - Written schedule
t
0
0
0
X
X
X
X
X
X
X
X
X
xisting
N
0
0
0
X
X
X
X
X
X
X
X
X
ew, Type 1^ 1 liner^ g-w STORAGE
N
0
0
0
X
X
X
X
X
X
X
X
X
eWj Type 2, 2 liners SI
N
0
0
0
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
E
0
0
0
X
X
X
X
X
X
X
X
X
xisting
N
0
0
0
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w DISPOSAL
N
0
0
0
X
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners SI
N
0
0
0
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
en
Part 270 Part 264 Subject Requirement
264.15(b)(2) - Statement as to where, at facility, inspection
and schedule and inspection records will be kept
265.15(d)
264.15(b)(l) - Identification of equipment/processes to be
inspected
264.15(b)(3) - Identification of types of problems each
equipment/process to be checked for
264.15(b)(4) - Frequency of inspections by equipment/process
264.15(c) - Schedule of remedial action
270.14(b)(5) and 264.15(a) and - Specific Inspection Requirements for Surface
270.17(d) 264.226 Impoundments, description of procedures for
- Inspection of liners/covers during and
immediately after installation
270.14(b)(5) and 264.15(a) and - Inspections weekly and after storms for
270.17(d) 264.226
Operation of overtopping controls
- Sudden drop in impoundment liquid level
- Presence of liquid in leak detection
system
Integrity of dikes/containment devices
Ei
X
X
X
X
X
e
X
X
X
X
-------
SURFACE IMPOUNDMENTS (Continued)
Page 4
IT.
I
CTl
Part 270 Part 264 Subject Requirement
- For new units, statement from qualified
engineer that integrity of dikes will
be certified upon construction.
Qualified engineer's certification of
dike integrity for
- Stress
- Piping/scouring
270.14(b)(6) Part 264 - Preparedness and Prevention Documentation
Subpart C
- Waiver(s) request and justification
264.32(a) - Description of internal communications/alarm
system(s)
264.34(a) - Documentation of personnel access to internal
communication/alarm system(s)
264.32(b) - Description of external communications/alarm
system(s)
264.34(b) - Documentation of personnel access to external
communications/alarm system(s)
264. 32(c) - Description of fire control/extinguishing,
spill control, and decontamination equipment
b
X
X
X
0
X
X
X
X
X
xisting
N
X
0
X
X
X
X
X
ew, Type 1, 1 liner, g-w STORAGE
N
X
0
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
0
X
X
X
X
X
ew, Type 3, 0 liners
E
X
X
X
0
X
X
X
X
X
xisting
N
X
0
X
X
X
X
X
ewj Type 1^ 1 liner^ g-w DISPOSAL
N
X
0
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
0
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
Page 5
en
i
Part 270 Part 264 Subject Requirement
264.32(d) - Documentation of adequate water volume and
pressure for above equipment
264.33 - Documentation of equipment testing/
maintenance schedule and procedures
264.35 - Documentation of adequate aisle space
264.37 (also - Documentation and descriptions of arrange-
264.52(c)) merits or attempts at arrangements with:
- Police department(s)
- Fire department(s)
- Hospitals
- Local emergency response teams
- State emergency response teams
- Emergency response contractors
- Equipment suppliers
264.37(a)(2) - Documentation of agreements designating
primary emergency authority
270. 14(b)(7) Part 264 - Contingency Plan Documentation
Subpart D
Existing
X
X
X
X
X
X
X
X
X
X
X
New, Type 1, 1 liner, g-w STORAGE
X
X
X
X
X
X
X
X
X
X
X
New, Type 2, 2 liners SI
X
X
X
X
X
X
X
X
X
X
X
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
X
X
X
Existing
X
X
X
X
X
X
X
X
X
X
X
New, Type 1, 1 liner, g-w DISPOSAL
X
X
X
X
X
X
X
X
X
X
X
New, Type 2, 2 liners SI
X
X
X
X
X
X
X
X
X
X
X
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
X
X
X
Location in
App 1 i cat i on Comments
-------
SURFACE IMPOUNDMENTS (Continued)
en
i
a
Part 270 Part 264 Subject Requirement
264.51 and - Criteria for implementation of contingency
264.52(a) plan
264.52(d) - Emergency Coordinators Identification
- Names
- Addresses
- Home/Work Phones
264.55 - Documentation of Qualifications
- Documentation of Authority
- Description of notification procedure
264. 52(e) - Emergency equipment list
- Documentation of equipment location
- Physical description of equipment
- Statement of equipment capabilities
264.52(f) - Evacuation Plan
Criteria for implementation
- Description of signal(s) to implement
E
X
X
X
X
X
X
X
X
X
X
X
X
xistinq
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w STORAGE
N
X
X
X
X
X
X
X
X
X
X
X
X
ew. Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
E
X
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w DISPOSAL
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
Page 7
tn
i
VJ
Part 270 Part 264 Subject Requirement
- Description of primary and alternate routes
264.53 - Contingency Plan Copy Location
- Description of location of facility's
copy of plan
Number of duplicate copies distributed
and their location
264.54 - Contingency Plan Amendment
- Identification of person responsible
and authorized to change/amend plan
- Description of procedure to change/amend
facility copy of plan
- Description of procedure to insure
update of all copies of plan
264.56 - Detailed Emergency Procedures
- Procedure for facility personnel
notification
- Procedure for state/local agency
notification
Procedure for identification of character,
source, amount, and area! extent of
released materials
t
X
X
X
X
X
X
X
X
X
< i s t i ng
New, Type 1, 1 liner, g-w STORAGE
X
X
X
X
X
X
X
X
X
New, Type 2, 2 liners 51
X
X
X
X
X
X
X
X
X
Ni
X
X
X
X
X
X
X
X
X
?w, Type 3, 0 liners
Existing
X
X
X
X
X
X
X
X
X
New^ Type 1^1 liner, g-w DISPOSAL
X
X
X
X
X
X
X
X
X
New, Type 2, 2 liners SI
X
X
X
X
X
X
X
X
X
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
X
Location in
Application Comments
-------
Page 8_
SURFACE IMPOUNDMENTS (Continued)
en
i
oo
o
Part 270 Part 264 Subject Requirement
- Procedure for assessment of environment/
human health hazards
- Identification of On-Scene Coordinator
for geographic area
- Description of specific responses and
control procedures for
- Fire
- Explosion
- Spill
- Description of process shutdown and
monitoring procedures
- Description of cleanup procedures and
associated material treating, storing,
disposal procedures
- Description of emergency equipment
cleaning and refitting procedures
- Description of procedures to insure
incompatible waste segregation during
cleanup
270.14(b)(7) and 264.227 - Specific Contingency Plan Requirements for
270. 17(f) Surface Impoundments
1
X
X
X
X
X
X
X
x i s t i ng
N
X
X
X
X
X
X
X
ew, Type 1, 1 liner, q-w STORAGE
N
X
X
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
ew, Type 3, 0 liners
E
X
X
X
X
X
X
X
x i s t i ng
N
X
X
X
X
X
X
X
ew, Type 1, 1 liner, q-w DISPOSAL
N
X
X
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
Part 270 Part 264 Subject Requirement
- Procedure for stopping waste addition to
impoundment
264.227 - Procedure for containing leakage
- Procedure to prevent catastrophic failure
V - Procedure for emptying impoundment
00
- Procedure for recertifying and reactivating
impoundment
- Procedure for closing impoundment
[Note: There are no §270 requirements which parallel Part 264, Subpart E.
However, the applicant should be familiar with the following sections
of the regulations since the requirements in them will be enforceable
under any permit received.
Part 264, Subpart E, §264.70 through §264.77
Part 270.30, Subpart C
The applicant should be prepared to respond to inquiries by the
permit application reviewers regarding these requirements.]
270.14(b)(8) - Preventive Procedures, Structures, and Equipment
Documentation, including description of
equipment/procedures to
- Prevent hazards during unloading operations
- Prevent water supply contamination
t
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w STORAGE
N
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
ew. Type 3, 0 liners
E
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w DISPOSAL
N
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
ew , Type 3 , 0 1 i ners
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
Page 10
CJI
i
oo
Part 270 Part 264 Subject Requirement
- Mitigate equipment failure and power outages
- Prevent undue personnel exposure to wastes
270.14(b)(9) 264.17 - Prevention of Accidental Ignition or Reaction
Documentation
- Description of separation and protection of
ignitable, reactive, incompatible wastes
- Description of ignitable, reactive,
incompatible wastes handling procedures
- Description of number, location, and type
of warning/prohibition signs
Documentation that procedures are adequate
to prevent accidental ignitions or reactions
270.14(b)(9) and 264.17(b) - Specific Ignitable/Reactive Waste Requirements
270.17(h) and for Surface Impoundments if I/R wastes
270.17(i) stored/disposed.
264.229 - Procedures that render waste nonreactive
or nonignitable, or
- Procedures for preventing reactions, and
Procedures for protecting wastes, or
- "Emergency use only" documentation
E
X
X
X
X
X
0
0
xisting
N
X
X
X
X
X
0
0
ew, Type 1, 1 liner, q-w STORAGE
N
X
X
X
X
X
0
0
ew, Type 2, 2 liners SI
N
X
X
X
X
X
0
0
ew, Type 3, 0 liners
E
X
X
X
X
X
0
xisting
N
X
X
X
X
X
0
ew, Type 1, 1 liner, g-w DISPOSAL
N
X
X
X
X
X
0
ew, Type 2L 2 liners SI
N
X
X
X
X
X
0
ew, Type 3, 0 liners
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
cr.
i
oo
to
Part 270 Part 264 Subject Requirement
264.230 - Incompatible waste segregation or
protection procedures
270. 14(b)(10) - Traffic Documentation, identification of:
Waste movement routes
- Number of movements by type vehicle
Quantity of waste moved per movement
per vehicle
Traffic control signals and personnel
Route surface composition and load
bearing capacity
270. 14(b)(ll) - Facility Location Documentation
270.14(b)(ll)(i) - Political jurisdiction identified (new
and (ii) facilities only)
Comparison to Appendix VI of Part 264
Demonstration that faults with displacement
in Holocene time are more than 3,000 feet
from facility (western states)
264.18(a) - If Holocene-time faults are within 3,000 feet,
demonstration that no faults pass within
200 feet of unit sites (western states)
E
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w STORAGE
N
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
E
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w DISPOSAL
N
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
Page 12
SURFACE IMPOUNDMENTS (Continued)
on
CO
Part 270 Part 264 Subject Requirement
270.14(b)(ll), 264.18(b) - Documentation of facility location relative
(iii) through (v) to 100-year flood plain level or wave
action flooding
- If unit in flood plain, documentation
that facility can withstand the 100-year
flood without washout by:
- Analysis of hydrodynamic/hydrostatic forces
resulting at site from 100-year flood, and
- Presentation of operating units and flood
protection devices design and how they will
prevent washout, or
- Plan for removal of waste before washout
including,
- Timing of removal relative to flood levels
- Estimated time to remove all waste
- Location to which waste will be moved
and proof of compliance with Parts 270
and 264 through 267 of this Chapter
- Detailed description of personnel,
equipment, and procedures for waste
removal sufficient to insure availability
in time for use
Existing
X
X
X
X
0
0
0
0
0
New, Type 1, 1 liner, g-w STORAGE
X
X
X
X
0
0
0
0
0
New, Type 2, 2 liners SI
X
X
X
X
0
0
0
0
0
Ni
X
X
X
X
0
0
0
0
0
»w, Type 3, 0 liners
Existing
X
X
X
X
0
0
0
0
0
N
X
X
X
X
0
0
0
0
0
sw. Type 1. 1 liner, g-w DISPOSAL
New, Type 2, 2 liners SI
X
X
X
X
0
0
0
0
0
New, Type 3, 0 liners
X
X
X
X
0
0
0
0
0
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
cri
en
Part 270 Part 264 Subject Requirement
- Analysis of potential for discharge
during waste movement
- A plan documenting how and on what time
schedule the facility will comply with
§264.18(b) if not in compliance
(existing facilities only)
270. 14(b)(12) 264.16 - Personnel Training Program Documentation
- Outline of introductory and continuing
personnel training programs
- Identification and qualifications of
program instructor
- Brief description of how training program
meets actual job tasks
- Description of procedures to insure all
appropriate personnel receive appropriate
training and receive annual training review
- Description of records to be kept, their
location, and procedures to insure they are
retained for proper length of time
270.14(b)(13) 264.112 - Closure Plan Documentation
Description of partial and final closure
procedures
E
0
X
X
xisting
N
0
X
BW, Type 1, 1 liner, g-w STORAGE
N
0
X
ew, Type 2, 2 liners SI
N
0
X
BW, Type 3, 0 liners
E
0
X
X
xisting
N
0
X
ew, Type 1, 1 liner, g-w DISPOSAL
N
0
X
ew, Type 2, 2 liners SI
N
0
X
BW, Type 3, 0 liners
Location in
Application Comments
-------
Page 14
SURFACE IMPOUNDMENTS (Continued)
Part 270 Part 264 Subject Requirement
- Description of maximum unclosed portion
during facility life
- Estimate of maximum waste inventory in
storage/ treatment during facility life
264.114 - Equipment decontamination procedure
01
oo - Estimated year of closure
en
254.113 - Description of closure schedule including
- Total time to close
270.14(b)(13) 254.113 - Trackable intervening closure activities
- Location(s) and number of copies of
closure plan
- Identification of person responsible for
storage and updating of facility copy of
closure plan
- Procedure for updating all other copies
of closure plan
270. 14(b)(13) and 264. 112 and - Specific Closure Plan Requirements for
270.17(g) 264.228(a) Surface Impoundments
- Procedures for removal and/or decontami-
nation of all wastes and materials/equipment
associated with the impoundment, or
Existing
X
X
X
X
X
X
X
X
X
X
X
New, Type 1, 1 liner, g-w STORAGE
X
X
X
X
X
X
X
X
X
X
X
N
X
X
X
X
X
X
X
X
X
X
X
sw, Type 2^ 2 liners SI
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
X
X
X
Existing
X
X
X
X
X
X
X
X
X
X
N
X
X
X
X
X
X
X
X
X
X
BW, Type 1, 1 liner, g-w DISPOSAL
N
X
X
X
X
X
X
X
X
X
X
BW, Type 2, 2 liners SI
N(
X
X
X
X
X
X
X
X
X
X
8Wj Type 3, 0 liners
Location in
Application Comments
-------
Page 15
SURFACE IMPOUNDMENTS (Continued)
I
CO
Part 270 Part 264 Subject Requirement
- Detailing plans and engineering reports
describing
- Elimination of free liquids
- Stabilization of remaining wastes
- Design of final cover demonstrating
- Liquid migration minimization
- Function with minimum maintenance
- Drainage promotion
- Erosion/abrasion minimization
- Settling/subsidence accommodation
- Permeability less than liner or
subsoils
270.14(b)(13) 264. 117 and - Post-Closure Plan Documentation
264. 118
Description of ground-water monitoring
activities and frequencies
- Description of maintenance activities
and frequencies for:
- Final containment structures
E
X
X
X
X
X
X
X
X
X
X
xi sting
t<
ew. Type 1, 1 liner, g-w STORAGE
M
ew, Type 2, 2 liners SI
N
ew, Type 3, 0 liners
E
X
X
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w DISPOSAL
N
X
X
X
X
X
X
X
X
X
X
X
X
ew. Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
00
CO
Part 270 Part 264 Subject Requirement
- Facility monitoring equipment
- Location(s) and number of copies of
post-closure plan
- Identification and location (address and
phone number) of person responsible for
storage and updating of facility copy of
post-closure plan prior to closure
- Identification and location (address and
phone number) of person responsible for
storage and updating facility copy of post-
closure plan during post-closure period
- Procedure for updating all other copies
of post-closure period
270.14(b)(13) and 264.118 and - Specific Post-Closure Plan Requirements1
270.17(g) 264.228(6) for Surface Impoundments
- Procedures for maintenance and repair of
final cover
- Procedures for maintenance and monitoring
of leak detection system
- Procedures for maintenance and monitoring
of ground-water monitoring system
- Procedures for compliance with Subpart F
Existing
X
X
X
X
X
X
X
X
New, Type 1, 1 liner, g-w STORAGE
New, Type 2, 2 liners SI
New, Type 3, 0 liners
Existing
X
X
X
X
X
X
X
X
New, Type 1, 1 liner, g-w DISPOSAL
X
X
X
X
X
X
X
X
New, Type 2, 2 liners SI
X
X
X
X
X
X
X
X
New, Type 3, 0 liners
X
X
X
X
X
X
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
Page 17
Part 270 Part 264 Subject Requirement
- Procedures for preventing run-on/run-off
final cover danage
270.14(b)(14) 264.120 - Documentation of Notice on Deed (existing
facilities only)
- Statement that land used to manage wastes
CJl
• - Statement of restricted use per §284.117(c)
^ 270.14(b)(15) 264.142 - Closure Cost Estimate
264.143 and - Documentation of a financial assurance
264.146 mechanism for closure that is one of the
following:
264.151(a) - Closure trust fund
264. 151(b) - Surety bond guaranteeing payment
264.151(c) - Surety bond guaranteeing performance
264.151(d) - Closure letter of credit
264.151(e) - Closure insurance
264.15(f) - Financial test and corporate guarantee
and (h)
- Multiple financial mechanism for one facility
t
X
X
X
X
X
X
0
0
0
0
0
0
0
xisting
N
X
X
0
0
0
0
0
0
0
ewj Type 1, 1 liner, g-w STORAGE
N
X
X
0
0
0
0
0
0
0
ew, Type 2, 2 liners SI
N
X
X
0
0
0
0
0
0
0
ew, Type 3, 0 liners
E
X
X
X
X
X
X
0
0
0
0
0
0
0
xisting
N
X
X
X
0
0
0
0
0
0
0
ew, Type 1, 1 linert g-w DISPOSAL
N
X
X
X
0
0
0
0
0
0
0
ewt Type 2, 2 liners SI
N
X
X
X
0
0
0
0
0
0
0
ewj Type 3, 0 liners
Location in
Application Comments
-------
Page 18
SURFACE IMPOUNDMENTS (Continued)
01
I
10
o
Part 270 Part 264 Subject Requirement
Single financial mechanism for multiple
facilities
270.14(b)(16) 264.144 - Post-Closure Cost Estimate1
264.145 and - Documentation of a financial assurance mechanism
264.146 for post-closure that is one of the following:
264.151(a) - Closure trust fund
264.151(b) - Surety bond guaranteeing payment
264.151(c) - Surety bond guaranteeing performance
264.151(d) - Post-closure letter of credit
264.151(e) - Post-closure insurance
264.151(f) - Financial test and corporate guarantee
and (h)
- Multiple financial mechanism for one facility
- Single financial mechanism for multiple
facil ities
270.14(b)(17) 264.147 - Documentation of Insurance
Request for variance from insurance
264.151(i) - Insurance for sudden/accidental occurrences
and (j)
E
0
X
X
0
0
0
0
0
0
0
0
X
0
X
xisting
N
0
X
0
X
ew, Type 1, 1 liner, g-w STORAGE
N
0
X
0
X
ew, Type 2, 2 liners SI
N
0
X
0
X
ew, Type 3, 0 liners
E
0
X
X
0
0
0
0
0
0
0
0
X
0
X
xisting
N
0
X
X
0
0
0
0
0
0
0
0
X
0
X
ew, Type 1, 1 liner, g-w DISPOSAL
N
0
X
X
0
0
0
0
0
0
0
0
X
0
X
ewj Type 2, 2 liners SI
N
0
X
X
0
0
0
0
0
0
0
0
X
0
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
Page 19
en
i
Part 270 Part 264 Subject Requirement
- Insurance for nonsudden/acc i dental occurrences
264.151(g) - Financial test for liability coverage
270.14(b)(18) 264.149 - Documentation of a State Required Financial2
Mechanism for Closure, Post-Closure, or
Liability including
- EPA I.D. number
- Facility name
- Facility address
- Amounts of liability coverage or funds
assured
2
264.150 - Documentation of State Assumed Responsibility
for Closure Post-Closure or Liability including
- Letter from State describing State's
responsibilities
- Facility EPA I.D. number
- Facility name
- Facility address
- Amounts of liability coverage or funds
assured
Existing
X
0
0
0
0
0
0
0
0
0
0
0
0
New, Type 1, 1 liner, g-w STORAGE
X
0
0
0
0
0
0
0
0
0
0
0
0
New, Type 2, 2 liners SI
X
0
0
0
0
0
0
0
0
0
0
0
0
New, Type 3, 0 liners
X
0
0
0
0
0
0
0
0
0
0
0
0
Existing
X
0
0
0
0
0
0
0
0
0
0
0
0
Newt Type 1, 1 liner, g-w DISPOSAL
X
0
0
0
0
0
0
0
0
0
0
0
0
New, Type 2, 2 liners SI
X
0
0
0
0
0
0
0
0
0
0
0
0
New, Type 1^ 0 liners
X
0
0
0
0
0
0
0
0
0
0
0
0
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
tn
i
ro
Part 270 Part 264 Subject Requirement
270.14(b)(19) - Topographic map showing a distance of 1,000 feet
around facility at a scale of not more than
1 inch equals 200 feet that clearly shows
- Contours
- Proper contour intervals
- Map scale and date
- 100-year flood plain area
- Surface waters and intermittent streams
- Surrounding land uses
270.14(b)(19) - Wind rose
- North orientation
- Legal boundaries of facility site
- Access control
- Injection and withdrawal wells onsite
and offsite
- Buildings and recreation areas
- Run-off control systems
Existing
X
X
X
X
X
X
X
X
X
X
X
X
X
X
New, Type 1A 1 liner^g-w STORAGE
X
X
X
X
X
X
X
X
X
X
X
X
X
X
New, Type 2, 2 liners SI
X
X
X
X
X
X
X
X
X
X
X
X
X
X
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Existing
X
X
X
X
X
X
X
X
X
X
X
X
X
X
New^Type 1, 1 liner, g-w DISPOSAL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
New, Type 2, 2 liners SI
X
X
X
X
X
X
X
X
X
X
X
X
X
X
NeWj Type 3A 0 liners
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Location in
Application Comments
-------
Page 21
SURFACE IMPOUNDMENTS (Continued)
tn
i
vo
CO
Part 270 Part 264 Subject Requirement
- Access and internal roads
- Storm, sanitary, and process sewerage systems
- Loading and unloading areas
- Fire control facilities
- Barriers for drainage or flood control
- Location of past or present operational
units and equipment cleanup areas
270.17, 270.18,
270.20 and 270.21 Part B Specific Information Requirements
270.17 - Specific requirements for Surface Impoundments
270.17(a) - List of hazardous wastes placed or to be
placed in impoundment
270.17(b) 264.221 - Detailed plans and an engineering report
describing
270.17(b)(l) 264.221(a) - Liner system construction (new only)
264.221(a)(l) - Material of construction
- Chemical properties
- Physical strength
Existing
X
X
X
X
X
X
X
e
e
e
e
N
X
X
X
X
X
X
X
X
X
X
X
sw, Type 1, 1 liner, g-w STORAGE
New, Type 2^ 2 liners SI
X
X
X
X
X
X
X
X
X
X
X
N
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Existing
X
X
X
X
X
X
X
e
e
e
e
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w DISPOSAL
N
X
X
X
X
X
X
X
X
X
X
X
ew. Type 2, 2 liners SI
Ni
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
Page 22
SURFACE IMPOUNDMENTS (Continued)
10
-p.
Part 270 Part 264 Subject Requirement
- Thickness
264.221(a)(2) - Foundation design/integrity
264.221(a)(3) - Area covered
264.221(a)(l) - Liner system integrity against (new only)
- Internal and external pressure
gradients
- Contact with waste/ leachate
- Climatic conditions
- Installation stresses
- Daily operational stresses
264.221(b) - Liner system exemption including
- Nature and quantity of wastes
- Alternative design and operation
Impoundment location description
- Hydrogeologic setting
- Attenuative capacity of materials
between impoundment and ground-
water and surface water
E
e
e
e
e
e
e
e
e
e
xi sting
N
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w STORAGE
N
X
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
ew, Type 3, 0 liners
E
e
e
e
e
e
e
e
e
e
xisting
h
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w DISPOSAL
N
X
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
I
10
en
Part 270 Part 264 Subject Requirement
- Documentation of no migration to ground/
surface waters at any future time
270.17(b)(2) 264.221(c) - Procedures/equipment to prevent
overtopping from:
- Normal operation
270.17(b)(2) 264.221(c) - Abnormal operation
- Overfilling
- Wind/wave action
- Rainfall
Run-on
- Equipment malfunctions
- Human error
270.17(b)(3) 264.221(d) - Structural integrity of dikes
270.17(c) 264.222(a) - Documentation for Part 264, Subpart F
exemption including
- Impoundment and liner location above
seasonal highwater table
- Two liners meeting §264.221(a)
requirements
Existing
X
X
X
X
X
X
X
X
X
X
New, Type 1, 1 liner, g-w STORAGE
X
X
X
X
X
X
X
X
X
X
New, Type 2, 2 liners SI
X
X
X
X
X
X
X
X
X
X
X
X
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
X
X
X
Existing
X
X
X
X
X
X
X
X
X
X
New, Type 1, 1 liner, g-w DISPOSAL
X
X
X
X
X
X
X
X
X
X
New, Type 2, 2 liners SI
X
X
X
X
X
X
X
X
X
X
X
X
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
X
X
X
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
Page 24
Part 270 Part 264 Subject Requirement
- Leak detection system between liners
270.14(c) Part 264 Part B Protection of Ground-Water Information3
Subpart F Requirements for Surface Impoundments, Waste
Piles, Land Treatment Units, and Landfills
270.14(c)(l) - Interim status period ground-water monitoring
y1 data summary
^0
0-1 270.14(c)(2) - Identification of uppermost and hydraulically
interconnected aquifers under facility including
- Water flow rate and direction
- Bases for identification
270.14(c)(3) and - Topographic map
270.14(b)(19)
- Delineation of property boundary
264.9S(b) - Delineation of waste management area
264.95(a) - Delineation of proposed point of compliance
- Ground-water monitoring well locations
- Location of aquifers
270. 14(c)(4)(i ) - Descriptions of existing contamination
through (ii)
- Delineation of plume extent
E
1
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
ew. Type 1, 1 liner, g-w STORAGE
N
(
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
E
(
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
ew. Type 1. 1 liner, g-w DISPOSAL
N
(
ew. Type 2. 2 liners SI
N
X
X
X
X
X
X
X
X
X
ew. Type 3, 0 liners
Location in
App 1 i cat i on Comments
-------
SURFACE IMPOUNDMENTS (Continued)
Page 25
Part 270 Part 264 Subject Requirement
- Appendix VIII constituents concentrations
- Concentrations throughout plume
- Maximum concentration in plume
270.14(c)(5) 264.97 - Detailed plans and an engineering report of
Ground-Water Monitoring Program
264.97(a) - Description of wells
- Number of wells
- Locations
- Depths
- Assurance of unaffected background
water measurement
- Assurance of compliance point
ground- water measurement
264.97(c) - Casing description
264.97(d) - Description of sampling/analysis procedures
- Sample collection methods
- Sample preservation/shipment
b
X
X
X
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w STORAGE
N
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
E
X
X
X
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, j-w DISPOSAL
N
ew, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
Page 26
SURFACE IMPOUNDMENTS (Continued)
Part 270 Part 264 Subject Requirement
- Analytical procedures
- Chain of custody control
264.97(e) - Documentation of proper/adequate
analytical procedures
264.97(f) - Procedure for determination of ground-
en water elevation with each sample
co 270.14(c)(6) 264.91(a)(4) - Description of Detection Monitoring Program4
and 264.98 including
270.14(c)(6)(i) 264.93 and - List of indicator parameters, waste
264.98(a) constituents, reaction products to be
monitored for, including
- Type, quantities, concentrations expected
in wastes
- Mobility, stability, persistence in
unsaturated zone
- Detectability in ground-water
270.14(c)(6)(ii) 264.98(a)(4) - Background ground-water concentration5
and (iii) and values and coefficients of variation
26498(c)(l) established by one of the following :
264.98(c)(3) - Use of an appropriate ground-water
monitoring system, and
Existing
X
X
X
X
X
X
X
X
X
0
New, Type 1, 1 liner, g-w STORAGE
X
X
X
X
X
X
X
X
X
0
New, Type 2, 2 liners SI
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
X
0
Existing
X
X
X
X
X
X
X
X
X
0
New, Type 1, 1 liner, g-w DISPOSAL
X
X
X
X
X
X
X
X
X
0
New, Type 2, 2 liners SI
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
X
0
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
en
i
Part 270 Part 264 Subject Requirement
264.97(g)(l) - Quarterly sampling of upgradient wells
for one year, or
264.97(g)(3) - Quarterly sampling of other wells for
one year, and
264.97(g)(4) - Data from a minimum of one sample/well
and minimum of four samples per
quarter, or
- Presentation of procedures to
calculate such values
270.14(c)(6)(ii) 264.98(b) - Description of an appropriate ground-water
monitoring system to be installed at the
compliance point
270.14(c)(6)(iv) 264.98(d) - Procedures for collecting semi-annual
ground-water samples at the compliance
point during
- Active life
- Closure period
- Post-closure period
264.98(e) - Procedure for annual determination of
uppermost aquifer flow rate and direction
E
0
0
0
0
X
X
X
X
X
X
-------
Page 28
SURFACE IMPOUNDMENTS (Continued)
O
o
Part 270 Part 264 Subject Requirement
264.98(f) and - Documentation of sample collection and
264.97(d) and analysis procedures
(e)
264.98(g) - Procedure for determining a statistically
significant increase for any monitored
parameter or constituent by
- Comparing compliance point data to
background value data using the
procedures in §264.97(h)(l) or (2), and
- Providing an estimate of the time
period after sampling completion
necessary to obtain results
264.98(h) - Procedure to be implemented if a
statistically significant increase in any
constituent or parameter is identified at
any compliance point monitoring well,
including
264.98(h)(l) - Written notification to Regional
Administrator
264.98(h)(2) - Sample collection and analysis methods
for all Appendix VIII constituents at
all monitoring wells
264.98(h)(3) - Method for establishing Appendix VIII
constituent background values
b
X
X
X
X
X
X
X
X
xisting
New, Type 1, 1 liner, g-w STORAGE
X
X
X
X
X
X
X
i
New, Type 2, 2 liners SI
N
X
X
X
X
X
X
X
f
BW, Type 3, 0 liners
Existing
X
X
X
X
X
X
X
X
N
X
X
X
X
X
X
X
t
BWj Type 1, 1 liner, ^-w DISPOSAL
N<
jw, Type 2^ 2 liners SI
New, Type 3, 0 liners
X
X
X
X
X
X
X
X
Location in
App 1 i cat i on Comments
-------
SURFACE IMPOUNDMENTS (Continued)
Page 29
en
i
Part 270 Part 264 Subject Requirement
264.98(h)(4) - Preparation of an application for permit
modification to establish compliance
monitoring
270.14(c)(7) 264.91(a)(l) - Description of Compl iance Monitoring Program6,
and 264.99 including
- List of wastes previously handled at facility
- Characterization of contaminated ground-water
- Hazardous constituents identified
- Hazardous constituents concentrations
264.99(b) - Description of compliance monitoring system
at the compliance point
- List of hazardous constituents to be
compliance monitored
264.96 - Proposed compliance period
264.99(d) - Procedure for collecting quarterly samples
at compliance point during compliance period
264.99(c)(3) - Procedures for establishing background
concentration values for constituents that
are based on one of the following:
Use of an appropriate ground-water
monitoring system, and
I
X
0
0
0
0
0
0
0
0
0
0
0
x i sting
N
X
0
0
0
0
0
0
ew, Type 1, i liner, g-w STORAGE
N
ew, Type 2,21 iners SI
N
X
0
0
0
0
0
0
ew, Type 3, 0 liners
E
X
0
0
0
0
0
0
0
0
0
0
0
xisting
N
X
0
0
0
0
0
0
ew, Type 1, 1 liner, g-w DISPOSAL
N
ew, Type 2, 2 liners SI
N
X
0
0
0
0
0
0
ew, Type 3, 0 liners
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Continued)
Page 3J)
ui
i
ho
Part 270 Part 264 Subject Requirement
264.97(g) - Data that is available prior to permit
issuance
- Data that accounts for measurement errors
in sampling and analysis
Data that accounts for seasonal ground-
water quality fluctuations
Data from a minimum of one sample per
well and a minimum of four samples from
monitoring system, each time system
is sampled
270.14(c)(7)(iv) 264.92 and - Proposed concentration limits for
264.99(c)(l), constituents with justification based on
(2)
- §264.94(a)(l) and §264.97(g)
- §264.94(a)(2)
- §264.94(b) and §264.99(c)(l)
264.99(e) - Procedure for annual determination of
uppermost aquifer flow rate and direction
264.99(f) - Procedures for annual testing of all
compliance point wells for Appendix VIII
constituents
264.99(g) - Documentation of all sampling and
and lysis procedures
t
0
0
0
0
0
0
0
0
0
0
0
-------
Page 31
SURFACE IMPOUNDMENTS (Continued)
CTJ
1
t—'
0
co
Part 270 Part 264 Subject Requirement
264.99(h) - Procedures for determining a statistically
significant increase for any monitored
constituent by
- Comparing compliance point data to the
concentration limit using the procedure
in §264.97(h)(2)
- Providing an estimate of the time period
after sampling completion necessary to
obtain results
264.99(1) - Procedures to be implemented if the ground-
water protection standard is exceeded at any
compliance point monitoring well, including
264.99(i)(l) - Written notification to Regional
Administrator
264.99(i)(2) - Preparation of an application for permit
modification to establish a corrective
action program, including
- Details of program to comply with
ground-water protection standard
270.14(c)(7)(v) 264.99(i)(2) - Details of ground-water monitoring to
(ii) demonstrate effectiveness of program
270.14(c)(8) 264.91(a)(2) - Description of Corrective Action Program8,
and 264.100 including
270. 14(c)(8)(i) - Characterization of contaminated ground-water
E
0
0
0
0
0
0
0
0
0
0
Kisting
N
0
0
0
0
0
0
0
0
0
sw, Type 1, 1 liner, g-w STORAGE
New, Type 2, 2 liners SI
N
0
0
0
0
0
0
0
0
0
ew. Type 3, 0 liners
Existing
0
0
0
0
0
0
0
0
0
0
New, Type 1, 1 liner, g-w DISPOSAL
0
0
0
0
0
0
0
0
0
N
ew, Type 2j 2 liners SI
New, Type 3, 0 liners
0
0
0
0
0
0
0
0
0
Location in
Application Comments
-------
SURFACE IMPOUNDMENTS (Concluded)
Part 270 Part 264 Subject Requirement
264.100(a)(l) - Identified hazardous constituents
- Concentrations of hazardous constituents
270.14(c)(8)(ii) 264. 100(a)(2) - Concentration limit for each hazardous
constituent
270.14(c)(8)(iii) 264.100(6) - Detailed plan and an engineering report
describing the corrective actions to be taken
at the compliance point
264.100(c) - Time period necessary to implement
corrective action program
270.14(c)(8)(iv) 264.100(d) - Description of ground-water monitoring
program that will be sufficient to assess
the adequacy of corrective action
264.91(a)(3) - Description of the corrective action to be
and 264. 100(e) taken for constituents in ground-water
between compliance point and downgradient
facility boundary
264.100(g) - Procedure and content for semi-annual ly
submitting written reports to the Regional
Administrator on program effectiveness
Part 8 Certification and Signatories
270 ll(d) - Certification paragraph
270. ll(a) - Appropriate signatory
Existing
0
0
0
0
0
0
0
0
X
X
New, Type 1, 1 liner, g-w STORAGE
0
0
0
0
0
0
X
X
New, Type 2, 2 liners SI
X
X
New, Type 3, 0 liners
0
0
0
0
0
0
X
X
Existing
0
0
0
0
0
0
0
0
X
X
Ni
0
0
0
0
0
0
X
X
ew, Type lt 1 liner, g-w DISPOSAL
New, Type 2, 2 liners SI
X
X
New, Type 3, 0 liners
0
0
0
0
0
0
X
X
Location in
Application Comments
-------
FOOTNOTES FOR SURFACE IMPOUNDMENTS
^Notwithstanding the fact that the applicant intends to remove
all wastes at closure, an existing storage surface impoundment
that does not have a liner meeting the Part 264 liner require-
ments and has not received a variance will be required to
present plans to cover the impoundment at closure in the event
that all hazardous material cannot be removed.
2state-specific. Contact State or Regional EPA representatives
to discuss requirements.
3New, Type 3 units are not automatically exempt from ground-water
protection standards of Subpart F. Applicants are subject to
indicated requirements unless a §264.90(b)(4) waiver has been
granted.
^Applies to new facilities and existing facilities at which con-
tamination has not been detected.
^Existing facilities must submit interim status ground-water
monitoring data including background data for certain parameters.
If no data are available, contact appropriate State or Regional
EPA personnel.
^Required of existing facilities where ground-water monitoring
data indicates the presence of hazardous constituents. New or
existing units without contamination may have a proposed Com-
pliance Monitoring Program included in the permit on "stand by"
under some circumstances.
^Applicable to existing facilities with indications of hazardous
constituents in the ground water.
^Applicability to existing facilities will be case-by-case/ based
on monitoring data indicating ground-water contamination. New
Type 1 and Type 3 units and existing units without contamination
may have Corrective Action Plans in permit on "stand by" under
some circumstances.
5-105
-------
-------
SECTION 6.0
WASTE PILE PERMIT APPLICATION GUIDANCE
The regulations promulgated in Part 264 apply 'to waste piles
used to treat and/or store hazardous waste. They apply to both
new and existing waste management units and distinguish between
these units in appropriate circumstances. Part 264, Subpart L
contains the design and operating standards.
Waste piles may not be used to intentionally dispose of
wastes. If the owner or operator of a pile wishes to dispose of
wastes, he must apply for a landfill permit and manage the pile
as a landfill.
The regulatory goal adopted in the design and operating
standards is to minimize the formation and migration of leachate
to the adjacent subsurface soil or ground water or surface water.
To this end, unless exempted, units must have liners to prevent
migration of wastes to the subsurface soil or to ground water
and surface waters during the active life of the unit. Waste
piles are also required to have leachate collection and removal
systems. A variance from the liner and leachate collection
requirements is available to units if applicants demonstrate
that wastes will never migrate to ground water or surface water.
In addition, existing portions of units are exempt from these
requirements. This section is divided into ten subsections:
6.1 Waste Description
6.2 Design and Operating Requirements
6.3 Monitoring and Inspection
6-1
-------
6.4 Exemption to Liner Standard and Ground-Water Protection
Standard
6.5 Treatment of Waste
6.6 Special Requirements for Ignitable or Reactive Wastes
6.7 Special Requirements for Incompatible Wastes
6.8 Closure
6.9 References
6.10 Checklist
6.1 WASTE DESCRIPTION
6.1.1 The Federal Requirement
Section 270.18(a) requires that the Part B Application
include:
A list of hazardous waste placed or to be placed in
each waste pile.
A related standard, Section 270.13(j), requires that the
application include:
A specification of the hazardous wastes listed or
designated under 40 CFR Part 261 to be treated, stored,
or disposed at the facility, an estimate of the quantity
of such wastes to be treated, stored, or disposed
annually, and a general description of the processes to
be used for such wastes.
A second related standard, Section 270.14(b)(2), requires
that the application include:
Chemical and physical analyses of the hazardous wastes
to be handled at the facility. At a minimum, these
analyses shall contain all the information which must
be known to treat, store, or dispose of the wastes
properly in accordance with Part 264.
6.1.2 Guidance to Achieve the Part 264 Standard
Section 264.13(a) requires the applicant to gather the data
that must be submitted to comply with the above application
6-2
-------
requirements. The Permit Applicants' Guidance Manual for General
Facility Standards (Reference (1)) provides detailed guidance on
waste analyses and waste analysis plans.
Under Section 270.18(a) the applicant is required to
submit a list and physical description of the wastes that have
been or will be placed in each waste pile. The source of the
data gathered to comply with this requirement will vary from site
to site. For example, the facility's records of analyses
performed on the waste before the effective date of these
regulations, or studies conducted on hazardous waste generated
from processes similar to that which generated the waste to be
managed at the facility, may assist in complying with this
requirement.
Under Part 270.18(a) the applicant is required to submit a
list and physical description of the wastes that have been or
will be placed in each waste pile. The source of the data gathered
to comply with this requirement will vary from site to site.
For example, the facility's records of analyses performed on the
waste before the effective date of these regulations, or studies
conducted on hazardous waste generated from processes similar to
that which generated the waste to be managed at the facility,
may assist in complying with this requirement. The permittee of
an off-site facility may obtain part or all of the information
required standard from the generator. If the generator does not
supply the information, and the permittee chooses to accept a
hazardous waste, the permittee is responsible for obtaining the
information required to comply with this section.
6-3
-------
In addition, §264.13(b)(4) requires that additional waste
analyses be conducted during the operating life of the facility
with sufficient frequency to ensure that the analysis is accurate
and up to date.
6.1.3 Guidance to Address the Application Information Requirement
The following information should be reported for each waste:
- Common name of waste
EPA hazardous waste ID number
Location(s) within the waste pile where the waste is or
will be located
Volume of waste received per month including actual or
estimated averages, maximum or minimums
Form of the waste when disposed (e.g., containerized,
bulk solid, etc.)
Approximate moisture content, texture, and other signifi-
cant features
- Special handling requirements
For guidance in this matter the applicant is referred to
Part 261, which includes regulations for identifying hazardous
wastes. These regulations include definitions, criteria for
identifying the characteristics of hazardous waste and for listing
hazardous wastes, characteristics of hazardous waste, and lists of
hazardous waste. In addition, appendices address representative
sampling methods and EP toxicity procedures. The sampling and
analytical methods applicable to identifying the constituents of
hazardous wastes are also described in EPA publication SW-846,
Test Methods for the Evaluation of Solid Waste, Physical/Chemical
Parameters [Reference (2)]. A suggested attachment to the permit
applications is the List of Hazardous Wastes.
6-4
-------
6.2 DESIGN AND OPERATING REQUIREMENTS
This section provides guidance on the permit application
information requirements related to the design and operating
requirements in §264.251. Topics discussed include the following:
6.2.1 Liner Performance Standards
6.2.2 Leachate Collection and Removal System
6.2.3 Liner and Leachate Collection System Exemption
6.2.4 Control of Run-On
6.2.5 Control of Run-Off
6.2.6 Management of Units Associated with Run-On and Run-
Off Control Systems
6.2.7 Control of Wind Dispersal
6.2.8 Ground-Water Protection Exemption for Double-Lined
Piles
6.2.9 Ground-Water Protection Exemption for Piles with
Inspectable Liners
6.2.1 Liner Performance Standards
6.2.1.1 The Federal Requirements—
Section 270.18(c) requires that the Part B application
include:
Detailed plans and an engineering report describing how
the pile is or will be designed, constructed, operated
and maintained to meet the requirements of §264.251.
This submission must address the following items as
specified in §264.251:
(1) The liner system (except for an existing portion of a
pile). If an exemption from the requirement for a
liner is sought, as provided by §264.251(b), the owner
or operator must submit detailed plans and engineering
and hydrogeologic reports as appropriate, describing
alternate design and operating practices that will, in
conjunction with location aspects, prevent the migration
of any hazardous constituents into the ground water or
surface water at any future time;
6-5
-------
(2) Control of run-on;
(3) Control of run-off;
(4) Management of collection and holding units associated
with run-on and run-off control systems; and
(5) Control of wind dispersal of particulate matter,
where applicable.
Facility Standard 264.251(a)(1) states:
(a) A waste pile (except for an existing portion of a
waste pile) must have:
(1) A liner that is designed, constructed, and installed
to prevent any migration of wastes out of the pile
into the adjacent subsurface soil or ground water or
surface water at any time during the active life
(including the closure period) of the waste pile.
The liner may be constructed of materials that may
allow waste to migrate into the liner itself (but not
into the adjacent subsurface soil or ground water or
surface water) during the active life of the facility.
The liner must be: (1) Constructed of materials that
have appropriate chemical properties and sufficient
strength and thickness to prevent failure due to
pressure gradients (including static head and external
hydrogeologic forces), physical contact with the waste
or leachate to which they are exposed, climatic
conditions, the stress of installation, and the stress
of daily operation.
(ii) Placed upon a foundation or base capable of
providing support to the liner and resistance to
pressure gradients above and below the liner to
prevent failure of the liner due to settlement,
compression, or uplift.
(iii) Installed to cover all surrounding earth likely
to be in contact with the waste or leachate.
6.2.1.2 Guidance to Achieve the Part 264 Standard —
The basic performance goal for waste pile liner designs
is that they prevent the release of hazardous constituents
to ground and surface waters through closure. Subpart L of
6-6
-------
Part 264 covers only waste piles from which all wastes,
waste residues, containment system components (e.g., liners),
and contaminated subsoils will be removed at closure. Waste
piles from which these will not be removed at closure are regula-
ted as landfills under Subpart N.
In accordance with §264.251(a), a waste pile liner system
must be designed, constructed, and maintained to prevent, through
scheduled closure, the migration of hazardous constituents from
the pile to the surrounding environment. The liner may be con-
structed of materials that may allow waste or hazardous
constituents to migrate into the liner, but must not allow migra-
tion through the liner into the adjacent subsurface soil or
ground or surface water during the active life of the pile. In
addition, EPA has recommended that liner systems be constructed
wholly above the seasonal high water table, that is, in the
unsaturated zone.
The design and operating standards contain an exemption for
"existing portions." An existing portion is any area of a waste
pile identified in a Part A permit application on which waste
has been placed at the time of permit issuance. However, existing
portions are subject to the remainder of the design and operating
requirements, as well as the ground-water protection requirements.
The exemption applies only to existing portions of existing
units. New portions of existing units are not entitled to the
exemption.
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In developing this guidance, the Agency has attempted to
come as close as possible to complete containment for the life
of the waste piles. However, the Agency also considered that
designs based on this guidance be based on conventional
technology, utilize readily available equipment and materials,
and be constructed at reasonable cost.
Essentially complete temporary containment is practical
using synthetic liners. However, experience with synthetic liners
in contact with chemicals is relatively recent. Predictions
based on chemistry, and limited, recent field experience are
sufficient to convince the Agency that, with proper selection
for chemical resistance, design, installation, and operation,
containment for at least 30 years is practical utilizing a
single, synthetic liner. Therefore, a single, synthetic liner
system may be appropriate for waste piles which will complete
closure in less than 30 years.
Soil liners, in contrast to synthetic liners, may become
saturated with leachate and eventually release hazardous
constituents. However, predictions can be made on the flow time
of leachate through soil liners. Therefore, if the soil used
possesses appropriate properties, is properly placed, and is of
sufficient thickness, soil liners can be expected to provide
containment for the life of the waste pile. Thus, because Subpart
L requires the removal of all wastes and liners (including soil
liners), and any contaminated subsoils at closure, the intent
is that no hazardous constituents should be released to ground
water.
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A third option for waste piles is a single base of admixed
materials such as concrete or asphalt. Such bases must be thick
enough to be structurally stable. A structurally stable base is
one which is not prone to cracking or crumbling under the conditions
to which it will be exposed. Appropriate base materials should
be chosen in consideration of the specfic waste anticipated to
be stored or treated in the pile and proposed operating techniques.
For waste piles which will not close within 30 years and
which incorporate a synthetic membrane, the Agency suggests a
double liner incorporating a top synthetic liner and a secondary
soil (clay) liner. With the double liner system, if the primary
synthetic liner deteriorates in the future, the secondary soil
(clay) liner will minimize transmission of leachate. Natural
materials such as clay are not prone to deterioration over time
and should function indefinitely unless physically damaged or
affected by chemical constituents. Liners of admixed materials
such as concrete or asphalt may also be used for long-lived waste
piles when an analysis of the chemistry and physics of the
application indicates that the liner will not deteriorate and
lose function during the pile life.
In addressing the requirements, the following key points should
be kept in mind:
Liner systems should be constructed wholly above the
seasonal high water table, i.e., in the unsaturated soil
or above grade;
As a minimum, the liner system should consist of a single
liner of soil (clay), synthetic material, or admixed
material;
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- Where a synthetic liner is used under any pile that will
not complete closure for 30 or more years after the first
placement of wastes, the liner system should consist of
the primary synthetic liner and a secondary soil liner,
such as clay.
- All waste piles must have a leachate collection and
removal system installed above the primary liner (except
for waste piles with exemption from the leachate collection
and removal system requirement).
A wide range of materials are available for the construction
of liners for hazardous waste piles, with the most common being
clay soil and synthetic liners. The liner must be constructed
of materials that will resist degradation. Synthetic liners can
be degraded by exposure to incompatible wastes or leachate and
in some cases by excessive exposure to sunlight. Clay liners
can develop highly increased permeabilities (sometimes by several
orders of magnitude) when exposed to certain types of chemicals.
Chemical testing of liners is prudent because liners can be
degraded by certain wastes and waste constituents. Because
wastes and the chemical characteristics of liners are almost
infinitely variable, it is difficult to generalize concerning
incompatibility. The Agency, therefore, prefers test data as
the way to demonstrate the compatibility of waste and liner
materials, but recognizes that historic data or theoretical
chemistry may provide sufficient information in some cases. The
EPA's Office of Research and Development in Cincinnati, Ohio
is currently developing a summary of waste/liner compatibility
information. Data currently available to EPA indicate that the
following combinations of waste types and liner materials are
often incompatible:
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Polyvinyl chloride (PVC) can be dissolved by chlorinated
solvents;
- Chlorsulfonated polyethylene can be dissolved by aromatic
hydrocarbons;
- Clays can exhibit permeability changes when exposed to
selected concentrated organics;
- Asphaltic materials can dissolve in oily wastes;
- Concrete and lime based materials are dissolved by acids;
and
Clays can exhibit permeability changes increase or decrease
when exposed to inorganics of high and low pH.
An acceptable test method for evaluating waste/liner
compatibility is included in Appendix B of the Draft RCRA Guidance
Document, Waste Piles - Liner Design (Reference 3). The test
method exposes a liner sample to the waste or leachate encountered
at the pile. After exposure, the liner sample is tested for
important characteristics—saturated hydraulic conductivity in
the case of soil liners; strength (tensile, tear, and puncture),
weight loss, and hydraulic conductivity in the case of synthetics.
The Agency considers any significant deterioration in any of the
measured properties to be evidence of incompatibility unless a
convincing demonstration can be made that the deterioration
exhibited will not impair the integrity of the liner over the
life of the pile. Even though test results may show the amount
of deterioration to be relatively small, the Agency is concerned
about the accumulative effects of exposure over time.
Synthetic liners should consist of at least a 0.76 mm
(30 mil) membrane that is chemically resistant to the waste
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managed and the leachate generated. In judging chemical
compatibility of wastes and liners, the Agency will consider
appropriate historical data, demonstrations involving theoretical
chemistry and actual test data. Testing of chemical resistance
of liners should be performed using either the EPA test method
or an equivalent test method.
Soil liners should have a hydraulic conductivity which will
not increase beyond 1 x 10~7 cm/sec as a result of prolonged
contact with the waste and leachate generated. Testing of the
effect of leachate on soil liner hydraulic conductivity should
be performed using either the EPA test method or an equivalent
test method.
Liner materials must have sufficient strength and thickness
to prevent failure due to physical stresses (e.g., earth-moving
equipment, dredging equipment, and the weight of large volumes
of liquid wastes). While this requirement applies to all liners,
it is especially crucial for synthetic liners, which can rupture
if they are mishandled or are too thin. Most synthetic liners
should be at least 0.76 mm (30 mils) thick to assure this
requirement is met.
The foundation beneath the liner must be capable of support-
ing the liner and waste material and resisting pressure gradients,
If the support system settles, or suffers uplifts, the liner
may rupture or crack. The existence of organics or soluble
material in the foundation could result in the generation of
gases and the creation of voids beneath the liner. Locations of
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waste piles should be selected to avoid these situations or
foundation designs .should account for them.
6.2.1.3 Guidance to Address the Application Information
Requirements —
Liner selection and design is one of the most difficult
aspects of waste pile design. The liner serves as the primary
barrier to leachate migration. It must be chemically compatible
with this leachate/ and strong enough to resist tearing during
installation and operation. The nature of the liner foundation
is an integral part of liner design. To address the application
information requirements for liner system design, the applicant
is advised to submit information on the following three areas:
Liner Specifications
- Foundation Analysis
Liner Integrity Analysis
A suggested attachment to the permit application is Liner
System Design. The attachment should contain detailed specifica-
tions, raw data, calculations, drawings, assumptions, and so on,
supporting the proposed design. A discussion of the rationale
supporting the overall design should be included in the basic
portion of the application. The discussion should present the
reasons why and how the design meets the specific requirements.
6.2.1.3.1 Liner Specifications — The applicant should
identify the materials of construction, and specifications of
strength, thickness, and chemical properties of the proposed
liner. The applicant should also submit design plans that show
the method of liner placement. This should demonstrate that the
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liner will cover all areas of the unit that will be exposed to
wastes and leachate.
The applicant is responsible for all aspects of the appli-
cation including material specifications. The liner material
specifications can be taken from specifications provided by
the manufacturer as long as the applicant proposes these as the
minimum acceptable specifications. The Liner Integrity Analysis
section describes the nature of engineering reports to justify
the selected liner strength, thickness, and chemical compatibility,
Appendix VIII of Reference (5) can be used to obtain the minimum
values of physical properties of a synthetic liner that are
necessary to produce a quality liner material.
The liner design plans should be in standard construction
drawing format. The plans should show the extent of areal cover-
age for each waste pile unit. The plan should also present
cross-sectional views. Details of seaming methods, anchoring,
and other special features should be provided in the plans and in
narrative form. See Appendix D for liner guide specifications.
6.2.1.3.2 Foundation Analysis — The soils beneath a liner
support the liner, waste, and cover. If these soils settle,
shear, or uplift, the liner may be damaged. Hydrostatic and
gas pressure can also impact on liner performance. The potential
for these situations to occur at a given location can be reliably
assessed by a geotechnically qualified, registered engineer. In
many cases, standard engineering practices can be implemented to
alleviate a potential for liner deflection.
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The foundation analysis should be a report, included in the
Liner System Design attachment, that assesses the potential for
liner deflection due to settlement, compression, shear, or
uplift of the foundation soils, and due to hydraulic and gas
pressures on the liner. The following items should be considered
in this report:
Geologic Data. A description should be provided of
regional and site geology, including:
— Geologic setting
— Soil types and characteristics (including boring
logs)
— Bedrock types and depths (including boring logs)
— Subsidence history
— Sinkhole potential
[Note that much of this information is also recommended in
Section 9.0. of this manual.]
- Geotechical Data. A description should be provided of
the engineering characteristics of the foundation soils.
Data on soil index properties, shear strength, hydraulic
conductivity, and compressibility should be provided.
- Hydrogeologic Data. A description should be provided of
the characteristics of the saturated zone of the site,
including its relationship to surface water. Section
9.0 can be used for further guidance on this topic.
- Seismic Setting. A description should be provided on the
potential for ground shaking and surface response at the
site. While the facility may not be in a jurisdiction
in which the seismic location standard [§264.18(a)l is
applicable, it is advisable to design a facility to
withstand a design earthquake. Many regions of the
country that have experienced earthquake activity should
have information on their frequency and magnitude, and
may even have established local standards for the design
of structures. Generally, earth structures can be easily
designed to withstand the vertical and horizontal accel-
erations experienced during such design earthquakes.
Specific seismic design consideration should be given to
structures used to shelter waste piles.
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The report should summarize the foundation investigation
and analysis. It should include all data collected during the
investigation, all calculations performed during the analysis,
and a description of the methods used in the investigation and
analysis. Total and differential settlements that can occur dur-
ing the active and closure period of the unit should be estimated,
including immediate settlement, primary and secondary consolidation,
creep, and liquefaction. Bearing capacity and stability of
the foundation should be evaluated.
The subsurface investigation should thoroughly characterize
the in situ properties of the subsurface materials. Subsurface
exploration should consist of test borings and test pits, and
may also include geophysical surveys.
Test borings should be performed to adequate depths and at
a sufficient number of locations to define the subsurface condi-
tions. The method of drilling should be based on a preliminary
subsurface investigation. Test pits should be excavated to
identify near-surface conditions. Geophysical surveys may be
performed to more accurately identify bedrock depths and fractured
zones. Other types of geotechnical tests (i.e., cone penetrometer,
vane shear, standard penetration) may be performed, as required,
for the specific conditions at the site. Many standard techniques
for geotechnical investigations are available in Sampling of Soil
and Rock, American Society for Testing and Materials (ASTM)
Special Technical Publication 483, June 1970, and Subsurface
Exploration and Sampling of Soils for Civil Engineering Purposes,
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M. Juul Hvorslev, Army Corps of Engineers, Waterways Experiment
Station, 1965. The subsurface investigation program can be
combined with the investigations undertaken in response to the
ground-water monitoring and aquifer identification requirements
in 264 Subpart F.
Laboratory testing of subsurface materials should be con-
ducted to determine index properties and engineering parameters.
Index property testing should include:
- Grain size distribution curves
Atterberg limits
Specific gravity
Moisture content and dry density
Shear strength of soils may be determined using direct shear,
triaxial, or unconfined compression testing, as appropriate for
the soil condition. The methods for saturated hydraulic con-
ductivity determination described in Reference 4 (Method 9100)
should be used; in most cases, hydraulic conductivity (often
referred to as permeability) should be determined using field
methods, rather than laboratory techniques. The compressibility
characteristics should be determined by performing a sufficient
number of consolidation tests.
6.2.1.3.3. Liner Integrity Analysis— The integrity of a
liner is a function of several factors. Incompatible chemicals
can dissolve the liner. Excessive stress during either installa-
tion or operation can cause tears or broken seams. Climate can
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also adversely affect a liner. It is critical that a liner be
carefully selected to be compatible with the wastes it must
contain. The liner must also have adequate strength to resist
tearing during installation. It must be protected from punctures
by a bedding layer. Normally, the leachate collection system,
can be the protective layer for the top of the liner; a bedding
layer beneath the liner is also needed. Seaming techniques are
extremely important as well. Finally, the liner should have
sufficient strength to resist failure from any anticipated or
likely settlement or movement of the foundation.
The applicant should submit a detailed report that demon-
strates the integrity of the liner against:
Contact with waste/leachate (i.e., waste-liner compati-
bility
Internal and external pressure gradients
Climatic conditions
Installation stresses
- Daily operational stresses
Waste-Liner Compatibility
The applicant should submit results of compatibility
testing. These results should demonstrate the acceptability of
the selected synthetic liner. The following information should
be provided on the tests used to make the compatibility demon-
strations:
Name of the test method used.
- Procedure and details of the test method (e.g., number
of test specimens, length of the test, and the nature of
leachate used).
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Chemical and physical characteristics of the waste(s)
tested, including the EPA hazardous waste number, physical
class (e.g., aqueous-inorganic, aqueous-organic; organic,
solid, sludge, etc.), and waste sources (including
description of production and waste treatment processes
from which the waste stream is generated).
Raw test results.
- An explanation of how the raw test results were inter-
preted to lead to the selection of the synthetic liner
proposed as the primary liner for the landfill.
An acceptable test method for examining compatibility of
wastes/leachate and synthetic liners is the "Immersion Test of
Membrane Liner Materials for Compatibility with Wastes," found
as Method 9090 in Reference 2. An earlier form of this test was
published as Appendix A in the July 1982 draft of the RCRA
Technical Guidance Document entitled Landfill Design; Liner
Systems and Final Cover (Reference 4).
Liner manufacturers commonly provide information on the
compatibility of their liners with single chemical compounds.
This information is generally in the form of qualitative rankings
(e.g., resistant, poor), rather than in quantitative form. These
types of data may be supportive, but will not be accepted as
definitive proof of compatibility. In most actual situations,
a liner will be exposed to a combination of waste types, rather
than to a single chemical compound. Consequently, the manu-
facturers' tests do not adequately simulate field exposure
conditions. Also, EPA is generally unaware of the numerical
bases used by manufacturers in establishing their qualitative
rankings. Therefore, EPA must examine the raw data from the
exposure test.
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Waste compatibility tests should be conducted using
representative samples of the wastes and leachates to which the
liner is, or will be, exposed. Several methods for obtaining
samples of hazardous wastes are discussed in Section 1 of Test
Methods for Evaluating Solid Waste (2). Reference (11) also pro-
vides information on collecting leachate samples. Selection of
a method depends on the ambient physical state of the waste to
be sampled (liquid, slurry, solid). If the waste is a liquid
or has a free liquid component, this liquid is called the primary
leachate and must be included in the sample. If the waste is a
solid or slurry that does not have a free liquid component, then
the procedures given below for extracting primary and secondary
leachates should be employed.
The primary leachate is the liquid that can be extracted from
the waste by vacuum filtration at 25° C and 15.3 kg/cm2 (15 bars)
of vacuum. It should be measured as a percentage of the total
waste on a wet weight basis. If there is more than one distinct
immiscible phase in the primary leachate, collect enough of each
phase (approximately 5 liters) to perform the compatibility
testing with each phase. The secondary leachate is a fluid
extracted by vacuum filtration after mixing the waste thoroughly
with just enough water to make a saturated paste (waste barely
flows together into a hole in the paste made with a spatula.
The Agency encourages applicants to include the use of liner
samples (coupons) in the liner system design. The coupons should
be separate pieces of liner material at least one foot square and
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include one field seam. The coupons are placed in the leachate
collection system sump and later retrieved and tested to assess
the liner's integrity. Testing of the coupons can forewarn
permittees of liner performance far enough in advance of failure
that remedial action may be taken before failure results in
catastrophic contamination, and immense corrective action costs.
The Agency also hopes to obtain data from sites using coupons to
further the knowledge of liner integrity. See Section 5.4.7 of
Reference 5 for more details on the use of coupons.
As discussed above, the applicant should submit data on
physical classification of the waste with the compatibility test
description and results. The following is a brief description of
the physical classes of waste. Aqueous-inorganic (AI) and
aqueous-organic (AO) are classes of waste in which water is the
solvent (predominant liquid), and the solutes are mostly other
organic chemicals dissolved in the organic solvent. Solids,
sludges, and slurries (S) are wastes high in solids such as
tailings, settled matter, or filter cakes.
Climatic Conditions
During liner system design, the applicant should consider
impacts of the local climate on the material(s) selected. Data
supporting liner selection with regard to climate should be sub-
mitted in the application and include:
Extremes of air temperatures at facility location.
Depth of soil freezing including local building codes
regarding subsurface foundation construction.
- Average monthly temperatures and relative humidity
readings.
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Maximum depth to permafrost (applicable only to sites in
Alaska).
- Data regarding the proposed liner's reactions (cracking,
loss of strength, etc.) to the above conditions.
The above climatic data should be available from the nearest
office of the National Weather Service. These offices are often
located at airports. Building codes can be obtained from local
county offices that issue building permits.
Liner manufacturers' data concerning the responses of the
proposed liner to the local climatic conditions should be
included. Quantitative data should be provided where available.
These should include the liner's strength, resistance to tearing
and puncture, and other failures as the range of conditions
likely to be encountered. The tendency of liners to crack is
a particularly important consideration for those that are to be
installed in cold climates and thus exposed to a seasonal freeze-
thaw cycle. Manufacturers' and other data should be submitted
indicating the materials' resistance to cracking.
Applicants may be able to reduce the negative effects of the
local climate through proper design techniques and/or selection of
materials. A liner installed entirely below the local freeze line
will not be subjected to the freeze-thaw cycle and resulting
stresses. Materials for the upper (above freeze line) portion of
a liner may be manufactured of one material and the lower portion of
of another. However, caution should be exercised concerning waste-
liner compatibility and the ability to join dissimilar materials,
and evidence of adequate strength must be presented.
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Installation Stresses
Stresses during installation can come form both below and
above the liner. The subgrade or bedding material on which the
liner is placed can exert pressure if rocks, roots, or similar
materials remain near the surface. Placement of the liner
itself and seaming techniques can stress the lines. Action of
earth-moving equipment spreading a bedding layer above the liner
and installation of a leachate collection system can also stress
or damage a liner. The liner system design should take into
account these considerations and include the following information:
State whether a bedding material will be placed above
or below the synthetic liner. The thickness, the type
of material used, and a drawing of the bedding layer in
relation to the placement of the synthetic layer should
be provided. Methods to prepare the bedding material
surface (discing, compaction, rolling, etc.) should be
described. An explanation of how the synthetic liner
will be protected from punctures or tears during install-
ation and operation should be provided if a protective
bedding layer is not proposed in the design.
Treatment of bedding material to prevent plant growth
(sterilization) should be described.
Slope of the sides of the unit and the ability of the
sides to resist creep or slumping during installation.
Methods to be used during liner installation to minimize
stress and damage, including detailed techniques for
field seaming.
Methods to be used to place bedding material over the
liner and specifications for the bedding material.
The liner system design should thoroughly address the above
items. This should include engineering drawings, detailed
construction specifications, and technical reports, as necessary.
More details are available in Chapter 5 of Reference 5.
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Operational Stresses
Daily operation of the waste pile will apply stresses to the
liner(s). The Liner System Design should account for these
stresses and minimize them. Information in the application should
include the following:
Overall layout and filling sequences of the unit(s).
Traffic patterns at the site, particularly near the edge
of the liner(s) and in the portions of the wastepile
closest to the liner.
Soils data indicating that adequate protection will be
provided to minimize operational stresses.
Design considerations that will minimize liner stress.
Specific, technical soils data can be taken from the
foundation analysis portion of the Liner System Design. Design
and operational factors should minimize stress. The waste pile
could be designed for sequential filling, with one portion completely
filled before starting another. The second area may have a
different entrance and exit, thus reducing traffic stress at the
original entrance and exit.
Depending on the soils, climate, and operations, the bedding
layer and/or surface roadways, and so forth, may have to be thick-
ened, recompacted, and graded periodically, and otherwise main-
tained to reduce liner stress. Applicants should consider these
possibilities and include them, as appropriate.
If an inspectable liner is planned, operational plans should
protect the integrity of the liner. Methods planned for waste
removal and liner inspection must be described. The methods
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used should not damage the liner to the point where it will not
fulfill its operational requirements. Particular care must be
exercised at points where movement of equipment will be concentrated,
such as at the edges of the waste pile or at entrances and exits.
Pressure Gradients
Sources of liner stress other than the above may also be
present. These include pressure gradients caused by soil movement,
water, or gases either above or below the liner(s). These situa-
tions should be considered and a liner with adequate strength and
thickness selected. Information in the application should include:
Potential for the foundation to be partially lost or to
become deformed due to piping, sinkholes, decomposition of
organic matter, slumping, and so on, and the ability of
the liner to withstand such stresses.
Impact of unexpected changes in water levels above or
below the liner(s) such as leachate temporarily deeper
than one foot due to heavy storms.
Potential for generation of gas within the waste contained
or present outside the liner.
In addressing information regarding internal and external
pressure gradients, the applicant should submit detailed engineer-
ing reports demonstrating that the liner system will withstand the
various physical stresses throughout the active life of the land-
fill. Soil-related information may be obtained from the analysis.
The soils factors listed above should be considered during site
selection, design and permit application, and applied to liner
selection. The impact of unusual water conditions should be
analyzed. Often, soil-related problems are caused by unusual
water situations. It may be wise to assess both together in a
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near worst-case scenario in the development of Liner System
Designs.
The applicant should consider potential gas pressures when
designing the liner(s). Gas pressure could develop above, below,
and possibly between liners (in a double-lined waste pile). Gases
may be generated in the wastes via anaerobic decomposition of
organic matter, yielding methane and carbon dioxide (landfill
gas), or via other mechanisms. These gases normally migrate to
the surface and vent to the atmosphere. However, gas can migrate
laterally and/or accumulate in localized areas resulting in
pressure on the liner(s). Gases within the waste may transport
hazardous constituents. If vented to the atmosphere, these gases
may require treatment prior to release.
External gas pressure should also be considered. Gas may be
present or be generated beneath a landfill's liner(s). Sites
located in soils containing significant amounts of organic matter
have potential gas problems. Existing units may be releasing gas
to the subsurface. New units built near existing units might be
affected by this gas. This is especially true of new hazardous
waste landfills adjacent to sanitary landfills, either active or
closed.
6.2.2 Leachate Collection and Removal System
6.2.2.1 The Federal Requirement —
Facility Standard 264.251(a)(2) states that a waste pile
for an existing portion of a waste pile) must have:
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A leachate collection and removal system immediately
above the liner that is designed, constructed, maintained,
and operated to collect and remove leachate from the pile.
The Regional Administrator will specify design and operating
conditions in the permit to ensure that the leachate depth
over the liner does not exceed 30 cm (one foot).
The leachate collection and removal system must be:
(1) Constructed of materials that are:
(A) Chemically resistant to the waste managed in the
pile and the leachate expected to be generated.
(B) Of sufficient strength and thickness to prevent
collapse under the pressures exerted by overlying
wastes, waste cover materials, and by any equipment
used at the pile.
(ii) Designed and operated to function without clogging
through the scheduled closure of the waste pile.
6.2.2.2 Guidance to Achieve the Part 264 Standard
6.2.2.2.1 Maximum head of leachate — To minimize the
potential for release of hazardous constituents during the regu-
lated unit's active life, waste piles (except for existing
portions) must have a liner and leachate collection and removal
system. To reduce pressure head on the liner, the leachate
collection and removal system must be designed and operated to
assure that leachate depth over the liner does not exceed one
foot. The Agency believes that it is practical to design a
leachate collection and removal system to maintain leachate
depth of 30 cm (1 ft.) or less, except perhaps temporarily during
severe storms.
Perhaps the simplest leachate collection system is a series
of swales in the liner of waste piles, when using a concrete or
asphaltic liner. The liner itself can be slightly sloped, with
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shallow swales to collect any leachate. The swales could be
interconnected, with the leachate directed to a holding facility,
sump, tank, or surface impoundment. Since the leachate is considered
a hazardous waste, it must be stored or treated in a permitted
facility.
Other applicable systems are related to those used in land-
fills. For such systems, the Agency recommends that the system
be constructed of a sand or gravel that is at least 30 centimeters
(12 inch) thick with a hydraulic conductivity not less than 1 x
10~3 cm/sec and a minimum slope of 2 percent. For additional
guidance and rationale for the design of the leachate collection
and removal system the applicant should refer to Reference (4).
See Figure 8-1 for a generalized diagram of a liner and leachate
collection system applicable to waste piles.
6.2.2.2.2 Chemical Resistance — All leachate collection
and removal systems must be designed so they will continue to
function throughout the active life of the pile. They must be
capable of withstanding the chemical attack that can result from
contact with leachate. The leachate from waste piles is likely
to be chemically corrosive to many materials. Construction
materials, especially for the perforated collection pipes, must
resist deterioration for the reguired operational lifetime.
This means that the applicant must have knowledge of the materials
included in the waste piles, and also of possible interactions
that can occur with the mixing of heterogeneous materials. It
is also important to take into consideration the chemical effect
of leachate on the pumps to be used for leachate removal.
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6.2.2.2.3 Strength and Thickness — The pipe used in the
collection system must be of sufficient strength and thickness
to withstand the pressure exerted by the weight of the overlying
materials and any equipment to be used on the waste piles. The
pipe under consideration is either a rigid conduit, such as
concrete and cast iron, or a flexible conduit, such as plastic
and fiberglass. Because of the probable corrosive properties of
the leachate, plastic or fiberglass are usually the materials of
choice. However, there are cases where solvents might be generated
which would preclude the use of these latter materials.
Leachate collection pipes beneath waste piles are generally
installed in a protective bed of porous material. Perforations
will reduce the effective strength of pipe available to carry
loads and resist pipe deflection under loading. In addition,
the capacity of buried pipe to support vertical stresses may be
limited by buckling and by the circumferential compressive strength
of the pipe. Deflection, buckling capacity and compressive
strength may be obtained from the pipe manufacturer, but should
also be calculated for the specific case. A pipe correctly
designed to withstand loading from a waste piles can fail from
equipment loading received during construction or operation.
This loading factor is based on the vertical distance between
the loaded surface and the top of the pipe. Moving loads cause
impact loading which may have twice the effect of stationary
loads. These loads must be considered when choosing pipe material,
designing the collection system, and specifying installation
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techniques. Appendix V of Reference 5 includes methods to
calculate these factors.
The leachate collection system should be thick enough to
protect the collection and removal pipes. It should also serve
as a sump into which leachate drains and is stored prior to and
during removal. The leachate system should have a storage capacity
such that leachate drains into the system and is removed fast
enough so that the wastes are not standing in leachate. Thus,
the thickness of the system will depend on factors such as
precipitation, control of run-on, and liquid content of the
wastes.
6.2.2.2.4 Prevention of Clogging — The leachate collection
and removal system may be overlain by a graded granular or
synthetic fabric filter as necessary. The purpose of this is to
prevent clogging of the pores in the drainage layer of the
collection system by infiltration of fine particles from the
waste. If a granular filter is used, it is important that the
relationship of grain sizes of the filter medium and the drainage
layer be appropriate if the filter is to fulfill its function to
prevent clogging of the drainage layer and not to contribute to
clogging. EPA guidance specifies a criterion for this purpose
which is widely used in construction to prevent clogging
(blinding) of drainage media. The criterion was developed by
the U.S Army Corps of Engineers and is used in their engineering
manuals.
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If pipes are used in the leachate collection system,
perforations in the pipes should be sized to be compatible with
the particle size of the bedding material in the drainage layer.
If the perforations are very large compared to grain size of the
bedding material, the latter may wash into the collection system
and be removed along with the leachate. For additional guidance
on the design of the collection and removal system the applicant
should refer to References (4), (5), and (6).
6.2.2.3 Guidance to Address the Application Information
Requirement —
The applicant should provide engineering reports and detailed
drawings to support the proposed design of the leachate collection
and removal system. A suggested attachment to the permit applica-
tion is Leachate Collection and Removal System Design. It should
contain the raw data, assumptions, calculations, plans, and
specifications for the system. The basic portion of the applica-
tion should contain a demonstration of how the proposed system
meets the requirements of §264.253.
6.2.2.3.1 Overall System Design — The applicant should
provide detailed drawings of the collection and removal systems.
These include construction details sufficient to actually build
the system and thus assess its adequacy. Specifications for
materials to be used and construction techniques should also be
included and the following provided:
Overall system layout, extent, slopes, design of sumps,
spacing of pipies, location of pumps and other ancillary
equipment.
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- Specific information on proposed collection pipes,
including materials, size, wall thickness.
- Calculations that show compliance with the requirement
that no more than one foot of leachate will exist above
the liner except during storms. (Reference 12)
6.2.2.3.2 Chemical Resistance — The leachate collection
system will likely be in the most hostile environment in the waste
pile. It must continue to operate even though attacked by
solutions of hazardous wastes. Thus, compatibility of the pipes,
pumps, and other features with the expected leachate is imperative,
Data must be provided indicating that the system will survive the
chemical attack of the leachate.
Manufacturers' data may be based only on exposure to one type
of waste. Better information may come from operating hazardous
waste sites handling similar wastes and using the types of
materials proposed. Chemical properties of the leachate and the
materials should be presented along with results of any long-term
exposure tests.
6.2.2.3.3 Strength and Thickness — The applicant should
submit engineering design calculations that demonstrate that the
proposed colleciton system is of sufficient strength and thickness
to withstand the pressures exerted by the weight of the overlying
landfill, waste cover material, and any equipment to be used in
the construction or operation of the landfill. The design calcu-
lations should take into account the loads acting on the pipes,
the perforation in the pipes, deflection of the pipes caused
by the loads, and the buckling capacity and compressive strength
of the pipes.
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The thickness of the system should also be shown. Rationale
for the design of the thickness should be presented. (See
Appendix V of Reference 5.)
6.2.2.3.4 Prevention of Clogging — The applicant should
provide information including engineering drawings, specifications,
and calculations that demonstrate the ability of the collection
system to function without clogging through the scheduled closure
of the landfill. Include information about the drainage layer
proposed and any proposed filter or pipes. See Reference 4 for
assistance in the selection of grain sizes for filters or bedding
materials.
6.2.3 Liner and Leachate Collection System Exemption
6.2.3.1 The Federal Requirement —
Part 270.18(c)(l) states:
If any exemption from the requirement for a liner is
sought, as provided by §264.252(b), the owner or operator
must submit detailed plans and engineering and
hydrogeologic reports as appropriate, describing
alternate design and operating practices that will, in
conjunction with location aspects, prevent the migration
of any hazardous constituents into the ground water or
surface water at any future time.
Facility Standard 264.252(b) states:
(b) The owner or operator will be exempted from the
requirements of Paragraph (a) of this section if the
Regional Administrator finds, based on a demonstration
by the owner or operator, that alternate design and
operating practices, together with location character-
istics, will prevent the migration of any hazardous
constituents (see §264.93) into the ground water or
surface water at any future time. In deciding whether
to grant an exemption, the Regional Administrator will
consider.
(1) The nature and quantity of the waste:
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(2) The proposed alternate design and operation:
(3) The hydrogeologic setting of the facility, including
attenuative capacity and thickness of the liners and
soils present between the pile and ground water or
surface water, and
(4) All other factors which would influence the quality and
mobility of the leachate produced and the potential for
it to migrate to ground water or surface water.
6.2.3.2 Guidance to Achieve the Part 264 Standard —
A variance from the liner and leachate collection and removal
requirements is provided if the applicant demonstrates to the
Regional Administrator that hazardous constituents will never
migrate from the pile into ground water or surface water. This
may be due to location aspects, local geology and hydrology,
waste characteristics, and other circumstances. The variance may
be obtained from any units or portions thereof that are not
existing portions.
6.2.3.3 Guidance to Address the Application Information
Requirement —
If an exemption from the liner and leachate collection and
removal system requirement is being requested for a new unit, the
application should provide:
Locational determinations relevant to assessing the
potential for leachate migration, such as soil
permeabilities and attentuation capacities, site geology
and geohydrology; and
A demonstration that facility design, locational aspects,
and operating practices will prevent the contamination of
surface water and ground water at any future time.
A suggested attachment to the permit application is a Report
Supporting Request for Exemption from Liner and Leachate Collection
and Removal System Requirement.
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6.2.4 Control of Run-On
6.2.4.1 The Federal Requirement —
Section 270.18(c) requires that the Part B Application
information include:
(c) Detailed plans and an engineering report describing
how the pile is or will be designed, constructed,
operated and maintained to meet the requirements of
§264.251. This submission must address the following
items as specified in §264.251:...
(1) Control of run-on.
Facility Standard 264.251(c) states that to minimize the
leachate generation:
The owner or operator must design, construct, operate,
and maintain a run-on control system capable of preventing
flow onto the active portion of the pile during peak
discharge from at least a 25-year storm.
6.2.4.2 Guidance to Achieve the Part 264 Standard —
One of the key elements of EPA's strategy for ground-water
protection at waste piles is a liquids management program. This
program is intended to minimize leachate generation in the units,
primarily by keeping liquids out of the piles. One aspect for
limiting the generation of leachate is the requirement that owners
or operators control run-on to the unit. The run-on control
system must be capable of preventing flow onto the active portion
of the pile during peak discharge from at least a 25-year storm.
6.2.4.3 Guidance to Address the Application Information
Requirement —
To demonstrate that run-on onto the active portion of the
pile during peak discharge from at least a 25-year storm will not
occur, the applicant should accomplish the following and submit
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the results for review and approval. A suggested attachment to
the permit application is Run-On Control System Design. The
following information and analyses should be submitted:
- A description of the hydrologic method used to estimate
peak flow rates including its source and justification
for its use in waste pile design/-
All data and input parameters used in conjunction with
the selected hydrologic method and their sources;
All calculations for estimating peak flow rates including
a discussion and justification of any necessary
assumptions;
- All hydraulic calculations and designs for sizing the
necessary collection and conveyance facilities (standard
hydraulic techiques and for determining flow capacities,
including allowance for freeboard, shall be used).
Structural designs of collection and conveyance facilities
and results of all field tests to ensure compatibility
with soils and foundation conditions (standard structural
design techniques, safety factors, and appropriate field
tests shall be used).
- A maintenance plan for ensuring the structural integrity
of the collection and conveyance facilities along with a
plan for restoration and repair in the event of a washout
failure.
- To maintain.capacity of the system, a plan for dewatering
any collection or holding facilities associated with run-
on control systems should be prepared.
6.2.5 Control of Run-Off
6.2.5.1 The Federal Requirement —
Section 270.18(c) requires that the Part B Application
information includes:
Detailed plans and an engineering report describing
how the pile is or will be designed, constructed,
operated and maintained to meet the requirements of
§264.251. This submission must address the following
items as specified in §264.251:...
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(3) Control of run-off.
Facility Standard 264.251(d) states that to minimize hazards
from run-off of contaminated liquid:
The owner or operator must design, construct, operate,
and maintain a run-off management system to collect and
control at least the water volume resulting from a
24-hour, 25-year storm.
6.2.5.2 Guidance to Achieve the Part 264 Standard —
The Agency interprets the run-off regulations in the
following ways:
Run-off from active portions of units will generally be
a hazardous waste, because it is presumed to contain
leachate. Leachate is generally considered to be a
hazardous waste under §261.3(a). However, the permittee
has the right to demonstrate that the collected liquid
consists only of precipitation run-off for which the
mixture rule in §261.3(b)(2) does not apply. Units used
to hold hazardous liquids should meet the applicable
Part 264 permitting standards (i.e., Subpart K for surface
impoundments, Subpart J for tanks, etc.). Run-off quality
should be monitored.
Run-off from fully closed (e.g., capped) units is generally
not a hazardous waste, because it has not drained through
waste or mixed with leachate. This run-off need not be
collected, but it should be managed in a manner designed
to protect the final cover as stipulated in §§264 .228(b)(4)
and 264 .310(b)(5) . It should be noted, however, that it
is useful to monitor closed-area run-off quality to
detect leachate seepage through the cap. Units used to
hold collected closed-area run-off need not meet the
permitting standards associated with the unit type,
unless the run-off is a hazardous waste.
Run-off from portions of a facility that are not part of
an active waste pile (undeveloped or unassociated areas)
need not be collected in the run-off management systems
required under $§264 .251(d) , 264.273(d), and 264.301(d).
Run-off volume can be calculated using the methods in the
U.S. Department of Agriculture, Soil Conservation Service,
National Engineering Handbook 4.
Collection and conveyance structure designs can be deter-
mined using the methods in the U.S. Department of Agricul-
ture, Soil Conservation Service, National Engineering
Handbook 5: Hydraulics (7).
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- The magnitude of the 24-hour, 25-year storm can be deter-
mined by using the data available in the National Oceanic
and Atmospheric Administration, Technical Publication 40,
with Regional revisions.
Of the three types of run-off from waste piles (active
area, closed area, and underdeveloped/unassociated area), the
Agency is most concerned with active area control. Precipitation
falling on exposed hazardous wastes can dissolve or transport
waste constituents. At typical waste piles, precipitation
run-off and leachate are likely to mix at the toe of the active
face or other low points.
If the permittee does not initially manage active area run-
off as a hazardous waste, then he has the continuing obligation
to determine whether the liquid meets the definition of a hazardous
waste. Run-off is not a listed waste because the "derived from"
rule in §261.3(c)(2) does not apply. As a result, run-off will
only be considered a hazardous waste if it exhibits one of the
characteristics associated with hazardous wastes as outlined in
40 CFR Part 261 Subpart C (§261.3) or if it mixed with leachate
or another hazardous waste. Three considerations, however,
suggest that it should be easier for the permittee to assume the
run-off to be a hazardous waste. First, the practical burden of
conducting the waste analysis is likely to outweigh any ultimate
benefit incurred as a result of avoiding initial treatment of the
run-off as a hazardous waste. Second, testing itself will be
difficult because collected run-off cannot be managed easily in
batch form; liquid is added to and removed from run-off collection
basins continuously. Third, an initial assumption that run-off
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is hazardous will save the problem of transferring the liquid from
a nonpermitted unit to a permitted unit when the liquid is found
to be hazardous.
The collection system must be emptied expeditiously after
storms to maintain its capacity. The rate and extent of fluid
removal are site-specific factors. It might not be necessary to
completely drain the system as long as there is sufficient
capacity to collect fluid from the 24-hour, 25-year storm. If
the fluid is managed in a Subpart K surface impoundment, the
impoundment must be designed to prevent overtopping.
The nature of fluid quality monitoring is also a site-specific
matter. If the fluid is not presumed to be a hazardous waste (see
above), monitoring must determine whether it meets the definition
of hazardous waste. If, on the other hand, the fluid is presumed
to be a hazardous waste and managed in appropriate units, monitor-
ing should be based on whatever information is needed to manage
those units.
The interim status standards for run-off management at exist-
ing facilities are found at §265.253 for waste piles. If the
leachate or run-off from a waste pile is a hazardous waste, then
either the run-off must be collected and managed as a hazardous
waste, or the pile must be protected from precipitation and run-
off and no liquids may be placed in the pile.
Run-off from disposal units that are closed under the Interim
Status Standards need not be collected.
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6.2.5.3 Guidance to Address the Application Information
Requirement
A suggested attachment to the permit application is Run-Off
Control System Design. The following information and analyses
should be submitted for review:
- A description of the hydrologic method and calculations
used to estimate peak flow rates and run-off volumes
including justification of necessary assumption.
- The 24-hour, 25-year rainfall volume used for facility
design including the source of the data; all other data
and necessary input parameters used in conjunction with
the selected hydrologic method and their sources should
be documented and described;
All hydraulic calculations and designs for sizing the
necessary collection, conveyance and storage
facilities (standard hydraulic techniques for
determining flow capacities and storage volumes,
including allowances for freeboard, shall be used);
Structural designs of the collection, conveyance,
and storage facilities, and results of all field
tests to ensure compatibility with soils and foundation
conditions (standard structural design) techniques and
factors of safety, and appropriate field tests should
be used);
A maintenance plan for ensuring the structural
integrity of the collection, conveyance and storage
facilities along with the plan for restoration and
repair in the event of a washout or failure.
6.2.6 Management of Units Associated with Run-On and Run-Off
Control Systems
6.2.6.1 The Federal Requirement —
Section 270.18(c) requires that the Part B Application
information include:
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Detailed plans and an engineering report describing
how the pile is or will be designed, constructed,
operated and maintained to meet the requirements of
§264.251. This submission must address the following
items as specified in §264.251:...
(4) Management of collection and holding units associated
with run-on and run-off control systems;
Facility Standard 264.251(e) states that
Collection and holding facilities (e.g., tanks or
basins) associated with run-on and run-off control
systems must be emptied or otherwise managed expeditiously
after storms to maintain design capacity of the system.
6.2.6.2 Guidance to Achieve the Part 264 Standard —
Section 264.251(e) states that collection and holding
facilities associated with run-on and run-off control systems
must be emptied or otherwise managed expeditiously after storms
to maintain the design capacity of the system. The specified
design capacity is that capacity necessary to collect and control
the water volume resulting from a 24-hour, 25-year storm. The
system may be designed to meet the above requirements or by
designing it for a volume in excess of the 24-hour, 25-year
storm capacity. Where additional storage capacity is necessary
to allow reuse or delayed disposal of collected water, it can be
separately provided by tanks or additional surface impoundments.
The applicant is reminded that run-off from the active area
of the landfill should generally be considered hazardous. This
will require management of this run-off in permitted treatment,
storage, or disposal facilities.
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6.2.6.3 Guidance to Address the Application Information
Request —
A suggested attachment to the permit application is Plan for
Management of Units Associated with Run-On and Run-Off Control.
The following information should be submitted:
A plan for emptying collection or holding facilities
associated with run-on and run-off management systems to
maintain the capacity of the system.
An estimation of the length of time it would take to empty
the holding facilities.
A description of the method to be used for collected run-
off disposal, such as treatment and discharge, evaporation,
and so forth. The description should address any environ-
mental concerns associated with the disposal method.
A description of the methods to be used to monitor run-off
quality.
6.2.7 Control of Wind Dispersal
6.2.7.1 The Federal Requirement —
Section 270.18(c) requires that the Part B application
information include:
Detailed plans and an engineering report describing
how the pile is or will be designed, constructed,
operated arid maintained to meet the requirements of
§264.251. This submission must address the following
items as specified in §264.251:...
(5) Control of wind dispersal of particulate matter,
where applicable;
Facility Standard 264.25(f) states that:
If the pile contains any particulate matter which may
be subject to wind dispersal, the owner or operator
must cover or otherwise manage the pile to control wind
dispersal.
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6.2.7.2 Guidance to Achieve the Part 264 Standard —
EPA requires wind dispersal controls to minimize emissions
of particulate matter at waste piles. Particulate air emissions
can be generated during the operation and closure of waste piles.
The generation and dispersion of dust from a hazardous waste
management site is of concern because of the potential health
hazards and safety considerations including impact on visibility
near the pile. These emissions are generated primarily from wind
erosion of open areas, vehicle traffic on unpaved haul roads, and
adding and removing material from piles.
The fugitive emissions produced by wind erosion of waste
piles depend on the waste type, moisture content, wind velocity,
surface geometry and wind protection. Although many equations
have been developed by researchers in estimating emissions
generated from agricultural soils, there seems to be a basic
agreement that between 2.5 and 10 percent of all the soil eroded
due to wind becomes airborne as suspendable particulate matter.
Fugitive dust emissions from unpaved surfaces caused by
vehicle traffic on exposed waste surfaces and haul roads are
affected by the surface texture of the road, road material,
surface moisture, vehicle speed, and level of activity. Fugitive
emissions from unpaved surfaces can be estimated using emission
factors developed in EPA Publication AP-42, Compilation of Emission
Factors. Factors that must be known include: the silt content of
the surface materials (percentage of weight of particles smaller
than 75 micrometers in diameter), average vehicle speed, and
average daily traffic.
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Chemical stabilizers can be added to reduce wind erosion.
Many of the compounds are proprietary developments, and their
properties are difficult to evaluate without site-specific field
testing. In selecting a stabilizer, one should consider effective-
ness, stability, ease of application, cost, safety, and environ-
mental impact. Most chemical stabilizers only provide dust
suppression for a limited period of time, generally no more than a
few months; thereafter, a reapplication or more permanent solution
is needed.
The geometry and orientation of waste piles can aid in
reducing wind dispersal. Low piles and those with their long
dimension parallel to the prevailing winds will likely have the
fewest problems with wind dispersal.
Windbreaks such as trees and fences may assist in minimizing
wind dispersal. Waste piles may also be amenable to man-made
windbreaks. The best possible protection is to completely enclose
a waste pile in a building.
6.2.7.3 Guidance to Address the Application Information
Requirement —
The applicant should assess the potential for wind dispersal.
This may be based on factors such as type of waste(s) disposed,
predominant wind direction and velocity, local topography, wind-
breaks, and operational procedures. The approach used in this
assessment and the results should be included in the basic portion
of the application.
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If the assessment indicates a potential for wind dispersal, a
control plan must be developed. A suggested attachment to the
permit application is Wind Dispersal Flow Control Plan.
The applicant should submit the following information on
wind dispersal control:
- A description of the method(s) proposed for controlling
wind dispersal. Include such considerations as the siting
of the waste pile; the use of water sprays, dust suppressants
other than water, stabilizers, windbreaks, and enclosures.
Particular attention should be paid to including plans to
minimize wind dispersal during the addition and removal of
wastes from the piles.
- Data supporting the effectiveness of the proposed wind
dispersal control technique(s ).
6.2.8 Ground-Water Protection Exemption for Double-Lined Piles
6.2.8.1 The Federal Requirement —
If the applicant desires exemption from the ground-water
protection standards because he proposes a double-lined waste pile,
section 270.18(c) requires that the Part B application include:
If an exemption from Subpart F of Part 264 is sought as
provided by §§264.252 or 264.253, submit detailed plans
and an engineering report describing how the requirements
of §§264.252(b) or 264.253(a) will be complied with;
Facility Standard 264.252(a) states:
The owner or operator of a double-lined wastepile is
not subject to regulation under Subpart F of this part
in the following conditions are met:
(1) The pile (including its underlying liners) must be
located entirely above the seasonal high water table.
(2) The pile must be underlain by two liners which are
designed and constructed in a manner that prevents the
migration of liquids into or out of the space between
the liners. Both liners must meet all the specifications
of 264.251(a).
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(3) A leak detection system must be designed, constructed,
maintained, and operated between the liners to detect
any migration of liquids into the space between the
liners.
(4) The pile must have a leachate collection and removal
system above the top liner that is designed, constructed,
maintained, and operated in accordance with §264.251(a)(2)
6.2.8.2 Guidance to Achieve the Part 264 Standard —
The design and operating standards contain special sets of
standards for waste piles with double liners and leak detection
systems. Compliance with these standards is not mandataory.
However, if an applicant voluntarily applies for and is issued a
permit to comply with these special standards (in addition to the
other standards generally applicable to these units), he is not
subject to the ground-water protection regulations contained in
Subpart F.
To be eligible for exemption from ground-water protection
requirements, a double-lined unit (including the liners and leak
detection system) must be placed entirely above the seasonal
high water table. Placement of units in the ground water poses
special problems including those associated with external pres-
sures applied by the saturated earth. The Agency is concerned
that these pressures can cause disruption (collapse or caving in)
of the liner system and disruption of the leak detection system
to the point that it may not work. While collapse of the liner
system can occur when a single liner unit is located in the
ground water, the ground-water monitoring system can be expected
to function to detect contamination. Since ground-water
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monitoring is waived for double-lined facilities, it is
imperative that the leak detection system function. The
Agency is not confident at this time that it can specify design
safeguards that will ensure continued function when the unit is
placed in the saturated zone.
The foundations on which the liners are installed must be
graded to allow for free, gravity flow of liquid to the leachate
collection system and the leak detection system. A minimum
slope of two percent is recommended. Guidance is provided in
Reference 3.
The regulations require that the liners used must meet
the requirements normally applicable to liners in single-liner
systems, i.e., they must each prevent the migration of wastes
to subsurface soil or to ground water or surface water during
the life of the unit. Applicants seeking this exemption
will have to ensure that each of the liners prevent migration
into or out of the space between the liner. Otherwise,
leakage into the leak detection system will occur, resulting
in the need to repair or replace the leaking liner or begin
ground-water monitoring. One approach to minimize migration
between the liners is to seal the edges of synthetic membrane
liners at the surface.
The leachate collection and removal requirements for
single-liner piles also apply to double-lined systems.
The leachate collection and removal system must be placed
above the upper liner, and must be maintained and operated
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to collect and remove the leachate. This implements the policy
objective of reducing the amount of leachate that can potentially
migrate to the subsurface soil, ground water or surface water.
The leachate collection system should be installed in a
drainage layer above the upper liner. This layer should be at
least 30 cm (1 ft) thick and have a hydraulic conductivity
of not less than 1 X 10~3 cm/sec. Any pipe used in the collection
system must be strong enougn to withstand the pressures of
overlying waste and movement of equipment. Strength attributes
of perforated pipes must be considered in the design of the
collection systems.
Proper spacing of the pipe network to ensure adequate liquid
collection is important. A reasonably sized drainage system and
adequate removal methods will provide an extra measure of protec-
tion by reducing the liquid head (see Reference 3).
A leak detection system is any system (a drain and pump or
appropriate instrumentation) that enables the permittee of the
waste piles to detect whether any liquid has entered into the
space between the liners. This is the means by which the permittee
will determine if the liner has failed or is leaking. Some water
may enter the space between the liners at the time of installation.
This would occur only once, at the time of unit start-up. A
prudent permittee would remove this water immediately, since the
presence of water in the leak detection system at a later time
will be assumed to indicate that one of the liners is leaking.
Failure or leakage of the liner requires the permittee to notify
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the Regional Administrator and either to repair the primary
liner or institute ground-water monitoring, pursuant to
§264.98.
Many designs of detection systems have been devised using
advanced instrumentation, such as resistivity and conductivity
measurement systems. However, direct collection and removal
of liquid leakage is perhaps the simplest and most reliable
method. This system is very similar to leachate collection
systems for surface impoundments and landfills. A series of
perforated pipes is placed in a porous medium between liners
during construction. Liquid that has penetrated the upper
liner collects in these pipes and flows by gravity to a
central drain or gallery, where the liquid can be detected
and withdrawn. EPA suggests that 10 cm. (4-inch) diameter
perforated pipe on 15 to 60 m. (50 to 200 ft.) centers
should be adequate to provide effective leak detection and
capacity to remove liquids from minor breaching in the
primary (upper) liner.
Ordinarily, a permit written for a double-lined unit
seeking an exemption from Subpart F would not contain detection
monitoring requirements. In that case, if the permittee
discovers a leak in the leak detection system, he will have
to repair or replace the leaking liner or be in violation of
the permit. Therefore, EPA recommends that those who anticipate
retrofitting problems in attempting to repair or replace
leaking liners should request that detection monitoring
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programs be established in their permits in accordance with
the requirements of §264.98, as contingent requirements. Such
requirements would be automatically triggered in the event of a
leak, but would not have to be complied with until such a leak
occurred. The permit would specify well placement, detection
parameters to be monitored, and the frequency of monitoring. If
a leak occurred, the permittee would then install the wells and
begin monitoring in accordance with a schedule set forth in the
permit.
6.2.8.3 Guidance to Address the Application Information
Requirement —
A waste pile must not be located within the saturated zone
in order to qualify for the exemption described in §264.252(a).
Many fine-grained geologic formations may not meet the character-
istics of an aquifer, but may be saturated nonetheless. A waste
pile constructed in such a formation would be within the ground-
water table, and could not qualify for the exemption. The appli-
cant should submit the following information if application is
being made for the ground-water monitoring program exemption:
A demonstration that the wastepile and its underlying
liners will be located entirely above the seasonal high
ground-water table. The applicant should refer to Section
9.3 of the manual for guidance on how to describe the
hydrogeologic characteristics of the facility's location.
- A demonstration that both liners satisfy the requirements
of §264.251 (a)(l). The applicant should refer to Section
8.2.1 for guidance on how to demonstrate compliance with
this standard for each liner. For those cases in which
two different types of liner material are to be used, a
liner integrity analysis (i.e., waste liner capability
test) for both liners must be submitted.
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A demonstration that the leak detection system between the
two liners will be designed, constructed, maintained, and
operated to detect any migration of liquid into the space
between the liners. EPA recommends that the leak detec-
tion system resemble the leachate collection and removal
system. If the top liner leaks, a leachate collection and
removal system will be present beneath it for immediate
operation. The applicant can refer to Section 8.2.2 for
guidance on leachate collection and removal system design.
A demonstration that the leachate collection and removal
system above the top liner satisfies the standard in
1264.251(a)(2). The applicant can refer to Section 8.2.2
for guidance in leachate collection and removal system
design.
A suggested attachment to the permit application in Report
Supporting Request for Exemption from Ground-Water Protection
Requirement for Double-Lined Waste Piles.
6.2.9 Ground-Water Protection Exemption for Piles with Inspectable
Liners
6.2.9.1 The Federal Requirement —
Facility Standard 264.253(a)(3) states:
The owner or operator of a pile is not subject to
regulation under Subpart F of this part if the following
conditions are met.
(3) The wastes in the pile must be removed periodically,
and the liner must be inspected for deterioration,
cracks, or other conditions that may result in leaks.
The frequency of inspection will be specified in the
inspection plan required in §264.15 and must be based
on the potential for the liner (base) to crack or
otherwise deteriorate under the conditions of operation
(e.g., waste type, rainfall, loading rates, and sub-
surface stability).
6.2.9.2 Guidance to Achieve the Part 264 Standard —
The permittee of a waste pile is not subject to Subpart F
regulation if the wastes in the pile are removed periodically
and the liner inspected for integrity. This allows the liner to
be visually inspected to determine that the performance standards
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are being achieved. The permittee can then determine if
hazardous constituents, leachate,and so forth have been prevented
from entering the ground or surface water. This exemption is
most applicable to piles where the wastes are normally removed
as part of the overall management plan.
Waste piles with a coated concrete or asphaltic liner are the
best candidates for this exemption. Such piles will likely have
the structural strength to allow the periodic removal of the waste,
inspection, and replacement of the waste. Wastes removed to allow
inspection must be managed as hazardous wastes and either moved
to another portion of the permitted waste pile, or to some other
permitted treatment, storage, or disposal facility.
6.2.9.3 Guidance to Address the Application Information
Requirement —
The applicant is required to submit documentation including
detailed plans, engineering reports and operating plans to show
how §264.253(a)(3) will be achieved. Detailed operating plans
must describe how the wastes will be removed without damaging
the liner. A suggested attachment to the permit application is
Report Supporting Request for Exemption from Ground-Water
Monitoring Requirements - Piles with Inspectable Liner. Informa-
tion to be submitted should include at least the following:
- Information concerning the liner that demonstrates that
the liner can withstand the stresses of periodic waste
removal and replacement including:
— type of and specifications for liner, including
reinforcement
— type of coating(s) to be used to seal the liner
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Equipment to be used, including operating procedures to
minimize liner stress.
Inspection procedures, including frequency, methods, and
documentation.
Contingency plans for liner repair/replacement if cracks
or deterioration are found.
6.3 MONITORING AND INSPECTION
6.3.1 Monitoring and Inspection During Construction, Installation,
and Operation
6.3.1.1 The Federal Requirement —
Section 270.18(e) requires that the Part B Application
include:
A description of how each waste pile, including the
liner and appurtenances for control of run-on and run-
off, will be inspected in order to meet the requirements
of §264.254(a) and (b). This information should be
included in the inspection plan submitted under
270.14(b)(5) of this section. If an exemption is
sought to Subpart F of Part 264 pursuant to §264.253,
describe in the inspection plan how the inspection
requirements of §264.253(a)(3) will be complied with.
The Facility Performance Standard 264.254(a) states:
During construction or installation, liners (except in
the case of existing portions of piles exempt from
§264.251(a) and cover systems (e.g., membranes, sheets,
or coatings) must be inspected for uniformity, damage,
and imperfections (e.g., holes, cracks, thin spots, or
foreign materials). Immediately after construction or
installation:
(1) Synthetic liners and covers must be inspected to
ensure tight seams and joints and the absence of tears,
punctures, or blisters; and
(2) Soil-based and admixed liners and covers must be
inspected for imperfections including lenses, cracks,
channels, root holes, or other structural non-uniformities
that may cause an increase in the permeability of the
liner or cover.
The Facility Performance Standard 264.254(b) states:
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While a waste pile is in operation, it must be inspected
weekly and after storms to detect evidence of any of the
following:
(1) Deterioration, malfunctions, or improper operation
of run-on and run-off control systems;
(2) The presence of liquids in leak detection systems,
where installed to comply with §264.252;
(3) Proper functioning of wind dispersal control systems,
where present; and
(4) The presence of leachate in and proper functioning
of leachate collection and removal systems, where
present.
6.3.1.2 Guidance to Achieve the Part 264 Standard —
6.3.1.2.1 Liner Inspection — Synthetic liner 'and cover
systems must be inspected during construction and installation
for uniformity, damage and imperfections, and after installation
to ensure tightness of seams and joints and absence of tears,
punctures, or blisters. Soil-based and admixed liners and covers
must be inspected for imperfections including lenses, cracks,
channels, root holes or other structural non-uniformities that
may adversely affect the permeability, strength, or other
engineering properties of the liner or cover. The applicant
should consult the EPA publication on liners (Reference
5) for information on specific inspection needs and objectives
for various liners. Information on evaluating cover systems
is available in Reference (8).
An effective quality control program will form the basis
for the inspection plan for the installation and construction
of liners. The applicant should propose a Liner Installation
Quality Control Program (QC) which addresses the proposed methods
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of liner inspection, testing and documentation. The QC Program
may be developed, in part, from manufacturers' standard inspection
procedures. For example, for a synthetic liner, it,should include,
but not be limited to, the following specific provisions:
- The permittee will designate a field representative
(QC Manager) with sole responsibility for inspection
and approval of liner work. For large projects, the
permittee should provide a sufficient number of
personnel to assist the QC Manager to achieve the
objectives of the QC Program.
- QC Program should include assurance that the following
objectives are met:
— The construction specifications required in the
permit are fully implemented;
— Subgrade preparation is consistent with requirements
for synthetic liner membranes;
— Handling of liner materials is performed in accor-
dance with manufacturer's recommended procedures;
Manufactured liner panels, upon arrival at the project
site, are free of product defects and damage resulting
from shipping;
— Fabricated seams of prefabricated sheet membranes
are tested by airlance, vacuum or other suitable
means to determine location of defects;
Liquid-applied membranes, adhesives, and solvents are
delivered in sealed containers and are used in accordance
with the manufacturer's recommendations.
Contractor's tools are consistent with manufacturer's
recommendations; sharp instruments such as pointed
scissors are not allowed.
Field seams constructed by adhesive, heat, welding or
other means are tested by airlance, vacuum, ultrasonic
method or by any combination of methods to determine
the location of defects.
Placement of soil and protective cover is accomplished
so that the soil is free of deleterious materials, and
in a manner such that damage is not caused to the liner
membrane by disposal operations.
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Samples of liner material, fabrication seams and field
seams are taken routinely in sufficient number to verify
the quality of workmanship of the completed work.
- Laboratory testing of field samples is conducted in
accordance with ASTM standards and procedures for syn-
thetic liner membranes. Results should be reviewed by
the QC Manager and corrective action taken if materials
and seams do not meet minimum specified strengths. The
permittee should notify the Regional Administrator of
such corrective action and make all test results avail-
able for review upon request.
- Documentation of all phases of the QC Program should be
prepared by the permittee for record purposes. Daily
reports should be maintained by the QC Manager describing
observations, activities, weather, production, contrac-
tor's equipment, and work force and specific problems.
Deviations from standard construction procedures by the
contractor, corrective measures, and changes in design
should be fully documented. Location of field samples
and laboratory test results should be made a part of
program documentation.
Soil-based and admixed liners and covers must be inspected
and tested to ensure that they are properly constructed according
to the approved design. The test data should consist of strength,
permeability and other material properties of samples representa-
tive of the liner or cover to be used in construction.
To ensure that the liner and cover system are constructed
according to the approved design and specifications, and to ensure
uniformity, absence of damage, and imperfections, an independent
test lab and inspector supervised by a qualified, registered
engineer should be present at all phases of construction and
installation to monitor and test the materials as they are placed.
Non-destructive or destructive sampling and testing should be
performed on a random basis in accordance with established,
acceptable standards. In destructive sampling and testing, the
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areas sampled or tested should be restored to original condition
immediately after sampling or testing. All test results and
other pertinent data, such as location, elevation, date, climatic
conditions, personnel, and so forth, should be documented and
kept on record.
6.3.1.2.2 Operation Inspection — In addition to inspections
during construction and installation, qualified personnel must
make inspections of a waste pile while it is in operation. These
inspections must be conducted weekly and after storms. A detailed
written schedule should be developed for inspection of: (a) run-on
and run-off control systems, (b) leak detection systems, (c) wind
dispersal control system, and (d) leachate collection and removal
system.
The inspection records should include the maintenance and
calibration records of all control systems, leak detection systems,
and leachate collection and removal systems. Furthermore, the
amount of leachate present in the collection and removal system
should be recorded. All information from each inspection should
be documented and kept on record for EPA review.
The applicant is advised that additional general inspection
requirements are delineated in §264.15(b) of the general facility
standards. The corresponding permit information requirements
for these requirements are provided in §270.14(b)(5). Guidance
on these overall inspection requirements is provided in the
Permit Applicants' Guidance Manual for General Facility Standards
(Reference 1).
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6.3.1,3 Guidance to Address the Application Information
Requirement —
The following information on inspection should be submitted
with the permit application. The applicant should include this
information in the overall Facility Inspection Plan as required
under §270.14(b)(5). Two suggested attachments within the
Facility Inspection Plan submitted with the permit application
are a Liner Construction Inspection Plan and an Operation
Inspection Plan.
6.3.1.3.1 Liner Inspection Plan —
- Describe procedures, including a quality control program,
for inspecting synthetic liners and covers during con-
struction and installation. The applicant should address
all inspection needs discussed above for synthetic liners
and covers.
- Describe procedures, including a quality control program,
for inspecting soil-based and admixed liners and covers
during construction and installation. The applicant
should address all inspection needs discussed above for
soil-based and admixed liners and covers.
6.3.1.3.2 Operation Inspection Plan —
- Describe the procedures for inspecting weekly and after
storms for detection of:
— deterioration, malfunction, or improper operation
of run-on and run-off control systems;
— presence of liquids in the leak detection system,
where installed,
— proper functioning of wind dispersal control systems;
and
— presence of leachate in and the proper functioning of
leachate collection and removal system, where present.
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6.3.2 Monitoring and Inspection of Liner if Exemption from
Ground-Water Protection Requirements is Sought
6.3.2.1 The Federal Requirement —
The Facility Performance Standard 264.253(a)(3) states:
(a) The owner or operator of a pile is not subject to
regulation under Subpart F of this part if the following
conditions are met:
(3) The wastes in the pile must be removed periodically,
and the liner must be inspected for deterioration,
cracks, or other conditions that may result in leaks.
The frequency of inspection will be specified in the
inspection plan required in §264.15 and must be based
on the potential for the liner (base) to crack or
otherwise deteriorate under the conditions of operation
(e.g., waste type, rainfall, loading rates, and subsurface
stabiity).
6.3.2.2 Guidance to Achieve the Part 264 Standard —
Section 264.253 provides a special exemption from Subpart F
for any waste pile where the waste is periodically removed from
the liner so that the liner may be inspected for cracks, erosion,
or other conditions that could result in leakage. This exemption
relies on inspection of the liner to assure that the liner is
intact and is not allowing leachate to migrate through it. This
inspection procedure eliminates any need to monitor the ground
water.
Synthetic membrane liners are not likely to be capable of
withstanding damage from repeated removal and replacement of
wastes during liner inspections. Clay liners will also be
unsuitable in many cases, because when exposed to air, they tend
to dry out to some extent and crack, resulting in the development
of channels through which leachate may migrate. Therefore, EPA
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expects that reinforced concrete with appropriate coatings will
be the liner material chosen by most applicants wishing to qualify
for an exemption under §264.253.
The regulations further provide that the inspection plan
usually required by §264.15 will incorporate a schedule of inspec-
tion which includes periodic removal of the waste and testing of
the liner to ensure that it has not deteriorated to where it is
no longer capable of containment or is already leaking.
This exemption is intended for, and will likely apply to
small piles, especially those where normal operations periodically
or routinely result in removal of the waste. Removal of the waste
from large piles on a periodic and routine basis would normally be
impractical because of handling and storage 'difficulties. Large
piles will also need a relatively permeable drainage layer and
possibly a drainage system to comply with the one-foot leachate
head requirement. To remove the wastes and drainage layers from
such piles in order to meet the inspection requirement will,
normally, be impractical. The regulations do not specify the
pile size in an exemption, but the practicality of both inspecting
the liner and meeting the one-foot head requirement will limit the
size in practice.
When the waste is removed, the integrity of the liner must
be thoroughly inspected by qualified personnel. The types of
inspections and tests required for synthetic liners and covers,
and soil based and admixed liners and covers have been discussed
in the preceding paragraphs of this section. However, the EPA
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expects that reinforced concrete with appropriate coatings will
be chosen most often by those wishing to qualify for exemption
under §264.253. For tests to evaluate these liners, the
following references can be used:
Asphalt in Hydraulics, The Asphalt Institute, Manual
Series No. 12, November 1976.
Linings for Irrigation Canals, Bureau of Reclamation,
U.S. Dept. of the Interior, Washington, D.C., 1963.
All test results and other pertinent data from each inspection
should be documented and kept on record for Agency review.
6.3.2.3 Guidance to Address the Application Information
Requirement —
A detailed written inspection plan must be developed
and submitted with the permit application to the EPA for
evaluation. A suggested attachment to the permit application
is Liner Inspection Plan. The inspection plan must specify
the frequency of inspections based on the potential of the
liner to deteriorate under the conditions of operation. The
active life of the facility is a consideration when design
and operating requirements for the facility are formulated.
Sections 6.2.1 through 6.2.4 mention the testing requirement
to predict the liner performance under operating conditions.
The results of these tests will give an indication as to the
proper inspection intervals.
6.4 EXEMPTION TO LINER STANDARD AND GROUND-WATER PROTECTION
STANDARD
6.4.1 The Federal Requirement
Section 270.18(b) states the Part B permit requirement as:
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If an exemption is sought to §264.251 and Subpart F of
Part 264 as provided by §264.250(c), an explanation of
how the requirements of §264.250(c) will be complied
with.
Section 264.250(c) states the facility standard as:
The owner or operator of any waste pile that is inside
or under a structure that provides protection from
precipitation so that neither run-off nor leachate is
generated is not subject to regulation under §264.251
or under Subpart F of this part, provided that:
(1) Liquids or materials containing free liquids are
not placed in the pile;
(2) The pile is protected from surface water run-on by
the structure or in some other manner;
(3) The pile is designed and operated to control
dispersal of the waste by wind, where necessary, by
means other than wetting; and
(4) The pile will not generate leachate through
decomposition or other reactions.
6.4.2 Guidance to Achieve the 264 Standard
If an applicant can demonstrate to the Regional Administrator
that the use of alternate design and operating practices, in
combination with location and waste characteristics, will prevent
the migration of any hazardous constituents into the ground water
or surface water at any future time, an exemption from the liner
and the leachate collection and removal requirements may be issued,
The basis for the exemption is that such requirements become
superfluous if there is no potential threat to ground water or
surface water. Specifically, an exemption from both the liner
and leachate collection and removal standards and the ground-water
requirements may be provided for dry piles that are inside or
under structures protected from precipitation, run-on and wind
dispersal.
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6.4.3 Guidance to Address the Application Information Requirement
In order to meet the above requirements the applicant should
submit information that includes the following. A suggested
attachment to the permit application is Report Supporting Request
for Exemption from Liner and Ground-Water Protection Standards.
- Documentation concerning the waste generation and handling
processes, and the waste characteristics to show that no
liquids or materials with free liquids have been or will
be placed in the waste pile.
- Documentation, details, drawings, and engineering analyses
showing that the waste pile is or will be protected from
run-on or precipitation by a structure or other means.
- Documentation showing that the waste pile has or will have
adequate control and protection against wind erosion and
dispersal.
- Documentation and engineering analyses showing that leachate
generation has not or will not occur through decomposition
or any other reaction.
6.5 TREATMENT OF WASTE
6.5.1 The Federal Requirement
Section 270.18(f) requires that the Part B application
include:
If treatment is carried out on or in the pile, details
of the process and equipment used, and the nature and
quality of the residuals;
6.5.2 Guidance to Achieve the Part 264 Standard
There are no specific 264 standards addressing the manner in
which the waste pile is to be treated.
6.5.3 Guidance to Address the Application Information Requirement
If treatment is carried out on or in the pile, the treatment
program must be carefully researched and designed. A suggested
attachment to the permit application is Waste Treatment Plan.
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The design and operating measures must include all details of the
process and equipment to be used during operation. A thorough
analysis of the wastes in the pile should be made prior to treat-
ment. Field and/or laboratory testing of the treatment wastes
should be carefully documented. The treatment program must ensure
careful management, operation, and maintenance of the waste pile.
Materials (residuals) remaining in the pile after treatment
should be analyzed to determine their hazardous nature. If
hazardous, they must eventually be disposed in a hazardous waste
disposal site. If non-hazardous, they may be disposed in a
sanitary landfill or by other methods.
Careful recordkeeping is an important part of the management
of the waste pile. The records should include all details of
the treatment, including dates, personnel, equipment numbers, and
analytical results.
Specific areas to be addressed in the permit application
include at least the following:
- Name of the treatment process to be applied to each waste.
- Reference to the literature or to test results indicating
that the process is applicable to the waste and is
effective.
- List of chemicals or other materials to be added to the
wastes.
Operational procedures including analyses of the residue
from the treatment process.
- Recordkeeping procedures.
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6.6 SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTES
6.6.1 The Federal Requirement
Section 270.18(g) requires that the Part B Application
include:
If ignitable or reactive wastes are to be placed in a
waste pile, an explanation of how the requirements of
§264.256 will be compiled with;
The Facilty Performance Standard 264.256 states:
Ignitable or reactive waste must not be placed in a
waste pile unless:
(a) The waste is treated, rendered, or mixed before or
immediately after placement in the pile so that:
(1) The resulting waste, mixture, or dissolution of
material no longer meets the definition of ignitable or
reactive waste under §264.21 or 261.23 of this chapter,
and
(2) Section 264.17(b) is complied with;
(b) The waste is managed in such a way that it is
protected from any material or conditions which may
cause it to ignite or react.
6.6.2 Guidance to Achieve the Part 264 Standard
The regulations require the permittee to take precautions to
prevent accidental ignition or reaction of ignitable or reactive
waste and protect the waste from sources of ignition. The
permittee is also required to take precautions in treating,
storing, or disposing of ignitable, reactive or incompatible
waste so that it does not ignite or explode, emit toxic gases,
damage the containment structure or through other like means
threaten human health or the environment.
Section 264.256 prohibits the placement of ignitable or
reactive wastes in a waste pile, unless the waste is made
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non-ignitable or non-reactive, as defined in §§261.21 and 261.23,
while also complying with §264.17(b). In addition, §264.229
allows the placement of ignitable or reactive waste in a waste
pile if the waste is protected from ignition or reaction.
6.6.3 Guidance to Address the Application Information Requirement
The applicant should submit the information defined below.
A suggested attachment to the permit application is Ignitable
and/or Reactive Wastes Management Plan(s).
Description of how ignitable or reactive wastes will be
identified when received at the site (should also be
included in the Waste Analysis Plan).
- Description of the procedure for treating, or mixing
the ignitable or reactive wastes before or immediately
after placement in the waste pile.
Results of laboratory or field experiments that demonstrate
that after treatment or mixing and placement in the
waste pile, the reactive or ignitable waste will be
rendered non-reactive or non-ignitable.
- A description of how §264.17(b) will be complied with
(i.e., describe what precautions will be taken to prevent
reactions which: (1) generate extreme heat or pressure,
fire or explosions, or violent reactions; (2) produce
uncontrolled toxic mists, fumes, dusts, or gases in
sufficient quantities to threaten human health or the
environment; (3) produce uncontrolled flammable fumes
or gases in sufficient quantities to pose a risk of
fire or explosion; (4) damage the structural integrity
of the device or facility, and (5) through other like
means threaten human health or the environment.
6.7 SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES
6.7.1 The Federal Requirement
Section 270.18(h) requires that the Part B application
include:
If incompatible wastes, or incompatible wastes and
materials will be placed in a waste pile, an explanation
of how §264.257 will be complied with;
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Facility Standard 264.257 states:
(a) Incompatible wastes, or incompatible wastes and
materials, (see Appendix V of this part for examples)
must not be placed in the same pile, unless §264.17(b)
is complied with.
(b) A pile of hazardous waste that is incompatible with
any waste or other material stored nearby in containers,
other piles, open tanks, or surface impoundments must
be separated from the other materials, or protected from
them by means of a dike, berm, wall, or other device.
(c) Hazardous waste must not be piled on the same base
where incompatible wastes or materials were previously
piled, unless the base has been decontaminated suffi-
ciently to ensure compliance with §264.17(b).
6.7.2 Guidance to Achieve the Part 264 Standard
The potential dangers from the mixing of incompatible
wastes and materials include extreme heat; fire; explosion;
violent reaction; production of toxic mists, fumes, dusts,
or gases; and damage to the structural integrity of the
waste pile. Clearly, the potential impacts on human health
or the environment which could result from such conditions
must be avoided. A list of incompatible wastes is included
in Section 7.9.2. Additional guidance on imcompatibility
can be found in References (9) and (10).
6.7.3 Guidance to Address the Application Information
Requirement
A suggested attachment to the permit application is
Management Plan for Incompatible Wastes. The applicant
should first determine whether incompatible wastes and/or
materials will be landfilled by following the subsequent
steps and by providing the information in the permit application:
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- Review the lists of incompatible wastes in Section 7.9.2
and identify any that may be received.
Identify other wastes to be disposed that are not shown
in Section 7.9.2.
Determine if any mixture of these wastes or materials is
incompatible and identify the wastes and nature of the
incompatibility. [Note: If available, the applicant
may use Reference 9, A Method for Determining Compati-
bility of Wastes, as an aid in determining compatibility
of wastes. This document, however, should be used with the
caution advised in Section 3.4.3.2 of this Manual.]
If incompatible wastes and/or materials will be stored in the
waste pile, the applicant must describe:
Methods for identifying these wastes as they are received
at the site.
Step-by-step procedures for managing incompatible wastes
or material to prevent undesirable reactions or effects
defined in §264.17(b);
Laboratory or field data demonstrating that incompatible
wastes can be safely managed at the waste pile using the
proposed procedures.
6.8 CLOSURE
6.8.1 The Federal Requirement
Section 270.18(1) requires that the Part B Application
include:
A description of how hazardous waste residues and
contaminated materials will be removed from the waste
pile at closure, as required under §264.258(a). For
any waste not to be removed from the waste pile upon
closure, the owner or operator must submit detailed
plans and an engineering report describing how §264.310(a)
and (b) will be complied with. This information should
be included in the closure plan and, where applicable,
the post-closure plan submitted under 270.14(b)(13).
Facility Standard 264.258 states:
(a) At closure, the owner or operator must remove or
decontaminate all waste residues, contaminated contain-
ment system components (liners, etc.), contaminated
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subsoils, and structures and equipment contaminated
with waste and leachate, and manage them as hazardous
waste unless §264.3(d) of this chapter applies.
(b) If, after removing or decontaminating all residues
and making all reasonable efforts to effect removal
or decontamination of contaminated components,
subsoils, structures, and equipment as required in
Paragraph (a) of this section, the subsoils can be
practicably removed or decontaminated, he must
close the facility and perform post-closure care in
accordance with the closure and post-closure care
requirements that apply to landfills §264.310.
(c) (1) The owner or operator of a waste pile that does
not comply with the liner requirements of §264.25(a)(1)
and is not exempt from them in accordance with
§§264.250(c) or 264.251(b) must:
(i) Include in the closure plan for the pile under
§264.112 both a plan for complying with paragraph (a)
of this section and a contingent plan for complying
with paragraph (b) of this section in case not all
contaminated subsoils can be practicably removed
at closure, and
(ii) Prepare a contingent post-closure plan under
§264.118 for complying with paragraph (b) of this
section in case not all contaminated subsoils can be
practicably removed at closure.
(2) The cost estimates calculated under §§264.142 and
264.144 for closure and post-closure care of a pile
subject to this paragraph must include the cost of
complying with the contingent closure plan and the
contingent post-closure plan, but are not required
to include the cost of expected closure under
paragraph (a) of this section.
6.8.2 Guidance to Achieve the Part 264 Standard
Since waste piles are storage facilities, all wastes,
residues, and contaminated subsoils and equipment must be
removed or decontaminated at closure. This is necessary
because under this option, no post-closure care or monitoring
is required. The waste pile is a storage unit leaving no
6-69
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hazardous constituents in the ground after closure. All the
removed residues, subsoils and equipment must be managed as
hazardous wastes unless the provisions of §264.3(d) are complied
with.
If the permittee removes or decontaminates all wastes and
waste residues and makes all reasonable efforts to remove or
decontaminate all contaminated containment systems, subsoils,
structures, and equipment, and finds after such efforts that some
contamination remains that he cannot remove or decontaminate,
then the pile will be considered a disposal unit under these
regulations and must be closed in accordance with the closure
requirements for landfills. Thereafter, the permittee must comply
with the landfill post-closure requirements.
This situation is likely to occur often in the case of
existing portions that do not have liners or have inadequate
liners. In a few cases, liners installed in accordance with the
requirements of §264.251 of these regulations may also fail. In
any of these cases, contamination may have migrated a considerable
distance from the waste pile and possibly even entered the ground
water. This situation necessitates closure under the landfill
closure requirements to minimize the rate of migration and to mon-
itor for potential ground-water contamination. In contrast,
facilities with good liners that do not fail will be able to
avoid post-closure responsibilities.
A "reasonable effort" to remove all contaminated subsoils
includes removal of all wastes and waste residues in the unit,
6-70
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all contaminated liners and equipment, and at least some
subsoil. The Agency considers that contamination has been
removed when the concentrations of hazardous constituents in
the remaining in situ soil are at background levels. After
making reasonable attempts to remove all contaminated subsoil
and failing thereby to remove all contaminated subsoil, the
permittee may then cease further removal attempts but must
close the unit and perform post-closure activities as he
would do in the case of a landfill.
EPA separately considered two types of units: (1) those
that do not have liners that comply with the design standard
for preventing migration (i.e., most existing portions),
and (2) those that do have such liners.
Piles that lack liners that meet the design standards,
by definition, do not prevent the migration of wastes to the
subsurface soil or ground or surface water. At best, they
minimize such migration, and at worst, they provide little
or no control. At these units, it will often not be possible
to remove all contaminated soils at closure. In some instances,
leachate may already have contaminated the ground water.
(See Section 9.0 regarding ground-water protection). It is
thus reasonable to conclude that, in many instances, such
piles will have to be closed as landfills and will require
post-closure maintenance and monitoring. Therefore, EPA is
requiring that such storage piles have: (1) closure plans to
remove or decontaminate the wastes, waste residues, and
6-71
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contaminated equipment and soils; (2) contingent closure plans
to cover the units as landfills; and (3) contingent post-closure
plans to perform post-closure monitoring and maintenance. The
contingent plans must be followed only if compliance with the
primary closure plan does not result in the removal of all
contaminated soils.
Applications for waste piles that have liners designed
to prevent migration are not required to prepare contingent
closure plans to close the units as landfills or contingent
post-closure plans to maintain and monitor the units. However,
in some cases, a liner will fail to meet its design objective
of preventing migration throughout the unit's life. In such
a case, the permittee will need to obtain a permit modification
that imposes final cover requirements as well as post-closure
monitoring and maintenance requirements. Further guidance
is provided in Section 8.3, Closure of Landfills.
6.8.3 Guidance to Address the Application Information Requirement
The applicant must submit documentation including detailed
plans, engineering reports, and operating plans showing that the
Section 264.258 standard wil be complied with. A description and
plan of how the wastes, waste residues and contaminated materials
will be removed from the waste pile at closure is required. For
waste piles, proposed or existing, not meeting the previously
mentioned standards, contingent closure plans or closure in
accordance with Section 264.310 may be required. A suggested
attachment to the permit application is Closure Plan.
6-72
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Information in the Closure Plan should include, but not be
limited to the following:
Planned ultimate disposition of the wastes, liner, and
any other contaminated material.
Methods to be used to remove the above from the site.
Test methods to be used to assure that all contaminated
materials have been removed (i.e., in situ soil is not
hazardous) .
6.9 REFERENCES
1. U.S. Environmental Protection Agency. Permit Applicants'
Guidance Manual for General Facility Standards. Washington,
D.C., 1984 (being drafted).
2. U.S. Environmental Protection Agency. Test Methods for the
Evaluation of Solid Waste, Physical/Chemical Properties.
SW-846, Washington, D.C., 1982. GPO Stock No. 055-002-81001-2
3. U.S. Environmental Protection Agency. Draft RCRA Guidance
Document, Waste Pile Design, Liner Systems. Washington,
D.C., 1982.
4. U.S. Environmental Protection Agency. Draft RCRA Guidance
Document, Landfill Design, Liner Systems and Final Cover.
Washington, D.C., 1980.
5. U.S. Environmental Protection Agency. Lining of Waste
Impoundments and Disposal Facilities. SW-870, Washington,
D.C., March 1983. GPO Stock No. 055-000-00231-2.
6. U.S. Environmental Protection Agency. Landfill and Surface
Impoundment Performance Evaluation. SW-869, September 1980.
GPO Stock No. 055-000-00233-9.
7. U.S. Soil Conservation Service. National Engineering
Handbook 5: Hydraulics. Washington, D.C., 1977. NTIS
No. PB243-644.
8. U.S. Environmental Protection Agency. Evaluating Cover
Systems for Solid and Hazardous Waste. SW-867, Washington,
D.C., September 1982. GPO Stock No. 055-000-00228-2.
9. Hatayama, H.K., J. J. Chen, E.R. deVera, R.D. Stephens,
and D.L. Storm. A Method for Determining the Compatability
of Hazardous Wastes. EPA-600/2-80-076. California
Department of Health Services, Berkely, CA, April 1980.
NTIS NO. PB80-H21005.
6-73
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10. Hatayama, H.K., R.D. Stephens, E.R. deVera, J.J. Chen, and
D.L. Storm. Hazardous WAste Compatibility. In: Disposal of
Hazardous Waste; Proceedings of the Sixth Annual Research
Symposium, Chicago, March 1980. EPA-600/9-80-010, March
Municipal Environmental Research Laboratory, Cincinnati, OH,
March 1980. NTIS No. PB80-175086. pp 21-30.
11. U.S. Environmental Protection Agency. Draft Solid Waste Leach-
ing Procedure Manual. Washington, D.C., 1983.
12. U.S. Environmental Protection Agency. User Guide for the
Hydrogeologic Evaluation of Landfill Performance (HELP) Model.
Washington, D.C. (to be released in 1984).
6.10 CHECKLIST
Table 6-1 is a checklist of permit application requirements
for waste piles. Waste piles are subdivided to identify new
versus existing units and the varying requirements depending on
liner configuration.
The applicant is encouraged to use the checklist and to
incorporate it into the permit application. The checklist identi-
fies the application requirements and provides references to Parts
264 and 270. The applicant should identify the location in the
application of the material addressing each requirement and state
this in the space provided. This will help ensure that the
application is complete. As noted in Section 4.0, it is suggested
that a copy of this checklist be included as part of the permit
application. It will aid the reviewers of the application.
Reviewers will be able to more readily locate specific aspects
of the application, thus facilitating communication between
reviewers and applicants.
Definitions of terms used in the checklist are provided below.
Footnotes included in the checklist are explained on the last page
of the checklist.
6-74
-------
Existing: A waste pile that was in operation or for which
construction had commenced on or before
issuance of Part B permit and which has or will
receive hazardous wastes after January 26, 1983,
New, Type 1: Single liner, non-inspectable. Ground-water
monitoring required (g-w).
New, Type 2: Single liner, inspectable. No ground-water
monitoring.
New, Type 3: Double synthetic liner, leachate collection,
leak detection, and above-ground water.
Ground-water monitoring not required.
New, Type 4: Enclosed dry waste pile. Exempt from liner
and ground-water monitoring requirements.
New, Type 5: Exempt from liner requirement. Ground-water
monitoring probably not required.
An "X" in the checklist indicates that the applicant for that
type of unit must address the specific item or an equivalent
optional item (if available) in the permit application.
An "0" in the checklist indicates that the item is optional in the
permit application. Response to an optional item may eliminate
the necessity of responding to certain items that might otherwise
be required.
An "e" in the checklist indicates that the item does not apply to
"existing portions" of existing units, but does apply to new
portions of existing units.
A blank space in the checklist means that either the subject
requirement is general and serves as a heading for subordinates
listed below it, or that the subject requirement does not apply to
that type of management unit.
6-75
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TABLE 6-1
PERMIT APPLICATION CHECKLIST FOR WASTE PILES
Paqe 1
Part 270 Part 264 Subject Requirement
270.14(b) Part B General Information Requirements
270 14(b)(l) - General description of the facility
270.14(b)(2) 264.13(a) - Chemical and physical analysis of hazardous
wastes to be handled
270.14(b)(3) - Waste analysis plan
cr>
vlj 264.13(b)(l) - Analysis parameters with rationale
01 through (5)
- Test methods for analyzing parameters
- Procedure for collecting representative samples
- Frequency of analyses
- List and description of waste analyses to be
generator supplied
264.13(b)(6) - Waste analysis procedures for ignitable,
and264.17(c) reactive, incompatible wastes
264.13(c) - For off-site facilities, procedures to identify
each waste movement, and
- Procedures for collecting representative
samples
270.14(b)(4) - Security description for active portion of
facility
264.14(a) - Security procedures waiver justification
Existing
X
X
X
X
X
X
X
X
X
X
0
Newj Type lj 1 liner, g-w
X
X
X
X
X
X
X
X
X
X
0
New, Type 2, 1 liner, inpsect
X
X
X
X
X
X
X
X
X
X
0
N
X
X
X
X
X
X
X
X
X
X
0
BW, Type 3, 2 liners
New, Type 4, 0 liners, enclosed
X
X
X
X
X
X
X
X
X
X
0
N
X
X
X
X
X
X
X
X
X
X
0
BW, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
en
i
Page 2
Part 270 Part 264 Subject Requirement
- Unknowing/unauthorized contact with waste
not harmful
- Unknowing/unauthorized disturbance of waste
or equipment cannot cause violation of
Part 264
264.14(b) - Description of 24-hour surveillance system, or
- Description of artificial or natural barriers,
and
- Description of controlled entry/egress
procedures, and
264.14(c) - Description of warning signs
- List of languages on signs
- Statement of 25- foot legibility
- Description of sign locations and numbers
of signs
270.14(b)(5) - General Inspection Schedule and Procedures
Description
264.15(b)(l) - Written schedule
264.15(b)(2) - Statement as to where, at facility, inspection
and schedule and inspection records will be kept
265.1S(d)
E
0
0
X
X
X
X
X
X
X
X
X
X
xisting
N
0
0
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
0
0
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 1 liner, inpsect
N
0
0
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 2 liners
N
0
0
X
X
X
X
X
X
X
X
X
X
ew, Type 4, 0 liners, enclosed
N
0
0
X
X
X
X
X
X
X
X
X
X
ew, Type 5, 0 liners
Location in
Application
Comments
—
-------
WASTE PILES (Continued)
CT>
I
00
Page 3
Part 270 Part 264 Subject Requirement
264.15(b)(l) - Identification of equipment/processes to be
inspected
264.15(b)(3) - Identification of types of problems each
equipment/process to be checked for
264.15(b)(4) - Frequency of inspections by equipment/process
264.15(c) - Schedule of remedial action
270.14(b)(5) and 264.15(a) and - Specific Inspection Requirements for Waste Piles,
270.18(e) 264.254 description of procedures for
- Inspection of liners/covers during and
immediately after installation
- Inspections weekly and after storms for
- Operation of run-on/run-off controls
- Liquids in leak detection system
- Proper functioning of wind dispersal'
controls
- Leachate in and proper operation of
leachate col lection/removal system
270.14(b)(6) Part 264 - Preparedness and Prevention Documentation
Subpart C
- Waiver(s) request and justification
Existing
X
X
X
X
e
X
X
X
e
0
New, Type 1, 1 liner, g-w
X
X
X
X
X
X
X
X
x'
0
New, Type 2, 1 liner, inpsect
X
X
X
X
X
X
X
X
X
0
New, Type 3, 2 liners
X
X
X
X
X
X
X
X
X
X
0
New, Type 4, 0 liners, enclosed
X
X
X
X
X
X
X
0
New, Type 5, 0 liners
X
X
X
X
X
X
0
Location in
Application
Comments
-------
WASTE PILES (Continued)
cr>
10
Page 4
Part 270 Part 264 Subject Requirement
264.32(a) - Description of internal communications/alarm
system(s)
264.34(a) - Documentation of personnel access to internal
communication/alarm system(s)
264.32(b) - Description of external communications/alarm
system(s)
264.34(b) - Documentation of personnel access to external
communications/alarm system(s)
264.32(c) - Description of fire control/extinguishing,
spill control, and decontamination equipment
264.32(d) - Documentation of adequate water volume and
pressure for above equipment
264.33 - Documentation of equipment testing/
maintenance schedule and procedures
264.35 - Documentation of adequate aisle space
264.37 (also - Documentation and descriptions of arrange-
264.52(c)) ments or attempts at arrangements with:
- Police department(s)
- Fire department(s)
- Hospitals
- Local emergency response teams
E
X
X
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
X
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 1 liner, inpsect
N
X
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 2 liners
N
X
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 4, 0 liners, enclosed
If
X
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
01
Page 5
Part 270 Part 264 Subject Requirement
- State emergency response teams
- Emergency response contractors
- Equipment suppliers
264.37(a)(2) - Documentation of agreements designating
primary emergency authority
270.14(b)(7) Part 264 - Contingency Plan Documentation
Subpart D
264.51 and - Criteria for implementation of contingency
264.52(a) plan
264.52(d) - Emergency Coordinators Identification
- Names
- Addresses
- Home/Work Phones
264.55 - Documentation of Qualifications
Documentation of Authority
- Description of notification procedure
264.52(e) - Emergency equipment list
- Documentation of equipment location
b
X
X
X
X
X
X
X
X
X
X
X
X
xi sting
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 linerA g-w
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 1 liner, inpsect
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 2 liners
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 4, 0 liners A enclosed
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
01
I
00
Page 6
Part 270 Part 264 Subject Requirement
- Physical description of equipment
- Statement of equipment capabilities
264.52(f) - Evacuation Plan
- Criteria for implementation
- Description of signal(s) to implement
- Description of primary and alternate routes
264.53 - Contingency Plan Copy Location
- Description of location of facility's
copy of plan
- Number of duplicate copies distributed
and their location
264.54 - Contingency Plan Amendment
- Identification of person responsible
and authorized to change/amend plan
Description of procedure to change/amend
facility copy of plan
- Description of procedure to insure
update of all copies of plan
t
X
X
X
X
X
X
X
X
X
X
xistinq
N
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 1 liner, inpsect
N
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 2 liners
N
X
X
X
X
X
X
X
X
X
X
BW, Type 4, 0 liners, enclosed
N
X
X
X
X
X
X
X
X
X
X
ew, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
I
00
ho
Paqe 7
Part 270 Part 264 Subject Requirement
264.56 - Detailed Emergency Procedures
- Procedure for facility personnel
notification
- Procedure for state/local agency
notification
- Procedure for identification of character,
source, amount, and areal extent of
released materials
• Procedure for assessment of environment/
human health hazards
- Identification of On-Scene Coordinator
for geographic area
- Description of specific responses and
control procedures for
Fire
Explosion
Spill
- Description of process shutdown and
monitoring procedures
- Description of cleanup procedures and
associated material treating, storing,
disposal procedures
t
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
ew, Type I, 1 liner, g-w
N
X
X
X
X
X
X
X
X
X
X
ew. Type 2, 1 liner, inpsect
N
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 2 liners
N
X
X
X
X
X
X
X
X
X
X
ew, Type 4, 0 liners, enclosed
N
X
X
X
X
X
X
X
X
X
X
ew, Type 5, 0 liners
Location in
Application Comments
-------
WASTE PILES (Continued)
CTi
CO
co
Page 8
Part 270 Part 264 Subject Requirement
- Description of emergency equipment
cleaning and refitting procedures
- Description of procedures to insure
incompatible waste segregation during
cleanup
[Note: There are no §270 requirements which parallel Part 264, Subpart E.
However, the applicant should be familiar with the following sections
of the regulations since the requirements in them will be enforceable
under any permit received.
Part 264, Subpart E, §264.70 through §264.77
Part 270.30, Subpart C
The applicant should be prepared to respond to inquiries by the
permit application reviewers regarding these requirements.]
270.14(b)(8) - Preventive Procedures, Structures, and Equipment
Documentation, including description of
equipment/procedures to
- Prevent hazards during unloading operations
- Prevent water supply contamination
- Mitigate equipment failure and power outages
Prevent undue personnel exposure to wastes
270.14(b)(9) 264.17 - Prevention of Accidental Ignition or Reaction
Documentation
- Description of separation and protection of
ignitable, reactive, incompatible wastes
t
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
X
X
X
X
X
X
X
ew, Type 2, 1 liner, inpsect
N
X
X
X
X
X
X
X
ew, Type 3, 2 liners
N
X
X
X
X
X
X
X
sw, Type 4, 0 liners, enclosed
N
X
X
X
X
X
X
X
ew, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
CTi
00
Page 9
Part 270 Part 264 Subject Requirement
- Description of ignitable, reactive,
incompatible wastes handling procedures
- Description of number, location, and type
of warning/prohibition signs
- Documentation that procedures are adequate
to prevent accidental ignitions or reactions
270.14(b)(9) and 264.17(b) - Specific Ignitable/Reactive Waste Requirements
270 18(g) and for Waste Piles if I/R waste stored.
270.18(h)
264.256 - Procedures that render waste nonreactive
or nonignitable, or
- Procedures for preventing reactions, and
- Procedures for protecting wastes
264.257 - Incompatible waste segregation or
protection procedures
270.14(b)(10) - Traffic Documentation, identification of:.
- Waste movement routes
- Number of movements by type vehicle
- Quantity of waste moved per movement
per vehicle
- Traffic control signals and personnel
Existing
X
X
X
X
0
0
X
X
X
X
X
New, Type 1, 1 liner, g-w
X
X
X
X
0
0
X
X
X
X
X
New, Type 2, 1 liner, inpsect
X
X
X
X
0
0
X
X
X
X
X
New, Type 3, 2 liners
X
X
X
X
0
0
X
X
X
X
X
New, Type 4, 0 liners, enclosed
X
X
X
X
0
0
X
X
X
X
X
New, Type 5, 0 liners
X
X
X
X
0
0
X
X
X
X
X
Location in
Application
Comments
-------
WASTE PILES (Continued)
CT>
I
oo
en
Page 10
Part 270 Part 264 Subject Requirement
Route surface composition and load
bearing capacity
270. 14(b)(ll) - Facility Location Documentation
270.14(b)(ll)(i) - Political jurisdiction identified (new
and (ii) facilities only)
Comparison to Appendix VI of Part 264
- Demonstration that faults with displacement
in Holocene time are more than 3,000 feet
from facility (western states)
264.18(a) - If Holocene-time faults are within 3,000 feet,
demonstration that no faults pass within
200 feet of unit sites (western states)
270. 14(b)(ll), 264.18(b) - Documentation of facility location relative
(iii) through (v) to 100-year flood plain level or wave
action flooding
If unit in flood plain, documentation
that facility can withstand the 100-year
flood without washout by:
- Analysis of hydrodynamic/hydrostatic forces
resulting at site from 100-year flood, and
- Presentation of operating units and flood
protection devices design and how they will
prevent washout, or
E)
X
X
X
X
X
X
X
X
-------
WASTE PILES (Continued)
CTi
I
CD
cr>
Page 11
Part 270 Part 264 Subject Requirement
- Plan for removal of waste before washout
including,
- lining of removal relative to flood levels
- Estimated time to remove all waste
- Location to which waste will be moved
and proof of compliance with Parts 270
and 264 through 267 of this Chapter
- Detailed description of personnel,
equipment, and procedures for waste
removal sufficient to insure availability
in time for use
- Analysis of potential for discharge
during waste movement
- A plan documenting how and on what time
schedule the facility will comply with
§264.18(b) if not in compliance
(existing facilities only)
270. 14(b)(12) 264.16 - Personnel Training Program Documentation
Outline of introductory and continuing
personnel training programs
Identification and qualifications of
program instructor
Existing
0
0
0
0
0
0
X
X
X
New, Type 1, 1 liner, g-w
0
0
0
0
0
0
X
X
New, Type 2, 1 liner, inpsect
0
0
0
0
0
0
X
X
New, Type 3, 2 liners
0
0
0
0
0
0
X
X
New, Type 4, 0 liners, enclosed
0
0
0
0
0
0
X
X
N
0
0
0
0
0
0
X
X
ew, Type 5, 0 liners
Location in
Appl i cat ion
Comments
-------
WASTE PILES (Continued)
Page 12
Part 270 Part 264 Subject Requirement
- Brief description of how training program
meets actual job tasks
- Description of procedures to insure all
appropriate personnel receive appropriate
training and receive annual training review
- Description of records to be kept, their
i location, and procedures to insure they are
Co retained for proper length of time
270.14(b)(13) 264.112 - Closure Plan Documentation
- Description of partial and final closure
procedures
- Description of maximum unclosed portion
during facility life
- Estimate of maximum waste inventory in
storage/treatment during facility life
264.114 - Equipment decontamination procedure
- Estimated year of closure
254.113 - Description of closure schedule including
- Total time to close
270.14(b)(13) 254.113 - Trackable intervening closure activities
E
X
X
X
X
X
X
X
X
X
X
X
xisting
M
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1. 1 liner, g-w
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 1 liner, inpsect
N
X
X
X
X
X
X
X
X
X
X
X
ew. Type 3, 2 liners
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 4, 0 liners, enclosed
N
X
X
X
X
X
X
X
X
X
X
X
ew. Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
Page 13
Part 270
Part 264
Subject Requirement
en
00
oo
270.14(b)(13) and 264.112
270.18(1)
264.258(a)
270.14(b)(13)
264.258(b)
264.117 and
264.118
- Location(s) and number of copies of
closure plan
- Identification of person responsible for
storage and updating of facility copy of
closure plan
- Procedure for updating all other copies
of closure plan
- Specific Closure Plan Requirements for
Waste Piles
- Procedure for removal and/or decontami-
nation of all wastes and materials/equipment
associated with the waste pile
- Procedure for closing in conformance
with landfill closing requirements
- Post-Closure Plan Documentation
- Description of ground-water monitoring
activities and frequencies
- Description of maintenance activities
and frequencies for:
- Final containment structures
- Facility monitoring equipment
Existing
New, Type 1. 1 liner, g-w
I New. Type 2. 1 liner, inpsect
New, Type 3. 2 liners
. Type 4. 0 liners, enclosed
New, Type
New. Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
CT>
I
00
ID
Page 14
Part 270 Part 264 Subject Requirement
- Location(s) and number of copies of
post-closure plan
- Identification and location (address and
phone number) of person responsible for
storage and updating of facility copy of
post-closure plan prior to closure
- Identification and location (address and
phone number) of person responsible for
storage and updating facility copy of post-
closure plan during post-closure period
- Procedure for updating all other copies
of post-closure plan
270.14(b)(13) and 264.118 and - Specific Post-Closure Plan Requirements for
270 18(i ) 264.2S8(b) Waste Piles
- Procedures for post-closure care that
meet the requirements for landfills
270. 14(b)(14) 264.120 - Documentation of Notice on Deed (existing
facilities only)
- Statement that land used to manage wastes
- Statement of restricted use per §284.117(c)
270.14(b)(15) 264.142 - Closure Cost Estimate
264.143 and - Documentation of a financial assurance mechanism
264 146 for closure that is one of the following:
Existing
X
X
X
X
X
X
X
X
X
Hew. Type 1, 1 liner, g-w
X
Hew. Type 2, 1 liner, inpsect
X
Mew. Type 3, 2 liners
X
New. Type 4, 0 liners, enclosed
X
New, Type 5, 0 liners
X
Location in
Application
Comments
-------
WASTE PILES (Continued)
I
10
o
Page 15
Part 270 Part 264 Subject Requirement
264.151(a) - Closure trust fund
264.151(b) - Surety bond guaranteeing payment
264.151(c) - Surety bond guaranteeing performance
264.151(d) - Closure letter of credit
264. 151(e) - Closure insurance
264.1S(f) - Financial test and corporate guarantee
and (h)
- Multiple financial mechanism for one facility
- Single financial mechanism for multiple
facilities
270.14(b)(16) 264.144 - Post-Closure Cost Estimate1
264.145 and - Documentation of a financial assurance mechanism
264.146 for post-closure that is one of the following:
264.151(a) - Closure trust fund
264.151(b) - Surety bond guaranteeing payment
264.151(c) - Surety bond guaranteeing performance
264.151(d) - Post-closure letter of credit
264.151(e) - Post-closure insurance
t
0
0
0
0
0
0
0
0
X
0
0
0
0
0
xisting
N
0
0
0
0
0
0
0
0
ew, Type 1, 1 liner, g-w
N
0
0
0
0
0
0
0
0
ew, Type 2, 1 liner^ inpsect
N
0
0
0
0
0
0
0
0
ew. Type 3, 2 liners
N
0
0
0
0
0
0
0
0
ew, Type 4, 0 liners, enclosed
N
0
0
0
0
0
0
0
0
ew, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
01
V£>
Page 16
Part 270 Part 264 Subject Requirement
264.151(f) - Financial test and corporate guarantee
and (h)
- Multiple financial mechanism for one facility
- Single financial mechanism for multiple
facilities
270.14(b)(17) 264.147 - Documentation of Insurance
- Request for variance from insurance
264.151(i) - Insurance for sudden/accidental occurrences
and (j)
- Insurance for nons udden/acc i dental occurrences
264.151(g) - Financial test for liability coverage
270.14(b)(18) 264.149 - Documentation of a State Required Financial2
Mechanism for Closure, Post-Closure, or
Liability including
- EPA I.D. number
- Facility name
- Facility address
- Amounts of liability coverage or funds
assured
2
264.150 - Documentation of State Assumed Responsibility
for Closure Post-Closure or Liability including
Existing
0
0
0
X
0
X
X
0
0
0
0
0
0
0
New, Type 1, 1 liner, g-w
X
0
X
X
0
0
0
0
0
0
0
New, Type 2, 1 liner, inpsect
X
0
X
X
0
0
0
0
0
0
0
New, Type 3, 2 liners
X
0
X
X
0
0
0
0
0
0
0
Ni
X
0
X
X
0
0
0
0
0
0
0
>w, Type 4, 0 liners, enclosed
New, Type 5, 0 liners
X
0
X
X
0
0
0
0
0
0
0
Location in
Application
Comments
-------
WASTE PILES (Continued)
rv>
Page 17
Part 270 Part 264 Subject Requirement
- Letter from State describing State's
responsibilities
- Facility EPA I.D. number
- Facility name
- Facility address
- Amounts of liability coverage or funds
assured
270.14(b)(19) - Topographic map showing a distance of 1,000 feet
around facility at a scale of not more than
1 inch equals 200 feet that clearly shows
- Contours
- Proper contour intervals
- Map scale and date
- 100-year flood plain area
- Surface waters and intermittent streams
- Surrounding land uses
270.14(b)(19) - Wind rose
- North orientation
- Legal boundaries of facility site
Existing
0
0
0
0
0
X
X
X
X
X
X
X
X
X
X
N(
0
0
0
0
0
X
X
X
X
X
X
X
X
X
X
-Wt Type 1, 1 liner, g-w
New, Type 2, 1 liner, inpsect
0
0
0
0
0
X
X
X
X
X
X
X
X
X
X
Ni
0
0
0
0
0
X
X
X
X
X
X
X
X
X
X
;wt Type 3, 2 liners
New, Type 4, 0 liners, enclosed
0
0
0
0
0
X
X
X
X
X
X
X
X
X
X
Nl
0
0
0
0
0
X
X
X
X
X
X
X
X
X
X
;w, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
co
Page 18
Part 270 Part 264 Subject Requirement
- Access control
- Injection and withdrawal wells onsite
and off site
- Buildings and recreation areas
- Run-off control systems
- Access and internal roads
- Storm, sanitary, and process sewerage systems
- Loading and unloading areas
- Fire control facilities
- Barriers for drainage or flood control
- Location of past or present operational
units and equipment cleanup areas
270.17, 270.18,
270.20 and 270.21 Part B Specific Information Requirements
270.18 - Specific Requirements for Waste Piles
270.18(a) - List of hazardous wastes placed or to be
placed in each waste pile
270. 18(b) 264.250(c) - Documentation of general exemption from
§264.251 and Part 264, Subpart F, including
- Waste pile protection from precipitation
E
X
X
X
X
X
X
X
X
X
X
X
Kistinq
N<
X
X
X
X
X
X
X
X
X
X
X
sw. Type 1, 1 liner, g-w
N
X
X
X
X
X
X
X
X
X
X
X
BW, Type 2, 1 liner, inpsect
N<
X
X
X
X
X
X
X
X
X
X
X
BW, Type 3, 2 liners
New, Type 4, 0 liners, enclosed
X
X
X
X
X
X
X
X
X
X
X
X
X
New, Type 5, 0 liners
X
X
X
X
X
X
X
X
X
X
X
Location in
Application
Comments
-------
WASTE PILES (Continued)
I
VO
Page 19
Part 270 Part 264 Subject Requirement
- Procedures for insuring liquids are not
placed in pile
- Description of run-on controls
- Description of wind dispersal controls
other than wetting
- Decomposition/ react ions do not cause
leachate generation
270.18(c) 264.251(a) - Detailed plans and an engineering report
describing
270.18(c)(l) 264.251(a)(l) - Liner system construction (new only)
- Material of construction
- Chemical properties
- Physical strength
- Thickness
- Foundation design/integrity
- Area covered
- Liner system integrity against (new only)
- Internal and external pressure
gradients
Existing
e
e
e
e
e
e
e
e
e
e
New, Type 1, 1 liner, g-w
X
X
X
X
X
X
X
X
X
X
New, Type 2, 1 liner, inpsect
X
X
X
X
X
X
X
X
X
X
New, Type 3, 2 liners
X
X
X
X
X
X
X
X
X
X
New, Type 4, 0 liners, enclosed
X
X
X
X
New, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
Page 20
Part 270
Part 264
Subject Requirement
264.251(a)(2)
I
<£>
264.251(b)
- Contact with waste/leachate
- Climatic conditions
- Installation stresses
- Daily operational stresses
Leachate collection and removal system
to maintain less than one foot of
leachate on liner including
- Materials of construction
- Chemical resistance to waste/leachate
- Strength sufficient to prevent collapse
- Provisions to prevent clogging
Liner system/leachate system exemption
including
- Nature and quantity of wastes
- Alternative design and operation
- Pile location description
- Hydrogeologic setting
- Attenuative capacity of materials
between pile, ground and surface
waters
Existing
New, Type 1, 1 liner, g-w
New, Type 2. 1 liner, inpsect
New. Type 3, 2 liners
New
lyp
. T;
4. 0 liners, enclosed
New. Type 5. 0 liners
Location in
Application
nts
-------
WASTE PILES (Continued)
CT>
I
CO
cr>
Page 21
Part 270 Part 264 Subject Requirement
Documentation of no migration to ground/
surface waters at any future time
270.18(c)(2) 264.251(c) - System for control of run-on from peak
discharge of a 25-year storm
270.18(c)(3) 264.251(d) - System for control of run-off water
volume of a 24-hour, 25-year storm
270.18(c)(4) 264.251(e) - Procedures to manage collection and
holding facilities associated with
run-on and run-off control systems
270.18(c)(5) 264.251(f) - Wind dispersal control procedures
270.18(d) 264.252(a) - Documentation for Part 264, Subpart F
exemption including
- Pile and liners above seasonal high
water table
- Two liners meeting requirements of
§264.251(a)(l)
- Leak detection system between liners
- Leachate system meeting §264.251(a)(2)
requirements
264.253(a) - Documentation for Part 264, Subpart F
exemption including
b
X
X
X
X
•
xi sting
N
X
X
X
X
ew, Type 1, 1 liner, g-w
N
X
X
X
X
X
ew, Type 2, 1 liner, inpsect
N
X
X
X
X
X
X
X
X
X
ew, Type 3, 2 liners
N
X
X
X
X
ew, Type 4, 0 liners, enclosed
N
X
X
X
X
X
ew, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
cr>
i
10
Page 22
Part 270 Part 264 Subject Requirement
- Pile and liners above seasonal high
water table
- Liner meets §264.251(a)(l) requirements
- Soil characteristics/depths
- Leachate system meets §264.251(a)(2)
requirements
- Schedule/procedures for liner inspection
by waste removal
- Sufficient liner strength/thickness to
allow periodic removal /replacement
of wastes
270.18(f) - Description of treatment carried out in or
on the pile including
- Details of treatment process
Equipment used
- Nature and quality of residuals
270.14(c) Part 264 Part B Protection of Ground-Water Information3
Subpart F Requirements for Waste Piles
270.14(c)(l) - Interim status period ground-water monitoring
data summary
t
X
X
X
X
xisting
N
X
X
X
X
ew, Type 1, 1 liner, q-w
N
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 1 liner, inpsect
N
X
X
X
X
ew, Type 3, 2 liners
h
X
X
X
X
ew, Type 4^ 0 liners, enclosed
N
X
X
X
X
ew, Type 5, 0 liners
Location in
Application Comments
-------
WASTE PILES (Continued)
01
I
ID
00
Page 23
Part 270 Part 264 Subject Requirement
270. 14(c)(2) - Identification of uppermost and hydraulically
interconnected aquifers under facility including
- Water flow rate and direction
- Bases for identification
270.14(c)(3) and - Topographic map
270.14(b)(19)
- Delineation of property boundary
264.95(b) - Delineation of waste management area
264.95(a) - Delineation of proposed point of compliance
- Ground-water monitoring well locations
- Location of aquifers
270. 14(c)(4)(i) - Descriptions of existing contamination
through (ii)
- Delineation of plume extent
- Appendix VIII constituents concentrations
- Concentrations throughout plume
- Maximum concentration in plume
270.14(c)(5) 264.97 - Detailed plans and an engineering report of
Ground-Water Monitoring Program
264.97(a) - Description of wells
E
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 linerj g^w
N
ew, Type 2^ 1 liner, inpsect
N
ew, Type 3L2 liners
N
ew, Type 4j 0 liners, enclosed
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 5, 0 liners
Location in
Application Comments
-------
HASTE PILES (Continued)
vo
vo
Page 24
Part 270 Part 264 Subject Requirement
- Number of wells
- Locations
- Depths
- Assurance of unaffected background
water measurement
- Assurance of compliance point
ground-water measurement
264.97(c) - Casing description
264.97(d) - Description of sampling/analysis procedures
- Sample collection methods
- Sample preservation/shipment
- Analytical procedures
- Chain of custody control
264.97(e) - Documentation of proper/adequate
analytical procedures
264.97(f) - Procedure for determination of ground-
water elevation with each sample
270. 14(c)(6) 264.91(a)(4) - Description of Detection Monitoring Program3'5
and 264.98 including
E
X
X
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
ew^Type 2, 1 liner^ inpsect
N
ew, Type 3, 2 liners
N
ew, Type 4, 0 linerSj enclosed
N
X
X
X
X
X
X
X
X
X
X
X
X
X
ew. Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
en
i
o
o
Page 25
Part 270 Part 264 Subject Requirement
270. 14(c)(6)(i) 264.93 and - List of indicator parameters, waste
264.98(a) constituents, reaction products to be
monitored for, including
- Type, quantities, concentrations expected
in wastes
- Mobility, stability, persistence in
unsaturated zone
- Detectability in ground- water
270.14(c)(6)(ii) 264.98(a)(4) - Background ground-water concentration
and (iii) and values and coefficients of variation
26498(c)(l) established by one of the following :
264.98(c)(3) - Use of an appropriate ground-water
monitoring system, and
264.97(g)(l) - Quarterly sampling of upgradient wells
for one year, or
264.97(g)(3) - Quarterly sampling of other wells for
one year, and
264.97(g)(4) - Data from a minimum of one sample/well
and minimum of four samples per
quarter, or
- Presentation of procedures to
calculate such values
E
X
X
X
X
X
0
0
0
0
0
xisting
N
X
X
X
X
X
0
0
0
0
0
ew, Type 1, 1 liner, g-w
New, Type 2, 1 liner, inpsect
N
ew, Type 3, 2 liners
New, Type 4, 0 liners, enclosed
New, Type 5, 0 liners
X
X
X
X
X
0
0
0
0
0
Location in
Application
Comments
-------
WASTE PILES (Continued)
Page 26
Part 270
Part 264
270.14(c)(6)(ii) 264.98(b)
270.14(c)(6)(iv) 264.98(d)
cr>
i—"
o
264.98(e)
264.98(f) and
264.97(d) and
(e)
264.98(g)
Subject Requirement
Description of an appropriate ground-water
monitoring system to be installed at the
compliance point
Procedures for collecting semi-annual
ground-water samples at the compliance
point during
- Active life
- Closure period
- Post-closure period
Procedure for annual determination of
uppermost aquifer flow rate and direction
Documentation of sample collection and
analysis procedures
Procedure for determining a statistically
significant increase for any monitored
parameter or constituent by
- Comparing compliance point data to
background value data using the
procedures in §264.97(h)(l) or (2), and
- Providing an estimate of the time
period after sampling completion
necessary to obtain results
Existing
New, Type 1, 1 liner, g-w
New, Type 2, 1 liner, inpsect
New, Type 3, 2 liners
New. Type 4, 0 liners, enclosed
New, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
o
ro
Page 27
Part 270 Part 264 Subject Requirement
264.98(h) - Procedure to be implemented if a
statistically significant increase in any
constituent or parameter is identified at
any compliance point monitoring well,
including
264.98(h)(l) - Written notification to Regional
Administrator
264.98(h)(2) - Sample collection and analysis methods
for all Appendix VIII constituents at
all monitoring wells
264.98(h)(3) - Method for establishing Appendix VIII
constituent background values
264.98(h)(4) - Preparation of an application for permit
modification to establish compliance
monitoring
270. 14(c)(7) 264.91(a)(l) - Description of Compliance Monitoring Program7,
and 264.99 including
- List of wastes previously handled at facility
o
- Characterization of contaminated ground-water
- Hazardous constituents identified
- Hazardous constituents concentrations
264.99(b) - Description of compliance monitoring system
at the compliance point
t
X
X
X
X
X
0
0
0
0
0
0
xi sting
N
X
X
X
X
X
0
0
ewj Type 1^ 1 liner, g-w
N
ew. Type 2. 1 liner, inpsect
N
ew, Type 3^2 liners
N
ew, Type 4. 0 liners, enclosed
N
X
X
X
X
X
0
0
ew, Type 5, 0 liners
Location in
Application Comments
-------
WASTE PILES (Continued)
CTl
O
CO
Page 28
Part 270 Part 264 Subject Requirement
- List of hazardous constituents to be
compliance monitored
264.96 - Proposed compliance period
264.99(d) - Procedure for collecting quarterly samples
at compliance point during compliance period
264.99(c)(3) - Procedures for establishing background
concentration values for constituents that
are based on one of the following:
- Use of an appropriate ground-water
monitoring system, and
264.97(g) - Data that is available prior to permit
issuance
- Data that accounts for measurement errors
in sampling and analysis
- Data that accounts for seasonal ground-
water quality fluctuations
- Data from a minimum of one sample per
well and a minimum of four samples from
monitoring system, each time system
is sampled
270.14(c)(7)(iv) 264.92 and - Proposed concentration limits for
264.99(c)(l) , constituents with justification based on
(2)
- §264.94(a)(l) and §264.97(g)
t
0
0
0
0
0
0
0
0
0
0
0
xi sting
N
0
0
0
0
0
0
0
0
0
0
ew, Type 1^ 1 liner, j^w
N
ew, Type 2, 1 liner, inpsect
N
ew, Type 3^ 2 liners
N
ew, Type 1, 0 liners, enclosed
N
0
0
0
0
0
0
0
0
0
0
ew, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
o
-p*
Page 29
Part 270 Part 264 Subject Requirement
- §264.94(a)(2)
- §264.94(b) and §264. 99(c)(l)
264.99(e) - Procedure for annual determination of
uppermost aquifer flow rate and direction
264.99(f) - Procedures for annual testing of all
compliance point wells for Appendix VIII
constituents
264.99(g) - Documentation of all sampling and
analysis procedures
264.99(h) - Procedures for determining a statistically
significant increase for any monitored
constituent by
- Comparing compliance point data to the
concentration limit using the procedure
in §264.97(h)(2)
- Providing an estimate of the time period
after sampling completion necessary to
obtain results
264.99(i) - Procedures to be implemented if the ground-
water protection standard is exceeded at any
compliance point monitoring well, including
264.99(i)(l) - Written notification to Regional
Administrator
t
0
0
0
0
0
0
0
0
0
0
xisting
N
0
0
0
0
0
0
0
0
0
0
ew, Type 1, 1 liner, g-w
N
ew, Type 2^ 1 liner, inpsect
N
ewj Type 3, 2 liners
N
ewi Type 4, 0 liners, enclosed
N
0
0
0
0
0
0
0
0
0
0
ew, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Continued)
Page 30
Part 270 Part 264 Subject Requirement
264.99(i)(2) - Preparation of an application for permit
Modification to establish a corrective
action program, including
Details of program to comply with
ground-water protection standard
270.14(c)(7)(w) 264.99(i)(2) - Details of ground-water monitoring to
,-r, (ii) demonstrate effectiveness of program
I q
o 270. 14(c)(8) 264.91(a)(2) - Description of Corrective Action Program3,
en and 264.100 including
270.14(c)(8)(i) - Characterization of contaminated ground-water
264.100(a)(l) - Identified hazardous constituents
- Concentrations of hazardous constituents
270.14(c)(8)(ii) 264.100(a)(2) - Concentration limit for each hazardous
constituent
270. 14(c)(8)(iii) 264.100(b) - Detailed plan and an engineering report
describing the corrective actions to be taken
at the compliance point
264.100(c) - Time period necessary to implement
corrective action program
270.14(c)(8)(iv) 264.100(d) - Description of ground-water monitoring
program that will be sufficient to assess
the adequacy of corrective action
E
0
0
0
0
0
0
0
0
0
0
0
xisting
N
0
0
0
0
0
0
0
0
ew, Type 1, 1 liner, g-w
N
ew, Type 2, 1 liner, inpsect
N
ew. Type 3, 2 liners
N
ew, Type 4, 0 liners, enclosed
N
0
0
0
0
0
0
0
0
ew, Type 5, 0 liners
Location in
Application
Comments
-------
WASTE PILES (Concluded)
O
CT>
Page 31
Part 270 Part 264 Subject Requirement
264.91(a)(3) - Description of the corrective action to be
and 264. 100(e) taken for constituents in ground-water
between compliance point and downgradient
faci 1 i ty boundary
264.100(g) - Procedure and content for semi-annual ly
submitting written reports to the Regional
Administrator on program effectiveness
Part B Certification and Signatories
270.11(d) - Certification paragraph
270.11(a) - Appropriate signatory
b
0
0
X
X
xisting
N
0
0
X
X
ew, Type 1, 1 liner, g-w
N
X
X
ew, Type 2, 1 liner^ inpsect
N
X
X
aw. Type 3, 2 liners
N
X
X
ew, Type 4^ 0 liners, enclosed
N
0
0
X
X
ew, Type 5, 0 liners
Location in
Application
Comments
-------
FOOTNOTES FOR WASTE PILES
1 Notwithstanding the fact that the applicant intends to
remove all hazardous materials at closure, an existing
waste pile that does not have a liner meeting the Part 264
liner requirements and has not received a variance will
be required to present plans to close the facility as a
landfill in the event that all hazardous waste cannot be
removed at closure. Such units are also required to have
contingent post-closure plans and financial plans similar
to those for landfills.
2 State-specific. Contact State or Regional EPA representa-
tives to discuss requirements.
3 New, Type 5 units are not automatically exempt from ground-
water protection standards of Subpart F. Applicants are
subject to indicated requirements unless a Section 264.90(b)(4)
waiver has been granted.
4 If data are available, they should be included.
5 Applies to new facilities, and existing facilities at which
contamination has not been detected.
6 New facilities and existing facilities containing only
waste piles must present procedures for determining these
background values or the values themselves. In addition,
depending on their condition, existing waste piles may be
required to collect ground-water quality data prior to
submission of a Part B permit application.
7 Required of existing facilities where ground-water monitoring
data indicate the presence of hazardous constituents. Under some
circumstances, new, Type 1 or Type 5 units and existing units
without contamination may have certain portions of a Compliance
Monitoring Program in the permit on "stand-by."
8 Applicable to existing facilities with indications of hazardous
constituents in the ground water.
9 Applicability to existing facilities will be case-by-case, based
on monitoring data indicating ground-water contamination. Under
some circumstances, new, Type 1 or Type 5 units and existing
units without contamination may have a Corrective Action Plan
included in permit on "standby."
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SECTION 7.0
LAND TREATMENT UNIT PERMIT APPLICATION GUIDANCE
7.1 SCOPE AND FORMAT
This section contains information and guidance applicable
to Part B permit applications for hazardous waste land treatment
units, which are waste management units at which hazardous wastes
are applied onto or incorporated into the soil surface. The
primary objective of land treatment unit operations must be to
degrade, transform or immobilize hazardous constituents in the
waste. The Part 264 and Part 270 regulations for land treatment
units include requirements in the following major subject areas:
treatment demonstration, land treatment program, design and
operating requirements, food chain crops, unsaturated monitoring
closure and post closure care, ignitable and reactive wastes,
and incompatible wastes.
Each major subject in this section is divided into the
following three parts: (1) Federal requirement, (2) guidance
on achieving the Part 264 standard, and (3) guidance in addressing
the application information requirements. The first part defines
the specific information requirement contained in Part 270, as
well as the corresponding technical standard contained in Part
264 . The second part provides references and general guidance
on how the Part 264 standard can be met, while the third part
provides the permit applicant with detailed guidance on what
information should be included in the permit application to
adequately address the Part 270 requirement.
7-1
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This section contains specific information items to be
included in Part B of the permit application for hazardous waste
land treatment units. These items should be included along with
the general facility information and the groundwater protection
information. Do not omit any item or part of any item without
providing a clear explanation of why the item was omitted.
7.2 SPECIAL PERMITTING PROCEDURES
Because all land treatment units are required to complete a
treatment demonstration prior to obtaining a full-scale permit,
special permitting procedures are provided. The regulations allow
the applicant to use, among other means, field or laboratory tests
to make the treatment demonstration. However, field and laboratory
tests can only be performed under a permit because they involve the
treatment and disposal of hazardous waste. The special land
treatment permitting procedures provide the applicant with various
approaches for obtaining a permit to conduct these field or labora-
tory tests, which will be necessary in many cases to successfully
complete the treatment demonstration. Three types of permits
pertain to land treatment units:
- Short-term treatment demonstration permit;
- Full-scale facility permit; and
- Two-phase permit.
Section 270.63 defines the nature of the short-term and two-phase
permits. A reprint of this section is provided in Section 7.3 of
this Manual. Table 7-1 outlines the essential aspects of these
permits.
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TABLE 7-1. LAND TREATMENT PERMITS
Short-Term Treatment Demonstration Permit
Small-scale lab or field experiment to demonstrate that
hazardous constituents in waste can be treated in the proposed
land treatment unit.
Used when insufficient "treatment" information exists to satisfy
treatment demonstration requirement or to establish preliminary
permit conditions for full-scale facility permits.
Permit must contain only provisions necessary to meet the
general performance standards in §264.272(c).
- Public comment and hearing required.
Full-Scale Facility Permit
Used when complete data have been collected to satisfy the
treatment demonstration requirement (i.e., using available
literature data, operating data, or lab or field test results).
Permit must contain provisions necessary to meet all the
Subpart M, Part 264 requirements and all other applicable
Part 264 standards.
- Public comment and hearing required.
Two-Phase Permit
- Combination of above two permits:
Phase 1: Treatment demonstration.
Phase 2: Full-scale facility design and operation.
- Used when substantial, but incomplete, "treatment" data exists.
Sufficient data are not available to completely satisfy treat-
ment demonstration, but sufficient data are available to
determine the preliminary set of full-scale facility permit
conditions.
Phase 1 and 2 permits written based on substantial but
incomplete information; Phase 2 permit modified to incorporate
results of Phase 1.
Avoids the burden of two separate permitting procedures (e.g.,
only one public comment and hearing is necessary rather
than two).
Phase 1 permit contains provisions necessary to meet
treatment demonstration; Phase 2 contains provisions to meet
7-3
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requirements and all other applicable Part 264 standards.
A short-term treatment demonstration permit authorizes small-
scale laboratory or field tests. This permit contains only pro-
visions necessary to meet the general performance standards in
§264.272(c). The applicant only submits a treatment demonstration
plan in the permit application (see Table 7-2). An applicant
should apply for this permit when insufficient treatment informa-
tion exists to satisfy the treatment demonstration or to at least
establish preliminary permit conditions for the full-scale
facility. The normal permitting procedures including public
comment and hearing, must be followed. After the lab or field
tests are complete, the applicant should apply for the full-scale
facility permit.
The full-scale facility permit is the "normal" permit used
when complete data has been collected to satisfy the treatment
demonstration. The applicant would submit both the treatment
demonstration plan and results, as well as all the other informa-
tion described in Table 7-2 for a full-scale facility permit.
The two-phase permit is a combination of the short-term
permit and full-scale permit. Phase 1 of the permit includes
conditions for the treatment demonstration and Phase 2 includes
provisions for the full-scale facility design and operation.
This permit should be used in cases in which substantial, but
incomplete treatment data exists to satisfy the treatment
demonstration, but sufficient data are available to determine
the preliminary set of full-scale facility conditions. The
applicant submits the same information as for the full-scale
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TABLE 7-2. PERMIT APPLICATION CONTENT
Short-Term Treatment Demonstration Permit
Treatment demonstration plan including provisions to meet the
§264.272(c) performance standard (see Section 7.3.3.1).
Results submitted to the Regional Administrator at end of study
(and as part of full-scale facility permit application). (See
Section 7.3.3.2 for guidance on results.)
Full-Scale Facility Permit
Information addressing the general standards applicable to all
facilities - §270.14, ("General Information Req."), - See
Permit Applicant's Guidance Manual for General Facility
Standards
Information addressing the Subpart M, Part 264 requirements -
§270.20 -
— Treatment Demonstration Plan and Results
— Land Treatment Program
— Design and Operating Requirements
— Food Chain Crops
— Closure and Post-Closure Care
-- Ignitable and Reactive Waste
-- Incompatible Wastes
Information addressing the ground-water protection requirements
in Subpart F, Part 264 (see Ground Water Section of this Manual)
Two-Phase Permit
- Same as for full-scale facility permit except that the results
of the treatment demonstration are submitted after completion
of the treatment demonstration (Phase 1).
7-5
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facility permit, except the results of the treatment demonstration
are submitted after the completion of the treatment demonstration
(Phase 1). The permitting official writes a draft permit for
Phases 1 and 2, and then modifies the Phase 2 Permit after the
treatment demonstration results are submitted. The primary advan-
tage of the two-phase permit is that it avoids two separate permit-
ting procedures, one for the treatment demonstration and one for
the full-scale facility permit.
A final approach for completing treatment demonstration field
tests under a permit is available for existing land treatment units
with interim status. Because permittees interim status facilities
are "treated as though they have been issued permits" (while await-
ing completion of the Part 264 permitting process), field tests
may be conducted at these units provided that these tests are not
carried out in a manner that will lead to a violation of the interim
status standards. If the tests are likely to cause a violation of
the interim status standards, one of the special permits (short-term
or two-phase) described above must be obtained.
In summary, an applicant who can complete the treatment
demonstration based on available literature data or operating data
from an existing interim status land treatment unit (see Section
7.3) may apply directly for a full-scale facility permit. An
applicant who must use laboratory or field studies to complete the
treatment demonstration, however, has two options. He may either
(1) apply for a short-term treatment demonstration permit and then
a full-scale facility permit; or (2) apply for a two-phase permit.
In addition, field studies may be completed at an interim status
7-6
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land treatment unit. The applicant is advised to review these
various options with the permit writer at the pre-application
meeting.
7.3 TREATMENT DEMONSTRATION
7.3.1 Federal Requirement
The Part B permit application for facilities that use land
treatment to dispose of hazardous waste must include plans for
conducting a treatment demonstration and presenting the complete
demonstration results (unless applying for a two-phase permit).
As stated in §270.20(a), the Part B application must include:
A description of plans to conduct a treatment demonstration
as required under §264.272. The description must include
the following information:
(1) The wastes for which the demonstration.will be made and
the potential hazardous constituents in the wastes;
(2) The data sources to be used to make the demonstration
(e.g., literature, laboratory data, field data, or operat-
ing data);
(3) Any specific laboratory or field test that will be
conducted, including
(i) the type of test (e.g., column leaching, degradation);
(ii) materials and methods, including analytical proce-
dures;
(iii) expected time for completion;
(iv) characteristics of the unit that will be simulated in
the demonstration, including treatment zone character-
istics, climatic conditions, and operating practices.
Permit applicants who use existing available data to
complete the treatment demonstration or who are issued short-term
demonstration permits must submit the demonstration results with
the Part B permit application. Applicants who are issued a
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two phase permit will submit the demonstration results upon
completion of testing, as specified in the two-phase permit.
(See discussion below regarding short-term and two-phase permits.)
The technical standards in Part 264 listed below define the
requirements for a treatment demonstration. Section 264.272(a),
(b), and (c) state:
(a) For each waste that will be applied to the treatment
zone/ the owner or operator must demonstrate, prior to
application of the waste, that hazardous constituents in
the waste can be completely degraded, transformed, or
immobilized in the treatment zone.
(b) In making this demonstration, the owner or operator may
use field tests, laboratory analyses, available data, or
in the case of existing units, operating data. If the
owner or operator intends to conduct field tests or labor-
atory analyses in order to make the demonstration required
under paragraph (a) of this section, he must obtain a
treatment or disposal permit under §270.63. The Regional
Administrator will specify in this permit the testing,
analytical, design, and operating requirements (including
the duration of the tests and analyses, and, in the
case of field tests, the horizontal and vertical dimen-
sions of the treatment zone, monitoring procedures,
closure, and cleanup activities) necessary to meet the
requirements in paragraph (c) of this section.
(c) Any field test or laboratory analysis conducted in order
to make a demonstration under paragraph (a) of this sec-
tion must:
(1) Accurately simulate the characteristics and operating
conditions for the proposed land treatment unit including:
(i) The characteristics of the waste (including the
presence of Appendix VIII of Part 261 of this chapter
constituents);
(ii) The climate in the area;
(iii) The topography of the surrounding area;
(iv) The characteristics of the soil in the treatment zone
(including depth); and
(v) The operating practices to be used at the unit.
(2) Be likely to show that hazardous constituents in the waste
7-8
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to be tested will be completely degraded, transformed,
or immobilized in the treatment zone of the proposed
land treatment unit; and
(3) Be conducted in a manner that protects human health and
the environment considering:
(i) The characteristics of the waste to be tested;
(ii) The operating and monitoring measures taken during
the course of the test;
(iii) The duration of the test;
(iv) The volume of waste used in the test;
(v) In the case of field tests, the potential for migra-
tion of hazardous constituents to ground water or
surface water.
7.3.2 Guidance on Achieving the Part 264 Standard
The treatment demonstration required under §264.272(a) can
be accomplished using information derived from published litera-
ture, laboratory studies, field studies and/or actual land treat-
ment unit operation experience (i.e., monitoring results).
Successful demonstrations will most often involve data obtained
from several of these sources.
EPA has not yet defined a specific battery of tests that must
be included in a treatment demonstration. Thus, the applicant
will select the specific tests to conduct when preparing the
treatment demonstration plan. Regardless of which tests, if
any, are conducted and which data sources (literature, operating
data, lab tests, or field trials) are used, the applicant's
demonstration must quantitatively assess the degradation,
transformation, mobility, volatility, and toxicity of hazardous
constituents in the treatment zone. (Transformation pertains to
reactions in which compounds are chemically changed to larger
7-9
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molecular weight compounds. Photolysis and hydrolysis reactions
may yield such results. Transformation may be addressed along
with degradation.)
By stating in §264.272 that the owner or operator must
demonstrate "complete" treatment (i.e., degradation, transforma-
tion, or immobilization) of hazardous constituent, the Agency
intends that the demonstration should provide sufficient data to
allow one to confidently predict that hazardous constituents can
be treated at the proposed unit to the extent necessary to prevent
statistically significant releases of these constituents from
the treatment zone. The quantity of data needed to demonstrate
"complete" treatment will vary depending on the treatment process
examined. For example, degradation data must clearly show that
the constituent is being degraded at a rate that will ensure
that no statistically significant releases will occur. Mobility
study results must show that no significant migration has occurred
during the study, in which the conditions of the proposed unit
must be accurately simulated.
There are numerous laboratory methods for assessing degrada-
tion, transformation, mobility, volatility, and toxicity of
hazardous constituents in soil. Typical types of laboratory
tests are listed in Table 7-3. The applicant may use other
published procedures or design laboratory methods more specific
to the applicant's needs.
When the information needed for a treatment demonstration is
beyond the scope of laboratory or greenhouse experiments, field
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tests should be conducted. Field tests allow the least control
over experimental conditions and may require extensive replica-
tion to obtain useful results. Field tests should be used only
TABLE 7-3. TYPICAL LABORATORY TESTS FOR ASSESSING DEGRADATION,
TOXICITY, TRANSFORMATION, VOLATILITY, AND MOBILITY OF
HAZARDOUS WASTE CONSTITUENTS
Type of Test Typical Results
Soil Respirometer Tests Degradation Rate, Microbial Toxicity
Soil Incubation Tests Degradation Rate, Transformation
Volatility Tests Flux of Volatile Constituents
Soil Thin layer
Chromatography Tests Mobility
Column Leaching Tests Mobility
Batch Sorption Tests Mobility
Extractability Tests Mobility and Transformation
Microbial Mutagenesis Tests Toxicity and Transformation
to assess the factors which cannot be simulated in the laboratory
or greenhouse, such as odor control or mechanical waste application
techniques. The applicant is referred to Hazardous Waste Land
Treatment (1) and RCRA Guidance Document; Land Treatment Units
(2) for information on conducting a treatment demonstration,
selecting tests, and designing test procedures.
If an applicant intends to conduct field or laboratory analyses
as part of the treatment demonstration, the unit must first obtain
a treatment or disposal permit. As discussed in Section 7.2, EPA
may issue a short-term permit covering only field testing and/or
laboratory analyses, or a two-phase facility permit covering the
treatment demonstration and facility design, construction, and
maintenance. Alternatively, treatment demonstration field tests
may be conducted at existing land treatment units with interim
7-11
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status provided that the field tests are not conducted in a
manner that will lead to a violation of the interim status stan-
dards. Section 270.63 defines the nature of these permits
(short-term or two-phase) and the conditions under which they
will be issued. §270.63 states:
Permits for land treatment demonstrations using field tests
or laboratory analyses.
(a) For the purpose of allowing an owner or operator to meet
the treatment demonstration requirements of §264.272 of
this chapter, the EPA Regional Administrator may issue a
treatment demonstration permit. The permit must contain
only those requirements necessary to meet the standards
in §264.272(c). The permit may be issued either as a
treatment or disposal permit covering only the field
tests, or laboratory analyses, or as a two-phase facility
permit covering the field tests, or laboratory analyses
and design, construction, operation and maintenance of
the land treatment unit.
(1) The EPA Regional Administrator may issue a two-phase
facility permit if he finds that, based on information
submitted in Part B of the application, substantial
although incomplete or inconclusive, information already
exists upon which to base the issuance of a facility
permit.
(2) If the EPA Regional Administrator finds that not enough
information exists upon which he can establish permit
conditions to attempt to provide for compliance with
all of the requirements of Subpart M, he must issue a
treatment demonstration permit covering only the field
tests or laboratory analyses.
(b) If the EPA Regional Administrator finds that a phased
permit may be issued, he will establish, as requirements
in the first phase of the facility permit, conditions
for conducting the field tests or laboratory analyses.
These permit conditions will include design and operating
parameters (including the duration of the tests or
analyses and, in the case of field tests, the horizontal
and vertical dimensions of the treatment zone), monitoring
procedures post-demonstration clean-up activities, and
any other conditions which the Director finds may be
necessary under §264.272(c). The Director will include
conditions in the second phase of the facility permit
to attempt to meet all Subpart M requirements pertaining
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to unit design, construction, operation, and maintenance.
The Director will establish these conditions in the
second phase of the permit based upon the substantial
but incomplete or inconclusive information contained in
the Part B application.
(1) The first phase of the permit will be effective as
provided in §124.15(b) of this Chapter.
(2) The second phase of the permit will be effective as
provided in paragraph (d) of this section.
(c) When the owner or operator who has been issued a two-
phase permit has completed the treatment demonstration,
he must submit to the EPA Regional Administrator a
certification, signed by a person authorized to sign a
permit application or report under $270.11, that the
field tests or laboratory analyses have been.carried
out in accordance with the conditions specified in
phase one of the permit for conducting such tests or
analyses. The owner or operator must also submit all
data collected during the field tests or laboratory
analyses within 90 days of completion of those tests or
analyses unless the EPA Regional Administrator approves
a later date.
(d) If the EPA Regional Administrator determines that the
results of the field tests or laboratory analyses meet
the requirements of §264.272 of this Chapter, he will
modify the second phase of the permit to incorporate
any requirements necessary for operation of the facility
in compliance with Part 264, Subpart M, of this Chapter,
based upon the results of the field tests or laboratory
analyses.
(1) This permit modification may proceed as a minor modifi-
cation under §122.17, provided any such change is minor,
or otherwise will proceed as a modification under
§122.15(a)(2) .
(2) If no modifications of the second phase of the permit
are necessary, or if only minor modifications are
necessary and have been made, the EPA Regional
Administrator will give notice of his final decision to
the permit applicant and to each person who submitted
written comments on the phased permit or who requested
notice of final decision on the second phase of the
permit. The second phase of the permit then will become
effective as specified in §124.15(b).
(3) If modifications under §122 .15(a)(2) are necessary,
the second phase of the permit will become effective
only after these modifications have been made.
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7.3.3 Guidance on Addressing the Permit Application Information
Requirement
7.3.3.1 Treatment Demonstration Plan —
The information required for a treatment demonstration plan
in the Part B application is identified in §270.20, as
previously defined. The items for submittal listed below are
recommendations to the permit applicant for providing the
required information. A suggested attachment to the permit appli-
cation is Treatment Demonstration Plan.
7.3.3.1.1 Wastes for treatment demonstration plan —
Part 1. Submit a list of all wastes that will be included
in the treatment demonstration. The list should include all
wastes, both hazardous and nonhazardous, destined for the pro-
posed land treatment unit. While permit authorization or a
treatment demonstration is not required for land treatment of
nonhazardous waste, the presence of nonhazardous wastes or nonhaz-
ardous waste constituents within the same treatment zone will
affect degradation, transformation, and immobilization of hazard-
ous constituents. Therefore, it is essential that the applicant
submit information concerning nonhazardous wastes and waste
constituents to be consistent with requirements for the "Treatment
Demonstration" and to establish conditions for maximum treatment
in the "Land Treatment program." The following information on
each waste should be reported:
- Common name
Generating process or source
Expected monthly quantity, including actual or estimated
averages, maximum and minimum
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- Form of the waste and approximate moisture content; and
EPA hazardous waste ID number (if applicable).
Please use the example format given on the following table.
TABLE 7-4. FORMAT FOR LISTING WASTES THAT WILL BE MANAGED IN THE
LAND TREATMENT UNIT
Name of
Waste
Monthly
Generating Process or Annual
or Source Quantity
EPA
Hazardous
Waste ID ic.
1. Oil/Water
Separator
Sludge
2 . Leaded Tank
Bottom
3 . Treated
Wastewater
Crude Topping Unit 60 MT
Leaded Gasoline
Storage
100 MT
Refinery Waste- 50,000 MT
water Treatment
Plant
K051
K052
Non-
hazardous
Part 2. For each hazardous waste listed in Part 1 above,
submit the names of all potentially hazardous constituents (see
§261 Appendix VIII), and pertinent nonhazardous constituents
reasonably expected to be present in or derived from the waste.
This list should be based on information about the generating
process, source of the waste, and chemical analyses. "Pertinent"
nonhazardous constituents means any nonhazardous constituents that
will likely affect the degradation, transformation, or immobiliza-
tion of hazardous constituents.
Part 3. Submit the results of a quantitative analysis of
each waste listed in Part 1 above if not previously submitted.
Test Methods for Evaluating Solid Waste (3) provides methods and
procedures for representative sampling and analysis of waste
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materials. Include the following information:
- Concentration of each hazardous constituent listed in
Part 2 above expressed on a mass basis (use total concentra-
tion, not EP toxicity data);
- Concentration of gaseous or easily volatilized hazardous
constituents at 25° C, volatile hazardous constituents from
25° C to 105° C, volatile hazardous constituents from 105 C
to 250° C and stable constituents above 250° C [for proce-
dures see Hazardous Waste Land Treatment (1)];
- Percent water;
- Specific gravity or bulk density;
- pH;
- Electrical conductivity;
- Total acidity or alkalinity;
- Total organic carbon.
7.3.3.1.2 Data sources for treatment demonstration — For
each hazardous constituent listed in the waste, identify the
information sources (e.g., published literature, field data,
operating records, laboratory tests, field tests) that will be
used to make the treatment demonstration. For each source,
describe the data expected to be obtained from the source and
how it will be used in the demonstration.
7.3.3.1.3 Laboratory and field test design —If laboratory
analyses or field testing will be used as a source of data in the
treatment demonstration, the applicant should describe the design
of each test in detail by submitting the following information.
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Part 1. For each proposed laboratory test, submit an explan-
ation of each test which includes the following information:
- Name of test;
- Objective of test;
- Materials and methods (a step-by-step explanation of the
test including analytical methods, experimental design,
statistical methods, sampling, equipment, monitoring, etc.);
- Schedule of completion;
- List of operating conditions or characteristics that will
or will not be simulated in the test such as climate, soil
properties, and waste application methods; and
- Description of the data that will be obtained from the
test and how it will be presented in final form.
The explanation should include sufficient detail for a third
party to conduct or repeat the test if desired.
Part 2. For each field test, prepare a written description
of how the test is designed and how it will be conducted.
Include the following information:
- The objective of the test;
- A scale drawing showing the location of test plots rela-
tive to the proposed land treatment unit;
- Number and size of test plots;
Statistical design of the test;
Horizontal and vertical dimensions of the treatment zone
for the field test plots;
Preparation of test plots (e.g. tillage, liming, ferti-
lizer, installation of monitoring devices, surface water
control structures, etc.);
Waste application rate on each plot, method of waste
application, and soil incorporation techniques;
Irrigation methods and scheduling;
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Methods for establishing and maintaining vegetation (if
plots will be vegetated);
- Methods for measuring and recording daily meteorological
data;
Procedures for monitoring soil, soil-pore liquid, run-off,
vegetation, ground water, and air, as applicable;
A daily schedule of events and activities;
Rationale for design and management of field tests to
preclude the migration of hazardous constituents to ground
or surface water;
The type of data expected from the test and how it will be
presented; and
Clean-up procedures upon completion of field tests.
7.3.3.3 Treatment Demonstration Results —
Permit applicants should submit the following treatment
demonstration results with the Part B permit application. Permittees
that are issued two-phase permits, however, will submit demonstration
results upon completion of testing as specified in the two-phase
permit.
7.3.3.3.1. Wastes and waste composition — If the wastes
used in the treatment demonstration differ in composition from the
information submitted in the treatment demonstration plan, identify
the wastes for which the demonstration was made and provide a
physical and chemical characterization of each waste. Submit the
information as prescribed in Section 7.3.3.1.1, part 1. Pretreat-
ment or mixing of wastes should also be noted.
7.3.3.3.2 Degradation/transformation — Submit infor-
mation on the rate and extent of degradation or transformation
of the specific organic hazardous constituents identified in
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Section 7.3.3.3.1 plus degradation of the bulk organic fraction of
the waste(s) in the following Parts:
Part 1. If existing literature will be used to demonstrate
degradation of hazardous constituents or bulk organics, submit a
brief written review of scientific literature and previous
studies that contain pertinent information. Sources of informa-
should be documented with citations in the text and a bibliography.
Photocopies of tables, graphs, or figures should be included as
deemed appropriate by the applicant. The test procedures should
be described, and the test results presented in detail, as described
below under Part 3 (laboratory tests) or Part 4 (field tests).
Part 2 . If operating data from existing land treatment units
were used to demonstrate degradation, submit a description of the
existing facility, operational records, waste composition, waste
application rates, and data demonstrating degradation of hazardous
constituents and/or bulk organics. At a minimum, include the
analytical results of soil sampling for hazardous constituents and
a plot of percent degradation or transformation as a function of
time for each waste application treatment.
Part 3. If laboratory test results were used to demonstrate
degradation or transformation of hazardous constituents or
degradation of bulk organics, submit the following information
concerning each test as described below.
- Name of test.
- Test procedures. Test procedures should be explained in a
step-by-step fashion and include a description of laboratory
apparatus, experimental design, waste application rates,
preparation and handling of soil and waste, analytical
methods, sampling procedures, and test conditions.
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- Test results. Results of the test should be presented in
tables and graphs as appropriate for the particular labora-
tory test. As mentioned in Section 7.2, there are many
laboratory tests that an applicant may choose to demonstrate
waste degradation and/or transformation. Each particular
test, however, often lends itself to a particular form
or method of presenting test results. For example, if
the applicant intends to demonstrate degradability with
soil respirometry tests, the results should be presented
in at least two graphs. One graph should show C02 evolution
as a function of time for each waste application treatment
including a no waste control. A second graph should show
the percent of carbon degraded (based on C02 evolution)
as a function of time for each waste application treatment.
If degradation or transformation will be demonstrated
by periodic sampling of incubated soil and waste mixtures,
test results should be presented in two graphs, one showing
the residual concentration of a particular waste constitu-
ent in the soil as a function of time and another showing
percent degradation as a function time.
In addition to test specific tables or graphs, the
applicant should calculate the half life of each organic
hazardous constituent in the treatment zone and identify
the waste application rate which exhibits the optimum
waste degradation rate. Further discussion on presenting
test results and performing calculations is contained in
Hazardous Waste and Treatment (1).
- Discussion. Test results should be discussed and explained
as needed to interpret the results.
Part 4. If field test results were used to demonstrate
degradation of hazardous constituents or bulk organics, the
following information should be submitted:
- Field test objectives. The objectives and function of the
field test should be stated briefly and concisely.
- Field test procedures. Describe how the field test was
designed and conducted including the information listed in
Table 7-5. Note any changes from test design described in
the Treatment Demonstration Plan.
- Field test results. Present test data in tables and
graphs as needed to demonstrate degradation or transfor-
mation of organic hazardous constituents. Include the
analytical results of soil sampling for hazardous consti-
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tuents and a plot of percent degradation or transformation
as a function of time for each waste application treatment.
Also, calculate the half life of each organic hazardous
constituent in the treatment zone and identify the waste
application rate that exhibits the optimum degradation
rate.
- Discussion. Provide discussion and explanation of the
field test results as needed for interpretation.
7.3.3.3.3. Immobilization -- Information should be submitted
that addresses the potential for organic and inorganic hazardous
constituents to migrate from the treatment zone under typical
waste application rates and operating conditions. There are
several methods for estimating the mobility of various elements
and compounds in soil discussed in Hazardous Waste Land Treatment
(1) (see Table 7-3 for typical methods). A substantial amount of
published information exists concerning the mobility of inorganic
elements and compounds while information concerning the mobility
TABLE 7-5. GENERAL INFORMATION TO BE INCLUDED IN FIELD TEST
DESCRIPTIONS
Location of test plots rela-
tive to the land treatment
unit.
Number and size of test
plots.
Dimensions of treatment zone
for field test plots.
Preparation of field test
plots.
Soil properties.
Waste application rate on
each plot.
Method of waste application
and soil incorporation tech-
niques .
Irrigation methods and fre-
quency.
Rainfall and temperature data
collected during the test.
Sampling schedule and proce-
dures.
Analytical methods.
Statistical methods.
Photographs of test plots.
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of organic compounds in soil is rather scarce. The following
information should be submitted:
Part 1. If data contained in existing literature were
used to demonstrate immobilization of hazardous constituents in
the treatment zone, the applicant should prepare and submit a
brief review of scientific literature and previous studies that
document the mobility of the constituents under consideration.
The review should include references to the literature and a
bibliography. Photocopies of specific data such as tables or
graphs should be included as necessary. The test procedures
should be described, and test results presented in the cited
literature, in detail similar to that described below under
Part 3 (laboratory tests).
Part 2. If operating data from existing land treatment units
were used in the demonstration, submit a description of the
existing facility, operational records, waste characteristics,
waste application rates, and analytical data reflecting the
mobility of hazardous constituents. Sampling procedures and
analytical methods should be included with the data. The
monitoring data should be presented in detail similar to that
described below for field tests (Part 4).
Part 3. If laboratory test results were used to assess
the mobility of hazardous constituents, submit the following
information concerning each test:
Name of test.
Test objectives. Describe the objectives and function of
the test briefly and concisely.
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Test procedures. Explain test procedures in a step-by-
step fashion including a description of laboratory
apparatus, experimental design, waste application
rates, preparation and handling of soil and waste,
sampling procedures, analytical methods, and test
conditions.
- Test results. Present the test results in tables as
appropriate for the particular laboratory test. Column
leach tests are the most widely used method to demonstrate
immobilization, and these test results should be presented
as a breakthrough curve. A breakthrough curve is a graph
showing the concentration of hazardous constituents in
the effluent, relative to the concentration in the influent
plotted as a function of the number of soil pore volumes
of liquid passed through the column. See Hazardous Waste
Land Treatment (1) for an example breakthrough curve.
Soil thin layer chromatography test results should be
presented as Rf values, the relative mobility of a compound
or element relative to a compound or element of known
mobility. If batch sorption tests are used, the results
should be presented as sorption isotherms, the amount of
the compound or element sorbed plotted as a function of
the solution concentration. Subsequent desorption
experiments will indicate the strength of the sorption
and the reversibility of the reaction.
If extractability tests are used, the results should be
presented in tables showing the relative solubility of
the sorbed element or compound in various extracting
solutions. There are other methods of assessing mobility
not mentioned here and other methods of presenting test
results. While the breakthrough curve is generally
accepted for expressing mobility, the applicant should
present test results in the form that is most appropriate
for the tests being conducted.
- Discussion. Provide written explanation as needed to
interpret test results.
Part 4. If field tests were used to demonstrate immobili-
zation of hazardous constituents, submit the following information
as described below.
Field test objectives. The objectives of the test should
be stated briefly and concisely.
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Field test procedures. Describe how the field test was
designed and conducted including the information listed in
Table 7-5. Note any changes from the test design described
in the Treatment Demonstration Plan.
Field test results. Present test data in tables and
graphs as needed to demonstrate the rate and extent of
hazardous constituents migration during the field test.
Typically, test results are presented as separate graphs
showing: the concentration of hazardous constituents in
the soil as a function of depth at various times during
the field test; the concentration of hazardous constituents
in the soilpore fluid at various depths plotted as a
function of time; the concentration of hazardous constit-
uents in rainfall run-off as a function of the depth of
rainfall; and the concentration of hazardous constituents
in the ground water underlying field test plots.
7.3.3.3.4 Volatilization — Volatilization of hazardous
constituents is generally limited to organic compounds with
relatively high vapor pressure. Volatilization of hazardous
constituents does not constitute degradation, transformation, or
immobilization. Therefore, data addressing volatilization of
potentially volatile hazardous constituents should be included in
the treatment demonstration results in order to confirm treatment
of these hazardous constituents. Extensive quantitative data
need not be submitted provided it can be shown that volatilization
will not be a significant release mechanism for the hazardous
constituent in question. Methods for estimating and controlling
volatilization are discussed in Hazardous Waste Land Treatment
(1). Data sources for estimating volatilization include existing
literature, previous operating data, laboratory tests, and field
tests.
Part 1. If existing literature were used to evaluate the
amount of hazardous constituents that are volatilized from the
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treatment zone, submit a brief review of the literature that
includes the vapor pressure of each organic hazardous constituent
in millimeters of mercury at standard temperature; estimated flux
of each hazardous constituent volatilized from the soil expressed
as the mass or concentration per unit area of soil as a function
of time; and other pertinent information. The review should be
documented with sources of information and a bibliography.
Photocopies of tables or figures should be included as deemed
appropriate.
Part 2. If operating data were used to evaluate volatili-
zation of hazardous constituents, submit a description of the
existing facility, operational records, waste composition, waste
application rates and data addressing the volatilization of
hazardous constituents from the treatment zone.
Part 3. If laboratory tests were used to evaluate volatili-
zation of hazardous constituents from the treatment zone, submit
the following information as described below.
- Name of test.
- Test procedures. Explain test procedures in a step-by-step
fashion and include a description of laboratory apparatus,
experimental design, waste application rates, preparation
and handling of soil and waste, analytical methods,
sampling procedures, and test conditions.
Test results. Present test results in a graph showing the
mass or concentration of hazardous constituents volatilized
per unit area of soil as a function of time for various
waste application rates.
- Discussion. Explain test data as necessary to interpret
test results and draw conclusions.
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Part 4. If field tests will be used to evaluate volatili-
zation of hazardous constituents from the treatment zone, submit
the following information as described below:
Test objectives. Briefly state the objectives of the field
test with respect to volatilization of hazardous constit-
uents.
Test procedures. Describe how the field test was designed
and conducted including the information listed in Table 7-4,
Test results. Present test results in a graph showing the
mass or concentration of hazardous constituents volatilized
per unit area of soil as a function of time for various
waste application rates.
Discussion. Explain test data as needed to interpret
results and formulate conclusions.
7.3.3.3.5. Microbial toxicity —The toxicity of a waste
to soil microbes may influence degradation and transformation
of the waste and its hazardous constituents and is an important
consideration in assessing the treatability of a waste. Obviously,
if a waste is highly toxic to the soil's microbial population, the
waste cannot be readily biodegraded unless it is applied to the
soil at a rate that is below the threshold of toxic effects.
Acute microbial toxicity of a waste to microbes can often be
evaluated simultaneously with an assessment of degradation using
existing field tests.
Part 1. If existing literature were used to demonstrate
that the toxicity of the waste(s) will not prevent or restrict
degradation or transformation of hazardous constituents, submit a
brief review of scientific literature or previous studies that
contain information concerning toxicity of the waste or its
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constituents to soil microbes. Sources of information should
be documented with citations and a bibliography. Photocopies
of tables, graph, or figures should be included as deemed
appropriate.
Part 2. If operating data were used to evaluate microbial
toxicity of the waste, submit a description of the existing facil-
ity, operational record, waste composition, waste application
rates and data to evaluate the toxicity of the waste. Operating
data should be presented in tables or graphs that show relative
microbial activity as a function of time for various concentrations
of waste in the soil.
Part 3. If laboratory test results were used to evaluate
the microbial toxicity of the waste, submit the following informa-
tion as described below.
Name of test.
Test procedures. Explain test procedures in a step-by-
step fashion and include a description of laboratory
apparatus, experimental design, waste application rates
preparation and handling of soil and waste, analytical
methods, sampling procedures and test conditions.
Test results. Results of the tests should be presented
in tables or graphs that show relative microbial activity
as a function of time for various concentrations of waste
in the soil.
Discussion. Explain test data as necessary to interpret
the test results and draw conclusions.
Part 4. If field test results were used to demonstrate
that the toxicity of the waste will not prevent or restrict
degradation of hazardous constituents, submit the following
information as described below.
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Test objective. Briefly state the objective of the field
test(s) with respect to microbial toxicity.
- Test procedures. Describe how the field test was designed
and conducted including the information listed in
Table 7-4.
Test results. Present the test results in tables or
graphs that show relative microbial activity as a function
of time at various waste application rates or operating
conditions.
7.3.3.3.6. Phytotoxicity — If nondegradable hazardous
constituents will be immobilized in the treatment zone and vegeta-
tive cover will be used as an integral part of facility design
(e.g., for wind dispersal control) during the operating life, data
concerning the phytotoxicity of these residuals to the planned
cover crop should be submitted in the treatment demonstration.
The phytotoxicity of residuals may be determined from existing
literature, operational data, greenhouse tests, or field tests.
Part 1. If existing literature were used to determine the
phytotoxicity of the waste(s), submit a brief review of the
literature including the concentration of waste in the soil that
causes a specified decrease in plant growth. Information such as
the plant species, waste application rates, and test procedures
should be included. Literature should be cited in the text with
a bibliography.
Part 2. If operating data from an existing land treatment
unit were used to evaluate the phytotoxicity of the waste,
submit a description of the existing facility, operational records,
waste application rates, and data indicating the toxicity of the
waste.
7-28
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Part 3. If greenhouse tests were used to assess phyto-
toxicity, submit test data and a description of test procedures
including apparatus, experimental design, waste application
rates, waste application schedule, and plant varieties. Test
data submitted should show the concentration of waste in the soil
that causes a specified decrease in plant growth.
Part 4. If field tests were used to evaluate the phyto-
toxicity of the waste, submit the following information as
described below.
- Test objective. Briefly state the objectives of the test
with respect to evaluating phytotoxicity.
- Test procedures, describe how the field test was designed
and conducted including the information in Table 7-5.
- Test results. Present test results in tables or graphs to
show the concentration of waste or waste constituents that
cause a specified decrease in plant growth or plant
survival.
- Discussion. Explain test data as needed to interpret
test results and draw conclusions.
7.4 LAND TREATMENT PROGRAM
7.4.1 Federal Requirement
Section 270.20(b) states that the Part B permit application
shall include:
(b) A description of a land treatment program, as
required under §264.271. This information must be
submitted with the plans for the treatment demonstration,
and updated following the treatment demonstration. The
land treatment program must address the following items:
(1) The wastes to be land treated;
(2) Design measures and operating practices necessary to
maximize treatment in accordance with §264.273(a)
including:
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(i) Waste application method and rate;
(ii) Measures to control soil pH; (iii) Enhancement of
microbial or chemical reactions;
(iv) Control of moisture content;
(3) Provisions for unsaturated zone monitoring, including:
(i) Sampling equipment, procedures, and frequency;
(ii) Procedures for selecting sampling locations;
iii) Analytical procedures;
(iv) Chain of custody control;
(v) Procedures for establishing background values;
(iv) Statistical methods for interpreting results;
(vi) The justification for any hazardous constituents
recommended for selection as principal hazardous
constituents, in accordance with the criteria for
such selection in §264.278(a);
(4) A list of hazardous constituents reasonably expected to
be in, or derived from, the wastes to be land treated
based on waste analysis performed pursuant to §264.13;
(5) The proposed dimensions of the treatment zone.
As evident above, there are several Part 264 standards upon
which the information requirement is based.
With respect to the land treatment program, the specific
technical standard is contained in §264.271, which states:
(a) An owner or operator subject to this subpart must establish
a land treatment program that is designed to ensure
that hazardous constituents placed in or on the treatment
zone are degraded, transformed, or immobilized within
The Regional Administrator will specify in the facility
permit the elements of the treatment program, including:
(1) The wastes that are capable of being treated at the
unit based on a demonstration under §264.272;
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(2) Design measures and operating practices necessary to
maximize the success of degradation, transformation,
and immobilization processes in the treatment zone in
accordance with §264.273(a); and
(3) Unsaturated zone monitoring provisions meeting the
requirements of §264.278.
(b) The Regional Administrator will specify in the facility
permit the hazardous constituents that must be degraded,
transformed, or immobilized under this subpart.
Hazardous constituents are constituents identified in
Appendix VIII of Part 261 of this chapter that are
reasonably expected to be in or derived from waste
placed in or on the treatment zone.
(c) The Regional Administrator will specify the vertical
and horizontal dimensions of the treatment zone in the
facility permit. The treatment zone is the portion of
the unsaturated zone below and including the land surface
in which the owner or operator intends to maintain the
conditions necessary for effective degradation, trans-
formation, or immobilization of hazardous constituents.
The maximum depth of the treatment zone must be:
(1) No more than 1.5 meters (5 feet) from the initial soil
surface; and
(2) More than 1 meter (3 feet) above the seasonal high
water table.
§264.271(a)(2) requires that the facility permit include
design measures and operating practices to maximize treatment in
accordance with §264.273(a), which states:
(a) The owner or operator must design, construct, operate,
and maintain the unit to maximize the degradation,
transformation, and immobilization of hazardous constituents
in the treatment zone. The owner or operator must
design, construct, operate, and maintain the unit in
accord with all design and operating conditions that
were used in the treatment demonstration under §264.272.
At a minimum, the Regional Administrator will specify
the following in the facility permit:
(1) The rate and method of waste application to the treatment
zone;
(2) Measures to control soil pH;
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(3) Measures to enhance microbial or chemical reactions
(e.g. fertilization, tilling); and
(4) Measures to control the moisture content of the
treatment zone.
§264.271(a)(3) requires that the facility permit include
unsaturated zone monitoring provisions that meet the requirements
of §264.278, which states that the owner or operator must
establish an unsaturated zone monitoring program to discharge the
following responsibilities:
(a) The owner or operator must monitor the soil and soil-pore
liquid to determine whether hazardous constituents migrate
out of the treatment zone.
(1) The Regional Administrator will specify the hazardous
constituents to be monitored in the facility permit. The
hazardous constituents to be monitored are those specified
under §264.271(b).
(2) The Regional Administrator may require monitoring for
principal hazardous constituents (PHCs) in lieu of the
constituents specified under §264.271(b). PHCs are
hazardous constituents contained in the wastes to be
applied at the unit that are most difficult to treat,
considering the combined effects of degradation,
transformation, and immobilization. The Regional
Administrator will establish PHCs if he finds, based on
waste analyses, treatment demonstrations, or other
data, that effective degradation, transformation, or
immobilization of the PHCs will assure treatment of at
least equivalent levels for the other hazardous constit-
uents in the wastes.
(b) The owner or operator must install an unsaturated zone
monitoring system that includes soil monitoring using
soil cores and soil-pore liquid monitoring devices such
as lysimeters. The unsaturated zone monitoring system
must consist of a sufficient number of sampling points
at appropriate locations and depths to yield samples
that:
(1) Represent the quality of background soil-pore liquid
quality and the chemical makeup of soil that has not
been affected by leakage from the treatment zone; and
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(2) Indicate the quality of soil-pore liquid and the
chemical make-up of the soil below the treatment zone.
(c) The owner or operator must establish a background
value for each hazardous constituent to be monitored
under paragraph (a) of this section. The permit will
specify the background values for each constituent or
specify the procedures to be used to calculate the
background values.
(1) Background soil values may be based on a one-time
sampling at a background plot having characteristics
similar to those of the treatment zone.
(2) Background soil-pore liquid values must be based on at
least quarterly sampling for one year at a background
plot having characteristics similar to those of the
treatment zone.
(3) The owner or operator must express all background
values in a form necessary for the determination of
statistically significant increases under paragraph (f)
of this section.
(4) In taking samples used in the determination of all
background values, the owner or operator must use an
unsaturated zone monitoring system that complies with
paragraph (b)(l) of this section.
(d) The owner or operator must conduct soil monitoring and
soil-pore liquid monitoring immediately below the
treatment zone. The Regional Administrator will specify
the frequency and timing of soil and soil-pore liquid
monitoring in the facility permit after considering the
frequency, timing, and rate of waste application, and the
soil permeability. The owner or operator must express
the results of soil and soil-pore liquid monitoring
in a form necessary for the determination of statistically
significant increases under paragraph (f) of this section.
(e) The owner or operator must use consistent sampling and
analysis procedures that are designed to ensure sampling
results that provide a reliable indication of soil-pore
liquid quality and the chemical make-up of the soil
below the treatment zone. At a minimum, the owner or
operator must implement procedures and techniques for:
- Sample collection;
- Sample preservation and shipment;
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- Analytical procedures; and
- Chain of custody control.
(f) The owner or operator must determine whether there is
a statistically significant change over background values
for any hazardous constituent to be monitored under
paragraph (a) of this section below the treatment zone
each time he conducts soil monitoring and soil-pore
liquid monitoring under paragraph (d) of this section.
(g) The owner or operator must use consistent sampling and
analysis procedures that are designed to ensure sampling
results that provide a reliable indication of soil-pore
liquid quality and the chemical make-up of the soil
below the treatment zone. At a minimum, the owner or
operator must implement procedures and techniques for:
- Sample collection;
- Sample preservation and shipment;
- Analytical procedures; and
- Chain of custody control
(f) The owner or operator must determine whether there is a
statistically significant change over background values
for any hazardous constituent to be monitored under
paragraph (a) of this section below the treatment zone
each time he conducts soil monitoring under paragraph
(d) of this section.
(1) In determining whether a statistically significant increase
has occurred, the owner or operator must compare the
value of each constituent, as determined under paragraph
(d) of this section, to the background value for that
constituent according to the statistical procedure specified
in the facility permit under this paragraph.
(2) The owner or operator must determine whether there has
been a statistically significant increase below the treatmer
zone within a reasonable time period after completion of
sampling. The Regional Administrator will specify that
time period in the facility permit after considering the
complexity of the statistical test and the availability
of laboratory facilities to perform the analysis of soil
and soil-pore liquid samples.
(3) The owner or operator must determine whether there is
a statistically significant increase below the treatment
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zone using a statistical procedure that provides reasonable
confidence that migration from the treatment zone will be
identified. The Regional Administrator will specify a
statistical procedure in the facility permit that he finds:
(i) is appropriate for the distribution of the data used
to establish background values; and
(ii) provides a reasonable balance between the probability
of falsely identifying migration from the treatment
zone and the probability of failing to identify real
migration from the treatment zone.
(g) if the owner or operator determines, pursuant to
paragraph (f) of this section, that there is a statisti-
cally significant increase of hazardous constituents
below the treatment zone, he must:
(1) Notify the Regional Administrator of this finding in
writing within seven days. The notification must indicate
what constituents have shown statistically significant
increases.
(2) Within 90 days, submit to the Regional Administrator
an application for a permit modification to modify the
operating practices at the facility in order to maximize
the success of degradation, transformation, or immobiliza-
tion processes in the treatment zone.
(h) If the owner or operator determines, pursuant to
paragraph (f) of this section, that there is a statisti-
cally significant increase of hazardous constituents
below the treatment zone, he may demonstrate that a
source other than regulated units caused the increase
or that the increase resulted from an error in sampling,
analysis, or evaluation. While the owner or operator
may make a demonstration under this paragraph in addition
to, or in lieu of, submitting a permit modification
application under paragraph (g)(2) of this section, he
is not relieved of the requirement to submit a permit
modification application within the time specified in
paragraph (g)(2) of this section unless the demonstration
made under this paragraph successfully shows that a
source other than regulated units caused the increase
or that the increase resulted from an error in sampling,
analysis, or evaluation. In making a demonstration
under this paragraph, the owner or operator must:
(1) Notify the Regional Administrator in writing within
seven days of determining a statistically significant
increase below the treatment zone that he intends to
make a determination under this paragraph;
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(2) Within 90 days, submit a report to the Regional
Administrator demonstrating that a source other than the
regulated units caused the increase or that the increase
resulted from an error in sampling, analysis, or
evaluation;
(3) Within 90 days, submit to the Regional Administrator
an application for a permit modification to make any
appropriate changes to the unsaturated zone monitoring
program at the facility; and
(4) Continue to monitor in accordance with the unsaturated
zone monitoring program established under this section.
7.4.2 Guidance on Achieving the Part 264 Standard
§264.271(a) requires each owner or operator to establish a
land treatment program that is designed to ensure that hazardous
constituents placed in or on the treatment zone are degraded,
transformed, or immobilized within the treatment zone. This
program must include (1) wastes that are capable of being treated
at the land treatment unit, (2) design measures and operating
procedures that maximize treatment in the treatment zone, and
(3) an effective unsaturated zone monitoring system.
The completion of treatment demonstration testing (see Section
7.3 above) will allow selection of acceptable waste(s). Guidance
on appropriate design measures and operating practices can be
found in Hazardous Waste Land Treatment (1) and RCRA Guidance
Document: Land Treatment Units (2). For guidance on unsaturated
zone monitoring, sampling methods, and analytical procedures, the
applicant is referred to the above-named documents as well as Test
Methods for Evaluating Solid Waste (3).
7.4.3 Guidance on Addressing the Application Information Requirement
A suggested attachment to the permit application is Land
Treatment Programs. It should include the following.
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7.4.3.1 Wastes for Land Treatment Program —
Submit a list of all hazardous wastes and hazardous constit-
uents to be included in the land treatment program (similar to
the list described in Section 7.3.3.1.1)
7.4.3.2 Waste Application Rate and Methods —
Part 1. The applicant should submit a table listing each
waste constituent listed in Section 7.4.3.1, its respective
application limit (AL), rate limit (RL), and capacity limit
(CD, plus a brief discussion of the rationale for assessing
each limit. Refer to the technical resource document, Hazardous
Waste Land Treatment (1), for an explanation of these various
limits and how to assess their values with respect to degradation,
transformation, toxicity, and mobility. Include calculations and
follow the example format in Table 7-6.
TABLE 7-6. FORMAT FOR REPORTING APPLICATION, RATE, AND CAPACITY
LIMITS
Waste
Constituent Limit
Value
Discussion
Phenol
AL 1 .1 X 103
kg/ha
(1 x 103 Ib/a)
RL 70 kg/ha/yr
(62 Ib/a/yr)
Concentration J> 500 mg/kg
soil are phytotoxic and
inhibit microbial activity
Optimum degradation
is 70 kg/ha/yr
(62 Ib/a/yr)
rate
Lead
AL
RL
CL
None
None
2.2 X 103
kg/ha
(2 x 103 Ib/a)
Not to exceed 1000 mg/kg
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Part 2. Prepare and submit a table which lists each waste
constituent identified in Section 7.4.3.1, its respective concentra-
tion in the waste, and the necessary quantity of waste applied per
hectare to reach that constituent's respective AL, RL, and CL. One
the example format in Table 7-7. On the table, identify the appli-
cation limiting constituent (ALC), rate limiting constituent (RLC),
and capacity limiting constituent (CLC) with an asterisk. (ALC,
RLC, and CLC are those constituents with the lowest amount of waste
necessary to reach its respective limit, plus those constituents
within 25% of the lowest values).
Part 3. Enclose a monthly waste application schedule based on
the ALC, RLC, and CLC for each waste stream, the waste generation
rate, seasonal restrictions on waste application, the expected life
span of the land treatment unit, and waste application methods.
Use the example format in Table 7-8 and show all calculations.
Part 4. Prepare and submit a brief explanation of how and
when waste will be applied to the land treatment unit. Explain
the chain of events occurring from the point of receiving waste
at the land treatment unit to final incorporation of waste in the
soil. Although management methods will differ from place to
place, the explanation should address the following topics:
Methods and frequency of waste collection and transport;
Location, type, and capacity of waste storage units
associated with the land treatment unit;
- Waste application equipment;
- Restrictions to waste application such as weather, cropping
practices, tillage requirements, and sedimentation; and
Plot configuration (if waste is applied progressively from
plot to plot or otherwise).
7-38
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TABLE 7-7. FORMAT FOR IDENTIFYING LIMITING CONSTITUENTS (ACLs, RLCs, AND CLCs ARE MARKED WITH AN ASTERISK)
Waste
Constituent
Concentration
in Waste
(mgAg)
Amount of Waste to
Reach AL
(kg/ha/Applicat ion)
(Ib/a/Application)
Amount of Waste to
Reach RL
(kg/ha/yr)
(Ib/a/yr)
Amount of Waste to
Reach CL
(kg/ha)
(Ib/a)
i
CO
UD
1. Water
8.5 x 105
3.53 x 106
(3.1 x 106)
N/A
2. Phenol
200
5.6 x 106*
(5.0 x 106)
3.5 x 105*
(3.1 x 103)
N/A
3. Lead
500
N/A
N/A
4.5 x 103*
(4.0 x 103)
N/A not applicable.
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TABLE 7-8. EXAMPLE WASTE APPLICATION SCHEDULE
Area to
Month Receive Waste Application
Waste Application Applications Rate
(kg/mo) (ha) (kg/ha/mo)
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Totals kg/yr ha kg/ha/yr
Total Amount of Available Land: ha
Expected Life Span of the Unit: years
Expected Total Quantity of Waste Applied Per ha: kg/ha
7-40
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7.4.3.3. Measures to Control Soil pH —
The applicant should submit the following information:
- The current soil pH in the proposed treatment zone based
on soil sampling and analysis. Include the mean soil pH
and range of values. Soil pH should be measured with a
glass electrode in a soil to water ratio of 1:1;
- The minimum and maximum soil pH in the proposed treatment
zone that will allow maximum treatment of wastes. Include
the rationale for deriving these values; and
- A description of methods to control soil pH including
monitoring within the treatment zone for changes in soil
pH and methods for calculating the quantity of soil amend-
ments to adjust soil pH, if necessary.
7.4.3.4 Measures to Enhance Microbial or Chemical Reactions --
Prepare and submit a brief written description of measures
to enhance waste treatment including the method and frequency of
such measures. Typical enhancement measures include incorporating
the waste in the soil, aeration of the soil, microbial inoculations,
fertilizer application, and establishment of vegetation.
7.4.3.5 Measures to Control Soil Moisture in the Treatment
Zone —
Prepare and submit a table indicating monthly gains and
losses of water at the land treatment unit. Prepare the table
from monthly water balance calculations. Recommended procedures
for estimating precipitation, evapotranspiration, run-off,
percolation, irrigation needs, and storage requirements are
discussed in the technical resource document, Hazardous Waste
Land Treatment (1). Include all calculations, assumptions, and
sources of information such as meteorological data, computation
methods, soil run-off factors, etc. In addition, describe irriga-
tion methods, if any, and subsurface drainage structures, if any.
7-41
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7.4.3.6 Unsaturated Zone Monitoring —
Unsaturated zone monitoring plans must be developed for all
land treatment units and the required monitoring must be performed
The applicant should submit an Unsaturated zone monitoring plan
that will demonstrate compliance with applicable standards in
§264.278, described above. The plan must, at a minimum, include
the information discussed below.
Part 1. Sampling Location. On a scale drawing of the land
treatment unit show the location of soil-pore liquid sampling
devices and locations for taking soil samples. For each location
specify the depth if installation for soil-pore liquid sampling
devices and depth of soil samples to be collected. Include the
rationale for selecting the number and position of sampling
locations to provide statistically representative samples.
Part 2. Sampling Frequency. Prepare a schedule for sampling
the soil-pore liquid and soil below the treatment zone. Include
a rationale for the proposed sampling frequency which shows
consideration of the waste application rate, waste application
schedule, climatic factors, and the hydraulic conductivity of the
treatment zone.
Part 3. Sampling Equipment. Identify and describe the
equipment that will be used to obtain both soil core samples and
soil-pore liquid samples. Include information such as the name
and manufacturer of sampling devices, recommended operating
procedures and limitations, and the compositing of materials that
will be in direct contact with the collected sample.
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Part 4. Equipment Installation. Provide a step-by-step
description of the procedure used for installing soil-pore liquid
monitoring devices.
Part 5. Sampling Procedures. Explain in a step-by-step
fashion how samples of soil-pore liquid and soil will be obtained
using the equipment described above. Include a description of
sample collection, preparation, preservation, and transport
procedures. Also, include the number of samples taken at each
sampling event, as well as compositing procedures, if used.
j?art 6. Analytical Procedures. Specify which analytical pro-
cedure will be used to determine the concentration of each
hazardous constituent in collected samples and the name of the
laboratory that will perform the analyses.
Part 7. Chain of-Custody Control. Explain in a step-by-step
fashion the plan for maintaining chain of custody control
throughout sampling, transportation, analysis, and reporting.
Part 8. Background. Describe in detail the procedures for
determining both soil background and soil-pore liquid background
values. Include the location and depth of background samples,
sampling procedures, analytical methods, and results.
Part 9. Statistical Methods. Describe the statistical
methods that will be used to determine a significant difference
between background sample concentrations and monitoring sample
concentrations for both soil and soil-pore liquids. Include the
rationale for developing the statistical methods to be used with
respect to the effectiveness of the method for determining real
differences between background and monitoring results.
7-43
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Section 264.278(f)(3) requires that the permittee determine
within a reasonable time period if monitoring results show a
significant increase over background values. Submit an estimate
of the amount of time in days that would be needed after sampling
to analyze samples, obtain test results, and make a determination
of whether a significant increase has occurred.
If the applicant desires to monitor only principal hazardous
constituents (PHCs) instead of all hazardous constituents list
the proposed PHCs. Submit an explanation with supporting data
to justify monitoring for PHCs in lieu of all hazardous constitu-
ents listed in Section 7.4.3.1. The explanation must demonstrate
that the selected PHCs meet the criteria set forth in
§264.278(a)(2). Methods for selecting PHCs are discussed in
RCRA Guidance Document; Land Treatment Units (2) .
7.4.3.7 Treatment Zone Description —
Describe the proposed treatment zone and soils that occur in
the land treatment unit that will comprise the treatment zone.
The description should include the information described below.
Part 1. Soil Survey. Submit a map or plot plan of the land
treatment unit which delineates the horizontal boundaries of the
treatment zone and all of the soil series that occur therein.
Current soil survey information may be obtained from local
offices of the U.S. Department of Agriculture, Soil Conservation
Service. Label the soil series identified on the map and include
the location of soil samples as required below.
Part 2_!L Series Descriptions. Submit a description of each
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soil series identified within the treatment zone. For native
soils that have not received waste applications, soil series
designations prepared by the Soil Conservation Service are
suitable, provided the soil sampling and analysis (Part 3 below)
confirms these designations. For severely disturbed soils, fill
materials, or soils that may have received previous applications
of waste, a new series description closely paralleling those
prepared by the Soil Conservation Service should always be prepared
on the basis of the soil sampling described in Part 3 below and
additional observations by a qualified soil scientist.
Series descriptions should include the following information:
- Profile description with horizonation, depth, color, USDA
texture, structure, reaction (an estimate of pH), and
thickness; - Physical setting with slope and annual
climatic data;
- Mineralogy;
- Use and vegetation; and
- Estimated soil properties including:
USDA texture shrink-swell potential
Atterburg limits erosion factors
permeability flood frequency and duration
available water capacity depth of seasonal high ground
pH water table
salinity frost action potential.
Part 3. Results of Soil Sampling and Analysis. Submit the
methods and results of soil sampling and analysis within the treat-
ment zone. Show the location of soil samples on the soil survey
map or plot plan prepared for Part 1 above. Describe methods of
sample collection, sample preparation, and analytical methods.
Recommended sampling methods and analytical procedures are
discussed in Hazardous Waste Land Treatment (1) and Methods of
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Soil Analysis (4). Tabulate the results of soil sampling and
analysis for at least the parameters listed in Table 7-9.
Include a separate table for each soil series and follow the
format of Table 7-9.
Part 4. Depth of Treatment Zone. Specify the vertical
dimensions of the treatment zone in meters below the initial soil
surface and meters above the seasonal high water table.
7.5 DESIGN, CONSTRUCTION, OPERATION, AND MAINTENANCE
7.5.1 Federal Requirement
Section 270.20(c) states that the Part B application must
include:
(c) A description of how the unit is or will be designed,
constructed, operated, and maintained in order to meet
the requirements of S264.273. This submission must
address the following items:
(1) Control of run-on;
(2) Collection and control of run-off;
(3) Minimization of run-off of hazardous constituents from
the treatment zone;
(4) Management of collection and holding facilities
associated with run-on and run-off control systems;
(5) Periodic inspection of the unit. This information
should be included in the inspection plan submitted under
270.14(b)(5);
(6) Control of wind dispersal of particulate matter, if
applicable;
The applicable Part 264 standards are contained in §264.273(b)
through (g) which state:
(b) The owner or operator must design, construct, operate, and
maintain the treatment zone to minimize run-off of hazard-
ous constituents during the active life of the land treat-
ment unit.
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TABLE 7-9. FORMAT FDR REPORTING THE RESULTS OF SOIL SAMPLING AND ANALYSIS
Series Name: Date of Sampling:
Horizon
Parameters
Analytical Methods'*
Value
Units
A (0-X on) pH
1:1 Glass Electrode
Standard pH Units
Particle Size Distribution
Electrical Conductivity
Total Organic Carbon
Cation Exchange Capacity
Lime Requirement of pH = 6.5
B (X-Y on) pH
Particle Size Distribution
Cation Exchange Capacity
Electrical Conductivity
Total Organic Carbon
C (Y-Z cm) pH
Particle Size Distribution
Hydrometer Method
Saturated Paste Extract -
Wheatstone Bridge
Dichromate Wet Oxidation Method
Ammonium Saturation Method
BaCl2 TEA Method
1:1 Glass Electrode
Hydrometer Method
Ammonium Saturation Method
Saturated Paste Method
Wheatstone Bridge
Dichromate Wet Oxidation Methods
1:1 Glass Electrode
Hydrometer Method
Sand
Silt
Clay
Sand
Silt
Clay
Sand
Silt
Clay
Dry Weight %
Dry Wieight %
weight %
mmhos/cm
Dry Weight %
meg/100 g soil
meg/100 g
Standard pH Un
Weight %
Weight %
Weight %
meg/100 g soil
mmhos/cm
Dry Weight %
Standard pH Units
Weight %
Weight %
Weight %
* Recommended methods for soil analysis are discussed in Hazardous Waste Land Treatment (1) and Methods of Soil
Analysis (4).
-------
(c) The owner or operator must design, construct, operate,
and maintain a run-on control system capable of
preventing flow onto the treatment zone during peak
discharge from at least a 25-year storm.
(d) The owner or operator must design, construct, operate,
and maintain a run-off management system to collect
and control at least the water volume resulting from a
24-hour, 25-year storm.
(e) Collection and holding facilities (e.g., tanks or
basins) associated with run-on and run-off control systems
must be emptied or otherwise managed expeditiously
after storms to maintain the design capacity of the
system.
(f) If the treatment zone contains particulate matter
which may be subject to wind dispersal, the owner or
operator must manage the unit to control wind dispersal.
(g) The owner or operator must inspect the unit weekly and
after storms to detect evidence of:
(1) Deterioration, malfunctions, or improper operation of
run-on and run-off control systems; and
(2) Improper functioning of wind dispersal control measures.
7.5.2 Guidance in Achieving the Part 264 Standard
Section 264.273(b) through (g) contain requirements related
to (1) minimizing run-off of hazardous constituents, (2)
controlling surface water (run-on and run-off), (3) managing run-
on and run-off control systems, (4) controlling wind dispersal,
and (5) inspecting run-on, run-off, and wind dispersal control
systems.
Specific guidance related to minimizing run-off of hazardous
constituents is provided in RCRA Guidance Document; Land
Treatment Units (2). Generally, the owner or operator should
closely evaluate treatment zone characteristics, particularly
infiltration properties, slope, and moisture conditions, and
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modify design and operating practices to optimize treatment and
minimize run-off. Additional design measures such as a vegetative
cover are often beneficial.
Information on design and management of run-on and run-off
control systems is provided in Hazardous Waste Land Treatment
(1). This document and the RCRA Guidance Document; Land
Treatment Units (2) discuss approaches for managing collected
run-off. Run-off from hazardous waste management units is not
specifically listed as a hazardous waste. However, if the run-off
is a hazardous waste according to the characteristic's defined in
Part 261 it must be managed as a hazardous waste. Also, if the
run-off contains leachate (a hazardous waste), it is automatically
considered a hazardous waste. "Leachate" is defined in §260.10
as any liquid, including any suspended components in the liquid,
that has percolated through or drained from hazardous waste. As
provided in §261.3, leachate is a hazardous waste. The Agency
will assume that active area run-off contains leachate (because
of direct contact with wastes) unless it is demonstrated otherwise.
Run-off from the active area of land treatment units is con-
sidered to be a hazardous waste unless the permittee can demonstrate
that it is only precipitation run-off. Thus equipment and facilities
used to collect, treat, store, and/or dispose of this run-off (and
any other run-off shown to be hazardous) must meet applicable
Part 264 standards (Subpart K for surface impoundments and Subpart
J for tanks).
Run-off from undeveloped portions of a facility, and from
areas that are not part of the land treatment unit need not be
7-49
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collected pursuant to §§264.251(d) , 264.273(d), and 264.301(d).
These portions include roadways and buildings.
Wind dispersal control measures include surface wetting
(irrigation) with water or chemical agents, establishment of a
vegetative cover, natural or manmade windbreaks, and waste appli-
cation timing. The effectiveness of these measures varies
depending on numerous site-specific factors. Often a combination
of these measures will be necessary to obtain effective wind
dispersal control. See RCRA Guidance Document; Land Treatment
Units (2) and Hazardous Waste Land Treatment (1) for additional
information on wind dispersal controls.
7.5.3 Guidance on Addressing the Application Information
Requirement
A suggested attachment to the permit application is Design,
Construction, Operation and Maintenance Plan. This should include
the following.
7.5.3.1 Surface Water Control Plans —
The applicant should submit a scale drawing of the land
treatment unit indicating the location of surface water control
structures and/or soil erosion control structures (such as
terraces, dikes, ponds, culverts, ditches, and canals) that will
be used to control run-on and run-off. For each structure,
include a typical cross section indicating elevation, inclination
of slopes, construction material specifications, and construction
methods. Also, include design calculations for sizing surface
water control structures based on storm frequency, duration, and
intensity.
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7.5.3.2 Minimizing Run-off of Hazardous Constituents —
The applicant should identify specific measures that will
be implemented at the land treatment unit to minimize the
concentration of hazardous constituents in surface water run-off
from the treatment zone.
7.5.3.3 Management of Accumulated Run-off and Run-on —
The applicant should submit a monthly tabulation of run-off
(and run-on) storage requirements followed by a brief explanation
of how the collected liquid will be managed for disposal. Include
methods for draining storage basins and disposing accumulated
stormwater, such as treatment and discharge, evaporation ponds,
spray irrigation, etc. If collected liquid is to be managed as a
nonhazardous waste, provide data showing that liquid is not a
hazardous waste according to criteria in Part 261 of the
hazardous waste regulations.
7.5.3.4 Control of Wind Dispersal —
The applicant should submit a wind erosion control plan
designed to minimize the wind dispersal of soil, soil-waste
mixture, or waste particulate matter. Describe in detail
specific measures for controlling wind erosion such as wind-
breaks, vegetative cover, soil stabilization, and/or irrigation.
Include any data supporting the effectiveness of the proposed
measure(s) at the land treatment unit.
7.5.3.5 inspection of Land Treatment Unit —
Submit a schedule for periodic inspections of the land
treatment unit to determine the adequacy of surface water control
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and wind erosion control measures. Also, include the name or
title of the person(s) responsible for conducting inspections, a
list of items to be inspected, procedures for responding to
observed inadequacies, and records for inspection results.
7.6 FOOD-CHAIN CROPS
7.6.1 Federal Requirement
Section 270.20(d)(l through 5) states:
(d) If food-chain crops are to be grown in or on the
treatment zone of the land treatment unit, a description
of how the demonstration required under §264.276(a)
will be conducted including:
(1) Characteristics of the food-chain crop for which the
demonstration will be made;
(2) Characteristics of the waste, treatment zone, and waste
application method and rate to be used in the demonstra-
tion;
(3) Procedures for crop growth, sample collection, sample
analysis, and data evaluation;
(4) Characteristics of the comparison crop including the
location and conditions under which it was or will be
grown.
(5) If food-chain crops are to be grown, and cadmium is
present in the land-treated waste; a description of how
the requirements of §264.276(b) will be complied with.
The corresponding Part 264 technical standard is contained
in §264.276 which states:
The Regional Administrator may allow the growth of
food-chain crops in or on the treatment zone only
if the owner or operator satisfies the conditions of
this section. The Regional Administrator will specify
in the facility permit the specific food-chain crops
which may be grown.
(a)(l) The owner or operator must demonstrate that there is
no substantial risk to human health caused by the growth
of such crops in or on the treatment zone by demonstrat-
ing, prior to the planting of such crops, that hazardous
constituents other than cadmium:
7-52
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(i) Will not be transferred to the food or feed portions of
the crop by plant uptake or direct contact, and will not
otherwise be ingested by food-chain animals (e.g., by
grazing); or
(ii) Will not occur in greater concentrations in or on the
food or feed portions of crops grown on the treatment
zone than in or on identical portions of the same
crops grown on untreated soils under similar conditions
in the same region.
(2) The owner or operator must make the demonstration
required under this paragraph prior to the planting of
crops at the facility for all constituents identified
in Appendix VIII of Part 261 of this chapter that are
reasonably expected to be in, or derived from, waste
placed in or on the treatment zone.
(3) In making a demonstration under this paragraph, the
owner or operator may use field tests, greenhouse studies,
available data, or, in the case of existing units,
operating data, and must:
(i) Base the demonstration on conditions similar to those
present in the treatment zone, including soil characteris-
tics (e.g., pH, cation exchange capacity), specific
wastes, application rates, application methods, and
crops to be grown; and
(ii) Describe the procedures used in conducting any tests,
including the sample selection criteria, sample size,
analytical methods, and statistical procedures.
(4) If the owner or operator intends to conduct field tests
or greenhouse studies in order to make the demonstration
required under this paragraph, he must obtain a permit
for conducting such activities.
(b) The owner or operator must comply with the following
conditions if cadmium is contained in wastes applied to
the treatment zone:
(l)(i) The pH of the waste and soil mixture must be 6.5 or
greater at the time of each waste application, except
for waste containing cadmium at concentrations of 2
mg/kg (dry weight) or less;
(ii) The annual application of cadmium from waste must not
exceed 0.5 kg/ha (0.45 Ib/a) on land used for production
of tobacco, leafy vegetables, or root crops grown for
human consumption. For other food-chain crops, the
annual cadmium application rate must not exceed
the rates shown in Table 7-10.
7-53
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Table 7-10. ALLOWABLE ANNUAL CADMIUM LOADING RATES
Time Period Annual Cd application rate
(kilograms per hectare)
Present to June 30, 1984 2.0 (1.8 Ib/a)
July 1, 1984 to Dec. 1986 1.25 (1.1 Ib/a)
Beginning Jan. 1, 1987 0.5 (0.45 Ib/a)
(iii) The cumulative application of cadmium from waste must
not exceed 5 kg/ha (4.4 Ib/a) if the waste and soil
mixture has a pH of less than 6.5; and
(iv) If the waste and soil mixture has a pH of 6.5 or greater
or is maintained at a pH of 6.5 or greater during crop
growth, the cumulative application of cadmium from
waste must not exceed the following:
Cumulative Application Cation Exchange Capacity of Soil
5 kg/ha 5 meq/lOOg
(4.5 Ib/a)
10 kg/ha 5-15 meg/lOOg
(9 Ib/a)
20 kg/ha > 15 meg/lOOg
(18 Ib/a)
(2)(i) Animal feed must be the only food-chain crop produced;
(ii) The pH of the waste and soil mixture must be 6.5 or
greater at the time the crop is planted, whichever occurs
later, and this pH level must be maintained whenever
food-chain crops are grown;
(iii) There must be an operating plan which demonstrates how
the animal feed will be distributed to preclude ingestion
by humans. The operating plan must describe the measures
to be taken to safeguard against possible health hazards
from cadmium entering the food chain, which may result from
alternative land uses; and
(iv) Future property owners must be notified by a stipulation
in the land record or property deed which states that
the property has received waste at high cadmium applica-
tion rates and that food-chain crops must not be grown
except in compliance with paragraph (b)(2) of this
section.
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7.6.2 Guidance on Achieving the Part 264 Standard
If food chain crops will be grown on the treatment zone,
§264.276 requires that the permittee demonstrate that there
is no substantial risk to human health caused by the growth
of such crops in or on the treatment zone. The permittee
may make the demonstration in one of two ways: (1) demonstrate
that hazardous constituents will not be transferred to food or
feed portions of the crop, and will not otherwise be ingested by
food chain animals, or (2) demonstrate that hazardous constituents
will not occur in greater concentrations in or on the food or
feed portions of crops grown on the treatment zone than in or on
identical crops grown on untreated soils under similar conditions
in the same region. In the second option, "in or on the crops"
includes the potential contamination pathway of soil adherence
to crops and ingestion by grazing animals. Both demonstration
options require the permittee to address all potential food
chain contamination pathways including crop uptake, physical
adherence to crop, and direct ingestion of contaminated soil by
grazing animals. The second option, however, allows one to
demonstrate that the uptake of a given hazardous constituent by a
food chain crop will not exceed acceptable concentrations (i.e.,
greater than identical crops grown on untreated soil under similar
conditions in the same region). The first option requires the
demonstration of transfer of the hazardous constituents to food
or feed portions of the crop. While demonstrating no transfer
of hazardous constituents may seem burdensome, it may be the
7-55
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preferred demonstration approach in cases where the hazardous
constituent is preferentially excluded from the food or feed
portions of the crop.
In making either of the above demonstrations, the owner or
operator may use field tests, greenhouse studies, available data,
or, in the case of existing units, operating data. The second
demonstration option described above, however, will in most cases
require field testing or operating data. Management methods
used in the test must simulate actual operating conditions such
as waste application rates, waste application scheduling, waste
application techniques, fertilizer applications, irrigation, and
crop harvesting techniques. Tests should be designed to identify
and differentiate between crop contamination caused by root or
foliar uptake and contamination resulting from external sources
such as dispersal of contaminated soil during mechanical harvest-
ing. Further discussion on design of field tests is included in
Hazardous-Waste Land Treatment (1). For guidance on design of
greenhouse studies, the applicant is also referred to Greenhouse
Techniques for Soil-Plant-Fertilizer Research (5). In designing
either greenhouse or field plant uptake studies, a qualified
agronomist should be consulted.
Section 264.276 also contains requirements pertaining to
situations in which cadmium is contained in wastes applied to
treatment zone when food chain crops are grown. These standards
may be met through strict adherence to the cadmium application
limits and careful control of treatment zone conditions (i.e.,
soil pH) .
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7 .6 .3 Guidance in Addressing the Application Information
Requirement
A suggested attachment to the permit application is Food Chain
Crop Demonstration Plan. It should contain the following.
7.6.3.1 Food Chain Crop Demonstration —
The Part B permit application must include a description of
how this demonstration will be made using available data, green-
house tests, field tests operating data.
Part 1. If existing literature or previous studies will be
used in the food chain crop demonstration, describe or identify
the literature or previous studies and how the data obtained from
these sources will be used in the demonstration.
Part 2. (Existing land treatment units only.) If previous
operating data will be used in the food chain crop demonstration,
describe the data, the source of the data, how it was obtained,
and how it will be used to make the food chain crop demonstration.
Part 3. If greenhouse tests will be used in the demonstra-
tion submit a description of the test including the following
information as described below.
- Crop characteristics. Identify the crop or crops to be
grown with both the common and scientific name. Describe
the potential food or feed portions of the crop.
- Waste characteristics. Identify hazardous constituents in
the waste and their respective concentration, if not
previously submitted.
- Assessment of potential crop uptake. Explain how the
potential for crop uptake will be assessed and describe
proposed test procedures in detail including the following
information:
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test location;
test schedule;
number and size of plots or containers;
number of treatment replications;
number of treatments;
rate of waste application;
soil characteristics;
soil preparation;
sampling and sample preparation methods;
analytical methods;
data interpretation methods; and
method of data presentation
- Potential for external contamination. Explain how external
contamination of the food or feed portion of the crop will
be precluded and how this will be substantiated in the
demonstration.
- Potential for ingestion by food chain animals. Explain
how food chain animals will be prevented from ingesting
hazardous constituents and how this will be substantiated
in the demonstration.
Part 4. If field tests will be used in the food chain crop
demonstration, describe how each test will be designed and
conducted including the information as decribed below.
- Plot configuration. Show the layout, location, and
dimensions of test plots on a scale drawing. Include site
characteristics such as surface waters, structures, and
property lines.
- Crop characteristics. Identify the species and variety of
the crop, the edible portion of the crop, and previous
information concerning plant uptake of the hazardous
constituents present in the waste by the crop beng tested
or by similar crops.
- Waste characteristics. Describe the concentration of
hazardous constituents in the waste, the volatility and
water solubility of the hazardous constituents, and the
persistence of these constituents in soil.
- Treatment zone characteristics. Evaluate soil properties
that will affect plant uptake of hazardous constituents
including soil pH, soil organic matter content, soil
texture, and cation exchange capacity.
- Waste application rate and application method. Describe
methods that will be used during land treatment operations
and methods used in the demonstration.
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- Sample collection procedures. Describe sampling methods
including harvest or sample collection, method of
collection, quantity of sample collected, methods for
obtaining representative samples, and sample preservation
and transport.
- Analytical procedures. Explain in detail or cite methods
for analytical methods, chain of custody control, and
expected detection levels of the constituents being
analyzed.
- Data evaluation methods. Explain statistical methods and
presentation of results. Data evaluation should include
factors to be assessed such as dilution effects due to
growth, variability between individual plants, variability
between waste application rates, biomagnification through
plant uptake, quantity taken up by crops, persistence of
hazardous constituents in crop tissues, and the concentra-
tion of hazardous constituents in the edible portion.
7.6.3.2 Wastes Containing Cadmium —
Part 1 . If cadmium is contained in the wastes to be land
treated on units growing food chain crops the applicant must
specify the concentration of cadmium in such wastes, the annual
waste application rates for cadmium containing wastes, and the
soil loading of cadmium resulting from the waste application
rates to be used. Use the example format in Table 7-10 and
include all calculations.
TABLE 7-11. EXAMPLE CADMIUM LOADING RATE TABLE
Waste Name Annual Waste Annual Cadmium
and EPA ID No. Cd in Waste Application Rate Loading
(mg/kg) (kg/ha) (kg/ha)
1.
2.
3.
7-59
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Part 2. If animal feed is the only food chain crop produced,
the applicant should submit the following:
Species and variety of crop produced;
Initial or native soil pH;
- Methods and frequency of soil pH adjustment (if
necessary);
An operating plan for preventing direct human consumption
of produced animal feed and a plan to safeguard against
cadmium entering the human food chain resulting from
future alternative land use; and
Proof that the deed records stipulate the land has
received elevated applications of cadmium and that food
chain crops should not be grown except in accordance with
§264 .276(b)(2) .
If animal feed will not be the only food chain crop
produced, submit the following:
- The species and variety of crop produced;
- Initial or native soil pH;
- Methods and frequency for adjusting soil pH (if necessary);
and
- An operating plan for controlling applications of cadmium
to the soil .
7.7 ESTABLISHMENT OF VEGETATIVE COVER AT CLOSURE
7.7.1 Federal Requirement
Section 270.20(d)(6) requires the Part B application to
include (as part of the facility closure plan):
(6) A description of the vegetative cover to be applied to
closed portions of the facility, and a plan for
maintaining such cover during the post-closure care
period, as required under §264 .280(a)(8) and
§264,280(c)(2). This information should be included in
the closure plan and, where applicable, the post-closure
care plan submitted under 1270.14(b)(13);
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Section 264.280(a)(8) requires the permittee, as part of
closure, to:
(8) Establish a vegetative cover on the portion of the
facility being closed at such time that the cover will
not substantially impede degradation, transformation,
or immobilization of hazardous constituents in the
treatment zone. The vegetative cover must be capable
of maintaining growth without extensive maintenance.
Section 264.28i(c)(2) states that during the post closure care
period the permittee must:
(2) maintain a vegetative cover over closed portions of the
facility.
7.7.2 Guidance on Achieving the Part 264 Standard
Guidance on when to establish a vegetative cover during the
closure period is provided in RCRA Guidance Document; Land
Treatment Units (2). The U. S. Soil Conservation Service publishes
information on the adaptability of major crops to certain regional
climates and conditions, and the technical resource document,
Hazardous Waste Land Treatment (1), provides information on
crops suitable for revegetating waste amended soils. Other
appropriate sources of information are referenced elsewhere (2).
7 .7 .3 Guidance on Addressing the Permit Application Information
Requirement
A suggested attachments to the permit application is Closure
Plan and Post-Closure Care Plan. The applicant should submit a
written description of procedures that will be used to establish
and maintain a vegetative cover on closed portions of the land
treatment unit. The description should, at a minimum, include
the following information:
7-61
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Common name, species, and variety of the cover crop to be
established;
Data or information demonstrating that the crop can thrive
and is adapted to the region in which the unit is located;
and
A description of the planting technique and necessary
maintenance activities (e.g., fertilization, irrigation);
and
The minimum percentage of soil cover that will be main-
tained on the closed land treatment unit. Describe the
method that will be used to measure the amount of soil
coverage.
7.8 IGNITABLE OR REACTIVE WASTES
7.8.1 Federal Requirement
Section 270.20(d)(7) states:
(7) If ignitable or reactive wastes will be placed in or
on the treatment zone, an explanation of how the
requirements of §264.281 will be complied with.
Section 264.281 states that the permittee must not apply
ignitable or reactive waste unless:
(a) The waste is immediately incorporated into the soil so
that:
(1) The resulting waste, mixture, or dissolution of material
no longer meets the definition of ignitable or reactive
waste under §§261.21 or 261.23 of this chapter; and
(2) Section 264.17(b) is complied with; or
(b) The waste is managed in such a way that it is protected
from any material or conditions which may cause it to
ignite or react.
Section 261.21 states:
(a) A solid waste exhibits the characteristic of
ignitability if a representative sample of the waste
has any of the following properties:
(1) It is a liquid, other than an aqueous solution containing
less than 24 percent alcohol by volume, and has a flash
7-62
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point less than 60° C (140° F) , as determined by a
Pensky-Martens Closed Cup Tester, using the test method
specified in ASTM Standard D-93-79, or a Setaflash
Closed Cup Tester, using the test method specified in
ASTM standard D-3278-78, or as determined by an equivalent
test method approved by the Administrator under the
procedures set forth in (§260.20 and 260.21.
(2) It is not a liquid and is capable, under standard
temperature and pressure, of causing fire through friction,
absorption of moisture or spontaneous chemical changes
and, when ignited, burns so vigorously and persistently
that it creates a hazard.
(3) It is an ignitable compressed gas as defined in 49 CFR
173.300 and as determined in that regulation or equivalent
test methods approved by the Administrator under
§§ 260.20 and 260.24.
(4) It is an oxidizer as defined in 49 CFR 173.151.
(b) A solid waste that exhibits the characteristic of
ignitability, but is not listed as a hazardous waste in
Subpart D, has the EPA Hazardous Waste number of D001.
Section 261.23 states:
(a) A solid waste exhibits the characteristic of reactivity
if a representative sample of the waste has any of the
following properties:
(1) It is normally unstable and readily undergoes violent
change without detonating.
(2) It reacts violently with water.
(3) It forms potentially explosive mixtures with water.
(4) When mixed with water, it generates toxic gases, vapors
or fumes in a quantity sufficient to present a danger
to human health or the environment.
(5) It is a cyanide or sulfide bearing waste which, when
exposed to pH conditions between 2 and 12.5, can generate
toxic gases, vapors or fumes in a quantity sufficient
to present a danger to human health or the environment.
(6) It is capable of detonation or explosive reaction if it
is subjected to a strong initiating source or if heated
under confinement.
7-63
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(7) It is readily capable of detonation or explosive decom-
position or reaction at standard temperature and pressure
(8) It is a forbidden explosive as defined in 49 CFR 173.51,
or a Class A explosive as defined in 49 of §173.53 or a
Class B explosive as defined in 49 CFR 173.88.
(b) A solid waste that exhibits the characteristic of
reactivity, but is not listed as a hazardous waste in
Subpart D, has the EPA Hazardous Waste Number of D003.
7.8.2 Guidance on Achieving the Part 264 Standard
Limited information is available on the land treatment of
specific ignitable or reactive wastes. The applicant should
thoroughly evaluate the best design and operating procedures in
the treatment demonstration. Section 264.281 requires that the
waste be either immediately incorporated into the soils so that
the waste is rendered nonignitable or nonreactive and §264.17(b)
is compiled with, or the waste is managed in such a way that is
protected from any material or conditions that may cause it to
ignite or react. The Agency recommends, as part of the manage-
ment procedures, that the waste be applied using subsurface
injection and/or it is premixed with soil. Appropriate safety
measures should be followed at all times. The applicant should
consult Hazardous Waste Land Treatment (1) for additional
information.
7.8.3 Guidance on Addressing the Permit Application Information
Requirement
If ignitable or reactive wastes will be placed in or on the
treatment zone, the applicant should submit a detailed written
plan for managing such wastes. A suggested attachment to the
permit application is Ignitable and/or Reactive Waste Management
Plan. The plan should include:
7-64
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Name of the waste and chemical composition;
Results of laboratory or field experiments which demon-
strate that when the waste is incorporated into the soil
of the treatment zone, the resulting mixture is no longer
ignitable or reactive;
- Provisions for immediate incorporation of the waste into
the soil of the treatment zone (e.g., subsurface injec-
tion) ; and
Handling procedures and safety precautions for preventing
conditions that may cause the waste to ignite or react.
7.9 INCOMPATIBLE WASTES
7.9.1 Federal Requirement
Section 270.20(d)(8) states:
(8) If incompatible wastes, or incompatible wastes and mater-
ials, will be placed in or on the same treatment zone, an
explanation of how $264 .282 will be complied with.
Section 264.282 states that:
The owner or operator must not place incompatible wastes
and materials (see Appendix V of this part for examples),
in or on the same treatment zone, unless §264.17(b) is
complied with.
Section 264.17(b) states:
(b) Where specifically required by other Sections of this Part,
the owner or operator of a facility that treats, stores or
disposes ignitable or reactive waste, or mixes incompatible
waste or incompatible wastes and other materials, must take
precautions to prevent reactions which:
(1) Generate extreme heat or pressure, fire or explosions,
or violent reactions;
(2) Produce uncontrolled toxic mists, fumes, dusts, or gases
in sufficient quantities to threaten human health or the
environment;
(3) Produce uncontrolled flammable fumes or gases in
sufficient quantities to pose a risk of fire or
explosions;
(4) Damage the structural integrity of the device or
facility;
7-65
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(5) Through other like means threaten human health or the
environment.
7.9.2 Guidance on Achieving the Part 264 Standard
Information on incompatible wastes and guidance on achieving
the standards specified in §264.282 is available in Hazardous
Waste Land Treatment (2) and Appendix V of the Part 264 regula-
tions. The data shown from Appendix V, below, are a useful guide
for predicting possible reactions resulting from mixing wastes,
but this information does not necessarily apply to such mixtures
within the soil matrix. Also, this information does not address
the issues of constituent concentrations or of the heterogeneity
or complexity of most waste streams. Lab and field testing (to
be completed with the treatment demonstration) may be needed when
knowledge about possible reactions resulting from mixing
particular waste streams is insufficient.
Appendix v of Part 264 states:
Many hazardous wastes, when mixed with other waste or
materials at a hazardous waste facility, can produce
effects which are harmful to human health and the
environment, such as (1) heat or pressure, (2) fire or
explosion, (3) violent reaction, (4) toxic dusts, mists,
fumes, or gases, or (5) flammable fumes or gases.
Below are examples of potentially incompatible wastes,
waste components, and materials, along with the harmful
consequences which result from mixing materials in one
group with materials in another group. The list is
intended as a guide to permittees of treatment, storage,
and disposal facilities, and to enforcement and permit
granting officials, to indicate the need for special
precautions when managing these potentially incompatible
waste materials or components.
7-66
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This list is not intended to be exhaustive. A permittee
must, as the regulations require, adequately analyze
this to avoid creating uncontrolled substances or
reactions of the type listed below, whether they are
listed below or not.
It is possible for potentially incompatible wastes to
be mixed in a way that precludes a reaction (e.g.,
adding acid to water rather than water to acid) or
that neutralizes them (e.g., a strong acid mixed with
a strong base), or that controls substances produced
(e.g., by generating flammable gases in a closed tank
equipped so that ignition cannot occur, and burning
the gases in an incinerator) . An applicant should
consider these as potential aspects of the overall
operating plan, facility design, and permit application.
In the lists below, the mixing of a Group A material
with a Group B material may have the potential con-
sequence noted.
Group 1-A
Acetylene sludge
Alkaline caustic liquids
Alkaline cleaner
Alkaline corrosive liquids
Alkaline corrosive battery fluid
Caustic wastewater
Lime sludge and other corrosive alkalies
Lime wastewater
Lime and water
Spent caustic
Group 1-B
Acid sludge
Acid and water
Battery acid
Chemical cleaners
Electrolyte, acid
Etching acid liquid or solvent
Pickling liquor and other corrosive acids
Spent acid
Spent mixed acid
Spent sulfuric acid
Potential consequences: Heat generation; violent reaction,
7-67
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Group 2-A
Aluminum
Beryllium
Calcium
Lithium
Magnesium
Potassium
Sodium
Zinc powder
Other reactive metals and metal hydrides
Group 2-B
Any waste in Group 1-A or 1-B
Potential consequences: Fire or explosion; generation of
flammable hydrogen gas.
Group 3-A
Alcohols
Water
Group 3-B
Any concentrated waste in Groups 1-A or 1-B
Calcium
Lithium
Metal hydrides
Potassium
SC-2C12, SOC12, PC13,
Other water-reactive waste
Potential consequences: Fire, explosion, or heat
generation; generation of flammable or toxic gases
Group 4-A
Alcohols
Aldehydes
Halogenated hydrocarbons
Nitrated hydrocarbons
Unsaturated hydrocarbons
Other reactive organic compounds and solvents
7-68
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Group 4-B
Concentrated Group 1-A or 1-B wastes
Group 2-A wastes
Potential consequences: Fire, explosion, or violent
reaction.
Group 5-A
Spent cyanide and sulfide solutions
Group 5-B
Group 1-B wastes
Potential consequences: Generation of toxic hydrogen
cyanide or hydrogen sulfide gas.
Group 6-A
Chlorates
Chlorine
Chlorites
Chromic acid
Hypochlorites
Nitrates
Nitric acid, fuming
Perchlorates
Permanganates
Peroxides
Other strong acidizers
Group 6-B
Acetic acid and other organic acids
Concentrated mineral acids
Group 2-A wastes
Group 4-A wastes
Other flammable and combustible wastes
Potential consequences: Fire, explosion, or other
violent reactions.
7-69
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7.9 .3 Guidance on Addressing the Permit Application Information
Requirement
If incompatible wastes and materials will be placed in or on
the same treatment zone, the applicant must submit a written plan
that explains procedures and precautions for handling such waste.
A suggested attachment to the permit application is Management Plan
for Incompatible wastes. The plan must contain the following
information:
Name of incompatible materials or wastes;
Explanation of incompatibility;
- Composition of incompatible materials and waste;
Rate and schedule of incompatible waste or material appli-
cations to the treatment zone;
- Step-by-step procedures for managing incompatible wastes
or materials to prevent undesirable reactions or effects;
and
Laboratory or field data demonstrating that incompatible
wastes can be safely managed at the land treatment unit
using the proposed procedures.
7.10 REFERENCES
1. K.W. Brown and Associates. Hazardous Waste Land
Treatment. SW-874, College Station, TX. GPO Stock No.
055-000-00232-1.
2. U. S. Environmental Protection Agency. RCRA Guidance Document:
Land Treatment Units. 0. S. EPA Office of Solid Waste,
Washington, D. C., 1983.
3. U. S. Environmental Protection Agency. Test Methods for Eval-
uating Solid Waste. SW-846, Washington, D.C., 1982.
GPO Stock No. 055-002-81001-21.
4. Black, A. C. ed. Methods of Soil Analysis. Agronomy 9.
American Society of Agronomy, Madison, WI, 1965.
2 volumes.
7-70
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5. Allen, S. E., G. L. Terman, and L. R. Clemens. Greenhouse
Techniques for Soil-Plant-Fertilizer Research. Bulletin Y-114,
National Fertilizer Development Center, Muscle Shoals,
Alabama, 1976.
7.11 CHECKLIST
Table 7-12 is a checklist of permit application requirements
for land treatment units. The requirements for both new and
existing units are included. The applicant is encouraged to
use the checklist and to incorporate it into the permit
application. The checklist identifies the application
requirements and provides references to Parts 264 and 270.
The applicant should identify the location in the application
of the material addressing each requirement. Space is provided
for this. This will help ensure that the application is
complete. As noted in Section 4.0, it is suggested that a
copy of this checklist be included as part of the permit
application to aid reviewers. Reviewers, then, will be able
to more readily locate specific aspects of the application,
and communications between reviews and applicants will be
facilitated.
Definitions of terms used in the checklist are provided
below. Checklist footnotes are explained on the last page
of the checklist. An "existing land treatment unit" is a
unit that was in operation or for which construction had
commenced before issuance of the final (Part B) permit and
has or will receive hazardous wastes after January 26, 1983.
7-71
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A "new unit" is one for which construction does not commence until
after issuance of the final (Part B) permit.
An "X" in the checklist indicates that the applicant for that type
of unit must address the specific item or an equivalent optional
item (if available) in the permit application.
An "0" in the checklist indicates that the item is optional in the
permit application. Response to an optional item may eliminate the
necessity of responding to certain items that might otherwise be
required.
A blank space in the checklist means that either the subject
requirement is general and serves as a heading for subordinates
listed below it, or that the subject requirement does not apply
to that type of management unit.
7-72
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^J
CO
Page 1_
TABLE 7-12
PERMIT APPLICATION CHECKLIST FOR LAND TREATMENT
Part 270
270.14(b)
270.14(b)(l)
270.14(b)(2)
270.14(b)(3)
270.14(b)(4)
Part 264 Subject Requirement
Part B General Information Requirements
General description of the facility
264.13(a) - Chemical and physical analysis of hazardous
wastes to be handled
- Waste analysis plan
264.13(b)(l) - Analysis parameters with rationale
through (5)
- Test methods for analyzing parameters
- Procedure for collecting representative samples
Frequency of analyses
- List and description of waste analyses to be
generator supplied
264.13(b)(6) - Waste analysis procedures for ignitable,
and 264.17(c) reactive, incompatible wastes
264.13(c) - For off-site facilities, procedures to identify
each waste movement, and
- Procedures for collecting representative
samples
- Security description for active portion of
faci li ty
264.14(a) - Security procedures waiver justification
Unknowing/unauthorized contact with waste
not harmful
E
X
X
X
X
X
X
X
X
X
X
0
0
xisting Units
N
X
X
X
X
X
X
X
X
X
X
0
0
ew Units
Location in
Application Comments
-------
Page 2
Part 270
--4
-P=>
270.14(b)(5)
LAND TREATMENT (Continued)
Part 264
Subject Requirement
264.14(b)
264.14(c)
264.15(b)(l)
264.15(b)(2)
and
265.15(d)
264.15(b)(l)
264.15(b)(3)
- Unknowing/unauthorized disturbance of waste
or equipment cannot cause violation of
Part 264
- Description of 24-hour surveillance system, or
- Description of artificial or natural barriers,
and
- Description of controlled entry/egress
procedures, and
- Description of warning signs
- List of languages on signs
- Statement of 25-foot legibility
- Description of sign locations and numbers
of signs
General Inspection Schedule and Procedures
Description
- Written schedule
- Statement as to where, at facility, inspection
schedule and inspection records will be kept
Identification of equipment/processes to be
inspected
Identification of types of problems each
equipment/process to be checked for
Existing Units
New Units
Location in
Application
Comments
-------
Page 3_
LAND TREATMENT (Continued)
~vl
tn
Part 270 Part 264
264.15(b)(4)
264.15(c)
270.14(b)(6) Part 264
Subpart C
264.32(a)
264.34(a)
264.32(b)
264.34(b)
264.32(c)
264.32(d)
264.33
264.35
264.37 (also
264.52(c))
Subject Requirement
- Frequency of inspections by equipment/process
- Schedule of remedial action
- Preparedness and Prevention Documentation
- Waiver(s) request and justification
- Description of internal communications/alarm
system(s)
- Documentation of personnel access to internal
communication/alarm system(s)
- Description of external communications/alarm
system(s)
- Documentation of personnel access to external
communications/alarm system(s)
Description of fire control/extinguishing,
spill control, and decontamination equipment
- Documentation of adequate water volume and
pressure for above equipment
- Documentation of equipment testing/
maintenance schedule and procedures
Documentation of adequate aisle space
Documentation and descriptions of arrange-
ments or attempts at arrangements with:
- Police department(s)
E
X
X
0
X
X
X
X
X
X
X
X
X
X
xisting Units
N
X
X
0
X
X
X
X
X
X
X
X
X
X
ew Units
Location in
Application Comments
-------
Page 4
Part 270
CT>
270.14(b)(7)
LAND TREATMENT (Continued)
Part 264
Subject Requirement
264.37(a)(2)
Part 264
Subpart D
264.51 and
264.52(a)
264.52(d)
264.55
264.52(e)
- Fire department(s)
- Hospitals
- Local emergency response teams
- State emergency response teams
- Emergency response contractors
- Equipment suppliers
- Documentation of agreements designating
primary emergency authority
- Contingency Plan Documentation
- Criteria for implementation of contingency
plan
- Emergency Coordinators Identification
- Names
- Addresses
- Home/Work Phones
- Documentation of Qualifications
- Documentation of Authority
- Description of notification procedure
- Emergency equipment list
Existing Units
New Units
Location in
Application
Comments
-------
Page 5
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
264.52(f)
264.53
264.54
264.56
- Documentation of equipment location
- Physical description of equipment
Statement of equipment capabilities
- Evacuation Plan
Criteria for implementation
- Description of signal(s) to implement
- Description of primary and alternate routes
- Contingency Plan Copy Location
- Description of location of facility's
copy of plan
- Number of duplicate copies distributed
and their location
- Contingency Plan Amendment
Identification of person responsible
and authorized to change/amend plan
- Description of procedure to change/amend
facility copy of plan
- Description of procedure to insure
update of all copies of plan
- Detailed Emergency Procedures
Existing Units
New Units
Location in
Application
Comments
-------
Page 6_
Part 270
Part 264
•vj
00
LAND TREATMENT (Continued)
Subject Requirement
Procedure for facility personnel
notification
Procedure for state/local agency
notification
Procedure for identification of character,
source, amount, and areal extent of
released materials
Procedure for assessment of environment/
human health hazards
Identification of On-Scene Coordinator
for geographic area
Description of specific responses and
control procedures for
Fire
Explosion
Spill
Description of process shutdown and
monitoring procedures
Description of cleanup procedures and
associated material treating, storing,
disposal procedures
Description of emergency equipment
cleaning and refitting procedures
Existing Units
New Units
Location in
Application
Comments
-------
Page 7_
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
[Note:
270.14(b)(8)
270.14(b)(9)
- Description of procedures to insure
incompatible waste segregation during
cleanup
There are no §270 requirements which parallel Part 264, Subpart E.
However, the applicant should be familiar with the following sections
of the regulations since the requirements in them wi11 be enforceable
under any permit received.
Part 264, Subpart E, §264.70 through §264.77
Part 270.30, Subpart C
The applicant should be prepared to respond to inquiries by the
permit application reviewers regarding these requirements.]
- Preventive Procedures, Structures, and Equipment
Documentation, including description of
equipment/procedures to
Prevent hazards during unloading operations
- Prevent water supply contamination
- Mitigate equipment failure and power outages
- Prevent undue personnel exposure to wastes
264.17
- Prevention of Accidental Ignition or Reaction
Documentation
- Description of separation and protection of
ignitable, reactive, incompatible wastes
Description of ignitable, reactive,
incompatible wastes handling procedures
- Description of number, location, and type
of warning/prohibition signs
Existing Units
New Units
I
Location in
Application
Comments
-------
Page 8
LAND TREATMENT (Continued)
00
o
Part 270
Part 264
Subject Requirement
270.14(b)(9) and
270.20(g) and
270.20(g)
270.14(b)(10)
270.14(b)(ll)
270.14(b)
and (ii)
264.17(b)
264.281
264.282
- Documentation that procedures are adequate
to prevent accidental ignitions or reactions
Specific Ignitable/Reactive Waste
Requirements for Land Treatment Facilities if
I/R wastes treated.
- Documentation that application to soil
renders waste nonreactive/nonignitable and
prevents reactions, or
- Procedures for protecting wastes
- Procedures which insure that incompatible
wastes are not applied to same treatment zone
Traffic Documentation, identification of:
- Waste movement routes
- Number of movements by type vehicle
- Quantity of waste moved per movement
per vehicle
- Traffic control signals and personnel
- Route surface composition and load
bearing capacity
Facility Location Documentation
- Political jurisdiction identified (new
facilities only)
- Comparison to Appendix VI of Part 264
Existing Units
New Units
Location in
Application
Comments
-------
Page 9
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
264.18(a)
270.14(b)(ll), 264.18(b)
(iii) through (v)
VI
CO
Demonstration that faults with displacement
in Holocene time are more than 3,000 feet
from facility (western states)
If Holocene-time faults are within 3,000 feet,
demonstration that no faults pass within
200 feet of unit sites (western states)
Documentation of facility location relative
to 100-year flood plain level or wave
action flooding
If unit in flood plain, documentation
that facility can withstand the 100-year
flood without washout by:
Analysis of hydrodynamic/nydrostatic forces
resulting at site from 100-year flood, and
Presentation of operating units and flood
protection devices design and how they will
prevent washout, or
Plan for removal of waste before washout
including,
- Timing of removal relative to flood levels
- Estimated time to remove all waste
- Location to which waste will be moved
and proof of compliance with Parts 270
and 264 through 267 of this Chapter
Existing Units
New Units
Location in
Application
Comments
-------
Page 10
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
i
CO
ro
270.14(b)(12) 264.16
270.14(b)(13) 264.112
- Detailed description of personnel,
equipment, and procedures for waste
removal sufficient to insure availability
in tine for use
- Analysis of potential for discharge
during waste Movement
- A plan documenting how and on what time
schedule the facility will comply with
§264.18(b) if not in compliance
(existing facilities only)
- Personnel Training Program Documentation
- Outline of introductory and continuing
personnel training programs
- Identification and qualifications of
program instructor
- Brief description of how training program
meets actual job tasks
- Description of procedures to insure all
appropriate personnel receive appropriate
training and receive annual training review
- Description of records to be kept, their
location, and procedures to insure they are
retained for proper length of time
- Closure Plan Documentation
- Description of partial and final closure
procedures
Existing Units
New Units
Location in
Application
Comments
-------
Page 11
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
oo 270.14(b)(13)
Co
264.114
254.113
254.113
270.14(b)(13) and 264.112
270.20(f)
264.280(a)
- Description of maximum unclosed portion
during facility life
- Estimate of maximum waste inventory in
storage/treatment during facility life
- Equipment decontamination procedure
- Estimated year of closure
- Description of closure schedule including
- Total time to close
- Trackable intervening closure activities
- Location(s) and number of copies of
closure plan
- Identification of person responsible for
storage and updating of facility copy of
closure plan
- Procedure for updating all other copies
of closure plan
Specific Closure Plan Requirements for Land
Treatment Facilities
- Procedures to maximize degradation of
waste in treatment zone
Procedures to minimize waste run-off
- Run-off system maintenance procedures
Existing Units
New Units
Location in
Application
nts
-------
Page 12
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
CO
270.14(b)(13) and
270.20(f)
264.118 and
264.280(c)
270.14(b)(14)
264.120
- Wind dispersal control procedures
Procedures for compliance with food-chain
crop growth
- Procedures for unsaturated zone monitoring
- Description of vegetative cover
- Procedures for establishing vegetative
cover
Specific Post-Closure Plan Requirements for
Land Treatment Facilities
- Procedures to enhance degradation of
wastes in treatment zone
- Procedure for maintaining vegetative cover
- Procedure for maintaining run-on controls
- Procedure for maintaining run-off controls
- Procedures for wind dispersal control
- Procedures to insure compliance with
food-chain crop prohibitions
- Procedures for unsaturated zone monitoring
Documentation of Notice on Deed (existing
faci lities only)
- Statement that land used to manage wastes
Existing Units
New Units
Location in
Application
Comments
-------
Page 13_
LAND TREATMENT (Continued)
00
01
Part 270 Part 264
270.14(b)(15) 264.142
264.143 and
264.146
264.151(a)
264. 151(b)
264.151(c)
264.151(d)
264.151(e)
264.15(f)
and (h)
270.14(b)(16) 264.144
264. 145 and
264.146
264.151(a)
264.151(b)
264.151(c)
Subject Requirement
- Statement of restricted use per f|284.117(c)
- Closure Cost Estimate
- Documentation of a financial assurance
mechanism for closure that is one of the
fol lowing:
Closure trust fund
Surety bond guaranteeing payment
- Surety bond guaranteeing performance
- Closure letter of credit
- Closure insurance
- Financial test and corporate guarantee
- Multiple financial mechanism for one facility
- Single financial mechanism for multiple
faci lities
- Post-Closure Cost Estimate
Documentation of a financial assurance mechanism
for post-closure that is one of the following:
Closure trust fund
Surety bond guaranteeing payment
- Surety bond guaranteeing performance
Existing Units
X
X
X
0
0
0
0
0
0
0
0
X
X
0
0
0
N
X
X
0
0
0
0
0
0
0
0
X
X
0
0
0
ew Units
Location in
Application Comments
-------
Page 14
LAND TREATMENT (Continued)
I
CO
a*
E
Part 270 Part 264 Subject Requirement
264.151(d) - Post-closure letter of credit 0
264.151(e) - Post-closure insurance 0
264.151(f) - Financial test and corporate guarantee 0
and (h)
- Multiple financial mechanism for one facility 0
- Single financial mechanism for multiple
facilities 0
270.14(b)(17) 264.147 - Documentation of Insurance X
- Request for variance from insurance 0
264.151(i) - Insurance for sudden/accidental occurrences X
and (j)
- Insurance for nonsudden/acci dental occurrences X
264.151(g) - Financial test for liability coverage 0
270.14(b)(18) 264.149 - Documentation of a State Required Financial1
Mechanism for Closure, Post-Closure, or
Liability including , 0
- EPA I.D. number 0
Facility name 0
- Facility address 0
Amounts of liability coverage or funds
assured 0
264.150 - Documentation of State Assumed Responsibility
for Closure Post-Closure or Liability including 0
xisting Units
New Units
Location in
Application Comments
0
0
0
0
0
X
0
X
X
0
0
0
0
0
0
0
-------
Page 15
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
270.14(b)(19)
00
270.14(b)(19)
- Letter from State describing State's
responsibililies
- Facility EPA I.D. number
- Facility name
- Facility address
- Amounts of liability coverage or funds
assured
Topographic map showing a distance of 1,000 feet
around facility at a scale of not more than
1 inch equals 200 feet that clearly shows
- Contours
Proper contour intervals
Map scale and date
- 100-year flood plain area
Surface waters and intermittent streams
Surrounding land uses
- Wind rose
North orientation
- Legal boundaries of facility site
Access control
Existing Units
New Units
Location in
Application
Comments
-------
Page 16
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
270.17, 270.18,
270.20 and 270.21
270.20
270.20(a)
270.20(a)
264.272(b)
- Injection and withdrawal wells onsite
and offsite
- Buildings and recreation areas
- Run-off control systems
- Access and internal roads
- Storm, sanitary, and process sewerage systems
- Loading and unloading areas
- Fire control facilities
- Barriers for drainage or flood control
- Location of past or present operational
units and equipment cleanup areas
Part B Specific Information Requirements
- Specific Requirements for Land Treatment
Facilities
- Description of treatment demonstration
plans by
- Field test
- Laboratory analysis
- Available data
- Operating data (existing units only)
Existing Units
New Units
Location in
Application
nts
-------
Page 17
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
264.272(c)
^J
CO
Submittal for laboratory analyses or field
test demonstration permit including
Documentation of accurate simulation
- Wastes and hazardous constituents
descriptions (Part 261, Appendix VIII)
Climatologic information
- Topographical data
- Operating practices
- Type of test to be conducted
- Test materials and methods
- Expected completion time
Statement on appropriateness of
demonstration
- Statement on human health and environment
protection considering
- Characteristics of wastes to be tested
- Operating and monitoring during tests
- Duration of tests
- Volume of waste used in test
- Potential for hazardous waste
migration to ground/surf ace waters
(f ielil tests only)
Existing Units
New Units
Location in
Application
Comments
-------
Page 18
Part 270
270.20(b)
270.20(b)(2)(i)
through (iv)
270.20(b)(3)(i)
through (vii)
LAND TREATMENT (Continued)
Part 264
Subject Requirement
264.271(a)
264.273(a)
264.278(a)
through (f)
Description of land treatment program
- Wastes to be land treated
- Design measures to maximize treatment
including
- Rate and method of waste application
- Soil pH control measures
- Mi crobi a 1 /chemical reaction
enhancements
- Treatment zone moisture control
measures
- Unsaturated zone monitoring procedures
including
- List of and rationale for selecting
compounds to be monitored
- Monitoring equipment, procedures,
frequency
- Procedures for selecting sampling
locations
- Sample collection procedures
- Sample preservation/shipment procedures
- Sample chain of custody control
- Sample analysis procedures
Existing Units
New Units
Location in
Application
Comments
-------
Page 19
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
270.20(b)(4)
270.20(b)(5)
264.271(c)
270.20(c)(l)
through (6)
264.273(b)
through (f)
Background value determination
procedures
Statistical methods description
List of hazardous constituents expected
to be in, or derived from, wastes to be
land treated
- The proposed vertical and horizontal
dimensions of the treatment zone with
maximum depth of
- No more than 5 feet from the initial
soi1 surface
- More than 3 feet above the seasonal
high water table
- Description of land treatment unit design
Procedures/equipment to prevent run-on
from peak discharge of 25-year storm
- Procedures/equipment to collect and .
control the run-off water volume from
a 24-hour, 25-year storm
- Procedures/equipment to minimize run-off
from treatment zone during active life
- Run-on and run-off collection and
control system management plan
- Procedures/equipment for wind
dispersal control
Existing Units
New Units
Location in
Application
Comments
-------
Page 20
LAND TREATMENT (Continued)
INi
Part 270 Part 264
270.20(d)(l) 264.276(a)
through (4)
270.20(d)(l) 264.276(a)
through (4)
%
Subject Requirement
- Documentation of request for growth of
food-chain crops on treatment zone not
receiving cadmium in wastes
- Statement that demonstration of no risk to
human health will be conducted by
- Field tests
- Greenhouse studies
- Available data
- Operating data (existing only)
- Demonstration program description, including
- Soil pH
- Cation exchange capacity of soil
- Specific wastes to be applied
- Waste application rates
- Waste application methods
- Identification of demonstration crops
- Planting and qrowth procedures
- Characteristics of crop
- Sample selection criteria
- Sample collection procedure
E
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
xisting Units
N
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
ew Units
Location in
Application Comments
-------
Page 21
LAND TREATMENT (Continued)
10
CO
Part 270 Part 264 Subject Requirement
- Sample size
- Analyses methods
- Statistical data evaluation procedures
- Identification of comparison crops
- Characteristics of crop
270.20(d)(l) 264.276(a) - Planting and growth procedures
through (4)
- Conditions of growth
- Sample selection criteria
Sample collection procedures
- Sample size
- Analyses methods
- Statistical data evaluation procedures
- Request for a permit to conduct
demonstration program
270.20(e) 264.276(b) - Documentation of request for growth of
food-chain crops on treatment zone if wastes
contain cadmium
- Cadmium concentration in waste
- Soil pH
E
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
xisting Units
N
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
ew Units
Location in
Application Comments
-------
Page 22
LAND TREATMENT (Continued)
vo
Part 270 Part 264
270.14(c) Part 264
Subpart F
270.14(c)(l)
270.14(c)(2)
270.14(c)(3) and
270.14(b)(19)
264.95(b)
264.95(a)
Subject Requirement
Annual application of cadmium in
kilograms per hectane
- Soil cation exchange capacity
- Identification of animal feeds to be grown
- Plan to prevent animal feed ingestion
by humans
- Documentation of notice on deed
- Internal and external pressure
gradients
Part B Protection of Ground-Water Information
Requirements for Surface Impoundments, Waste
Piles, Land Treatment Units, and Landfills
- Interim status period ground-water monitoring
data summary
- Identification of uppermost and hydraulically
interconnected aquifers under facility including
- Water flow rate and direction
- Bases for identification
- Topographic map
- Delineation of property boundary
- Delineation of waste management area
- Delineation of proposed point of compliance
E
G
C
G
0
0
0
X
X
X
X
X
X
X
X
xisting Units
N
G
G
0
0
0
0
X
X
X
X
X
X
X
ew Units
Location in
Application Comments
-------
Page 23
LAND TREATMENT (Continued)
tn
Part 270 Part 264 Subject Requirement
Ground-water monitoring well locations
- Location of aquifers
270. 14(c)(4)(i ) - Descriptions of existing contamination
through ( i i )
- Delineation of plume extent
- Appendix VIII constituents concentrations
Concentrations throughout plume
- Maximum concentration in plume
270.14(c)(5) 264.97 - Detailed plans and an engineering report of
Ground-Water Monitoring Program
264.97(a) - Description of wells
- Number of wells
- Locations
- Depths
- Assurance of unaffected background
water measurement
Assurance of compliance point
ground-water measurement
264.97(c) - Casing description
264.97(d) - Description of sampling/analysis procedures
Sample collection methods
E
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
xisting Units
N
X
X
X
X
X
X
X
X
X
X
X
X
ew Units
Location in
Application Comments
-------
Page 24
LAND TREATMENT (Continued)
CTl
Part 270
270.14(c)(6)
270.14(c)(6)(i)
270.14(c)(6)(ii)
and (iii)
Part 264
264.97(e)
264.97(f)
264.91(a)(4)
and 264.98
264.93 and
264.98(a)
264.98(a)(4)
and
26498(c)(l)
264.98(c)(3)
264.97(g)(l)
Subject Requirement
Sample preservation/shipment
Analytical procedures
- Chain of custody control
- Documentation of proper/adequate
analytical procedures
Procedure for determination of ground-
water elevation with each sample
2
- Description of Detection Monitoring Program
including
- List of indicator parameters, waste
constituents, reaction products to be
monitored for, including
- Type, quantities, concentrations expected
in wastes
*
- Mobility, stability, persistence in
unsaturated zone
- Detectability in ground-water
- Background ground-water concentration
values and coefficients of variation
established by one of the following :
- Use of an appropriate ground-water
monitoring system, and
- Quarterly sampling of upgradient wells
for one year, or
t
X
X
X
X
X
X
X
X
X
X
0
0
xisting Units
N
X
X
X
X
X
X
X
X
X
X
0
0
ew Units
Location in
Application Comments
-------
Page 25
LAND TREATMENT (Continued)
Part 270
Part 264
264.97(g)(3)
264.97(g)(4)
270.14(c)(6)(ii) 264.98(b)
270.14(c)(6)(iv) 264.98(d)
264.98(e)
264.98(f) and
264.97(d) and
(e)
264.98(g)
Subject Requirement
- Quarterly sampling of other wells for
one year, and
- Data from a minimum of one sample/well
and minimum of four samples per
quarter, or
- Presentation of procedures to
calculate such values
Description of an appropriate ground-water
monitoring system to be installed at the
compliance point
Procedures for collecting semi-annual
ground-water samples at the compliance
point during
Active life
- Closure period
- Post-closure period
Procedure for annual determination of
uppermost aquifer flow rate and direction
Documentation of sample collection and
analysis procedures
Procedure for determining a statistically
significant increase for any monitored
parameter or constituent by
Existing Units
New Units
Location in
Application
Comments
-------
Page 26
LAND TREATMENT (Continued)
Part 270
i
to
oo
270.14(c)(7)
Part 264
Subject Requirement
- Comparing compliance point data to
background value data using the
procedures in §264.97(h)(l) or (2), and
- Providing an estimate of the time
period after sampling completion
necessary to obtain results
264.98(h) - Procedure to be implemented if a
statistically significant increase in any
constituent or parameter is identified at
any compliance point monitoring well,
including
264.98(h)(l) - Written notification to Regional
Administrator
264.98(h)(2) - Sample collection and analysis methods
for all Appendix VIII constituents at
all monitoring wells
264.98(h)(3) - Method for establishing Appendix VIII
constituent background values
264.98(h)(4) - Preparation of an application for permit
modification to establish compliance
monitoring
4
264.91(a)(l) - Description of Compliance Monitoring Program ,
and 264.99 including
- List of wastes previously handled at facility
Characterization of contaminated ground-water
- Hazardous constituents identified
Existing Units
New Units
Location in
Application
Comments
-------
Page 27
LAND TREATMENT (Continued)
Part 270
Part 264
Subject Requirement
264.99(b)
264.96
264.99(d)
264.99(c)(3)
264.97(g)
270.14(c)(7)(iv) 264.92 and
264.99(c)(l),
(2)
Hazardous constituents concentrations
Description of compliance monitoring system
at the compliance point
List of hazardous constituents to be
compliance monitored
- Proposed compliance period
- Procedure for collecting quarterly samples
at compliance point during compliance period
- Procedures for establishing background
concentration values for constituents that
are based on one of the following:
- Use of an appropriate ground-water
monitoring system, and
Data that is available prior to permit
issuance
- Data that accounts for measurement errors
in sampling and analysis
Data that accounts for seasonal ground-
water quality fluctuations
Data from a minimum of one sample per
well and a minimum of four samples from
monitoring system, each time system
is sampled
Proposed concentration limits for
constituents with justification based on
Existing Units
New Units
Location in
Application
Comments
-------
Page 28
LAND TREATMENT (Continued)
Part 270
Part 264
o
o
264.99(e)
264.99(f)
264.99(g)
264.99(h)
264.99(i)
264.99(i)(l)
Subject Requirement
- §264.94(a)(l) and §264.97(g)
- §264.94(a)(2)
- §264.94(b) and §264.99(c)(l)
Procedure for annual determination of
uppermost aquifer flow rate and direction
Procedures for annual testing of all
compliance point wells for Appendix VIII
constituents
Documentation of all sampling and
analysis procedures
Procedures for determining a statistically
significant increase for any monitored
constituent by
- Comparing compliance point data to the
concentration limit using the procedure
in §264.97(h)(2)
- Providing an estimate of the time period
after sampling completion necessary to
obtain results
Procedures to be implemented if the ground-
water protection standard is exceeded at any
compliance point monitoring well, including
- Written notification to Regional
Administrator
Existing Units
New Units
Location in
Application
Comments
-------
Page 29
LAND TREATMENT (Continued)
—i
i—•
o
Part 270
270.14(c)(7)(v)
270.14(c)(8)
270.14(c)(8)(i)
Part 264
Subject Requirement
264.99(i)(2)
264.99(i)(2)
(ii)
264.91(a)(2)
and 264.100
264.100(a)(l)
270.14(c)(8)(ii) 264.100(a)(2)
270.14(c)(8)(iii) 264.100(b)
264.100(c)
270.14(c)(8)(iv) 264.100(d)
- Preparation of an application for permit
modification to establish a corrective
action program, including
Details of program to comply with
ground-water protection standard
Details of ground-water monitoring to
demonstrate effectiveness of program
Description of Corrective Action Program ,
i nc 1 ud i ng
- Characterization of contaminated ground-water
- Identified hazardous constituents
- Concentrations of hazardous constituents
Concentration limit for each hazardous
constituent
Detailed plan and an engineering report
describing the corrective actions to be taken
at the compliance point
- Time period necessary to implement
corrective action program
Description of ground-water monitoring
program that will be sufficient to assess
the adequacy of corrective action
Existing Units
New Units
Location in
Application
Comments
-------
Page 30
Part 270
270.11(d)
270.11(a)
LAND TREATMENT (Concluded)
Part 264
Subject Requirement
264.91(a)(3)
and 264.100(e)
264.100(g)
- Description of the corrective action to be
taken for constituents in ground-water
between compliance point and downgradient
facility boundary
- Procedure and content for semi-annually
submitting written reports to the Regional
Administrator on program effectiveness
Part B Certification and Signatories
- Certification paragraph
- Appropriate signatory
Existing Units
New Units
Location in
Application
Comments
-------
FOOTNOTES FOR LAND TREATMENT UNITS
^•State-specific. Contact State or Regional EPA representatives
to discuss requirements.
2Applies to new facilities and existing facilities at which
contamination has not been detected.
^Existing facilities must submit interim status ground-water
monitoring data, including background data for certain parameters,
If no data are available, contact appropriate State or Regional
EPA personnel.
^Required of existing facilities where ground-water monitoring
data indicate the presence of hazardous constituents. New or
existing units without contamination may have a Compliance
Monitoring Program included in the permit on "stand-by" under
some circumstances.
^Applicable to existing facilities with indications of hazardous
constituents in the ground water.
^Applicability to existing facilities will be case-by-case, based
on monitoring data that indicate ground-water contamination.
Under some circumstances, new or existing units without contam-
ination may have Corrective Action Plans included in a permit on
"standby."
7-103
-------
FOOTNOTES FOR LAND TREATMENT UNITS
^State-specific. Contact State or Regional EPA representatives
to discuss requirements.
^Applies to new facilities and existing facilities at which
contamination has not been detected.
3£xisting facilities must submit interim status ground-water
monitoring data, including background data for certain parameters
If no data are available, contact appropriate State or Regional
EPA personnel.
^Required of existing facilities where ground-water monitoring
data indicate the presence of hazardous constituents. New or
existing units without contamination may have a Compliance
Monitoring Program included in the permit on "stand-by" under
some circumstances.
5Applicable to existing facilities with indications of hazardous
constituents in the ground water.
^Applicability to existing facilities will be case-by-case, based
on monitoring data that indicate ground-water contamination.
Under some circumstances, new or existing units without contam-
ination may have Corrective Action Plans included in a permit on
"standby."
7-104
-------
SECTION 8.0
LANDFILL PERMIT APPLICATION GUIDANCE
The regulations promulgated in Part 264 apply to both new
and existing landfill waste management units and distinguish
between these units in appropriate circumstances. Part 264,
Subpart N contains the design and operating standards. This
section of the manual is divided into eleven subsections:
R.I Waste Description
8.2 Design and Operating Requirements
8.3 Closure
8 .4 Post-Closure
8.5 Special Requirements for Ignitable or Reactive Wastes
8.6 Special Requirements for Incompatible Wastes
8.7 Special Requirements for Liquid Wastes
8.8 Special Requirements for Containers
8.9 Disposal of Small Containers in Overpacked Drums (Lab
Packs)
8 .10 References
8.11 Checklist
The regulatory goal adopted in the design and operating
standards is to minimize the formation and migration of leachate
to the adjacent subsurface soil or ground water or surface water.
To this end, unless exempted, units must have liners to prevent
migration of wastes to the subsurface soil or to ground water and
surface waters during the active life of the unit. Landfills are
also required to have leachate collection and removal systems. A
8-1
-------
available to units if applicants demonstrate that wastes will never
variance from the liner and leachate collection requirements is
migrate to ground water or surface water. In addition, existing
portions of units are exempt from these requirements.
8.1 WASTE DESCRIPTION
8.1.1 The Federal Requirement
Section 270.21(a) requires that the Part B application include:
A list of the hazardous wastes placed or to be
placed in each landfill or landfill cell;
The above Part 270 requirement does not apply to any one specific
Part 264 standard in the Subpart N landfill requirements. Rather,
the required information is necessary to comply with all the land-
fill requirements.
8.1.2 Guidance to Achieve the Part 264 Standard
The general facility standards [specifically Section 264.13(a)]
require the applicant to complete waste analyses as necessary
to treat, store, or dispose of wastes in accordance with all of
the Part 264 standards. The Permit Applicants' Guidance Manual
for General Facility Standards (Reference 1), provide guidance
on waste analyses and waste analyses plans.
8.1.3 Guidance to Address the Application Information
Requirement
Section 270.21 requires the applicant to submit a list
of all hazardous wastes that will be disposed of in the landfill.
A suggested attachment to the permit application is List of
Hazardous Wastes. The following information on each waste should
be reported:
8-2
-------
Common name of the waste.
EPA hazardous waste ID number.
Location(s) within landfill where waste is or will be
disposed of (e.g., cell number).
Volume of waste received per month including actual or
estimated averages, maximums and minimums.
Form of the waste when disposed (e.g., containerized,
sludge, bulk solid).
Approximate moisture content, texture, and other signifi-
cant features of the waste.
Special handling requirements.
The sampling and analytical methods applicable to identify-
ing the characteristics of hazardous waste placed in landfills
are described in Part 261 of the regulations and in EPA Publica-
tion Number SW-846, "Test Methods for the Evaluation of Solid
Waste, Physical/Chemical Properties" (2).
The applicant is advised that additional waste analysis
information must be included in Part A of the application (see
§270.13) and in the general facility description (see §270.14).
The Part A must include a specification of the hazardous wastes
to be disposed of at the facility, an estimate of the quantity
of such wastes to be disposed annually, and a general description
of the processes to be used for such wastes. The Permit Appli-
cants' Guidance Manual for General Standards (1) includes guidance
on the general information requirements (i.e., §270.14) on waste
analysis. The information reported for the landfill will be a
subset of the information reported for the entire facility when
the facility consists of other waste management units(e.g., sur-
face impoundments).
8-3
-------
8.2 DESIGN AND OPERATING REQUIREMENTS
This section provides guidance on the permit application
information requirements related to the design and operating
requirements contained in §264.301. This section addresses the
Part 270 and Part 264 standards in the order in which they appear,
Topics discussed include the following:
8.2.1 Liner Performance Standards
8.2.2 Leachate Collection and Removal System
8.2.3 Liner and Leachate Collection and Removal System
Exemption Variance
8.2.4 Control of Run-On
8.2.5 Control of Run-Off
8.2.6 Management of Units Associated with Run-On and Run-
Off Control Systems
8.2.7 Management of Wind Dispersal
8.2.8 Ground-water Protection Subpart F Exemption
8.2.9 Inspections
8.2.1 Liner Performance Standards
8.2.1.1 The Federal Requirements —
Section 270.2Kb) (1) requires that the Part B application
include:
(ii) Detailed plans and an engineering report describ-
ing how the landfill is or will be designed,
constructed, operated, and maintained to comply
with the requirements of $264.301. This submission
must address the following items as specified in
S264.301...
•
(1) The liner system and leachate collection and
removal system (except for an existing portion of
a landfill)....
8-4
-------
Section 264.301U) (1) states:
(A) A landfill (except for an existing portion of a
landfill) must have:
(1) A liner that is designed, constructed, and installed
to prevent any migration of wastes out of the
landfill to the adjacent subsurface soil or ground
water or surface water at any time during the
active life (including the closure period) of the
* landfill. The liner must be constructed of mater-
ials that prevent wastes from passing into the
liner during the active life of the facility.
The liner must be:
(i) Constructed of materials that have appropriate
chemical properties and sufficient strength and
thickness to prevent failure due to pressure
gradients (including static head and external
hydrogeologic forces), physical contact with the
waste or leachate to which they are exposed,
climatic conditions, the stress of installation,
and the stress of daily operation;
(ii) Placed upon a foundation or base capable of provid-
ing support to the liner and resistance to pressure
gradients above and below the liner to prevent
failure of the liner due to settlement, compression,
or uplift.
(iii) Installed to cover all surrounding earth likely to
be in contact with the waste or leachate.
8.2.1.2 Guidance to Achieve the 264 Standard —
Section 264.301(a) contains two key elements:
- It exempts "existing portions" from the requirement
to install a liner and a leachate collection and
removal system; and
It establishes a general performance standard for
liners (i.e., the liner must be constructed of
materials that prevent wastes from passing into
the liner during the active life of the facility).
An "existing portion" means that land surface area of an
existing waste management unit (included in the original Part A
permit application) on which wastes have been placed prior to
8-5
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the issuance of a Part B permit. Existing portions are
exempt from the requirement to install a liner and a leachate
collection and removal system. However, they remain subject
to the remainder of the design and operating requirements,
in §264.301, as well as the ground-water protection requirements
of Part 264, Subpart F.
EPA interprets the general performance standard to mean
that only synthetic liners comply with §264.301(a)(1).
Synthetics are essentially 100 percent effective, when installed
properly and undamaged, in rejecting leachate reaching the
liner surface. The leachate can then be removed by the
leachate collection system.
The Agency realizes that very small amounts of liquid may
enter the structure of synthetic membranes, causing them to
swell, but the amount is negligible. The Agency also believes
that clay liners are valuable as backups to synthetic liners
and recommends their use as an extra measure of protection
in all cases. The use of a clay secondary liner at facilities
that will operate longer than 30 years is a specific example
of where a clay secondary liner should be used.
There are several different types of synthetic liners;
each is compatible with certain types of wastes, but incompatible
with other types. No one synthetic liner material can be
used with all wastes. The following types of synthetic
liners are most commonly used:
High density polyethylene
8-6
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- Chlorosulfonated polyethylene
Polyvinyl chloride
Chlorinated polyethylene
The applicant should refer to Reference 3 for additional
examples of synthetic liner materials. Appendix VIII, of
Reference 3, Suggested Standards for Representative Flexible
Polymeric Membranes, can be used as a guidance tool for obtaining
the minimum values of physical properties of a synthetic liner
that are necessary to produce a quality liner material.
In addition to the general liner performance standard,
§264.301(a){1) also includes several subsidiary performance
standards intended to assure that each liner will meet the goal
of preventing wastes from passing into the liner during the
landfill's active life, including the closure period. These
subsidiary standards consist of general engineering goals
addressing:
Chemical characteristics of liners
- Liner strength and thickness
Liner foundations
- Liner extent
Guidance on designs that comply with these standards is provided
in Reference 3 and in the RCRA Guidance Document for Landfills
(Reference 4).
8.2.1.3 Guidance to Address the Application Information
Requirement
Liner selection and design is one of the most difficult
prospects of landfill design. The liner serves as a primary
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barrier to leachate migration. It must be chemically compatible
with this leachate, and it must be strong enough to resist
tearing during installation and operation. The nature of
the liner foundation is an integral part of liner design.
To address the application information requirements for
liner system design, the applicant is advised to submit
information on the following three areas:
- Liner Specifications
- Foundation Analysis
- Liner Integrity Analysis
A suggested attachment to the permit application is Liner
System Design. The attachment should contain detailed specifica-
tions, raw data, calculations, drawings, assumptions, etc.
supporting the proposed design. A discussion of the rationale
supporting the overall design should be included in the basis
portion of the application. The discussion should present the
reasons why and how the design meets the specific requirements.
The applicant is responsible for all aspects of the application
including material specifications.
8.2.1.3.1 Liner Specifications
The applicant should identify the materials of construction,
and specifications of strength, thickness, and chemical properties
of the proposed liner. The applicant should also submit design
plans that show the method of liner placement in the landfill
unit(s); this should demonstrate that the liner will cover all
areas of the unit that will be exposed to wastes and leachate.
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This normally means that the floor and walls of the cell or trench
must be lined. Liner material specifications can be taken from
the specifications provided by the manufacturer as long as the
applicant proposes these as the minimum acceptable specifications.
Liner integrity analysis section describes the nature of engi-
neering reports to justify the selected liner strength, thickness,
and chemical compatibility. Appendix VIII of Reference (3) can
be used to obtain the minimum values of properties of a synthetic
liner that are necessary to specify a quality liner material.
The liner design plans should be in standard construction
drawing format. The plans should show the extent of areal coverage
for each landfill unit. The plan should also present cross-
sectional views. Details of seaming methods, anchoring, and other
special features should be provided in the plans and in narrative
form. See Appendix D for synthetic liner guide specifications.
8.2.1.3.2 Foundation Analysis
The soils beneath a liner support the liner, waste, and cover.
If these soils settle, shear, or uplift, the liner may be damaged.
Hydrostatic and gas pressure can also impact on liner performance.
The potential for these situations to occur at a given location
can be reliably assessed by a qualified registered geotechnical
engineer. In many cases, standard engineering practices can be
implemented to alleviate a potential for liner deflection.
The foundation analysis should be a report included in the
Liner System Design attachment that assesses the potential for
liner deflection due to settlement, compression, shear, or uplift
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of the foundation soils, and due to hydraulic and gas pressures
on the liner. The following items should be considered in this
report:
- Geologic data. A description should be provided of
regional and site geology, including:
— geologic setting
— bedrock types and depths (include boring logs)
— sediment types and characteristics (include boring
logs)
— subsidence history
— sinkhole potential
[Note that much of this information is also recommended
in Section 9.O.]
- Geotechnical Data. A description should be provided
of the engineering characteristics of the foundation
soils. Data on soil index properties, shear strength,
hydraulic conductivity, and compressibility should
be provided.
- Hydrogeologic Data. A description should be provided
of the characteristics of the saturated zone of the
site, including its relationship to surface water.
Section 9.0 can be used for further guidance on this
topic.
- Seismic Setting. A description should be provided on
the potential for ground shaking and surface rupture
at the side. While the facility may not be in a
jurisdiction in which the seismic location standard
(§264.18(a)) is applicable, it is adviseable to
design a facility to withstand a design earthquake.
Many regions of the country that have information on
the frequency and magnitude of earthquake activity,
and may even have established local standards for the
design of structures. Earth structures can generally
be easily designed to withstand the vertical and
horizontal accelerations experienced during such
design earthquakes.
The report should summarize the foundation investigation
and analysis. It should include all data collected during
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the investigation, all calculations performed in the analysis,
and a description of the methods used in the investigation
and analysis. Total and differential settlements that can
occur during the active and closure period of the unit should
be estimated, including immediate settlement, primary and
secondary consolidation, creep, and liquification. The
bearing capacity and stability of the foundation should be
evaluated.
The subsurface investigation should thoroughly characterize
the in-situ properties of the subsurface materials.- The sub-
surface exploration should consist of test borings and test pits,
and may also include geophysical surveys.
Test borings should be performed to adequate depths and at
a sufficient number of locations to define the subsurface condi-
tions. The method of drilling should be based on a preliminary
subsurface investigation. Test pits should be excavated to
identify near-surface conditions. Geophysical surveys may be
performed to more accurately identify bedrock depths and fractured
zones. Other types of geotechnical tests (i.e., cone pene-
trometer, vane shear, standard penetration) may be performed as
required for the specific conditions at the site. Many standard
techniques for geotechnical investigations are available in
Sampling of Soil and Rock, American Society For Testing and
Materials (ASTM) Special Technical Publication 483, ASTM, June
1970 and Subsurface Exploration and Sampling of Soils for Civil
Engineering Purposes, M. Juul Hvorslev, Army Corps of Engineers
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Waterways Experiment Station, 1965. The subsurface investiga-
tion program can be combined with the investigations undertaken
in response to the ground-water monitoring and aquifer
identification requirements in Part 264 Subpart F.
Laboratory testing of subsurface materials should be
conducted to determine index properties and engineering
parameters. Index property testing should include:
- Grain size distribution curves
- Atterberg limits
- Specific gravity
- Moisture content and dry density
Shear strength of soils may be determined using direct
shear, triaxial, or unconfined compression testing, as
appropriate for the soil condition. The methods for saturated
hydraulic conductivity determination described in Reference
4 (Method 9100) should be used; in most cases, hydraulic
conductivity (often referred to as permeability) should be
determined using field methods, rather than laboratory techniques,
The compressibility characteristics should be determined'by
performing a sufficient number of consolidation tests.
8.2.1.3.3 Liner Integrity Analysis
The integrity of a liner is a function of several factors.
Incompatible chemicals can dissolve the liner. Excessive stress
during either installation or operation can cause tears or
broken seams. Climate can also adversely affect a liner.
It is critical that a liner be carefully selected to be
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compatible with the wastes it must contain. The liner must
also have adequate strength to resist tearing during installation.
It must be protected from puncturing during operation by a
bedding layer. Normally, the leachate collection system can
be the protective layer for the top of the liner; a bedding
layer beneath the liner is also needed. Seaming techniques
are extremely important as well. Finally, the liner should
have sufficient strength to resist failure from any anticipated
or likely settlement or movement of the foundation.
The applicant should submit a detailed report that demon-
strates the integrity of the liner against:
- contact with waste/leachate (i.e., waste-liner compat-
ibility) ,
- internal and external pressure gradients,
- climatic conditions, and
- daily operational stresses.
Waste-Liner Compatibility
The applicant should submit results of compatibility testing.
These results should demonstrate the acceptability of the selected
synthetic liner. The following information should be provided on
the tests used to make the compatibility demonstrations.
- The name of test method that was used.
- The procedure and details of the test method (e.g., number
of test specimens, length of the test, and the nature of
leachate used).
- Chemical and physical characteristics of the wastes(s)
tested including the EPA hazardous waste number, physical
class (e.g., aqueous-inorganic, aqueous-organic; organic;
solid, sludge, etc.), waste sources (including description
or production and waste treatment processes from which the
waste stream is generated.
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- The raw tests results, and
- An explanation of how the raw test results were inter-
preted to lead to the selection of the synthetic liner
proposed as the primary liner for the landfill.
An acceptable test method for examining the compatibility
of wastes/leachate and synthetic liners is the Immersion
Test of Membrane Liner Materials for Compatibility with
Wastes, and is found as Method 9090 in Test Methods for
Evaluating Solid Waste (Reference 2). An earlier form of this
test was published as Appendix A in the July, 1982 draft
RCRA Technical Guidance Document entitled Landfill Design;
Liner Systems and Final Cover (Reference 4)
Liner manufacturers commonly provide information on the
compatibility of their liners with single chemical compounds.
This information is generally in the form of qualitative
rankings (e.g., resistant, poor), rather than in quantitative
form. These types of data may be supportive, but will not
be accepted as definitive proof of compatibility. In most
actual situations, a liner will be exposed to a combination
of waste types, rather than to a single chemical compound.
Consequently, the manufacturers' tests do not adequately
simulate field exposure conditions. Also, EPA is unaware of
the numerical bases used by manufacturers in establishing
their qualitative rankings. EPA must examine the raw data
from the exposure tests.
Waste compatibility tests should be conducted using
representative samples of the wastes and leachates to which
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the liner is, or will be exposed. Several methods for obtaining
samples of hazardous wastes are discussed in Section One of
Test Methods for Evaluating Solid Waste (2). Reference 17
also provides information on collecting leachate samples.
Selection of a method depends on the ambient physical state
of the waste to be sampled (liquid, slurry, solid). If the
waste is a liquid or has a free liquid component, this liquid
is called the primary leachate and must be included in the
sample. If the waste is a solid or slurry that does not
have a free liquid component, then the procedures given
below for extracting primary and secondary leachates should
be employed.
The primary leachate is the liquid that can be extracted
from the waste by vacuum filtration at 25° C and 15.3 kg/cm2
(15 bars) of vacuum. it should be measured as a percentage
of the total waste on a wet weight basis. If there is more
than one distinct immiscible phase in the primary leachate,
collect enough of each phase (approximately 5 liters) to
perform the compatibility testing with each phase. The secondary
leachate is a fluid extracted by vacuum filtration after mixing
the waste thoroughly with just enough water to make a saturated
paste (waste barely flows together into a hole in the paste made
with a spatula) .
The Agency encourages applicants to include the use of
liner samples (coupons) in the liner system design. The
coupons should be separate pieces of liner material at least
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one foot square and include one field seam. The coupons are
placed in the waste management unit and later retrieved and
tested to assess the liner's integrity. Testing of the
coupons can forewarn permittees of liner deterioration far
enough in advance of failure that remedial action may be
taken before failure which could result in catastrophic
contamination and immense corrective action costs. The
Agency also hopes to obtain data from sites using coupons to
further the knowledge of liner integrity. See Section 5.4.7
of Reference 3 for more details on the use of coupons.
As discussed above, the applicant should submit data on
the physical classification of the waste with the compatibility
description of the physical classes of waste. Aqueous-inorganic
(AI) and aqueous-organic (AO) are classes of waste in which
water is the solvent (predominant liquid), and the solutes are
mostly inorganic and organic, respectively. Organic (O) is the
class of waste in which the predominant liquids are organic, and
the solutes are mostly dther organic chemicals dissolved in the
organic solvent. Solids, sludges, and slurries (S) are wastes
high in solids such as tailings, settled matter, or filter cakes.
Climatic Conditions
During the liner system design, the applicant should consider
the impacts of the local climate on the material(s) selected.
Data supporting the liner selection with regard to climate should
be submitted in the application including:
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- Extremes of air temperatures at the units location
- Depth of soil freezing including local building codes
regarding subsurface foundation construction
- Average monthly temperatures and relative humidity readings
- Maximum depth to permafrost (applicable only to sites in
Alaska)
- Data regarding the proposed liner's reactions (cracking,
loss of strength, etc.) to the above conditions.
The above climatic data should be available from the nearest
office of the National Weather Service. These offices are often
located at airports. Building codes can be obtained from local
county offices issuing building permits.
Liner manufacturers' data concerning the responses of the
proposed liner to the local climatic conditions should be included.
Quantitative data should be provided where available. These
should include the liner's strength, resistance to tearing,
puncture, and other failures at the range of conditions
likely to be encountered. Cracking tendency is particularly
important for liners to be installed in cold climates and
those exposed to a seasonal freeze-thaw cycle. Manufacturer's
and other data should be submitted indicating the material's
resistance to cracking.
Applicants may be able to reduce the negative effects of
the local climate through proper design techniques and/or
selection of materials. A liner installed entirely below
the local freeze line will not be subjected to the freeze-thaw
cycle and resulting stresses. Materials for the upper (above
freeze line) portion of a liner may be selected of one material
8-17
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and the lower portion of another. However, caution should
be exercised concerning waste-liner compatibility and the
ability to join dissimilar materials.
Installation Stresses
Stresses during installation can come from both below and
above the liner. The subgrade or bedding material on which the
liner is placed can exert pressures if rocks, roots, or similar
materials remain near the surface. Placement of the liner itself
and seaming techniques can stress the liner. Action of earth
moving equipment spreading a bedding layer above the liner and
installation of a leachate collection system can also stress or
damage a liner. The liner system design should take into account
these considerations and include the following information:
- State whether a bedding material will be placed above
or below the synthetic liner. The thickness of this
bedding layer, the type of material used in the bedding
layer and a drawing of the bedding layer in relation to
the placement of the synthetic layer should be provided.
Methods to be used to prepare the bedding material surface
(discing, compaction, rolling, etc.) should be described.
An explanation of how the synthetic liner will be
protected from punctures or tears during installation
and operation should be provided if a protective bedding
layer is not proposed in the design.
- Treatment of bedding material to prevent plant growth
should be described.
- Slope at the sides of the unit and the ability of the
sides to resist creep or slumping during installation
- Methods to be used during liner installation to minimize
stress and change including detailed techniques for field
seaming
- Methods to be used to place bedding material over liner
and specifications for the bedding material
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The liner system design should thoroughly address the above
items. This should include engineering drawings, detailed con-
struction specifications, and technical reports as necessary.
More details are available in Chapter 5 of Reference 3.
Operational Stresses
Daily operation of the landfill will apply stresses to the
liner(s). The Liner System Design should account for these
stresses and minimize them. Information to be included in the
application should include the following:
- Overall layout and filling sequence of the unit(s)
- Traffic patterns at the site, particularly near the
edges of the liner(s) and in the portions of the landfill
closest to the liner
- Soils data indicating that adequate protection will be
provided to minimize operational stresses
- Design considerations that will minimize liner stress
- Operational techniques to reduce liner stress.
Specific, technical soils data can be taken from the founda-
tion analysis portion of the Liner System Design. Design and
operational factors should minimize stress. The landfill could
be designed for sequential filling with one area completely filled
and closed before starting another area. The second area may have
a different entrance and exit, thus reducing traffic stress at the
original entrance and exit.
Depending on the soils, climate, and operations, the bedding
layer and/or surface roadways, etc. may have to be periodically
thickened, recompacted, graded, and otherwide maintained to reduce
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liner stress. Applicants should consider these possibilities
and include them as appropriate.
Pressure Gradients
Sources of liner stress other than the above may also
be present. These include pressure gradients caused by soil
movement, water above or below the liner(s) and gases either
above or below the liner(s). These situations should be
considered and a liner with adequate strength and thickness
selected. Information to be included in the application
includes:
- Potential for the foundation to be partially lost or
to deform due to piping, sinkholes, decomposition of
organic matter, slumping, etc. and the ability of the
liner to withstand resulting stresses
- Impact of unexpected changes in water levels above or
below the liner(s) such as leachate temporarily deeper
than one foot due to heavy storms
- Potential for generation of gas within the waste contained
or present outside the liner.
In addressing information regarding internal and external
pressure gradients, the applicant should submit detailed
engineering reports demonstrating that the liner system
will withstand the various physical stresses throughout the
active life of the landfill. Soils-related information may
be obtained from the foundation analysis. The soils factors
listed above should be considered during site selection and
design and applied to liner selection. The impact of unusual
water conditions should be analyzed. Often soil-related
problems are caused by unusual water situations. It may be
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wise to assess both together in a near worst-case scenario
in the development of the Liner System Designs.
The applicant should consider potential gas pressures when
designing the liner(s). Gas pressure could develop above, below,
and possibly between liners (in a double-lined landfill). Gases
may be generated in the wastes via anaerobic decomposition of
organic matter yielding methane and carbon dioxide (landfill
gas) or via other mechanisms. These gases normally migrate to
the surface and vent to the atmosphere. However, gas can migrate
laterally and/or accumulate in localized areas resulting in
pressure on the liner(s). These conditions may become more
pronounced after closure when the cover is in place, and are
waste-specific. Gases within the waste may transport hazardous
constituents. If vented to the atmosphere, these gases may
require treatment prior to release.
External gas pressure should also be considered. Gas may
be present or be generated beneath a landfill's liner(s). Sites
located in soils containing significant amounts of organic matter
have potential gas problems. Existing units may be releasing gas
to the subsurface. New units built near existing units might be
affected by this gas. This is especially true of new hazardous
waste landfills adjacent to sanitary landfills, either active or
closed.
8.2.2 Leachate Collection and Removal System
8.2.2.1 The Federal Requirements —
Section 270.21(b) requires the applicant to submit
information in the Part B permit application addressing:
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(1) The liner system and leachate collection and removal
system (except for an existing portion of a landfill)
Section 264 .301(a)(2) states that a landfill (except
for an existing portion of a landfill) must have:
(2) A leachate collection and removal system
immediately above the liner that is designed,
constructed, maintained, and operated to
collect and remove leachate from the landfill.
The Regional Administrator will specify design
and operating conditions in the permit to
ensure that the leachate depth over the liner
does not exceed 30 cm (one foot).
The leachate collection and removal system must be:
(i) Constructed of material that are:
(A) Chemically resistant to the waste managed
in the landfill and the leachate expected to be
generated;
(B) Of sufficient strength and thickness to
prevent collapse under the pressures exerted by
underlying wastes, waste cover materials, and by
any equipment used at the landfill;
(ii) Designed and operated to function without clogging
through the scheduled closure of the landfill.
8.2.2.2 Guidance to Achieve the Part 264 Standard —
8.2.2.2.1 Maximum Head of Leachate — To minimize the
potential for release of hazardous constituents during the
regulated unit's active life, landfills (except for existing
portions) must have a liner and leachate collection and
removal system. To reduce pressure head on the liner, the
leachate collection and removal system must be designed
and operated to assure that leachate depth over the liner
does not exceed 30 cm (1 ft.). The Agency believes that it
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is practical to design a leachate collection and removal
system to maintain leachate depth at the above depth or
less, except perhaps temporarily during severe storms.
The Agency recommends that leachate collection and removal
systems should be constructed of a sand or gravel that is have
at least a 30 centimeter (12 inch) thick layer with a hydraulic
conductivity not less than 1 x 10~3 cm/sec and a minimum slope
of 2 percent. For additional guidance and rationale for the
design of the leachate collection and removal system the applicant
should refer to Reference 4. See Figure 8-1 for a generalized
diagram of a liner and leachate collection system.
8.2.2.2.2 Chemical Resistance — All leachate collection
and removal systems must be designed so that they will continue
to function. They must be capable of withstanding the chemical
attack that can result from contact with leachate. The leachate
from landfills is likely to be chemically corrosive to many
materials. Construction materials, especially for the perforated
collection pipes, must resist deterioration for the required
operational lifetime. This means that the applicant must
have knowledge not only of the materials included in the landfill,
but of the possible interactions that can occur with the mixing
of heterogeneous materials. It is also important to take into
consideration the chemical effect of the leachate on the pumps
to be used for leachate removal and materials used to construct
the risers or manholes accessing the sumps from which the leachate
is withdrawn.
8-23
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8.2.2.2.3 Strength and Thickness — The pipe used in the
collection system must be of sufficient strength and thickness
to withstand the pressure exerted by the weight of the overlying
landfill, waste cover materials, and any equipment to be
used on the landfill. The pipe under consideration is either
a rigid conduit, such as concrete and cast iron, or a flexible
conduit, such as plastic and fiberglass. Because of the probable
corrosive properties of the leachate, plastic or fiberglass
are usually the materials of choice. However, there are
cases where solvents might be generated which would preclude
the use of these latter materials.
Leachate collection pipes beneath landfills are generally
installed in a protective bed of porous material. Perforations
will reduce the effective strength of the pipe that is available
to carry loads and resist pipe deflection under loading. In
addition, the capacity of buried pipe to support vertical
stresses may be limited by buckling and by the circumferential
compressive strength of the pipe. Deflection, buckling
capacity and compressive strength may be obtained from the
pipe manufacturer, but should also be calculated for the
specific case. A pipe correctly designed to withstand
loading from a landfill can fail from equipment loading
received during construction or operation of the landfill.
This loading factor is based on the vertical distance between
the loaded surface and the top of the pipe. Moving loads
cause impact loading which may have twice the effect of
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stationary loads. These loads must be considered when choosing
pipe material and designing the collection system. Appendix
V of Reference 3 includes methods to calculate these factors.
The leachate collection system should be thick enough to
protect the the collection and removal pipes. It should
also serve as a sump into which leachate drains and is stored
prior to and during removal. The leachate system should
have a storage capacity such that leachate drains into the
system and is removed fast enough so that the wastes are not
standing in leachate. Thus the thickness of the system will
depend on factors such as precipitation, control of run-on,
and liquid content of the wastes.
8.2.2.2.4 Prevention of Clogging — The leachate collection
and removal system should be overlain by a graded granular
or synthetic fabric filter. The purpose of this is to prevent
clogging of the pores in the drainage layer of the collection
system by infiltration of fine particles from the waste. If
a granular filter is used, it is important that the relationship
of grain sizes of the filter medium and the drainage layer
be appropriate if the filter is to fulfill its function to
prevent clogging of the drainage layer and not to contribute
to clogging. EPA guidance (Reference 2) specifies a criterion
for this purpose which is widely used in construction to
prevent clogging (blinding) of drainage media. The criterion
was developed by the U.S. Army Corps of Engineers and is
used in their engineering manuals. If pipes are used in the
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leachate collection system, perforations in the pipes should
be sized to be compatible with the particle size of the
bedding material in the drainage layer. If the perforations
are very large compared to the grain size of the bedding
material, the latter may wash into the collection system
and be removed along with leachate. For additional guidance
on the design of the collection and removal system the applicant
should refer to References 3, 4, and 5.
8.2.2.3 Guidance to Address the Application Information
Requirement —
The applicant should provide detailed plans and specifica-
tions for the proposed leachate collection and removal system.
A suggested attachment to the permit application is Leachate
Collection and Removal System Design. It should contain the raw
data, assumptions, calculations, plans and specifications for the
system. The basic portion of applications should contain a
demonstration of how the proposed system meets the requirements
of §264.301(a)(2).
8.2.2.3.1 Overall System Design — The applicant should
provide detailed drawing of the collection and removal systems.
These should include construction details sufficient to actually
build the system and thus assess its adequacy. Specifications
for materials to be used and construction techniques should also
be included. The following should be provided:
- Overall system layout, extent, slopes, design of sumps,
spacing of pipes, location of pumps or other auxiliary
equipment
8-27
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- Specific information on proposed collection pipes
including material, size, wall thickness
- Calculations that show compliance with the requirement
that no more than 1 foot of leachate will exist above
the liner except during storms (See Reference 13).
8.2.2.3.2 Chemical Resistance - The leachate collection system
will likely be in the most hostile environment in the landfill.
It. must continue to operate even though attacked by solutions
of hazardous wastes. Thus the compatibility of the pipes,
pumps, and other features with the expected leachate is
imperative. Data must be provided indicating that the system
will survive the chemical attack of the leachate.
Manufacturers' data may be based only on exposure to one
type of waste. Better information may come from operating
hazardous waste sites handling similar wastes and using the
types of materials proposed. Chemical properties of the
leachate and the materials should be presented along with
results of any long-term exposure tests.
8.2.2.3.3 Strength and Thickness — The applicant should
submit engineering design calculations that demonstrate that
the proposed collection system is of sufficient strength and
thickness to withstand the pressures exerted by the weight
of the overlying landfill, waste cover material, and any
equipment to be used in the construction or operation of the
landfill. The design calculations should take into account
the loads acting on the pipes, the perforation in the pipes,
the deflection of the pipes caused by the loads, the buckling
capacity of the pipes, and the compressive strength of the pipes.
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The thickness of the system should also be shown. Rationale
for the design of the thickness should be presented. (See
Appendix V of Reference 3).
8.2.2.3.4 Prevention of Clogging — The applicant should
provide information including engineering drawings, specifications,
and calculations that demonstrate the ability of the collection
system to function without clogging through the scheduled closure
of the landfill. Include information about the drainage layer
proposed, any proposed filter, and any pipes. See Reference 4
for assistance in the selection of grain sizes for filters or
bedding materials.
8.2.3 Liner and Leachate Collection and Removal System
Exemption Variance (Not Applicable to Existing Portions)
8.2.3.1 The Federal Requirement —
Section 270.21(b) contains the following:
(1) ...If an exemption from the requirements for a
liner and a leachate collection and removal
system is sought as provided by §264.301(b),
submit detailed plans and engineering and
hydrogeologic reports as appropriate,
describing alternate design and operating
practices that will, in conjunction with
location aspects, prevent the migration of
any hazardous constituent into the ground
water or surface water at any future time.
Section 264.301(b) states:
(b) The owner or operator will be exempted
from the requirements of paragraph (a) of this
section if the Regional Administrator finds,
based on a demonstration by the owner or
operator, that alternative design and operating
practices, together with location characteristics,
will prevent the migration of any hazardous con-
stituents (see §264.93) into the ground water or
surface at any future time. In deciding whether to
grant exemption, the Regional Administrator will
consider.
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(1) The nature and quantity of the wastes;
(2) The proposed alternate design and
operation;
(3) The hydrogeologic setting of the facility,
including the attenuative capacity and
thickness of the liners and soils present
between the landfill and ground water or surface
water; and
(4) All other factors which would influence the quality
and mobility of the leachate produced and the potential
for it to migrate to ground water or surface water.
8.2.3.2 Guidance to Achieve the Part 264 Standard —
The applicant may request a variance from the requirement
to install a liner and leachate collection and removal system
on new units and new portions of existing units (i.e.,
everything that is not an existing portion) by providing a
thorough and convincing demonstration that the performance
goals described in Section 8.2.3 will be achieved without an
installed liner system.
8.2.3.3 Guidance to Address the Application Information
Requirements —
If an exemption from the liner and leachate collection
and removal system requirement is being requested for a
new unit, the application should provide:
- Locational determinations relevant to assessing
the potential for leachate migration, such as soil
permeabilities and attenuation capacities, site
geology and geohydrology; and
- A demonstration that facility design, locational
aspects and operating practices will prevent the
contamination of surface water and ground water at
any future time.
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A suggested attachment to the permit application is a
Report Supporting Request for Exemption from Liner and Leachate
Collection and Removal System Requirement.
8.2.4 Control of Run-on
8.2.4.1 The Federal Requirement —
Section 270.21(b)(l) requires that the Part B Application
information include:
(1) Detailed plans and an engineering report describing
how the landfill is or will be designed, constructed,
operated, and maintained to comply with the require-
ments of §264.301. This submission must address
the following items as specified in §264.301...
(2) Control of run-on.
Section 264.301(c) states that to minimize leachate
generation:
(C) The owner or operator must design, construct,
and maintain a run-on control system capable
of preventing flow onto the active portion of the
landfill during peak discharge from at least a 25-
year storm.
8.2.4.2 Guidance to Achieve the Part 264 Standard —
One of the key elements of EPA's strategy for ground-water
protection at landfills is a liquids management program. This
program is intended to minimize leachate generation in the units,
primarily by keeping liquids out of landfills. One aspect for
limiting the generation of leachate is the requirement that
owners or operators control run-on to the unit. The run-on
control system must be capable of preventing flow onto the
active portion of landfills during peak discharge from at
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least a 25-year storm. Methods for estimating peak flow
rates from watershed areas have been developed by the U.S.
Department of Agriculture, Soil Conservaton Service, National
Engineering Handbook (Reference 6), and the U.S. Geological
Survey. Additional sources of information are References 7
and 8.
8.2.4.3 Guidance to Address the Application Information
Requirement
To demonstrate that peak flow rates associated with
at least a 25-year storm over the tributary watershed will
not flow onto the active portion of the landfill, hydrologic,
hydraulic, and structure analyses and designs should be
completed. A suggested attachment to the permit application
is Run-off Control System Design. The following information
and analyses should be submitted for review:
A description of the hydrologic method used
to estimate peak flow rates including its source
and justification for its use in landfill design;
- All data and input parameters used in conjunction
with the selected hydrologic method and their
sources;
- All calculations for estimating peak flow rates
including a discussion and justification of any
necessary assumptions;
All hydraulic calculations and designs for sizing
the necessary collection and conveyance facilities
(standard hydraulic techniques for determining
flow capacities, including allowance for freeboard,
shall be used).
Structural designs of collection and conveyance
facilities and results of all field tests to ensure
compatibility with soils and foundation conditions
(standard structural design techniques and factors of
safety and appropriate field tests shall be used).
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A maintenance plan for ensuring the structural
integrity of the collection and conveyance facilities
along with the plan for restoration and repair in the
event of a washout or failure.
8.2.5 Control of Run-off
8.2.5.1 The Federal Requirement —
Section 270.2Kb) requires that the Part B Application
information include:
(ii) Detailed plans and an engineering report
describing how the landfill is or will be designed,
constructed, operated, and maintained to comply
with the requirements of 5264.301. This submission
must address the following items as specified in
S264 .301...
(3) Control of Run-off.
Section 264.301(d) states that to minimize hazards from
run-off of contaminated liquid:
(d) The owner or operator must design, construct,
operate, and maintain a run-off management system to
collect and control at least the water volume resulting
from a 24-hour, 25-year storm.
8.2.5.2 Guidance to Achieve the Part 264 Standard —
The Agency interprets the run-off regulations in the following
ways:
- Run-off from active portions of units will generally
be a hazardous waste, because it is presumed to contain
leachate. Leachate is generally considered to be a
hazardous waste under §261.3(a). However, the permittee
has the right to demonstrate that the collected liquid
consists only of precipitation run-off for which the
mixture rule in §261.3(b)(2) does not apply. Units
used to hold hazardous liquids should meet the applicable
Part 264 permitting standards (i.e., Subpart K for
surface impoundments, Subpart J for tanks, etc.).
Run-off quality should be monitored.
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- Run-off from fully closed (e.g., capped) units is
generally not a hazardous waste, because it has not
drained through waste or mixed with leachate. This
run-off need not be collected, but it should be managed
in a manner designed to protect the final cover as
stipulated in §§264.228(b)(4) and 264.310(b)(5). It
should be noted, however, that it is useful to monitor
closed-area run-off quality to detect leachate seepage
through the cap. Units used to hold collected closed-
area run-off need not meet the permitting standards
associated with the unit type, unless the run-off is
a hazardous waste. Run-off from closed landfills
should be collected and managed in the same way as
active unit run-off.
- Run-off from portions of a facility that are not part
of an active landfill (underdeveloped or unassociated
areas) need not be collected in the run-off management
systems required under §§264.251(d), 264.273(d), and
264.301(d).
- Run-off volume can be calculated using the methods in
the U.S. Dept. of Agriculture - Soil Conservation Service,
National Handbook 4.
- Collection and conveyance structure designs can be
determined using the methods in the U.S.D.A. - SCS,
National Engineering Handbook 5: Hydraulics (8).
- The magnitude of the 24-hour, 25-year storm can be
determined by using the data available in the National
Oceanic and Atmospheric Administration, Technical
Publication 40 with Regional revisions.
Of the three types of run-off from landfills (active area,
closed area, and undeveloped/unassociated area), the Agency is
most concerned with active area control. Precipitation falling
on exposed hazardous wastes can dissolve or transport waste con-
stituents. At typical landfills, precipitation run-off and
leachate are likely to mix at the toe of the active face or the
low point of the trench floor.
If the permittee does not initially manage active area
run-off as a hazardous waste, then he has the continuing
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obligation to determine whether the liquid meets the definition
of a hazardous waste. Run-off is not a listed waste because the
"derived from" rule in §261.3(c)(2) does not apply. As a result,
run-off will only be considered a hazardous waste if it exhibits
one of the characteristics associated with hazardous wastes as
outlined in 40 CFR Part 261 Subpart C (§261.3) or if it has
mixed with leachate or with another hazardous waste. Three
considerations, however, suggest that it should be easier for
the permittee to assume the run-off to be a hazardous waste.
First, the practical burden of conducting the waste analysis is
likely to outweigh any ultimate benefit incurred as a result of
avoiding initial treatment of the run-off as a hazardous waste.
Second, testing itself will be difficult because collected run-off
cannot be managed easily in batch form; liquid is added to and
removed from run-off collection basins continuously. Third, an
initial assumption that run-off is hazardous will save the problem
of transferring the liquid from a nonpermitted unit to a permitted
unit when the liquid is found to be hazardous.
The collection system must be emptied expeditiously after
storms to maintain its capacity. The rate and extent of fluid
removal are site-specific factors. It might not be necessary to
completely drain the system as long as there is sufficient capacity
to collect fluid from the 24-hr, 25-year storm. If the fluid is
managed in a Subpart K surface impoundment, the impoundment must
be designed to prevent overtopping.
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The nature of fluid quality monitoring is also a site-
specific matter. If the fluid is not presumed to be a hazardous
waste (see above), monitoring must determine whether it
meets the definition of a hazardous waste. If the fluid is
presumed to be a hazardous waste and managed in appropriate
units, monitoring should be based on whatever information is
needed to manage those units.
The interim status standards for run-off management at
existing facilities are found at §265.302(b) for landfills.
The standards for landfills require that run-off from action
portions must be collected. If this run-off is a hazardous
waste, it must be managed as a hazardous waste.
Run-off from disposal units that are closed under the
Interim Status Standards need not be collected.
8.2.5.3 Guidance to Address the Application Information
Requirement
A suggested attachment to the permit application is Run-Off
Control System Design. The following information and analyses
should be submitted for review:
- A description of the hydrologic method and calcu-
lations used to estimate peak flow rates and
run-off volumes including justification of necessary
assumptions;
The 24-hour, 25-year rainfall volume used for
facility design including the source of the data;
all other data and necessary input parameters used in
conjunction with the selected hydrologic method and
their sources should be documented and described;
All hydraulic calculations and designs for sizing
the necessary collection, conveyance and storage
facilities (standard hydraulic techniques for
determining flow capacities and storage volumes,
including allowances for freeboard, shall be used);
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Structural designs of the collection, conveyance,
and storage facilities, and results of all field
tests to ensure compatibility with soils and;
Foundation conditions (standard structural design
techniques and factors of safety, and appropriate
field tests should be used);
A maintenance plan for ensuring the structural
integrity of the collection, conveyance and
storage facilities along with the plan for restoration
and repair in the event of a washout or failure.
8.2.6 Management of Urn.ts Associated with Run-On and Run-Off
Control Systems
8.2.6.1 The Federal Requirement —
Section 270.21(b) requires that the Part B Application
information include:
Detailed plans and an engineering report
describing how the landfill is or will be designed,
constructed, operated, and maintained to comply with
the requirements of §264.301. This submission must
address the following items as specified in §264.301...
(4) Management of collection and holding facilities
associated with run-on and run-off control
systems...;
Section 264.301(e) states that:
Collection and holding facilities (e.g., tanks or
basins) associated with run-on and run-off control
systems must be emptied or otherwise managed
expeditiously after storms to maintain design capacity
of the system.
8.2.6.2 Guidance to Achieve the Part 264 Standard —
Section 264.301(e) states that collection and holding
facilities associated with run-on and run-off control systems
must be emptied or otherwise managed expeditiously after
storms to maintain the design capacity of the system. The
specified design capacity is that capacity necessary to
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collect and control the water volume resulting from a 24-hour,
25-year storm. The system may be designed to meet the above
requirements or by designing it for a volume in excess of the
24-hour, 25-year storm capacity Where additional storage
capacity is necessary to allow reuse or delayed disposal of
collected wastes, it can be separately provided by tanks or
additional surface impoundments.
The applicant is reminded that run-off from the active
area of the landfill should generally be considered hazardous.
This will require management of this run-off in permitted
treatment, storage, or disposal facilities.
8.2.6.3 Guidance to Address the Application Information
Request —
A suggested attachment to the permit application is Plan
for Management of Units Associated with Run-On and Run-Off
Control. The following information should be submitted on
management of run-on and run-off:
- A plan for emptying collection or holding facilities
associated with run-on and run-off management
systems to maintain the capacity of the system;
- An estimation of the length of time it would take
to empty the holding facilities;
- A description of the method to be used for collected
run-off disposal, such as treatment and discharge,
evaporation, etc. The description should address
any environmental concerns associated with the
disposal method;
- A description of the methods to be used to monitor
run-off quality.
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8.2.7 Management of Wind Dispersal
8.2.7.1 The Federal Requirement —
Section 270.21(b) requires that the Part B application
information include:
Detailed plans and an engineering report describing
how the landfill is or will be designed, constructed,
operated, and maintained to comply with the requirements
of §264.301. This submission must address the following
items as specified in §264.301...
(5) Control of wind dispersal of particulate matter, where
applicable
Section 264.301(f) states that:
If the landfill contains any particulate matter which may
be subject to wind dispersal, the owner or operator must
cover or otherwise manage the landfill to control wind
dispersal.
8.2.7.2 Guidance to Achieve the Part 264 Standard —
The degree of wind erosion of landfill wastes depends on the
waste type, moisture content, wind velocity, and surface geometry.
Particulate emissions caused by wind erosion of landfilled waste
materials or soils covering a landfill can be minimized by use
of physical, chemical, or vegetative stabilization. Physical
stabilization methods function to cover the exposed surfaces with
a material that prevents the wind from disturbing the surface
particles. A common stabilizing material is soil used as an
intermediate cover over the exposed surface of the waste after
the daily operations.
Chemical stabilizers can be added to cover soils to reduce
wind erosion. Many of the compounds are proprietary developments,
and their properties are difficult to evaluate without actual
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site-specific field testing. In selecting a soil additive,
one should consider effectiveness, stability, ease of
application, cost, safety, and environmental impact. Most
chemical stabilizers only provide dust suppression for a
limited period of time, generally no more than a few months;
thereafter, a more permanent solution is needed. This solution
generally consists of the establishment of a vegetative
cover. Information on chemical soil stabilizing materials
and their characteristics is available from References 9,
10, and 11.
Vegetation can be effectively used to stabilize a variety
of exposed soil surfaces and is used primarily in the final
cover. This method of stabilization not only provides permanent
dust suppression but makes the site more aesthetically acceptable.
The control efficiency of this method varies considerably
with the amount and type of cover established on the site.
Efficiencies of nearly 100 percent should be achieved with
complete vegetative covering on some sites.
Finally, windbreaks such as tree lines or fences may
assist in minimizing wind dispersal of particulates. Such
measures alone, however, often are not adequate, particularly
when large areas are involved. The effectiveness of windbreaks
should be evaluated on a case-by-case basis.
8.2.7.3 Guidance to Address the Application Information
Requirement
The applicant would assess the potential for wind dispersal.
This may be based on factors such as type of waste(s) disposed,
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predominant wind direction and velocity, local topography,
windbreaks, and operational procedures. The approach used
in this assessment and the results should be included in the
basic portion of the application.
If the assessment indicates a potential for wind dispersal,
a control plan must be developed. A suggested attachment to
the permit application is Wind Dispersal Flow Control Plan.
The applicant should submit the following information
on wind dispersal control:
- A description of the method(s) proposed for controlling
wind dispersal. Include such considerations as
the siting of the landfill; the use of water sprays,
dust suppressants other than water, stabilizers,
windbreaks, and enclosures (if they are used as
landfill management techniques for control of wind
dispersal).
- Data supporting the effectiveness of the proposed
wind dispersal control technique(s).
8.2.8 Ground-Water Protection Exemption for Double-Lined Landfills
8.2.8.1 The Federal Requirement —
If the applicant desires exemption from the ground-water
protection standards because he proposes a double-lined landfill,
section 270.21(c) requires the Part B application information
include:
(c) If an exemption from Subpart F of
Part 264 is sought, as provided by §264.302(a),
the owner or operator must submit detailed
plans and an engineering report explaining the
location of the saturated zone in relation to
the landfill, the design of a double-liner
system that incorporates a leak detection
system between the liners, and a leachate
collection and removal system above the liners;
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Section 264.302(a) states:
The owner or operator of a double-lined landfill is
not subject to regulations under Subpart F of this
part if the following conditions are met:
(1) The landfill (including its underlying liners)
must be located entirely above the seasonal high
water table.
(2) The landfill must be underlain by two liners
which are designed and constructed in a manner to
prevent the migration of liquids into or out of the
space between the liners. Both liners must meet all
the specifications of 264 .301(a)(1).
(3) A leak detection system must be designed,
constructed, maintained, and operated between
the liners to detect any migration of liquid
into the space between the liner.
(4) The landfill must have a leachate collection
and removal system above the top liner that is
designed, constructed, maintained, and operated
in accordance with §264 .301(a)(2).
8.2.8.2 Guidance to Achieve the Part 264 Standard —
The design and operating standards contain special sets
of standards for landfills with double liners and leak
detection systems. Compliance with these standards is not
mandatory. However, if an applicant voluntarily applies for
and is issued a permit to comply with these special standards
(in addition to the other standards generally applicable to
these units), he is not subject to the ground-water protection
regulations contained in Subpart F. These special standards
require that there be two synthetic liners underlying the
unit and a leak detection system between the two liners.
The leak detection system enables the permittee of the
landfill to detect whether any liquid has entered into the space
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between the liners. This is the means to determine if the upper
liner has failed or is leaking. It serves as a substitute for
the ground-water monitoring system.
Because a permit written for a double-lined unit does not
contain any ground-water detection monitoring requirements,
the permittee must repair or replace the leaking liner if liquid
is found in the leak detection system. Therefore, EPA suggests
that those who anticipate retrofitting problems in attempting to
repair or replace leaking liners should consider requesting
that a detection ground-water monitoring program be established
in their permits in accordance with the requirement of §264.98,
as contingent requirements. Such requirements would be
automatically triggered in the event of a leak, but would
not have to be complied with until such a leak occurred.
The permit would specify well placement, detection parameters
to be monitored, and the frequency of monitoring. If a leak
in the top liner occurred, the permittee would then install
the wells and begin a ground-water monitoring program in
accordance with a schedule set forth in the permit.
8.2.8.3 Guidance to Address the Application Information
Requirement —
A landfill must not be located within the saturated zone
in order to qualify for the exemption described in §264.302(a).
Many fine-grained geologic formations may not meet the charac-
teristics of an aquifer, but may be nonetheless saturated. A
landfill constructed in such a formation would be within the
ground water table, and could not qualify for the exemption.
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The applicant should submit the following information if
the ground-water monitoring program exemption is being applied
for:
- A demonstration that the landfill and its underlying
liners will be located entirely above the seasonal high
ground water table. The applicant should refer to
section 9.3 of this manual for guidance on how to describe
the hydrogeologic characteristics of the facility's
location.
- A demonstration that both liners satisfy the requirements
of §264.301(a)(1). The applicant should refer to
Section 8.2.1 for guidance on how to demonstrate compliance
with this standard for each liner. For these cases in
which two different types of liner material are to be
used, a liner integrity analysis (i.e., waste-liner
compatibility test) for both liners must be submitted.
- A demonstration that the leak detection system between
the two liners will be designed, constructed, maintained,
and operated to detect any migration of liquid into
the space between the liners. EPA recommends that
the leak detection system resemble the leachate collection
and removal system. If the top liner leaks, a leachate
collection and removal system will be present beneath
it for immediate operation. The applicant can refer
to Section 8.2.2 for guidance on leachate collection
and removal system design.
- A demonstration that the leachate collection and removal
system above the top liner satisfies the standard in
§264.301(a)(2). The applicant can refer to section 8.2.2
for guidance on collection and removal system design.
A suggested attachment to the permit application is Report
Supporting Request for Exemption from Ground-Water Protection
Requirements for Double-Lined Landfills.
8.2.9 Inspections
8.2.9.1 The Federal Requirement —
Section 270.21(d) requires that the Part B Application
include:
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(i) A description of how each landfill, including the
liner and cover systems, will be inspected in order to
meet the requirements of §264.303 (a) and (b). This
information should be included in the inspection plan
submitted under 270.14(b)(5).
Section 264.303(a) states:
(a) During construction or installation, liners (except
in the case of existing portions of landfills exempt
from §264.221(a) and cover systems (e.g., membranes,
sheets, or coatings) must be inspected for uniformity,
damage, and imperfections (e.g., holes, cracks, thin
spots, or foreign materials). Immediately after
construction or installation:
(1) Synthetic liners and covers must be inspected to
ensure tight seams and joints and the absence of tears,
punctures, or blisters; and
(2) Soil-based and admixed liners and covers must be
inspected for imperfections including lenses, cracks,
channels, root holes, or other structural non-uniformities
that may cause an increase in the permeability of the
liner or cover.
Section 264.303(b) states:
(b) While a landfill is in operation, it must be inspected
weekly and after storms to detect evidence of any of
the following:
(1) Deterioration, malfunctions, or improper operation
of run-on and run-off control systems;
(2) The presence of liquids in leak detection systems,
where installed to comply with §264.302;
(3) Proper functioning of wind dispersal control
systems, where present; and
(4) The presence of leachate in and the proper functioning
of leachate collection and removal systems, where present.
8.2.9.2 Guidance to Achieve the 264 Standard —
8.2.9.2.1 Liner and Membrane Inspections
Synthetic liner and cover systems must be inspected during
construction and installation for uniformity, damage and
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imperfections, and after installation to insure tightness of
seams and joints and absence of tears, puctures, or blisters.
Soil-based and admixed liners and covers must be inspected for
imperfections including lenses, cracks, channels, root holes or
other structural non-uniformities that may adversely affect
the permeability, strength, or other engineering properties of
the liner or cover. The applicant should consult the EPA
publication on liners (Reference 3) for information on specific
inspection needs and objectives for various liners. Information
on evaluating cover systems is also available in Reference 12.
An effective quality control program will form the basis for
the inspection plan for the installation and construction of
liners. The applicant should propose a Liner Installation Quality
Control Program (QC) that addresses the proposed methods of liner
inspection, testing and documentation. The QC Program may be
developed, in part, from manufacturer's standard inspection
procedures. For example, for a synthetic liner, it should include,
but not be limited to, the following specific provisions:
(1) The permittee will designate a field representative
(QC Manager) with sole responsibility for inspection
and approval of liner work. For large projects,
the permittee should provide a sufficient number
of personnel to assist the QC Manager to achieve
the objectives of the QC Program;
(2) QC Program should include assurance that the following
objectives are met:
The construction specifications required in
the permit are fully implemented;
Subgrade preparation is consistent with
requirements for synthetic liner membranes;
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Handling of liner materials is performed in
accordance with manufacturer's recommended
procedures;
Manufactured liner panels, upon arrival at the
project site, are free of product defects and
damage resulting from shipping;
- Fabricated seams of prefabricated sheet
membranes are tested by airlance, vacuum or
other suitable means to determine location of
defects;
- Liquid-applied membranes, adhesives, and
solvents are delivered in sealed containers
and are used in accordance with the manufacturer's
recommendations;
- Contractor's tools are consistent with manufac-
turer's recommendations; sharp instruments
such as pointed scissors are not allowed;
Field seams constructed by adhesive, heat,
welding or other means are tested by airlance,
vacuum, ultrasonic method or by any combination
of methods to determine the location of defects;
Placement of soil and protective cover is
accomplished so that the soil is free of
deleterious materials, and in such a manner
that damage is not caused to the liner membrane
by disposal operations;
- Samples of liner material, fabrication seams
and field seams are taken routinely in sufficient
number to verify the quality of workmanship
of the completed work;
Laboratory testing of field samples is
conducted in accordance with ASTM standards
and procedures for synthetic liner membranes.
Results should be reviewed by the QC Manager
and corrective action taken if materials and
seams do not meet minimum specified strengths.
The permittee should notify the Regional
Administrator of such corrective action and
make all test results available for review
upon request.
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Documentation of all phases of the QC Program
should be prepared by the permittee for record
purposes. Daily reports should be maintained
by the QC Manager describing observations,
activities, weather, production, contractor's
equipment, and work force and specific problems.
Deviations from standard construction procedures
by the contractor, corrective measures and
changes in design should be fully documented.
Location of field samples and laboratory test
results should be made a part of program
documentation.
Soil-based and admixed liners and covers must be inspected
and tested to ensure that they are properly constructed according
to the approved design. The test data should consist of strength,
permeability and other material properties of samples representa-
tive of the liner or cover to be used in construction. Actual
waste fluid or equivalent should be used whenever appropriate in
the tests.
To ensure that the liner and cover system are constructed
according to the approved design and specifications, and to ensure
uniformity, absence of damage and imperfections, an independent
test lab and inspector supervised by a qualified, registered
engineer should be present at all phases of construction and
installation to monitor and test the materials as they are placed.
Non-destructive or destructive sampling and testing should be
performed on a random basis in accordance with established accep-
table standards. In destructive sampling and testing, the areas
sampled or tested should be restored to original condition
immediately after sampling or testing. All test results and other
pertinent data, such as location, elevation, date, climatic condi-
tions, personnel, etc. should be documented and kept on record.
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8.2.9.2.2 Operational Inspections
In addition to inspections during construction and installa-
tion, qualified personnel must make inspections of a landfill while
it is in operation. These inspections must be conducted weekly
and after storms. A detailed written schedule should be developed
for inspection of: (a) run-on and run-off control systems,
(b) leak detection systems, (c) wind dispersal control system, and
(d) leachate collection and removal system.
The inspection records should include the maintenance and
calibration records of any control systems, leak detection systems,
and leachate collection and removal systems. The amount of
leachate present in the collection and removal system should be
recorded. All information from each inspection should be docu-
mented and kept on record for EPA review.
The applicant is advised that additional general inspection
requirements are delineated in §264.15(b) of the general facility
standards. The corresponding permit information requirements
for these requirements are provided in §270.14(b)(5). Guidance
on these overall inspection requirements is provided in the
Permit Applicants' Guidance Manual for General Facility Standards,
Reference 1.
8.2.9.3 Guidance to Address the Application Information
Requirement —
The following information on inspection should be submitted
with the permit application. The applicant should include this
information in the overall Facility Inspection Plan as required
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under §270.14(5)(5). Two suggested attachments within the
Facility Inspection Plan submitted with the permit application
are a Liner and Membrane Construction Inspection Plan and an
Operation Inspection Plan.
Liner and Membrane Inspection Plan
- Describe procedures, including a quality control
program, for inspecting synthetic liners and covers
during construction and installation. The applicant
should address all inspection needs discussed above
for synthetic liners and covers.
- Describe procedures, including a quality control
program, for inspecting soil-based and admixed
liners and covers during cnstruction and installation.
The applicant should address all inspection needs
discussed above for soil-based and admixed liners
and covers.
Operation Inspection Plan
- Describe the procedures for inspecting weekly and after
storms for detection of:
— deterioration, malfunction, or improper operation
of run-on and run-off control systems;
— presence of liquids in the leak detection system,
where installed to comply with §264.302;
— proper functioning of wind dispersal control
systems; and
— presence of leachate in and the proper functioning
of leachate collection and removal system, where
present.
Indicate who will conduct these inspections, how the
inspection records will be maintained, and what
conditions will trigger a response.
8.3 CLOSURE
8.3.1 The Federal Requirement
Section 270.21(e) requires that the Part B application
include:
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(e) Detailed plans and an engineering report describing
the final cover which will be applied to each landfill
or landfill cell at closure in accordance with
§264.310(a). .. This information should be included
in the closure and post closure plans submitted
under 270.14(b)(13).
Section 264.310(a) requires that:
(a) At final closure of the landfill or upon closure of
any cell, the owner or operator must cover the landfill
or cell with a final cover designed and constructed
to:
(1) Provide long-term minimization of migration of
liquids through the closed landfill;
(2) Function with minimum maintenance;
(3) Promote drainage and minimize erosion or abrasion
of the cover;
(4) Accommodate settling and subsidence so that the
cover's integrity is maintained; and
(5) Have a permeability less than or equal to the
permeability of any bottom liner system or natural
subsoils present.
8.3.2 Guidance to Achieve the Part 264 Standard —
A final cover must be placed on the unit at closure.
The final cover should be placed as each cell is closed or,
preferably, as the filling of the cell progresses. In some
cases, such as when operations are conducted in the multiple
lifts, final cover cannot be applied until the lift or layer
is filled. Less substantial, interim cover should be applied
to cells other than the topmost in multiple-lift landfills.
The Agency believes that a three-layer final cover (cap)
will adequately minimize infiltration of precipitation, which
is the primary purpose of the final cover. The final cover
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acts to minimize infiltration by causing precipitation to
run off through use of slopes, drainage layers, and impermeable
and slightly permeable barriers. Other functions of the final
cover include prevention of contamination of surface run-off,
prevention of wind dispersal of hazardous wastes, and prevention
of direct contact with hazardous wastes by people and animals
straying onto the site. For guidance on an acceptable final
cover, the applicant should refer to Reference 4.
To prevent the "bathtub effect, i.e., to prevent the
landfill from filling with leachate after closure when the
leachate collection system ceases to function, the final
cover must be no more permeable than the most impermeable
component of the liner system (or of the underlying soils).
In this way, no more precipitation is allowed to infiltrate
the cell than can escape through the bottom liner. Prevention
of the bathtub effect is important to eliminate the possibility
of surface overflow or migration through porous surface
strata.
The final cover should be designed to accommodate pressures
resulting from gas generated within the wastes. The cover
should either withstand these pressures and retain the gases;
or preferably, the gases should be safely vented to the
atmosphere. The design shall include a discussion of the
potential for gas generation and include features to manage
the gas. See the discussion about gas in Section 8.2.1.2.
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In some instances, an entire landfill will not be completely
filled and ready for final cover at the same time. The Agency
suggests that, when possible, portions of a landfill be completed
to final grade and the final cover installed. This will provide
the best protection to the site as early as possible.
When this is not possible or economically feasible, an
intermediate cover should be installed over completed portions
or portions that will not receive additional waste for some time.
An impermeable cap is not required; however, the intermediate
cover should minimize infiltration and run-off. .Several feet of
compacted soil planted with an intermediate vegetative cover are
suggested. This intermediate cover may also serve as a surcharge
to accelerate differential settlement of the landfill compared
to a site without a surcharge, this may result in a more stable
site upon which to install the final cover.
8.3.3 Guidance to Address the Application Information
Requirement
The applicant should present an analysis of the final cover
design in the basic portion of the application. This final
cover analysis should demonstrate that the proposed final cover
meets the requirements of §264.310(a). Details of the design
including drawings, specifications, calculations, etc. should
be attached. A suggested attachment to the permit application
is Cover Design.
The final cover analysis should describe how the following
factors are provided for, with details included in the attached
Cover Design:
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- Minimization of Liquid Migration. If a design other
than that defined by EPA in Reference 4 is used,
submit engineering calculations to show that the
proposed cover will provide long-term minimization
of migration of liquids through the closed,landfill.
The applicant should demonstrate that infiltration
is equivalent to or less than the cover design provided
in RCRA Guidance Document; Landfill Design - Liner
Systems and Final Cover 4. The use of the H.E.L.P.
model is suggested (See Reference 13).
- Maintenance Needs. Demonstrate that the cover system
will function effectively with minimum maintenance.
For example, data should be provided showing that the
vegetative cover crop is adapted to regional conditions
and is able to thrive with minimal irrigation or
fertilization.
- Drainage and Erosion. Provide the following information:
— Data demonstrating that the proposed slopes will
not cause significant erosion of the final cover.
The USDA Universal Soil Loss Equation may be used
in this demonstration. This equation is described
in EPA Reference 4 and should be used when proposed
slopes do not conform to the Reference 4 policy.
— A description of the material in the drainage layer
of the final cover that will be used including the
type and permeability of the material.
— Engineering calculations and designs showing that
precipitation will drain freely to the side.
(Note: If the applicant proposes the design
recommended by EPA (4), this information does not
have to be submitted).
— Data addressing the potential for clogging of the
drainage layer. The use of the Army Corp of
Engineers clogging criteria formulas described in
Reference 4 is recommended.
- Settlement and Subsidence. Submit the following informa-
tion:
— Data addressing the potential for settlement due to
compression of the foundation. This analysis should
consider immediate settlement, primary consolidation,
secondary consolidation and creep, and liquifaction.
The immediate settlement estimate should consider
the strength and elastic properties of the foundation
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soils. The primary and secondary consolidation
should be estimated based on consolidation tests
performed on undisturbed soil samples. Settlement
due to creep or liquifaction should also be estimated
for the slopes and bottom of a landfill, if the sub-
surface soils are susceptible to creep or if there
is a potential for liquifaction of the foundation
soils.
Data addressing the potential for settlement
due to compression of the liner. This analysis
should consider the same factors as described above
for foundation compression. Analysis of settlement
due to compression of the liner may be similar to
that for the foundation, except that liquifaction
potential for the filter and drain materials above
or underlying the liner should also be considered
in the analysis.
Data addressing the potential for settlement due
to compression of waste in the landfill, the
following factors should be included in the analysis:
dewatering of waste material; biological oxidation
of organics; and chemical conversion of solids to
dissolved waste materials.
Analysis of settlement due to dewatering of waste
material should consider the evaporation, drainage
conditions, and fluidity and homogeneity of the
waste material. The settlement due to consolidation
under the weight of the waste and the cover may
be analyzed based on consolidation test results
performed on undisturbed representative waste
sediment samples in the landfill. Both primary
and secondary consolidation settlement shall be
estimated. For nonhomogeneous, unsaturated,
compacted or uncompacted waste sediments, the
settlement analysis should take into consideration
the collapsing of voids within the waste material.
To accommodate the amount of settlement, the
placement of the cover should be scheduled
accordingly.
Information addressing the effects of freeze/thaw
on the integrity of the proposed cover.
Data on the effects of subsidence/settlement on
the ability of the final cover to minimize
infiltration.
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- Permeability Documentation. Clearly document that the
final cover has a permeability less than or equal to
the permeability of any bottom liner system or natural
subsoils present. This item can simply point out
permeability data for the liner and cover systems
attached to application.
- Freeze/Thaw Effects. Discussion of the effects on
the final cover due to freeze/thaw. The applicant
should demonstrate that the synthetic liner in the
final cover is located wholly below the average
depth of frost penetration in the specific area.
The attached Cover Design should contain the raw data,
assumptions, calculations, drawings, and specifications necessary
to support the analysis of the final cover's ability to meet
the requirements. The Cover Design should include:
- Detailed drawing(s) of the proposed layers in the
final cover (including such items as the thickness
of each layer, the slope of each layer, and the
dimensions of the cover system);
- The common name, species and variety of the cover
crop to be established;
- A description of the synthetic liner that will be
used in the final cover including the type of
synthetic liner, its chemical properties, and the
manufacturer's specifications of its physical
strength and thickness. An explanation of why the
synthetic liner was selected should also be provided.
- Descriptions of any protective materials placed
above and below the synthetic liner and specification
of the type of material.
- Characteristics of any clay layer placed beneath
the liner in the final cover (including thickness
and permeability).
- The construction plans for the clay layer and the
sequence of the lifts.
- Analysis of surface drainage and discussion of erosion
control
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- Installation procedures for each layer of the cover
with emphasis on installation of the synthetic
membrane
- Specifications for the drainage layer including
hydraulic conductivity
8.4 POST-CLOSURE
8.4.1 The Federal Requirement
Section 270.21(e) requires that the Part B applicant
include:
... a description of how each landfill will be
maintained and monitored after closure in
accordance with §264.310(b). This information
should be included in the closure and post-closure
plans submitted under §270.14(b)(13).
Section 264.310(b) states that:
After final closure, the owner or operator
must comply with all post-closure requirements
contained in §§264.117-264.120, including main-
tenance and monitoring throughout the post-
closure care period (specified in the permit
under §264.117). The owner or operator must:
(1) Maintain the integrity and effectiveness
of the final cover, including making repairs to
the cap as necessary to correct the effects of
settling, subsidence, erosion, or other events;
(2) Maintain and monitor the leak detection
system in accordance with §264.302, where such
a system is present between double liner
systems;
(3) Continue to operate the leachate collection
and removal system until leachate is no longer
detected;
(4) Maintain and monitor the ground-water
monitoring system and comply with all other
applicable requirements of Subpart F of this
Part;
(5) Prevent run-on and run-off from eroding
or otherwise damaging the final cover; and
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(6) Protect and maintain surveyed benchmarks
used in complying with §264.309.
8.4.2 Guidance to Achieve the Part 264 Standard
Post-closure care must be continued for 30 years after
the date of completing closure. Post-closure care consists
of maintaining the final cover and performing monitoring
and response as necessary, to prevent adverse impacts on
human health and on the environment. The frequency of
monitoring and maintenance activities should be balanced
with the specific factors considered in the initial closure
design (i.e., climate, waste type, soil, vegetation, etc.).
8.4.3 Guidance to Address the Application Information Requirement
The applicant should submit a description of planned
activities that will be conducted in order to comply with
the §264.310(b) post-closure care requirements. This information
should be included in the Post-Closure Care Plan, submitted
as an attachment to the permit application. The description
should address, at a minimum, the following activities:
Frequency of inspection of the closed facility
and what will be inspected.
Operation of leachate collection and removal system
until leachate is no longer observed.
Maintenance of the final cover (e.g. reestablishing
the vegetative layer, and assessment of subsidence).
Maintenance and monitoring of leak detection system,
groundwater monitoring (frequency and list of
constituents to be monitored).
- Maintenance and inspection of run-on and run-off
controls in order to prevent erosion of and/or
damage to the final cover.
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- Maintenance of surveyed benchmarks used in complying
with §264.309.
8.5 SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTES
8.5.1 The Federal Requirement
Section 270.21(f) requires that the Part B application
include:
If ignitable or reactive wastes will be landfilled,
an explanation of how the requirements of §264.312
will be complied with;
Facility Standard 264.312 states:
(a) Except as provided in paragraph (b) of this
section, and in §264.316, ignitable or reactive
waste must not be placed in a landfill, unle.ss
the waste is treated, rendered, or mixed before
or immediately after placement in a landfill so
that:
(1) The resulting waste, mixture, or dissolution
of material no longer meets the definition of ignitable
or reactive waste under §§261.21 or 261.23 of this
Chapter, and
(2) Section 264.17(b) is complied with.
(b) Ignitable wastes in containers may be landfilled
without meeting the requirements of paragraph (a) of
this section, provided that the wastes are disposed
of in such a way that they are protected from any
material or conditions which may cause them to
ignite. At a minimum, ignitable wastes must be
disposed of in non-leaking containers which are
carefully handled and placed so as to avoid heat,
sparks, rupture, or any other condition that might
cause ignition of the wastes; must be covered daily
with soil or other noncombustible material to minimize
the potential for ignition of wastes; and must not be
disposed of in cells that contain or will contain
other wastes which may generate heat sufficient to
cause ignition of the waste.
8.5.2 Guidance to Achieve the Part 264 Standard
The regulations require the permittee to take precautions
to prevent accidental ignition of ignitable wastes and protect
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the waste from sources of ignition. The Agency will allow
the management of ignitable wastes in landfills if the wastes
are protected from any material or conditions that may cause
them to ignite. The restrictions on liquid wastes in general,
coupled with the requirements that ignitable wastes be in con-
tainers when landfilled, as a practical matter, greatly restrict
the landfilling of ignitable wastes.
8.5.3 Guidance to Address the Application Information
Requirement
The applicant should submit the information defined in
Option 1 or Option 2 below. A suggested attachment to the
permit application is Ignitable and/or Reactive Waste Management
Plan(s).
Option 1
- Description of how ignitable or reactive wastes will
be identified when received at the site (should also
be included in the Waste Analysis Plan).
- Description of the procedure for treating, or mixing
the ignitable or reactive wastes before or immediately
after placement in the landfill.
- Results of laboratory or field experiments that
demonstrate that, after treatment or mixing and place-
ment in the landfill, the reactive or ignitable waste
will be rendered non-reactive or non-ignitable.
- Description of how §264.17(b) will be complied with
(i.e., describe what precautions will be taken to
prevent reactions which: (1) generate extreme heat or
pressure, fire or explosions, or violent reactions;
(2) produce uncontrolled toxic mists, fumes, dusts,
or gases in sufficient quantities to threaten human
health or the environment; (3) produce uncontrolled
flammable fumes or gases in sufficient quantities to
pose a risk of fire or explosion; (4) damage the
structural integrity of the device or facility, and
(5) through other like means threaten human
health or the environment).
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Option 2 (applicable only to ignitable wastes in
containers).
- If ignitable wastes in containers are landfilled,
a description of how the wastes will be disposed
of so that they are protected from any material
or conditions that may cause them to ignite.
This description should include handling proce-
dures, the daily cover characteristics, and
characteristics of the other wastes disposed
in the same cell.
Additional guidance on the ignitable and reactive waste
information needs is provided in Reference 1.
8.6. SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES
8.6.1 The Federal Requirement
Section 270.21(g) requires that the Part B application
include:
(g) If incompatible wastes, or incompatible
wastes and materials will be landfilled, an
explanation of how §264.313 will be complied
with:
Section 264.313 states:
Incompatible wastes, or incompatible wastes and
materials, (see Appendix V of this part for examples)
must not be placed in the same landfill cell unless
§264.17(b) is complied with.
8.6.2 Guidance to Achieve the Part 264 Standard
The potential dangers from the mixing of incompatible wastes
and materials include extreme heat, fire, explosion, violent
reaction, production of toxic mists, fumes, dusts, or gases, and
damage to the structural integrity of the landfill. Clearly, the
potential impacts on human health or the environment which could
result from such conditions must be avoided. Additional guidance
on incompatibility can be found in References 14 and 15.
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8.6.3 Guidance to Address the Application Information Requirement
A suggested attachment to the permit application is Management
Plan for Incompatible Wastes. The applicant should first determine
whether incompatible wastes and/or materials will be landfilled by
following the subsequent steps and providing the information in
the permit application:
- Review the lists of incompatible wastes in Section 7.9.2
and identify any that may be received
- Identify other wastes to be disposed that are not
shown in Section 7.9.2.
- Determine if any mixture of these wastes or materials
is incompatible and identify the wastes and nature
of the incompatibility. Note: if available, the applicant
may use Reference 14, A Method for Determining Compatibility
of Wastes as an aid in determining compatibility of
wastes; however, this document should be used with the
caution noted in Section 3.4.3.2 of this manual.
If incompatible wastes and/or materials will be landfilled,
the applicant must describe:
- Methods for identifying these wastes as they are received
at the site
- Step-by-step procedures for managing incompatible
wastes or material to prevent undesirable reactions
or effects defined in §264.17(b);
- Laboratory or field data demonstrating that incompatible
wastes can be safely managed at the landfill using the
proposed procedures.
8.7 SPECIAL REQUIREMENTS FOR LIQUID WASTE
8.7.1 The Federal Requirement
Section 270.21(h) requires that the Part B application
include:
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If bulk or non-containerized liquid waste or waste
containing free liquids is to be landfilled, an
explanation of how the requirements of §264.314 will
be complied with;
Section 264.314 states:
(a) Bulk or non-containerized liquid waste or waste
containing free liquids must not be placed in a landfill
unless:
(1) The landfill has a liner and leachate collection
and removal system that meet the requirements of
§264.301(a); or
(2) Before disposal, the liquid waste or waste containing
free liquids is treated or stabilized, chemically or phys-
ically (e.g., by mixing with an absorbent solid), so
that free liquids are no longer present.
(b) Containers holding free liquids must not be placed
in a landfill unless:
(1) All free-standing liquid: (a) has been
removed by decanting, or other methods; (ii)
has been mixed with absorbent or solidified so
that free-standing liquid is no longer observed;
or (iii) has been otherwise eliminated; or
(2) The container is very small, such as an
ampule; or
(3) The container is designed to hold free
liquids for use other than storage, such as a
battery or capacitor; or
(4) The container is a lab pack as defined
in §264.316 and is disposed of in accordance
with §254.316.
8.7.2 Guidance to Achieve the Part 264 Standard
Section 264.314 restricts the disposal of liquids in land-
fills. To accept bulk or non-containerized liquids, the landfill
must have a liner and leachate collection and removal system
which meets the requirements of §264.301(a), or the liquid
or waste containing free liquids must be treated or stabilized
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to remove free liquids before disposal. Physical processes,
such as mixing with an absorbent solid, will remove free
liquids. Chemical treatment processes, such as stabilization/
solidification will also remove free liquids from the waste.
Several stabilization/solidification methods are currently
available or under development. Detailed information
concerning each of these methods can be found in Reference
16.
EPA interprets "before disposal" for the treatment/
stabilization of liquids in §264.314(a) and (b) to mean that
these processes are completed outside the landfill. Thus no
bulk or non-containerized liquids are to enter a landfill
unless the unit has a liner and leachate collection and
removal system. The above interpretation and regulations
apply to both hazardous and non-hazardous liquids and waste
containers entering a Part B permitted landfill.
The EPA interprets free-standing liquids as those that
form distinct pools or layers within a container. Included
in the definition are those covered with a scum or film, or
those liquids known to accumulate in layers or pools below
the surface of a container. Where it is difficult to determine
whether a given substance that separates out from the waste
is a freestanding liquid, the EPA recommends that the
paint filter test described in 46 FR 8311, February 25, 1982,
proposed rules be used.
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Permittees are not required to open and inspect all
containers if they can demonstrate that such practices assume
reasonable compliance. For example, where the landfill
receives a batch of containerized wastes and has evidence
that the content among containers does not vary significantly,
and does not contain free-standing liquid, a representative
sample of the containers may be opened and inspected.
Section 264.314(b)(4), concerning lab packs, is discussed
in Section 8.9
8.7.3 Guidance to Address the Application Information
Requirement
The applicant must determine whether bulk or non-containerized
liquids will be received at the landfill. Procedures to accomplish
this should be included in the overall Waste Management Plan.
If. bulk or non-containerized liquid waste or waste containing
free liquids are proposed to be placed in the landfill, the
applicant should submit the following information in (a) or
(b) below. A suggested attachment to permit the application
is Liquid Waste Management Plan.
(a) Information demonstrating that the landfill has (or
will have) a liner and leachate collection and removal
system that meet the requirement of §264.301(a). See
Sections 8.2.1 and 8.2.2 for a discussion of specific
information that should be included to address
§264.301(a). (If this information is presented
elsewhere in the application, the applicant should
simply note this here).
(b) Data demonstrating that the liquid waste or waste
containing free liquids is treated or stabilized,
chemically or physically, so that free liquids are
no longer present. Describe the treatment or
stabilization process in detail.
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If containers holding free liquids are proposed to be
landfilled, the applicant should submit as an attachment a
Liquid Waste Management Plan for Containers. This plan should
be coordinated with the overall Waste Management Plan and
include:
- Descriptions showing that the free standing liquids
will be removed by decanting or other methods, mixed
with absorbent or solidified so that free-standing
liquids are no longer observed, or otherwise
eliminated. The applicant should identify any
test methods that will be used to determine the
presence or absence of free standing liquids,
unless the applicant provides:
- Documentation that the containers will be very small,
such as an ampule or;
Data demonstrating that the containers are
designed to hold free liquids for use other than
storage, such as battery or capacitor or;
- Information showing that the containers will be
lab packs as defined in §264.316. (Additional
information on lab packs must also be submitted;
see Section 8.9 of this manual.
8.8 SPECIAL REQUIREMENTS FOR CONTAINERS
8.8.1 The Federal Requirement
Section 270.21(i) requires that the Part B application
include:
If containers of hazardous waste are to be landfilled,
an explanation of how the requirements of §§264.315
or 264.316, as applicable, will be complied with.
Section 264.315 states:
Unless they are very small, such as an ampule, containers
must be either:
(a) At least 90 percent full when placed in the
landfill; or
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(b) Crushed, shredded, or similarly reduced in
volume to the maximum practical extent before burial
in the landfill.
8.8.2 Guidance to Achieve the Part 264 Standard
The purpose of the §264.315 standard is to minimize subsidence
in the landfill resulting from decaying containers having
void spaces. The EPA believes by allowing only full containers
or those that have been crushed or otherwise reduced in void
space to be placed in a landfill, disruptive subsidence of the
final cover resulting from the placement of partially filled
containers in landfills can be avoided. Container crushing
equipment is readily available.
Those permittees having containers which are partially
filled may either (a) fill them to greater than 90 percent
of their capacity, (b) empty them and then crush or shred
them to the maximum extent practical, or, (c) to the extent
technology and safety allow, reduce the volume of the partially
full containers. The provision allowing landfilling of
containers that are 90 percent full means that there could
be about 4 inches of void space in the typical 55-gallon
drum. Very small containers, such as ampules, were exempted
because these containers have void spaces which would not
significantly affect the stability of a landfill.
8.8.3 Guidance to Address the Application Information
Requirement
The applicant should submit the information in (a), (b),
or (c) below, if containers of hazardous waste are proposed to
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be landfilled. A suggested attachment to the permit application
is Management Plan for Containers.
(a) Documentation that the containers will be very
small, such as an ampule;
(b) Data demonstrating that the containers will be
at least 90 percent full when placed in the
landfill. Also, describe the procedure for
inspection or verification in the Waste Analysis
Plan.
(c) Description of procedure for crushing, shredding,
or similarly reducing the containers in volume to
the maximum practical extent before burial in
the landfill.
8.9 DISPOSAL OF SMALL CONTAINERS IN OVERPACKED DRUMS
(LAB PACKS)
8.9.1 The Federal Requirement
Section 270.21(1) requires that the Part B application
include:
(ix) If containers of hazardous waste are to be
landfilled, an explanation of how the requirements
of §§264.315 or 264.316, as applicable, will be
complied with.
Section 264.316 states:
Small containers of hazardous waste in over-
packed drums (lab packs) may be placed in a
landfill if the following requirements are met:
(a) Hazardous waste must be packed in non-
leaking inside containers. The inside containers
must be of a design and constructed of a material
that will not react dangerously with, be decomposed
by, or be ignited by the contained waste. Inside
containers must be tightly and securely sealed.
The inside containers must be of the size and type
specified in the Department of Transportation (DOT)
hazardous materials regulations (49 CFR Parts 173,
178, and 179), if those regulations specify a
particular inside container for the waste.
8-68
-------
(b) The inside containers must be overpacked
in an open head DOT-specification metal shipping
container (49 CFR Parts 178 and 179) of no more
than 416 liter (110 gallon) capacity and surrounded
by, at a minimum, a sufficient quantity of absorbent
material to completely absorb all of the liquid
contents of the inside containers. The metal outer
container must be full after packing with inside
containers and absorbent material.
(c) The absorbent material used must not be
capable of reacting dangerously with, being
decomposed by, or being ignited by the contents
of the inside containers in accordance with
§264.17(b).
(d) Incompatible wastes, as defined in §260.10
of this chapter, must not be placed in the same
outside container.
(e) Reactive wastes, other than cyanide- or
sulfide-bearing waste as defined in §261,23(a)(5)
of this chapter, must be treated or rendered non-
reactive prior to packaging in accordance with
paragraphs (a) through (d) of this section. Cyanide-
and sulfide-bearing reactive waste may be packed
in accordance with paragraphs (a) through (d) of this
section without first being treated or rendered non-
reactive.
8.9.2 Guidance to Achieve the Part 264 Standard
Section 264.316 provides that small containers of hazardous
wastes in overpacked drums, commonly known as "lab packs",
may be placed in landfills if the requirements are met. This
provision allows disposal of certain types of reactive wastes,
and liquid wastes in drums in accordance with these special
conditions.
Permittees are not required to open and inspect all lab
packs if they can demonstrate that such practices assume
reasonable compliance. For example, where the landfill
receives lab packs and has evidence of compliance with the
8-69
-------
above regulations, a representative sample of the containers
may be opened and inspected. Similarly, when the waste
generator certifies that the wastes delivering to the landfill
comply with the standard, the landfill permittee may satisfy
the responsibilities by obtaining the generator's certification
and verifying the generator's performance on a representative
number of the containers received.
8.9.3 Guidance to Address the Application Information Requirement
The applicant should submit a plan to verify compliance
with the regulations regarding disposal of lab packs including:
- review of waste generator's certifications of compliance
- methods to be used to verify compliance.
A suggested attachment to the permit application is Management
Plan for Overpacked Drums (Lab Packs).
8.10 REFERENCES
1. U.S. Environmental Protection Agency. Permit Applicants'
Guidance Manual for General Facility Standards. Washington,
D.C., 1984. (Being drafted)
2. U.S. Environmental Protection Agency. Test Methods for the
Evaulation of Solid Waste. SW-846, Washington, D.C., 1982.
GPO Stock No. 055-002-81001-2.
3. U.S. Environmental Protection Agency. Lining of Waste
Impoundments and Disposal Facilities. SW-870, Washington,
D.C., 1983. GPO Stock No. 055-000-000231-2.
4. U.S. Environmental Protection Agency. Draft RCRA Guidance
Document: Landfill Design, Liner Systems and Final
Cover. Washington, D.C., 1980.
5. U.S. Environmental Protection Agency. Landfill and Surface
Impoundment Performance Evaluation. SW-869, Washington,
D.C., 1980. GPO Stock No. 055-000-00233-9.
8-70
-------
6. U.S. Soil Conservation Seravice National Engineering
Handbook 4: Hydrology. Washington, D.C., 1977. NTIS
PB244-463.
7. U.S. Weather Bureau. Precipitation Frequency Atlas of
the United States. Technical Paper 40, Washington, D.C.,
1961.
8. U.S. Soil Conservation Service National Engineering
Handbook 5: Hydraulics. Washington, D.C., 1977. NTIS
No. PB24-644.
9. U.S. Environmental Protection Agency. Closure of Hazardous
Waste Surface Impoundment. SW-873, Washington, D.C., 1982.
GPO Stock No. 055-000-00227-4.
10. Armbrust, D.W., and J.D. Dickerson. Temporary Wind Erosion
Control: Cost and Effectiveness of 34 Commercial Materials.
J. Soil Water Conserv., 26: 154-157, 1981.
11. Lutton, R.J., G.L. Regan, and L.W. Jones. Design and
Construction of Covers for Solid Waste Landfils. EPA-
600/2-79-165, Army Engineers Experiment Station, Vicksburg,
Mississippi, August 1979. NTIS No. PB80-100381.
12. U.S. Environmental Protection Agency. Evaluation Cover
Systems for Solid and Hazardous Waste. SW-867, Washington,
D.C., 1982. GPO Stock No. 055-000-00228-2.
13. U.S. Environmental Protection Agency. User Guide for the
Hydrologic Evaluation of Landfill Performance (HELP) Model.
Washington, D.C. (to be released in 1984).
14. Hatayama, H.K., J.J. Chen, E.R. deVera, R.D. Stephens, and
D.L. Storm. A Method for Determining the Compatibility of
Hazardous Wastes. EPA 600/2-80-076, California Department
of Health Services, Berkeley, April 1980. NTIS No.
PB80-221005.
15. Hatayama, H.K., R.D. Stephens, E.R. deVera;, J.J. Chen, and
D.C. Storm. Hazardous Waste Compatibility. In: Disposal
of Hazardous waste; Proceedings of the 6th Annual Researach
Symposium, Chicago, March 1980. Environmental Research
Laboratory, Cincinnati, March 1980. NTIS No. PB80-175086.
pp. 21-30.
16. U. S. Environmental Protection Agency. Guide to the Disposal
of Chemically Stabilized and Solidified Waste. SW-872,
Washington, D.C., 1982. GPO Stock No. 055-000-0022-6.
8-71
-------
17. U.S. Environmental Protection Agency. Draft Solid Waste
Leaching Procedure Manual. Washington, D.C., 1983.
8.11 CHECKLIST
Table 8-1 is a checklist of permit application requirements
for landfills. The applicant is encouraged to use the checklist
and to incorporate it into the permit application. The checklist
identifies the application requirements and provides references
to Parts 264 and 270. The applicant should identify the location
in the application of the material addressing each requirement.
Space is provided for this. This will help insure that the
application is complete. As noted in Section 4.0, it is
suggested that a copy of this checklist be included as part of
the permit application. It will aid the reviewers of the
application. Reviewers will be able to more readily locate
specific aspects of the application and communications between
reviewers and applicants will be facilitated.
Definitions of terms used in the checklist are provided
below. Footnotes included in the checklist are explained on
the last page of the checklist.
Existing: A landfill that was in operation or for which
construction had commenced on or before
issuance of Part B permit and which has or will
receive hazardous wastes after January 26, 1983.
New, Type 1: Single synthetic liner, leachate collection
system. Ground-water monitoring (g-w).
New, Type 2: Double synthetic liner, leachate collection system,
leak detection, and above ground water. No ground-
water monitoring.
New, Type 3: Exempt from liner requirement. Ground-water
monitoring may not be required.
8-72
-------
An "X" in the checklist indicates that the applicant for that
type of unit must address the specific item or an equivalent
optional item (if available) in the permit application.
An "O" in the checklist indicates that the item is optional in
the permit application. Response to an optional item may
eliminate the necessity of responding to certain items that
might otherwise be required.
An "e" in the checklist indicates that the item does not apply
to "existing portions" of existing units, but does apply to
new portions of existing units.
A blank space in the checklist means that either the subject
requirement is general, with specific requirements listed below
it - the general subject requirement serves as a heading for
subordinates, or that the subject requirement does not apply
to that type of management unit.
8-73
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Page 1
oo
TABLE 8-1
PERMIT APPLICATION CHECKLIST FOR LANDFILLS
Part 270 Part 264 Subject Requirement
270.14(b) Part B General Information Requirements
270.14(b)(l) - General description of the facility
270.14(b)(2) 264.13(a) - Chemical and physical analysis of hazardous
wastes to be handled
270.14(b)(3) - Waste analysis plan
264.13(b)(l) - Analysis parameters with rationale
through (5)
- Test methods for analyzing parameters
Procedure for collecting representative
samples
- Frequency of analyses
- List and description of waste analyses to be
generator supplied
264.13(b)(6) - Waste analysis procedures for ignitable,
and 264.17(c) reactive, incompatible wastes
264.13(c) - For off-site facilities, procedures to identify
each waste movement, and
- Procedures for collecting representative
samples
270.14(b)(4) - Security description for active portion of
facility
264.14(a) - Security procedures waiver justification
E
)
)
X
>
X
X
X
X
X
X
0
xisting
fi
)
X
X
X
X
X
X
X
X
X
0
ew, Type 1, 1 liner, g-w
N
)
X
X
X
X
X
X
X
X
X
0
ew, Type 2, 2 liners
N
»
>
X
X
X
X
X
X
X
X
0
ew, Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Continued)
Page 2
oo
i
cr.
Part 270 Part 264 Subject Requirement
- Unknowing/unauthorized contact with waste
not harmful
- Unknowing/unauthorized disturbance of waste
or equipment cannot cause violation of
Part 264
264.14(b) - Description of 24-hour surveillance system, or
- Description of artificial or natural barriers,
and
- Description of controlled entry/egress
procedures, and
264.14(c) - Description of warning signs
- List of languages on signs
- Statement of 25- foot legibility
- Description of sign locations and numbers
of signs
270.14(b)(5) - General Inspection Schedule and Procedures
Description
264.15(b)(l) - Written schedule
264.15(b)(2) - Statement as to where, at facility, inspection
and schedule and inspection records will be kept
265.15(d)
264.15(b)(l) - Identification of equipment/processes to be
inspected
E
0
0
X
X
X
X
X
X
X
X
X
X
X
xisting
N
0
0
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
0
0
X
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners
N
0
0
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Continued)
CO
I
*~J
(Ti
Part 270 Part 264 Subject Requirement
264.15(b)(3) - Identification of types of problems each
equipment/prucess to be checked for
264.15(b)(4) - Frequency of inspections by equipment/process
264.15(c) - Schedule of remedial action
270.14(b)(5) and 264.15(a) and - Specific Inspection Requirements for Landfills,
270.21(d) 264.303 description of procedures for
- Inspection of liners/covers during and
immediately after installation
- Inspection weekly and after storms for
Operation of run-on/run-off controls
Liquids in leak detection system
Proper functioning of wind dispersal
controls
Leachate in and proper operation of
leachate collection/removal system
270 14(b)(6) Part 264 - Preparedness and Prevention Documentation
Subpart C
- Waiver(s) request and justification
264.32(a) - Description of internal communications/alarm
system(s)
264.34(a) - Documentation of personnel access to internal
communication/alarm system(s)
Existing
X
X
X
e
X
X
X
p
n
X
X
New, Type 1, 1 liner, g-w
X
X
X
X
X
X
X
X
n
X
X
New, Type 2, 2 liners
X
X
X
X
X
X
X
X
X
n
X
X
New, Type 3, 0 liners
X
X
X
X
X
X
n
X
X
Location in
Appl i cation
Comments
-------
LANDFILLS (Continued)
Page 4
CO
i.
Part 270 Part 264 Subject Requirement
264.32(b) - Description of external communications/alarm
system(s)
264.34(b) - Documentation of personnel access to external
communications/alam system(s)
264.32(c) - Description of fire control/extinguishing,
spill control, and decontamination equipment
264.32(d) - Documentation of adequate water volume and
pressure for above equipment
264.33 - Documentation of equipment testing/
maintenance schedule and procedures
264.35 - Documentation of adequate aisle space
264.37 (also - Documentation and descriptions of arrange-
264.52(c)) merits or attempts at arrangements with:
- Police department(s)
- Fire department(s)
- Hospitals
- Local emergency response teams
- State emergency response teams
- Emergency response contractors
Equipment suppliers
E
X
X
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
X
X
X
X
X
X
X
X
X
X
X
X
X
BW, Type 2, 2 liners
N
X
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application
i
Comments
-------
LANDFILLS (Continued)
Page 5
oo
-~j
oo
Part 270 Part 264 Subject Requirement
264.37(a)(2) - Documentation of agreements designating
primary emergency authority
270.14(b)(7) Part 264 - Contingency Plan Documentation
Subpart D
264.51 and - Criteria for implementation of contingency
264.52(a) plan
264.52(d) - Emergency Coordinators Identification
- Names
Addresses
- Home/Work Phones
264.55 - Documentation of Qualifications
- Documentation of Authority
- Description of notification procedure
264.52(e) - Emergency equipment list
- Documentation of equipment location
- Physical description of equipment
- Statement of equipment capabilities
264.52(f) - Evacuation Plan
- Criteria for implementation
E
X
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
X
X
sw, Type 1, 1 liner, g-w
N
X
X
X
X
X
X
X
X
X
X
X
X
sw, Type 2,21 iners
N
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Continued)
Page 6_
Part 270
Part 264
Subject Requirement
264.53
CO
vo
264.54
264.56
- Description of signal(s) to implement
- Description of primary and alternate routes
- Contingency Plan Copy Location
- Description of location of facility's
copy of plan
- Number of duplicate copies distributed
and their location
- Contingency Plan Amendment
- Identification of person responsible
and authorized to change/amend plan
- Description of procedure to change/amend
facility copy of plan
- Description of procedure to insure
update of all copies of plan
- Detailed Emergency Procedures
Procedure for facility personnel
notification
Procedure for state/local agency
notification
- Procedure for identification of character,
source, amount, and area! extent of
released materials
Existing
New, Type 1, 1 liner, g-w
New, Type 2. 2 liners
New. Type 3, 0 liners
Location in
Application
Comments
-------
Page
LANDFILLS (Continued)
CO
00
o
Part 270 Part 264 Subject Requirement
- Procedure for assessment of environment/
human health hazards
- Identification of On-Scene Coordinator
for geographic area
- Description of specific responses and
control procedures for
- Fire
- Explosion
- Spill
- Description of process shutdown and
monitoring procedures
- Description of cleanup procedures and
associated material treating, storing,
disposal procedures
- Description of emergency equipment
cleaning and refitting procedures
- Description of procedures to insure
incompatible waste segregation during
cleanup
[Note: There are no §270 requirements which parallel Part 264, Subpart E.
However, the applicant should be familiar with the following sections
of the regulations since the requirements in them will be enforceable
under any permit received.
Part 264, Subpart E, §264.70 through §264.77
Part 270.30, Subpart C
The applicant should be prepared to respond to inquiries by the
permit application reviewers regarding these requirements.]
E
X
X
X
X
X
X
X
X
X
listing
Ni
X
X
X
X
X
X
X
X
X
?w, Type 1, 1 liner, g-w
Ni
X
X
X
X
X
X
X
X
X
?w, Type 2, 2 liners
N<
X
X
X
X
X
X
X
X
X
?Wj Type 3^ 0 liners
Location in
Application
Comments
-------
Page 8
LANDFILLS (Continued)
Part 270
Part 264
Subject Requirement
270.14(b)(8)
CO
CO
270.14(b)(9)
264.17
270.14(b)(9) and
270.21(f) and
270.21(g)
264.17(b)
264.312
Preventive Procedures, Structures, and Equipment
Documentation, including description of
equipment/procedures to
- Prevent hazards during unloading operations
- Prevent water supply contamination
- Mitigate equipment failure and power outages
- Prevent undue personnel exposure to wastes
Prevention of Accidental Ignition or Reaction
Documentation
- Description of separation and protection of
ignitable, reactive, incompatible wastes
- Description of ignitable, reactive,
incompatible wastes handling procedures
- Description of number, location, and type
of warning/prohibition signs
Documentation that procedures are adequate
to prevent accidental ignitions or reactions
Specific Ignitable/Reactive Waste Requirements
for Landfills if I/R wastes disposed.
- Procedures that render wastes nonreactive
and nonignitable, or
- Procedures for preventing reactions, and
Existim
New
ing
, Type 1,
1 liner, g-w
lype
New, Type 2, 2 liners
New, Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Continued)
Page 9
Part 270 Part 264 Subject Requirement
- Procedures for protecting wastes
264.313 - Procedures for insuring that incompatible
wastes will not be disposed of in same
landfill cell
264.316(c) - Procedures for identifying contents and
through (e) insuring proper landfill ing of incoming
labpacks
270.14(b)(10) - Traffic Documentation, identification of:
- Waste movement routes
- Number of movements by type vehicle
- Quantity of waste moved per movement
per vehicle
- Traffic control signals and personnel
- Route surface composition and load
bearing capacity
270.14(b)(ll) - Facility Location Documentation
270.14(b)(ll)(i) - Political jurisdiction identified (new
and (ii) facilities only)
- Comparison to Appendix VI of Part 264
- Demonstration that faults with displacement
in Holocene time are more than 3,000 feet
from facility (western states)
E
0
X
X
X
X
X
X
X
X
X
xisting
N
0
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
0
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners
N
0
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Appl i cat ion
Comments
-------
Page 10
LANDFILLS (Continued)
00
00
co
Part 270 Part 264 Subject Requirement
264.18(a) - If Holocene-time faults are within 3,000 feet.
demonstration that no faults pass within
200 feet of unit sites (western states)
270.14(b)(ll), 264.18(b) - Documentation of facility location relative
(iii) through (v) to 100-year flood plain level or wave
action flooding
- If unit in flood plain, documentation
that facility can withstand the 100-year
flood without washout by:
- Analysis of hydrodynamic/hydrostatic forces
resulting at site from 100-year flood, and
- Presentation of operating units and flood
protection devices design and how they will
prevent washout, or
- Plan for removal of waste before washout
including,
- Timing of removal relative to flood levels
- Estimated time to remove al 1 waste
- Location to which waste will be moved
and proof of compliance with Parts 270
and 264 through 267 of this Chapter
- Detailed description of personnel,
equipment, and procedures for waste
removal sufficient to insure availability
in time for use
I
X
X
X
X
X
0
0
0
0
0
xisting
N
X
X
X
X
X
0
0
0
0
0
ew, Type 1, 1 liner, g-w
N
X
X
X
X
X
0
0
0
0
0
ew, Type 2, 2 liners
N
X
X
X
X
X
0
0
0
0
0
ew, Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Continued)
Page 11
oo
I
00
-F=.
Part 270 Part 264 Subject Requirement
- Analysis of potential for discharge
during waste movement
- A plan documenting how and on what time
schedule the facility will comply with
§264.18(b) if not in compliance
(existing facilities only)
270. 14(b)(12) 264.16 - Personnel Training Program Documentation
- Outline of introductory and continuing
personnel training programs
- Identification and qualifications of
program instructor
- Brief description of how training program
meets actual job tasks
- Description of procedures to insure all
appropriate personnel receive appropriate
training and receive annual training review
- Description of records to be kept, their
location, and procedures to insure they are
retained for proper length of time
270.14(b)(13) 264.112 - Closure Plan Documentation
- Description of partial and final closure
procedures
- Description of maximum unclosed portion
during facility life
E
0
X
X
X
X
X
X
X
X
listing
N
0
X
X
X
X
X
X
X
sw, Type 1, 1 liner, g-w
New, Type 2, 2 liners
0
X
X
X
X
X
X
X
N
0
X
X
X
X
X
X
X
ew. Type 3, 0 liners
Location in
Application
Comments
-------
Page 12_
LANDFILLS (Continued)
Part 270
Part 264
Subject Requirement
00
I
CO
270.14(b)(13)
264.114
254.113
254.113
270.14(b)(13) and
270.21(e)
264.112 and
264.310(a)
- Estimate of maximum waste inventory in
storage/treatment during facility life
- Equipment decontamination procedure
- Estimated year of closure
- Description of closure schedule including
- Total time to close
- Trackable intervening closure activities
- Location(s) and number of copies of
closure plan
- Identification of person responsible for
storage and updating of facility copy of
closure plan
- Procedure for updating all other copies
of closure plan '
Specific Closure Plan Requirements for
Landfills
Detailed plans and an engineering report
which describes the final cover components
in detail
- Documentation that the final cover will
- Provide long-term minimization of
migration of liquids through closed
landfill
Existing
New, Type 1, 1 liner, g-w
New, Type 2, 2 liners
New, Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Continued)
Page 13
oo
i
oo
CTl
Part 270 Part 264 Subject Requirement
- Function with minimum maintenance
Promote drainage and minimize
erosion/abrasion
- Settle/subside without losing integrity
- Be less permeable than bottom liners
or subsoils
270. 14(b)(13) 264.117 and - Post-Closure Plan Documentation
264. 118
Description of ground-water monitoring^
activities and frequencies
- Description of maintenance activities
and frequencies for:
- Final containment structures
- Facility monitoring equipment
- Location(s) and number of copies of
post-closure plan
- Identification and location (address and
phone number) of person responsible for
storage and updating of facility copy of
post-closure plan prior to closure
- Identification and location (address and
phone number) of person responsible for
storage and updating facility copy of post-
closure plan during post-closure period
E
X
X
X
X
X
X
X
X
X
X
X
xi sting
N
X
X
X
X
X
X
X
X
X
X
X
BW, Type 1, 1 liner, g-w
Ni
X
X
X
X
X
X
X
X
X
X
sw, Type 2, 2 liners
N
X
X
X
X
X
X
X
X
X
X
BW, Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Continued)
Page 14_
Part 270
Part 264
Subject Requirement
270.14(b)(13) and 264.118 and
270.21(e) 264.310(b)
CO
I
oo
—I
270.14(b)(14)
264.310(c)
264.120
270.14(b)(15)
264.142
Procedure for updating all other copies
of post-closure period
Specific Post-Closure Plan Requirements
for Landfills
- Procedures for maintenance and repair
of final cover
- Monitoring and maintenance procedures
for leak detection system
- Procedure for leachate collection/removal
system operation
- Procedures to maintain and monitor
ground water monitoring system
- Procedures for preventing final cap
erosion due to run-on and run-off
- Procedures for protection and maintenance
of benchmarks
- Procedures to be undertaken if liquid is
found in leak detection system
Documentation of Notice on Deed (existing
facilities only)
- Statement that land used to manage wastes
Statement of restricted use per §284.117(c)
Closure Cost Estimate
Existing
New, Type 1, 1 liner, g-w
New, Type 2, 2 liners
New, Type 3,01iners
Location in
Application
Comments
-------
LANDFILLS (Continued)
Page 15
OD
oo
oo
Part 270 Part 264 Subject Requirement
264.143 and - Documentation of a financial assurance
264.146 mechanism for closure that is one of the
following:
264.151(a) - Closure trust fund
264.151(b) - Surety bond guaranteeing payment
264.151(c) - Surety bond guaranteeing performance
264.151(d) - Closure letter of credit
264.151(e) - Closure insurance
264.15(f) - Financial test and corporate guarantee
and (h)
- Multiple financial mechanism for one facility
- Single financial mechanism for multiple
facilities
270.14(b)(16) 264.144 - Post-Closure Cost Estimate
264.145 and - Documentation of a financial assurance mechanism
264.146 for post-closure that is one of the following:
264.151(a) - Closure trust fund
264.151(6) - Surety bond guaranteeing payment
264.151(c) - Surety bond guaranteeing performance
264.151(d) - Post-closure letter of credit
t
X
0
0
0
0
0
0
0
0
X
X
0
0
0
0
xi sting
N
X
0
0
0
0
0
0
0
0
X
X
0
0
0
0
ew, Type 1, 1 liner, g-w
N
X
0
0
0
0
0
0
0
0
X
X
0
0
0
0
ew, Type 2, 2 liners
N
X
0
0
0
0
0
0
0
0
X
X
0
0
0
0
ew, Type 3, 0 liners
Location in
Application
Comments
-------
Page 16
LANDFILLS (Continued)
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Part 270 Part 264 Subject Requirement
264.151(e) - Post-closure insurance
264.151(f) - Financial test and corporate guarantee
and (h)
- Multiple financial mechanism for one facility
- Single financial mechanism for multiple
facilities
270.14(b)(17) 264.147 - Documentation of Insurance
- Request for variance from insurance
264.151(i) - Insurance for sudden/accidental occurrences
and (j)
- Insurance for nonsudden/accidental occurrences
264.151(g) - Financial test for liability coverage
270. 14(b)(18) 264.149 - Documentation of a State Required Financial1
Mechanism for Closure, Post-Closure, or
Liability including
- EPA I.D. number
- Facility name
- Facility address
• Amounts of liability coverage or funds
assured
264.150 - Documentation of State Assumed Responsibility
for Closure Post-Closure or Liability including
E
0
0
0
0
X
0
X
X
0
0
0
0
0
0
0
xisting
N
0
0
0
0
X
0
X
X
0
0
0
0
0
0
0
ew, Type 1^ 1 liner, g-w
N
0
0
0
0
X
0
X
X
0
0
0
0
0
0
0
ew, Type 2, 2 liners
N
0
0
0
0
X
0
X
X
0
0
0
0
0
0
0
ew, Type 3, 0 liners
Location in
Application Comments
-------
LANDFILLS (Continued)
Page 17
oo
i
Part 270 Part 264 Subject Requirement
- Letter from State describing State's
responsibilities
- Facility EPA I.D. number
- Facil ity name
- Facility address
Amounts of liability coverage or funds
assured
270. 14(b)(19) - Topographic map showing a distance of 1,000 feet
around facility at a scale of not more than
1 inch equals 200 feet that clearly shows
- Contours
Proper contour intervals
- Map scale and date
100-year flood plain area
- Surface waters and intermittent streams
Surrounding land uses
270.14(b)(19) - Wind rose
North orientation
- Legal boundaries of facility site
Access control
E
0
0
0
0
0
X
X
X
X
X
X
X
X
X
X
X
xisting^
N
0
0
0
0
0
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
0
0
0
0
0
X
X
X
X
X
X
X
X
X
X
X
ew, Type 2, 2 liners
N
0
0
0
0
0
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application
Comments
-------
Page 18
LANDFILLS (Continued)
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Part 270 Part 264 Subject Requirement
- Injection and withdrawal wells onsite
and off site
- Buildings and recreation areas
- Run-off control systems
- Access and internal roads
- Storm, sanitary, and process sewerage systems
- Loading and unloading areas
- Fire control facilities
- Barriers for drainage or flood control
- Location of past or present operational
units and equipment cleanup areas
270.17, 270.18,
270.20 and 270.21 Part B Specific Information Requirements
270.21 - Specific Requirements for Landfills
270.21(a) - List of hazardous wastes to be placed in
each landfill cell
270.21(b) 264.301(a) - Detailed plans and an engineering report
describing
270.21(b)(l) 264.301(a)(l) - Liner system construction (new only)
- Material of construction
E
X
X
X
X
X
X
X
X
X
X
e
e
xi sting
N
X
X
X
X
X
X
X
X
X
X
X
X
BW, Type 1, 1 liner, g-w
N
X
X
X
X
X
X
X
X
X
X
X
X
BW, Type 2, 2 liners
N
X
X
X
X
X
X
X
X
X
X
?w, Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Continued)
Page 19
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i
Part 270 Part 264 Subject Requirement
- Chemical properties
- Physical strength
- Thickness
- Foundation design/ integrity
- Area covered
- Liner system integrity against (new only)
- Internal and external pressure
gradients
- Contact with waste/leachate
- Climatic conditions
- Installation stresses
- Daily operational stresses
264. 301(a)(2) - Leachate collection and removal system
to maintain less than one foot of leachate
on liner including
- Materials of construction
- Chemical resistance to waste/leachate
- Sufficient strength to prevent collapse
270.21(b)(l) - Provisions to prevent clogging
Existing
e
e
e
e
e
e
e
e
e
e
e
e
e
e
e
e
N
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N(
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
*W_L Type 2, 2 liners
New, Type 3, 0 liners
Location in
Appl i cat ion
Comments
-------
Page 20
LANDFILLS (Continued)
CO
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Part 270 Part 264 Subject Requirement
264.301(b) - Liner system/leachate system exemption
including
- Nature and quantity of wastes
- Alternative design and operation
- Landfill location description
- Hydrogeologic setting
- Attenuate ve capacity of materials
between landfill and ground and
surface waters
270.21(b)(2) 264.301(c) - System for control of run-on from peak
discharge of a 25-year storm
270.21(b)(3) 264.301(d) - System for control of run-off water
volume from a 24-hour, 25-year storm
270.21(b)(4) 264.301(e) - Procedures to manage collection and
holding facilities associated with
run-on and run-off control systems
270.21(b)(5) 264.301(f) - Wind dispersal control procedures
270.21(c) 264.302(a) - Documentation for Part 264, Subpart F
exemption including
Landfill and liners above seasonal
high water table
- Two liners meeting requirements of
§264.301(a)(l)
t
X
X
X
X
xisting
N
X
X
X
X
ew, Type 1, 1 liner, g-w
N
X
X
X
X
X
X
X
ew, Type 2, 2 liners
N
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application Comments
-------
Page 21
LANDFILLS (Continued)
00
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-fa.
Part 270 Part 264 Subject Requirement
- Leak detection system between liners
- Leachate system meeting §264. 301(a)(2)
requirements
270.21(h) 264.314 - Documentation of procedures/equipment for
landfilling liquid wastes
270.21(i) 264.315 - Documentation of procedures/equipment for
landfilling containers
2
270.14(c) Part 264 Part B Protection of Ground-Water Information
Subpart F Requirements for Surface Impoundments, Waste
Piles, Land Treatment Units, and Landfills
270.14(c)(l) - Interim status period ground-water monitoring
data summary
270.14(c)(2) - Identification of uppermost and hydraulically
interconnected aquifers under facility including
- Water flow rate and direction
- Bases for identification
270.14(c)(3) and - Topographic map
270.14(b)(19)
Delineation of property boundary
264.95(b) - Delineation of waste management area
264.95(a) - Delineation of proposed point of compliance
- Ground-water monitoring well locations
E
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
X
X
X
X
ew, Type 2, 2 liners
N
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application
Comments
-------
Page 22
LANDFILLS (Continued)
CO
tn
Part 270 Part 264 Subject Requirement
- Location of aquifers
270.14(c)(4)(i) - Descriptions of existing contamination
through (ii)
- Delineation of plume extent
- Appendix VIII constituents concentrations
- Concentrations throughout plume
- Maximum concentration in plume
270. 14(c)(5) 264.97 - Detailed plans and an engineering report of
Ground-Water Monitoring Program
264.97(a) - Description of wells
- Number of wells
- Locations
- Depths
- Assurance of unaffected background
water measurement
- Assurance of compliance point
ground-water measurement
264.97(c) - Casing description
264.97(d) - Description of sampling/analysis procedures
- Sample collection methods
t
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
xisting
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 1, 1 liner, g-w
N
ew, Type 2, 2 liners
N
X
X
X
X
X
X
X
X
X
X
X
ew, Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Continued)
00
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CTi
Part 270 Part 264 Subject Requirement
- Sample preservation/shipment
- Analytical procedures
- Chain of custody control
264.97(e) - Documentation of proper/adequate
analytical procedures
264.97(f) - Procedure for determination of ground-
water elevation with each sample
270.14(c)(6) 264.91(a)(4) - Description of Detection Monitoring Program
and 264.98 including
270.14(c)(6)(i) 264.93 and - List of indicator parameters, waste
264.98(a) constituents, reaction products to be
monitored for, including
- Type, quantities, concentrations expected
in wastes
- Mobility, stability, persistence in
unsaturated zone
- Detectability in ground-water
270.14(c)(6)(ii) 264.98(a)(4) - Background ground-water concentration
and (iii) and values and coefficients of variation
26498(c)(l) established by one of the following :
264.98(c)(3) - Use of an appropriate ground-water
monitoring system, and
264.97(g)(l) - Quarterly sampling of upgradient wells
for one year, or
E
X
X
X
X
X
X
X
X
X
X
0
0
Kisting
N
X
X
X
X
X
X
X
X
X
X
0
0
BW, Type 1, 1 liner, g-w
N
X
BW, Type 2, 2 liners
N
X
X
X
X
X
X
X
X
X
X
0
0
ew, Type 3, 0 liners
Location in
Application
Comments
-------
Page 24
LANDFILLS (Continued)
00
I
Part 270 Part 264 Subject Requirement
264.97(g)(3) - Quarterly sampling of other wells for
one year, and
264.97(g)(4) - Data fro* a minimum of one sample/well
and minimum of four samples per
quarter, or
- Presentation of procedures to
calculate such values
270.14(c)(6)(ii) 264.98(b) - Description of an appropriate ground-water
•onitoring system to be installed at the
compliance point
270.14(c)(6)(iv) 264.98(d) - Procedures for collecting semi-annual
ground-water samples at the compliance
point during
- Active life
- Closure period
- Post-closure period
264.98(e) - Procedure for annual determination of
uppermost aquifer flow rate and direction
264.98(f) and - Documentation of sample collection and
264.97(d) and analysis procedures
(e)
264.98(g) - Procedure for determining a statistically
significant increase for any monitored
parameter or constituent by
t
0
0
0
X
X
X
X
X
X
X
X
xisting
N
0
0
0
X
X
X
X
X
X
X
X
ew, Type 1. 1 liner, g-w
N
ew, Type 2, 2 liners
N
0
0
0
X
X
X
X
X
X
X
X
ew. Type 3, 0 liners
Location in
Application
Comments
-------
Page 25
LANDFILLS (Continued)
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Part 270 Part 264 Subject Requirement
- Comparing compliance point data to
background value data using the
procedures in §264.97(h)(l) or (2), and
- Providing an estimate of the time
period after sampling completion
necessary to obtain results
264.98(h) - Procedure to be implemented if a
statistically significant increase in any
constituent or parameter is identified at
any compliance point monitoring well,
including
264.98(h)(l) - Written notification to Regional
Administrator
264.98(h)(2) - Sample collection and analysis methods
for all Appendix VIII constituents at
all monitoring wells
264.98(h)(3) - Method for establishing Appendix VIII
constituent background values
264.98(h)(4) - Preparation of an application for permit
modification to establish compliance
monitoring
270.14(c)(7) 264.91(a)(l) - Description of Compliance Monitoring Program5,
and 264.99 including
- List of wastes previously handled at facility
- Characterization of contaminated ground-water
E
X
X
X
X
X
X
X
0
0
0
xisting
N
X
X
X
X
X
X
X
0
ew, Type 1, 1 liner, g-w
N
ew. Type 2, 2 liners
N
X
X
X
X
X
X
X
0
0
0
ew, Type 3, 0 liners
Location in
Application
Comments
-------
Page 26
LANDFILLS (Continued)
00
I
Part 270 Part 264 Subject Requirement
- Hazardous constituents identified
- Hazardous constituents concentrations
264.99(b) - Description of compliance monitoring system
at the compliance point
- List of hazardous constituents to be
compliance monitored
264.96 - Proposed compliance period
264.99(d) - Procedure for collecting quarterly samples
at compliance point during compliance period
264.99(c)(3) - Procedures for establishing background
concentration values for constituents that
are based on one of the following:
- Use of an appropriate ground-water
monitoring system, and
264.97(g) - Data that is available prior to permit
issuance
- Data that accounts for measurement errors
in sampling and analysis
- Data that accounts for seasonal ground-
water quality fluctuations
Data from a minimum of one sample per
well and a minimum of four samples from
monitoring system, each time system
is sampled
E
0
0
0
0
0
0
0
0
0
0
0
0
xisting
N
0
0
0
0
0
0
0
0
0
ew. Type 1, 1 liner, g-w
N
ew, Type 2, 2 liners
N
0
0
0
0
0
0
0
0
0
0
0
ewj Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Continued)
Page 27
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o
Part 270 Part 264 Subject Requirement
270. 14(c)(7)(iv) 264.92 and - Proposed concentration limits for
264.99(c)(l), constituents with justification based on
(2)
- §264.94(a)(l) and §264.97(g)
- §264.94(a)(2)
- §264.94(b) and §264.99(c)(l)
264,99(e) - Procedure for annual determination of
uppermost aquifer flow rate and direction
264.99(f) - Procedures for annual testing of all
compliance point wells for Appendix VIII
constituents
264.99(g) - Documentation of all sampling and
analysis procedures
264.99(h) - Procedures for determining a statistically
significant increase for any monitored
constituent by
- Comparing compliance point data to the
concentration limit using the procedure
in §264.97(h)(2)
- Providing an estimate of the time period
after sampling completion necessary to
obtain results
264.99(i) - Procedures to be implemented if the ground-
water protection standard is exceeded at any
compliance point monitoring well, including
E
0
0
0
0
0
0
0
0
0
0
0
xi sting
N
0
0
0
0
0
0
0
0
0
0
0
ew, Type 1, 1 liner, g-w
N
ew, Type 2, 2 liners
N
0
0
0
0
0
0
0
0
0
0
0
ew, Type 3, 0 liners
Location in
Application
Comments
-------
Page 28
LANDFILLS (Continued)
00
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Part 270 Part 264 Subject Requirement
264.99(i)(l) - Written notification to Regional
Administrator
264.99(i)(2) - Preparation of an application for permit
modification to establish a corrective
action program, including
Details of program to comply with
ground-water protection standard
270.14(c)(7)(v) 264.99(i)(2) - Details of ground-water monitoring to
(ii) demonstrate effectiveness of program
270. 14(c)(8) 264.91(a)(2) - Description of Corrective Action Program
and 264.100 including
270. 14(c)(8)(i ) - Characterization of contaminated ground-water
264. 100(a)(l) - Identified hazardous constituents
- Concentrations of hazardous constituents
270.14(c)(8)(ii) 264. 100(a)(2) - Concentration limit for each hazardous
constituent
270. 14(c)(8)(iii) 264.100(b) - Detailed plan and an engineering report
describing the corrective actions to be taken
at the compliance point
264.100(c) - Time period necessary to implement
corrective action program
270. 14(c)(8)(iv) 264.100(d) - Description of ground-water monitoring
program that will be sufficient to assess
the adequacy of corrective action
E
0
0
0
0
0
0
0
0
0
a
0
0
Kisting
N
0
0
0
0
0
0
0
0
0
ew, Type 1, 1 liner, g-w
N
sw, Type 2, 2 liners
N
0
0
0
0
0
0
0
0
0
sw, Type 3, 0 liners
Location in
Application
Comments
-------
LANDFILLS (Concluded)
Part 270 Part 264 Subject Requirement
264.91(a)(3) - Description of the corrective action to be
and 264.100(e) taken for constituents in ground-water
between compliance point and downgradient
facility boundary
264.100(g) - Procedure and content for semi-annual ly
submitting written reports to the Regional
Administrator on program effectiveness
Co Part B Certification and Signatories
i— '
° 270.11(d) - Certification paragraph
270.11(a) - Appropriate signatory
E
0
0
X
X
dsting
New, lype 1, 1 liner, g-w
0
0
x
x
New, Type 2, 2 liners
x
x
New, lype 3, 0 liners
0
0
x
x
Location in
Application
Consents
-------
FOOTNOTES FOR LANDFILLS
State-specific. Contact State or Regional EPA representatives to
discuss requirements.
2
New, Type 3 units are not automatically exempt from ground-water
protection standards of Subpart F. Applicants are subject to
indicated requirements unless Section 264.90(b)(4) waiver has been
granted.
3
Applies to new facilities and existing facilities at which
contamination has not been detected.
4
Existing facilities must submit interim status ground-water monitoring
data including background data for certain parameters. If no data
are available, contact appropriate State or Regional EPA personnel.
Required of existing facilities where ground-water monitoring data
indicate the presence of hazardous constituents. New or existing
units without contamination may have a Compliance Monitoring Program
included in the permit on "stand-by" under some circumstances.
Applicable to existing facilities with indications of hazardous
constituents in the groundwater.
Applicability to existing facilities will be on a case-by-case
basis based on monitoring data indicating groundwater contamination.
New Type 1 and Type 3 units and existing units without contamination
may have Corrective Action Plans in the permit on "stand-by" under
some circumstances.
-. 103
-------
-------
SECTION 9.0
GROUND-WATER PROTECTION
Section 9.0 is divided into nine subsections as follows:
9.1 Introduction
9.2 Summary of Interim Status Monitoring Data
9.3 Identification of the Uppermost Aquifer and
Its Characteristics
9.4 Waste Management Area, Point of Compliance,
and Well Locations
9.5 Description of any Ground-Water Contamination
9.6 Detection Monitoring Program
9.7 Compliance Monitoring Program
9.8 Corrective Action Program
9.9 References
9.1 INTRODUCTION
This section provides detailed guidance to applicants on
the permit application information requirements of §270.14(c)
and the corresponding ground-water protection standards in
Part 264, Subpart F.
9.1.1 Applicability
The ground-water protection requirements are applicable to
"regulated units", as explained in Section 9.4. There are
limited exemptions from the standards. Any of the general
exclusions of §264.1 remove certain facilities from ground-
water protection as well. Other exemptions include:
- Double-lined surface impoundments, waste piles, and
landfills (§264.222, §264.252, and §264.302 respectively)
9-1
-------
Indoor waste piles with no liquids (§264 .250(c) ) .
Waste piles at which the waste is periodically removed
and the liner is inspected (§264.253).
9.1.2 Summary of the Regulations
The ground-water protection requirements establish a three-
stage program to detect, evaluate, and, if necessary, correct
ground-water contamination during the active life of the unit
plus a compliance period designated in the permit. The basic
elements of this program are described in Figure 9-1.
Unless there is known contamination, the first stage of
the ground-water monitoring and response program is a detection
monitoring program, which requires the permittee to install
a ground-water monitoring system (including both upgradient
and downgradient wells) to monitor the ground water for
hazardous constituents. The detection program must be capable
of indicating whether a leachate plume has brought hazardous
constituents to the point of compliance. This program is
described in Section 9.6.
If hazardous constituents are detected in ground water at
the point of compliance, a second stage - a compliance
monitoring program - is established. The compliance monitoring
program measures the concentration of all hazardous constituents
in the ground water. The results of compliance monitoring
are compared against a Ground-Water Protection Standard
established in the permit. Section 9.7 describes this program.
If the Ground-Water Protection Standard is violated, the
third stage - corrective action - must be implemented.
9-2
-------
Regional Administrator
may provide provision in
permit to immediately
implement Detection
Monitoring Program
if leak is detected
Site is exempted from
monitoring due to design
or operation
Application for
Part 264
hazardous waste
facility permit
Statistical analysis of
indicator parameters
reveals presence of
contamination at
Compliance Point
Site has
Interim Status
Continue operation
without groundwater
monitoring
Implement Detection
Monitoring Program or
correct the failure
Regional Administrator
requires implementation of
Detection Monitoring
Program and may include in
permit on a standby basis a
Compliance Monitoring
Program or Corrective
Action Program
Regional Administrator
requires implementation of
Compliance Monitoring or
Corrective Action Program
Figure 9-1. Basic elements of ground-water protection program.
-------
Corrective action must continue until the Standard is complied
with. Corrective action consists of the removal of the
contamination (by pumping or other means) or in-situ treatment
of the hazardous constituents. Section 9.8 describes this
program. Permit modifications are required when there is
a need to progress from one stage of the program to the
next, unless the permit includes the next stage on a contingent
basis.
9.1.3 Permit Application information Requirements
The permit application information requirements covering
the ground-water protection requirements are established in
§270.14(c) and are presented in Sections 9.2 through 9.8.
These application information requirements can be divided
into two basic groups and establish a convenient system for
applicants to assemble information and hold progress discussions
with the Regional Office, as outlined below.
The first group consists of §270 .14(c)(1) through §270.14
(c)(4). These requirements establish the nature of any impact
of the facility on the ground water, as well as the aquifer's
characteristics and the extent of the waste management area.
It will be useful for applicants to meet with the Regional
Office during and, in particular, after the compilation of the
information necessary to address these requirements. This
contact will assist the applicant in addressing the information
appropriate for one of the basic monitoring and response programs,
The second group includes the ground-water monitoring and
response programs (Detection Monitoring, Compliance Monitoring,
9-4
-------
Corrective Action). Responses to the first group of requirements
above and contact with the Regional Office will determine which
program is appropriate for the facility.
9.1.4 Facilities Without Interim Status Monitoring Data
Some facilities with Interim Status may not have ground-water
monitoring data. Some facilities may have no data due to
the self-granted waiver opportunity under §265.90(c). The
owners or operators of such facilities seeking permits under
Part 264 should contact the Regional Office at their earliest
opportunity. The Regional Office will evaluate the information
used in addressing the waiver under §265.90(c). If the Regional
Office finds that the waiver was inappropriate, it will direct
the applicant to obtain information which satisfies the informa-
tion requirements, in particular, §270.14(c).
If the waiver was appropriate, and if the applicant
also proposes an exemption from Subpart F under §264 .90(b)(4),
the applicant should fully discuss the necessary demonstrations
for this exemption with the Regional Office at the earliest
opportunity. This is necessary to ensure efficient processing
of the permit application.
When there are no monitoring data because the facility
is an Interim Status waste pile not subject to the Interim
Status ground-water monitoring requirements, the applicant
should meet with the Regional Office at the earliest opportunity.
The applicant should collect information in response to the
requirements in §270 .14(c)(2) through §270 .14(c)(4) presented
in Sections 9.3 through 9.5.
9-5
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9.2 SUMMARY OF INTERIM STATUS MONITORING DATA
9.2.1 The Federal Requirement
Section 270.14(c)(l) states the Part B application should
include:
A summary of the ground-water monitoring data obtained
during the interim status period under §§265.90-265.94,
where applicable.
Sections 265.90 through 265.94 are too long to reprint here.
The reader should consult the regulations for the complete
text. See 45 FR 33240.
9.2.2 Guidance to Achieve the Part 264 Standard
There is no explicit permitting standard in Part 264
which corresponds to the application information requirement.
Rather, §270.14(c)(1) requires the applicant to present the
data collected during Interim Status monitoring at an existing
facility as a means of determining how the facility should be
permitted under the Part 264 Subpart F three-stage system.
The preamble to Part 264 states (see 47 JFR 32294):
The nature of the program established in the initial
permit will depend on the information available at the
time of permitting. The key question is whether a
regulated unit has begun to leak. For new units this
is not an issue, but it may be somewhat problematic for
existing units. Since the owners or operators of most
existing units will be conducting monitoring in accord
with the Part 265 interim status requirements, there
should be a reliable base of information that can be
used to determine whether hazardous constituents have
entered the ground water.
An applicant also may seek to use data from interim
status monitoring results to justify an alternate concentration
limit for particular hazardous constituents (see 47 FR 32305),
9-6
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or to demonstrate a qualification for an exclusion from
Subpart F reponsibilities.
9.2.3 Guidance to Address the Application Information Requirement
This section is divided into guidance for facilities
that have Interim Status ground-water monitoring results, and
those that do not.
9.2.3.1 Facilities That Have Interim Status Ground-Water
Monitoring Data —
For facilities which have ground-water monitoring data,
the following information should be submitted. Detailed
guidance on how to gather and report these data is given in
Ground-Water Monitoring Guidance for Owners and Operators of
Interim Status Facilties (SW-963). A suggested attachment
to the permit application is Interim Status Ground-Water
Monitoring Data.
A copy of the map provided for in Part 270.14(b)(19),
on which the location and identification of each
monitoring well are indicated. Indicate which wells
are upgradient of the disposal area and which are
downgrad ient.
A description of the design and construction of each
monitoring well (e.g., depths of screen and casing,
depths at which water was encountered, filter pack
and sealing materials placement, dates of construction,
boring logs, etc.).
A copy of the facility's ground-water sampling and
analysis plan that includes the procedures used and
the protocol followed in:
— sample collection;
— sample preservation and shipment;
— analytical procedures; and
-- chain of custody control.
9-7
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A description of the statistical procedures used (if
applicable) in processing the data (as in the use of
a Student t-test and the level of significance used).
Copies of each quarterly (from first year) water analysis
results for each well, and copies of any subsequent
(annual or semi-annual) water analysis reports to
date. Sample data report forms are provided in
Figures 9-2 and 9-3. Include copies of any notifica-
tions of significant change in water analysis parameter
values made to the Regional Administrator (or State
Director) pursuant to S265.93.
- A description of observable trends in the above data,
showing the coefficient of variability, seasonality and
including a discussion of probable causes for changes.
9.2.3.2 Facilities That Do Not Have Interim Status Data —
New facilities will not have Interim Status ground-water
monitoring results. The applicant should proceed to the next
application information requirement (§270 .14(c)(2)) .
Some existing, Interim Status facilities may not have
Interim Status ground-water monitoring data due to a waiver
under §265.90(c). A permit applicant whose facility fits this
category should consult Section 9.1.4 for guidance.
Owners and operators of waste piles with Interim Status
are not subject to the Interim Status ground-water monitoring
standards. They are not, however, exempt from the ground-
water protection standards under Part 264, Subpart F (except
under the special cases described in §264.250(c), 264.252,
and 264.253). Persons submitting applications for waste piles
that have Interim Status, and do not have ground-water monitoring
data should consult Section 9.1 for guidance.
9-8
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EPA Identifier
RESULTS OF FIRST YEAR'S
GROUND-WATER MONITORING
Figure 9-2
9-9
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Instructions and Comments for
Recording of Ground-Water Monitoring Data
for the First Year
The forms are self-explanatory.
- This data recording format contains pages for the following
information:
General Information
Indicator Parameters at Upgradient Wells
Indicator Parameters at Downgradient Wells
Indicator Parameters at Downgradient Wells
(Optional Form)
Ground-Water Quality Parameters
Drinking Water Suitability Parameters
EPA Interim Primary Drinking Water Standards
- Put the EPA Identifier on each page.
If more than four wells are monitored or additional recording
forms are required, these forms may be duplicated and used.
These should be designated consecutively in small case letters
immediately after the page number (e.g., pages 5a, 5b, 5c,
etc.).
Designate upgradient and downgradient wells where specified.
Samples for the indicator parameters need not be replicated at
downgradient wells during the first year.
Use "<" to designate less than the detection limit and report
the detection limit. For example, "<5.0" means the observed
value is less than the detection limit of 5.0.
Indicate with a "*" any values for each of the Drinking Water
Suitability Parameters which exceed EPA Interim Primary
Drinking Water Standards (which are attached at end of packet).
Locations and identifications of the wells should be shown on
the site map required in §270.14(b)(19).
Attach any additional information, data or comments to this
recording form.
If you have any questions contact personnel at the EPA Regional
Office.
Figure 9-2 (con't)
9-10
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Figure 9-2 (con't)
EPA Identifier
Person to contact about data;
Telephone number:
Number of wells reported:
Sampling Dates (Month, Year)
Upgradient
Downgradient
Total
Name and address of laboratory performing analyses:
9-11
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Figure 9-2 (con't)
EPA Identifier
PARAMETERS USED AS INDICATORS OF GROUND-WATER CONTAMINATION
Upgradient Well
Well #
PARAMETER
(UNIT)
Quarter 1
Sample Date
Water Elev.
Quarter 2
Sample Date
Water Elev.
Quarter 3
Sample Date
Water Elev.
Quarter 4
Sample Date
Water Elev.
Background Mean
Background Variance
REPS
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
pH
(pH UNITS)
SPECIFIC
CONDUCTANCE
(umhos/cm)
TOC
(mg/1)
TOX
(ug/1)
9-12
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Figure 9-2 (con't)
EPA Identifier:
PARAMETERS USED AS INDICATORS OF GROUND-WATER CONTAMINATION
Downgradient Wells*
PARAMETER
(UNIT)
Well #
Sample Date
Water Elev.
Well #
Sample Date
Water Elev.
Well #
Sample Date
Water Elev.
Well #
Sample Date
Water Elev.
QUARTER
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
pH
(pH UNITS)
SPECIFIC
CONDUCTANCE
(umhos/cm)
TOC
(mg/1)
TOX
(US/1)
* Use optional form on next page if downgradient samples were replicated.
NOTE: Downgradient samples do not need to be replicated.
9-13
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Figure 9-2 (con't)
EPA Identifier:
PARAMETERS USED AS INDICATORS OF GROUND-WATER CONTAMINATION
Optional Form for Downgradient Wells*
Well #
PARAMETER
(UNIT)
Quarter 1
Sample Date
Water Elev.
Quarter 2
Sample Date
Water Elev.
Quarter 3
Sample Date
Water Elev.
Quarter 4
Sample Date
Water Elev.
REPS
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
t>H
(pH UNITS)
SPECIFIC
CONDUCTANCE
(umhos/cm)
TOG
(tng/1)
TOX
(up/1)
* Xerox this form and use one form per well if downgradient samples were
replicated.
9-14
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PARAMETERS ESTABLISHING GROUND-WATER QUALITY
PARAMETER
(UNIT)
Chloride (mg/1)
Iron (mg/1)
Manganese (mg/1)
Phenols (ug/1)
Sodium (mg/1)
Sulfate (mg/1)
Upgradient
WELL # Downgradient
01
02
03
04
Upgradient
WELL f Downgradient
01
02
03
04
COMMENTS
l_l
Jl
PARAMETER
(UNIT)
Chloride (mg/1)
Iron (mg/1)
Manganese (mg/1)
Phenols (ug/1)
Sodium (mg/1)
Sulfate (mg/1)
Upgradient
WELL # Downgradient
01
02
03
04
Upgradient
WELL # Downgradient
01
02
03
04
COMMENTS
Ouarter
-------
EPA Identifier
DRINKING WATER SUITABILITY PARAMETERS
PARAMETER (UNIT)
Arsenic (rag/1)
Barium (mg/1)
Cadmium (mg/1)
Chromium (mg/1)
Fluoride (mg/1)
Lead (mg/1)
Mercury (mg/1)
Nitrate, as N (mg/1)
Selenium (mg/1)
Silver (mg/1)
Endrin (ug/1)
Lindane (ug/1)
Methoxychlor (ug/1)
Toxaphene (ug/1)
2,4-D (ug/1)
2,4,5-TP Silvex
(ug/1)
Radium (pCi/1)
Gross Alpha (pCi/1)
Gross Beta (pCi/1)
Coliform Bacteria
(/100ml)
Upgradient Downgradient
Quarter 1
Well 1
Quarter 2
Quarter 3
Quarter 4
Upgradient Downgradient
Quarter 1
Well #
Quarter 2
Quarter 3 (Quarter 4
1
COMMENTS
vo
H
(D
10
I
O
o
*Exceeds EPA interim primary drinking water standards
-------
EPA Identifier
DRINKING WATER SUITABILITY PARAMETERS
PARAMETER (UNIT)
Arsenic (tng/1)
Barium (mg/1)
Cadmium (mg/1)
Chromium (mg/1)
Fluoride (mg/1)
Lead . (mgA)
Mercury (mg/1)
Nitrate, as N (mg/1)
Selenium (mg/1)
Silver (mg/1)
Endrin (ug/1)
Lindane (ug/1)
Methoxychlor (ug/1)
Toxaphene (ug/1)
2,4-D (ug/1)
2,4,5-TP Silvex
(ug/1)
Radium (pCi/1)
Gross Alpha (pCi/1)
Gross Beta (pCi/1)
Coliform Bacteria
(/100ml)
Upgradient Downgradient
Quarter 1
Well #
Quarter 2
Quarter 3
Quarter 4
Upgradient Downgradient
Quarter 1
Well #
Quarter 2 | Quarter 3
Quarter 4
COMMENTS
i-i
(D
I
N)
O
o
M
^J
*Exceeds EPA interim primary drinking water standards
-------
Figure 9-2 (con't)
PARAMETERS
EPA INTERIM PRIMARY DRINKING WATER STANDARDS
EPA IPDWS
MAX LEVEL
(mg/1)
Arsenic
Barium
Cadmium
Chromium, Total
Fluoride
Lead
Mercury
Nitrate (as N)
Selenium
Silver
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP Silvex
Radium
Gross Alpha
Gross Beta
Coliform Bacteria
0.05
1.0
0.01
0.05
1.4 - 2.4
0.05
0.002
10
0.01
0.05
0.0002
0.004
0.1
0.005
0.1
0.01
5pCi/l
15pCi/l
pCi/1
l/100ml
9-18
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EPA Identifier
RESULTS OF GROUND-WATER MONITORING
AFTER THE FIRST YEAR
Figure 9-3
9-19
-------
Figure 9-3 (con't)
Instructions for Recording
of
Ground-Water Monitoring Data
After the First Year
- The forms are self-explanatory.
- The data reporting form contains pages for the following
information:
General Information
Indicator Parameters
Parameters Establishing Ground-Water Quality
Put the EPA Identifier on each page.
If more than four wells are monitored, additional data forms
can be duplicated and used. These should be designated
consecutively in small case letters immediately after the
page number (e.g., pages 3a, 3b, 3c, etc.)
Designate upgradient and downgradient wells.
Indicator parameters, which need to be replicated (4 replica-
tions per sample per parameter) at each well, are to be sampled
at least semiannually and the results submitted by March 1 of
each year.
The ground-water quality parameters which need not be repli-
cated are to be sampled at least annually.
Use "<" to designate less than the detection limit and report
the detection limit. For example, "<5.0" means the observed
value is less than the detection limit of 5.0.
Locations and identifications of the wells should be shown on
the site map required in §270.14(b)(19).
Attach any additional information, data or comments to the
back of this reporting form.
If any questions contact personnel at the EPA Regional Office.
9-20
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Figure 9-3 (con't)
EPA Identifier
Person to contact about data:
Telephone number:
Number of wells reported:
Sampling Dates (Month, Year):
Upgradient
Downgradient
Total
Name and address of laboratory performing analyses:
9-21
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EPA Identifier
Sample Bate:
PARAMETERS USED AS INDICATORS OF GROUND-WATER CONTAMINATION
PARAMETER
(UNIT)
pH (pH units)
Specific
Conductance
(umhos/cm)
TOC (mg/1)
TOX (ug/1)
Upgradient
Well
Rep#l
#
Rep it 2
Rep// 3
Downgradient
Water Elev. (ft.)
Rep #4
Mean
Variance
Upgradient
Well
Rep#l
#
Downgradient
Water Elev. (ft.)
Rep #2
Rep#3
Rep #4
Mean
Variance
COMMENTS
I
ro
ro
PARAMETERS USED AS INDICATORS OF GROUNDWATER CONTAMINATION
PARAMETER
(UNIT)
pH (pH units)
Specific
Conductance
(umhos/cm)
TOC (mg/1)
TOX (ug/1)
Upgradient
Well #
Rep#l
Rep #2
Rep #3
Downgradient
Water Elev. (ft.)
Rep #4
Mean
Variance
Upgradient
Well I
Rep#l
Rep #2
Rep#3
Downgradient
Water Elev. (ft.)
Rep#4
Mean
Variance
COMMENTS
-------
EPA Identifier
Sampling Date:
PARAMETERS ESTABLISHING GROUND-WATER QUALITY
PARAMETER
(UNIT)
Chloride (mg/1)
Iron (mg/D
Manganese (mg/1)
Phenols (ug/1)
Sodium (mg/1)
Sulfate (mg/1)
UPGRADIENT
WELL #
WATER ELEV. (ft)
WELL #
WATER ELEV. (ft)
WELL #
WATER ELEV. (ft)
WELL #
WATER ELEV. (ft)
COMMENTS
ill
U)
PARAMETER
(UNIT)
Chloride (mg/1)
Iron (mg/1)
Manganese (mg/1)
Phenols (ug/1)
Sodium (mg/1)
Sulfate (mg/1)
DOWNGRADIENT
WELL #
WATER ELEV. (ft)
WELL #
WATER ELEV. (ft)
WELL #
WATER ELEV. (ft)
WELL #
WATER ELEV. (ft)
COMMENTS
-------
9.3 IDENTIFICATION OF UPPERMOST AQUIFER AND ITS CHARACTERISTICS
9.3.1 The Federal Requirement
Section 270.14(c)(2) requires:
Identification of the uppermost aquifer and aquifers
hydraulically interconnected beneath the facility
property, including ground-water flow direction and
the basis for such identification (i.e., the
information obtained from hydrogeologic investigations
of the facility area).
Definitions from §260.10 include:
'Aquifer1 means a geologic formation, group of formations
or part of a formation capable of yielding a significant
amount of ground water to wells or springs.
'Uppermost aquifer1 means the geologic formation nearest
the natural ground surface that is an aquifer, as well
as lower aquifers that are hydraulically interconnected
with this aquifer within the facility's property boundary,
9.3.2 Guidance to Achieve the Part 264 Standard
The rationale for this requirement is explained in the
preamble (47 FR 32305). EPA will be evaluating the adequacy of
the proposed ground-water monitoring system during the permitting
process. Accurate information about the aquifer(s) beneath the
facility is essential for this evaluation. The information
presented for this requirement will serve as a basis for locating
arid constructing monitoring wells. It is also needed for deter-
mining the frequency of sampling of these wells. Applicants who
propose alternative concentration limits under §264.99 will need
to thoroughly explain the hydrogeologic system in their applica-
tions. Finally, if corrective action measures are required, a
complete and thorough description of the hydrogeologic system
and flow rates are essential for designing an effective and
efficient corrective action plan.
9-24
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As noted in the preamble discussion on the definition of
aquifer (47 FR 32289), determining what quantity is a "significant
amount" is site specific and variable.
The definition of uppermost aquifer (normally the first
aquifer affected by facility leakage) includes any lower
aquifers that are hydraulically interconnected (see 47 FR 32290).
In some locations, aquifers at different levels beneath a facility
are linked, thereby enabling any contaminants that enter the
topmost water body to infiltrate to a lower aquifer.
9 .3 .3 Guidance on Addressing the Application Information
Requirement
To address this standard, the applicant should provide a
specific identification of the uppermost aquifer beneath the
facility, and a determination of flow rate and direction in that
uppermost aquifer. Additionally, the applicant should provide
the information that was used to make the identification and
determination. This should be a report written by a qualified
hydrogeologist on the hydrogeologic characteristics of the
facility property supported by at least the drilling logs of the
monitoring wells and the available professional literature.
9.3.3.1 Uppermost aquifer —
The identification of the uppermost aquifer may or may not be
straightforward. The most difficult aspect of the identification
is determining the degree of hydraulic interconnection of water-
bearing units. It can be argued that any sequence of aquifers is
interconnected hydraulically to some degree. For most sites,
9-25
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the degree of interconnection will be either high or low
depending on the presence of an aquitard.
The American Geological Institute defines "aquitard" as "a
confining bed that does not prevent the flow of water to or from
an adjacent aquifer" but "does not readily yield water to a well
or spring". An aquitard "may serve as a storage unit for ground
water". A formation is usually considered an aquitard if its
hydraulic conductivity is 10~6 cm per sec or less.
The Agency assumes that any of the following is evidence
of a high degree of multiple aquifer interconnection:
- The aquitard pinches out within the property boundary,
- The aquitard is significantly fractured or karst,
Numerous wells that are inadequately sealed penetrate
the aquitard within the facility property boundary, or
- Pumping or injection tests show a measurable response
in the aquifer on the other side of the aquitard.
Conditions for which a lack of interconnection can usually
be assumed are:
- The aquitard is laterally continuous and easily correlat-
able between borings/wells, the contrast in hydraulic
conductivity between the aquifer and the aquitard is at
least 100 to 1, and the aquitard is not karst or signs
of fracturing are minimal (the aquitard's hydraulic con-
ductivity being no greater than 10-6 cm per sec,
- Measurably different piezometric levels in different
water bearing zones above and below aquitard,
- Quantitatively minor leakage from aquitard during pump
test or minor intake during inflow (packer) test, or
Lack of measurable response in lower water bearing unit
during pump test within overlying water bearing unit.
9-26
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For aquitards that do not meet one of the above classifications,
the applicant should determine whether contaminated fluids could
possibly migrate through the aquitard during the life (i.e., the
active period, the closure period, and the post-closure care
period) of the facility. This assessment should be based on
travel time calculations assuming the conservative factors
required for any waiver demonstration under §264.90(b)(4).
9.3.3.2 Aquifer —
An aquifer is defined as "a geologic formation, group of
formations, or part of a formation capable of yielding a
significant amount of water to wells and springs". Two key
words are "capable" and "significant". A hydrogeologic unit
can be an aquifer whether or not it is currently being used
as a source of water supply, as long as the unit is capable
of yielding a significant amount. The word "significant" is
relative in this context. In areas underlain by high yield
aquifers, low yield units may not be locally considered as
aquifers. In other areas, similar low yield units may be used
extensively for domestic water supplies. When the applicant is
uncertain whether a particular unit should be considered to
be an aquifer, he should discuss the matter with the Regional
Office after seeking information on the matter from State or
local water resource agencies.
The point of measurement of significant amount is not
restricted to wells. Ground-water discharge at springs must
also be considered. Springs occur as isolated features, or
9-27
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more typically, along the length of surface water bodies such
as streams and ponds. These features are, in fact, typical
ground-water discharge zones. Consequently, the Agency
considers a hydrogeologic unit to be an aquifer for monitoring
purposes if the lateral flow of ground water discharges
significant amounts of water to a surface water body. Further
guidance on identifying aquifers is presented in the Permit
Writer's Guidance Manual for Subpart F, Ground-Water Protection
(Reference 1).
9.3.3.3 Flow rate and direction —
The ground water flow rate and direction in the uppermost
aquifer can be determined from ground-water head data (or pressures
in some cases), and hydraulic conductivity data, or by direct,
in-situ measurement (e.g., tracer tests). This information
must be obtained by hydrogeologic studies conducted at (and in
some cases, nearby) the facility. The flow rate and direction
have three possible components; two components are horizontal,
and one is vertical. Flow rate and direction can vary significantly
over the area of a facility and with time.
In order to determine flow rate and direction, the hydrogeologi
study should include water level monitoring in wells and piezometers
The monitoring of water levels should normally be conducted over
several seasons in order to characterize transient changes in
flow rates and directions. The amount of water level monitoring
and hydrologic testing required at a facility will increase with
the complexity and variability of the flow system. Further
9-28
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guidance on the determination of flow rate and direction is
provided in the Reference 1.
EPA strongly recommends the use of nested piezometers for
determination of the vertical components of the gradient.
Such piezometer clusters will provide the hydrogeologist with
data to distinguish between recharge and discharge conditions.
The information is necessary to properly locate the open
interval of monitoring wells.
A requirement of both the detection monitoring and
compliance monitoring programs is an annual redetermination
of flow rate and direction (see §§264.98(c) and 264.99(e)).
EPA believes that it may often be possible for a permittee
to compare ground-water level data against the levels present
when the original determination was made; if these levels
are the same, it is most likely that the flow rate and
direction has not changed. EPA is considering an amendment
to Subpart F that will clarify this option.
9.3.3.4 Hydrogeologic report —
In addressing the application information requirement, the
applicant should include supporting information used to identify
the uppermost aquifer and to determine flow rate and direction.
Supporting information should be in the form of a report of the
hydrogeologic field investigation conducted at the site with
field data appended to the report. The report should include a
description of the regional geologic and hydrogeologic setting.
The report serves as a basis for addressing many concerns.
It provides information needed to implement the monitoring
9-29
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system design standards under §264.97, including water intake
interval and well construction, sampling frequency and definition
of upgradient and downgradient. Applicants proposing alternate
concentration limits under §264.98 will need to show the
patterns of ground-water flow and use in the vicinity of the
facility, as well as attenuative properties of the aquifer.
Applicants preparing corrective action plans must have a thorough
understanding of the hydrogeologic system around the facility,
in order to develop a monitoring plan and design the correction
plan. Specific application information requirements for these
concerns are addressed in later sections of this manual. The
report should be prepared by a qualified hydrogeologist and
should include:
A description of the regional geologic and hydro-
geologic characteristics in the vicinity of the
facility. This information is generally obtainable
from published or open-file documents from Federal,
State or local agencies, and from the professional
literature.
- An analysis of any topographic or geomorphic features
that might influence the ground-water flow system.
(Note that stereoscopic analysis of aerial photographs
can aid in this analysis.)
A classification and description of the hydrogeologic
properties (hydraulic conductivity, porosity, texture,
thickness, etc.) of all of the hydrogeologic units found
at the site (i.e., the aquifers and any intervening
saturated and unsaturated units). This classification
should be as consistent as possible with the classifica-
tions used in the regional review.
- Using the §270.14(b)(19) topographic map as a base,
isopach and structural contour maps and/or geologic
sections showing the extent of the hydrologic units
contained in the uppermost aquifer, and any intervening
aquitards or other soil units within the facility
property boundary.
9-30
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A description of water level or fluid pressure
monitoring, including: (a) water level contour maps or
vertical sections, (b) well or piezometer hydrographs,
and (c) an interpretation of the flow system, including
the vertical and horizontal components of flow.
A description of the field methods used in the study,
and a summary of which data were collected by each
method.
Each of the above elements is discussed in more detail
in the Permit Writer's Guidance Manual for Subpart F, Ground-
Water Protection (Reference 1). EPA has also established
standard methods for determining hydraulic conductivity in
Test Methods for Hydraulic Conductivity, Leachate Conductivity,
and Intrinsic Permeability (see Section 3.0 of this manual).
These test methods should be reviewed before conducting any
field investigations.
9.4 WASTE MANAGEMENT AREA, POINT OF COMPLIANCE, AND WELL
LOCATIONS
9.4.1 The Federal Requirement
Section 270.14(b)(19) identifies the type of topographic
map, and map information to be submitted in the permit applica-
tion.
Section 270.14(c)(3) states:
On the topographic map required under para-
graph (b)(19) of this section, a delineation
of the waste management area, the property
boundary, the proposed "point of compliance"
as defined under §264.97 and, to the extent
possible, the information required in paragraph
(c)(2) of this section.
Section 270.14(c)(2) requires the identification of the
uppermost aquifer (see Section 9.3).
Section 264.95(b) describes "waste management area" as:
9-31
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(b) The waste management area is the limit
projected in the horizontal plane of the area
on which waste will be placed during the active
life of a regulated unit.
(1) The waste management area includes
horizontal space taken up by any liner, dike, or
other barrier designed to contain waste in a
regulated unit.
(2) If the facility contains more than one
regulated unit, the waste management area is
described by an imaginary line circumscribing
the several regulated units.
Section 264.95(a) describes "point of compliance" as:
(a) The Regional Administrator will specify in the
facility permit the point of compliance at which the
ground-water protection standard of §264.92 applies and
at which monitoring must be conducted. The point of
compliance is a vertical surface located at the
hydraulically downgradient limit of the waste management
area that extends down into the uppermost aquifer
underlying the regulated units.
- Section 264.97 establishes general ground-water
monitoring requirements. It is too long to reprint
here. The reader should consult the regulations for
the complete
text.
9.4.2 Guidance to Achieve the Fart 264 Standard
The applicant should read the preamble to Part 264, Subpart F
for a complete discussion of the nature of the waste management
area and point of compliance (see 47 FIR 3228832299). Some
important considerations are presented below.
9.4.2.1 Waste Management Area —
The "waste management area" is described by the collection
of "regulated units" at the facility. A regulated unit is any
"waste management unit" that has or will receive hazardous
wastes after January 26, 1983 (the effective date of the Part 264
9-32
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Land Disposal Permitting Standards). Section 3.0 of this
manual provides additional discussion on the definition of
regulated units.
A waste management unit is generally synonymous with a
surface impoundment, waste pile, land treatment unit, or landfill
cell. It is a contiguous area of land on or in which waste is
placed. Landfills may present an exception to this general
rule. A landfill can be designed as a collection of separately
lined trenches with each individual trench considered to be a
separate waste management unit. A waste management unit can
be a regulated unit even though it contains predominantly non-
hazardous waste or hazardous waste which was disposed prior
to January 26, 1983.
The waste management area is made up of one or more waste
management units that have received hazardous wastes after
January 26, 1983 (i.e., regulated units). The waste management
area is the area on which waste will be placed during the active
life of the regulated unit. It includes any horizontal space
taken up by barriers designed to contain waste, such as dikes.
Where there are more than one regulated units, the waste manage-
ment area is described by an imaginary line circumscribing
these regulated units.
9.4.2.2 Point of Compliance —
The "point of compliance" is a vertical surface located at
the hydraulically downgradient limit of the waste management
area, extending from the Earth's surface down into the uppermost
9-33
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aquifer. The point of compliance is, in fact, a set of points
(or surface). It is the location along which the Ground Water
Protection Standard (see §264.92) must be met, and at which
detection monitoring wells are located. The Regional Adminis-
trator will specify the location of the point of compliance in
the permit after evaluation of the description of the waste
management area and the nature of the hydrogeology of the site.
9.4.2.3 Monitoring Well Locations —
The ground-water monitoring system required by §264.97 is
discussed in Section 9.6 for Detection Monitoring Programs and
in Section 9.7 for Compliance Monitoring Programs. These Sections
describe in detail how monitoring well locations should be deter-
mined. In general, monitoring wells must be located along the
point of compliance. Their open intervals must be within the
uppermost aquifer, as determined by site investigations and
design evaluations.
9.4.3 Guidance to Address the Application Information Requirement
9.4.3.1 Waste Management Area —
The applicant should define the waste management area on the
topographic map prepared for §270.14(b)(19). The waste management
area is easily described for facilities that will contain only one
regulated unit. It is simply the area occupied by this unit and
any barriers used to contain the waste. When several adjacent
regulated units are present, the waste management area is described
by a line circumscribing, or encompassing, these units (See Figure
3-1). If the permittee of a facility will add new units adjacent
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to the existing units, the existing waste management area will
expand to encompass the new units. Similarly the compliance point
will move if the new units are downgradient from the existing
units. This situation requires new downgradient monitoring wells
(See Figure 9-4). Applicants should not propose a point of
compliance that is geographically remote from the waste handling
area. Rather the downgradient monitoring wells should be
closely associated with the regulated units.
If new units at an expanded facility are remote from existing
units, an expanded waste management area and compliance point are
required to encompass the remote units. However, new downgradient
(and possible new upgradient) wells will probably be necessary
even though the entire area was included in the original permit
because this area is not adjacent to existing units (see Figure 9-5).
Figure 9-6 illustrates a recommended approach for new facilities,
It involves initial operations at the compliance point. Later
expansion proceeds upgradient. Thus, only one set of monitoring
wells is needed. This approach may be applicable to some existing
facilties. This approach may reduce costs for the permittee
since only one set of monitoring wells is required. If this approach
is not used, the concept of an expanding waste management area and
moving compliance point and downgradient monitoring wells shown in
Figure 9-4 applies.
9.4.3.2 Point of Compliance —
The permit applicant should propose the point of compliance
on the map showing the waste management area. The applicant
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PHASE I WASTE
MGT. AREA
COMPLIANCE POINT,
AND DOWNGRADIENT
MONITORING WELLS
I
OO
CT>
UPGRADIENT MONITORING WELLS (PHASES I and II)
PHASE II LIMIT OF WASTE MANAGEMENT AREA
PERMIT APPLIES TO AREA \
WITHIN FACILITY BOUNDARY \
\
PHASE II
LANDFILL
CELL +3
PHASE II
SURFACE
IMPOUNDMENT
+ 2
EQUIP. SHED
PHASE II COMPLIANCE
POINT AND RELATED
DOWNGRADIENT MONITORING
WELLS
AKinc / y
-------
UPGRADIENT MONITORING WELLS (PHASES I and II)
PHASE II LIMIT OF WASTE MANAGEMENT AREA
PERMIT APPLIES TO AREA
WITHIN FACILITY BOUNDARY
PHASE I WASTE
COMPLIANCE POINT.
AND OOWNQRAOIENT
MONITORING WELLS
PHASE I
LANDFILL
CELL *2
PHASE II
SURFACE
IMPOUNDMENT
PHASE II
LANDFILL
CELL *3
PHASE II
SURFACE
IMPOUNDMENT
+ 2
EQUIP. SHED
PHASE II COMPLIANCE
POINT AND RELATED
DOWNGRADIENT MONITORING
WELLS
ROAD
PHASE III
SURFACE
IMPOUNDMENT
Figure 9-5.
WASTE MANAGEMENT AREA. COMPLIANCE POINT.
AND MONITORING WELLS FOR PHASE III
BOTH AREAS INCLUDED
IN INITIAL PERMIT
Concept of Separate Waste Management
Compliance Points, and Monitoring Wells for
Remote Areas Within Same Permit Boundary.
9-37
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1
DIRECTION OF
GROUND-WATER FLOW
i
PHASE III
LANDFILL CELL
LANDFILL CELL
LANDFILL CELL
PHASE II
SURFACE
IMPOUNDMENT
PHASE I
SURFACE
IMPOUNDMENT
MONITORING WELLS AND COMPLIANCE POINT
FOR ALL PHASES
BOUNDARY
OF
PERMITTED
FACILITY
Figure 9-6. Recommended Operational Approach - First
Phase Operations at Compliance Point.
9-33
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must support this proposal by showing that this surface is
hydraulically downgradient of the waste management area. Guidance
on this topic is presented in Section 9.3 of this manual.
The point of compliance depth should extend to the base of
the lowest relatively permeable unit of the uppermost aquifer.
Additional guidance on determining the location and depth of the
point of compliance is provided in the Permit Writer's Guidance
Manual for Subpart F, Ground-Water Protection (Reference 1).
9.4.3.3 Monitoring Well Locations —
The applicant should indicate the locations of the proposed
monitoring wells on the map developed under §270,14(b)(19).
Guidance for establishing these locations is presented in Sections
9.6 and 9.7 of this manual.
9.4.3.4 Hydrogeologic Information —
The permit applicant should show, to the extent possible,
the information required by §270.14(c)(2) on the base map noted
below. Section 9.3 of this manual provides guidance on obtaining
this information. As an example, a contour map of the ground-
water table should be presented on the map prepared for
S270.14(b)(19) (use additional copies of this base map if all
the information cannot be presented on one sheet). This map
may also present surficial geologic and soils information.
9.5 DESCRIPTION OF ANY GROUND-WATER CONTAMINATION
9.5.1 The Federal Requirement
Section 270.14(c)(4) states:
A description of any plume of contamination that has
entered the ground water from a regulated unit at the
9-39
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time that the application is submitted that:
(i) Delineates the extent of the plume on
the topographic map required under paragraph
(a)(19) of this section;
(ii) Identifies the concentration of each
Appendix VIII of Part 261 of this chapter
constituent throughout the plume or identifies
the maximum concentrations of each Appendix
VIII constituent in the plume.
Definitions from §260.10 include:
'Constituent1 or "hazardous waste constituent1
means a constituent which caused the Administrator
to list the hazardous waste in Part 261, Subpart D,
of this chapter, or a constituent listed in Table 1
of §261.24 of this chapter.
'Ground water' means water below the land surface
in a zone of saturation.
The reader should consult the regulations for a list
of the constituents contained in Appendix VIII of Part 261.
9.5.2 Guidance to Achieve the Part 264 Standard
Section 270.14(c)(4) requires the applicant to describe the
nature and extent of any ground-water contamination attributable
to a regulated unit. The reader should review Section 9.4 for
description of a regulated unit. This standard does not apply to
new facilities. This requirement also applies to owners and
operators required to conduct corrective actions (see §264.100(e) ).
As described at 47 FR 32292, there may be situations where
it will be difficult to tell if a plume originates at a regulated
unit, or if it originates at an adjacent, upgradient waste manage-
ment unit which may or may not also be a regulated unit, or from
another source. The regulations provide that any waste constituent
that migrates beyond the compliance point is presumed to come
9-40
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from a regulated unit. The permit applicant may overcome
this presumption if he demonstrates, with monitoring data
or other information, that the constituents are coming from
another source, such as an adjacent, upgradient waste management
unit which is not also a regulated unit.
The Interim Status ground-water monitoring requirements
(§265.90-265.94) do not require the permittee to monitor for the
constituents listed in Appendix VIII of Part 261. Rather, general
parameters describing ground-water quality and indicators of
contamination are monitored. Should such monitoring and attendant
data comparison indicate a significant difference in downgradient
water quality compared with background, the permittee is required
to conduct a general assessment of the extent of contamination.
This assessment, in most cases, would not be likely to include
analysis of all of the Appendix VIII constituents. In addition,
the triggering mechanism for this assessment is the use of the
Student's t-test at the 0.01 level of significance. The statis-
tical procedure used for 264 Supbart F is a modification of the
Student's t-test at the 0.05 level of significance. This latter
procedure is more likely to indicate the presence of a constituent,
9.5.3 Guidance to Address tne Application Information Requirement
The relationship of this standard to the Interim Status
ground-water monitoring program may be confusing to many
applicants. The standard can be applied to cases where no Interim
Status ground-water monitoring data are available, and to cases
where Interim Status monitoring shows the presence of hazardous
9-41
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constituents downgradient from the regulated units. It is also
particularly relevant to facilities at which corrective action
measures are necessary; the information will form the basis for
the corrective action plan.
Applicants should address this requirement in light of the
following points:
If the Interim Status monitoring indicates a signifi-
cant increase (or decrease in the case of pH) in any
parameter downgradient from the regulated unit(s),
or if it indicates the presence of any hazardous
constituent at the compliance point above background
concentration, the applicant should address the
instruction requirements of §270 .14(c)(4).
EPA will review and evaluate the Interim Status ground-
water monitoring program conducted by the applicant at
the facility, using, in part, the information assembled
under Section 9.2. EPA will evaluate the effectiveness
of the monitoring well network design in determining
the presence of any plume associated with a regulated
unit. EPA will also evaluate the effectiveness of the
ground-water sampling and analysis program to detect
and identify the presence of hazardous constituents,
regardless of whether a statistically significant
increase in the monitoring parameters (or significant
change in the case of pH) has been identified. EPA
will also evaluate the results of any assessment plan
conducted under the Interim Status rules.
If these evaluations indicate, to the satisfaction of
the Regional Administrator, that there is no plume of
contamination in the ground water from a regulated unit,
the applicant will not be expected to address §270,14(c)(4)
any further. Instead, the permit application will be
processed under the Part 264 Detection Monitoring
Program standards (see Section 9.6).
If these evaluations indicate to the Regional Administrator
that the Interim Status ground-water monitoring program
cannot adequately determine whether a plume of con-
tamination has entered the ground water from a regulated
unit, he will direct the applicant to implement a ground-
water monitoring program which satisfies §264.97, §264.98,
and §270,14(c)(4) at once. Alternately, the Regional
Office may issue a compliance order under the Interim
9-42
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Status program that directs the applicant to collect
information describing the nature of any ground-water
contamination within the site. The applicant must
then obtain data on ground-water quality responsive to
§270.14(c)(4) for use in determining how the facility
should be permitted under the Part 264, Subpart F system.
Applicants should discuss their Interim Status ground-water
monitoring program with the Regional Office at their earliest
opportunity prior to submitting a Part 264 permit application.
When it is necessary for the applicant to fully address
§270.14(c)(4), as outlined above, the following information
will be useful:
- Techniques useful for describing the extent of a plume
are described in Section 3 of Ground-Water Monitoring
Guidance for Owners and Operators of Interim Status
Facilities (U.S.EPA; SW-963; October, 1982). Indirect
methods, such as earth resistivity, may be useful in
many cases. The applicant should delineate the extent
of the plume on the map prepared under §270.14(b)(19).
The applicant should also attempt to describe the
vertical distribution of the plume through the use of
hydrogeologic cross-sections.
- Except where constituent concentrations are very high
(in the ten ppm or more range), it should be sufficient
to indicate the peak concentrations of each constituent,
rather than assembling isoconcentration contour maps
for each constituent.
9.6 DETECTION MONITORING PROGRAM
The application information requirements in §270.14(c)(5)
and §270.14(c)(6) are closely related, and are treated together
in this section.
9.6.1 The Federal Requirement
Section 270.14(c)(5) states:
Detailed plans and an engineering report describing
the proposed ground-water monitoring program to be
implemented to meet the requirements of §264.97
9-43
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Section 270.14(c)(6) indicates that:
If the presence of hazardous constituents has not been
detected in the ground water at the time of permit
application, the owner or operator must submit sufficient
information, supporting data, and analyses to establish
a detection monitoring program which meets the require-
ments of §264.98. This submission must address the
following items as specified under §264.98:
(i) A proposed list of indicator parameters, waste
constituents, or reaction products that can provide a
reliable indication of the presence of hazardous
constituents in the ground water;
(ii) A proposed ground-water monitoring system;
(iii) Background values for each proposed monitoring
parameter or constituent, or procedures to calculate
such values; and
(iv) A description of proposed sampling, analysis
and statistical comparison procedures to be utilized in
evaluating ground-water monitoring data."
Section 264.97 and §264.98 are too long to reprint here.
The reader should consult the regulations at 47 FR 32352 and
32353, respectively.
9.6.2 Guidance to Achieve the Part 264 Standard
The Preamble discussions of the detection monitoring program
under §264.98, and the general ground-water monitoring require-
ments under §264.97 are found at 47 FR 32304 and 32300,
respectively. A detection monitoring program will be specified
by the Regional Administrator in the case of new sites and for
Interim Status sites when the presence of hazardous constituents
has not been detected in the ground water. Evidence of the
presence of hazardous constituents may be based on previous
monitoring under the Interim Status Standards, on the results of
9-44
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a site investigation undertaken outside the scope of Interim
Status monitoring, or on data collection in response to permit
application preparation under Part 264.
The objective of a detection monitoring program is to provide
the earliest possible indication that regulated units are leaking
into the uppermost aquifer. The permittee must conduct monitoring
semi-annually at the point of compliance specified under 15264.95.
This monitoring involves a regular program of sampling and
analysis for parameters which provide an indication of the
presence of hazardous constituents. These results are compared
to background values of these parameters using a specific statis-
tical procedure. When this process indicates a statistically
significant decrease in downgradient ground-water quality (which
is reported to the Regional Administrator), the permittee may
attempt to show that the decrease is due to a deterioration
in water quality unattributable to the facility or due to errors
in sampling analysis or evaluation. Otherwise, the change is
assumed to be the result of leakage from the regulated units.
In such an event, the permittee must notify the Regional
Administrator, and submit an application for a permit modification.
This permit modification application must include specific
information on the nature of the change in ground-water quality,
and must address the information requirements for a compliance
monitoring program permit and an engineering feasibility plan
for a corrective action program (see §264.98(h)(4) and (5)).
In issuing a permit modification, the Regional Administrator
9-45
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will specify a ground-water protection standard (see §264.92),
and may specify either a compliance monitoring program or a
corrective action program, or some combination of the two.
The requirements of a detection monitoring program are illustrated
in Figure 9-7.
9.6.3 Guidance to Address the Application Information Requirement
To address these information requirements, the applicant
should provide as detailed a presentation of the proposed
monitoring program as possible. The Regional Administrator
must specify explicit requirements on the design of the monitoring
system, parameter analyses, data comparison methods, and response
requirements in the permit.
It is suggested that the applicant develop and present the
proposed Detection Monitoring Program as a group of related, but
distinct attachments to the application. These attachments should
be identified one from the other, but all should be identified as
part of the Detection Monitoring Program. For example, the attach-
ments might be named DMP-1, DMP-2, or DET-1, DET-2, etc. Suggested
attachments include the following:
- Map of Detection Monitoring Wells
- Plans and Specifications for Detection Monitoring Wells
- Sampling Techniques Including Flow Rate and Direction
Determinat ions
- Sample Preservation and Shipping Procedures
- Parameters to be Monitered and Sample Analysis Protocols
- Sample Chain of Custody Procedures
- Procedures to Establish Background Values for Ground
Water
9-46
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vo
i
Permittee believe* Change it 1
attributable to another source 1
or error ,n sampling analysis 1
or evaluation 1
4»
• Notify Regional
withtn 7 days indicating
intent to prove change was
due to error or from
•nother source
• Submit report containing
proof to Regional
Administrator within
90davs
• It required submil within
90 days plan ot Chang**
lo Detection Monilormg
Program
i
Region*! Admmiilrator L
1^
1
IMMEDIATE ACTION
Admnwirator oi change
«lltwn70«y.
• ImnwdtaMy twnpW •»
well* and determine
Part »1 Appwidn Vl
-------
- Statistical Procedures Used to Evaluate Changes in Ground
Water Parameters
9.6.3.1 Proposed List of Monitoring Parameters —
The applicant should propose a list of parameters to be
used in monitoring at the point of compliance. The Agency
will attempt to minimize the permittee's burden through the
use of carefully selected indicator parameters, rather than a
comprehensive list of hazardous constituents. The proposed
parameters should be capable of indicating the presence of
hazardous constituents in the ground water. In some cases,
parameters that signal the presence of leachate are a less
expensive means to indicate the presence of hazardous constituents
than analyzing for the constituents themselves. The difference
between these two groups is that the indicator parameters
(such as Total Organic Halogen or TOX) do not identify the
presence of specific chemical compounds, but rather signal the
presence of a family of similar compounds.
However, the natural background variability of some indicator
parameters (such as Total Organic Carbon (TOC), specific conductance
and pH) may hinder statistical detection of some pollutants
released at low concentration levels from the facility. Consequent]
most applicants should propose a list of monitoring parameters
that includes specific hazardous constituents (chemical compounds)
and/or their reaction products as well as general parameters
that serve as indicators of the presence of leachate (e.g.,
TOC, TOX, specific conductance, pH, color, TDS, temperature).
In developing this list, the following items should be considered:
9-48
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The nature of the wastes managed at the facility
should be reviewed, to determine which constituents
(and any reaction products if this chemical process
is understood) are relatively mobile and persistent.
The results of this review should be submitted along
with the list of monitoring parameters.
The effects of the unsaturated zone (if present)
beneath the facility on the mobility, stability
and persistence of the waste constituents
The detectability of the parameters
- The concentrations and coefficients of variability
of the proposed parameters in background ground-
water quality
A useful reference on the mobility and fate of hazardous
constituents is Water-Related Fate of 129 Priority Pollutants,
Reference (2). Further guidance on the selection of monitoring
parameters is given in the Permit Writer's Guidance Manual
for Subpart F, Ground-Water Protection (Reference 1).
9.6.3.2 Proposed Ground-Water Monitoring System —
The permit applicant should propose, in detail, the
individual elements of the monitoring system to be used during
detection monitoring. The design of the system; including
the number, location, and open (or screened) intervals of all
upgradient and downgradient wells must be clearly indicated.
In addition, the design features and construction procedures
for each monitoring well, including drilling methods, well
casing and materials, well diameter, well intake design, well
development procedures, and method for sealing the annular
space must be clearly shown.
Guidance on the design of the monitoring network (i.e., the
number, location and open interval) is provided in Chapter 3 of
9-49
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Reference 1. The downgradient monitoring wells must be located
along the point of compliance. Upgradient wells must be located
in areas of the facility property that should not have any
potential for ground-water contamination from the facility; such
areas are typically upgradient from the facility. When such
upgradient wells cannot be located at the site (usually because
the facility straddles a ground water divide, or because there
is not enough space between the facility and the upgradient
property line), background wells must be installed in a nearby,
hydrogeologically similar area unaffected by the facility.
This problem is discussed in both Reference 1 and in Ground-Water
Monitoring Guidance For Owners ana Operators of Interim status
Facilities (SW-963).
The detection monitoring wells at the point of compliance
should be installed at locations and depths most likely to
intercept ground water contaminated by the regulated units.
Design considerations include the relative hydraulic conductivity
of the geologic materials beneath the facility. The Agency has
not set any minimum for the number of wells, as was done under
the Interim Status rules. Rather, the number must be established
on a site specific basis. Large facilities may need more than
three downgradient wells.
9.6.3.3 Background Values —
The applicant has two basic approaches for establishing
background values. In the first approach, specific values for
each parameter can be fixed in the permit. There are two ways
9-50
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to do this. Specific values (and their coefficients of variability)
can be submitted for each proposed monitoring parameter. Or, in
situations where background data are not available at the time
of the application, (such as at new facilities, or where the
Interim Status monitoring did not include determinations of all
of the monitoring parameters proposed for use in the detection
monitoring program), the applicant must propose a plan for
establishing these values. Details of these methods are discussed
later in this section.
In the second approach, ongoing sampling of upgradient wells
could be used to continuously define background. This approach
may be useful where upgradient off-site sources of contamination
result in transient changes in ground-water quality.
Background values generally must be based on quarterly
sampling over one year. In addition, the quarterly sampling must
include at a minimum one sample from each background upgradient
well, and four samples from the entire system of background wells.
For example, if there are two background wells, each must be
sampled twice dieting each quarterly sampling sampling event.
Background values are to be expressed in a form suitable for the
for the determination of a statistically significant change
using the specified statistical procedure. For example, to use
the procedure specified in the Part 264, Subpart F rules, the
mean, variance and number of samples analyzed for each parameter
must be recorded. Applicants should also supply all sample
results, indicating the well number, replicate number, date
9-51
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sampled and parameter value. Applicants are encouraged to
supply such a complete package of background information for
each proposed monitoring parameter.
If it is necessary for the applicant to propose a plan for
establishing background values, the plan should describe how the
values will be established over the first year of the permit.
The plan should indicate the wells and schedule to be used to
collect the data, along with the calculations to be used to
summarize the data. Unless a different statistical procedure
than that described in Part 264, Subpart F is proposed, the
applicant should follow the procedures outlined in the preceeding
paragraph.
When the applicant proposes to conduct ongoing sampling of
upgradient wells to define background, the Part 264, Subpart F
statistical test may not be applicable. In such cases, the
applicant should propose a specific statistical test, and indicate
how it is comparable to the Part 264 test. The wells to be used,
the sampling schedule, and the calculation procedures must
similarly be proposed.
9.6.3.4 Sampling, Analysis and Statistical Procedures —
The applicant should propose a sampling and analysis
plan that includes procedures for sample collection, sample
preservation and shipment, analytical methods and chain of
custody controls. Sample collection involves well evacuation
and sample withdrawal methods. A principle objective is to
insure that sample represents ground-water quality unaffected
9-52
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by well construction or sampling equipment. Guidance on designing
a sample collection plan is provided in Manual of Ground-Water
Quality Sampling Procedures (Reference 3), the Ground-Water
Monitoring Guidance for Owners and Operators of Interim Status
Facilities (SW-963) and Chapter 5 of Reference 1.
The applicant should indicate the analytical technique that
will be used for each monitoring parameter. The methods specified
in the most recent edition of Test Methods for Evaluating Solid
Waste (SW-846) must be used unless a varience is sought under
§260.21.
The applicant must also propose the statistical comparison
procedure(s) to be used. Appendix IV of Part 264, Subpart F
outlines the techniques presently specified as the standard
method. The Agency believes that this method is applicable to a
wide range of monitoring programs. Put the Agency also recognizes
that it is not applicable in some situations (see 47 FR 32274
through 32348). The Agency therefore allows the applicant the
option of proposing alternative statistical techniques when
appropriate. If the applicant proposes the standard technique,
he must only show that the background data are compatible with
its use. For alternative techniques, the applicant must describe
the calculation procedure, state all underlying assumptions,
and show that use of the method is consistent with available
data on each monitoring parameter. In some cases, different
statistical techniques will be applied to different monitoring
parameters. In these cases, the applicant must clearly specify
which statistical technique will be applied to each parameter.
9-53
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9.7 COMPLIANCE MONITORING PROGRAM
The application information requirements in §270.14(c)(5)
and §270.14(c)(7) are closely related, and are treated together
in this section.
9.7.1 The Federal Requirement
Section 270.14(c)(5) states:
Detailed plans and an engineering report describing
the proposed ground-water monitoring program to be
implemented to meet the requirements of §264.97
Section 270.14(c)(7) indicates that:
If the presence of hazardous constituents has been
detected in the ground water at the point of compliance
at the time of permit application, the owner or operator
must submit sufficient information, supporting data, and
analyses to establish a compliance monitoring program
which meets the requirements of §264.99. The owner or
operator must also submit an engineering feasibility
plan for a corrective action program necessary to meet
the requirements of §264.100, except as provided in
§264.98(h)(5). To demonstrate compliance with §264.99,
the owner or operator must address the following items:
(i) A description of the wastes previously handled
at the facility;
(ii) A characterization of the contaminated ground
water, including concentrations of hazardous constituents;
(iii) A list of hazardous constituents for which
compliance monitoring will be undertaken in accordance
with §264.97 and §264.99;
(iv) Proposed concentration limits for each hazardous
constituent, based on the criteria set forth in §264.94(a),
including a justification for establishing any alternate
concentration limits;
(v) Detailed plans and an engineering report describing
the proposed ground-water monitoring system, in accord-
ance with the requirements of §264.97; and
(vi) A description of proposed sampling, analysis
and statistical comparison procedures to be utilized in
evaluating ground-water monitoring data.
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Sections 264.94(a), 264.97, 264.99 and 264.100 are too
long to reprint here. The reader should consult the regulations
for the complete text.
9.7.2 Guidance to Achieve the Part 264 Standard
The Preamble discussion of the compliance monitoring program
under §264.99, and the general ground-water monitoring requirements
under §264.97 are found at 47 FR 32308 and 32300, respectively.
The discussion of the criteria for hazardous constituent
concentration limits is found at 47 FR 32297. The scope of the
corrective action program under §264.100 is found at 47 FR 32310.
When the permittee determines that hazardous constituents
from a regulated unit have reached ground water, he must establish
a compliance monitoring program. The evidence of the presence
of hazardous constituents may be based on previous monitoring
and/or assessment under Interim Status, on the results of a
detection monitoring program, or on the results of investigations
outside the scope of these monitoring programs. For some existing
facilities that have not complied with the Interim Status
requirements, and which pose a threat to human health and the
environment, the Regional Administrator may require the permittee
to submit an application for a compliance monitoring program.
This program is illustrated in Figure 9-8.
Many features of the compliance monitoring program are
analogous to those required in a detection monitoring program.
The significant differences in the compliance monitoring program
are described below.
9-55
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Not required but should also
regularly monitor upgradlent
wells
nltorlng
essary,
Ion to
nlstrator
ION
al
of change
y necessary to
of
i in ground-
.ation to
Inistrator
ys for permit
o establish a
Ion Program
application
a If an
visibility plan
action was
ing Detection
ogram
Statistical comparison ^j
with concentration limits ^1
Implement Corrective Action ^m
Regional Administrator ^M
Permittee's Lm
responsibilities end •
t
-------
9.7.2.1 Ground-Water Protection Standard —
The compliance monitoring permit will include a Ground-Water
Protection Standard under §264.92. This standard indicates when
corrective action is necessary to control plumes of contamination
that have emerged from a regulated unit. The standard has
four principle elements:
The hazardous constituents to be monitored and removed,
if necessary (see §264.93)
The concentration limits for each hazardous constituent
that trigger corrective action (see §264.94)
The point of compliance for measuring concentration
limits (see §264.95)
- The compliance period (see §264.96)
Each of these four elements is briefly described below.
9.7.2.1.1 Hazardous Constituents — Hazardous constituents to be
monitored and removed, if necessary, are based on the list of
constituents in Appendix VIII of Part 261. Appendix VIII is a
list of hazardous constituents and classes of constituents that
have been shown to have toxic, carcinogenic, mutagenic or teratogenic
effects on humans or other life forms. EPA has prepared a Health
and Environmental Effects Background Document on each constituent.
To select a hazardous constituent for inclusion in the
standard, two additional criteria must be met. First, it must
be in the ground water. Second, it must reasonably be expected
to be in or derived from waste contained in a regulated unit.
EPA will consider the presence of the constituent in the ground
water at the compliance point as a sufficient initial indication
that the constituent is derived from waste in a regulated unit.
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The regulations allow the applicant two grounds for arguing that
a constituent did not originate from a regulated unit. First,
the waste handled may have relatively uniform chemical charac-
teristics, and the applicant may show that it is impossible for
certain constituents to ever appear in the leachate. If so, the
Regional Administrator may conclude that the compound should not
be a hazardous constituent. Second, the applicant may be able to
show that the constituent found in the ground water is coming
from a source other than the regulated unit(s), based on sufficient
monitoring data and statistical comparisons with background
values. Such a showing, however, is not a sufficient cause for
deleting an Appendix VIII constituent from the list of hazardous
constituents in the ground-water protection standard.
There is a limited variance opportunity in §264.93(b) for
an applicant to ask the Regional Administrator to eliminate
some constituents found in ground water from the list of
hazardous constituents specified in the permit. Basically,
the applicant must demonstrate that the constituent is not
capable of posing a substantial threat to human health or the
environment at any time under any circumstances, barring war
or acts of God. An applicant cannot receive a variance by
arguing that a plume would not reach potential users for some
period of time. However, an applicant might demonstrate that,
regardless of its concentration, because of its half-life and
the slow rate of ground-water flow, the constituent can never
pose a hazard to human health or the environment. Section
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264.93(b) specifies a set of criteria which the Regional
Administrator will consider when evaluating a variance request.
The Regional Administrator will also consider any Decisions
made under §144.7 (the provision that allows for identification
of Underground Sources of Drinking Water, under the Underground
Injection Control Program, and exempted aquifers) in any
decisions about ground-water use for purposes of this variance,
to the extent that it is consistent with the ground-water
protection strategy in the Part 264 standards.
9.7.2.1.2 Concentration Limits — The second element of the
ground-water protection standard is the establishment of
concentration limits for each hazardous constituent. These
limits are the action levels which trigger initiation of a
corrective action program. EPA has used health-based contaminant
limits, where such limits exist. The maximum contaminant limits
established for the constituents in the National Interim Primary
Drinking Water Regulations under the Safe Drinking Water Act
will be used in the ground-water protection standard. Table 1
of §264.94 presents these values.
In those situations where there is no concentration limit
specified for a hazardous constituent in the regulations (i.e.,
Table 1 of §264.94), and where the applicant fails to justify
an alternate concentration limit under the variance (see
§264.94(b)), the standard will specify that the concentration
not exceed the background concentration in the ground water.
If background water quality already exceeds the concentration
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specified for a Table 1 constituent, this "no increase over
background" rule would apply to the constituent as well.
An applicant may request an alternate concentration limit
under §264.94(b). Specific time frames are established for
submitting information to justify this variance request. The
Preamble discussion on alternate concentration limits is found
at 47 FR 32298. The factors that the Regional Administrator
will use in considering this variance are identical to the
factors considered for the variance in §264.93, which allows
exclusion of some Appendix VIII constituents from the ground-
water protection standard. The reader should review the
Preamble for more information on this topic, and for several
examples that explain the variance in §264.94(b).
9.7.2.1.3 Point of Compliance — The third element in the ground-
water protection standard is the point of compliance. This
topic is addressed in Section 9.4.
9.7.2.1.4 Compliance Period —The fourth element in the ground-
water protection standard is the compliance period. In
§264.96, the compliance period is set at the number of years
equal to the active life of the waste management area, including
any waste management activity prior to permitting, and the
closure period. Note that the waste management area includes
the individual waste management units and regulated units.
The compliance period begins to run when the compliance monitoring
program begins. The compliance period may extend beyond the
number of years equal to the active life and closure period of
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the waste management area if corrective action has been initiated
but not completed. A completion demonstration should include a
showing, with monitoring data, that the ground-water protection
standard has not been exceeded for a period of three consecutive
years. The Preamble discussion on the compliance period is found
at 47 FR 32299. Also note that the compliance period and the
post-closure care period under §264.117 may not be coterminus,
although the Regional Administrator may extend the post-closure
care period to be coterminus with the compliance period.
9.7.2.2 Corrective Action Feasibility Plan —
An engineering feasibility plan for corrective action
must be submitted under two circumstances. First, when the
detection monitoring program shows that hazardous constituents
have entered the ground water from a regulated unit, the
permittee must, along with a permit modification application for
a compliance monitoring program, submit a feasibility plan for
corrective action (see §264.98(h)(5)). In this case, the
permittee has 180 days to prepare the plan. The second case
applies to any applicant applying for a compliance monitoring
program permit (see §270.14(c)(7)).
There are two situations in either of the above cases for
which a feasibility plan is not needed. First, if the only
hazardous constituents are those listed in Table 1 of §264.94,
and if their concentrations at the compliance point are below
the limits specified in the Table, the plan is not required.
Second, if the applicant (or permittee) has requested an alternate
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concentration limit (ACL) (under §264.94(b)) for every Appendix
VIII constituent significantly above background, or above appropriate
Table 1 values found at the point of compliance, the plan is not
required. Rather, the Regional Administrator will make a decision
on the ACL demonstration before requiring that the plan be submitted
When monitoring indicates that hazardous constituents are
present in the ground water, EPA believes that corrective action
is likely to be necessary. In many cases, the Regional Admin-
istrator will specify a corrective action program in conjunction
with a compliance monitoring program. Thus, if correction action
becomes necessary, the program can be initiated rapidly.
The feasibility plan does not need to detail every aspect
of a corrective action program. Rather, it should show what
general corrective action measures can be taken. The plan should
be sufficiently specific to allow EPA to decide that the proposed
corrective action program could work at the facility. Section
9.8 of this manual should be reviewed for information on the
scope of corrective action programs. The Preamble discussion of
corrective action feasibility plans is found at 47 FR 32307.
9.7.2.3 Compliance Point Monitoring - -
Sampling at the point of compliance wells must occur at
least quarterly. This is more frequent than the minimum
frequency for the detection monitoring program.
9.7.2.4 Duty to Search for Additional Hazardous Constituents - -
The permittee is required to sample and analyze the ground
water to determine whether additional hazardous constituents
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besides those identified in the permit are present at the point
of compliance. Ground-water samples must be analyzed for the
Appendix VIII constituents at least annually. If additional
constituents are found, the permittee must report this information
to the Regional Administrator. It will then be up to the Regional
Administrator to modify the permit by adding new hazardous
constituents and appropriate concentration limits.
9.7.2.5 Response to Significant Increase - -
In the detection monitoring program, the response to finding
a statistically significant change is the requirement to submit a
permit modification application for a compliance monitoring
program (which may, in addition, include certain corrective
action requirements). In the compliance monitoring program, the
response is the requirement to submit a permit modification
application for a corrective action plan. The Preamble discussion
on this topic is found at 47 PR 32309.
The permittee has 90 days to submit this application, unless
either of the two situations under which a feasiblity plan is
not required had occurred earlier (Section 9.7.2.2). In this
latter case, the permittee has 180 days to submit the application.
The contents of an application for a corrective action plan are
discussed in Section 9.8 of this manual.
9.7.3 Guidance to Address the Application Information Requirement
To address the application information requirements, the
applicant should provide as detailed a presentation of the pro-
posed compliance monitoring program as possible. The Regional
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Administrator must specify explicit requirements in the permit.
It is suggested that the applicant develop and present the pro-
posed Compliance Monitoring Program as a group of related, but
distinct attachments to the application. These attachments should
be identified one from the other, but all should be identified as
part of the Compliance Monitoring Program. For example, the
attachments might be named CMP-1, CMP-2, or COMP-1, COMP-2, etc.
Suggested attachments include the following:
List of Wastes Previously Handled
- Map of Compliance Monitoring Wells
- Plans and Specifications for Compliance Monitoring Wells
- Sampling Techniques Including Flow Rate and Direction
Determination
Sample Preservation and Shipping Procedures
Sample Analysis Protocols
Sample Chain of Custody Procedures
Characterization of Ground Water
- Proposed Hazardous Constituent Concentration Limits
Statistical Procedures Used to Evaluate Changes in
Ground Water Parameters
9.7.3.1 Description of Wastes Previously Handled —
A description of the wastes previously handled at the facility
is required in the application. The information is needed to
aid in the identification of hazardous constituents, to assure
that the monitoring system is still appropriate, and to assess
the feasibility of proposed corrective actions. This description
should include:
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Historical records of volumes, types (including EPA ID
number, if applicable), and chemical composition of
wastes placed in units in the waste management area;
The results of any direct sampling of the waste (see
Test Methods for Evaluating Solid Waste, SW-846);
A list of constituents that are reasonably expected
to be in or derived from the waste; and
Identification of the dominant constituents expected to
be present, and their relative abundance.
Additionally, if it is expected that some constituents may form
a separate, immiscible fluid, the composition of this fluid and
its viscosity and density should be included in the application.
The applicant may also wish to review the waste character-
ization section of the Surface Impoundment, Waste Pile or
Landfill sections of this Manual, as appropriate, as well as
the Waste Analysis and Waste Analysis Plan sections of the
Permit Applicant's Guidance Manual for the General Facility
Standards.
9.7.3.2 Characterization of Contaminated Ground Water —
The permittee is required to characterize the contaminated
ground water. For each well at the point of compliance, and
for each background well, the applicant should provide:
- Concentrations of each constituent in Appendix VIII
of Part 261;
- Concentrations of major anions and cations;and
Concentrations of the constituents listed in Table 1
of S264.94, if not already determined by the above.
Determination of the concentration of all of the hazardous
constituents in Appendix VIII can be expensive. The Agency is
currently developing a hierarchial screening procedure for
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reducing the analysis burden. This procedure will be included
in an update to Test Methods for Evaluating Solid Waste (SW-846).
However, there currently is no waiver available for the require-
ment to analyze for all Appendix VIII constituents.
Where evidence of migration of hazardous constituents beyond
the point of compliance exists, the applicant should also
characterize the extent of the plume as required under §270.14(c)(4)
if the hazardous constituent concentrations at downgradient wells
exceed the ground-water protection standard. (see Section 9.5
of this manual).
9.7.3.3 Proposed Hazardous Constituent Concentration Limits —
The application must include a proposed list of hazardous
constituents to be included in the Ground-Water Protection
Standard. The permittee will monitor ground water at the point
of compliance for these constituents. The regulatory criteria
for identifying hazardous constituents are described in Section
9.7.2.1, as well as the options available to an applicant
for seeking to exclude certain constituents.
The applicant should use the results from Section 9.7.3.1
(Description of Wastes Previously Handled) and from similar
analyses of wastes currently handled (see the Waste Analysis
sections for the sections of this manual addressing Surface
Impoundments, Waste Piles, Land Treatment, and Landfills) in
assembling this list. The applicant should present a rationale
for the selection of the proposed hazardous constituents. This
rationale should explain why the selected hazardous constituents,
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and not other constituents (which are also expected to be present
in or derived from the wastes, and which have been identified in
the ground water) are appropriate for inclusion in the Ground Water
Protection Standard.
The applicant must also propose concentration limits for
each of the proposed hazardous constituents. The regulatory
criteria for concentration limits are described in Section 9.7.2.1.
These criteria express the Agency's policy of allowing no degrada-
tion of water quality unless the applicant can demonstrate that no
adverse public health and environmental effects will result.
Due to a lack of currently available standards based on health
criteria, specific concentration limits for only a few constituents
are specified in the regulations. These limits are the standards
established in the National Interim Primary Drinking Water Regulations,
and are listed in Table 1 of S264.94. if a hazardous constituent
is not included in Table 1, or if its background concentration is
above that allowed in Table 1, no degradation beyond background
ground-water quality is allowed. In such cases, the concentration
limit should be set at the background concentration of that hazardous
constituent.
However, a specified amount of degradation beyond that allowed
by §264.91 Table 1 or beyond background levels can be permitted by
establishing alternate concentration limits. The criteria for
establishing alternate concentration limits are discussed in Section
9.7.2.1.
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Alternate concentration limits can be permitted only after
the applicant makes a successful demonstration that the higher
concentrations will not adversely affect public health and the
environment. The demonstration may be based on:
- An assessment of health risks
An analysis of attenuation mechanisms in the
saturated zone
- Proof of discharge of all contaminated ground water
to a surface water body prior to any opportunity
for ground water use, and subsequent dilution to
acceptable concentrations in the surface water
The applicant must provide sufficient and relevant data and
analyses to support each proposed concentration limit. Guidance
on setting alternate concentration limits is provided in Chapter
8 of Reference 1.
9.7.3.4 Ground-Water Monitoring System —
The applicant must provide complete information on the
proposed ground water monitoring system. This system is
essentially the same as the system used in the Detection
Monitoring Program described earlier. The monitoring system
includes well locations and designs.
For applicants seeking alternate concentration limits
based on attenuation mechanisms or discharge to surface water,
additional monitoring wells downgradient from the point of
compliance may be necessary. This additional monitoring is
required to verify the analyses used in setting the alternate
concentration limits. Guidance on such additional monitoring
needs is included in Chapters 3 and 8 of Reference 1.
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9.7.3.5 Sampling, Analysis and Statistical Comparison Methods —
The applicant must present a description of the proposed
sampling, analysis and statistical data comparison procedures
to be used in the Compliance Monitoring Program. The required
information is addressed in the discussion of the Detection
Monitoring Program.
9.8 CORRECTIVE ACTION PROGRAM
The application information requirements in §270.14(c)(5)
and §270.14(c)(8) are closely related, and are treated together
in this section.
9.8.1 The Federal Requirement
Section 270.14(c)(5) requires:
Detailed plans and an engineering report describing
the proposed ground-water monitoring program to be
implemented to meet the requirements of §264.97
Section 270.14(c)(8) states that:
If hazardous constituents have been measured in the
ground water which exceed the concentration limits
established under §264.94 Table 1, or if ground-water
monitoring conducted at the time of permit application
under §§265.90-265.94 at the waste boundary indicates
the presence of hazardous constituents from the facility
in ground water over background concentrations, the
owner or operator must submit sufficient information,
supporting data, and analyses to establish a corrective
action program which meets the requirements of §264.100.
However, an owner or operator is not required to submit
information to establish a corrective action program
if he demonstrates to the Regional Administrator that
alternate concentration limits will protect human
health and the environment after considering the
criteria listed in §264.94(b). An owner or operator
who is not required to establish a corrective action
program for this reason must instead submit sufficient
information to establish a compliance monitoring
program which meets the requirements of §264.99 and
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paragraph (c)(7) of this section. To demonstrate
compliance with §264.100, the owner or operator must
address, at a minimum, the following items:
(i) A characterization of the contaminated ground
water, including concentrations of hazardous
const ituents;
(ii) The concentration limit for each hazardous
constituent found in the ground water as set forth
in §264.94;
(iii) Detailed plans and an engineering report
describing the corrective action to he taken; and
(iv) A description of how the ground-water
monitoring program will assess the adequacy of
the corrective action."
The sections of Part 264 referenced in the above text are
too long to reprint here. The reader should consult the regula-
tions for the complete text.
9.8.2 Guidance to Achieve tne Fart 264 Standard
The Preamble discussion of the Corrective Action Program
can be found at 47 FR 32310. There are basically two ways in
which a permittee would conduct corrective action. In the first
case, if hazardous constituents from a regulated unit exceed the
Ground-Water Protection Standard (see §264.92) already established
in a permit for that unit, the permittee must conduct a corrective
action program designed to bring the unit back into compliance
with the standard. Additionally, the permittee is responsible
for determining if contamination has migrated beyond the com-
pliance point and if so, must implement measures to correct
contamination present between the compliance point and the
downgradient facility boundary.
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In the second case, if the ground water between the compliance
point and the downgradient facility property boundary contains
concentrations of hazardous constituents which exceed the concen-
tration limits specified in §264.94, regardless of whether the
facility has a permit or not, the owner or operator must submit
a corrective action program permit application. This second case
primarily applies to Interim Status facilities which have not yet
been permitted under Part 264, and at which either Interim Status
monitoring or the plume delineation under §270.14(c)(4) indicate
the presence of such contaminated ground water. Owners or
operators of these facilities should submit permit applications
for corrective action programs.
A corrective action program may stand on its own in a permit,
or may be specified in conjunction with a compliance monitoring
program. In addition, a compliance monitoring program permit
might include a generic corrective action plan on "stand-by",
ready to be put into action if compliance monitoring results so
require. Applicants for compliance monitoring program permits
are required to submit engineering feasibility plans for corrective
action programs as discussed in Section 9.7.
A permit issued for a corrective action program will include
a Ground-Water Protection Standard for the regulated unit(s).
Section 9.7 of this manual describes the nature of the Ground-
Water Protection Standard; the applicant should refer to it for
further information. Figure 9-9 illustrates the major steps
associated with a corrective action program.
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Obtain permit to conduct
Corrective Action Program {or
. . permit modification if already
""7 I have a Part 264 permit)
Monitor ground-water quality
to determine compliance with
Ground-Water Protection
Standard and effectiveness
of Corrective Action Program
Ground-Water Protection
Standard is exceeded at
Compliance Point of facility
with Part B permit
Permittee s
responsibilities end
Implement Corrective Action
Program at direction of
Regional Administrator
Discontinue corrective action
but continue Compliance
Monitoring Program
Were Corrective Action
Program requirements fulfilled
for specified Compliance
Period or for 3 additional years
if the Compliance Period has
ended?
For Interim Status sites, do
concentrations of hazardous
constituents beyond
compliance point exceed
background levels or are
concentrations of hazardous
constituents greater than
those listed in Section
26494,Table 1 when these
(Table 1) constituents are the
only hazardous constituents
present?
Are concentrations of
hazardous constituents at the
Compliance Point at or below
those specified in the Ground
Water Protection Standard?
Apply for Detection or
Compliance Monitoring
Program as appropriate
• Continue/reinstate
corrective action and
continue monitoring
• Submit application for
permit modification to
Regional Administrator
within 90 days if change is
required in Corrective
Action Program
Report effectiveness of
Corrective Action Program
to Regional Administrator
semt-annually
Figure 9-9. Corrective action program requirements.
-------
9.7.2.1 Objective of Corrective Action —
The general goal of corrective action is to achieve
compliance with the Ground-Water Protection Standard. This goal
must be achieved by removing the hazardous constituents, or by
treating them in place. Methods that only prevent movement of
hazardous constituents in the ground water for some period of
time are not adequate. Such measures as slurry walls that only
modify the ground-water gradient or create short-term barriers
are not adequate corrective action methods by themselves.
However, slurry walls combined with pumping wells used to extract
contaminated ground water for treatment, and measures to
control the source of hazardous constituents may be acceptable.
Corrective action measures are highly dependent on site-
specific factors. In order to accommodate this situation, and in
recognition of the likely technological advances in ground-water
cleanup in the coming years, the Agency will rely on the broad
performance goals in §264.100 to evaluate proposed corrective
action programs.
9.8.2.2 Timing of Corrective Action —
The regulations establish that corrective action measures be
installed within a reasonable time. The permit will specify the
actual time limit within which the action must begin. When a
permit combines both compliance monitoring and corrective action,
the appropriate response to a statistically significant increase
in hazardous constituents is the initiation of the already approved
corrective action, rather than submission of a permit modifica-
tion application (see §264.100(c)).
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Corrective action must be performed as long as is necessary
to achieve stable compliance with the Ground Water Protection
Standard. Three consecutive years of compliance is recommended
before terminating the corrective action program.
Corrective action must continue through the compliance period
(see §264.96) to the extent necessary to meet the Ground-Water
Protection Standard. The compliance period is extended if
corrective action is still needed at the originally scheduled end
of the compliance period.
9.8.2.3 Duty to Clean Up Contamination Beyond the Compliance
Point —
At the time that EPA considers a regulated unit at an
existing facility for permitting, it is possible that a
plume of contamination will have already migrated from the
unit to beyond the compliance point. As required by §264.100(e),
the permittee will be required to clean up such a plume of
hazardous constituents between the compliance point and the
facility property boundary. If the owner or operator can
show that the plume does not originate from a regulated
unit, the permit would not require him to clean it up. The
time frame criteria for this cleanup are the same as those
explained in Section 9.8.2.2.
9.8.2.4 Corrective Action Monitoring —
The corrective action program must include a monitoring
program that can show whether the corrective action has been
successful. The monitoring program should be based at a minimum
on the compliance monitoring program of S264.99 (see Section 9.7).
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In some cases, it may be necessary to conduct more frequent
monitoring or to have additional wells than in the compliance
monitoring program, in order to evaluate the progress of the
corrective action.
9.8.2.5 Reporting —
Permittees must report semi-annually on the effectiveness
of the corrective action program to the Regional Administrator.
This report will be used by EPA to ensure that the permittee does
not simply continue to implement measures that are not achieving
the Ground-Water Protection Standard.
9.8.3 Guidance to Address tne Application Information Requirement
It is suggested that the applicant develop and present the
proposed Corrective Action Program as a group of related, but
distinct attachments to the application. These attachments
should be identified one from the other, but all should be
identified as part of the Corrective Action Program. For
example, the attachments might be named CAP-1, CAP-2, CORR-1,
CORR-2, etc. Suggested attachments include the following:
Map of Corrective Action Monitoring Wells
Plans and specifications for Corrective Action Monitoring
Wells
Sampling Techniques Including Flow Rate and Direction
Determinations
Sample Preservation and Shipping Procedures
Sample Analysis Protocolsa
Sample Chain of Custody Procedures
Statistical Procedures Used to Evaluate Changes in Ground
Water Parameters
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Characterization of Ground Water
Proposed Hazardous Constituent Concentration Limits
- Plans and Specifications for Corrective Action Plan
9.8.3.1 Characterization of Contaminated Ground Water—
This information requirement is the same as that described
in §270.14(c)(7)(ii) for a compliance monitoring program. The
applicant should consult Section 9.7.3.2 for guidance. It is
necessary to characterize the extent and concentration of contam-
ination that has migrated beyond the point of compliance. This
information is needed for the proper design and implementation
of corrective actions. Guidance on characterization of such plumes
beyond the compliance point is also provided in Section 9.5.
9.8.3.2 Proposed Hazardous Constituent Concentration Limits —
The applicant must propose a concentration limit for each
hazardous constituent found in the ground water. The Regional
Administrator will evaluate this proposal in establishing a
Ground-Water Protection Standard. This requirement is the same
as that described in Section 9.7.3.3.
After conducting site investigations necessary to design a
corrective action program, the applicant may have new data useful
in justifying alternate concentration limits in the Ground-Water
Protection Standard. The applicant may wish to consider proposing
a permit modification based on these new data.
9.8.3.3 Corrective Action Plan —
The applicant must submit detailed plans and an engineering
report on the corrective actions proposed for the facility. This
information should include:
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Maps and plans showing the location of engineered
barriers, caps, drains and wells, etc. (use the
§270.14(b)(19) base map);
- Descriptions and engineering drawings of construction
details and specifications of engineered barriers,
caps, drains, wells, etc.;
If proposed, plans for removing and handling of
any hazardous wastes;
A description of the treatment technologies to be
used for contaminated ground water that is pumped
or drained from the zone of contamination;
A prediction and sensitivity analysis on the
effectiveness of corrective actions. For example,
anticipated drain flow rates, assuming a range of
hydrologic properties (Numerical simulation models
of ground water flow and solute transport may be
particularly useful);
If treated ground or surface water is to be
reinjected at the site, the concentration levels
of all hazardous constituents to be reinjected;
- A description and summary of any additional hydro-
geologic data collected for use in designing the
corrective action;
Operation and maintenance plans for the corrective
action measures; and
If applicable, closure and post-closure care plans
for the materials used to handle hazardous wastes
as part of the corrective action.
Guidance for designing and evaluating corrective action
measures is available in the Handbook; Remedial Action at Waste
/
Disposal Sites EPA-625/6-82-006, in Chapter 10 of Reference 1
and in the Guidance Manual for Minimizing Pollution from
Waste Disposal Sites EPA-600/2-78-142, 1978, NTIS No. PB286905.
9.8.3.4 Ground-Water Monitoring/—
The application must include a description of the ground-
water monitoring program used to assess the effectiveness
9-77
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of the corrective action measures. This program will normally
involve both water level and water quality monitoring. Water
level monitoring is generally necessary to determine whether
drains, barriers and wells are altering the ground-water flow
field as intended. Water quality monitoring must be conducted
over the on-site extent of the contaminated ground water.
The applicant must provide details on well location, con-
struction, sampling frequency and methods, analysis methods, and
chain of custody procedures. Further guidance on these topics
is available in Section 9.6 and 9.7 of this Manual, and in
Chapters 3 and 10 of the Permit Writer's Guidance Manual for
Subpart F, Ground-Water Protection (Reference 1).
9.9 REFERENCES
1. U.S. Environmental Protection Agency. Permit Writers'
Guidance Manual for Subpart F, Ground-Water Protection.
Wahington, D.C., 1983.
2. Callahan, M.A., M.W. Slimak, N.W. Babe, I.P. May, and
C.F. Fowler. Water-selected Environmental Fate of 129
Priority Pollutants. Volume 1. Introduction and Technical
Background, Metals and Inorganics, Pesticides and PCBs.
Final Report. EPA-440/4-79-029a, Versar, Inc., Springfield,
Virginia, December 1979. NTIS No. PB80-204373.
3. Scalf, M.R., J.F. McNabb, W.J. Dunlap, R.L. Cosby, and
J.S. Fryberger. Manuals of Ground-Water Quality Sampling
Procedures. EPA-600/2-81-160, Robert S. Kerr Environmental
Research Laboratory, Ada, Oklahoma, September 1981. NTIS No.
PB82-103045.
9-78
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APPENDIX A
RCRA PART A PERMIT APPLICATION
FORMS AND INSTRUCTIONS
A-l
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United States
Environmental Protection
Agency
Office of
Enforcement
Washington, DC 20460
EPA Form 3510-1
June 1980
Permits Division
>EPA
Application Form 1 - General
Consolidated Permits Program
This form must be completed by all persons applying for
a permit under EPA's Consolidated Permits Program. See
the general instructions to Form 1 to determine which
other application forms you will need.
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DESCRIPTION OF CONSOLIDATED
PERMIT APPLICATION FORMS
FORM 1 PACKAGE
TABLE OF CONTENTS
The Consolidated Permit Application Forms are:
Form 1 - General Information (included in this part);
Form 2 - Discharges to Surface Water tNPDES Permits!:
2A. Publicly Owned Treatment Works (Reserved — not included in
this package!,
2B. Concentrated Animal Feeding Operations and Aquatic Animal
Production Facilities (not included in this package),
2C. Existing Manufacturing, Commercial, Mining, and Silvicultural
Operations (not included in this package), and
2D. New Manufacturing, Commercial, Mining, and Silvicultural
Operations (Reserved — not included in this package);
Form 3 — Hazardous Waste Application Form (RCRA Permit* —
included in Part 2 of this package);
Form 4 — Underground Injection of Fluids (UIC Permits — Re-
served — not included in this package); and
Form 5 — Air Emissions in Attainment Areas (PSD Permits — Re-
served — not included in this package).
Section A. General Instructions
Section B. Instructions for Form 1
Section C. Activities Which Do Not Require Permits
Section D. Glossary
Form 1 (two copies)
SECTION A - GENERAL INSTRUCTIONS
Who Must Apply
With the exceptions described in Section C of these instructions. Fed-
eral laws prohibit you from conducting any of the following activities
without a permit.
NPDES (National Pollutant Discharge Elimination System Under the
Clean Water Act, 33 U.S.C. 1251). Discharge of pollutants into the
waters of the United States.
RCRA (Resource Conservation and Recovery Act. 42 U.S.C. 6901).
Treatment, storage, or disposal of hazardous wastes.
UIC (Underground Injection Control Under the Safe Drinking Waur
Act, 42 U.S.C 3001). Injection of fluids underground by gravity flow
or pumping.
PSD (Prevention of Significant Deterioration Under the Clean Air
Act, 72 U.S.C. 7401). Emission of an air pollutant by a new or modi-
fied facility in or near an area which has attained the National Ambient
Air Quality Standards for that pollutant.
Each of the above permit programs is operated in any particular State
by either the United States Environmental Protection Agency (EPA)
or by an approved State agency. You must use this application form to
apply for a permit for those programs administered by EPA. For those
programs administered by approved States, contact the State environ-
mental agency for the proper forms.
If you have any questions about whether you need a permit under any
of the above programs, or if you need information as to whether a
particular program is administered by EPA or a State agency, or if you
need to obtain application forms, contact your EPA Regional office
(listed in Table 11.
Upon your request, and based upon information supplied by you,
EPA will determine whether you are required to obtain a permit for
a particular facility. Be sure to contact EPA if you have a question,
because Federal laws provide that you may be heavily penalized rf
you do not apply for a permit when a permit is required.
Form 1 of the EPA consolidated application forms collects general
information applying to all programs. You must fill out Form 1 regard-
less of which permit you are applying for. In addition, you must fill
out one of the supplementary forms (Forms 2 — 5) for each permit
needed under each of the above programs. Item II of Form 1 will
guide you to the appropriate supplementary forms.
You should note that there are certain exclusions to the permit require-
ments listed above. The exclusions are described in detail in Section C
of these instructions. If your activities are excluded from permit re-
quirements then you do not need to complete and return any forms.
NOTE: Certain activities not listed above also are subject to EPA
administered environmental permit requirements. These include per-
mits for ocean dumping, dredged or fill material discharging, and
certain types of air emissions. Contact your EPA Regional office for
further information.
Table 1. AdJrasMi of EPA Regional Contact! and States Within the
Regional Office Jurisdictions
REGION I
Permit Contact, Environmental and Economic Impact Office, U.S.
Environmental Protection Agency, John F. Kennedy Building, Bos-
ton, Massachusetts 02203, (617) 223-4635, FTS 223-4635.
Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island,
and Vermont.
REGION II
Permit Contact, Permits Administration Branch, Room 432, U.S.
Environmental Protection Agency, 26 Federal Plaza, New York,
New York 10007, (212) 264-9880, FTS 264-9880.
New Jersey, New York, Virgin Islands, and Puerto Rico.
REGION III
Permit Contact (3 EN 23), U.S. Environmental Protection Agency,
6th ft Walnut Streets, Philadelphia. Pennsylvania 19106, (216)
597-8816. FTS 597-8816.
Delaware, District of Columbia, Maryland, Pennsylvania, Virginia,
and Watt Virginia.
REGION IV
Permit Contact, Permits Section, U.S. Environmental Protection
Agency, 345 Courtland Street. N.E., Atlanta, Georgia 30365, (404)
881-2017, FTS 257-2017.
Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina,
South Carolina, and Tennessee.
REGION V
Permit Contact (S£P), U.S. Environmental Protection Agency, 230
South Dearborn Street, Chicago, Illinois 60604, (312) 353-2105,
FTS 353-2105.
Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin.
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SECTION A - GENERAL INSTRUCTIONS (continued)
Table 1 (continued)
REGION VI
Permit Contact (6AEPI, U.S. Environmental Protection Agency,
First International Building, 1201 Elm Street, Dallas, Texas 75270,
(214) 767-2766, FTS 729-2765.
Arkansas, Louisiana, New Mexico, Oklahoma, and Texas.
REGION VII
Permit Contact, Permits Branch, U.S. Environmental Protection'
Agency, 324 East 11th Street, Kansas City, Missouri 64106, (816)
758-5955, FTS 758-5955.
Iowa, Kansas, Missouri, and Nebraska.
REGION VIII
Permit Contact (BE-WE). Suite 103, U.S. Environmental Protection
Agency, 1816 Lincoln Street, Denver, Colorado 80203, (303) 837—
4901, FTS 837-4901.
Colorado, Montana, North Dakota, South Dakota, Utah, and
Wyoming.
REGION IX
Permit Contact, Permits Branch (E—41, U.S. Environmental Protection
Agency, 215 Fremont Street, San Francisco, California 94105,
(415) 556-3450, FTS 556-3450.
Arizona, California, Hawaii, Nevada, Guam, American Samoa, and
Trust Territories.
REGION X
Permit Contact IM/S 521), U.S. Environmental Protection Agency,
1200 6th Avenue, Seattle, Washington 98101, (206) 442-7176,
FTS 399-7176.
Alaska, Idaho, Oregon, and Washington.
When to File
The application forms should be mailed to the EPA Regional office
whose Region includes the State in which the facility is located (see
Table 1).
If the State in which the facility is located administers a Federal permit
program under which you need a permit, you should contact the appro-
priate State agency for the correct forms. Your EPA Regional office
(Table 1) can tell you to whom to apply and can provide the appro-
priate address and phone number.
When to File
Because of statutory requirements, the deadline* for filing applications
vary according to the type of facility you operate and the type of per-
mit you need. These deadlines are as follows:'
Table 2. Filing Dates for Permits
FORMCpwm/f
WHEN TO FILE
2AWPDESI 180 days before your present NPDES per-
mit expires.
2B(NPDESi 180 days before your present NPDES per-
mit expires1, or 180 days prior to start-
up if you are a new facility.
2C(NPD£Si 180 days before your present NPDES per-
mit vxpires*.
2D(NPD£S) 180 Jays prior to startup.
^(Hazardous Waste). . . .Existing facility: Six months following
publication of regulations listing hazard-
ous wastes.
New facility: 180 days before commencing
physical construction.
Table 2 (continued)
AlUICi A reasonable time prior to construction
for new wells; as directed by the Director
for existing wells.
5{PSDI Prior to commencement of construction.
' Please note that some of these forms are not yet available for use
and are listed as "Reserved" at the beginning of these instructions.
Contact your EPA Regional office for information on current appli-
cation requirements and forms.
1 If your present permit expires on or before November 30, 1980, the
filing date is the date on which your permit expires. If your permit
expires during the period December 1, 1980 — May 31, 1981, the fil-
ing date is 90 days before your permit expires.
Federal regulations provide that you may not begin to construct a
new source in the NPDES program, a new hazardous waste management
facility, a new injection well, or a facility covered by the PSD program
before the issuance of a permit under the applicable program. Please
note that if you are required to obtain a permit before beginning con-
struction, as described above, you may need to submit your permit
application well in advance of an applicable deadline listed in Table 2.
Feet
The U.S. EPA does not require a fee for applying for any permit under
the consolidated permit programs. (However, some States which ad-
minister one or more of these programs require fees for the permits
which they issue.)
Availability of Information to Public
Information contained in these application forms will, upon request,
be made available to the public for inspection and copying. However,
you may request confidential treatment for certain information which
you submit on certain supplementary forms. The specific instructions
for each supplementary form state what information on the form, if
any, may be claimed as confidential and what procedures govern the
claim. No information on Forms 1 and 2A through 2D may be claimed
as confidential.
Completion of Forms
Unless otherwise specified in instructions to the forms, each item in
each form must be answered. To indicate that each item has been con-
sidered, enter "NA," for not applicable, if a particular item does not
fit the circumstances or characteristics of your facility or activity.
If you have previously submitted information to EPA or to an approved
State agency which answers a question, you may either repeat the in-
formation in the space provided or attach a copy of the previous sub-
mission. Some items in the form require narrative explanation. If more
space is necessary to answer a question,.attach a separate sheet entitled
"Additional Information."
Fir
cial Ami*
i for Pollution Control
There are a number of direct loans, Irin guarantees, and grants available
to firms and communities for pollut >n control expenditures. These are
provided by the Small Business Administration, the Economic Devel-
opment Administration, the Farmers Home Administration, and the
Department of Housing and Urban Development. Each EPA Regional
office (Table 1) has an economic assistance coordinator who can pro-
vide you with additional information.
EPA's construction grants program under Title II of the Clean Water
Act is an additional source of assistance to publicly owned treatment
works. Contact your EPA Regional office for details.
1-2
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SECTION B - FORM 1 LINE-BY-LINE INSTRUCTIONS
This form must be completed by all applicants.
Completing This Form
Please type or print in the unshaded areas only. Some items have small
graduation marks in the fill—in spaces. These marks indicate the num-
ber of characters that may be entered into our data system. The marks
are spaced at 1/6" intervals which accommodate elite type (12 charac-
ters per inch). If you use another type you may ignore the marks. If
you print, place each character between the marks. Abbreviate if neces-
sary to stay within the number of characters allowed for each item.
Use one space for breaks between words, but not for punctuation
marks unless they are needed to clarify your response.
Item I
Space is provided at the upper right hand corner of Form 1 for inser-
tion of your EPA Identification Number. If you have an existing facil-
ity, enter your Identification Number. If you don't know your EPA
Identification Number, please contact your EPA Regional office (Table
11, which will provide you with your number. If your facility is new
(not yet constructed), leave this item blank.
Item II
Answer each question to determine which supplementary forms you
need to fill out. Be sure to check the glossary in Section D of these
instructions for the legal definitions of the bold faced words. Check
Section C of these instructions to determine whether your activity
is excluded from permit requirements.
If you answer "no" to every question, then you do not need a permit,
and you do not need to complete and return any of these forms.
If you answer "yes" to any question, then you must complete and file
the supplementary form by the deadline listed in Table 2 along with
this form. (The applicable form number follows each question and it
enclosed in parentheses.) You need not submit a supplementary form if
you already have a permit under the appropriate Federal program,
unless your permit is due to expire and you wish to renew your permit.
Questions (I) and (J) of Item II refer to major new or modified sources
subject to Prevention of Significant Deterioration (PSD) requirements
under the Clean Air Act. For the purpose of the PSD program, major
sources are defined as: (A) Sources listed in Table 3 which have the po-
tential to emit 100 tons or more per year emissions; and (B) All other
sources with the potential to emit 250 tons or more per year. See
Section C of these instructions for discussion of exclusions of certain
modified sources.
Table 3. 28 Industrial Categories Listed in Section 189(1) of the Clean
Air Act of 1977
Fossil fuel-fired steam generators of more than 250 million BTU per
hour heat input;
Coal cleaning plants (with thermal dryers);
Kraft pulp mills;
Portland cement plants;
Primary zinc smelters;
Iron and steel mill plants;
Primary aluminum ore reduction plants;
Primary copper smelters;
Municipal incinerators capable of charging more than 250 tons of re-
fuse per day;
Hydrofluoric acid plants;
Nitric acid plants;
Sulfuric acid plants;
Petroleum refineries;
time plants;
Phosphate rock processing plants;
Coke oven batteries;
Sulfur recovery plants;
Carbon black plants (furnaceprocess);
Primary lead smelters;
Fuel conversion plants;
Sintering plants;
Secondary metal production plants;
Chemical process plants;
Fossil fuel boilers (or combination thereof) totaling more than 250
million BTU per hour heat input;
Table 3 (continued)
Petroleum storage and transfer units with a total storage capacity
exceeding 300,000 barrels;
Taconite ore processing plants;
Glass fiber processing plants; and
Charcoal production plants.
Item III
Enter the facility's official or legal name. Do not use a colloquial
name.
Item IV
Give the name, title, and work telephone number of a person who is
thoroughly familiar with the operation of the facility and with the facts
reported in this application and who can be contacted by reviewing
offices if necessary.
Item V
Give the complete mailing address of the office where correspondence
should be sent. This often is not the address used to designate the lo-
cation of the facility or activity.
Item VI
Give the address or location of the facility identified in Item III of this
form. If the facility lacks a street name or route number, give the most
accurate alternative geographic information (e.g., section number or
quarter section number from county records or at intersection of Rts.
425 and 22).
Item VII
List, in descending order of significance, the four 4-digit standard
industrial classification (SICI codes which best describe your facility
in terms of the principal products or services you produce or provide.
Also, specify each classification in words. These classifications may dif-
fer from the SIC codes describing the operation generating the dis-
charge, air emissions, or hazardous wastes.
SIC code numbers are descriptions which may be found in the "Stan-
dard Industrial Classification Manual" prepared by the Executive Of-
fice of the President, Office of Management and Budget, which is
available from the Government Printing Office, Washington, D.C.
Use the current edition of the manual. If you have any questions con-
cerning the appropriate SIC code for your facility, contact your EPA
Regional office (see Table 1).
Item VIII-A
Give the name, as it is legally referred to, of the person, firm, public
organization, or any other entity which operates the facility described
in this application. This may or may r t be the same name as the fa-
cility. The operator of the facility is Lie legal entity which controls
the facility's operation rather than the plant or site manager. Do not
use a colloquial name.
Item VIII-B
Indicate whether the entity which operates the facility also owns it
by marking the appropriate box.
Item VIII-C
Enter the appropriate letter to indicate the legal status of the operator
of the facility. Indicate "public" for a facility solely owned by local
government/^ such as a city, town, county, parish, etc.
Items VIII-D - H
Enter the telephone number and address of the operator identified in
Item VIII-A.
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SECTION B - FORM 1 LINE-BY-LINE INSTRUCTIONS (continued)
Item IX
Indicate whether the facility is located on Indian Lands.
ItwnX
Give the number of each presently effective permit issued to the fa-
cility for each program or, if you have previously filed an application
but have not yet received a permit, give the number of the application,
if any. Fill in the unshaded area only. If you have more than one cur-
rently effective permit for your facility under a particular permit pro-
gram, you may list additional permit numbers on a separate sheet of
paper. List any relevant environmental Federal (e.g., permits under the
Ocean Dumping Act, Section 404 of the Clean Water Act or the Surface
Mining Control and Reclamation Act), State (e.g.. State permits for
new air emission sources in nonattainment areas under Pan D of the
Clean Air Act or Sate permits under Section 404 of the Clean Water
Act), or local permits or applications under "other."
Item XI
Provide a topographic map or maps of the area extending at least to
one mile beyond the property boundaries of the facility which clearly
show the following:
The legal boundaries of the facility;
The location and serial number of each of your existing and proposed
intake and discharge structures;
All hazardous waste management facilities;
Each well where you inject fluids underground; and
All springs and surface water bodies in the area, plus all drinking
water wells within 1/4 mile of the facility which are identified in the
public record or otherwise known to you.
If an intake or discharge structure, hazardous waste disposal site, or
injection well associated with the facility is located more than one mile
from the plant, include it on the map, if possible. If not, attach addi-
tional sheets describing the location of the structure, disposal site, or
well, and identify the U.S. Geological Survey (or other) map corres-
ponding to the location.
On each map, include the map scale, a meridian arrow showing north,
and latitude and longitude at the nearest whole second. On all maps of
rivers, show the direction of the current, and in tidal waters, show the
directions of the ebb and flow tides. Use a 7-1/2 minute series map
published by the U.S. Geological Survey, which may be obtained
through the U.S. Geological Survey Offices listed below. If a 7-1/2
minute series map has not been published for your facility site, then
you may use a 15 minute series map from the U.S. Geological Survey.
If neither a 7-1/2 nor 15 minute series map has been published for your
facility site, use a plat map or other appropriate map, including all the
requested information; in this case, briefly describe land uses in the
map area (e.g., residential, commercial).
You may trace your map from a geological survey chart, or other map
meeting the above specifications. If you do, your map should bear a
note showing the number or title of the map or chart it was traced
from. Include the names of nearby towns, water bodies, and other
prominent points. An example of an acceptable location map is shown
in Figure 1—1 of these instructions. (NOTE: Figure 1—1 is provided for
purposes of illustration only, and does not represent any actual fa-
cility.)
U.S.G.S. OFFICES
AREA SERVED
Eastern Mapping Center
National Cartographic Information
Center
U.S.G.S.
536 National Center
Reston, Va. 22092
Phone No. (703) 860-6336
Ala., Conn., Del., D.C., Fla.,
Ga., Ind., Ky., Maine, Md.,
Mass., N.H., N.J., N.Y., N.C.,
S.C., Ohio, Pa., Puerto Rico,
R.I., Tenn., Vt., Va., W. Va.,
and Virgin Islands.
Item XI (continued)
Mid Continent Mapping Center
National Cartographic Information
Center
U.S.G.S.
1400 Independance Road
Rolla, Mo. 65401
Phone No. (314) 341-0851
Rocky Mountain Mapping Center
National Cartographic Infomation
Center
U.S.G.S.
Stop 504, Box 25046 Federal Center
Denver, Co. 80225
Phone No. (303) 234-2326
Western Mapping Center
National Cartographic Information
Center
U.S.G.S.
345 Middlefield Road
Menlo Park, Ca. 94025
Phone No. (415) 323-8111
Ark., III., Iowa, Kans., La.,
Mich., Minn., Miss., Mo.,
N. Dak., Nebr.. Okla., S. Dak.,
and Wis.
Alaska, Colo., Mont., N. Mex.,
Tex., Utah, and Wyo.
Ariz., Calif., Hawaii, Idaho,
Nev., Oreg., Wash., American
Samoa, Guam, and Trust
Territories
Item XII
Briefly describe the nature of your business (e.g., products produced
or services provided).
Item XIII
Federal statues provide for severe penalties for submitting false inform-
ation on this application form.
18 U.S.C. Section 1001 provides that "Whoever, in any matter within
the jurisdiction of any department or agency of the United States
knowingly and willfully falsifies, conceals or covers up by any trick,
scheme, or device a material fact, or makes or uses any false writing
or document knowing same to contain any false, fictitious or fraudu-
lent statement or entry, shall be fined not more than $10,000 or im-
prisoned not more than five years, or both."
Section 309(cH2) of the Clean Water Act and Section 113(c)(2) of the
Clean Air Act each provide that "Any person who knowingly makes
any false statement, representation, or certification in any applica-
tion, . . . shall upon conviction, be punished by a fine of no more than
$10,000 or by imprisonment for not more than six months, or both."
In addition. Section 3008(d)(3) of the Resource Conservation and Re-
covery Act provides for a fine up to $25,000 per day or imprisonment
up to one year, or both, for a first conviction for making a false state-
ment in any application under the Act, and for double these penalties
upon subsequent convictions.
FEDERAL REGULATIONS REQUIRE THIS APPLICATION TO BE
SIGNED AS FOLLOWS:
A. For a corporation, by a principal executive officer of at least the
level of vice president. However, if the only activity in Item II which
is marked "yes" is Question G, the officer may authorize a person
having responsibility for the overall ope- tions of the well or well
field to sign the certification. In that case, the authorization must be
written and submitted to the permitting authority.
B. For partnership or sole proprietorship, by a general partner or the
proprietor, respectively; or
C. For a municipality. State, Federal, or other public facility, by
either a principal executive officer or ranking elected official.
1-4
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SECTION C - ACTIVITIES WHICH DO NOT REQUIRE PERMITS
I. National Pollutant Discharge Elimination System Permits Under
' the Clean Water Act. You are not required to obtain an NPDES permit
if your discharge is in one of the following categories, as provided by
the Clean Water Act ICWA) and by the NPDES regulations (40 CFR
Para 122-125). However, under Section 510 of CWA a discharge ex-
empted from the federal NPDES requirements may still be regulated
by a State authority; contact your State environmental agency to de-
termine whether you need a State permit.
A. DISCHARGES FROM VESSELS. Discharges of sewage from ves-
sels, effluent from properly functioning marine engines, laundry,
shower, and galley sink wastes, and any other discharge incidental to
the normal operation of a vessel do not require NPDES permits.
However, discharges of rubbish, trash, garbage, or other such mater-
ials discharged overboard require permits, and so do other discharges
when the vessel is operating in a capacity other than as a means of
transportation, such as when the vessel is being used as an energy or
mining facility, a storage facility, or a seafood processing facility, or
is secured to the bed of the ocean, contiguous zone, or waters of the
United States for the purpose of mineral or oil exploration or de-
velopment.
B. DREDGED OR FILL MATERJAL. Discharges of dredged or fill-
material into waters of the United States do not need NPDES permits
if the dredging or filling is authorized by a permit issued by the U.S.
Army Corps of Engineers or an EPA approved State under Section
404 of CWA.
C. DISCHARGES INTO PUBLICLY OWNED TREATMENT WORKS
(POTW). The introduction of sewage, industrial wastes, or other pol-
lutants into a POTW does not need an NPDES permit. You must
comply with all applicable pretreatment standards promulgated
under Section 307(b) of CWA, which may be included in the permit
issued to the POTW. If you have a plan or an agreement to switch
to a POTW in the future, this does not relieve you of the obligation
to apply for and receive an NPDES permit until you have stopped
discharging pollutants into waters of the United States.
(NOTE: Dischargen into privately owned treatment works do not
have to apply for or obtain NPDES permits except as otherwise re-
quired by the EPA Regional Administrator. The owner or operator
of the treatment works itself, however, must apply for a permit and
identify all users in its application. Users so identified will receive
public notice of actions taken on the permit for the treatment works.)
D. DISCHARGES FROM AGRICULTURAL AND SILVICULTUR-
AL ACTIVITIES. Most discharges from agricultural and silviculture!
activities to waters of the United States do not require NPDES per-
mits. These include runoff from orchards, cultivated crops, pastures,
range lands, and forest lands. However, the discharges listed below
do require NPDES permits. Definitions of the terms listed below are
contained in the Glossary section of these instructions.
1. Discharges from Concentrated Animal Feeding Operations.
(See Glossary for definitions of "animal feeding operations" and
"concentrated animal feeding operations." Only the latter require
permits.)
2. Discharges from Concentrated Aquatic Animal Production
Facilities. (See Glossary for size cutoffs.)
3. Discharges associated with approved Aquaculture Projects.
4. Discharges from Silviculture! Point Sources. (See Glossary for
the definition of "silvicultural point source.") Nonpoint source
silviculture! activities- are excluded from NPDES permit require-
ments. However, some of these activities, such as stream crossings
for roads, may involve point source discharges of dredged or fill
material which may require a Section 404 permit. See 33 CFR
209.120.
E. DISCHARGES IN COMPLIANCE WITH AN ON-SCENE CO-
ORDINATOR'S INSTRUCTIONS.
II. Hazardous Waste Permits Under the Resource Conservation and
Recovery Act. You may be excluded from the requirement to obtain
a permit under this program if you fall into one of the following
categories:
Generators who accumulate their own hazardous waste on—site for
less than 90 days as provided in 40 CFR 262.34;
Farmers who dispose of hazardous waste pesticide from their own use
as provided in 40 CFR 262.61;
Certain persons treating, storing, or disposing of small quantities of
hazardous waste as provided in 40 CFR 261.4 or 261.5; and
Owners and operators of totally enclosed treatment facilities as de-
fined in 40 CFR 260.10.
Check with your Regional office for details. Please note that even if
you are excluded from permit requirements, you may be required by
Federal regulations to handle your waste in-a particular manner.
III. Underground Injection Control Permits Under the Safe Drinking
Water Act. You are not required to obtain a permit under this program
if you:
Inject into existing wells used to enhance recovery of oil and gas or
to store hydrocarbons (note, however, that these underground injec-
tions are regulated by Federal rules); or
Inject into or above a stratum which contains, within 1/4 mile of the
well bore, an underground source of drinking water (unless your in-
jection is the type identified in Item II-H, for which you do need a
permit). However, you must notify EPA of your injection and submit
certain required information on forms supplied by the Agency, and
your operation may be phased out if you are a generator of hazardous
wastes or a hazardous waste management facility which uses wells
or septic tanks to dispose of hazardous waste.
IV. Prevention of Significant Deterioration Permits Under the Clean
Air Act. The PSD program applies to newly constructed or modified
facilities (both of which an referred to as "new sources") which in-
crease air emissions. The Clean Air Act Amendments of 1977 exclude
small new sources of air emissions from the PSD review program. Any
new source in an industrial category listed in Table 3 of these instruc-
tions whose potential to emit is less than 100 tons per year is not re-
quired to get a PSD permit. In addition, any new source in an industrial
category not listed in Table 3 whose potential to emit is less than 250
tons per year is exempted from the PSD requirements.
Modified sources which increase their net emissions (the difference
between the total emission increases and total emission decreases at
the source) leu than the significant amount set forth in EPA regulations
are also exempt from PSD requirements. Contact your EPA Regional
office (Table 1) for further information.
1-3
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SECTION D - GLOSSARY
NOTE: This Glossary includes terms used in the instructions and in Forms 1, 2B, 2C, and 3. Additional terms will be included in the
future when other forms are developed to reflect the requirements of other parts of the Consolidated Permits Program. If you have
any questions concerning the meaning of any of these terms, please contact your EPA Regional office (Table 1).
ALIQUOT means a sample of specified volume used to make up a total
composite sample.
ANIMAL FEEDING OPERATION means a lot or facility (other than
an aquatic animal production facility) where the following conditions
are met:
A. Animals (other than aquatic animals) have been, are, or will be
stabled or confined and fed or maintained for a total of 45 days or
more in any 12 month period; and
B. Crops, vegetation, forage growth, or post—harvest residues are not
sustained in the normal growing season over any portion of the lot
or facility.
Two or more animal feeding operations under common ownership
are a single animal feeding operation if they adjoin each other or if
they use a common area or system for the disposal of wastes.
ANIMAL UNIT means a unit of measurement for any animal feeding
operation calculated by adding the following numbers: The number of
slaughter and feeder cattle multiplied by ,1.0; Plus the number of ma-
ture dairy cattle multiplied by 1.4; Plus the number of swine weighing
over 25 kilograms (approximately 56 pounds) multiplied by 0.4; Plus
the number of sheep multiplied by 0.1; Plus the number of horses
multiplied by 2.0.
APPLICATION means the EPA standard national forms for applying
for a permit, including any additions, revisions, or modifications to the
forms; or forms approved by EPA for use in approved States, including
any approved modifications or revisions. For RCRA, "application"
also means "Application, Part B."
part of the Consolidated Permit
Application forms which a RCRA permit applicant must complete to
qualify for interim status under Section 3005(e) of RCRA and for con-
sideration for a perm ft. Part A consists of Form 1 (General Informa-
tion) and Form 3 (Hazardous Waste Application Form).
APPLICATION, PART B means that part of the application which a
RCRA permit applicant must complete to be issued a permit. (NOTE:
EPA it not developing a specific form for Part B of the permit appli-
cation, out an instruction booklet explaining what information must be
supplied is available from the EPA Regional office.)
APPROVED PROGRAM or APPROVED STATE means a State pro-
gram which has been approved or authorized-by EPA under 40 CFR
Part 123.
AQUACULTURE PROJECT means a defined managed water area
which uses discharges of pollutants into that designated area for the
maintenance or production of harvestable freshwater, estuarine, or
marine plants or animal*. "Designated area" means the portions of the
waters of the United States within which the applicant plans to con-
fine the cultivated species, using a method of plan or operation (includ-
ing, but not limited to, physical confinement) which, on the basis of
reliable scientific evidence, is expected to ensure the specific individual
organisms comprising an aquaculture crop will enjoy increased growth
attributable to the discharge of pollutants and be harvested within a
defined geographic area.
AQUIFER means a geological formation, group of formations, or part
of a formation that is capable of yielding a significant amount of water
to a well or spring.
AREA OF REVIEW means the area surrounding an injection well
which is described according to the criteria set forth in 40 CFR Section
146.06.
AREA PERMIT means a UIC permit applicable to all or certain wells
within a geographic area, rather than to a specified well, under 40 CFR
Section 122.37.
ATTAINMENT AREA means, for any air pollutant, an area which has
been designated under Section 107 of the Clean Air Act as having
ambient air quality levels better than any national primary or secondary
ambient air quality standard for that pollutant. Standards have been set
for sulfur oxides, particulate matter, nitrogen dioxide, carbon monox-
ide, ozone, lead, and hydrocarbons. For purposes of the Glossary,
"attainment area" also refers to "unclassifiable area," which-means,
for any pollutants, an area designated under Section 107 as unclassi-
fiable with respect to that pollutant due to insufficient information.
BEST MANAGEMENT PRACTICES (BMP) means schedules of activi-
ties, prohibitions of practices, maintenance procedures, and other man-
agement practices to prevent or reduce the pollution of waters of the
United States. BMP's include treatment requirements, operation proce-
dures, and practices to control plant site runoff, spillage 'or leaks,
sludge or waste disposal, or drainage from raw material storage.
BIOLOGICAL MONITORING TEST means any test which includes
the use of aquatic algal, invertebrate, or vertebrate species to measure
acute or chronic toxicity, and any biological or chemical measure of
bioaccumulation.
BYPASS means the intentional diversion of wastes from any any por-
tion of a treatment facility.
CONCENTRATED ANIMAL FEEDING OPERATION means an animal
feeding operation which meets the criteria set forth in either (A) or (B)
below or which the Director designates as such on a case—by—case
basis:
A. More than 'the numbers of animals specified in any of the follow-
ing categories are confined:
1. 1,000 slaughter or feeder cattle,
2. 700 mature dairy cattle (whether milked or dry cows),
3. 2,500 swine each weighing over 25 kilograms (approximately
SS pounds),
4. 500 horses,
5, 10,000 sheep or lambs,
6. 55,000 turkeys,
7. 100,000 laying hens or broilers (if the facility has a continuous
overflow watering),
8. 30,000 laying hens or broilers (if the facility has a liquid manure
handling system),
9. 5,000 ducks, or
10. 1,000 animal units; or
B. More than the following numbers and types of animals are con-
fined:
1. 300 slaughter or feeder cattle,
2. 200 mature dairy cattle (whether milked or dry cows),
3. 750 swine each weighing over 25 kilograms (approximately 55
pounds),
4. 150 horses.
1-6
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SECTION D - GLOSSARY {continued)
CONCENTRATED ANIMAL FEEDING OPERATION (continued)
5. 3,000 sheep or lambs,
6. 16,500 turkeys,
7. 30,000 laying hens or broilers (if the facility has continuous
overflow watering),
8. 9,000 laying hens or broilers (if the facility has a liquid manure
handling system).
9. 1,500 ducks, or
10. 300 animal units; AND
Either one of the following conditions are met: Pollutants are dis-
charged into waters of the United States through a manmade ditch,
flushing system or other similar manmade device ("manmade"
means constructed by man and used for the purpose of transporting
wastes); or Pollutants are discharged directly into waters of the
Unites States which originate outside of and pass over, across, or
through the facility or otherwise come into direct contact with the
animals confined in the operation.
Provided, however, that no animal feeding operation is a concen-
trated animal feeding operation as defined above if such animal
feeding operation discharges only in the event of a 25 year, 24 hour
storm event.
CONCENTRATED AQUATIC ANIMAL PRODUCTION FACILITY
means a hatchery, fish farm, or other facility which contains, grows or
holds aquatic animals in either of the following categories, or which the
Director designates as such on a case—by—case basis:
A. Cold water fish species or other cold water aquatic animals includ-
ing, but not limited to, the Salmonidae family of fish (e.g., trout and
salmon) in ponds, raceways or other similar structures which dis-
charge at least 30 days per year but does not include:
1. Facilities which produce less than 9,090 harvest weight kilograms
(approximately 20,000 pounds) of aquatic animals per year; and
2. Facilities which feed less than 2,272 kilograms (approximately
5,000 pounds) of food during the calendar month of maximum
feeding.
B. Warm water fish species or other warm water aquatic animals
including, but not limited to, the Ameiuridae, Cetrarchidae, and
Cyprinidae families of fish (e.g., respectively, catfish, sun fish, and
minnows) in ponds, raceways, or other similar structures which dis-
charge at least 30 days per year, but does not include:
1. Closed ponds which discharge only during periods of excess run-
off; or
2. Facilities which produce less than 45,454 harvest weight kilo-
grams (approximately 100,000 pounds) of aquatic animals per year.
CONTACT COOLING WATER means water'used to reduce tempera-
ture which comes into contact with a raw material, intermediate pro-
duct, waste product other than heat, or finished product.
CONTAINER m ans any portable device in which a material is stored,
transported, treated, disposed of, or otherwise handled.
CONTIGUOUS ZONE means the entire zone established by the United
States under article 24 of the convention of the Territorial Sea and the
Contiguous Zone.
CWA means the Clean Water Act (formerly referred to the Federal
water Pollution Control Act) Pub. L. 92-500, as amended by Pub.
L. 95-217 and Pub. L. 95-576, 33 U.S.C. 1251 etseq.
DIKE means any embankment or ridge of either natural or manmade
materials used to prevent the movement of liquids, sludges, solids, or
other materials.
DIRECT DISCHARGE means the discharge of a pollutant as defined
36IOW.
DIRECTOR means the EPA Regional Administrator or the State Di-
rector as the context requires.
DISCHARGE (OF A POLLUTANT) means:
A. Any addition of any pollutant or combination of pollutants to
waters of the United States from any point source; or
B. Any addition of any pollutant or combination of pollutants to the
waters of the contiguous zone or the ocean from any point source
other than a vessel or other floating craft which is being used as a
means of transportation.
This definition includes discharges into waters of the United States
from: Surface runoff which is collected or channelled by man; Dis-
charges through pipes, sewers, or other conveyances owned by a State,
municipality, or other person which do not lead to POTW's; and Dis-
charges through pipes, sewers, or other conveyances, leading into
privately owned treatment works. This term does not include an ad-
dition of pollutants by any indirect discharger.
DISPOSAL (in the RCRA program/ means the discharge, deposit, in-
jection, dumping, spilling, leaking, or placing of any hazardous waste
into or on any land or water so that the hazardous waste or any constit-
uent of it may enter the environment or be emitted into the air or
discharged into any waters, including ground water.
DISPOSAL FACILITY means a facility or part of a facility at which
hazardous waste is intentionally placed into or on land or water, and
at which hazardous waste will remain after closure.
EFFLUENT LIMITATION means any restriction imposed by the
Director on quantities, discharge rates, and concentrations of pollu-
tants which are discharged from point sources into waters of the
United States, the waters of the continguous zone, or the ocean.
EFFLUENT LIMITATION GUIDELINE means a regulation published
by the Administrator under Section 304(b) of the Clean Water Act to
adopt or revise effluent limitations.
ENVIRONMENTAL PROTECTION AGENCY
United States Environmental Protection Agency.
(EPA) means the
EPA IDENTIFICATION NUMBER means the number assigned by EPA
to each generator, transporter, and facility.
EXEMPTED AQUIFER means an aquifer or its portion that meets the
criteria in the definition of USDW, but which has been exempted ac-
cording to the procedures in 40 CFR Section 122.35(b).
EXISTING HWM FACILITY means a Hazardous Waste Management
facility which was in operation, or for which construction had com-
menced, on or before October 21, 1976. Construction had commenced
if (A) the owner or operator had obtained all necessary Federal, State,
and local preconstruction approvals or permits, and either (B1) a con-
tinuous on—site, physical construction program had begun, or (B2)
the owner or operator had entered into contractual obligations, which
could not be cancelled or modified without substantial loss, for con-
struction of the facility to be completed within a reasonable time.
(NOTE: This definition reflect* the literal language of the statute.
However, EPA believes that amendments to RCRA now in conference
will shortly be enacted and will change the t" 'to for determining when
a facility is an "existing facility" to one no earlier than May of 1980;
indications an the conferees an considering October 30, 1980.
Accordingly, EPA encourages every owner or operator of a facility
which was built or under construction as of the promulgation date of
the RCRA program regulations to file Part A of its permit application
so that it can be quickly processed for interim status when the change
in the law takes effect. When those amendments are enacted, EPA will
amend this definition.)
EXISTING SOURCE or EXISTING DISCHARGER (in the NPDES
program) means any source which is not a new source or a new dis-
charger.
1-7
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SECTION D - GLOSSARY (continued)
EXISTING INJECTION WELL means an injection well other than a
new injection welt.
FACILITY means any HWM facility, UIC underground injection well,
NPDES point source, PSD stationary source, or any other facility or
activity (including land or appurtenances thereto) that is subject to
regulation under the RCRA, UIC, NPDES, or PSD programs.
FLUID means material or substance which flows or moves whether in
a semisolid, liquid, sludge, gas, or any other form or state.
GENERATOR means any person by site, whose act or process produces
hazardous waste identified or listed in 40 CFR Part 261.
GROUNDWATER means' water below the land surface in-a zone of
saturation.
HAZARDOUS SUBSTANCE means any of the substances designated
under 40 CFR Part 116 pursuant to Section 311 of CWA. (NOTE:
These substances are listed in Table 2c~4 of the instructions to Form
2C.)
HAZARDOUS WASTE means a hazardous waste as defined in 40 CFR
Section 261.3 published May 19.1980.
HAZARDOUS WASTE MANAGEMENT FACILITY (HWM facility)
means all contiguous land, structures, appurtenances, and improve-
ments on the land, used for treating, storing, or disposing of hazardous
wastes. A facility may consist of several treatment, storage, or disposal
operational units (for example, one or more landfills, surface impound-
ments, or combinations of them).
IN OPERATION means a facility which is treating, storing, or disposing
of hazardous waste.
INCINERATOR tin the RCRA program) means an enclosed device
using controlled flame combustion, the primary purpose of which is to
thermally break down hazardous waste. Examples of incinerators are
rotary kiln, fluidized bed, and liquid injection incinerators.
INDIRECT DISCHARGER means a nondomestic discharger introduc-
ing pollutants to a publicly owned treatment works.
INJECTION WELL means a well into which fluids are being injected.
INTERIM AUTHORIZATION means approval by EPA of a State
hazardous waste program which has met the requirements of Section
3006(c) of RCFtA and applicable requirements of 40 CFR Part 123,
Subparts A, B, and F.
LANDFILL means a disposal facility or part of a facility where hazard-
ous waste is placed in or on land and which is not a land reatment
facility, a surface impoundment, or an injection well.
LAND TREATMENT FACILITY (in the RCPA program) means a
facility or part of a facility at which hazardous watte is applied onto or
incorporated into the soil surface; such facilities are disposal facilities
if the waste will remain after closure.
LISTED STATE means a State listed by the Administrator under
Section 1422 of SDWA as needing a State UIC program.
MGD means millions of gallons per day.
MUNICIPALITY means a city, village, town, borough, county, parish,
district, association, or other public body created by or under State
law and having jurisdiction over disposal of sewage, industrial wastes,
or other wastes, or an Indian tribe or an authorized Indian tribal organ-
ization, or a designated and approved management agency under
Section 208 of CWA.
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES) means the national program for issuing modifying, revoking
and reissuing, terminating, monitoring, and enforcing permits and
imposing and enforcing pretreatment requirements, under Sections
307, 318, 402, and 405 of CWA. The term includes an approved
program.
NEW DISCHARGER means any building; structure, facility, or instal-
lation: (A) From which there is or may be a new or additional discharge
of pollutants at a site at which on October 18, 1972, it had never dis-
charged pollutants; (B) Which has never received a finally effective
NPDES permit for discharges at that site; and (C) Which is not a "new
source." This definition includes an indirect discharger which com-
mences discharging into waters of the United States. It also includes
any existing mobile point source, such as an offshore oil drilling rig,
seafood processing vessel, or aggregate plant that begins discharging
at a location for which it does not have an existing permit.
NEW HWM FACILITY means a Hazardous Waste Management facility
which began operation or for which construction commenced after
October 21, 1976.
NEW INJECTION WELL means a well which begins injection after a
UIC program for the State in which the well is located is approved.
NEW SOURCE tin the NPDES program) means any building, structure,
facility, or installation from which there,is or may be a discharge of
pollutants, the construction of which commenced:
A. After promulgation of standards of performance under Section
306 of CWA which are applicable to such source; or
B. After proposal of standards of performance in accordance with
Section 306 of CWA which are applicable to such source, but only if
the standards are promulgated in accordance with Section 306 within
120 days of their proposal.
NON-CONTACT COOLING WATER means water used to reduce
temperature which does not come into direct contact with any raw
material, intermediate product, waste product (other than heat), or
finished product.
OFF-SITE means any site which is not "on—site."
ON—SITE means on the same or geographically contiguous property
which may be divided by public or private right(W—of—way, provided
the entrance and exit between the properties is at a cross—roads inter-
section, and access is by crossing as opposed to going along, the
rightW—of—way. Non—contiguous properties owned by the same per-
son, but connected by a right—of—way which the person controls and
to which the public does not have access, is also considered on—site
property.
OPEN BURNING means the combustion of any material without the
following characteristics:
A. Control of combustion air to maintain adequate temperature for
efficient combustion;
B. Containment of the combustion—reaction in an enclosed device
to provide sufficient residence time and mixing for complete com
bustion; and
C. Control of emission of the gaseous combustion products.
(See also "incinerator"and "thermal treatment").
OPERATOR means the person responsible for the overall operatioi
of a facility.
OUTFALL means a point source.
OWNER means the person who owns a facility or part of a facility
t-8
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SECTION D - GLOSSARY (continued)
PERMIT means an authorization, license, or equivalent control docu-
m«nt issued by EPA or an approved State to implement the require-
ments of 40 CFR Parts 122, 123, and 124.
PHYSICAL CONSTRUCTION (in the RCRA program) means excava-
tion, movement of earth, erection of forms or structures, or similar
activity to prepare a HWM facility to accept hazardous waste.
PILE means any noncontainerized accumulation of solid, nonflowing
hazardous waste that is used for treatment or storage.
POINT SOURCE means any discernible, confined, and discrete convey-
ance, including but not limited to any pipe, ditch, channel, tunnel,
conduit, well, discrete fissure, container, rolling stock, concentrated
animal feeding operation, vessel or other floating craft from which pol-
lutants are or may be discharged. This term does not include return
flows from irrigated agriculture.
POLLUTANT m'eans dredged spoil, solid waste, incinerator residue,
filter backwash, sewage, garbage, sewage sludge, munitions, chentical
waste, biological materials, radioactive materials (except those regulated
under the Atomic Energy Act of 1954. as amended [42 U.S.C. Section
2011 et seq.Ji. heat, wrecked or discarded equipment, rocks, sand,
cellar dirt and industrial, municipal, and agriculture waste discharged
into water. It does not mean:
A. Sewage from vessels; or
B. Water, gas, or other material which is injected into a well to facili-
tate production of oil or gas, or water derived in association with oil
and gas production and disposed of in a well, if the well used either
to facilitate production or for disposal purposes is approved by
authority of the State in which the well is located, and if the State
determines that the injection or disposal will not result in the degrada-
tion of ground or surface water resources.
(NOTE: Radioactive materials covered by the Atomic Energy Act are
those encompassed in its definition of source, byproduct, or special
nuclear materials. Examples of materials not covered include radium
and accelerator produced isotopes. See Train v. Colorado Public
Interest Research Group, Inc., 426 U.S. 1 [1976]. >
PREVENTION OF SIGNIFICANT
the national permitting program under 40 CFR 52.21 to prevent emis-
sions of certain pollutants regulated under the Clean Air Act from signi-
ficantly deteriorating air quality in attainment areas.
PRIMARY INDUSTRY CATEGORY means any industry category list-
ed in the NRDC Settlement Agreement (Natural Resources Detente
Council v. Train, 8 ERC 2120 [D.D.C. 1976], modified 12 ERC 1833
[D.D.C. 1979]).
PRIVATELY OWNED TREATMENT WORKS means any device or
system which is: (A) Used to treat wastes from any facility whose
operator is not the operator of the treatment works; and (B) Not a
POTW.
PROCESS WASTEWATER means any water which, during ma. ufactur-
ing or processing, comes into direct contact with or results from the
production or use of any raw material, intermediate product, finished
product, byproduct, or waste product.
'UBLICLY OWNED TREATMENT WORKS or POTW meant any de-
rice or system used in the treatment (including recycling and reclame-
'ion! of municipal sewage or industrial wastes of a liquid nature which
s owned by a State or municipality. This definition includes any sew-
srs, pipes, or other conveyances only if they convey wastewater to a
'OTW providing treatment.
1ENT means use of another's property in return for regular payment.
ICRA means the Solid Waste Disposal Act as amended by the Resource
:onservation and Recovery Act of 1976 (Pub. L 94-580, as amended
y Pub. L 95-609, 42 U.S.C. Section 6901 etseoj.
ROCK CRUSHING AND GRAVEL WASHING FACILITIES are facil-
ities which process crushed and broken stone, gravel, and riprap (see
40 CFR Part 436, Subpart B, and the effluent limitations guidelines
for these facilities).
SDWA means the Safe Drinking Water Act (Pub. L. 95-523, as amend-
ed by Pub. L 9S-19OO, 42 U.S.C. Section 300[f] etseqj.
SECONDARY INDUSTRY CATEGORY means any industry category
which is not a primary industry category.
SEWAGE FROM VESSELS means human body .wastes and the wastes
from tiolets and other receptacles intended to receive or retain body
wastes that are discharged from vessels and regulated under Section 312
of CWA, except that with respect to commercfal vessels on the Great
Lakes this term includes graywater. For the purposes of this definition,
"graywater" means galley, bath, and shower water.
SEWAGE SLUDGE means the solids, residues, and precipitate separat-
ed from or created in sewage by the unit processes of a POTW. "Sew-
age" as used in this definition means any wastes, including wastes from
humans, households, commercial establishments, industries, and storm
water runoff, that are discharged to or otherwise enter a publicly
owned treatment works.
SILVICULTURAL POINT SOURCE means any discernable, confined,
and discrete conveyance related to rock crushing, gravel washing, log
sorting, or log storage facilities which are operated in connection with
silvicultural activities and from which pollutants are discharged into
waters of the United States. This term does not include nonpoint
source silvicultural activities such as nursery operations, site prepara-
tion, reforestation and subsequent cultural treatment, thinning^ pre-
scribed burning, pest and fire control, harvesting operations, surface
drainage, or road construction and maintenance from which there is
natural runoff. However, some of these activities (such as stream cross-
ing for roads) may involve point source discharges of dredged or fill
material which may require a CWA Section 404 permit. "Log sorting
and log storage facilities" are facilities whose discharges result from the
holding of unprocessed wood, e.g., logs or roundwood with bark or
after removal of bark in self—contained bodies of water (mill ponds or
log ponds) or stored on land where water is applied intentionally on
the logs (wet decking). (See 40 CFR Part 429, Subpart J, and the efflu-
ent limitations guidelines for these facilities.l
STATE means any of the 50 States, the District of Columbia, Guam,
the Commonwealth of Puerto Rico, the Virgin Islands, American
Samoa, the Trust Territory of the Pacific Islands (except in the case of
RCRA), and the Commonwealth of the Northern Mariana Islands
(except in the case of CWA).
STATIONARY SOURCE (in the PSD program) means any building,
structure, facility, or installation which emits or may emit any air pol-
lutant regulated under the Clean Air Act. "Building, structure, facility,
or installation" means any grouping of pollutant-emitting activities
which are located on one or more contiguous or adjacent properties
and which are owned or operated by the same person (or by persons
under common control J.
STORAGE (in the RCRA program) means the holding of hazardous
waste for a temporary period at the end of which the hazardous waste
is treated, disposed, or stored elsewhere.
STORM WATER RUNOFF means water discharged as a result of rain,
snow, or other precipitation.
SURFACE IMPOUNDMENT or IMPOUNDMENT means a facility or
part of a facility which is a natural topographic depression, manmade
excavation, or diked area formed primarily of earthen materials (al-
though it may be lined with manmade materials), which is designed to
hold an accumulation of liquid wastes or wastes containing free liquids,
and which is not an injection well. Examples of surface impoundments
are holding, storage, settling, and aeration pits, ponds, and lagoons.
TANK (in the RCRA program) means a stationary device, designed to
contain an accumulation of hazardous waste which is constructed pre-
marily of non—earthen materials (e.g., wood, concrete, steel, plastic)
which provide structural support.
1-9
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SECTION D - GLOSSARY (continued)
THERMAL TREATMENT (in the RCRA program) means the treat-
ment of hazardous waste in a device which uses elevated temperature as
the primary means to change the chemical, physical, or biological char-
acter or composition of the hazardous waste. Examples of thermal
treatment processes are incineration, molten salt, pyrolysis, calcination,
wet air oxidation, and microwave discharge. (See also "incinerator" and
"open burning").
TOTALLY ENCLOSED TREATMENT FACILITY (in the RCRA pro:
gram} means a facility for the treatment of hazardous waste which is di-
rectly connected to an industrial production process and which is con-
structed and operated in a manner which prevents the release of any
hazardous waste or any constituent thereof into the environment dur-
ing treatment. An example is a pipe in which waste acid is neutralized.
TOXIC POLLUTANT means any pollutant listed as toxic under Section
307(a)(1)of CWA.
TRANSPORTER (in the RCRA program) means a person engaged in
the off-site transportation of hazardous waste by air, rail, highway, or
water.
TREATMENT (in the RCRA program) means any method, technique,
or process, including neutralization, designed to change the physical,
chemical, or biological character or composition of any hazardous
waste so as to neutralize such waste, or so as to recover energy or ma-
terial resources from the waste, or so as to render such waste non-haz-
ardous, or less hazardous; safer to transport, store, or dispose of; or
amenable for recovery, amenable for storage, or reduced in volume.
UNDERGROUND INJECTION means well injection.
UNDERGROUND SOURCE OF DRINKING WATER or USDW means
an aquifer or its portion which is not an exempted aquifer and:
A. Which supplies drinking water for human consumption; or
B. In which the ground water contains fewer than 10,000 mg/l total
dissolved solids.
UPSET means an exceptional incident in which there is unintentional
and temporary noncompliance with technology—based permit effluent
limitations because of factors beyond the reasonable control of the
permittee. An upset does not include noncompliance to the extent
caused by operational error, improperly designed treatment facilities,
inadequate treatment facilities, lack of preventive maintenance, or care-
less or improper operation.
WATERS OF THE UNITED STATES means:
A. All waters which are currently used, were used in the past, or may
be susceptible to use in interstate or foreign commerce, including
all waters which are subject to the ebb and flow of the tide;
B. All interstate waters, including interstate wetlands;
C. All other waters such as intrastate lakes, rivers, streams (including
intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie
potholes, wet meadows, playa lakes, and natural ponds, the use,
degradation, or destruction of which would or could affect interstate
or foreign commerce including any such waters:
1. Which are or could be used by interstate or foreign travelers for
recreational or other purposes,
2. From which fish or shellfish are or could be taken and sold in
interstate or foreign commerce,
3. Which are used or could be used for industrial purposes by in-
dustries in interstate commerce;
D. All impoundments of waters otherwise defined as waters of the
United States under this definition;
E. Tributaries of waters identified in paragraphs (A) — (D) above;
F. The territorial sea; and
G. Wetlands adjacent to waters (other than waters that are themselves
wetlands) identified in paragraphs (A) - (F) of this definition.
Waste treatment systems, including treatment ponds or lagoons design
ed to meet requirement of CWA (other than cooling ponds as defines
in 40 CFR Section 423.11(m) which also meet trie criteria of thii
definition) are not waters of the United States. This exclusion applies
only to manmade bodies of water which neither were originally createc
in waters of the United States (such as a disposal area in wetlands) not
resulted from • the impoundments of waters of the United States
WELL INJECTION or UNDERGROUND INJECTION means the sub-
surface emplacement of fluids through a bored, drilled, or driven well,
or through a dug well, where the depth of the dug well is greater than
the largest surface dimension.
WETLANDS means those areas that are inundated or saturated by
surface or groundwater at a frequency and duration sufficient to sup-
port, and that under normal circumstances do support, a prevalence ol
vegetation typically adapted for life in saturated soil conditions. Wet-
lands generally include swamps, marshes, bogs, and similar areas
1-10
-------
O
c
a
m
40047'30" -
,*. Injection
VWelK
•' 'CENTRAL PROCESSING CO".
UTM GRID AND 1970 MAGNETIC NORTH
DECLINATION AT CENTER OF SHEET
Scat* 1:24,000
1000 OFMt
USGS Map Central City. Ohio
Location Map
Central Procasung Co.
Central City, Ohio
750 37' 30"
i Hamilton 9.4 miles
-------
^> "^ rrV
"'' *C .C ADDRESS,
\ \ \\v
.." _ n areas are spaced for elite type, i.e., 12 characters/inch).
FORM
&EPA
U.S. ENVIRONMENTAL PROTECTION AGENCY
GENERAL INFORMATION
Consolidated Permttt Program
(Read the "General Jnttructiont" before starting.)
If a preprinted label has bean provided, affix
it in the designated spece. Review the inform-
ation carefully; if any of it is incorrect, crass
through it and enter the correct data in the
appropriate fill—in area below. Also, if any of
the preprinted data is absent (the area to the
left of, the label space lists the information
that should appear), please provide it in the
proper fill—in areatsl below. If the label is
complete and correct, you need not complete
Items I, III, V, and VI (except VI-B which
must be completed regardless). Complete all
items if no label has been provided. Refer to
the instructions for detailed item descrip-
tions and for the legal authorizations under
which this data is collected.
,^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
HTPOLLUTANT CHARACTERISTICS
••••• —^—
INSTRUCTIONS: Complete A through J to determine whether you need to submit any permit application forms to the EPA. If you answer "yes" to any
questions, you must submit this form and the supplemental form listed in the parenthesis following the question. Mark "X" in the box in the third column
if the supplemental form is attached. If you answer "no" to each question, you need not submit any of these forms. You may answer "no" if your activity
it excluded from permit requirements; see Section C of the instructions. See also, Section D of the instructions for definitions of bold-faced terms.
Form Approves OMB No. J 58-H0175
I. EPA I.D. NUMBER
SPCCIPIC QUESTIONS
UAPK
SPECIFIC QUESTIONS
MARK -X"
A. It this facility a publicly owned treatment works
which results in a discharge to waters of the U.S.?
(FORM 2A)
8, Doe* or wilt this facility leither existing or proposed)
include a concentrated animal feeding operation or
aquatic animal production facility which results in a
discharge to waters of the U.S.? (FORM 2B)
C. Is this a facility which currently results in discharges
to waters of the U.S. other than those described in
A or B above? (FORM 2C> . . -
D. Is this a proposed facility (other than those described
in A or B above) which will result in a discharge to
. waters; of the U.S.? (FORM 2D) ... .
E. Does or will this facility treat, store, or dispose of
hazardous wastes? (FORM 3)
F. Do you or will you inject at this facility industrial or
municipal effluent below the lowermost stratum con-
taining, within one quarter mile of the well bore,
underground sources of drinking water? (FORM 4)
G. Do you or will you inject at this facility any produced
water or other fluids which are brought to the surface
in connection with conventional oil or natural gas pro-
duction, inject fluids used for enhanced recovery of
oil or natural gas, or inject fluids for storage of liquid
hydrocarbons? (FORM 4)
H. Do you or will you inject at this facility fluids for spe-
cial processes such as mining of sulfur by the Frasch
process, solution mining of minerals, in situ combus-
tion of fossil fuel, or recovery of geothermal energy?
(FORM 4)
Is this facility a proposed stationary source which is
one of the 28 industrial categories listed in the in-
structions and which will potentially emit 100 tons
per year of any air pollutant regulated under the
Clean Air Act and may affect or be located in an
attainment area? (FORM 5>
Is this facility a proposed stationary source which is
NOT one of the 28 industrial categories listed in the
instructions and which will potentially emit 250 tons
per year of any air pollutant regulated under the Clean
Air Act and may affect or be located in an attainment
i? (FORM 5)
"I. NAME OP FACILITY
A. NAME * TITLE (lott, flrit, A title)
V. FACILITY MAILING ADDRESS
r—r
A. STREET. ROUTE NO. OR OTHER SPECIFIC IDENTIFIER
I"1 ! I 1 1 T
T i i i r
•.COUNTY NAME
i—i—\—i—i—i—i—\—i—i—i—i—i—i—i—i—i—r
c- err* on TOWN
D. STATE
E. ZIP CODE
coUHTV CoBf
'I/ fcnotsvn J
"•A Form 3510-1 (6-80)
CONTINUE ON REVERSE
-------
CONTINUED FROM THE FRONT
VII. SIC COOES (4-c/ig/t. in order olpriority 1^
B. SECOND
(specify)
(specify)
O. FOURTH
VIII. OPERATOR .INFORMATION
A. NAME
I T I 1 1 I I I I I I I I I I I I 1 I I I I I I 1 I I | | I I I | | ( | } { j
B. ltth*nwn*H«t*tt In
Itwn VIII-A »l»th»
owner?
DYES. QMO
c. STATUS or OPERATOR (Enter the appropriate letter into the answer box; if "Other", specify.)
o. PHONE (area code * no.)
F « FEDERAL
S"STATE
P - PRIVATE
M - PUBLIC (other than federal or state)
0 • OTHER
(specify)
f. STREET OR P.O. BOX
I J I } I I 1 I I I I \
F. CITY OR TOWN
1 I I I
X EXISTING ENVIRONMENTAL PERMITS:
G.STATE
H. ZIP CODE
IX. INDIAN LANDj
Is the facility located on Indian lands?
EH YES- O NO.
A. NPDES (Discharges to Surface Water)
N
f i 1
D. PSD (Air Emissions from Proposed Sources)
I i I
». uic (Underground Infection of Fluids)
B, OTHBB (specify)
1« %m IV It
(specify)
c. RCKA (Htttordotu Wastes)
B. OTHER- (specify)
9 R
aftl •
o»lTCT^j?Jljj
(specify}
Attach to this application a topographic map of the area extending to at (east one mile beyond property bounderies. The map must show
the outline of the facility, the location of each of its existing and proposed intake ami discharge structures, each of its hazardous waste
treatment, storage, or disposal facilities, and each well where it injects fluids underground. Include all springs, rivers and other surface
water bodies in the map area. See instructions for precise requirements.
XII. NATURE OF BUSINESS (provide abriit dmctiptionT
XIII. CERTIFICATION ft»r/«im
-------
United States
Environmental Protection
Agency
Office of Water and
Hazardous Waste
Washington, DC 20460
EPA Form 3510-3
June 1980
Solid Waste
r/EPA
Application Form 3 -
Hazardous Waste Information
Consolidated Permits Program
This form must be completed by all persons applying for
an EPA hazardous waste permit.
-------
-------
FORM 3 - GENERAL INFORMATION
This form must be completed by ail applicants who check "yes" to
Item II—E in Form 1.
Permit Application Process
There are two parts to a RCRA permit application — Part A and Part B.
Part A consists of this form and Form 1 of the Consolidated Permit
Application. Part B requires detailed site—specific information such as
geologic, hydrologic, and engineering data. 40 CFR 122.25 specifies
the information that will be required from hazardous waste manage-
ment facilities in Part B.
RCRA established a procedure for obtaining "interim status" which
allows existing hazardous waste management facilities to continue their
operations until a final hazardous waste permit is issued. In order to
qualify for interim status, existing hazardous waste management facil-
ities must submit Part A of the permit application to EPA within six
months after the promulgation of regulations under Section 3001 of
RCRA !40 CFR Part 2611. In order to receive a hazardous waste per-
mit, existing facilities must submit a complete Part B within six months
after it is requested by EPA. New facilities must submit both Part A
and Part B to EPA at least 180 days before physical construction is
expected to commence.
Operation During Interim Status
As provided in 40 CFR 122.23(b), Part A of the permit application
defines the processes to be used for treatment, storage, and disposal of
hazardous wastes; the design capacity of such processes; and the speci-
fic hazardous wastes to be handled at a facility during the interim status
period. Once Part A is submitted to EPA, changes in the hazardous
wastes handled, changes in design capacities, changes in processes, and
changes in ownership or operational control at a facility during the in-
terim status period may only be made in accordance with the proce-
dures in 40 CFR 122.23(c). Changes in design capacity and changes in
processes require prior EPA approval. Changes in the quantity of waste
handled at a facility during interim status can be made without sub-
mitting a revised Part A provided the quantity does not exceed the de-
sign capacities of the processes specified in Part A of the permit appli-
;ation. Failure to furnish all information required to process a permit
application is grounds for termination of interim status.
Confidential Information
Ml information submitted in this form will be subject to public dis-
:losure, to the extent provided by RCRA and the Freedom of Inform-
ition Act, 5 U.S.C. Section 552, and EPA's Business Confidentiality
Regulations, 40 CFR Part 2 (see especially 40 CFR 2.305). Persons
ilmg this form may make claims of confidentiality. Such claims must
>e clearly indicated by marking "confidential" on the specific informa-
lon on the form for which confidential treatment is requested or on
ny attachments, and must be accompanied, at the time of filing, by a
written substantiation of the claim, by answering the following ques-
tons:
Confidential Information (continuedI
A. Which portions of the information do you claim are entitled to
confidential treatment?
B. For how long is confidential treatment desired for this informa-
tion?
C. What measures have you taken to guard against undesired dis-
closure of the information to others?
D. To what extent has the information been disclosed to others, and
what precautions have been taken in connection with that disclosure?
E. Has EPA or any other Federal agency made a pertinent confident-
iality determination? If so, include a copy of such determination or
reference to it, if available.
F. Will disclosure of the information be likely to result in substantial
harmful effects on your competitive position? If so, what would those
harmful effects be and why should they be viewed as substantial?
Explain the causal relationship between disclosure and the harmful
effects.
Information covered by a confidentiality claim and the above sub-
stantiation will be disclosed by EPA only to the extent and by means
of the procedures set forth in 40 CFR Part 2.
If no claim of confidentiality or no substantiation accompanies the in-
formation when it is submitted, EPA may make the information avail-
able to the public without further notice to the submitter.
Definitions
Terms used in these instructions and in this form are defined in the
Glossary section of the instructions to Form 1. For additional defini-
tions and procedures to use in applying for a permit for a hazardous
waste management facility, refer to the regulations promulgated under
Section 3005 of RCRA and published in 40 CFR Parts 122 and 124.
FORM 3 LINE-BY-LINE INSTRUCTIONS
ompleting This Form
ease type or print in the unshaded areas only. Some items have small
aduation marks or boxes in the fill—in spaces. These marks indicate
ie number of characters that may be entered into our data system.
*ie marks are spaced at 1/6" Intervals which accommodate elite type
2 characters per inch — one space between letters!. If you do not
ive a typewriter with elite type then please print, placing each charac-
r between the marks. Abbreviate if necessary to stay within the num-
r of characters allowed for each item. Use one space for breaks be-
'een words, but not for punctuation marks unless the space is needed
clarify your information.
urn I
listing hazardous waste management facilities should enter their
'A Identification Number (if known!. New facilities should leave this
m blank.
Item II
A. FIRST APPLICATION. If this is the first application that is being
filed for the facility place an "X" in either the Existing Facility box
or the New Facility box.
1. EXISTING FACILITY. Existing facilities are:
a. Those facilities which received hazardous waste for treatment,
storage, and/or disposal on or before October 21, 1976; or
b. Those facilities for which construction had commenced on or
before October 21, 1976. Construction had "commenced" only if:
(1) The owner or operator had obtained all necessary Federal,
State, and local preconstruction approvals or permits: and
3-1
-------
FORM 3 LINE-BY-LINE INSTRUCTIONS (continued)
Item II (continued)
(2-a) A continuous physical, on—site construction program bad-
begun (facility design or other preliminary non—physical and
non-site specific, preparatory activities do not constitute an
on—site construction programl, or
(2-b)- The owner or operator had entered into contractual obliga-
tions (options- to purchase or contracts for feasibility, engineering,
and design studies do not constitute contractual obligations)
which could not be cancelled or modified without substantial
loss. Generally, a loss is deemed substantial if the amount an own-
er or operator must pay to cancel construction agreements or stop
construction exceeds 10% of the total project cost.
(NOTE: This definition of "existing facility" reflects the literal
language of the statute. However, EPA believes that amendments
to RCRA now in conference will shortly be enacted and will change
the date for determining when a facility is an "existing facility" to
one no earlier than May of 1980; indications are the conferees are
considering October 30, 1980. When those amendments are enacted,
EPA will amend the definition of "existing facility."
Accordingly. EPA encourages every facility built or under construc-
tion on the promulgation date of the RCRA program regulations to
notify EPA and file Part A of the permit application so that it can be
quickly processed for interim status when the change in the law takes
effect I
EXISTING FACILITY DATE. If the Existing Facility box is mark-
ed, enter the date hazardous waste operations began (i.e., the date
the facility began treating, storing, or disposing of hazardous waste)
or the date construction commenced.
2. NEW FACILITY. New facilities are all facilities for which construc-
tion commenced, or will commence, after October 21, 1976.
NEW FACILITY DATE. If the New Facility box is marked, enter
the date that operation began or is expected to begin.
B. REVISED APPLICATION. If this is a subsequent application that is
being filed to amend data filed in a previous application, place an "X"
in the appropriate box to indicate whether the facility has interim sta-
tus or a permit.
1. FACILITY HAS INTERIM STATUS. Place an "X" in this box
if this is a revised application to make changes at a facility during the
interim status period.
2. FACILITY HAS A PERMIT. Place an "X" in this box if this is
a revised application to make changes at a facility for which a permit
has been issued.
(NOTE: When submitting a revised application, applicants must
resubmit in their entirety each item on the application for which
changes are requested. In addition. Items I and IX [and Item X if ap-
plicable] must be completed. It is not necessary to resubmit informa-
tion for other items that will not change).
Item III
The information in Item III describe! all the processes that will be used
to treat, store, or dispose of hazardous waste at the facility. The design
capacity of each process must be provided as part of the description.
The design capacity of injection wells and landfills at existing facilities
should be measured as the remaining, unused capacity. See the form for
the detailed instructions to Item III.
Item IV
The information in Item IV describes all the hazardous wastes that
will be treated, stored, or disposed at the facility. In addition, the pro-
cesses that will be used to treat, store, or dispose of each waste and the
estimated annual quantity of each waste must be provided. See the
form for the detailed instructions to Item IV.
Item V
All existing facilities must include a drawing showing the general lay-
out of the facility. This drawing should be approximately to scale and
fit in the space provided on the form. This drawing should show the
following:
The property boundaries of the facility;
The areas occupied by all storage, treatment, or disposal operations
that will be used during interim status;
The name of each operation. /Example — multiple hearth incinerator,
drum storage area, etc.);
Areas of past storage, treatment, or disposal operations;
Areas of future storage, treatment, or disposal operations; and
The approximate dimensions of the property boundaries and all
storage, treatment, and disposal areas.
See Figure 3—1 for an example of a facility drawing. New facilities
do not have to complete this item.
Item VI
All existing facilities must include photographs that clearly delineate
all existing structures; all existing areas for storing, treating, or dis-
posing of hazardous waste; and all known sites of future storage,
treatment, or disposal operations. Photographs may be color or black
and white, ground—level or aerial. Indicate the date the photograph was
taken on the back of each photograph.
Item VII
Enter the latitude and longitude of the facility in degrees, minutes,
and seconds. For larger facilities, enter the latitude and longitude at
the approximate mid—point of the facility. You may use the map you
provided for Item XI of Form 1 to determine latitude and longitude.
Latitude and longitude information is also available from Regional
Offices of the U.S. Department of Interior, Geological Survey and
from State Agencies, such as the Department of Natural Resources.
Item VIII
Seethe form for the instructions to Item VIII.
Item IX and Item X
All facility owners must sign Item IX. If the facility will be operatec
by someone other than the owner, then the operator must sign Item X,
Federal regulations require the certification to be signed as follows:
A. For a corporation, by a principal executive officer at least the
level of vice president;
B. For a partnership or sole proprietorship, by a general partner o
the proprietor, respectively; or
C. For a municipality. State, Federal, or other public facility, b>
either a principal executive officer or ranking elected official..
The Resource Conservation and Recovery Act provides for sever
penalties for submitting false information on this application form
Ser'ion 3008(d) of the Resource Conservation and Recovery Ac
provides that "Any person who knowingly makes any false statemen
or representation in any application, . . . shall, upon conviction b
subject to a fine of not more than $25,000 for each day of violatior
or to imprisonment not to exceed one year, or both."
3-2
-------
---fnued from page 4
\ FACILITY DRAWING fsce page 41
EXAMPLE
Form Approved OMB No 158-S80004
u.
i
of.
lU
o-
Q
100
r
1
VAST
ll
L- • I
ISO f\.
\
AtROftIC
LANDHll
Z7S Ft.
r
LAWrtILL
I
300 Ft.
J
UJ
I
SCALti
=100FEtT
:PA Form 3510-3 (6-80)
FIGURE 3-1
-------
-------
Please print or type in the unshaded areas only
(fill-in areas are spaced for elite type, i.e., 12 characters/inch).
FbRM I
3
Form Approved OMB No. 158-S80004
oEPA
RCRA
FOR OFFICIAL USE ONLY
U.S. ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE PERMIT APPLICATION
Consolidated Permits Program
(Thii information it required under Section 3005 of RCRA.)
I. EPA I.D. NUMBER
APPLICATION DATE RECEIVED
APPROVED (yr.^rno,^ Aday)
II. FIRST OR REVISED APPLICATION
Place an "X" in the appropriate box in A or 8 below (mark one box only! to indicate whether this is the first application you are submitting for your facility or a
revised application. If this is your first application and you already know your facility's EPA I.D. Number, or if this is a revised application, enter your facility's
EPA 1.0. Number in Item I above.
A. FIRST APPLICATION (place an "X" b-'low and provide, the appropriate date)
| 11. EXISTING FACILITY (See instructions for definition of "existing" facility.
if Complete item below.)
.MO..
FOR EXISTING FACILITIES. PROVIDE THE DATE (yr., mo., & day)
OPERATION BEGAN OR THE DATE CONSTRUCTION COMMENCED
(uie the boxet-to the left)
FACILITY (Complete item below.)
FOR NEW FACILITIES.
PROVIDE THE DATE
(yr., mo., & day) OPERA-
TION BEGAN OR IS
EXPECTED TO BEGIN
7RC
_£
ISED APPLICATION (place an "X" below and complete Item I above!
t. FACILITY HAS INTERIM STATUS
I \Z. FACILITY HAS A RCRA PERMIT
III. PROCESSES - CODES AND DESIGN CAPACITIES
••••. ii i in i ..—.. - ,..— .. ...IP —....j*
A. PROCESS CODE — Enter the code from the list of process codes below that best describes each process to be used at the facility. Ten lines are provided for
entering codes. If more lines are needed, enter the codeW in the space provided. If a process will be used that is not included in the list of codes below, then
describe the process {Including to detign capacity> in the space provided on the form (Item III-C).
B. PROCESS DESIGN CAPACITY — For each code entered in column A enter the capacity of the process.
1. AMOUNT-Enter the amount.
2. UNIT OF MEASURE — For each amount entered in column BID, enter the code from the list of unit measure codes below that 'describes the unit of
measure used. Only the units of measure that are listed below should be used.
PROCESS
PRO- APPROPRIATE UNITS OF
CESS MEASURE FOR PROCESS
CODE DESIGN. CAPACITY
PROCESS
PRO- APPROPRIATE UNITS OF
CESS MEASURE FOR PROCESS
CODE DESIGN CAPACITY
Storage:
CONTAINER (barrel, drum, etc.)
TANK
WASTE PILE
SURFACE IMPOUNDMENT
Disposal:
INJECTION WELL
LANDFILL
LANO APPLICATION
OCEAN DISPOSAL
SURFACE IMPOUNDMENT
SOI GALLONS OR LITERS
SO2 GALLONS OR LITERS
S03 CUBIC YARDS OR
CUBIC METERS
SO4 GALLONS OR LITERS
D79 GALLONS OR LITERS
D»o ACRE-FEET (the volume that
would cover one acre to a
depth of one foot) OR
HECTARE-METER
D*1 ACRES OR HECTARES
DS2 GALLONS PER DAY OR
LITERS PER DAY
DS3 GALLONS OR LITERS
Treatment:
TANK
SURFACE IMPOUNDMENT
INCINERATOR
OTHER (U»e for physical, chemical,
thermal or biological treatment
processes not occurring In tank*,
surface impoundments or inciner-
ator*. Describe the processes In
the space provided; Item III-C.)
TO! GALLONS PER DAY OR
LITERS PER DAY
TO2 GALLONS PER DAY OR
LITERS PER DAY
TO3 TONS PER HOUR OR
METRIC TONS PER HOUR:
GALLONS PER HOUR OR
LITERS PER HOUR
T04 GALLONS PER DAY OR
LITERS PER DAY
UNIT OF
MEASURE
UNIT OF MEASURE CODE
GALLONS a
LITERS
CUBIC V
CUBIC N
GALLOr
EXAMPLE
ithercan t
.. i
(NUMBER
-1
-^
(
L
AH
1ST
••I
FC
10)0
DS y
>ER DAY u
)R COMPLETING ITEM III known in line
400 gallons. The facility also has an incint
r/A
DUP
U 14
A. PRO-
CESS
CODE
(from lift
above)
S
T
0
0
2
3
l« - IS
B. PF 1CESS DESIGN
t. AMOUNT
(OMClfy)
600
1
15.
UNIT OF UNIT OF
MEASURE MEASURE
UNIT OF MEASURE CODE UNIT OF MEASURE CODE
LITERS PER DAY
TONSP»R HOUR
METRIC TON* P*
GALLONS PER HC
LITERS PER HOU
numbers X-1 and X
irator that can burn
R H
>ur
OUR. W ACRES.
\ • HECTARES
A
F
B
a
2 below): A facility has two storage tanks, one tank can hold 200 gallons and the
up to 20 gallons per hour.
\\\\\\\\\\\\\\\\\\\\\\v
CAPACITY
20
'A Form 3B10-3 (6-80)
2. UNIT
OF MEA-
SURE
(enter
code)
G
E
at
FOR
OFFICIAL.
USE
ONLY
tt 1*
IulNE
(NUMBER
5
6
7
8
9
10
A. PR
CES
COD
(from
about
O*
s
E
lUt
t>
B. PROCESS DESIGN CAPACITY
1. AMOUNT
2. UNIT
OF MEA-
SURE
(enter
code)
_£•_
U
FOR
OFFICIAL
USE
OHL.Y
"
PAGE 1 OF 5 CONTINUE ON REVERSE
-------
Continued from the front.
III. PROCESSES (continued).
C. SPACE FOR ADDITIONAL. PROCESS CODES OR FOB DESCRIBING OTHER PROCESSES (code "T04"). FOR EACH PROCESS ENTERED HERE
INCLUDE DESIGN CAPACITY.
IV. DESCRIPTION OF HAZARDOUS WASTES
A. EPA HAZARDOUS WASTE NUMBER — Enter the four—digit number from 40 CFR, Subpart D for each listed hazardous waste you will handle. If you
handle hazardous wastes which are not listed in 40 CFR, Subpart D, enter the four—digit numberfef from 40 CFR, Subpart C that describes the characteris-
tics and/or the toxic contaminants of those hazardous wastes.
B. ESTIMATED ANNUAL QUANTITY - For each lifted watte entered in column A estimate the quantity of that waste that will be handled on an annual
basis. For each characteristic or toxic contaminant entered in column A estimate the total annual quantity of all the non—listed wasted that will be handled
which possess that characteristic or contaminant.
C. UNIT OF MEASURE — For each quantity entered in column B enter the. unit of measure code. Units of measure which must be used and the appropriate
codes are:
ENGLISH UNIT OF MEASURE
METRIC UNIT OF MEASURE
CODE
POUNDS.
TONS. . .
KILOGRAMS . .
METRIC TONS .
. K
. M
If facility records use any other unit of measure for quantity, the units of measure must be converted into one of the required units of measure taking into
account the appropriate density or specific gravity of the waste.
D. PROCESSES
1. PROCESS CODES:
For listed hazardous watt*: For each listed hazardous waste entered in column A select the coded) from the list of process codes contained in Item III
to indicate how the waste will be stored, treated, and/or disposed of at the facility.
For non-Jisted hazardous wastes: For each characteristic or toxic contaminant entered in column A, select the codefcj from the list of process codes
contained in Item III to indicate all the processes that will be used to store, treat, and/or dispose of all the non—listed hazardous wastes that possess
that characteristic or toxic contaminant.
Note: Four spaces are provided for entering ptoces* codes. If mom are needed: (t> Enter the first three as described above; (2) Enter "000" In the-
extreme right box of Item IV-D<1); and (3t Enter In the space provided on page 4, the line number and the additions) codtls),
2. PROCESS DESCRIPTION: If a code is not listed for a process that will be used, describe the process in the space provided on the form.
NOTE: HAZARDOUS WASTES DESCRIBED BY MORE THAN ONE EPA HAZARDOUS WASTE NUMBER - Hazardous wastes that can be described by
more than one EPA Hazardous Waste Number shall be described on the form as follows:
1. Select one of the EPA Hazardous Wast* Numbers and enter it in column A. On the same line complete columns B,C, and D by estimating the total annual
• quantity of the watte and describing all the- processes to be used to treat, store, and/or dispose of the waste.
2. In column A of the next line enter the other EPA Hazardous Waste Number that can be used to describe the waste. In column 0(2) on that line enter
"included with above" and make no other entries on trtr ine.
3. Repeat step 2 for each other EPA Hazardous Wast* NumLar that can be used to describe the hazardous waste.
EXAMPLE FOR COMPLETING ITEM IV (thown inlin»numbtn X-1, X-2. X-3, andX-4 Mow! - A facility will treat and dispose of an estimated 900 pound*
par year of chrome shavings from leather tanning and finishing operation. In addition, the facility will treat and dispose of three non—listed wastes. Two waste*
are corrosive only and there will be an estimated 200 pound* par year of each waste. The other watte is corrosive and ignitable and there will be an estimated
100 pounds par year of that watte. Treatment will be In an incinerator and disposal will be in a landfill.
Ill
56
JZ
X-1
X-2
X-3
X-4
A. EPA
HAZARD.
WASTE NO
(enter code)
K
D
D
D
0
0
0
0
5
0
0
0
4
2
1
2
B. ESTIMATED ANNUAL
QUANTITY OF WASTE
900
400
100
C.UNIT
OP MEA-
SURE
(enter
code;
P
P
P
D. PROCESSES
t . PROCESS COOES
(enter)
\ \
T 0 3
i i
T 0 3
T 0 3
i i
i i
D 8 0
D 8 0
D 8 0
i i
i i
i i
i i
i i
i i
i i
i i
2. PROCESS DESCRIPTION
(it a code ti not entered in D(ll)
included with above
EPA Form 3510-3 (6-80)
PAGE a OF 5
CONTINUE ON PAGI
-------
-: -uea from page 2.
"- TE Photocopy this page before completing if YOU have more than 26 wastes to list.
Form Approved OMB No r 58-580004
SPA l.o. NUMBER (enter from page 1)
'Ai
7V. DESCRIPTION
u
So
JZ
1
2
3
4
5
A. EPA
HAZARD.
WASTE NO
(enter code)
6
1
3
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
r/A
1
13
~\\
FOR OFFICIAL USE ONLY \ \ \ \ \ \ \
-M T/iH c \ \ \ \ \ \ x
W! DUP |2DUP\\\\\\\
l|2 13 14 1 t» "21 1 M_ \ \ V \ \ V V
OF HAZARDOUS WASTES (continued) "^^^^^^^^^^^^^^^^^^^^^^•••^••11™ ••"••m™
B. ESTIMATED ANNUAL
QUANTITY OF WASTE
:PA Form 3510-3 (6-80)
C. UNIT
OF MEA-
SURE
(enter
code)
D. PROCESSES
1. PROCESS CODES
(enter)
1 1
1 1
1 1
1 )
1 1
1 1
1 t
1 1
1 1
I 1
1 1
I 1
I 1
1 1
I 1
1 1
I 1
1 1
1 1
1 1
1 1
! 1
I 1
1 i
1 1
1 )
1 i
i I
1 I
i i
I i
1 l
1 1
1 1
1 I
™ 1 I1"
1 1
1 1
i i
1 1
1 1
1 t
i i
i i
i i
i i
I i
1 I
1 i
1 1
i i
i i
— i — r ••
t i
1 t
i 1
1 I
1 1
1 1
...., ^ ,
2. PROCESS DESCRIPTION
(if a code u not entered in D(l)>
\ .
CONTINUE ON REVERSE
PAGE 3 OF 5
(enter "A", "B", "C", etc. behind the "3" to identify photocopied pafet)
-------
Continued from the front
EPA I.D. NO. (enter from page I)
V. FACILITY DRAWING
All existing facilities must include in the space provided on page 5 a scale drawing of the facility (see instructions for more detail!.
IV. DESCRIPTION OF HAZARDOUS WASTES Icontwuedj
E. USE THIS SPACE TO LIST ADDITIONAL PROCESS CODES FROM ITEM DM) ON PAGE 3.
<^BB*BBi^HBi^Hil^^BlM^BMHHBHM^HBMBHHMBH^HMI^MiHHHHM^^Hi^H*^Mi[MBHHH«H
All existing facilities must include photographs (aerial or ground—level) that clearly delineate all existing structures; existing storage,
treatment and disposal areas; and sites of future storage, treatment or disposal areas (see instructions for more detail).
VII. FACILITY GEOGRAPHIC
LATITUDE (degrees, minutes, & seconds)
LONGITUDE (degrees, minutes, & seconds!
VIII. FACILITY OWNER
I 1 A. If the facility owner is also the facility operator as listed in Section VIII on Form 1, "General Information", place an "X" in the box to the left and
skip to Section IX below.
B. If the facility owner is not the facility operator as listed in Section VIII on Form 1, complete the following items:
2. PHONE NO. (area code & no.,'
f. NAME Of FACILITY'S LEGAL OWNER
3. STREET OR P.O. BOX
«. CITY OR TOWN
IX. OWNER CERTIFICATION
/ certify under penalty of law that I have personally examined and am familiar with the information submitted in this and all attached
documents, and that based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the
submitted information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment.
A. NAME (print or type)
B. SIGNATURE
C. DATE SIGNED
X. OPERATOR CERTIFICATION^
/ certify under penalty of law that I have personally examined and am familiar with the information submitted in this and all attached
documents, and that based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the
submitted information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment.
A. NAME (print or type)
B. SIGNATURE
C. DATE SIGNED
EPA Form 3510-3 (6-80)
PAGE 4 OF 5
CONTINUE ON PAGE
-------
from page 4
Form Approved OMB No 7 58-580004
\ . FACILITY DRAWING (see page 41
A Form 3510-3 (6-80)
PAGE 5 OF 5
-------
-------
APPENDIX B
CROSS REFERENCE OF
PART 122 REGULATIONS TO PART 270
B-l
-------
-------
Federal Register / Vol. 48. No. 64 / Friday. April 1. 1983 / Rules and Regulations 14149
List of Subjects
40 CFR Part 122
Administrative practice and
procedure, Reporting and recordkeeping
requirements. Water pollution control.
Confidential business information.
4O CFR Part 123
Indians—lands. Reporting and
recordkeeping requirements, Water
pollution control, Intergovernmental
relations, Penalties, Confidential
business information.
40 CFR Part 124
Administrative practice and
procedure, Air pollution control,
Hazardous materials, Waste treatment
and disposal, Water pollution control,
Water supply, Indians—lands.
40 CFR Part 125
Water pollution control. Waste
treatment and disposal.
40 CFR Part 144
Administrative practice and
procedure. Reporting and recordkeeping
requirements. Confidential business
information. Water supply.
40 CFR Part 145
Indians—lands, Reporting and
recordkeeping requirements,
Intergovernmental relations, Penalties,
Confidential business information.
Water supply.
40 CFR Part 148
Hazardous materials, Reporting and
recordkeeping requirements. Waste
treatment and disposal, Water supply.
40 CFR Part 233
Administrative practice and
procedure. Reporting and recordkeeping
requirements, Confidential business
information. Water supply, Indians—
lands, Intergovernmental relations,
Penalties, Confidential business
information.
40 CFR Part 260
Administrative practice and
procedure. Confidential business
information, Hazardous materials,
Waste treatment and disposal.
40 CFR Part 261
Hazardous materials, Waste
treatment and disposal. Recycling.
40 CFR Part 262
Hazardous materials, Imports,
Labeling, Packaging and containers,
Reporting and recordkeeping
requirements, Waste treatment and
disposal.
40 CFR Part 263
Hazardous materials transportation.
Waste treatment and disposal.
40 CFR Part 264
Hazardous materials, Packaging and
containers. Reporting and recordkeeping
requirements, Security measures, Surety
bonds. Waste treatment and disposal.
40 CFR Part 265
Hazardous materials. Packaging and
containers. Reporting and recordkeeping
requirements, Security measures. Surety
bonds. Waste treatment and disposal
Water supply.
40 CFR Part 270
Administrative practice and
procedure. Reporting and recordkeeping
requirements, Hazardous materials.
Waste treatments and disposal. Water
pollution control, Water supply,
Confidential business information.
40 CFR Part 271
Hazardous materials, Reporting and
recordkeeping requirements, Waste
treatment and disposal. Water pollution
control. Water supply,
Intergovernmental relations, Penalties,
Confidential business information.
Dated: March 16,1983.
John W. Hernandez,
Acting Administrator.
Authority: Clean Water Act, Safe Drinking
Water Act. Clean Air Act Resource
Conservation and Recovery Act: 42 U.S.C.
6905, 69T2, 0925, 6927. 6974.
Appendix
This appendix describes the
reorganization of former Parts 122 and
123. Four tables follow—one for each
program: NPDES, RCRA, UIC, 404. Each
table lists all provisions of former Parts
122 and 123 applicable to the particular
program and the new location at which
the provisions are now presented.
NPDES Program
Below is a list of the NPDES-related
sections in former Parts 122 and 123 and
their corresponding sections in new
Parts 122 and 123.
NtviM ww OKI
What are the consolidated permit
regulations?
5122.1
(a)..
(b).....
(d)
(f).—
Purpose and scope of Part 122
} 1222..._._.__. .._._.___.
(a) „.
New
122.1(c).
'22.1(g)
122.1(0.
Removed.
Name end oM
(b)
5122.3.
Application for s puirwl
5122.4...
(b) ___________
(c) ......... ---- .....
(d) __________________
(e) ______ .........
Continuation of expimg permits
§ 122.5 __
Signatories to permit appicMtona and
5 122.6
Conditions applicable to aft perm*
§ 122 7
EstaM
5122.8 .
5 '22.9...
g pern* condit
Duration of permits
(a)
(b) _.
(c)...._
(d).
(e) _._
Schedules of compliance
5 12i10
Requramsnte tar racorrjng and repoilliio
} 122.11
Considerations under Fedsral law
512Z12-...-
Effect of a permit
{ 122.13
Transfer of permits
; 122.14
Modification or revocation and
reveuance of parmM
{ 122.15-
(aXSXl)..
Teiiwiation of panwta
5 122.16 _
Minor modifications of permits
5 122.17
Noncompkance and program reporting by
neOrector
1122.18...-
(b)
(d)
(e)..
Confidentiality of information
$ 122.19 _
Purpose and tcooe of Subpart 0
§ 122.51
(a)
(cKD -
-------
14150
Federal Register / Vol. 48, No. 64 / Friday, April 1, 1983 / Rules and Regulations
Name and old
taClfHiet
1 122.55 .-...-..
Aquaculture projects
1 122*4
Separate storm sew-as
1 122.57
SiMaifturai acsvOes
1 122.58 ..._.„....._......_.....
General permits
1 12? S9 . , -,-•- ,., ,
NPOESpemMs
{12290
(a) —«« «.
(c)
(rt) „ „-,..,,--
(0
(g)
(h|._. „_„____ „
AddMtanal condNfona ^nilirriile to
speeded categones of NPOES permits
1122.61 -_
EsUbaaNng NPOES p«m* condWona
1199119 , , -— - , ,„--,
Catouhdlng NPOES parmM condWora
1122.63 ..
Duration of certain NPOES pern**
j 1??iu
(1) .,, .,,, ,
(b) „„. ,
(c)._
OKpotel of poHutante into weta. Mo
publicly owned MMnent works or by
land application
New tourcea and new dtehargera
1 12244 • »" --,
Purpose Mid scope
(ft)
(to
fey „ _ .„
(.
(23).
{ 123.45.
123-2S(a)(3)
Name and old
(15)
(16) _ _.
(17)
(18)
(19)
(2T4
(21)
(b)
(2)
(3)
(5) „
(7)
(B) .____
(9) _ _
(10) ,„ „
(12)
(13).._. , „
(14)
(15) „_..
(16) ._„„__ _.__ _—
(17) „.„____ .._..
(18) . ..• i
(19) „
(e) , , ,,,., ,,,
RequteiiierHs tor compliance evaluation
programs
{ 123* ..___.._.,..
Recjuiieiiieiili for enfforcemont authority
(tX-iHWMA) .,-,--,,.„ , ,—„„-,-
(aM3HH)(B) ...
(aK3M*KC)...
Sharing of mfuriiiaHon
Coordtataon with other programs
5 123.11 .._ _._
Approval process
1 123.12 -.._ .... -.. .-.
Procedures for revision of State
programs
JIM 13 , „„- ..-,--,„ - ----- ,
IfA | m ........
Criteria for withdrawal of State programs
Procedures for withdrawal of State
programs
1 123.15 . .
Purpose and scope
1 123.71 ... _„ .... .....
(a) ....-....._ —
(dj
Control of disposal of poUutanta into
weds
5 123 72 _
Receipt and use of Federal information
{12373 . -
Transmission of information to EPA
§ 123 74
EPA review of and detection* to State
pOfllNUI
j 123 75 _
Prohibitions
J 123 76 .. ........
Approval process
} 123.77 _.„..._„ .......
New
(24).
(25).
(26).
(27).
(28).
129).
00).
(31).
Removed.
Removed.
(aid).
w.
(6).
(7).
(8).
(9).
(10).
(11).
(12).
(13).
(15).
(16).
(17).
(20).
(32).
(33).
(34).
(36).
(37).
(b).
12326.
123.27.
(»H3)(i).
(ii)
Requirements for recording and
reporting of monitoring results
Considerations under Federal law
{ 122 12 ....
Effects of a permit
§12213 _ ..
Transfer of permits
8 122.14
Modification of revocation and
reissuance of penmut
K 122 15
Termination of poinuls
j 122.16 - — -..
Minor modification of permits
5122.17 _ _..
K 1 22. 1 7(f)(1 )
1 122.17(f)(2))
5 122.l7(t)(3)) -
by the director
5 122 18
J 122 18(c) .....
§ 122 18(cV(4) ..
Confidentiality of information
Purpose and scope of subpart C
(rewritten)
$ 12231 „ „.„...
Classification of wets
5 122.32
3 122.33
Prohibition of movement of ftud into
underground sources of drinking water
} 122 34
Identification of underground sources of
i 1 22.35...........
Elimination of certain class IV wets
1 1 22.36 „ . ,__„_
Authorization of underground infection
by rule
J 122. 37 . .
Mew
} 144.1.
{ 144.1.
{ 144.3.
{144.31.
Removed.
{ 144.31 (b).
{ 144.31(0).
} 144.31(e).
§ 144.31(f).
{ 144.37.
J144.32.
}144.51(aH1)
i 144.52(a).
f 144.S2IDX1M3*
J 144.52IC).
{144.36.
J 144.36(a).
5144.36(b).
J 144.36IC).
{ 144.53.
} 144.53(a«l|(i)
§ 144 53(aH2).
j 144.53(aK3).
5144.54.
J 144.4.
{14435.
{ 144.38.
{ 144.39.
{ 144.40.
} 144.41.
J14441(ei.
{ 144.41(0.
J 144.41(0.).
{ 144.8.
{ 144.8(b).
5 144.8(b)(2)
{ 144.8(0).
{1445.
{ 144.1.
1 1 44.6L
{144.11.
514412.
{ 144.7.
{ 144.13.
-------
Federal Register / Vol. 48, No. 64 / Friday, April 1, 1983 / Rules and Regulations
14151
Name and old
1 12£37(a)(1)
1 12237(1X2)
{12Z37(aX3). —
1 122.37(b) .._ .
f 122.37(0) -
1 122.37(d) .._.___
AppUcatton tor • parnilt authorization
by perm*
5 122.38(b)
$12238(c)
Arat permits
EnMig«ncy permit*
§ 1 22.40 ......
UCpamvs
$12911 -,„-„....
$192.41(a) --„„„„ , ,
f i?2.ii(h),, ,„.. ,
9 122.41(c)
} 122.41(d) ...„.....„..„. ....„.„...„..'.„.......
a 19241tot
51 29 A? „„ , ,,, ,
f 1 22.42(0)
{ 122.42(d) ._..._„._.___ „....
9122-42(e)
i 122.42(0
( 122.42(g) ,
( 122.42(1))
Waiver of requirements by director
} 199 4.1
Corrective action
( 122.44
Reguraments tor wetts injecting
hazardous mute
} 122.45
PiuiMulg&tlon of class ll programs tot
Man lands
| 1&41I .,„.„,.,., . . ..„ , ,
PuipoM and aoope
iiW-1-.,,,,,, ,
§ 199 1(«) ._,.„„,„„
}123.1(b).
{ 123 1(c)
(123.1(d)._
{123.1 (a)...
1 123.1(1) _.
f 123.1(9) ._. _™ .
{ 123.1(11) .. „
( 123.10) _
( 123.1 (D
Definitions
Elements Of a program SubmSSIOn
{123.3 _._
Program description
0 123.4 -„,.........„..
5 i23[4tei ZZZZZZ ZZZ"
Attorney General's statement
$ 123.5
Memorandum of agreement with the
roQtonot ftdnnntttl/AUw
{ 123.6 „ _..
ReQukojiieiilB tor permitting
J 123.7
} 123.7(«H1H21) _
New
J144.21.
914422.
} 144.23.
} 144.24.
{144.25.
{144.26.
9 144.15.
5 144.31(8).
} 144.31(0).
{ 144.31(g).
{144.33
1 144.34.
9144.51(8).
9 144.51(D42XI).
J 144.51(m).
] 144.51(1X6).
} 144.51).
9145.1(0.
9145.1(d).
91 45.31 (d).
9 145.21(e).
9 145.1(0.
Deleted.
9 145.21(0.
9 1-15.1(9).
9 145.2.
9 145.21.
9145.22.
9 145.22(0.
914523
5 145.24
§145.11.
5145.11(8X1)-
(21).
Name and old
{1237(eK1Hl2)
Requirements tor compliance evaluation
programs
5 123 8 „ . ..
Requrements for ontoicomont authority
{1239 „._
{ 123.9(aX3MiiXA)
5 123.9(a)(3)0iXB)
Snaring of information
{123 10
CoonJnaaon with other programs
( 1 23. 1 1 --,-
Approval process
{ 123.12 _
Procedure tor revision of Slate
fw»*ik*'W
{ 12313...... _
{123.13(0 .
Criteria tor withdrawal of State
programs
{ 123.14
Procedures tor withdrawal of Stale
programs
{ 123.15 ._.
( 123.15(a)..
Purpose and scope of subpart C
{ 123.51(8)... ...„_„„ _
9 123.51(b)
9 123.51(0) _._ „„__
}1MHaHc)
{ 123.54(d)
Procedures tor withdrawal of State UK
programs
} 123.55 _.
( 123.55-
(33).
9 145.12
9 145.13.
5 145.13(aX3)(i).
5 145.13(a)(3)-00
1 22. 1 5(a)(3)(H) . „.
122.15(aK5)
122.15(a)(6)
122.15(b) _
122 15(c) .... - _
Termination of permits
1 22. 1 6
1 22. 1 6(aX1 )
122.16(8X2)
1 22 1 6(ai(3)
122.16(8X4)
122 16(b)
Minor mouMcation of penmts
12217.
l22.17(aHd)
122 17(eHg)
122 I7fhl
New
Removed
233.3
233.4.
233.4
-------
14152 Federal Register / Vol. 48, No. 64 / Friday. April 1. 1983 / Rules and Regulations
OWnwne
NoncornpUane* and program reporting
by the director
122.10 .
122 18(cl
122 18(e)
Confidentiality of information
122.19 _ _..
122.19(a). - -
122.19(b)(i) —
122.19(bM2M3)
122.19(b)!4)
Purpose and loop*
123 1
123 1(a)
123 i(b) . „ „
123 1(c)
123.1(d)
123.1(el - -
123.1(f)
123.1(g) _ ,.
123 1(h) _ .- -
123 1(1)
123 1(0
Definitions
1232 „„._.._
Elemenla at a program submission
1233 _._...,
1?3 3(aHd) —
Program description
123 4 _ _
1?3 4(aMs) — • - •
1234
123.6(0 - - -
1 23.6(g) „
Requirements tor permitting
123 7 _
123.7(a) _
123 7(bWd) . .... . . ..
1 23 7(e) . . . ..
Requirements for enforcement
evaluation programa
1238 ~
1 23 8(aMd)
123 8(8) -
Requirements for enforcement authority
1239 _ _
123 9(a)(3) -
123 9(a)(3)OHS)
123.9(aM3)(iii)
Sharing of information
Coordination with other programs
123 1 1
Approval process
123.12 _.,..
Procedures for revision of State
programs
123.13
New
23317
Removed
23317(8)
Removed
233.17(b).
233.17(c).
233.18.
Removed.
233.18(a)<1)
Removed.
233.18(a)(3).
Removed.
233.20
233.20(a).
Removed.
233.20(0).
233.20(0)
233.20(d).
233,20(e)
233-20.
233.24(6X3.)
Removed.
233.24(bH4.)
233.24(0
Removed
Removed.
233.24M)
233 24(e).
233.26.
233-2613)
Removed.
23326(0).
23327.
233 27(aHd).
Removed.
233.28.
23a.26(a)l4).
Removed.
233 28)
(d) _„
(e) _ . ..
Schedules of compllanoe
{12210 _„
(3H3M4) ~ ~ -
Requirements for recording and mpuUiiy
of monitoring resutta
j 122 11 _
Consideration under Federal law
{, 122 12 .
Effect of a permit
§122.13 - -...
Transfer ot permta
j 122 14 .
Modification or revocation and
reosuanceof permits.
J12215 ,..,., T- „
(a)(7) „..„
Termination of permlta
} 122 18 -
Minor modifications of parmKs
512217 . «_ —
(•)(!)-(») -..••-
Noncompkance and program reporting by
the Director
$122 18
(C)
(e) - .
Confidentiality of information
$122 19
References
] 122.20 _
Purpose and scope of Sutapart 8
512221
(a) _..
.
270.13ffl.
270.13.
(aX2).
(bHO.
Removed
.
270.70-270.73.
270.70.
270.71(a>.
-------
APPENDIX C
LIST OF RECOMMENDED
PERMIT APPLICATION ATTACHMENTS
SURFACE IMPOUNDMENTS
Section Suggested Title
5.1.3 List of Hazardous Wastes
5.2.1.3 Liner System Design
5.2.2.3 Report Supporting Request for Exemption
from Liner Requirement
r
5.2.3.3 Design of System to Prevent Overtopping
5.2.4.3 Report of Structural Integrity of Dikes
5.2.5.3 Report Supporting Request from Exemption
from Ground-Water Protection Requirements
Double-Lined Surface Impoundments
5.3.1.3 Construction Inspection Plan
5.2.2.3 Operating Inspection Plan
5.4.3 Dike Certification
5.5.3 Contingency Plan
5.6.1.3 Closure Plan for Storage Surface
Impoundment
5.6.2.3 Closure Plan for Disposal Surface
Impoundment
5.6.3.3 Post-Closure Care Plan
5.7.3 Ignitable and/or Rective Waste Management
Plan(s)
5.8.3 Management Plan for Incompatible Wastes
C-l
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WASTE PILES
Se_9_ti_qn Suggeste d Title
6.1.3 List of Hazardous Wastes
6.2.1.3 Liner System Design
6.2.2.3 Leachate Collection and Removal System Design
6.2.3.3 Report Supporting Request for Exemption from
Liner and Leachate Collection and Removal
System Requirements
6.2.4.3 Run-On Control System Design
6.2.5.3 Run-Off Control System Design
6.2.6.3 Plan for Management of Units Associated with
Run-On and Run-Off Control
6.2.7.3 Wind Dispersal Control Plan
6.2.8.3 Report Supporting Request for Exemption from
Ground-Water Protection Requirements - Double-
Lined Piles
6.2.9.3 Report Supporting Request for Exemption from
Ground-Water Protection Requirements - Piles
With Inspectable Liners
6.3.1.3 Construction Inspection Plan
6.3.1.3 Operation Inspection Plan
6.3.1.3 Liner Inspection Plan
6.4.3 Report Supporting Request for Exemption from
Liner and Ground-Water Protection Requirements
6.5.3 Waste Treatment plan
6.6.3 Ignitable and/or Reactive Waste Management Plan(s)
6.7.3 Management Plan for Incompatible Wastes
6.8.3 Closure Plan
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LAND TREATMENT UNITS
Section Suggested Title
7.3.3.1 Treatment Demonstration Plan
7.4.3 Land Treatment Program
7.5.3 Design, Construction, Operation, and
Maintenance Plans
7.6.3 Food Chain Crop Demonstration Plan
7.7.3 Closure Plan
7.7.3 Post-Closure Plan
7.8.3 Ignitable and/or Reactive Waste Management
Plan
7.9.3 Management Plan for Incompatible Wastes
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LANDFILLS
Section Suggested Title
8.1.3 List of Hazardous Wastes
8.2.1.3 Liner System Design
8.2.2.3 Leachate Collection and Removal System
Design
8.2.3.3 Report Supporting Request for Exemption
from Liner and Leachate Collection and
Removal System Requirement
8.2.4.3 Run-on Control System Design
8.2.5.3 Run-off Control System Design
8.2.6.3 Plan for Management of Units Associated
with Run-on and Run-off Control
8.2.7.3 Wind Dispersal Control Plan
8.2.8.3 Report Supporting Request for Exemption
from Ground-Water Protection Requirements
for Double-Lined Landfills
8.2.9.3 Construction Inspection Plan
8.2.9.3 Operating Inspection Plan
8.3.3 Cover Design
8.4.3 Post-Closure Care Plan
8.5.3 Ignitable and/or Reactive Waste Management
Plan
8.6.3 Management Plan for Incompatible Waste
8.7.3 Liquid Waste Management Plan
8.8.3 Management Plan for Containers
8.9.3 Management Plan for Overpacked Drums
(Lab Packs)
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GROUND-WATER PROTECTION
Section Suggested Title
9.2.3.1 Interim Status Ground-Water Monitoring Data
9.6.3 Map of Detection Monitoring Wells
9.6.3 Plans and Specifications for Detection Monitoring
Wells
9.6.3 Sampling Techniques Including Flow Rate and
Direction Determinations
9.6.3 Sample Preservation and Shipping Procedures
9.6.3 Parameters to be Monitored and Sample
Analysis Protocols
9.6.3 Sample Chain of Custody Procedures
9.6.3 Procedures to Establish Background Values for
Ground Water
9.6.3 Statistical Procedures Used to Evaluate Changes
in Ground Water Parameters
9.7.3 List of Wastes Previously Handled
9.7.3 Map of Compliance Monitoring Wells
9.7.3 Plans and Specifications for Compliance
Monitoring Wells
9.7.3 Sampling Techniques Including Flow Rate and
Direction Determination
9.7.3 Sample Preservation and Shipping Procedures
9.7.3 Sample Analysis Protocols
9.7.3 Sample Chain of Custody Procedures
9.7.3 Characterization of Ground Water
9.7.3 Proposed Hazardous Constituent Concentration
Limits
9.7.3 Statistical Procedures Used to Evaluate Changes
in Ground-Water Parameters
-------
GROUND-WATER PROTECTION (Con't)
Section Suggested .Title
9.8.3 Map of Corrective Action Monitoring Wells
9.8.3 Plans and Specifications for Corrective Action
Monitoring
9.8.3 Sampling Techniques Including Flow Rate and
Direction Determinations
9.8.3 Sample Preservation and Shipping Procedures
9.8.3 Sample Analysis Protocols
9.8.3 Sample Chain of Custody Procedures
9.8.3 Statistical Procedures Used to Evaluate Changes
in Ground Water Parameters
9.8.3 Characterization of Ground Water
9.8.3 Proposed Hazardous Constituent Concentration
Limits
9.8.3 Plans and Specifications for Corrective Action
Plan
-------
APPENDIX D
GUIDE
SPECIFICATIONS
FOR
CONSTRUCTION
OF
FLEXIBLE MEMBRANE LINERS
FOR
HAZARDOUS WASTE DISPOSAL FACILITIES
FOREWORD
The following Guide Specifications represent an
effort to establish a comprehensive framework to
verify and document the construction of a flexible
membrane liner (FML) system for hazardous waste
disposal facilities. Some of the technical requirements
may have significant impact upon the FML industry
and review and comments should be solicited from
industry representatives.
D-l
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-2-
TABLE OF CONTENTS
Page
INTRODUCTION 5
1 FML CONSTRUCTORS 6
1.1 FML Manufacturer 6
1.2 FML Fabricator 6
1.3 FML Installer 6
2 FLEXIBLE MEMBRANE LINER 7
2.1 Raw Materials 7
2.2 Rolls 7
2.3 Blanket Fabrication 9
2.3.1 Blanket Geometry 9
2.3.2 Factor) -earning 9
3 INSTALLATION 11
3.1 Definition of Responsibilities 11
3.2 Surface Preparation 11
3.3 Handling of FML 12
3.3.1 Packaging 12
3.3.2 Transportation 12
3.3.3 On-site Storage 12
3.3.4 On-site Handling 12
3.3.5 Panel Placement 12
3.4 Considerations of Site Geometry 14
3.4.1 Layout Drawings 14
3.4.2 Anchor Trench 14
3.4.3 Installation Around Appurtenances 14
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-3-
TABLE OF CONTENTS
(continued)
3.5 Field Seaming 15
3.5.1 Requirements of Personnel 15
3.5.2 Overlapping 15
3.5.3 Preparation 15
3.5.4 Seaming Equipment and Products 15
3.5.5 Weather Conditions for Seaming 16
3.5.6 Seaming Procedure 16
3.5.7 Procedure for Seaming Wrinkles 17
3.5.8 Cap-Strips 18
3.6 Installation of Materials in Contact with
the Geomembrane 19
3.6.1 Granular Materials 19
3.6.2 Concrete 19
3.6.3 Geotextiles 20
QUALITY CONTROL AND INSPECTION 20
4.1 Materials 20
4.2 Factory Seams 20
4.2.1 Inspection 20
4.2.2 Non-Destructive Testing 21
4.2.3 Destructive Testing 22
4.3 Transportation, Handling and Placement 22
4.4 Field Seams 23
4.4.'l Field Seaming Operations 23
4.4.2 Test Seams 23
4.4.3 Non-Destructive Seam Testing 23
4.4.4 Destructive Seam Testing 24
4.4.5 Verification of Special Seams 25
4.5 Defects and Repairs 26
4.5.1 Identification 26
4.5.2 Evaluation 26
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-4-
TABLE OF CONTENTS
(continued)
Paee
4.5.3 Repair Procedures 26
4.5.4 Verification of Repairs 26
4.6 Documentation 27
4.6.1 Material Quality Control Certificates 27
4.6.2 Surface Preparation Certificate 27
4.6.3 Daily Fabrication Reports 27
4.6.4 Daily Field Installation Reports 27
5 PERFORMANCE REQUIREMENTS AND ACCEPTANCE OF INSTALLATION 28
5.1 Guarantees 29
5.2 Performance Expectations 29
5.3 Long Term Monitoring 29
5.3.1 Exterior Monitoring System 29
5.3.2 Leak Detection System 29
5.3.3 Leachate Collection (Specific For Land 29
Disposal Cells and Waste Piles)
5.3.4 Coupon Monitoring Program 29
5.4 FML Acceptance 30
NOTES 31
APPENDIX: DEFINITION OF TERMS 32
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-5-
INTRODUCTION
The Guide Specifications which follow are intended to be used by persons writing
specifications for the construction of a flexible membrane liner (FML) for land disposal
of hazardous wastes.
The specifications do not relate to design of the FML system but rather provide
guidelines for control and verification of construction of the designed FML system. The
guidelines are not all inclusive to the needs of each site but form a framework into which
site specific requirements can be inserted. Where appropriate, choices are provided,
with examples for high density polyethylene (HOPE), reinforced chlorosulfonated
polyethylene (CSPER, known as "Hypalon") and polyvinyl chloride (PVC).
These specifications have recognized the need to verify that the installed FML
must provide total containment of hazardous waste fluids. This recognition resulted in
requirements for thorough quality control during FML fabrication and installation, and
systematic documentation. Further, the recognition of the parties involved in FML
installation and the need for these parties of agree on individual responsibilities have
been highlighted.
Parties who may be involved with FML installation include: Designer, Earthwork
Constructor, FML Fabricator, FML Installer, FML Manufacturer, Inspector, Monitor,
Owner, Regulatory Authority, and Specifier. These terms are defined in the Appendix.
Each of these parties may be involved in FML installation, or responsibilities defined for
one party may be assumed by another party (ie, the FML Manufacturer may also be the
FML Fabricator).
Reference is made in the text to the test procedures of the American Society for
Testing and Materials (ASTM) and the Proposed Standards for Flexible Membrane Liners
of the National Sanitation Foundation (NSF).
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1 FML CONSTRUCTORS
1.1 FML Manufacturer
To demonstrate an ability to manufacture the FML rolls, the FML Manufacturer
shall provide the Monitor with a list of at least projects totaling a minimum of
hundreds of thousands irr (millions sq. ft), for which the FML Manufacturer supplied the
same generic type of FML. For each project, the following information shall be
provided: name and purpose of project, location, date, name of owner, designer, fabri-
cator, and installer, type of FML, thickness, surface area, and available written informa-
tion on the performance of the project.
1.2 FML Fabricator
The FML Fabricator shall be trained and qualified to fabricate the type of FML
to be used for the project. The FML Fabricator shall be an approved and/or licensed
Fabricator of the FML Manufacturer. A copy of the approval letter or license shall be
submitted to the Monitor.
To demonstrate an ability to fabricate FML, the FML Fabricator shall provide
the Monitor with a list of at least previous fabrications, totaling a minimum of
hundreds of thousands m2 (millions sq. ft), completed with the same generic type of
FML. For each fabrication, the following information shall be provided: name and
purpose of project, location, date, name of owner, designer, manufacturer, and installer,
type of FML, thickness, total amount of FML fabricated, type of seaming, and available
written information on the performance of the project. Also, the FML Fabricator shall
provide information on the factory size and equipment, and daily production quantity
available.
1.3 FML Installer
The FML Installer shall be trained and qualified to install the type of FML to be
used for the project. The FML Installer shall be an approved and/or licensed Installer of
the FML Manufacturer and/or FML Fabricator. A copy of the approval letter or license
shall be submitted to the Monitor.
To demonstrate an ability to install FML, the FML Installer shall provide the
Monitor with a list of at least previous installations, totaling a minimum of
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hundreds of thousands m2 (millions sq. ft). For each installation, the following infor-
mation shall be provided: name and purpose of project, location, date, name of owner,
designer, manufacturer, fabricator and leader of the installer's crew, type of FML,
thickness, surface area, type of seaming, duration of installation, and available written
information on the performance of the project.
2 FLEXIBLE MEMBRANE LINER
2.1 Raw Materials
The FML shall be manufactured of first quality newly produced raw materials.
The use of reclaimed polymers and other materials shall not be permitted. Recycling of
materials containing reinforcing scrim shall not be permitted. Recycling scrap that does
not contain scrim may be permitted.
The FML Manufacturer shall: (i) indicate the origin of raw materials; (ii) provide
a copy of quality control certificates issued by the producer of raw materials; and (iii)
provide reports on the tests conducted to verify the quality of the raw materials. These
tests should include at least:
Density (ASTM D792-66) and melt index (ASTM D 1238-79), for HOPE.
Analysis of the chemical composition of the plasticizers, for PVC.
2.2 Rolls
The FML rolls shall be designed and manufactured specifically for the purpose of
fluid containment. The FML shall be free of holes, blisters, undispersed raw materials,
and any sign of contamination by foreign matter.
The FML to be used for this project shall be mm ( mil) thick (mention
here the type of FML, such as HOPE; Hypalon; PVC). The FML shall meet the
specifications listed in Table 1. (Note 1)
The following information shall be provided by the FML Manufacturer as an
indication of the quality of the material supplied:
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-8-
Material properties sheet, pertaining to the FML to be used for the
project, (including data regarding chemical compatibility of the FML with
contacting fluids) shall be provided. The sheet should at least include all
properties listed in Table 1. The allowable range in values of properties
listed in the sheet must meet the specifications given in Table 1. The
sheet shall provide minimum properties guaranteed by the FML
Manufacturer and indicate test methods used. Unless otherwise specified,
test methods shall be in accordance with NSF Proposed Standards.
Quality control certificates pertaining to the rolls of material delivered
to the site shall accompany the rolls. Each roll shall be identified by a
unique manufacturing number. The quality control certificate shall
include results of at least the following tests: thickness, tensile charac-
teristics, and tear resistance (also, coefficient of thermal expansion-
contraction for HDPE) (also: hydrostatic burst resistance, and ply
adhesion, in the case of Hypalon). Unless otherwise necessary, test
methods shall be in accordance with NSF Proposed Standards. The quality
control certificates shall be signed by a responsible party employed by the
FML Manufact -er, such as production manager, and shall be notarized.
2.2 (Continued for Hypalon)
The FML Manufacturer shall indicate the composition of roll material. The
polymeric compound shall contain at least 45% by weight of "Hypalon type 45" as the
sole elastomer. The reinforcing scrim shall be defined by the number of yarns per unit
width (eg. per meter or per inch) in each direction and by the linear density (in kg/m, tex,
or deniers) of the yarns. The type of polymer used for the reinforcing scrim shall also be
indicated.
2.2 (Continued for unreinforced PVC)
The FML Manufacturer shall indicate the proportion by weight of plasticizers,
and the amount of volatile loss measured using ASTM D 1203, method A. The maximum
value of the volatile loss shall be . (Note: the NSF Proposed Standards recommend
0.7% for a 0.75 mm (30 mil) thick FML and 0.5% for a 1.15 mm (45 mil) thick FML;
values for other FML thicknesses may be interpolated or extrapolated beyond the
1.15 mm (45 mil) value).
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2.3 Blanket Fabrication
(Note: The entire section 2.3 shall be deleted if the rolls are not fabricated into
blankets in a plant. This is usually the case for HOPE FML.)
2.3.1 Blanket Geometry
The FML shall be fabricated into blankets. Blanket sizes shall be: (i) proposed
by the FML Fabricator; (ii) consistent with the instructions (if any) given by the
Designer; and (iii) approved by the Monitor and the FML Installer.
2.3.2 Factory Seaming
The rolls shall be fabricated into the designed blanket sizes using one of the
following seaming techniques: adhesive, heat seaming, or dielectric seaming.
The overlap shall provide the minimum required seam width (as indicated
below). The seam shall extend to the edge of the sheet, so that no loose flap is present
on the top side of the blanket. A loose flap is permissible on the bottom side of the
fabricated blanket.
The rolls shall be laid out without tension and seamed without wrinkles or fish-
mouths. If wrinkles occur within the sheet due to the seaming process, the wrinkle shall
not extend into the seamed width. Wrinkles which extend into the seamed width shall be
treated as specified in Section 3.5.7.
The overlap area to be seamed shall be free from moisture, dust, dirt, debris of
any kind, and foreign material. The fabrication area shall be in a clean, enclosed,
temperature controlled facility.
The dielectric and heat seaming devices shall be accurately monitored and
controlled at all times to effect a consistently acceptable seamed width. Dielectric bars
or wheels with ribs shall effect the full specified seam width. Space between the bar ribs
shall not be counted in the seam width.
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2.3.2 (Continued for Hypalon)
To effect a clean, bondable surface, the seam interfaces shall be cleaned with
trichlorethylene or perchlorethylene solvent before the Hypalon adhesive is applied. The
Hypalon based adhesive product for seaming the rolls together shall be as recommended
by the Hypalon FML Manufacturer. The adhesive product shall be applied as specified by
the Hypalon FML Manufacturer with special attention to the ambient temperature and
rolling pressure.
The minimum scrim-to-scrim seam widths shall be:
Hypalon based adhesive 50 mm (2 in.)
Heat seaming 25 mm (1 in.)
Dielectric seaming 25 mm (1 in.)
The minimum seam width shall be the scrim-to-scrim seam width, plus the
selvage width.
2.3.2 (Continued for PVC)
The PVC adhesive used for seaming the rolls together shall be as recommended
by the PVC FML Manufacturer and shall not be deleterious to the PVC FML material in
any way after seaming. The adhesive product shall be applied as specified by the PVC
FML Manufacturer with special attention to the ambient temperature and rolling
pressure. The adhesive shall have been tested for longevity in contact with the PVC FML
material and its application shall result in no appreciable stiffening of the FML.
Prepared adhesive tapes shall not be used.
The minimum seam widths shall be:
Unrein forced Reinforced
PVC adhesive seaming 25 mm (1 in.) 50 mm (2 in.)
Heat seaming 25 mm (1 in.) 25 mm (1 in.)
Dielectric seaming 20 mm (3/* in.) 25 mm (1 in.)
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-11-
3 INSTALLATION
3.1 Definition of Responsibilities
All parties involved with FML installation shall attend a meeting held prior to
installation of any FML. The purpose of this meeting is to: (i) define the responsibilities
of each party; (ii) establish lines of authority and lines of communication; (iii) establish
site specific quality control and monitoring procedures; and (iv) define the method of
acceptance of the completed liner. The meeting shall be documented and minutes trans-
mitted to all parties.
3.2 Surface Preparation
The upper 0.1 m (4 in.) of the supporting soil shall not contain stones larger than
25 mm (1 in.). The surface to be lined shall be rolled with a smooth drum steel or pneu-
matic roller so as to be free of irregularities, loose earth, and abrupt changes in grade.
The surface preparation shall be done by the Earthwork Constructor. The FML Installer
shall certify in writing that the surface on which the FML is to be installed is accept-
able. Thereafter, the FML Installer shall provide the necessary equipment and personnel
to maintain an acceptable soil surface during liner installation.
No FML shall be placed in an area which has become softened by precipitation
(ie, unconfined compressive strength less than 50 kPa (0.5 tsf)).
3.2 (Specific to surface preparation when the FML is supported on a soil liner)
Special care must be taken to maintain the prepared soil surface in areas where
the soil functions as an impermeable soil liner. The soil surface shall be observed daily
by the Monitor and FML Installer to evaluate desiccation cracking. The daily
observations shall also ascertain the effects of surface desiccation cracking upon the
integrity of the soil liner. Prior to installation of any FML, the Designer and Monitor
shall define in writing the maximum allowable crack depth and width which will not
significantly affect the soil liner design intent. The Monitor shall inform the FML
Installer of the requirements regarding crack depth and width. Precautions for reducing
desiccation potential (ie, temporary FML cover) and crack repairs shall also be defined
by the Designer and approved by the Monitor. (Note 2)
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3.3 Handling of FML
3.3.1 Packaging
FML rolls or blankets shall be packaged and labeled prior to shipment to the
site. The label shall indicate the FML Manufacturer, FML Fabricator, type of FML,
thickness, and roll or blanket number.
3.3.2 Transportation
When transported to the site, FML rolls or blankets shall be handled by appro-
priate means so that no damage is caused. Wooden cases shall be strong enough to
withstand impacts and rough handling without breaking or splintering.
Transportation shall be the responsibility of the FML Manufacturer (if fabrica-
tion is not required, which is usually the case of HOPE), or of the FML Fabricator (if
fabrication is required, which is usually the case of Hypalon and PVC).
3.3.3 On-site Storage
Once on-site, storage of the FML is the responsibility of the FML Installer. The
FML shall be protected from direct sunlight and heat to prevent degradation of the FML
material and adhesion of individual whorls of a roll or layers of a blanket.
Adequate measures shall be taken to keep FML materials away from possible
deteriorating sources (ie, vandalism, theft).
3.3.* On-site Handling
On-site handling of the FML is the responsibility of the FML Installer. Appro-
priate handling equipment shall be used when moving rolled or folded FML from one
place to another. Instructions for moving the FML shall be given by the FML Installer to
the workers and shall be approved by the Monitor.
3w3.5 Panel Placement
Each roll or blanket shall be redesignated with a panel number. A panel is the
unit area of in-place membrane which is to be seamed (ie, one roll may be cut into
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several panels). The FML shall be positioned on the site as shown in the layout
drawings. Instructions on the boxes or wrapping containing the FML materials shall be
followed to assure the panels are unrolled or unfolded in the proper direction for
seaming. Only the panels which are to be anchored or seamed together in one day shall
be unrolled or unfolded. Care shall be exercised to not damage the FML during this
operation. All workers shall wear shoes which will not damage the FML.
Pulling FML panels shall be minimized to reduce permanent tension.
The following precautions should be taken to minimize the risk of damage by
wind during panel placement:
No more than one panel should be unrolled prior to seaming (unless
authorized by the Monitor);
Work shall be oriented according to the direction of prevailing winds if
possible, unless otherwise specified;
Adequate loading on FML panels to prevent uplift by wind shall be
provided by sand bags, tires or any other means which will not damage the
FML. Along the edges, loading shall be continuous, to avoid possible wind
flow under the panels.
Any panels, which, in the judgement of the Monitor, become seriously damaged (torn or
twisted permanently), shall be replaced. Less serious damage should be repaired
according to Section *f.*.
FML placement shall not proceed at an ambient temperature below 5°C (
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-u-
3.3.* (Specific to PVC)
Unless otherwise specified, the PVC panels shall be installed in a slack unten-
sioned condition allowing for a 5% excess in each direction (unless otherwise specified).
3.4 Considerations of Site Geometry
3.4.1 Layout Drawings
The FML Installer shall produce layout drawings of the proposed FML placement
pattern and seams prior to FML placement. The drawings shall indicate the panel
configuration and location of seams. Field seams should be differentiated from factory
seams (if any). (Note 3)
3.4.2 Anchor Trench
The anchor trench (if required) shall be constructed to the lines and width shown
on the design drawings prior to FML placement. If clay soils, susceptible to desiccation,
will be encountered in the anchor trench, no more than one days trench length shall be
excavated in advance of the .;ML placement. Backfilling shall proceed rapidly, unless
otherwise specified, to minimize desiccation potential of the anchor trench clay soils.
3.4.3 Installation Around Appurtenances
The FML shall be installed around any pipes, piers, concrete pits (or other appur-
tenance protruding through the FML) as detailed on the design drawings. Unless other-
wise specified, a FML sleeve or shield shall initially be installed around each appur-
tenance, prior to the areal FML installation. After the FML has been placed and seamed,
the final field seam connection between the appurtenance sleeve or shield and the FML
shall be completed. A sufficient initial overlap of the appurtenance sleeve shall be
maintained so that shifts in location of the FML can be accomodated.
Installation on rough surfaces such as concrete shall be carefully performed to
minimize FML damage. Additional, loosely placed FML or geotextile sections may be
used by the FML Installer as protection for the FML if approved by the Monitor. (Note 4)
All clamps, clips, bolts, nuts or other fasteners used to secure the FML around
each appurtenance shall have a life-span equal to or exceeding the FML.
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3.5 Field Seaming
3.5.1 Requirements of Personnel
All personnel performing seaming operations shall be qualified by experience or
by successfully passing seaming tests.
At least one seamer shall have experience seaming at least one hundred thousand
m2 (1 million sq. ft.) of a FML of the same generic type as the FML used for the project
using the same type of seaming method. This master seamer shall provide direct super-
vision over apprentice seamers.
Apprentice seamers shall be qualified by attending training sessions taught by
the master seamer and performing at least two successful seaming tests under similar
weather conditions using the seaming method used for production seaming.
3.5.2 Overlapping
3.5.2 (Specific to HOPE)
The panels shall be overlapped a minimum of 75 mm (3 in.)
3.5.2 (Specific to Hypalon and PVC, Heat Seaming)
The panels shall be overlapped a minimum of 100 mm (4 in.)
3.5.3 (Specific to Hypalon and PVC, Adhesive Seaming)
The panels shall be overlapped a minimum of 150 mm (6 in.).
3*5.3 Preparation
Prior to seaming, the seam area shall be clean and free of moisture, dust, dirt,
debris of any kind, and foreign material.
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3.5.3 (Specific to HOPE)
The seam overlaps shall be ground according to the FML Manufacturer's instruc-
tions.
3.5.3 (Specific to Hypalon)
The seam overlaps shall be cleaned with thrichlorethylene or perchlorethylene in
accordance with the FML Manufacturer's instructions.
3,5,* Seaming Equipment and Products
3.5.4 (Specific to HOPE)
Each seaming unit must include thermometers giving the temperature of the
extrudate in the machine and at the nozzle.
3.5.4 (Specific to Hypalon and PVC, Heat Seaming)
The heat seaming device (hot air or hot wedge) shall include a thermometer
allowing the temperature to be monitored.
3.5.4 (Specific to Hypalon and PVC, Adhesive Seaming)
The adhesive (bodied solvent compound or cement) shall be formulated in accor-
dance with the FML Manufacturer's specifications.
3.5.5 Weather Conditions for Seaming
Weather conditions required for seaming are as follows: (i) no weld shall be done
below 1°C (34°F); (ii) between 1°C (34°F) and 10°C (50°F), seaming is possible if the
FML is preheated by either sun or hot air device, and if there is not excessive cooling
resulting from wind (as determined by the Monitor); and (iii) above 10°C (50°F), no pre-
heating is required. In all cases, the FML shall be dry.
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3.5.6 Seaming Procedure
Seaming on horizontal surfaces shall commence at the center of a panel side and
proceed to either end of a side (if possible) in an effort to reduce wrinkles and subsequent
fishmouths at the seam interface. The direction of seaming on slopes shall be the most
expedient direction for the type of seaming used. Seaming shall extend to the outside
edge of panels to be placed in the anchor trench.
If the supporting soil is soft, a firm substrate shall be provided by using a homo-
geneous board, a conveyor belt, or similar hard surface directly under the seam overlap
to effect proper rolling pressure.
3.5.6 (Specific to Hypalon and Reinforced PVC, Heat Seaming)
The width of the seam shall be 25 mm (1 in.) scrim to scrim. Then, the loose
upper flap shall be bonded using either a hot air gun or an adhesive (bodied solvent or
cement).
3.5.6 (Specific to Hypalon and PVC, Adhesive Seaming)
The width of the seam shall be 100 mm (^ in.) starting from the edge of the FML
placed on top (so there is no loose flap).
3.5.6 (Specific to Unreinforced PVC, Heat Seaming)
The width of the seam shall be 25 mm (1 in.) starting, if possible, from the edge
of the FML placed on top. Any loose flap shall be bonded using either a hot air gun or an
adhesive.
X3.7 Procedure for Seaming Wrinkles
Fishmouths or wrinkles at the seam overlaps shall be cut along the ridge of the
wrinkle back into the panel so as to effect a flat overlap. The cut fishmouths or wrinkles
shall be seamed as well as possible, and shall then be patched with an oval or round patch
of the same generic FML extending a minimum of 150 mm (6 in.) beyond the cut in all
directions.
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3.5.7 (Specific to Hypalon and PVC)
The patch shall be bonded over its entire area, using either a hot air gun or an
adhesive (bodied solvent or cement).
3.5.8 Cap-strips
Cap-strips shall be at least 75 mm (3 in.) wide and shall be centered over the
completed seam edge. Cap-strips shall be of the same generic FML material as the liner
but without reinforcing scrim. The thickness of cap-strip shall be mm ( mils) (at
least 0.75 mm (30 mils)).
Cap-strips shall shall be placed on all field seams. They shall be placed only
after quality control of the original seam has been performed.
3.5.8 (Specific to HOPE)
Cap-strips shall not be longer than 3 m (10 ft) long if they are not bonded over
their entire surface.
3.5.8 (Specific to Hypalon and PVC)
Cap-strips shall not be placed on a loose flap (loose flaps shall be bonded as
explained in Section 3.5.6). Cap-strips shall be bonded over their entire surface, using
hot air gun or adhesives (either bodied solvent or cement).
3.5.8 (Specific to Hypalon and Reinforced PVC)
Cap-strips shall be placed on all seams where the reinforcing scrim daylights: (i)
ends of rolls; (ii) tapered rolls in corners and other special locations of cells or ponds; and
(Hi) places where the unreinforced selvage is too narrow (smaller than 3 mm (1/8 in.)) or
has been damaged.
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3.6 Installation of Materials in Contact with the FML
3.6.1 Granular Materials
Granular materials (ie, for FML protection or as a leachate collection system)
shall be placed by the FML Installer or Earthwork Constructor at the direct supervision
of the FML Installer in a manner so as not to damage the FML.
Placement of a granular material layer shall commence after the FML anchor
trench (if any) has been completely backfilled and compacted and the leachate collection
sump structures (if any) have been installed.
Unless otherwise specified, initial granular material placement shall be done by
placing the material at the toe of the lined slope and pushing the material up the side
slope with a light dozer (eg. D-6) or other equipment approved by the Monitor. The full
design thickness of the granular material layer shall be maintained when spreading the
material. The granular layer shall be placed over the FML before any construction
traffic is allowed. If necessary, an access ramp comprised of granular material shall be
gradually advanced over the geomembrane to the bottom of the disposal cell. The access
ramp and other highly trafficked areas shall be a minimum of 0.9 m (3 ft) thick. Rubber
tired vehicles shall not be allowed where the granular layer is less than 0.9 m (3 ft) thick.
The layer of material shall be compacted using the dozer. The Monitor shall
obtain direct layer thickness measurements to verify conformance with design drawing
requirements.
3,^2 Concrete
If concrete is to be placed on the FML, care should be taken to avoid all damage
to the FML. Additional layers of FML or geotextiles should be considered as protection
layers for the FML.
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3.6.3 Geotextiles
Geotextiles shall be overlapped 0.3 m (1 ft) unless otherwise specified (Note 5).
If necessary because of the wind, the overlaps can be glued together with spots of glue
(one to three per meter) (at a distance of one to three feet). In general, overlaps shall be
oriented parallel to the lines of maximum slope.
During the placement of the geotextile, care should be taken not to entrap
stones in the geotextile.
Unless specially selected for their ultraviolet light resistance, geotextiles shall
not be exposed more than seven days.
* QUALITY CONTROL AND INSPECTION
4.1 Materials
The test reports, material properties sheets, and quality control certificates
required in Sections 2.1 and 2.2 shall be supplied to the Monitor by the FML
Manufacturer prior to fabrication or installation if there is no fabrication).
The quality control certificates shall be reviewed by the Monitor to verify that a
certificate has been received for all rolls.
%»2 Factory Seams
(Note: The entire Section 4.3 shall be deleted if the rolls are not fabricated into
blankets in a plant. This is usually the case for HOPE FML.)
Inspection
The Monitor shall visit the FML Fabricator's plant and verify that:
The plant is clean.
Ambient temperature in the plant is adequate (higher than 10°C (50°|5).
The specified rolls are used.
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The unreinforced selvage is wide enough (at least 3 mm (1/8 in.)).
Seaming procedures recommended by the FML Manufacturer are followed.
Appropriate seaming equipment and adhesive products are used.
The specified overlaps are used.
The factory seams have no upper loose flap.
Non-destructive and destructive testing equipment is available in the
plant.
The Monitor shall also:
Observe non-destructive testing.
Collect samples for destructive laboratory testing.
Obtain, from the FML Fabricator, reports on quality control tests
performed on factory seams.
Obtain, from the FML Fabricator, daily reports on the plant's production,
including number and identification of blankets, and number and
identification of rolls used to fabricate each blanket.
4*2.2 Non-Destructive Testing
Non-destructive testing of factory seams shall be performed by the FML
Fabricator. All factory seams shall be checked for loose flaps using an air nozzle
directed on the upper seam edge and surface to detect unbonded overlaps within the
seam. In addition, random vacuum seam testing shall be performed if required by the
Monitor. All required repairs shall be made by the FML Fabricator before the FML
blanket is packed for shipment.
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4.2.3 Destructive Testing
Destructive testing of specimens of factory seams shall be done by the FML
Fabricator and by an independant laboratory designated by the Monitor.
One 0.45 m (18 in.) square sample, with a seam in the middle, shall be cut-off
from each fabricated blanket. This sample can be cut-off at the edge of a blanket, or
from an extra length of seam, in order not to make a hole. All holes, if any, remaining in
the FML from destructive seam testing shall be immediately repaired in accordance with
repair procedures described in Section 4.5.3.
Each sample for destructive seam test shall be numbered. The number and the
location where the sample was taken from the blanket shall be recorded by the Monitor.
One half of the sample shall be retained by the FML Fabricator, the other half by the
Monitor.
<- Tests to be performed in a laboratory designated by the Monitor include "Bonded
J5hea"r Strength" (ie, tensile shear) and "Peel Adhesion", as recommended in the NSF
Proposed Standards for FML. The specified values to be obtained in these tests are the
values recommended in the NSF Proposed Standards for FML for the particular type of
FML tested.
%%3 Transportation, Handling and Placement
Upon arrival at the site, the FML Installer and Monitor shall inspect all materials
for defects in the manufacturing process and for damage during transportation.
Materials judged by the Monitor to be severly damaged shall be rejected and removed
from the site. Minor damages and other defects shall be repaired.
The Monitor shall inspect each panel, after placement and prior to seaming, for
damage caused by placement operations or by wind. Damaged panels or portions of
damaged panels which have been rejected, as judged by the Monitor, shall be marked and
their removal from the work area recorded.
The Monitor shall also verify that the weather conditions (air temperature, non-
excessive wind, and lack of precipitation) are acceptable for panel placement, in
accordance with Section 3.3.5.
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4.4 Field Seams
4.4.1 Field Seaming Operations
The Monitor shall verify that:
The seaming personnel have the qualifications required in Section 3.5.1.
The overlaps meet the requirements presented in Section 3.5.2.
The seaming area is clean, as described in Section 3.5.3.
A hard substrate such as a board or a piece of conveyor belt is used if the
supporting soil is soft.
Seaming equipment and adhesive products are available on the site and
meet the requirements presented in Section 3.5.*.
Weather conditions for seaming are acceptable, as required in
Section 3.5.5.
Seaming procedures described in Section 3.5.6 are followed.
The panels are properly positioned to minimize wrinkling and wrinkled
areas are seamed according to the procedures presented in Section 3.5.7.
All cap-strips required in Section 3.5.8 are placed.
Equipment for testing seams is available on site.
4.4.2 Test Seams
Test seams shall be performed to verify that seaming conditions are adequate.
Test seams shall be conducted at the Monitor's discretion and at least two times each day
(at the beginning of the morning and the beginning of the afternoon), for each seaming
equipment or adhesive product used that day. Also, each seamer shall perform at least
one test seam each day. Test seaming shall be performed under the same conditions ac
production seamy. The test seam shall be at least 0.6 m (2 ft) long.
as
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Specimens shall be cut from the test seam. These specimens shall be mm
( in.) wide (eg, 10 mm (0.5 in.) in the case of HOPE or 50 mm (2 in.) in the case of
Hypalon or PVC). Specimens shall be tested by hand in shear and peel, and shall not fail
in the joint. If a test seam fails, an additional test seam shall be immediately
conducted. If the additional test seam fails, the seaming equipment or product shall be
rejected and not used for production seaming until the deficiencies are corrected and a
successful full test seam is produced.
The Monitor shall observe ail test seams. A sample from each test seam shall be
retained and labeled with the date, ambient temperature, number of seaming unit,
seamer, and pass or fail description. One half of the sample shall be given to the FML
Installer for subsequent laboratory testing and the other half retained by the Monitor.
4.4.3 Non-Destructive Seam Testing
All field seams shall be non-destructively tested over their full length. Each
seam shall be numbered or otherwise designated. The location, date, test unit, name of
tester, and outcome of all non-destructive testing shall be recorded by the Monitor.
The Monitor shall observe all testing. Testing shall be done as the seaming work
progresses, not at the completion of all field seaming. All defects found during testing
shall be numbered and marked immediately after detection. All defects found shall be
repaired, retested and remarked to indicate completion of the repair and acceptability.
f.4.3 (Continued for HOPE)
The test unit shall be a vacuum test unit or an ultrasonic test unit.
4.4.3 (Continued for Hypalon and PVC)
The test unit shall be air lance or vacuum test unit.
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*.*.* Destructive Seam Testing (Also see page 25a)
Destructive seam testing involves cutting out a sample of an existing seam for
the purpose of verifying seam conditions through laboratory testing. Unless otherwise
noted, destructive seam testing shall not be performed except as directed in Section 5.4.
The destructive testing specimen shall be a 0.45 m (18 in.) square sample with
the seam in the middle.
Each destructive seam test sample shall be numbered. The sample number, seam
number, location of sample along the seam, and reason for the destructive seam test
shall be recorded on the test sample by the Monitor. One half of the test sample shall be
retained by the FML Installer, the other half by the Monitor.
All holes remaining in the FML from taking destructive seam, sample shall be
immediately repaired in accordance with repair procedures described in Section 4.5.3.
The new seams in the repaired area shall be tested according to Section 4.4.3.
Destructive seam test samples shall be stored and shipped, in a manner which will
not damage the test sample.
c „* Tests to be performed in a laboratory designated by the Monitor include "Bonded
§h?nr Strength" (ie, tensile shear) and "Peel Adhesion", as recommended in the NSF
Proposed Standards for FML. The specified values to be obtained in these tests are the
values recommended in the NSF Proposed Standards for FML for the particular type of
FML tested.
%»t.5 Verification of Seams in Special Locations
All seams in special locations shall be non-destructively tested if the seam is
accessible to testing equipment. If the seam cannot be tested in-place, but is accessible
to testing equipment prior to final installation, the seam shall be non-destructively
tested prior to final installation (eg, seams around pipes and appurtenances). The
Monitor shall observe all seam testing operations. If the seam cannot be tested in-place,
nor prior to final installation, it shall be observed by the Monitor and FML Installer, for
uniformity and completeness.
The seam number, date of observation, name of tester, and outcome of the test
or observation shall be recorded by the Monitor.
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-25a-
4.4.4 Destructive Seam Testing
EPA recommends random destructive seam testing in addition
to the destructive testing of test seams described in Section
4.4.2. Specifications should include the number of tests to
be made and the method of selection. At least one seam made
during each day by each seamer should be destructively tested.
Destructive seam test samples shall be identified, and
shipped in such a manner as to not damage the test sample.
Destructive seam test shall include both shear and peel
tests.
All areas from which samples are removed shall be
immediately repaired in accordance with Section 4.5.3. The
new seams in the repaired areas shall be tested according to
Section 4.4.3. The repaired area shall be completely covered
by a one-piece cap of liner material itself seamed to the
liner.
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All defective seams shall be promptly repaired, retested and remarked to
indicate completion of the repair.
4.5 Defects and Repairs
4.5.1 Identification
All seams and non-seam areas of the FML shall be inspected for identification of
defects, holes, blisters, undispersed raw materials and any sign of contamination by
foreign matter.
The surface of the FML shall be clean at the time of inspection. Brooming
and/or washing of the FML surface shall be required if the amount of surface dust or mud
inhibits inspection.
4.5.2 Evaluation
Each suspect location both in seam and non-seam areas shall be non-
destructively tested using the methods described in Section 4.4.3. Each location which
fails the non-destructive teshnei snail be marked and repaired.
%^*3 Repair Procedures
Defective seams shall be repaired by reseaming or applying a cap-strip. Tears or
pinholes shall be repaired by seaming or patching. Blisters, larger holes, undispersed raw
materials, and contamination by foreign matter shall be repaired by patches. Each patch
shall be numbered. Patches shall be round or oval in shape, made of the same generic
FML, and extend a minimum of 150 mm (6 in.) beyond the edge of defects.
%.5.% Verification of Repairs
Each repair shall be non-destructively tested using the methods described in
Section 4.4.3. Tests which pass the non-destructive test shall be taken as an indication
of an adequate repair. Failed tests shall be reseamed and retested until a passing test
results. The Monitor shall observe all non-destructive testing of repairs and shall record
the number of each patch, date, location, patcher and test outcome.
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4.6 Documentation
4.6.1 Material Quality Control Certificates
The quality control certificates pertaining to raw materials and manufactured
FML rolls required in Sections 2.1 and 2.2 shall be provided by the FML Manufacturer to
the Monitor prior to installation. The Monitor shall review the test results for
completeness and for compliance with the required minimum properties for both the raw
materials and manufactured FML rolls. Materials and rolls which are in non-compliance
with the minimum required properties shall be rejected.
4.6.2 Surface Preparation Certificate
The FML Installer shall provide the certification of acceptance of surface
preparation to the Monitor prior to any FML installation. Thereafter the FML Installer
shall provide the Monitor written acceptance daily for the surface to be covered by FML
in that days operations.
4.63 Daily Fabrication Reports
The FML Fabricator shall provide the Monitor with daily reports addressing; (i)
the total amount of FML seamed; (ii) identifiers of rolls and fabricated blankets; (iii)
quality control tests of materials used during the day; (iv) seaming equipment and
products used; (v) names of seamers; and (vi) seam testing performed. The Monitor shall
visit the FML Fabricator's plant and independently record observations of daily
fabrication activities, including all testing performed.
4.6.4 Daily Field Installation Reports
The FML Installer shall provide the Monitor with daily reports of: (i) the total
amount and location of FML placed; (ii) total amount and location of seams completed
and seamer and units used; (iii) changes in layout drawings; (iv) results of test seams; (v)
location and results of non-destructive testing; (vi) location and results of repairs and;
(vii) location of destructive test samples.
The Monitor shall record daily all activities of the FML installation, which shall
include but not be limited to:
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receipt of the written daily acceptance of surface preparation from the
FML Installer;
observations of all FML placement activities and record of defects caused
during transportation and handling;
observations of test seams, including seaming unit number or
identification of adhesive products, names of seamers, weather conditions
and results;
observations of anchor trench excavation, backfilling and compaction;
observations of field seaming operations, including weather conditions,
cleaning, overlaps, rate of seaming, names of seamers and units used;
observations of seams around appurtenances, and connection to
appurtenances;
observations of non-destructive seam testing, including testing location,
location of defects and testing unit used;
observations of repairs and retesting, including locations, name of
repairer and seaming equipment or product used.
5. PERFORMANCE REQUIREMENTS AND ACCEPTANCE OF INSTALLATION
5.1 Guarantees
The FML Manufacturer shall guarantee the FML materials to be free of defects
for a period of _ years after manufacture. \-*>
The FML Fabricator shall guarantee the factory seams to be free of defects for
a period of _ years after fabrication.
The FML Installer shall guarantee the installed FML and field seams to be free
of defects for a period of _ years after installation.
''
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5.2 Performance Expectations
It is expected that the FML installation will perform satisfactorily for a period
of not less than years. The intent of the FML is to jninimiee -the migration of fluids to
the adjacent subsurface soils and to ground water and surface water. Performance of the
FML will be partially evaluated by observations and testing of the long term monitoring
system.
5.3 Long Term Monitoring
5.3.1 Exterior Monitoring System
It shall be the responsibility of the Owner or Owner's representative to observe
and test monitor wells exterior to the cell or impoundment area for compliance with the
permitted monitoring program. The presence of significant levels of contaminants in
these exterior monitoring wells may be judged to indicate non-performance of the FML
installation.
5.3.2 Leak Detection System
If the cell or impoundment design incorporates a leak detection system below or
outside of the FML, it shall be the responsibility of the Owner or Owner's representative
to monitor the leak detection system at regular intervals. Detection of leaks by the leak
detection system may be judged to indicate non-performance of the FML installation.
5.3.3 Leachate Collection System (Specific to Land Disposal Cells and Waste Piles)
If a leachate collection system is incorporated into the design, it shall be the
responsibility of the Owner or Owner's representative to monitor the leachate collection
system and remove leachate at design levels or designated intervals. Failure to maintain
design levels or pumping intervals may negate FML performance guarantees.
5*3.% Coupon Monitoring Program
A coupon monitoring program shall be a part of the long term monitoring of
durability of the FML and FML seams. Coupons (small samples of the FML with and
EPA V\ct6 fjr M-ftA ct 4*ou'Cu
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without seam) shall be buried at the disposal site under the same construction conditions
and shall be placed for ready retrieval at eonotmctien intervals to be determined by the
Monitor. locaUnfi,
5.* FML Liner Acceptance
The FML liner shall be accepted by the Monitor when: (i) the installation is
finished; (ii) all documentation of installation is completed; and (iii) verification of the
adequacy of all field seams and repairs, and associated testing is complete.
A passing test seam shall be an indicator of the adequacy of the seaming unit and
seamer working under prevailing site conditions, but not necessarily an indicator of seam
adequacy. A passing non-destructive test of seams and repairs shall be taken to indicate
the adequacy of field seams and repairs. If the laboratory tests of the field test seams
fail, they shall be taken as an indicator of the possible inadequacy of the entire seamed
length corresponding to the test seam. Destructive test portions shall then be taken by
the FML Installer at locations suggested by the Monitor and the same laboratory tests
required of test seams shall be performed. Passing tests shall be taken as an indicator of
adequate seams. Failing tests shall be an indicator of non-adequate seams and all seams
represented by the destructive test location shall be repaired with a cap-strip. The cap-
strip shall be non-destructively tested and repaired, as required, until adequacy of the
seams is achieved.
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NOTES
Note 1 Table 1 should list the required properties of the FML, as determined by the
Designer. Table 1 can be presented in a way similar to the tables of material
properties presented in the NSF proposed standards.
Note 2 FML, such as 10 mil polyethylene, or other available FML may be used for
temporary protection. A temporary FML should be overlapped 0.3 m (1 ft) and
does not need to be seamed. The temporary FML may remain in place under
the design FML. Crack repairs may consist of re-wetting, if a sufficient time
is available for crack healing, or brooming dry powdered bentonite onto the soil
surface to fill the cracks.
Note 3 In general, seams should be oriented parallel to line of the maximum slope. In
corners and odd shaped geometric locations, the total length of field seams
should be minimized. No seams should be placed at the toe but should be a
minimum of 1.5 m (5 ft) away from the toe toward the inside of the cell or
impoundment.
Note * Additional, loosely placed FML or geotextile sections may create a potential
path for liquids between the FML and the supporting soil, which may be
detrimental, especially if the supporting soil is a liner.
Note 5 Specifications regarding geotextiles (including plastic nets) used as drains
should be prepared by the Designer.
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APPENDIX
DEFINITION OF TERMS
Designer
Earthwork Constructor
FML Fabricator
FML Installer
FML Manufacturer
Inspector
Monitor
Owner
Regulatory Authority
Specifier
The organization or person who generated the
design drawings and plans of the FML system
including the supporting soil.
The organization which is responsible for the
preparation of the surface on which the FML
is to be installed; also the party responsible
for placing the granular materials over the
installed FML.
The organization responsible for production of
FML blankets from FML rolls.
The organization responsible for field unroll-
ing, placing, seaming and other site aspects of
the FML construction.
The organization responsible for production of
FML rolls from raw materials.
A person who observes the FML construction
but is not responsible for the monitoring,
testing or documentation.
The organization or person independent of the
FML Manufacturer, Fabricator and Installer
that is responsible for observing and docu-
menting most activities and testing and
approving certain other activities relating to
FML construction.
The organization or person that owns the
hazardous waste disposal facility.
The organization responsible for issuing a
permit for the completed waste disposal
facility.
The organization or person who generated the
specifications for the FML construction.
fcU.S. GOVERNMENT PRINTING OFFICEl 1 9B4-421 - 545/t I 818
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