DRAFT   GUIDANCE
    STANDARDS APPLICABLE TO OWNERS AND OPERATORS
OF HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL
  FACILITIES UNDER RCRA, SUBTITLE C, SECTION 3004
 Closure and Postclosure;  Interim Status Standards
              (40 CFR 265, Subpart (G)
  This report (SW-912) was prepared under contract
      68-01-5794 for the Office of Solid Waste
        U.S.  ENVIRONMENTAL PROTECTION AGENCY
                        1981
                   Reprinted 1984
                  (With Addendum)

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This draft guidance document has been prepared by the International Research
and Technology Corporation.  In preparing this document,  we have sought and
incorporated the advice of the Office of Solid Waste, Environmental Protection
Agency (EPA).  The Regional Offices, the Office of General Counsel and the Office
of Enforcement have not yet reviewed this draft guidance  document; therefore,  this
document does not represent EPA's final views and opinions.


                                     U^S. Environmental Protection Agency

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                              PREFACE
     This guidance manual was developed to accompany  the  May  19,
1980 Subpart G interim status regulations and their technical
amendments.  Since this manual was prepared, Subpart  G regula-
tions were promulgated on January 12,  1981, which  supersede the
May 19, 1980 requirements.   In addition, interim status closure
requirements specific to land disposal facilities  promulgated
on July 26, 1982, have not been incorporated into  the existing
manual.

     EPA Headquarters is planning to revise the guidance  to
incorporate these new requirements.  In order to meet the
immediate needs of the regulated community in preparing closure
and post-closure care plans, and Regional personnel in reviewing
those plans, we have included an addendum to clarify  several
points.

     This manual is intended to serve as a guide to the types of
information that are appropriate to include in closure and post-
closure plans.  The sample plans contained in this document
illustrate a format and level of detail that is acceptable to
the U.S. Knvironmenta 1 Protection Agency.  The are not, however,
intended to serve as sample  forms required by the  Agency.  In
addition, these samples do not necessar i ly represent  a typical
facility and,  as a result, some sections of the plans may be
inapplicable to certain facilities.  Finally, the  sample  plans
and the accompanying guidelines do not address those  require-
ments promulgated after May  19, 1980.  The U.S. EPA urges members
of the regulated community to contact their State  agency  or EPA
Regional Office to discuss the applicability of this guide to
their facilities and other facility-specific requirements.

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                                                        January 1984
                        SUBPART G ADDENDUM

p. 1-2
    Plan must identify the steps to completely or_ partially
    close the facility.   [§265 .112(a) ]

pp. 2-1, 2-13
    Closure of land treatment  facility may be certified by an
    independent certified soil scientist.   [§265.280(e)
    July 26, 1982]

p. 2-2, para. 1(3)
    A description of the steps needed to decontaminate facility
    equipment during closure.  [§265 .112(a ) ( 3) ]

p . 2-3 para . 1
    Plan revisions must be made within 60 days of a change in
    operations.   [§265.112(b)]

p. 2-8, para. 1
    The regulations only restrict the time  for removing inventory
    to 90 days from the final receipt of waste.   [§265.113]

pp. 2-10, 11 (Sec. 2.2.6)
    The plan must only include a schedule indicating the  total
    time required to close the facility and  the time required
    for intervening activities.  Subsequent  sections of the
    manual state the need to include  dates  for activities which
    is not required.   Similarly, the  sample  closure plan  outlines,
    provided for each  process type, need not  include dates for
    closure activities.   [ §265 .112( 2) ( 4) ]

p. 3-10, p. 1
    The regulations do not require owners or  operators of storage
    and treatment tanks and  incinerators to  address the removal
    of contaminated soils or soil testing.

p . 5-18, para. 3
    Soil pore monitoring may be terminated  90 days from the  last
    application of waste.  [ §265 . 280(d ) (1) ]

p. 10-5, para. 1
    The post-closure plan must include the  name, address, and
    phone number of a  contact person.  [§265 .118(a ) ( 3) ]

p . 13-1, para . 2
    The date when closure commences should be within 30 days after
    the date on which  the owner or operator  expects to receive the
    last waste.  The plcTn, however should be  submitted 180 days prior
    to the expected date of closure.  The expected date is the date
    of the final receipt of waste.   [§265.112(c) Comment]

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p . 13-1 et . seq.
    The guidance on procedures for submitting and approving plans
    is incomplete.  Therefore, Regional staff will rely on the
    regulations themselves tu ensure that proper procedures are
    followed.

p. 13-2, para. 1
    The regulations do not currently specify how the Regional
    Administrator must handle written comments  (i.e.,  "...read
    all written comments and address them in a prepared written
    statement ") .

p. 13-13, para 2
    During interim status, no notice in the deed stating that
    the survey plat and record of wastes are on file is required.
    [$265.120]

p. 13-15, para . 3
    Delete #5

p. 13-18, para. 1
    The RA will consider petitions only when they present new and
    relevant information not previously considered by the Regional
    Administrator.fS265.118(f)(1)(ii)]

p. 13-20, para. 3
    The RA,  when considering a petition, (see above correction)
    must seek public comment through a newspaper notice.  If the
    RA denies the petition, he must send the petitioner a brief
    written response giving a reason for the denial.
    [265.118(f)(l)(iij, (iii)J

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                                     CONTENTS
1.0   INTRODUCTION	1-1

2.0   BASIC RULES FOR DEVELOPING CLOSURE AND POST-CLOSURE
        PUNS	2-1

      2.1   DETERMINING THE TECHNICAL ADEQUACY OF CLOSURE AND
              POST-CLOSURE PLANS FOR LANDFILLS, SURFACE
              IMPOUNDMENTS AND LAND TREATMENT FACILITIES
              (Reserved)	2-1
      2.2   BASIC RULES FOR DEVELOPING CLOSURE PLANS	2-1
            2.2.1   "Active" Portions of a Facility	2-2
            2.2.2   "Maximum Extent of Operation"	2-3
            2.2.3   Partial Closure	2-5
            2.2.4   Maximum Inventory of Wastes	2-6
            2.2.5   Decontaminating the Facility	2-10
            2.2.6   Schedule for Final Closure	2-10
            2.2.7   Monitoring	2-12
            2.2.8   Closure Certification	2-13
      2.3   BASIC RULES FOR DEVELOPING POST-CLOSURE PLANS	2-14
            2.3.1   Area of the Facility Included in the
                      Post-Closure Plan	2-15
            2.3.2   Ground-water Monitoring	2-16
            2.3.3   Maintenance of Waste Containment and
                      Monitoring Systems.	2-16
            2.3.4   Kinds of Maintenance to be Included in
                      the Post-Closure Plan...	2-16
            2.3.5   Cover Maintenance in the Early Post-
                      Closure Years	2-17
      2.4   DOCUMENTATION	2-18
      2.5   PLAN REVISIONS	2-19
      2.6   PLAN EVALUATION	2-19

3.0   TANKS:   GUIDANCE FOR DEVELOPING CLOSURE PLANS	3-1

      3.1   INTRODUCTION	3-1
      3. 2   FACILITY CONDITIONS	3-2
            3.2.1   General Information	3-2
            3. 2. 2   Maximum Inventory	3-3
            3.2.3   Equipment and Facilities	3-3
            3.2.4   Schedule of Activities	3-3
      3.3   REMOVING INVENTORY	3-5
            3.3.1   Maximum Amount of Inventory	3-5

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                              CONTENTS  (ContiniwxO                          *

            3.3.2   Pre treatment	3-6
            3.3.3   Methods and  Procedures for Treating or
                      Disposing  of Inventory	3-7          ^
            3.3.4   Time Schedule	3-9          I
      3.4   DECONTAMINATING THE  FACILITY	3-9
            3.4.1   Decontaminating the  Soil	3710
            3.4.2   Decontaminating the  Equipment and Facility	3-10
      3. 5   CLOSURE CERTIFICATION	3-11
      3.6   SAMPLE CLOSURE PLAN  OUTLINE:  TANKS	3-13

4.0   SURFACE IMPOUNDMENTS:  GUIDANCE FOR DEVELOPING
        CLOSURE PLANS	4-1

      4.1   SURFACE IMPOUNDMENTS IN WHICH WASTES REMAIN
              AT CLOSURE	4-3
            4.1. 1   Introduction	«...	4-4
            4.1.2   Facility Conditions	4-4
            4.1.3   Removing Inventory	4-9
            4.1.4   Decontaminating the  Facility	4-12
            4.1.5   Cover and Vegetation	4-15
            4.1.6   Ground-water Monitoring	4-22
            4.1.7   Closure Certification	4-24
            4.1.8   Requirements for Some Facilities	4-25
      4.2   SURFACE IMPOUNDMENTS IN WHICH WASTES ARE REMOVED
              AT CLOSURE	4-28
            4.2.1   Introduction	4-28
            4.2.2   Facility Conditions	4-29
            4.2.3   Removing Inventory	4-32
            4.2.4   Decontaminating the  Facility..	4-36          "jj
            4.2.5   Ground-water Monitoring	4-38          ^
            4.2.6   Closure Certification	4-39
      4.3   SAMPLE CLOSURE PLAN  OUTLINE:  SURFACE IMPOUNDMENTS IN
              WHICH WASTES REMAIN AT CLOSURE	4-41
      4.4   SAMPLE CLOSURE PLAN  OUTLINE:  SURFACE IMPOUNDMENTS IN
              WHICH WASTES ARE REMOVED AT CLOSURE	4-49

5.0   LAND TREATMENT FACILITIES:  GUIDANCE FOR DEVELOPING
        CLOSURE PLANS	5-1

      5. 1   INTRODUCTION	5-1
      5.2   FACILITY CONDITIONS	5-4
            5.2.1   General Information	5-4
            5.2.2   Maximum Extent of Operation	5-5
            5. 2. 3   Maximum Inventory	5-6
            5.2.4   Equipment and Facilities	5-6
            5.2.5   Schedule of  Activities	,	5-6
      5.3   REMOVING ALL INVENTORY	5-8
            5.3.1   Maximum Inventory	5-8

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                               CONTENTS (Continued)

                    Procedures f"or land* w (MiUug Wai»t*»s
            '}. 5. '}   Other Methods of Removing Inventory ............. i-1'
            5.3.4   Time Schedule.... ............................... 5-10
      5.4   MATERIAL IN TREATMENT ................................... 5-11
            5.4.1   Maximum Extent of Operation ....... ..............5-11
            5.4.2   Procedures Required to Complete Treatment. ..... .5-12
            5.4.3   Time Schedule ................................... 5-12
      5.5   REMOVING CONTAMINATED SOIL REMAINING ON THE LAND
              TREATMENT FIELDS ................... . . ................. 5-13
      5.6   DECONTAMINATING THE FACILITY ............................ 5-14
            5.6.1   Decontaminating the Soil ........... . ............ 5-14
            5.6.2   Decontaminating the Equipment and Facility ...... 5-15
      5. 7   COVER AND VEGETATION .................................... 5-16
            5.7.1   Area of the Facility Requiring Cover and
                      Vegetation .................................... 5-1 7
            5.7.2   Characteristics of Proposed Cover and
                      Vegetation ....... . ............................ 5-18
      5.8   MONITORING OPERATIONS ................................... 5-18
            5.8.1   Soil Monitoring ................................. 5-18
            5.8.2   Ground-water Monitoring ....................... ..5-20
      5.9   CLOSURE CERTIFICATION ................................... 5-22
      5.10  FOOD CHAIN CROPS ...................... . ................. 5-23
      5.11  INSTALLING OR MAINTAINING FENCES ........................ 5-23
      5.10  SAMPLE CLOSURE PLAN OUTLINE:  LAND TREATMENT
              FACILITY .............................................. 5-25

6.0   LANDFILLS:  GUIDANCE FOR DEVELOPING CLOSURE PLANS ............. 6-1

      6. 1   INTRODUCTION ............................................ 6-1
      6.2   FACILITY CONDITIONS ..................................... 6-3
            6.2.1   General Information .......... . .................. 6-3
            6.2.2   Partial Closure ................................. 6-4
            6.2.3   Maximum Inventory ............................... 6-6
            6.2.4   Equipment  and  Facilities ........................ 6-6
            6.2.5   Schedule of Activities .......................... 6-6
      6.3   MAINTENANCE  OF PARTIALLY CLOSED AREAS ................... 6-8
            6.3.1    Visual Inspections .............................. 6-8
            6.3.2    Ground-water Monitoring... ...................... 6-9
            6.3.3   Maintaining the Cover and  Vegetation ............ 6-9
            6.3.4    Erosion Control ....... . ......................... 6-10
      6.4   REMOVING ALL INVENTORY .................................. 6-10
            6.4.1    Maximum Inventory ............ . ........ ..........6-11
            6.4.2    Methods and  Procedures for  Removing
                      Inventory ....... . ................. . ........... 6-12
            6.4.3    Time  Schedule ................................... 6-14
      6.5   DECONTAMINATING THE  FACILIT :' ............................ 6-14
            6.5.1    Decontaminating the Soil ........................ 6-15

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                              CONTENTS  (Continued)                           v

            6.5,2   Decontaminating the  Equipment and Facility	6-16
      6.6   COVER AND VEGETATION	6-16
            6.6.1   Final Cover	6-18           .
            6.6.2   Vegetation	6-21          I
      6.7   GROUND-WATER MONITORING	;	6-23          ^
            6.7.1   Analyses Required During Closure	6-24
            6. 7.2   Maintenance	6-25
      6.8   CLOSURE CERTIFICATION	6-25
      6.9   REQUIREMENTS FOR SOME FACILITIES	6-26
            6.9.1   Collecting,  Removing and Treating Leachate	6-26
            6.9.2   Gas Collection	6-27
            6.9.3   Installing or Maintaining Fences	6-28
      6.10  SAMPLE CLOSURE PLAN  OUTLINE:  LANDFILLS	6-30

7.0   INCINERATORS:  GUIDANCE FOR DEVELOPING CLOSURE PLANS	7-1

      7.1   INTRODUCTION	7-1
      7.2   FACILITY CONDITIONS	7-1
            7.2.1   General Information	7-2
            7.2.2   Maximum Inventory	7-2
            7.2.3   Equipment and Facilities...	7-3
            7.2.A   Schedule of  Activities	,	7-3
      7.3   REMOVING INVENTORY	7-4
            7.3.1   Maximum Amount of Inventory	......7-4
            7.3.2   Pre treatment	7-5
            7.3.3   Methods and  Procedures for Treating
                      Inventory.	7-6
            7.3.4   Time Schedule	7-7
      7.4   DECONTAMINATING THE  FACILITY	7-8           ^
            7.4.1   Decontaminating the  Soil.	7-9           •
            7.4.2   Decontaminating the  Equipment and Facility......7-9
      7.5   AIR QUALITY MONITORING	7-10
      7.6   CLOSURE CERTIFICATION	7-10
      7.7   SAMPLE CLOSURE PLAN  OUTLINE:  INCINERATORS,	7-12

8.0   MULTIPLE PROCESS  FACILITIES:   GUIDANCE FOR  DEVELOPING
        CLOSURE PLANS	8-1

      8.1   INTRODUCTION	8-1
      8. 2   CLOSURE PLAN FORMULATION	8-1
      8.3   SAMPLE FACILITY	8-2

9.0   CLOSURE AND POST-CLOSURE ACTIVITIES REQUIRED AT SOME
        DISPOSAL FACILITIES	9-1

      9. 1   TYPES OF FACILITY PROBLEMS	9-1
      9.2   FACILITY CLOSURE	9-2
      9. 3   POST-CLOSURE	9-4

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                               CONTENTS  (Continued)

10.0  GUIDANCE FOR DEVELOPING POST-CLOSURE PLANS	10-1

      10.1  INTRODUCTION	10-1
            10.1.1  Facilities Requiring Post-Closure Care	10-2
            10.1.2  Post-Closure Period	10-2
            10.1.3  Frequencies of Monitoring and Maintenance	10-3
      10. 2  GROUND-WATER MONITORING	10-3
      10.3  MAINTENANCE ACTIVITIES	10-4
            10.3.1  Inspecting the Facility	10-5
            10.3.2  Maintaining the Cover and/or Vegetation	10-7
            10.3.3  Maintenance of the Ground-water Monitoring
                      System	10-9
      10.4  ACTIVITIES REQUIRED AT SOME FACILITIES	10-10
            10.4.1  Leachate Collection,  Removal and Treatment
                      System:  Maintenance and Operation	10-10
            10.4.2  Gas Collection System:  Monitoring and
                      Maintenance.	10-11
            10.4.3  Security System Maintenance	10-12
      10.5  SAMPLE POST-CLOSURE PLAN OUTLINE	10-13

11.0  REVISING CLOSURE AND POST-CLOSURE  PLANS	11-1

      11.1  REVISING CLOSURE PLANS	11-1
      11.2  REVISING POST-CLOSURE PLANS	11-5

12.0  ADEQUACY OF CLOSURE AND POST-CLOSURE PLANS	12-}.

      12.1  INTRODUCTION	12-1
      12.2  ADEQUACY OF SUBMITTED CLOSURE PLANS:   CRITERIA
              FOR APPROVAL	12-1
            12.2.1  Inspecting the Facilitv	12-2
            12.2.2  Plans for Treating,  Disposing  or Removing
                      Inventory	•	12-2
            12.2.3  Plans for Decontaminating the  Facility	12-3
            12.2.4  Evaluation of Proposed Cover  and
                      Vegetation	12-4
            12.2.5  Monitoring Plans	12-4
            12.2.6  Closure  Certification	12-5
      12.3  ADEQUACY OF SUBMITTED POST-CLOSURE PLANS:   CRITERIA
              FOR APPROVAL	12-5

13.0  IMPLEMENTING CLOSURE AND POST-CLOSURE DURING INTERIM
        STATUS	13-1

      13.1   PROCEDURES REQUIRED PRIOR TO  CLOSURE  ACTIVITIES	13-1
            13.1.1  Submitting the  Closure Plan	13-1
            13.1.2  Submitting the  Post-Closure Plan	13-3
            13.1.3  Inspecting the  Facility	13-4

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13.2  CLOSURE PROCEDURES	13-1>
      13.2.1   Closure  Schedule	13-5
      13.2.2   Revising Closure  Plans  During Closure...	13-7
      13.2.3   Closure  Certification Procedures	13-8
13.3  POST-CLOSURE  PROCEDURES	13-11
      13.3.1   Effective Date  of Post-Closure	13-11
      13.3.2   Notice to Local Land  Authority	13-11
      13.3.3   Revising Post-Closure Plans  During
                Post-Closure	13-13
      13.3.4   Notice in Deed  to Property	13-13
      13.3.5   Post-Closure  Security Requirements	13-15
      13.3.6   Post-Closure  Property Use	.13-16
      13.3.7   Duration of  Post-Closure  Requirement.	13-17

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                            1.0  INTRODUCTION

     The EPA has developed closure and post-closure performance stan-
dards as part of the Interim Status Standards — Subpart G, Closure and
Post-Closure Requirements.  This guidance document accompanies only
those portions of the regulations which were issued on May  19, 1980 and
the Technical Amendments to those regulations.  It should be noted that
several sections are interim final regulations and are subject to change
at a later date.  Additional guidance will be provided when these
interim final regulations become final to reflect any future changes.
This document provides guidance for the following portions of the
regulations:

    §265.111 -Closure performance standards (Interim final)
    §265.112 - Closure plan; amendment of plan (Interim final)
    §265.113 -Time allowed for closure (Interim final)
    §265.114 - Disposal or decontamination of equipment
    §265.115 - Certification of closure
    §265.117 - Post-closure care and use of property; period of
               care (Interim final)
    §265.118 - Post-closure plan; amendment of plan (Interim final)
    §265.119 - Notice to local land authority
    §265.120 - Notice in deed to property

     The EPA has developed the closure performance standards to ensure
that all hazardous waste management facilities are closed "in a manner
that (1) minimizes the need for further maintenance,  and  (2) controls,
minimizes or eliminates, to the extent necessary to protect human health
and the environment,  post-closure escape of hazardous waste, hazardous
waste  constituents,  leachate, contaminated rainfall,  or waste decompo-
sition products to the ground water,  or surface waters, or to the
                                  1-1

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atmosphere."*  As part of these closure requirements, an owner or
operator of a hazardous waste treatment, storage or disposal facility                I
must develop a closure plan which "will identify the steps necessary to
completely close the facility at any point during its intended life and
at the end of its intended life."**  The closure plans for treatment and
storage facilities must be available on the premises of a facility on
the effective date of these regulations, i.e., November 19, 1980. Owners
or operators of land disposal facilities, or facilities closed as land
disposal facilities, must have their closure plans available until 12
months after the promulgation of these regulations, i.e., May 19,
1981.  The owner or operator of a surface impoundment may close it as
either a landfill or a storage or treatment facility.  To close without
being responsible for post-closure care, he must either (1) remove all
hazardous wastes and residues, the liner, and underlying and surrounding
contaminated soil, or (2) show that any wastes removed are not
hazardous.

     In addition to the closure regulations, the EPA has developed post-
closure care regulations which apply to the owners or operators of all               M
facilities designed for waste disposal, i.e., facilities at which wastes
remain after closure.  These facilities require ground-water monitoring
and maintenance of the monitoring and waste containment systems for a
period of years after operations have ceased.  As part of these require-
ments, an owner or operator must prepare a post—closure plan which "must
identify the activities which will he carried on after final closure and
the frequency of those activities."***  The post-closure plan must be
available six months after the effective date of the regulations.
*EPA Interim Status Standards, 40 CFR §265.111.
**EPA Interim Status Standards, 40 CFR §265.1l2(a).
***EPA Interim Status Standards, 40 CFR §265.118(a),

                                  1-2

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     The closure and post-closure plans are required In order to ensure
that adequate preparations have been made for closure and, If
applicable, post-closure care.  Additionally, these plans are the basis
for the closure and post-closure cost estimates required as part of
§5265.142(a) and 265.144(a).

     The purpose of this guidance document is to assist the Regional
Office In implementing those sections of the regulation relevant to
closure and post-closure plans.  This document will:

     •   Clarify the concepts, definitions and rationale behind
         the requirements;
     •   Identify the major issues that affect closure and post-
         closure requirements;
     •   Discuss site-specific factors that affect closure and
         post-closure plans;
     •   Clarify the role of the Regional Office in evaluating
         these plans;
     •   Provide examples of the kinds of information that might
         be appropriate for closure and post-closure plans; and
     •   Provide guidance to owners or operators who need to
         develop closure and post-closure plans.

     The remainder of this document Is divided into the following
sections:  basic rules for developing closure and post-closure plans;
guidance for developing closure and post-closure plans; revising closure
and post-closure plans; adequacy of closure  and post-closure plans; and
implementing closure and post-closure during interim status.

     All hazardous waste treatment,  storage, or disposal facilities
(TSDF) are required to have closure and,  If applicable, post-closure
plans.  This document concentrates on the closure plans specific to six
types of TSDF's:  tanks; surface impoundments; land treatment
                                  1-3

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facilities; landfills; incinerators; and multiple process facilities.             A
Although there are no sections devoted specifically to closure and, if            "
applicable, post-closure requirements for containers, waste piles,
thermal treatment facilities, and chemical, physical and biological
treatment facilities, the basic principles still apply.  For example,
some of the closure requirements that are discussed in the section on
incinerators will also apply to thermal treatment facilities; similarly,
an owner or operator of a chemical, physical and biological treatment
facility may find portions of the section on surface impoundments
relevant to his facility.  An owner or operator of a multiple process
facility may prepare a closure plan for each individual portion of the
facility or one combining the various facilities.

     With the exception of multiple process facilities, a closure plan
outline has been included for each of these types of facilities to
provide further clarification and to illustrate one possible example of
documentation.  A post-closure outline is included in Section 10.0,
Post-Closure Guidance, for similar illustrative purposes.  Section 9.0
provides a general discussion of closure and post-closure measures which          *
might be necessary at some facilities to ensure the protection of human
health and the environment.

     The emphasis throughout this document is upon the interim status
situation.  This is particularly important to the sections on adequacy
of closure and post-closure plans, which are designed for rapid review
and inspection.  Much of the material contained in this document is
repetitive.  In order to ensure that the guidance relevant to each type
of facility is autonomous, it is necessary to repeat many of the
concepts that are generic to more than one type of facility.
                                  1-4

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                 2.0  BASIC RULES FOR DEVELOPING CLOSURE
                         AND POST-CLOSURE PLANS

2.1  DETERMINING THE TECHNICAL ADEOUACY OF CLOSURE AND  POST-CLOSURE
     PLANS FOR LANDFILLS, SURFACE IMPOUNDMENTS AND LAND TREATMENT
     FACILITIES
                            (RESERVED)
2.2  BASIC RULES FOR DEVELOPING CLOSURE PLANS

     The purpose of the closure plan is to ensure that an owner or
operator has considered and prepared for all that is necessary to
adequately close his particular facility with its site-specific
conditions.  The closure period begins at the time of the final accep-
tance of waste and is considered completed, from the standpoint of
technical requirements, when closure, in accordance with the closure
plan, is certified hv a professional engineer.  The Agencv understands
that facilities are very site-specific with respect to their operational
procedures, the wastes handled, and steps required to adequately close a
facility, and has not stipulated specific technical requirements for
closure.  The closure plan, therefore, serves as the mechanism for the
owner or operator to describe the most appropriate methods and
procedures, given all of the site-specific factors, to complete all of
the activities necessary to close the facility in a manner that will
minimize the threat of danger to human health and the environment.  The
closure plan, by describing the steps necessary to close the facilitv
and site-specific factors affecting these steps, will provide the EPA
Regional Administrator with a basis for evaluating the adeouacv of the
proposed plans for closure.
                                  2-1

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     Although all facLiiti.es will have .'-'ite-specific closure plans, all
closure plans must provide, at a minimum:*

     (I) A description of how and when the facility will he
         partially closed, if applicable, and ultimately closed,
         including an estimate of the maximum extent of the
         operation which will be open at any point during the life
         of the facility;
     (2) An estimate of the maximum inventory of wastes in storage
         or treatment at anv time;
     (3) A description of steps nec^s -tar / to decontaminate the
         facility or render it non-hazard .-••.••j at closure; and
         A schedule for final closure activities.
     A closure plan which is deve loo,.-
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2-2.2   "Maximum Extent of Operation"

     The closure plan, which identifies the steps necessary  to  close  the
facility at any point during its expected life, must include any steps
that would likely he required to close "the maximum extent of the
operation which will he unclosed during the life of the facility."*   The
plan will include those activities necessary if the facility suddenly
has to  stop receiving wastes and begin closure.  The closure plan must
be written so that if an inspector came onto the facility, none of the
conditions observed would exceed those stated in the plan.  Any time  an
owner or operator exceeds his estimate, he must revise his closure plan
to reflect his new estimate of the maximum extent of operation.
Although this assumption and description of requirements may differ
significantly from what an owner or operator hopes will he required at
the expected time of closure, the Agency believes that it is desirable
to have available such a plan in the event of forced closure due to an
unforeseen event, e.g., business failure of the facility owner or
operator.  The conditions assumed at closure and the steps that will  be
required should therefore he the maximum extent ever likely over the
life of the facility.  For example, an estimate of the maximum extent of
operation would include:  the maximum area of a landfill ever open,
Including areas inactive but open because of operating problems; the
most extensive amount of cleanup likely to be required; and the most
extensive inventory ever on hand.  In the case of a land treatment
facility, the maximum extent of operation would be based on the
assumption that the maximum amount of land had been recently spread with
hazardous waste.

     Although the plan is to account for the maximum extent of opera-
tion,  It need not include provisions for highly unusual contingencies,
unless  they affect the conditions of the facility at the time the owner
*EPA Interim Status Standards, 40 CFR §265.112Ca)(1).
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or oper.itor prepares the closure plan.  (This obvlouslv la a problem
unique to facilities operating under interim status which may already
have experienced problems during previous operations.)  For example, the
closure plan does not need to account for the effects of the 50-year
flood or liner failure in a large cell (e.g., extensive construction and
cleanup activities) unless such contingencies affect the facility
conditions when the plan is written.  If an owner or operator does
exceed his estimate of maximum extent of operation over the life of the
facility, he "must amend his plan any time changes in operating plans or
facility design affect the closure plan."*  Under 8ome circumstances, if
the owner or operator can justify to the Regional Administrator that the
change in conditions was caused by an unlikely contingency, and
conditions, as described in the plan, will be restored within a short
time, he may not be required to revise his plan.

     An owner or operator of a land treatment facility should, based on
his operating experience, assume for his closure plan that:  (1) all
hazardous materials will be rendered non-hazardous by the completion of
the closure period; (2) hazardous constituents will remain at closure
and the contaminated soil will be removed; or (3) hazardous constituents
will remain when closure is completed and the facility will be
stabilized to control waste migration.

     The original closure plan should describe the activities necessary
to close the maximum extent of operation, assuming one of the three
options described above.  If an owner or operator changes his assumption
about the conditions at the facility at the time closure is completed,
or changes his procedures, he must revise his closure plan to reflect
current requirements.  For example, if as a result of testing required
in Section 265.278 an owner or operator finds that the treatment is not
rendering the wastes non-hazardous, and he based his original plan on
*EPA Interim Status Standards, 40 CFR §265.112(b),

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the assumption that there would be no hazardous wastes at  the  completion
of closure, he would need to either plan to remove all contaminated  soil
or stabilize the facility and provide for post-closure care.   He would
also need to prepare a post-closure plan if the hazardous  wastes were to
remain at the facility after closure.  Similarly, if an owner  or
operator decided to stabilize the facility and provide for  post-closure
care instead of removing all contaminated soils, he would  need  to revise
his original plan and prepare a post-closure plan as soon  as he changed
his original assumptions.

2.2.3  Partial Closure
     It is common practice and environmentally desirable for owners or
oeprators of certain types of facilities (e.g., landfills and surface
impoundments) to periodically perform certain closure requirements
during the course of operations.  For example, portions of a landfill
are usually capped as they are filled which reduces the size of the area
to be closed at final closure.  The regulations require that an owner or
operator include in his closure plan "a description of how and when the
facility will he partially closed, if applicable, and ultimately
closed."*  All partial closure activities must be In accordance with the
closure regulations and included in the closure plan.

     The owner or operator must also describe the activities required to
close the maximum area open at any given time.  The maximum area open is
directly affected by the partial closure schedule and the extent of the
partial closure activities.  It is conceivable that if an owner or
operator closed areas as they were filled and operations went exactly as
expected, little would need to be done at final closure.  It must be
assumed for the closure plan, however, that, at closure, the maximum
area open at any time will need to he closed to account for the maximum
*EPA Interim Status Standards, 40 CFR §265.112(a)(1).
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extent of operation; therefore, it should be assumed that closure occurs
just prior to such an activity (e.g., periodic capping) which would
reduce closure requirements.  For example, if a landfill operator
routinely fills one cell at a time and covers it with a clay cap and
vegetation, the closure plan should include a description of the
procedures needed to close that cell and an indicator that one cell
represents the maximum extent of operation open at any time.  If
vegetation is not planted and maintained on cells previously closed, the
discussion of the maximum extent of operations should also include a
description of procedures for vegetating the entire facility or the
largest area requiring vegetation at closure.  In summary, an adequate
closure plan will include a description and schedule of all partial
closures and activities that will be necessary at final closure.  The
owner or operator must ensure that if at any time an inspector came onto
the facility, the maximum conditions assumed in the closure plan would
not be exceeded.

2.2.A  Maximum Inventory of Wastes

     All owners or operators will be required, as part of closure, to
treat or dispose on-site or remove to an off-site TSDF all wastes
accumulated at the time of closure.  The closure plan must include "an
estimate of the maximum inventory of wastes in storage or in treatment
at any given time during the life of the facility."*  The plan should
also include a description of the procedures for treating or removing
these wastes to ensure that, in the event of an early or unexpected
closure, the owner or operator has made plans to remove, treat, or
dispose of the maximum amount of waste on-site.

     Inventory is defined as all undisposed hazardous wastes at all
stages of processing, and residues from the actual processes involved
*EPA Interim Status Standards, 40 CFR §265. 112(a)(2),

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with  the  facility's  operations.   For  purposes  of  the  closure  plan,  the
maximum closure inventory is a hypothetical inventory of  the  maximum
amount of waste in storage or  treatment at any time during  the  life of
the facility, including all inventory  that will likely accumulate under
normal conditions.   Certain types of  facilities may not routinely
accumulate wastes as part of operating procedures; for example, an owner
or operator of a land  treatment facility may spread wastes  directly from
a truck onto the land  and may therefore have no inventory.

      In developing an  estimate of maximum inventory ever  on-site over
the life of the facility, an owner or operator must take  into account
expected  periodic accumulations of inventory and  predictable  events that
will  likely affect operating procedures over the  life  of  the  facility.
For example, an owner  or operator may, as part of routine operations,
cyclically accumulate  inventory over a certain period  and then work it
off.  The estimate of  the maximum amount ever  on-site, in this case,
would he the maximum amount ever accumulated.  This estimate should also
incorporate inventory  that will likely accumulate as  a result of predic-
table conditions,  such as adverse winter weather conditions, which
affect landfilling activities, and periodic "down times"  to rebrick an
incinerator.  The  estimate does not need to account for large accumula-
tions of inventory caused by unusual contingencies, such as the 50-year
flood or liner failures, unless they affect the amount of inventory at
the time the owner or  operator prepares the closure plan.

     The estimate  of maximum inventory must always he  high enough to
include all inventory  on-site at the time the plan is  prepared.  If
unusual events occur over the life of the facility and cause the
original estimate  to be exceeded, the owner or operator must revise the
estimate to reflect current conditions unless he can  justify to the
Regional Administrator that the inventory accumulation was caused bv an
unlikeIv contingency and the  amount  will be reduced to the original
estimate within a  short time.
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     For a tank or surface impoundment facility, the term "removal of
inventory" has a somewhat different meaning.  The estimate of the                 I
maximum inventory includes the maximum amount of hazardous wastes ever
in the tank or impoundment and the associated residues and containers.
If the wastes in the tank or impoundment are not considered hazardous,
the owner or operator is not required to treat or dispose of them as
hazardous wastes.  The plan must also include a description of how and
where the wastes ultimately will he treated or disposed.  A surface
impoundment may or may not be a disposal facility, i.e., a facility in
which wastes remain after closure; if all hazardous wastes are to be
removed from the impoundment as part of closure, removal of all inven-
tory refers to the processes of removing and disposing of all liquids,
sludges, liners, and contaminated soils in the impoundment.

              Procedures  for  Removing  the Maximum  Inventory

     The closure plan must contain a description of procedures for
removing inventory assuming that the maximum amount will need to he              _
treated, removed or disposed.  The regulations restrict the time                   J
allotted for treating, removing or disposing of inventory to 90 days.

     Although requiring all inventory to he managed within 90 days does
not restrict the amount that could Accumulate, since an unlimited amount
could theoretically be removed off-site, it does ensure that an owner or
operator has prepared for treating, disposing or sending hazardous waste
off-site in a timely fashion.  Since most environmental damage caused by
improperly operated waste facilities has begun as a result of excessive
accumulation of wastes on-site without proper plans for timely
management, the closure plan must provide detailed descriptions of
procedures for treating, removing or disposing of the inventorv.

     In addition to the environmental advantages of limiting inventorv,
it is also advantageous to the owner or operator to limit the amount of
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inventory.  Since all inventory must be  treated, disposed  or  removed
within  90 days, the more inventory an owner or operator has on hand,  the
more intensive the activities necessary  to ensure  that all wastes are
managed within 90 days.  If the owner or operator accumulated an
excessive amount of inventory and could  not reasonably expect to treat
or dispose of it all within 90 days, he  would need to send the wastes to
an off-site TSDF which is more costly than on-site treatment or
disposal.

     The Regional Office should use discretion in determining whether or
not an owner or operator is justified in taking longer than 90 days to
treat, remove or dispose of all inventory.  For example, if liquids are
routinely removed from a surface impoundment by evaporation, it may not
be possible to complete the process within 90 days from receiving final
wastes.  Similarly, an owner or operator may be unable to complete land
treatment within that time frame.

     The maximum amount of inventory on-site includes all wastes
requiring pretreatment, and procedures will thus include all processes
required prior to final treatment or disposal.  In most cases, it is
likely that wastes awaiting disposal will require varying degrees of
processing and treatment.   At an incineration facility, for example, all
wastes may be incinerated  on-site and the residues will be hauled off-
site; at a landfill facility,  some wastes may require different degrees
and tvpes of treatment prior to disposal, while other wastes may be
removed to an off-site TSDF if enough trenches have not been
constructed.  In both cases, the plan will describe in detail the
various procedures to be  followed, including treatment and  disposal
methods and an estimate of the likely proximity of the ultimate
treatment or disposal facility.

     An owner or operator  of a treatment or storage facility may
indicate in his  closure  plan that  he  will dispose of  wastes on-site  if
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it is a multiple process raci.Ii.ty with disposal capabilities.  It is
esential to note, however,  that such an owner or operator may dispose of             A
wastes in a landfill on-site only if the landfill is already operating
under interim status or is  permitted.  Under no circumstances may an
owner or operator build a landfill at the time he closes the treatment
or storage facility in order to dispose of wastes on-site.

2.2.5  Decontaminating the  Facility

     "When closure is completed, all facility equipment: and structures
must have been properly disposed of, or decontaminated by removing all
hazardous waste and residues."*  This includes, but is not limited to,
the equipment, and facilities used for earth-moving and storage,
processing, treatment, and  disposal of wastes and residues, including
any contaminated soil from  drips and spills.  Decontaminating the
facility is not intended to involve highly complex mechanical
activities; rather, for a well operated facility it should include
routine cleaning procedures.  The closure plan will contain a                      ~
description of all of the equipment and facilities affected and                      ^
procedures for decontamination, which may Include proposed methods for               *
cleaning equipment, soil testing, and removing and disposing of
contaminated soil, cleaning residues, and fluids.  Requiring a
description of procedures needed to decontaminate the facility ensures
that the owner or operator  is aware of all of the equipment and
surrounding area that requires cleaning and has a plan for such cleanup.

2.2.6  Schedule for Final Closure

     The closure plan must  include a schedule of all activities required
to completely close the facility, including intervening activities which
contribute to final closure.  All closure activities should be completed
*EPA Interim Status Standards, 40 CFR §265.114.

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within  six  months  ot" receiving  the  final  volume  of  wastes  unless  the
Regional Administrator approves a longer  period.  The  schedule  of
closure activities should  include:

     • The  final date that wastes will he accepted;
     • The  final date of completed  closure;
     • Dates for completion of activities performed during final
       closure (e.g., dates for completing the treatment and
       disposal of all wastes on-site, removing all residual
       wastes in storage facilities, decontaminating the facility,
       completing  final capping, and planting vegetation); and
     • Dates for any partial closure activities.

     A schedule of these periodic activities is required to ensure that
if an estimate of  the maximum area ever conceivably open at a facility
is based on periodic activities, these activities are performed with the
scheduled regularity.  This, again, is to ensure that the closure plan
is based on the maximum area of the facility ever open and the maximum
extent of activities required to close the facility.

     "The owner or operator must complete closure activities in accor-
dance with the approved closure plan and within six months after
receiving the final volume of wastes.   The Regional Administrator may
approve a longer closure period under  §265.112(c) if the owner or
operator can demonstrate that:   (1) the required  or  planned closure
activities will, of necessity,  take  him longer than six months to
complete,  and (2) that he  has taken  all steps to  eliminate any signif-
icant threat to human health and the environment from the unclosed but
inactive facility."*
*EPA Interim Status Standards,  40 CFR §265.113(b)

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     The Agency believes that, at most facilities, it should be possible
to complete closure within six months.  Given site-specific conditions,
however, the regulations allow for a longer closure period if an exten-
sion is justified.  For example, closure activities at a land treatment
facility are completed when the wastes are rendered non-hazardous or
less hazardous; this may not he achievable within six months.  If an
owner or operator, as part of normal operations, removes liquids from a
surface impoundment by evaporation, it may of necessity take longer than
six months to complete closure.  Assuming an owner or operator is
operating in accordance with the regulations and is justified in
requesting an extension, the Regional Office should approve a longer
closure period.

     The owner or operator must ensure that he has taken the appropriate
steps to eliminate any significant threat to human health and the envi-
ronment.  It is intended that the owner or operator should continue
those activities normally performed to protect against pollution.  This
section of the regulation allows the Regional Administrator to specify
additional requirements if adequate precautions are not being taken.

2.2.7  Monitoring

     In addition to the above requirements, all owners or operators who
are required to monitor their facility during operation must continue to
do so throughout the closure period, since the facility still contains
wastes and poses a potential ground-water, surface water, or air quality
threat.  If the facility is a permanent waste repository, ground-water
monitoring will also continue throughout post-closure until the Regional
Administrator determines that the monitoring may he terminated.

     The closure plan must include provisions for ground-water
monitoring in accordance with the requirements of §265.90 et seq. of
these regulations.  As part of §265.92(a), an owner or operator must
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develop a ground-water sampling and analysis plan.   The  simplest  way  to
describe in the closure plan the monitoring required during closure is
to include a copy of  the sampling and analysis plan.   However,  since  the
ground-water monitoring program required under §265.90 will not be
implemented until one year after the effective date  of these
regulations, the sampling and analysis plan may not be available  at the
time the closure and, if applicable, post-closure plans  are written.  It
is Intended, therefore, that the owner or operator use his judgment in
describing the kinds of monitoring required to comply  with the ground-
water regulations.  The Agency will he developing guidance for the
preparation of these monitoring programs, and the owner  or operator will
gain operating experience about the monitoring needs of  his facility
once the program is implemented.  Therefore, it is expected that  the
owner or operator will revise his plans as more guidance and data on
ground-water monitoring become available.  A copy of the ground-water
sampling and analysis plan should be included in the closure plan when
it becomes available.

2.2.8  Closure Certification
     There are two certification requirements:  (1) the owner's or
operator's personal certification that closure has been done in accor-
dance with the approved closure plan; and (2) an independent profes-
sional engineer's certification that closure has been done, to the best
of his knowledge, in accordance with the approved closure plan.  The
engineer's certification does not guarantee the adequacy of the closure
procedures and does not necessarily involve detailed testing and
analysis; rather, it implies that, based on periodic facility
inspections,  closure has been completed in accordance with the
specifications in the approved closure plan.  The professional
engineer's certification applies to the entire facility including those
portions which were partially closed.  Since it is difficult for a
professional  engineer to certify closure unless he has made insoections
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while the area is being closed, the owner or opreator should consider
having each partial closure certified as it is closed.

     The professional engineer's certification is the final step of  the
technical closure requirements and signals the beginning of the post-
closure care period, if the facility is a disposal facility.  The
certification does not guarantee the adequacy of closure itself nor does
it relieve the owner or operator of future responsibility for the
closure procedures.  For example, if the Regional Office inspects the
facility after closure has been certified and finds that closure is
inadequate or has not been performed in accordance with the plan, the
owner or operator is responsible for making necessary changes.  This
certification also does not terminate the closure financial responsibil-
ity requirements.  The final date of closure, for purposes of financial
responsibility requirements, is the date that the Regional Administrator
releases the closure fund to the owner or operator.

2.3  BASIC RULES FOR DEVELOPING POST-CLOSURE PLANS

     Owners or operators of disposal facilities, i.e., facilities at
which wastes remain after closure, are required to have post-closure
plans describing the activities to be performed after facility opera-
tions have ceased and the facility has been closed.  Disposal facilities
include landfills, and surface impoundments and land treatment
facilities in which wastes remain after closure.  The post-closure care
period begins on the date that the professional engineer certifies that
closure has been performed in accordance with the approved closure plan
and ends 30 years thereafter unless the Regional Administrator specifies
a different time period based on cause.

     The purpose of the post-closure plan is to ensure that the owner or
operator has adequately prepared for post-closure monitoring and
maintenance, and security if necessary.  The post-closure plan will
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contain descriptions of those activities  to be performed during  the  30-
year period, given the site-specific conditions.  The Agency has not
stipulated specific technical requirements for post-closure care because
of the wide variances among facility conditions.

     Although all disposal facilities will have site-specific  post-
closure plans, all will include at least:

     (1) A description of ground-water monitoring activities and
         frequencies; and
     (2) Maintenance activities and frequencies to ensure the
         integrity of the cap and final cover or other containment
         structures and monitoring systems, as specified in the
         regulations for each type of facility.

     A post-closure plan, developed in accordance with the objectives
stated above, must include certain kinds of activities which are
applicable to all types of disposal facilities.  The purpose of this
section is to clarify what Is intended by these requirements.

2.3.1  Area of the Facility Included in the Post-Closure Plan

     The post-closure plan should provide for post-closure care  "or the
entire facility as it is expected to exist at the  time of final
closure.  For example, if a ISO-acre landfill facility is expected to be
filled at a rate of 10 acres per year during its 18 years of operational
life, the post-closure plan must reflect the post-closure activities to
be performed  for the  full 180 acres.  It should be noted that post-
closure care  only applies to those portions of the facility which are
considered "active" on or after the  effective date of these  regulations.
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2.3.2  Ground-vater Monitoring

     Hazardous waste disposal facilities are required to conduct ground-
water monitoring operations during the post-closure period.  The moni-
toring operations conducted during the active operation of the facility
are expected to continue during post-closure.  Ae discussed above, the
discussion of monitoring in the plan will likely he revised after the
ground-water monitoring program is implemented a year after the
effective date of these regulations.

2.3.3  Maintenance of Waste Containment and Monitoring Systems

     During the post-closure care period, the majority of the routine
maintenance operations are directed at maintaining the integrity of the
waste containment system and ensuring that the monitoring systems remain
functional throughout the post-closure care period.  These maintenance
activities which must be described in the post-closure plan include both
those required annually (e.g., monitoring, mowing, inspections) and
those required on a periodic basis (e.g., replacing wells, replanting).
The post-closure plan must include the types of activities required and
their frequencies to enable the Regional Office to evaluate the plan
and, when applicable, the post-closure care nerformance. If an owner or
operator is not familiar with certain post-closure care activities, he
may need Co rely on his judgment and revise the plan when more
information or operating experience becomes available.

2.3.4  Kinds of Maintenance to be Included in the Post-Closure Plan

     The post-closure plan should include provisions for the kinds of
maintenance activities that can reasonably be expected to be needed
within the post-closure care period.  These events may result from
either natural phenomena or from accidental consequences of human
activities.  Natural events such as storms, droughts, seismic activity
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or  subsidence  should  he considered  "expected  occurrences"  if  they  could
be  expected to occur  within 30 years, and the maintenance  program  should
account for them.  Similarly, over  a period of  30 years, an owner  or
operator will  likely  be required to either replace or repair  parts of
the ground-water monitoring system.  The owner's or operator's operating
experience, combined  with historical records of the area,  can provide a
reasonable estimate of expected future conditions and needs.  For
example, an owner or  operator may be able to base his estimate of  the
rate of replacement of wells during post-closure on the replacement rate
during operation; maintenance required to repair damage from storms can
also be predicted on  the basis of personal experience and  historical
records.  Although an owner or operator nay have little experience when
he  originally prepares his plan, when more data become available (e.g.,
operating experience, engineering manuals, EPA guidance),  he may amend
his original estimates.

     Trying to predict future accidental contingencies, such as off-the-
road vehicles being driven across the cover during a period of wet
weather, vandalism, or inappropriate use of land, is more  difficult, but
some provision might be appropriate depending on the location of the
facility and past experience.  The post-closure plan is not meant to
include extraordinary contingencies such as a total liner  failure caused
bv a major earthquake.  Such a catastrophic disaster is largely
unpredictable, and an event of such low probability should  not be
included as a "routine" activity.

2.3.5  Cover Maintenance  in the Early Post-Closure Years

     During the early years of post-closure,  a more extensive cover
maintenance program may be required for  two reasons:

     •   To repair damages to the cover  caused by settling; and
     •   To replant areas  of the  cover  that did  not become
         established  during the closure  period.

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Since In many cases much of Che settling of the cover occurs in the
initial years after its placement, portions of the facility that were
covered during the closure period may require some reworking.  If
vegetation is used, it will also be necessary to include provisions
during the early years of post-closure for replanting of areas of the
cover that did not become established during the closure period.  This
is important to include in the post-closure plan because the owner or
operator is only expected to plant vegetation once during closure and
does not need to ensure that it becomes established.

2.4  DOCUMENTATION

     Although written closure and post-closure plans are required, the
regulations do not specify the format or documentation necessary.  As a
result, the Regional Administrator will have discretion over ultimate
requirements.  However, certain kinds of general guidance might be
appropriate.  The plan must be sufficiently detailed to achieve the
following purposes:

     (1) Provide for reasonable review to ensure that the
         conditions assumed in the plan adequately reflect the
         true conditions of the facility.
     (2) Contain sufficient detail to permit a cost estimate of
         the kind described in Suhpart H.  Such a cost estimate
         will not require engineering drawings,  but will require
         adequate descriptions of the methods, materials, and
         magnitudes of all significant activities.
     (3) Provide assurance that the methods and materials employed
         will be able to carry out their intended purposes.
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 2.5   PLAN  REVISIONS

      In  order  to ensure  that  the activities  described  in  the  closure  and
 post-closure care  plans  are appropriate,  given  the conditions  of  the
 facility at a  given  time,  the  plans  must  be  revised whenever  changes  in
 operating  plans or facility design affect  the plans.   The closure and
 post-closure plans must  always  include  provisions for  the most extensive
 activities that may  be required under normal operating conditions.
 Since  this requires  the  owner  or operator  to accurately predict
 uncertain  future conditions, revisions  to  the plans will likely be
 necessary  when unexpected  conditions or changes in facility design
 become evident.  A discussion of revising  the closure and post-closure
 plans  is included  in Section  11.0.

 2.6  PLAN EVALUATION

     Faced with the  range  of site-specific variables and the host of
 technical alternatives for satisfying the requirements of the regula-
 tions, the EPA has opted for determining specific technical measures on
 a case-by-case basis.  Given the site-specificity of the requirements,
 evaluating the adequacy  of the closure and post-closure plans  is
 critical for ensuring environmental protection.   No single engineering
 study  can address or provide a comprehensive guide to all of the
 variables involved in this problem.

     This leaves the Regional Administrator with a critical role in
evaluating technical procedures In approving closure  plans.   The
 Regional Administrator should therefore base his evaluation on
engineering studies  that do exist:   EPA guidance documents,  to the
extent the data are applicable; information from the  facility owner's or
 operator's experience and operating records; data relevant to the
 facility location that could affect environmental conditions (e.g.,
climate, hydrology, land use,  water quality); and suggestions from
regional engineering personnel.

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            3.0  TANKS:  GUIDANCE  FOR  DEVELOPING CLOSURE  PLANS

3.1  INTRODUCTION

     The following material provides  guidance  for  the EPA Regional
Offices and the regulated community concerning  the preparation of
closure plans.  The instructions  are  followed  by a sample closure plan
outline which illustrates the concepts and intentions of the plan.  The
discussion of closure plans provided  in this document is based on the
assumption that the facility has  been operating  properly and that no
special requirements will he necessary to ensure adequate closure.  The
purpose of this document is not to provide guidance for remedial
measures but rather to provide guidance to owners or operators of well-
operated facilities.  The instructions and the closure plan outline in
this section are separated into the following major headings which, in
most cases, correspond with the closure regulations applicable to tanks:

     •  Removing Inventory
     •  Decontaminating the Facility
     •  Closure Certification
     •  Summary of Facility Conditions

     According to the regulations, a  tank is defined as "a stationary
device designed to contain an accumulation of hazardous waste which is
constructed primarily of non-earthen materials (e.g., wood, concrete,
steel, plastic) which provide structural support."*  Since tanks are
considered instruments of storage or treatment, they are normally found
as part of a larger hazardous waste facility, rather than as single
storage sites.  At a multiple process facility composed of an
incinerator and several tanks,  an owner or operator may choose to
prepare individual closure plans  for tanks or incorporate them into the
*EPA Interim Status Standards, 40 CFR §260.10(a)(68),

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incinerator closure plan.  It is left to the owner's or operator's
discretion to decide which is the more appropriate approach.  Guidance
for preparing a closure plan for such multiple process facilities is
briefly discussed in Section 8.0.

3.2  FACILITY CONDITIONS

     The primary purpose of this portion of the closure plan is to
provide the Regional Offices with the information for an initial check
of the adequacy of the closure plan.  This section of the plan includes
a description of the factors determining the condition of the facility;
that is, a description of the facility (including storage equipment size
and capacity), a description of equipment, a characterization of the
wastes currently stored, the maximum amount of inventory ever on-site
during operations, and a complete schedule of closure activities.  With
this information readily available, an inspector can quickly evaluate
the closure plan using a visual inspection to confirm that facility
conditions never exceed the specifications described in the first part
of the closure plan.

3.2.1  General Information

     General information that would be useful in a closure plan
includes:

     •  Facility size;
     •  Storage facility descriptions;
     •  Other facilities on-site (e.g. landfill, incinerator,
        surface impoundment, etc.); and
     •  Waste characterization.
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3.2.2  Maximum Inventory

     The owner or operator must Include  in  the  closure  plan  "an  estimate
of the maximum inventory of wastes in storage or  in  treatment  at any
given time during the life of the facility."*   This  estimate of  the
maximum amount of inventory ever expected over  the life of the facility
should enable an inspector to evaluate quickly  this  portion  of the  plan
based on a visual inspection of the facility.

3.2.3  Equipment and Facilities

     The owner or operator should list and describe  in  the closure  plan
the kinds of equipment and facilities on-site to enable an inspector  to
evaluate quickly the proposed plans for  facility decontamination.

3.2.4  Schedule of Activitie3

     The closure plan must include "a schedule  for final closure  which
must include, as a minimum, the anticipated date when wastes will no
longer be received,  the date when completion of final closure  is  antici-
pated, and intervening milestone dates which will allow tracking  of  the
progress of closure.  (For example, the expected date for completing
treatment or disposal of waste inventory must be included, as  must the
planned date for removing any residual wastes from storage facilities
and treatment processes.)"**
*EPA Interim Status Standards, 40 CFR §265.112(a)(2).
**EPA Interim Status Standards, 40 CFR §265.112(a)(4).

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     The closure period begins with the final acceptance of waste and
concludes when closure has been certified by a professional engineer.*
The schedule of closure activities for a tank facility should include:

     •  Final date for accepting wastes;
     •  Final date for all processing and treatment;
     •  Final date for treatment, disposal or removal of
        inventory;
     •  Final date facility decontaminated;
     •  Final date closure completed, which is the date that
        closure has been certified by the professional engineer;
     •  The total time required to close the facility; and
     •  Justification if closure will take longer than six months
        from the date of the final acceptance of wastes
        (§265.113(b)).  If an owner or operator requires more than
        six months to close the facility, the closure plan must
        include a justification for the need for additional time
        as well as proof that all steps have been taken to
        eliminate any significant threat to human health and the
        environment.  A further discussion of closure schedules is
        in Section 2.2.6.
*The final date of closure referred to here is the date that the
 closure technical requirements have been certified by the professional
 engineer.  The final date of closure for purposes of the financial
 responsibility requirements is the date that the Regional Administrator
 releases the closure fund to the owner or operator.  A discussion of
 the legal implications of closure certification is in Section 2.2.8.

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3.3  REMOVING INVENTORY

     An owner or operator must include in the closure plan:

     •  An estimate of the maximum amount of inventory reasonably
        expected on-site over the life of the facility;
     •  Procedures for any necessary pretreatment;
     •  Methods and procedures for treating, disposing or removing
        inventory, including all residues from processing; and
     •  Time schedule.

3.3.1  Maximum Amount of Inventory

     The closure plan must include "an estimate of the maximum inventory
of wastes in storage or in treatment at any given time during the life
of the facility."*  Inventory includes all wastes in all stages of
processing, including wastes in the tanks, in storage, and residues from
processing.

     It should be noted that the concept of inventory may be somewhat
misleading in the case of tanks, because a hazardous waste facility
would rarely have tanks to the exclusion of all other forms of storage,
treatment or disposal.  Tanks, in fact, are most frequently found in
combination with another type of facility; the wastes contained in tanks
represent a portion of a facility's inventory.  In the case of a
facility providing only storage and/or treatment services, the inventory
would include all wastes in the tanks and in other forms of storage
(e.g., waste piles, drainage pits).  A tank storage/treatment facility
will probably have additional inventory stored in drums or similar con-
tainers.  Such inventory should also he considered in determining an
estimate of the "maximum amount ever on-site."  If an owner or operator
*EPA Interim Status Standards, 40 CFR §265.112(a)(2).

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of * multiple process facility prepares a separata closure  plan  for  the
tanks at the facility, he should be careful not to double count  his              |
inventory.  The tank's contents and any inventory in other  forms of
storage directly associated with the tank (e.g., wastes requiring
storage and/or treatment in the tank) should be included in the  estimate
of the tank's maximum inventory.

     The estimate of inventory must be based on the maximum amount that
would be on-site during the life of the facility.  It should always  be
high enough to ensure that if an inspector came onto the facility, the
amount of inventory would not exceed the estimate in the plan, assuming
normal operating conditions.

     Since accumulating inventory has often been the cause of severe
environmental damage, requiring in the closure plan an estimate  of the
maximum inventory ever on-site alerts the Regional Office of a potential
hazard if a visual inspection shows more wastes than the plan indicated.
If the amount of inventory on-site ever exceeds the estimate in  the              ~
plan, the owner or operator must revise the plan to reflect actual                fl
conditions; however, if the owner or operator can justify to the
Regional Administrator that the excess inventory is a result of
unexpected operating contingencies and the original estimate of  maximum
inventory can be restored quickly, the Regional Administrator might  not
require the owner or operator to revise the plan.  A further discussion
of maximum inventory is in Section 2.2.4.

3.3.2  Pre treatment

     The closure plan must include a description of all processing and
treatment of inventory necessary to prepare the contents of the  tank or
other storage facility for removal.  Waste analyses and actual tests may
be required if waste treatment processes not normally used will  be
necessary.  The plan should also specify the quantitv of wastes
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requiring pretreatment and  the quantity resulting from  pretreatment.
The types of waste will affect the kinds of treatment required  prior  to
disposal, as well as the methods for disposal  (e.g., incompatible wastes
may require special, or at  least separate, modes of disposal).

3.3.3  Methods and Procedures for Treating or  Disposing of Inventory

     The procedures to be followed for treating or disposing of
inventory are very site-specific and depend largely on whether or not
on-site capacity is available and on the quantity of waste to be treated
or disposed.  Since tanks are frequently found as part of a treatment or
disposal facility, it may be possible simply to manage all inventory on-
site.  In such a situation, on-site treatment or disposal is clearly the
most convenient and least expensive method of managing the inventory
because it involves, at most, only a short haul and requires only that
the owner or operator follow normal operating procedures.  If an owner
or operator disposes of inventory on-site in a landfill which is
permitted or has interim status,  he must also provide for post-closure
care for the landfill.   If, however, there is not a treatment or
disposal facility on-site,  it will be necessary to remove all wastes to
an off-site TSDF.  The  closure plan will include a description of the
procedures necessary to complete  the following activities:

     •  Operating the facility in a routine manner for  the com-
        plete treatment or  disposal of all inventory if inventory
        is to be treated  or disposed on-site,  including all stages
        of waste processing and treatment;
     •  Treating and disposing of wastes on-site in  a different
        manner  than routinely practiced during operation; and
     •  Removing and transporting all inventory for  which on-site
        treatment or disposal is  not feasible  to an operating
        permitted hazardous waste facility or  one  operating under
        interim status.
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                      On-Site Treatment or Dispoaal

     If inventory is treated or disposed  on-site,  the closure plan must
include an estimate of the amount of waste to be treated or disposed on-
site, taking into account all residues from processing, if applicable.
The plan will be based on the owner's or  operator's estimate of the
maximum number of drums and  the maximum quantity of bulk waste and
residues on hand at any time.  The plan will contain a discussion of the
kinds of activities necessary to operate  the facility in a routine
manner for the complete disposal of all inventory  to be disposed on-
site.  The type and quantity of wastes in the tanks will greatly affect
the procedures followed.  The type of waste will affect the kind of
pretreatment required prior  to disposal.  The quantity of waste will
determine whether the owner or operator will have  sufficient capacity if
there is a permitted landfill or one with interim  status on-site.  If
the landfill is part of the multiple process facility, the owner or
operator should refer to the closure plan of the landfill.

                       Removing  Inventory  Off-Site

     It is possible that, in some cases,  off-site removal of inventory
will be required.  For example, if the tanks are simply part of a
storage and treatment facility, if there  is not available capacity at
the landfill on-site, or if operating problems make ori-site treatment or
disposal impossible, all wastes would need to be transported and dis-
posed off-site.  If an owner or operator  plans to  dispose of some wastes
off-site, he should include in the plan the quantity to be removed, a
description of any treatment performed prior to transport, final treated
disposal method, and an estimate of the distance to the final TSDF, to
ensure that a facility will  likely be available to accept the wastes.
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3.3.4  Tine Schedule
     Accumulating inventory over long periods of  time has  often  been  the
cause of serious environmental damages; thus, the regulations restrict
the amount of time allotted during closure for treating, disposing  or
removing all wastes:

     "Within 90 days after receiving the final volume of hazardous
     wastes, the owner or operator must treat all hazardous wastes
     in storage or in treatment, or remove them from the site, or
     dispose of them on-site, in accordance with the approved
     closure plan."*

     The owner or operator should state in the plan the procedures  to be
used for treating, disposing, or removing all inventory within 90
days.  This ensures that an owner or operator must always have either
the capacity available to treat or dispose of wastes quickly on-site or
have made plans to remove inventory off-site.

3.4  DECONTAMINATING THE FACILITY

     The closure plan must include "a description of the steps needed to
decontaminate facility equipment during closure."**  According to the
regulations, "At closure all hazardous waste and hazardous waste
residues must be removed from tanks, discharge control equipment, and
discharge confinement structures."***  The plan should include a
description of the cleaning, testing and/or disposing of all items so
that no hazardous materials remain on-site.  This will include cleaning
*EPA Interim Status Standards, 40 CFR §265.113(a).
**EPA Interim Status Standards, 40 CFR 5265.112(a)(3),
***EPA Interim Status Standards, 40 CFR §265.114.

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up or disposing of contaminated equipment, soils and residues*  The
degree of cleanup required at a given facility at the time of final
closure will vary according to the owner's or operator's operating
practices.

3.4.1  Decontaminating the Soil

     The closure plan will include a list of all areas with potentially
contaminated soil requiring removal and disposal, and include a descrip-
tion of disposal methods.  Residues will be likely on the surrounding
grounds as a result of drips and spills or storage (e.g., residues on
drainage pits, spill containment areas).  Soil testing may or may not he
necessary depending on the facility conditions; the owner or operator
should state in the plan the criteria used to determine the amount of
contaminated soil to be removed and disposed.  An owner or operator will
need to refer to Section 261 of these regulations, "Identification and
Listing of Hazardous Wastes," for the criteria for identifying the
characteristics of hazardous wastes.

     The amount of contaminated soil which must be removed and disposed
will be a major factor in determining whether disposal will be on- or
off-site.  For example, if the tank is part of a multiple process
facility which has permitted land disposal facilities or ones with
interim status, the soil may be disposed on-site.  If the tank is part
of a facility without land disposal capabilities (e.g., an incinerator
facility), plans for off-site disposal will also be necessary since most
incinerators are not able to handle large quantities of contaminated
soil.

3.4.2  Decontaminating the Equipment and Facility

     The closure plan should describe the procedures used to
decontaminate or dispose of the following:
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     •  Tanks and other storage areas;
     •  All equipment used prior to storage/treatment in a tank,
        such as waste feed systems, by-pass systems, drainage
        systems, conveyors, containers used for transport;
     •  Discharge confinement structures (e.g., dikes);
     •  Piping, pumps, valves;
     •  Cleaning equipment; and
     •  Cleaning wastes and residues from cleaning.

     The owner or operator must include in the closure plan a descrip-
tion of procedures for cleaning all equipment and facilities, an
estimate of the amount of residues resulting from cleaning (e.g.,
residues from the cleaning process, hazardous cleaning fluids, waste-
waters, containers, etc.) and plans for disposal.  As discussed above,
these residues may be disposed on-site if there is an available
permitted disposal area or one with interim status as part of the
multiple process facility, or they may be disposed off-site.

3.5  CLOSURE CERTIFICATION

     "When closure is completed, the owner or operator must submit to
the Regional Administrator certification both by the owner or operator
and by an independent registered professional engineer that the facility
has been closed in accordance with the specifications in the approved
closure plan."*

     An independent professional engineer is required to certify that
closure activities were  performed in accordance with the approved
closure plan.   It is not: expected that an engineer will perform detailed
tests.   The owner or operator will include  an estimate of the number of
*EPA Interim Status Standards,  40 CFR §265.115.
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periodic inspections to be made by an engineer in th« closure  plan.   he
closure plan need not Include the name and the state professional
engineer license number of the engineer although this might be required
later as documentation.
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                3.6  SAMPLE CLOSURE PLAN OUTLINE:  TANKS
EPA Facility I.D. No.
Owner's or Operator's Name
Address & Phone No.	
Facility Address	
     FACILITY CONDITIONS
     A.  General information
         1.  Size of facility
         2.  Number of tanks
         3.  Storage facilities
             a.  Type (e.g., hulk or drums)
             b.  Capacity/volume
         4.  Other facilities on-site
             a.  Type (landfill, incinerator, basin, etc.1
             b.  Volume/capacity
         5.  Waste characterization (to he filled out for each tvrce of
             waste in inventory [e.g., phenolic wastewater, scrubber
             sludge, etc.], including waste material at any stage of
             processing,  and/or any residue generated by the normal
             processing of the waste before or during closure, including
             contaminated soil or containers).*
             a.  Chemical composition
             b.  Physical state (i.e., liquid, solid, gas or mixture)
*NOTE:  The Interim Status Standards require that "unless the owner or
 operator can demonstrate...that any solid  waste removed  from his tank
is not a hazardous waste,  the owner or operator becomes a generator of
 hazardous waste  and must  manage it in accordance with all applicable
 requirements of  Parts 262, 263, and 265 of this Chanter" (§265.197)
 (emphasis added).
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             c.  Combustion temperature
             d.  Specific gravity of the waste
     B.  Maximum amount of inventory ever on-site in any stage of
         processing
     C.  Inventory of auxiliary equipment
     D.  Schedule of final closure (milestone chart)
         1.  Final date wastes accepted
         2.  Dates for completion of Inventory disposal
             a.  Date all preprocessing completed
             b.  Date all on-slte disposal completed
             c«  Date that all Inventory has been disposed on-slte
             d.  Date that all inventory has been removed off-site
         3.  Final date facility decontaminated
         4.  Final date closure completed
         5.  Total time required to close the facility
         6.  Justification If closure Is longer than six months

II.  REMOVING ALL INVENTORY (to be filled out for each type of waste in
     inventory, Including waste material at any stage of processing,
     and/or any residue generated by the normal processing of the waste
     before or during closure)*
     A.  Maximum amount of waste on-slte in any stage of processing
         1.  Total amount of waste/residue In drums and number of
             drums, if applicable
         2.  Total amount of waste/residue in tanks and number of tanks
             (Include tag number or other means of identification for
             each tank)
*NOTE:  The Interim Status Standards note that "unless the owner or
operator can demonstrate...that anv solid waste removed from his tank is
not A hazardous waste, the owner or operator becomes a generator of
hazardous waste and must manage it in accordance with all applicable
requirements of Parts 262, 263, and 265 of this Chapter" ($265.197)
(emphasis added).
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         3.  Total amount of waste/residue In other forms of storage,
         If applicable (e.g., waste piles, basins, drainage pits, etc.)
     B.  Pretreatment
         1.  Quantity requiring pretreatment
         2.  Pretreatment process (including any equipment or materials
             needed)
         3.  Total amount to he treated or disposed following
             pre treatment
     C.  Methods and procedures for treating, disposing,  or
         removing inventory
         1.  Procedures for on-site inventory treatment or disposal
             a.   Quantity
             b.   Method of treatment or disposal
             c.   Size of area,  capacity or number of trenches necessarv
                 for inventory  treatment or disoosal
         2.  Procedures for off-site removal of  inventory
             a.   Quantity
             b.   Method of treatment or disposal
             c.   Approximate distance to off-site TSDF

III.   DECONTAMINATING THE FACILITY
     A.  Area of facility with  potential soil contamination (sq.  vd .)
         1.  List areas with potential contaminated soil
             a.   Numher of soil samples, if necessarv
             h.   Criteria for determining contamination
         2.  Estimated depth of soil requiring removal
         3.  Total amount of contaminated soil (cu. yd.)
             a.   Amount of contaminated soil disposed on-site
             b.   Amount of contaminated soil removed  off-site
     B.  All equipment and/or facilities requiring cleaning (e.g.,
         tanks,  surface Impoundments,  drainage pits,  discharge  control
         equipment,  tank trucks)
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         1.  Describe each piece of equipment and/or storage facilities             A
             and procedures for cleaning (e.g.,  steam-cleaning,  hydro-              "
             blasting, etc.)
             a.   Owner or  operator labor or contractor
             b.   Quantity  of residues from cleaning
         2.  Treatment or  disposal method for residues from decon-
             tamination (including wastewater and liquid  wastes)
             a.   Quantity  treated or disposed on-site and method
                 of treatment or disposal
             b.   Quantity  sent off-site, method  of treatment or
                 disposal, and approximate distance to TSDF

IV.   CLOSURE CERTIFICATION
     A.  A schedule or estimate of the number of periodic inspections by
         the certifying engineer anticipated during closure.
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                       4.0  SURFACE  IMPOUNDMENTS:
                  GUIDANCE FOR DEVELOPING CLOSURE PLANS

     The following material provides instructions for  the EPA Regional
Offices and the regulated community concerning the preparation of
closure plans.  The instructions are followed hv a sample closure plan
outline which illustrates the concepts and intentions  of the plan.  This
document and the accompanying outline are intended merely as guidance
and many parts of them may not be applicable to any given facility.
This guidance is based on the assumption that the surface impoundment
has been operating properly and that no special requirements will be
necessary to ensure adequate closure.  The purpose of  this document is
not to provide guidance for remedial measures but rather to provide
assistance to owners or operators of well-operated facilities in devel-
oping closure plans.  A general discussion of conceivable problems that
might exist at some facilities and the kinds of measures that might be
needed is included in Section 9.0, "Closure and Post-Closure Activities
Reouired at Some Disposal Facilities."

     The instructions and the outline are separated into two categories:
(1) surface impoundments in which wastes remain in the impoundment after
closure; and (2) surface impoundments in which wastes are removed from
the impoundment at closure.  An owner or operator of a surface impound-
ment which is a disposal facility, i.e., a facilitv in which wastes
remain in the impoundment after closure, "must close the impoundment and
provide post-closure care as for a landfill under Subpart G and
§265.310."*  If an owner or operator removes standing  liquids, hazardous
wastes, residues, the liner, and underlying and surrounding contaminated
soil from the impoundment at closure, or can show that use of these
remaining are hazardous wastes then "the impoundment is not further
*EPA Interim Status Standards, 40 CFR §265.228(c),
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subject to the requirements of this Part."*  It should he noted that              .
these regulations onlv require removal of hazardous wastes; therefore,           '
an owner or operator who removes all hazardous mat€srials is in compli-
ance with these regulations but may need to perform other activities to
comply with other regulations (e.g., zoning ordinances, solid waste
regulations,  etc.).

     Since these regulations only require that hazardous wastes he
removed, an owner or operator has the third option of preparing a plan
Hased on the  assumption that no hazardous wastes remain in the impound-
ment at closure.  For example, if an owner or operator is treating
hazardous organic chemicals, it is possible that,  aissuming treatment is
successful, there will he no hazardous wastes remaining at closure.  In
this case, closure activities would include the completion of treatment
operations, tests proving that no hazardous wastes remain in the
impoundment,  and necessarv facilitv decontamination.  An owner or oper-
ator must have sufficient evidence to demonstrate  that the facilitv's
treatment processes render all wastes non-hazardous and that he Is
justified in  preparing a closure plan based on this assumption.                  •

     When developing the closure plan, an owner or operator assumes that
he will:  close the impoundment as a disposal facilitv, with the addi-
tional post-closure responsibilities; remove all hazardous wastes from
the impoundment and eliminate the need for post-closure care; or provide
test results  demonstrating that no hazardous constituents remain in the
impoundment at closure.  It is possible that an owner or operator will
remove wastes from the impoundment and place them  in a separate landfill
on-site if one is operating with interim status or a permit; in this
case, the owner or operator must prepare a closure plan for the impound-
ment and closure and post-closure plans for the landfill. An owner or
operator may  also transfer all wastes into one section of the
*EPA Interim Status Standards, 40 CFR §265.228(h).

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impoundment at closure.  In this case, the closure plan should distin-
guish between the area from which all wastes have been removed and the
area in which wastes remain which will be closed like a disposal facil-
ity, i.e., a facility in which wastes remain at closure.

     In preparing the closure and, if applicable, post-closure plan, the
owner or operator must address how the facility will be closed "in a
manner that (a) minimizes the need for further maintenance, and (b)
controls, minimizes or eliminates, to the extent necessary to protect
human health and the environment, post-closure escape of hazardous
waste, hazardous waste constituents, leachate, contaminated rainfall, or
waste decomposition products to the ground water, or surface waters, or
to the atmosphere."*  The terms "human health," "environment" and
"control" are all relative terms.  In some cases, protection of human
health and environment may mean no discharge, while, in other cases,
some escape may be acceptable.  To meet these objectives,  the owner or
operator must develop as part of his closure and post-closure plan an
adequate analysis of the effectiveness of the proposed closure and nost-
closure procedures.

4.1  SURFACE IMPOUNDMENTS IN WHICH WASTES REMAIN AT CLOSURE

     A surface impoundment in which wastes remain at closure is consid-
ered a disposal facility.  A disposal facility is defined  as "a facilitv
or part of a facility at which hazardous waste is intentionally placed
into or on any land  or water, and at which waste will remain after
closure."**
*EPA Interim Status Standards,  40 CFR §265.112(a).
**EPA Interim Status Standards,  40 CFR $260.10(a)(15).
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     If the owner or operator does not remove all hazardous materials
from the impoundment at closure, "he must close the impoundment and
provide post-closure care as for a landfill under Suhpart G and
§265.310.  If necessary to support the final cover specified in the
approved closure plan, the owner or operator must treat remaining
liquids, residues, and soils hy removal of liquids, drying, or other
means."*  This requirement only applies to hazardous wastes; if tests
show that all or part of the wastes have been rendered non-hazardous,
those non-hazardous wastes need not he removed.

4.1.1  Introduction
     The instructions and the outline are separated into the following
major headings which correspond with the regulations applicahle to
impoundments in which wastes remain at closure.  The closure plan should
include a general description of facility conditions and must include
descriptions of the activities required to comply with the following
closure requirements:

     •  Removing Inventory
     •  Removing Standing Liquids
     •  Decontaminating the Facility
     •  Cover and Vegetation
     •  Ground-water Monitoring
     •  Closure Certification

A.1.2  Facility Conditions

     The primary purpose of this portion of the closure plan is to
provide the Regional Office with the Information for an initial check of
the adequacy of the closure plan.  This section of the plan contains a
*EPA Interim Status Standards, 40 CFR §265.228(c),
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description of the factors determining the conditions of the facility,
including the capacity of the impoundment, the maximum amount of inven-
tory expected to accumulate on-site during operations, a description of
equipment and facilities, and a complete schedule of closure activ-
ities.  With this information readily available, an EPA inspector can
quickly evaluate the closure plan using a visual inspection to confirm
that facility conditions never exceed the specifications described in
the first part of the closure plan.

                          General  Information

     General information that would be useful in a closure plan
includes:

     •  Facility size;
     •  Volume of impoundment;
     •  Type of treatment;
     •  Copy of NPDES permit, if the impoundment discharges
        through a point source to U.S. waters;  and
     •  Procedures and  schedules for dredging during operation,  if
        applicable.

     It is likely that  during the course  of  normal operations,  the
impoundment  will be  dredged.   The closure  plan  should  provide  a  schedule
for these periodic dredgings which may Include:

     •  Volume of waste dredged;
     •  Frequency of dredging;
     •  Procedures for  dredging; and
     •  Method of disposing  of dredged material.
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                             Partial Closure

     An owner or operator may partially close the impoundment during
facility operations by diking off areas that are no longer to be used,
and properly closing those areas.  Partial  closure includes those activ-
ities that reduce what needs to done at final closure to comply with the
regulations.  The closure plan must include plans to close the largest
area of the impoundment that will be open at any given time.  If an
owner or operator intends to partially close the impoundment, the
closure plan must include "a description of how and when the facility
will be partially closed, if applicable, and ultimately closed."*  The
closure plan must provide a schedule of these activities and a descrip-
tion of:

     •  The size of the area partially closed;
     •  Frequency of these partial closures; and
     •  Proposed methods for partial closures (i.e., removal of
        all wastes or cover for buried wastes), including, if
        applicable, type and source of cover and maintenance
        program.

     An owner or operator may partiallv close an impoundment in one of
two ways:  sections may he diked off and all hazardous wastes may be
removed; or the wastes may be retained in the diked off area and the
area closed in compliance with the landfill disposal requirements.  If
no hazardous wastes remain in these areas, no further activities are
required at closure.  If the area is filled and covered, the closure
plan must describe how these areas will be closed and maintained to
prevent water infiltration and runoff, to prevent soil and wind erosion,
to mitigate subsidence problems, and to ensure that these areas are in
good condition at final closure.  A discussion of the kinds of
*EPA Interim Status Standards, 40 CFR §265.112(a)(1),
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maintenance activities required for disposal areas that have been
partially closed (e.g., inspections, monitoring, routine maintenance) is
included in Section 6.3, "Maintenance of Partially Closed Areas."

     The key factor about partial closure which must be made clear in
the closure plan is that partial closure procedures (i.e., activities
which reduce the requirements at final closure) must be in accordance
with the technical closure requirements and- consistent with the plans
for final closure.  For example, if an owner or operator dikes off a
portion of the Impoundment and covers it with an inadequate cap which
will either require reworking or replacement at the time of final
closure, this area cannot be considered partially closed.  Similarly, if
the activities stipulated for final closure include a cap with 2 feet of
clay with a permeability of 10   cm/sec and 2 more feet of a more perme-
able material, these specifications must apply to all portions of the
facility which have a cover, including areas that have been partially
closed.

                        Maximum Amount  of  Waste
     The owner or operator must include in the closure plan "an estimate
of the maximum inventory of wastes in storage or in treatment at any
given time during the life of the facility."*  This estimate of the
maximum amount of inventory ever expected over the life of the facility
enables an inspector to evaluate this portion of the plan based on a
visual inspection of the facility.

                        Equipment and Facilities

     The owner or operator should describe the kinds of equipment and
facilities on-site (e.g.,  transport vehicles, excavation equipment,
*EPA Interim Status Standards,  40 CFR §265. H2(a)(2).
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spreaders, etc.) to enable an inspector to quickly evaluate the proposed
plans for decontaminating the facility.

                       Schedule of  Final  Closure
     The closure plan must include "a schedule for final closure which
must include, as a minimum, the anticipated date when wastes will no
longer be received, the date when completion of final closure is antici-
pated, and intervening milestone dates which will allow tracking of the
progress of closure.  (For example, the expected date for completing
treatment or disposal of waste inventory must he included, as must the
planned date for removing any residual wastes from storage facilities
and treatment processes.)"*

     The closure period hegins with the final acceptance of waste and
concludes when closure has been certified by the professional engi-
neer.**  The schedule of closure activities apolicahle to surface
impoundments in which wastes remain at closure should include:

     •  Final date for accepting wastes;
     •  Date all treatment completed;
     •  Date that all standing liquids will have been removed;
     •  Final date facility decontaminated;
     •  Date final cover completed (this date is largelv affected
        by the size of the area to be covered and climatic condi-
        tions which mav halt construction activities);
*EPA Interim Status Standards, 40 CFR §265.112(a)(4).
**The final date of closure referred to here is the date that the
  closure technical requirements have been certified by the professional
  engineer.  The final date of closure for purposes of financial respon-
  sibility requirements Is the date that the Regional Administrator
  releases the closure fund to the owner or operator.  A discussion of
  the legal implications of closure certification is in Section 2.2.8.
                                  4-8
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     •   Final date vegetation  planted  or  material  used  to  control
         erosion  placed; the date  to be listed here  is the  date
         that planting  has been completed,  if vegetation is used;
     •   Final date of  closure and  the effective date of post-
         closure, which is the date that closure has heen certified
         by the professional engineer;
     •   Total tvne required to close the  facility,  i.e., time from
         the final acceptance of waste to  certification  by  the
         professional engineer; and
     •   Justification  if closure will take longer  than  six months
         from the date  of the final acceptance of wastes
         (§265.113(h)).  If an owner or operator requires more than
         six months to  complete closure, the closure plan must
         include a justification for the need for additional time
         as well as proof that all steps have been  taken  to elimi-
         nate any significant threat to human health and  the
         environment.   A further discussion of closure schedules is
         in Section 2.2.6.

4.1.3  Removing Inventory

     An  owner or operator of an impoundment must include in the closure
plan:

     •   An estimate of the maximum amount of inventory  reasonably
        expected on-site  over  the life  of the facility;
     •  Methods and procedures for treating, storing or removing
        all inventory, including processing residues;  and
     •  Time schedule.

                           Maximum Inventory

     The closure plan  must include "an  estimate  of the  maximum inventory
of wastes in storage  or in treatment  at any given  time  during the life

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of Che facility".*  Inventory, in the case of impoundments in which
wastes are to remain after closure, includes all wastes in all stages of
processing, including storage, residues from processing, and standing
liquids in the impoundment which must be removed.

     The estimate of inventory must he based on the maximum amount ever
expected to be on-site over the life of the facility, assuming normal
conditions.  It should always be high enough to ensure that if an
inspector came onto the facility, the amount of wastes in storage as
well as the amount of liquid in the impoundment would not exceed the
estimate in the plan, assuming normal operating conditions.

     Since accumulating inventory has often been the cause of severe
environmental damage, an owner or operator should keep the amount of
wastes in storage at a minimum.  Requiring in the closure clan an esti-
mate of the maximum amount of inventory also alerts the Regional Admin-
istrator to a potential hazard if a visual inspection of the facility
shows more wastes than the plan indicated.  If the amount of wastes on-
site ever exceeds the estimate in the plan, the plan must he revised to
reflect actual conditions; however, If the owner or operator can justify
to the Regional Office that the excess inventory is a result of unex-
pected operating conditions and the original estimate of maximum inven-
tory can be restored quicklv, the Regional Administrator might not
require the owner or operator to revise the plan.  A further discussion
of maximum inventorv is in Section 2.2.4.

   Methods and Procedures for Treating, Storing or Removing Inventory

     The procedures to he followed are very site-specific and must he
described in the closure plan.  At a minimum, the owner or operator will
describe procedures necessary to complete the following activities:
*EPA Interim Status Standards, 40 CFR §265.112(a)(2).
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     •  Operating  the  facility in a routine manner while  treating
        and removing wastes in storage, including all standing
        liquids, if standing liquids are  to he removed hy evapora-
        tion or treatment and discharge;
     •  Stabilizing all sludge remaining  in the impoundment;
     •  Removing and transporting liquids not removed hy  evapora-
        tion or treated and discharged on-site to an operating
        permitted  facility or a facility  operating under  interim
        status; and
     •  Removing all hazardous wastes from sections of the
        impoundment which will not be disposal areas.

     The closure plan  should descrihe procedures to he used for treating
all wastes in storage and removing all standing liquids.  If wastes are
to he discharged,  the  owner or operator must comply with  the Clean Water
Act.  The plan should  also include a discussion of proposed procedures
for stahilizing the sludge (e.g., quantity and type of hulking agents
used).  An owner or operator may prefer to transfer some  liquids to
another facility hecause of operating prohlems or because treatment is
taking longer than anticipated.  In this case, the owner  or operator
should include an estimate of the amount disposed off-site and ensure
that the receiving facility is either permitted or operating under
interim status.

     At the time of closure, an owner or operator may transfer all
remaining sludge to one portion of the impoundment, dispose of it else-
where on-site if he has a permitted landfill or one with  interim status,
or dispose of some of it off-site to reduce the size of the area that
will require a final cover and nost-closure care.  If removing sludge is
to he part of closure procedures,  the plan should include the quantity
of sludge to he removed and explain how it will he disposed.  If it will
he disposed in a permitted landfill on-site or one which has interim
status, the owner or operator must have prepared  closure and post-
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closure plans for the landfill.  If some of the sludge is to be disposed
off-site, the plan also should include an estimate of the distance to a
permitted operating facility or one operating under interim status.  If
an owner or operator intends to only close a portion of the facility as
a disposal facility, the remainder of the facility must be devoid of all
hazardous materials.

                              Time  Schedule
     Accumulating; inventory over lonp; periods of time has often heen the
cause of serious environmental damage; thus, the regulations restrict
the amount of time allotted during closure for treating, storing or
removing all wastes:

     "Within 90 days after receiving the final volume of hazardous
     wastes, the owner or operator must treat all hazardous wastes
     in storage or in treatment, or remove them from the site, or
     dispose of them on-site, in accordance with the approved
     closure plan."*

     The owner or operator of an impoundment should include an estimate
of the time required for  treatment.  If treatment nrocesses routinely
take longer than 90 days, the olan should  include a justification  for
this extension, subject  to the Regional Administrator's approval.

4.1.4  Decontaminating the Facility

     The closure plan must Include "a description of  the steps needed  to
decontaminate facility equipment during closure."**   According to  the
regulations, "when closure is completed, all facility eouipment
 *EPA  Interim  Status  Standards,  40 CFR  §265.113(a).
 **EPA Interim Status Standards,  40 CFR §265.112(a)(3),

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structures must have been properly disposed of, or decontaminated hy
removing all hazardous waste and residues."*  The closure plan should
include a description of the cleaning, testing and/or disposing of all
items so that no hazardous materials remain undisposed on-site.  This
will include cleaning up or disposing of contaminated equipment, soils
and residues.  The degree of cleanup required at a given facility at the
time of final closure will vary according to t.<~>. owner's or operator's
operating practices.

                        Decontaminating the Soil

     The closure plan will include a list all areas with potentially
contaminated soil requiring removal and disposal, an estimate of the
quantity of contaminated soil to he disposed, and a description of
disposal methods.  Cleanup of hazardous waste drips and spills will he
part of routine operating practices.  The residues included in the
closure plan are those on the surrounding grounds as a result of closure
operations and those not previously cleaned up (e.g., residues on dikes,
storage areas, trenches, diversions, spill containment areas).  Soil
testing mav not be necessary depending on the facility conditions; the
owner or operator should state in the plan the criteria used to deter-
mine the amount of contaminated soil to be disposed or removed to an
off-site TSDF.  An owner or operator will need to refer to Section 261
of these regulations, "Identification and Listing of Hazardous Wastes,"
for the criteria for identifying the characteristics of hazardous
wastes.

     The amount of contaminated soil which must be removed and disposed
will be a major factor In determining whether it will be disposed of in
the Impoundment itself, on-site in a permitted landfill or one with
interim status if part of a multiple process facilitv, or removed off-
*EPA Interim Status Standards, 40 CFR §265.114.
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site to a TSDF.  If space is not available in the impoundment, the
closure plan must include plans for removing the soil off-site to a TSDF
or disposing of it on-site in a landfall if the facility is a multiple
process facility.

               Decontaminating the Equipment and Facility

     The closure plan mav include a description of procedures used to
decontaminate or dispose of the following:

     •  All transport and storage containers, tanks and ancillary
        facilities;
     •  All equipment, including that used for transport, storage,
        treatment, disposal, earth-moving, and cleaning processes;
     •  Cleaning wastes and residues from cleaning; and
     •  Any remaining water on-site from rain or snow.

     The owner or operator must include in the closure plan a descrip-
tion of procedures for cleaning all equipment and facilities, an
estimate of the amount of residues resulting from cleaning (e.g.,
residues from the cleaning process, cleaning fluids that are hazardous,
wastewaters, containers), and plans for their disposal or removal to an
off-site TSDF.  For facilities at which it is common for water to accu-
mulate as a result of rain or snow, the closure plan must provide for
removing excess water at the time of closure.

     It is likely that most, if not all, of these residues will he
disposed of in the impoundment.  An owner or operator mav need to dis-
pose of some wastes in a landfill on-site if the facilitv is a multiple
process facility, or remove them to an off-site facilitv if the impound-
ment is already filled to capacity or cleaning residues are incompatible
with the sludge in the impoundment.  If the wastes are to he disposed in
a cell on-site apart from the impoundment, the description of activities
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should include  landfilling  procedures and  closure  activities  if  a
separate closure plan has not been  prepared  for  the  landfill.

4.1.5  Cover and Vegetation

     An owner or operator of an impoundment  which  is a disposal
facility, i.e., a facility  in which wastes remain  at closure,  .rust  close
in accordance with the landfill closure regulations.  If an owner or
operator designates only a  section of the  impoundment as a waste reposi-
tory, these landfill regulations apply only  to that  section of the
facility.

     According  to the regulations, "in the closure and nost-closure plan
under §265.118, the owner or operator must address the following objec-
tives and indicate how they will be achieved:

     (1)  Control of pollutant migration from the  facility via
          ground water, surface water, and air;
     (2)  Control of surface water infiltration, including
          prevention of pooling; and
     (3)  Prevention of erosion."*

     An owner or operator of a land disposal facility must demonstrate
in the closure and post-closure plans that the post-closure escape of
hazardous waste constituents to ground water, surface water or the
atmosphere will he controlled in a manner so as not  to pose a threat to
human health and the environment.  In addressing these objectives, the
owner or operator must consider at a minimum the site location, topo-
graohv and land use, climate, hydrogeological conditions, and character-
istics of the proposed final cover.  The closure plan should include a
description of the natural or synthetic liner system, final cover, and
*EPA Interim Status Standards, 40 CFR 5265.310(a),
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vegetation.  The type of cover and vegetation required will vary on a
site-specific basis depending on what is necessary to protect human
health and the environment.  In some cases, this protection may mean
that no discharge is acceptahle from a particular facility, while in
other cases, some escane could he acceptahle.  For example, the level of
discharge acceptable from a facility located near a drinking water
source would he significantly less than from a facility that only dis-
charges into a completely nonpotahle water source.

     It is expected that most well-operated facilities will require, at
a minimum, a final cover and vegetation, or other material to stabilize
the cover, to ensure adequate control of the migration of wastes.  A
general discussion of other kinds of control technologies that might be
needed to adequately close a facility is in Section 9,0, "Closure and
Post-Closure of Disposal Facilities With Less than Optimum Control
Technology."

                               Final  Cover
     The final cover refers to the materials and surface contours used
to cover the impoundment at closure.  In most cases, vegetation or some
other material will he required to stabilize the final cover.  The
integrity of the final cover is an important closure requirement for an
impoundment which is a disposal facility.  The owner or operator must
describe in the closure plan the type of cover (material and final
surface contours) most appropriate at that facility, taking into account
the functions of the cover (e.g., infiltration control, erosion and run-
off control, wind erosion control, and prevention of ponding), and
characteristics of the cover.   The owner or operator will also need to
demonstrate the adequacy of the particular cover chosen in meeting the
objectives of the regulations, i.e., adequate containment or control of
wastes.  The description of final cover in the closure plan should
include:
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     •    The area of the  facility  that requires a  final cover;
     •    Characteristics  of cover  (e.g., type of soil, thickness,
          permeability); and
     •    Cover design.

These site-specific specifications  of  the cover included in  the closure
plan also apply to all  previous partial closures.   A further discussion
of partial closures is  in  Section 4.1.2.

     •  Area of the Impoundment Requiring Final Cover

     An owner or operator must include in the closure plan an estimate
of the maximum area of  the facility that will require a final cover at
closure and the size of the area from which all wastes will  he removed.
The size of the area requiring a final cover depends upon how much, if
any, of the impoundment has heen partially closed,  the procedures used
for partial closures, and plans for final closure.  If all hazardous
wastes were removed from sections of the impoundment and these areas
were diked off as part of partial closures, these sections will not be
disposal areas and will therefore not require a final cover; partially
closed areas that were designated as disposal areas and were therefore
not previously covered  in accordance with landfill regulations may
require extensive earthwork, depending on the extent to which these
inactive areas were maintained.  At final closure, an owner or operator
may choose to designate one portion of an impoundment as a disnosal area
and transfer all of the wastes from the rest of the impoundment to that
section.  In this situation, the owner or operator would close part of
the impoundment in accordance with the landfill regulations and the rest
as a treatment facility (see Section 4.2).
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     •  Characteristics of Cover

     In describing the characteristics of the final cover, the closure
plan should Include:

     -  The type(s) of material(s) used for the cover (e.g.,
        density, porosity, permeability, compatibility with waste
        to ensure wastes will not corrode cover);
     -  The thickness of each material chosen;
     -  Total amount of material required which is a function of
        the size of the area to be closed and depth of cover;
     -  Amount and type of soil additives, if applicaible; and
        Source of materials.

     It is likely that at most facilities the final cover will he of
some impermeable material to protect against surface water infiltration.
This impermeable material may be compacted clay (e.g., soil with a
permeability of 10~  cm/sec) or may be a barrier membrane liner over a
buffer laver of soil, depending on soil availability and the site-
specific conditions of the facility.  If the final cover is to be
planted with vegetation for purposes of erosion control, a top laver
capable of supporting vegetation will be required.  In arid regions of
the country, gravel may be preferable to vegetation for controlling
erosion.

     The materials to be used will depend on the types of soil available
cm-site as well as the conditions of the facility.  Since purchasing
soil off-site is costlv, it is most likely that most owners or operators
will use soil available on-site, if at all possible, for the final
cover, i.e., the layer with low permeability and the layer capable of
supporting vegetation, if applicable.  It is possible to improve the
quality of available soil bv blending various soils, using soil addi-
tives, or making other provisions which would provide equivalent
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 protection.  For example,  soil  blending  and  synthetic  additives nav
 decrease  the permeability  of  the  on-site  soil  as  well  as  make  certain
 soils more capable of  supporting  vegetation.   In  addition to  improving
 the quality of available soil,  the  Agency anticipates  that many owners
 or ooerators will use  membrane  liners protected above  and below bv
 buffer soil layers instead of compacted  clay for  the cover layer which
 should he low in permeability.  These membrane liners  may be cost effec-
 tive if adequate material  is unavailable  or an acceptable degree of
 compaction is not possible at a particular facilitv, given the  wastes
 disposed  or facility conditions.

     If the owner or operator intends to  use soil available on-site for
 the final cover, he should state  in the  plan whether the  soil has previ-
 ously been excavated and stockpiled or whether excavation will  be
 required at closure.   The hauling distance of the soil should also  be
 included.  The plan will include  an estimate of the quantity of mate-
 rials to be purchased  off-site, if applicable.  If a membrane liner  is
 to be used, the owner  or operator should  state the tvpe of liner to be
 used and describe the  sub-hase preparation and the protective cover  of
 the liner in the closure plan.

     •  Cover Design

     The closure plan  shall contain descriptions of the proposed grading
and terracing for purposes of erosion control.  The description will
 include :

        Slope of cover which must be great enough to prevent water
        pooling but not encourage erosion;
        Length of run of slope; and
        Drainage and diversion structures to channel water away
        from the waste area.
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The owner or operator should also state whether a contractor or the
owner or operator will do the earthwork activities and whether the
necessary equipment is availahle on-site.

                               Vegetation

     Most impoundments, or portions of impoundments that have been
covered, will require Rood vegetation to stabilize slopes and retard
runoff flow, thus providing effective erosion control.  Other materials
besides vegetation may he used for this purpose; for example, facilities
located in very arid regions may use a gravel layer to stabilize the
cover soil.  In describing the vegetation to he used, the owner or
operator should include in the closure plan:

     •  Surface area requiring vegetation or other stabilizing
        material;
     •  Characteristics of vegetation to he planted, if
        applicable;
     •  Soil preparation nrocedures, if applicable; and
     •  Description of methods or techniques for alternative
        stabilizing cover if vegetation will not be planted.

     If vegetation is to be planted, the closure plan need onlv include
provisions for planting once during the closure period.  Any necessary
replanting will he carried out during the early years of post-closure
and will be discussed in the post-closure plan.

     •  Surface Area Requiring Vegetation or Other Stabilizing
        Material

     The estimate of the area requiring vegetation or other stabilizing
material at closure will be the maximum amount ever required during the
life of the facility, and will include:
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     -  Area of the impoundment requiring vegetation or other
        stabilizing material at final closure;
     -  Any portions of the impoundment that were capped as part
        of partial closure but were not vegetated, if applicable;
        and
     -  Areas that were previously vegetated but require some
        replanting.

     •  Characteristics of Vegetation

     The type of vegetation chosen, assuming vegetation is used to
prevent erosion, will vary according to the type of soil used for the
final cover (e.g., depth,  nutrients, pH, moisture), climate, amount of
rainfall, and other site-specific factors.  Information that would be
helpful in the closure plan includes the type of vegetation chosen;
climatic, soil, and maintenance requirements (e.g., temperature, rain-
fall, nutrients, pH, depth and moisture of soil, frequency of replant-
ing, watering, fertilizing); and the depth of the root structure to
ensure that the roots could not penetrate  through the cover into the
buried wastes.

     •  Soil Preparation Procedures

     A description of soil preparation  activities may include:

     -  Type and quantitv  of fertilizer reauired;
     -  Quantity of seed required;
     -  Tvpe and quantitv  of mulch required;  and
        Procedures for soil preparation (e.g.,  disking).

     If an alternative to  vegetation is to be used,  the  closure  plan
should include the tvpe  and quantity of materials to  be  used and an
explanation of how it will protect  the  integrity of the  cover.
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     The owner or operator should state whether or not a contractor will
be responsible for planting the vegetation or an alternative cover.  If
planting vegetation has heen part of prior partial closure procedures,
much of this information will he known from operating experience.

4.1.6  Ground-water Monitoring

     Ground-water monitoring "must he carried out during the active life
of the facility, and for disposal facilities, during the post-closure
care period as well."*  Monitoring will he in accordance with the
requirements specified in §265.90 at seq. of these regulations.  A
description of a monitoring program to he included in the closure plan
would include:

     •  The types of analyses required during closure, i.e., from
        the date that final wastes are received until closure is
        certified by the professional engineer, assuming the
        manner and frequency as required during operation; and
     •  Maintenance that is required of the ground-water
        monitoring svstem to ensure that it is in working
        condition for the post-closure period.

     The simplest way to describe the monitoring to be performed during
closure is to include a copy of the facility's ground-water sampling and
analysis program.  Since this program will not he implemented until one
year after the effective date of these regulations, the Agency will he
developing guidance for preparing monitoring plans.  This document is
not intended to provide guidance in this area; therefore, it is expected
that, in developing the closure plan, an owner or operator will use his
judgment in describing appropriate ground-water monitoring as required
by §265.90 et seq. and revise the plan when more data and guidance
become available.  The closure plan should include a coov of the facil-
itv's ground-water sampling and analysis program when it is available.
*EPA Interim Status Standards, 40 CFR 5265.90(h).
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                    Analyses Required  During  Closure

     According  to  the ground-water monitoring regulations,  samples
collected to establish ground-water quality must he obtained  and  ana-
lyzed for the following  parameters at  least annually:

     •  chloride
     •  iron
     •  manganese
     •  phenols
     •  sodium
     •  sulfate

Samples collected  to indicate ground-water contamination must be
obtained and analyzed for the following narameters at least semi-
annually:

     •  pH
     •  specific conductance
     •  total organic carbon
     •  total organic halogen

     The closure plan should include the maximum number and types of
ground-water analyses required during the closure period.  The number
and types of sampling and analyses required during closure depend on the
length of the closure period.  For example, if one set of analyses are
required annually and the others are required semi-annually, the  owner
or operator  should allow in his plan for the possibility that both sets
of analyses will be required within the closure period, in order  to make
provisions for the maximum number of analyses.  For this reason the
closure  plan mav include a schedule of more analyses than actually will
be needed  during closure.
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                              Maintenance

     The closure plan will also include a description of maintenance
activities necessary to ensure that the ground-water monitoring system
is in working condition for the post-closure period, which may include
replacing or redrilling wells, replacing seals and caps, pumps, etc.,
and required general maintenance.   Since ground-water monitoring during
closure is merely a continuation of monitoring performed during routine
operations, most of this information will he based on past operating
experience.

4.1.7  Closure Certification

     "When closure is completed, the owner or operator must suhmit to
the Regional Administrator certification hoth by the owner or operator
and by an independent registered professional engineer that the facilitv
has heen closed in accordance with the specifications in the approved
closure plan."*

     An independent professional engineer is required to certifv that
closure activities were performed  in accordance with the closure plan.
It is not expected that an engineer will perform detailed tests.  The
owner or operator will include in  the plan an estimate of the number of
periodic inspections to be made by an engineer.  The plan need not
include the name and state professional engineer's license number of the
engineer, although this will be required later as documentation.
*EPA Interim Status Standards, 40 CFR §265.115.

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4.1.8  Requirements for Some Facilities

     Some facilities, because of their site-specific characteristics,
e.g., facility design or location, may require additional activities at
closure.  These additional requirements include:

     •  Collecting, removing and treating leachate
     •  Gas collection
     •  Installing or maintaining fences

               Collecting, Removing and Treating Leachate

     If a system for collecting, removing and treating leachate is
present at an impoundment, the owner or operator must include plans for
its oneration during the closure period.  Procedures will he similar to
those during operation and include monitoring, collecting, removing,
treating, and disposing of leachate.  Since these procedures are only
required at facilities that have such a system in place,  it is expected
that an owner or operator will continue to operate as he  has done during
facility life.

     For facilities with such a system, a description of  procedures
might include:

     •  Procedures for collecting and pumping leachate (e.g.,
        leachate may collect in a sump and he pumped to a holding
        tank or pond or collected hy portahle equipment such as a
        vacuum truck;
     •  Monitoring program;
     •  Approximate volume of leachate collected during closure
        which will he  a function of  the length of closure;
     •  Location and procedures for  leachate treatment (including
        methods for storing,  pretreating,  and treating, e.g.,
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        biological or physical-chemical treatment,  evaporation,
        package treatment facility);
     •  A description of procedures including the design objec-
        tives of the treatment  chosen and all materials and equip-
        ment required;
     •  Procedures for treating and disposing of leachate (e.g.,
        transport/pumping procedures, procedures for discharging,
        including NPDES permit  number as required under the Clean
        Water Act, if applicable,  or  off-site services);
     •  Procedures for disposing or removing residuals from treat-
        ment (e.g.,  on-site  or  off-site); and
     •  Maintenance required during the closure period to ensure
        that the system is operating properly before post-closure
        begins, which may include:
        -  Repairs to parts  of  the system,
        -  Replacing and reinstalling parts, and
           Routine maintenance.

                          Gas Collection

     If a gas collection system is required during operation,  an owner
or operator should include in the  closure plan the monitoring procedures
to be followed during the closure  period.  Monitoring will likely  be
similar to that required during operation, and the details can therefore
be based on the owner's or operator's operating records.  The closure
plan will include:

     •  Procedures for collecting  gas, including:
        -  Design objectives of system, and
        -  Materials and equipment required;
     •  Details of monitoring required during closure which will
        he based on the length of  the closure period, including
        the tvpe and number  of samples and analyses and whether
        analyses are Hone on- or off-site; and

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     •  Maintenance required during  the closure  period  Co ensure
        that the system is operating  properly before  post-closure
        begins, which may include:
        -  Repairs to parts of the system,
        -  Replacement and reinstallation of parts, and
        -  Routine maintenance.

                 Installing or Maintaining Fences

     At some facilities, it may be desirable to restrict access, in
accordance with the security regulations, Subpart B,  §265.14, even after
the facility has been closed.  Although this requirement is at the
Regional Administrator's discretion,  the owner or operator should use
his judgment, considering factors such as facility location, surrounding
land use, and types of wastes buried  to decide whether to include a
security provision in the plan. At facilities in which access will he
restricted during the post-closure care period, owners or operators will
address either the maintenance of security equipment used during the
active life of the facility or installation of appropriate security
equipment.  In most cases,  this will  likely mean that an owner or
operator will install a fence or ensure that the existing fence is in
good condition at the time  of closure.

     If an owner or operator plans to Install a fence at closure, the
closure plan should state the area of the facility that will be enclosed
by the fence, the type of materials to be used, and dimensions of the
fence.  If a fence is already installed at the facility, the plan will
describe the types of repairs expected to be needed to ensure that it is
in good condition when post-closure begins.
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4.2  SURFACE IMPOUNDMENTS IN WHICH WASTES ARE REMOVED AT CLOSURE

     "(,i)  Ac closure,  the owner or operator may elect to remove from
the impoundment:

         (1)  Standing  liquids;
         (2)  Waste and waste residues;
         (3)  The liner,  if anv; and
         (4)  Underlying  and surrounding contaminated soil.

     (h)  If the owner  or operator removes all the impoundment materials
in paragraph (a) of this  Section, or can demonstrate under §261.3(f) of
this Chapter that none  of the materials listed in paragraph (a) of this
Section remaining at anv  stage of removal are hazardous wastes, the
impoundment is not further suhject to the requirements of this Part."*

4.2.1  Introduction
     The instructions and the outline are separated into the following
major headings which correspond with the regulations applicahle to
impoundments in which wastes are removed at closure.  The closure plan
should include a general description of facility conditions and must
include descriptions of the activities required to comply with the
following requirements:

     •  Removing of Inventory
     •  Decontaminating the Facility
     •  Cround-water Monitoring
     •  Closure Certification
*KPA Interim Status Sf indnrrls,  40 CFR §265.22«(a) and (M
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4.2.2  Facility Conditions

     The primary purpose of this portion of the closure plan is to
provide the Regional Offices with the information for an initial check
of the adequacy of the closure plan.  This section of the plan contains
a description of the factors determining the conditions of the facility,
including the capacity of the impoundment, the maximum amount of inven-
tory expected to accumulate on-site during operations, a description of
equipment and facilities, and a complete schedule of closure activities.
With this information readily available, an EPA inspector can quickly
evaluate the closure plan using a visual inspection to confirm that
facility conditions never exceed the specifications described in the
first part of the closure plan.

                          General  Information
     General information that would be useful in a closure plan
includes:

     •  Facility size;
     •  Volume of impoundment;
     •  Type of treatment
     •  Copy of NPDES permit, if the impoundment discharges
        through a point source to U.S. waters; and
     •  Procedures and  schedules for dredging during operation, if
        applicable.

     It is likely that  during the course of normal operations the
impoundment will he  dredged.   The closure  plan should  provide a schedule
for these periodic dreHgings, if applicable,  which will  include:

     •  Volume of waste dredged;
     •  Frequency of dredging;
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     •  Procedures for dredging; and
     •  Method of disposing of dredged material.

                             Partial Closure
     An owner or operator may partially close the impoundment during
facility operations by diking off areas of the impoundment which are no
longer to he used and properly closing those areas.  Partial closure
includes those activities that reduce what needs to he done at final
closure to comply with the regulations.  The closure plan must include
plans to close the largest areas of the impoundment that will be open at
any given time.  If an owner or operator intends to partially close the
impoundment, the closure plan must include "a description of how and
when the facility will he partially closed, if applicahle, and ulti-
mately closed".*  The plan must provide a schedule of these activities
and a description of:

     •  The size of the area partially closed;
     •  Frequency of these partial closures; and                                    M
     •  Procedures for removing all hazardous wastes and
        partially closing the area.

     The kev factor about partial closure which must be made clear in
the closure plan is that partial closure procedures (i.e., activities
which reduce the requirements at final closure) must he in accordance
with the technical closure requirenients and consistent with the plans
for final closure.  Therefore, an owner or operator of an impoundment in
which wastes are removed at closure must remove and properly dispose of
all hazardous wastes from areas xvhich are partially closed.
*EPA Interim Status Standards, 40 CFR §265.112(a)(1),
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                         Maximum Amount of Waste

     The owner or operator must  include  in  the  closure plan  "an estimate
of the maximum inventory of wastes in storage or in treatment at any
given  time during the life of the facility."*   This estimate of the
maximum amount of inventory ever expected over  the life of the facility
enables an inspector to evaluate this portion of plan based  on a visual
inspection of the facility.

                        Equipment and Facilities

     The owner or operator should describe  the kinds of equipment and
facilities on-site (e.g., transport vehicles, excavation equipment,
spreaders, etc.), to enable an inspector to quickly evaluate the pro-
posed plans for decontaminating the facility.

                        Schedule  of  Final Closure

     The closure plan must include a "schedule for final closure which
must include,  as a minimum, the anticipated date when wastes will no
longer be received,  the date when completion of final closure is antici-
pated, and intervening milestone dates which will allow tracking of the
progress of closure.   (For example,  the expected date for completing
treatment or disposal of waste inventory must be included, as must the
planned date for removing any residual wastes from storage facilities
and treatment  processes.)"**

     The closure period begins with the final acceptance of waste and
concludes when closure  has been certified by the professional
*EPA Interim Status Standards, 40 CFR §265.112(a)(2).
**EPA Interim Status Standards,  40 CFR §265.112(a)(4).

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engineer.*  The schedule of closure activities applicable to surface
impoundments in which wastes are removed at closure should include:

     •  Final date for accepting wastes;
     •  Date all treatment completed;
     •  Date that all standing liquids will have heen removed;
     •  Date that all sludge will have been removed;
     •  Final date facility decontaminated;
     •  Final date of closure, which is the date that closure has
        heen certified by the professional engineer;
     •  The total time required to close the facility, i.e., time
        from the final acceptance of waste to certification by the
        professional engineer;
     •  Justification if closure will take longer than six months
        from the date of the final acceptance of wastes
        (§265.113(b)).  If an owner or operator requires more than
        six months to complete closure, the closure plan must
        include a justification for the need for additional time
        as well as proof that all steps have been taken to elimi-                       m
        nate all threats to human health and the environment.  A
        further discussion of closure schedules is in Section
        2.2.6.

4.2.3  Removing Inventory

     An owner or operator of an impoundment must include in the closure
plan:
*The final date of closure referred to here is the date that the
  closure technical requirements have been certified by the professional
  engineer.  The final date of closure, for purposes of financial
  responsibility requirements is the date that the Regional Adminis-
  trator releases the closure fund to the owner or operator.  A
  discussion of the legal implications of closure certification is in
  Section 2.2.8.
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     •  An estimate of the maximum amount of inventory reasonably
        expected on-site over the life of the facilitv;
     •  Methods and procedures for treating or removing all inven-
        torv, including processing residues; and
     •  Time schedule.

                           Maximum  Inventory
     The closure plan must include "an estimate of the maximum inventory
of wastes in storage or in treatment at any given time during the life
of the facility".*  Inventory, in the case of impoundments in which all
wastes are to be removed at closure, includes all wastes in all stages
of processing, including wastes in storage and in the impoundment.

     The estimate of inventory must be based on the maximum amount ever
expected to be on-site over the life of the facility, assuming normal
conditions.  It should alwavs be high enough to ensure that if an
inspector came onto the facility, the amount of inventory would not
exceed the estimate in the plan, assuming normal operating conditions.

     Since accumulating inventory has often been the cause of severe
environmental damage, an owner or operator should keep the amount of
wastes in storage to a minimum.  Requiring in the closure plan an esti-
mate of the maximum amount of inventory also alerts the Regional Admin-
istrator to a potential hazard if a visual check of the facilitv shows
that the estimate in the plan has been exceeded.  If the amount of
wastes on-site ever exceeds the estimate in the plan, the owner or
operator must revise the plan to reflect actual conditions; however, if
the owner or operator can justify to the Regional Administrator that the
excess inventory is a result  of unexpected operating conditions and the
*F.PA Interim Status Standards,  40 CFR §265. 112(a)(2).
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original estimate of maximum inventory can be restored quickly, the
Regional Office might not require the owner or operator to revise the
plan.  A further discussion of maximum inventory is in Section 2»2.A.              I

       Methods and Procedures for Threat ing and Removing Inventory

     The procedures to be followed are very site-specific and must be
described in the closure plan.  At a minimum, the owner or operator will
describe procedures necessary to complete the following activities:

     •  Operating the facility in a routine manner while treating
        all hazardous wastes in storage and in the impoundment
        which are to be removed by evaporation or treated and
        discharged;
     •  Removing and transporting all liquids, not removed by
        evaporation or treated and discharged on-site, to an
        operating permitted facility or a facility operating under
        interim status; and                                                        -
     •  Removing all hazardous sludge and other hazardous wastes
        from the impoundment.                                                     M

     The closure plan should include a description of procedures to be
used for treating all wastes in storage and removing all standing
liquids.  If wastes are to be discharged, the owner or operator must
comply with the Clean Water Act.  An owner or operator may prefer to
transfer some liquids to another facility because of operating problems
or because treatment is taking longer than anticipated.  In this case,
the owner or operator should include an estimate of the amount disposed
off-site and ensure that the receiving facility is either permitted or
operating under interim status.

     An owner or operator must include plans for removing and managing
all hazardous sludges, and procedures for sludge stabilization if
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performed cm-site.  Under these regulations, an owner or operator  is
only required to remove and manage the hazardous solid wastes  from the
impoundment.  Upon removing the sludge from the impoundment, "he becomes
a generator of hazardous waste and must manage it in accordance with all
applicable requirements of Parts 262, 263 and 265 of this Chapter."*

     The closure plan should include an estimate of the quantity of
sludge to be removed and the procedures to be used.  If disposed on-
site, the owner or ooerator must have an available permitted disposal
area or one with interim status.  The owner or operator also must  conply
with all regulations applicable to disposal facilities, including  post-
closure care.  If removed to an off-site TSDF, the owner or operator
should ensure that the receiving facility is either permitted or operat-
ing under interim status.

                             Time  Schedule
     Accumulating inventory over long periods of time has often been the
cause of serious environmental damages; thus, the regulations restrict
the amount of time allotted during closure for removing all wastes:

     "Within 90 davs after receiving the final volume of hazardous
     wastes, the owner or operator must treat all hazardous wastes
     in storage or in treatment, or remove them from the site, or
     dispose of them on-site, in accordance with the approved
     closure plan."**

     The owner or operator of an impoundment should include an estimate
of the  time required for treatment and removal of wastes.  If treatment
*EPA Interim Status Standards,  40 CFR §265.228 (Comment),
**EPA Interim Status Standards,  40 CFR §265.113(a).
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processes routinely take longer than 90 days, the plan should include a
justification for this extension,  subject to the Regional Administra-
tor's approval.

4.2.4  Decontaminating the Facility

     The closure plan must include "a description of the steps needed to
decontaminate facility equipment during closure."*  According to the
regulations, "when closure is completed, all facility equipment and
structures must have been properly disposed of, or decontaminated by
removing all hazardous waste and residues."**  The closure plan should
include a description of the cleaning, testing and/or disposing of all
items so that no hazardous materials remain on~site.  This will include
cleaning up or disposing of contaminated equipment, soils and residues.
The degree of cleanup required at a given facility at the time of final
closure will vary according to the owner's or operator's operating
practices.

                        Decontaminating the Soil
     The closure plan will include a list of all areas with potentiallv
contaminated soil requiring removal and disposal, an estimate of the
quantity of contaminated soil to be disposed, and a description of
disposal methods.  Cleanup of hazardous waste drips and spills will be
part of routine operating practices.  The residues included in the
closure plan are those on the surrounding grounds as a result of closure
operations and  those not previously cleaned up (e.g., residues on dikes,
storage areas,  trenches, diversions, spill containment areas).  Soil
tasting may be  necessary depending on the facility conditions; the owner
 *EPA  Interim  Status  Standards, 40 CFR  $265.112(a)(3).
 **EPA Interim Status Standards,  40 CFR §265.114.

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or operator should state in the plan  the criteria used  to determine  the
amount of contaminated soil to he disposed or removed to an off-site
TSDF.  An owner or operator will need to refer to Section 261 of  these
regulations, "Identification and Listing of Hazardous Wastes,"  for the
criteria for identifying the characteristics of hazardous wastes.
Contaminated soil may be either disposed on-site in a separate  permitted
landfill, one operating under interim status, or disposed off-site to a
TSDF.  If disposed on-site at a multiple process facility, the  owner or
operator must prepare a closure and post-closure plan for the landfill.

               Decontaminating the Equipment and Facility

     The closure plan mav include a description of procedures used to
decontaminate or dispose of the following:

     •  All transport and storage containers, tanks and ancillarv
        facilities;
     •  All equipment, including that used for transport, storage,
        treatment disposal and cleaning processes;
     •  Cleaning wastes and residues from cleaning; and
     •  Any remaining water on-site from rain or  snow.

     The owner or operator must include in the closure plan a descrip-
tion of procedures for cleaning all equipment and facilities,  an
estimate of the amount of residues resulting from cleaning (e.g.,
residues from the cleaning process, cleaning fluids that are hazardous,
wastewaters, containers), and plans for their disposal or removal to an
off-site TSDF.   For facilities at which it is common for water to accu-
mulate as a result of rain or snow, the closure plan must provide for
removing excess water at the time of closure.

     An owner or operator will either choose to dispose of all residues
from decontamination  off-site  or  will dispose of  them on-site  if a
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disposal facility is available.  As discussed above In Section 4.2.3, if
wastes are disposed of in a trench on-site, an owner or operator must
also perform post-closure care.

4.2.5  Ground-water Monitoring

     Ground-water monitoring "must be carried out during the active life
of the facility."*  The closure plan must include provisions for moni-
toring throughout the closure period until the professional engineer
certifies that closure has been completed.  Monitoring will be in accor-
dance with the requirements specified in §265.90 et aeq. of these
regulations.

     The simplest way to describe the monitoring to be performed during
closure is to include a copy of the facility's ground-water sampling and
analysis program.  Since this program will not be implemented until one
year after the effective date of these regulations, the Agency will he
developing guidance for preparing monitoring  plans.  This document is
not intended to provide guidance in this area; therefore, it is expected
that, in developing the closure plan, an owner or operator will use his
judgment in describing appropriate ground-water monitoring as required
by §265.90 et ge
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     •   chloride
     •   iron
     •   manganese
     •   phenols
     •   sodium
     •   sulfate

Samples  collected  to indicate ground-water contamination must  be
obtained and analyzed for the following parameters at  least  semi-
annually:

     •   pH
     •   specific conductance
     •   total organic carbon
     •   total organic halogen

     The closure plan should include the maximum number and  types of
ground-water analyses required during the closure period.  The number
and types of sampling and analyses required during closure depend on the
length of the closure period.  For example, if one set of analyses are
required annually and the others are required semi-annually, the owner
or operator should allow in his plan for the possibility that both sets
of analyses will be required within the closure period, in order to make
provisions for the maximum number of analyses.  For this reason the
closure plan may need to include a schedule of more analyses than will
actually be performed during closure.

4.2.6  Closure Certification

     "When closure is completed, the owner or operator must submit r.o
the Regional Administrator certification both by the owner or operator
and bv an independent registered professional engineer that the facility
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has been closed in accordance with the specifications in the approved
closure plan."*

     An independent professional engineer is required to certify that
closure activities were performed in accordance with the closure plan.
It is not expected that an engineer will perform detailed tests.  The
owner or operator will estimate the numher of periodic inspections to be
made hv an engineer and include it in the plan.  The plan need not
include the name and state professional engineer's license numher of the
engineer, although this might he required later as documentation.
*EPA Interim Status Standards, 40 CFR §265.115.
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         4.3   SAMPLE  CLOSURE  PLAN OUTLINE:   SURFACE IMPOUNDMENTS
                   IN  WHICH  WASTES  REMAIN  AT  CLOSURE
EPA Facility ID No.
Owner's or Operator's Name
Address & Phone No. _______
Facility Address 	
 I.   FACILITY CONDITIONS
     A.   General information
         1.  Size of impoundment facility (include reference map)
         2.  Volume  of impoundment
         3.  Type of treatment
         4.  Copy of NPDES water pollution control permit if you
             discharge through a point source to U.S. waters
         5.  Schedule of dredging, if applicable
             a.   Volume of waste dredged
             h.   Frequency of dredging
             c.   Procedures for dredging
             d.   Method of disposal of dredged materials
     B.   Schedule of partial closures, if applicable (milestone chart)
         1.  Size of each area partially closed
         2.  Methods for partial closure (removal of wastes or cover)
         3.  Maintenance of partially closed  areas
     C.   Maximum amount of waste ever on-site in any stage of processing
         1.  Maximum volume of waste In impoundment
         2.  Maximum volume of waste in storage awaiting impoundment
     D.   Inventory of auxiliary equipment
     E.   Schedule of final closure (milestone chart)
         1.  Final date wastes accepted
         2.  Date all treatment completed
         3.  Date all free liquids removed
         4.  Date facility decontaminated

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         5.  Date final cover completed
         6.  Final date vegetative cover planted or other material
             placed
         7.  Final date closure completed
         8.  Total time required to close facility
         9.  Justification if closure is longer than six months

II.  REMOVING ALL INVENTORY
     A.  Maximum amount of waste on-site in any stage of processing
         1.  Total amount of wastes in drums and number of drums in
             storage,  if applicable
         2.  Volume of hulk wastes in any stage of processing including
             storage
         3.  Total amount of residues from processing
         4.  Maximum quantity of liquid in impoundment
     B.  Procedures for treating or disposing of inventory, including
         free liquids, on-site
         1.  Amount of inventory treated on-site
         2.  Method of treatment (e.g., package treatment facility,
             evaporation, hiological treatment)
         3.  Method of discharge or disposal
         4.  Time estimate for treatment or disposal, if disposed of in
             a landfill on-site
     C.  Method of stabilizing sludge
         1.  Type of bulking agent used
         2.  Amount of bulking agent required
         3.  Source of material
         4.  Equipment required for stabilizing sludge
         5.  Availability of equipment
     D.  Sludge disposal, if applicable
         1.  Quantity of sludge to he disposed
         2.  Procedures for sludge disposal
             a-  State If disposed in another section of impoundment
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              b.  If disposed on-site in landfill, describe procedures
              c.  If removed to an off-site TSDF
                 (1)  Method of treatment or disposal
                 (2)  Approximate distance to TSDF
      E.  Procedures for off-site treatment or removal of inventory
          1.   Quantity of wastes removed to an off-site TSDF
          2.   Method of off-site treatment or disposal
          3.   Approximate distance to TSDF

III.   DECONTAMINATING THE FACILITY
      A.  Area of facilitv with potential soil contamination (sq.  yd.)
          1.   List areas with potential  contaminated  soil
              a.  Number of soil samples, if necessary
              h.  Criteria for determining contamination
          2.   Estimated depth of soil requiring removal
          3.   Total amount of contaminated soil (cu.  yd.)
              a.  Amount of contaminated soil disposed on-site  and method
                  of disposal
              b.  Amount of contaminated soil disposed off-site
      B.  All  equipment and/or facilities (e.g.,  tanks,  basins,  earth-
          moving equipment,  piping and containers) requiring
          decontamination
          1.   Name  each piece of equipment and/or storage facilities  and
              procedures for  cleaning (e.g.,  steam-cleaning, hydro-
              blasting, etc.)
              a.  Owner or operator  labor or  contractor
              b.  Ouantitv of residues from cleaning
          2.   Nvimber of containers requiring  disposal  or decontamination
              a.  Method of  cleaning  and/or disposal  of  containers
              b.  Volume of residues
          3.   Method for treating or  disposing of residues  from
              rtecontamination (including wastewater and  liquid  wastes'!
              a.   Ouantitv treated or disposed of on-site and method  of
                  treatment or  disposal
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             h.  Quantity removed  off-site
         4.   Estimated  amount of water  on-site requiring removal (e.g.,
             snow and  rain accumulation)
             a.  Methods  for  removal
             b.  Source of disposal  (on-site  versus off-site)
                (1)  If on-site disposal  area
                    (a)  Procedures

IV.   COVER AND VEGETATION
     A.   Final cover
         1.   Total area to be covered  (sq. yd.) (line  a 4- line b)
             a.  Area  of  facility  not  previously partially closed  with
                 appropriate  cover
             b.  Area  of  any  portions  of  facility open to dispose  of
                 inventory and wastes  from decontamination
         2.   Characteristics  of  final  cover
             a.  Type(s)  of material(s) (e.g., soil of 10"  cm/sec
                 permeability)
             b.  Depth  of material(s)
             c.  Total  amount of material(s)  required
             d.  Amount and type of  soil  additives, if applicable
             e.  Source of material(s)
                (1)  Quantity available on-site
                    (a)  Excavation  required
                    (b)  Approximate hauling  distance
                (2) Amount purchased  off-site
                    (a)  Approximate hauling  distance
         3.   Final cover  design
             a.  Slope  of cover
             b.  Length of run of  slope
             c.  Type  of  drainage  and  diversion structures
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4.  Earth-moving procedures
    a.  Contractor or owner or operator to lay cover?
    b.  Equiument needed for hauling, spreading, grading,
        compacting
    c.  Available on-site or rental?
Vegetation (if not planting vegetation, omit parts 1 through 3)
1.  Total area requiring vegetation (acres)
    a.  Area of final cover which will have vegetation (acres)
    b.  Area partially closed but never vegetated (acres)
    c.  Area previously vegetated but requiring some replanting
        (acres)
    d.  Percentage of total area assumed to require replanting
        during closure (%)  (number of acres)
2.  Characteristics of vegetation
    a.  Name or tvpe of vegetation (e.g.,  rve grass)
    b.  Climatic, soil and  maintenance requirements (e.g.,
        temperature, moisture and nutrients requirements,
        replanting freauency)
    c.  Root structure (expected  penetration depth of roots)
3.  Soil preparation procedures
    a.  Tvpe and  quantity of fertilizer  required  per  acre;
        total required
    b.  Ouantity  of seed  required per acre; total required
    c.  Tvoe and  quantity of mulch renuired per  acre; total
        required
    d.  Contractor  labor  or owner or operator labor?
4.  Procedures for  controlling  cover erosion if  vegetation is
    not to he planted
    a.  Tvpe and  quantity of materials to  be  used
    b.  Justification  for materials chosen
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  V.  GROUND-WATER MONITORING
      A.  Analyses required during closure
          1.  Maximum number of ground-water quality analyses required
              during closure
          2.  Maximum number of ground-water contamination analyses
              required during closure
          3.  Details of ground-wj'ter monitoring program (include copv of
              ground-water sampling and analysis program when available)
      B.  Maintenance of monitoring equipment
          1.  Number of wells requiring redrilling
          2.  Number of wells requiring replacement
          3.  Need for replacement parts to system (name parts, e.g.,
              pumps, seals, caps)
          4.  Required routine maintenance

 VI.  CLOSURE CERTIFICATION
      A.  Approximate number or schedule (e.g., everv two weeks) of
          periodic inspections expected by certified professional
          engineer

VII.  COLLECTING, REMOVING AND TREATING LEACHATE
      If a leachate collection, removal and treatment system is installed
      at vour facilitv, complete this section.
      A.  Describe your leachate collection system (i.e., pumping and
          collecting procedures
          1.  Describe the monitoring svstem
          2.  Estimated volume of leachate collected per month
      B.  Describe leachate treatment process
          1.  Is treatment on-site or off-site?  If on-site treatment,
              describe process for treatment
              a.  Design objectives
              b.  Materials and equipment required
      C.  Disposing of leachate
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           1.  If discharged to public waters, refer to water pollution
               control pernit number in Section I - "Facility Conditions'
           2.  If hauling off-site, distance to TSDF
           3.  Disposing of residuals
               a.  Quantitv of residuals
               h.  Characteristics
               c.  If disposed on-site, where?  (including drawing of
                   disposal area)
               d.  If off-site,  distance to TSDF
           4.  Maintaining equipment
               a.  Repairs and replacements required
               b.  Regular maintenance required over the duration of
                   closure

VIII.   GAS COLLECTION
       If a gas collection system  exists at your facility, complete this
       section.
       A.  Procedures for collecting gas
           1.  Design objectives of system
           2.  Materials and equipment required
       B.  Monitoring requirements
           1.  Type  of monitoring  samples
           2.  Number of samples
           3.  Tvpe  of analysis
           4.  Where  are analyses  performed?
       C.  Maintenance of monitoring equipment
           1.  Repairs renuired  during closure
           2.  Replacements required during closure
           3.  Routine maintenance  required during the  closure period

  IX.   INSTALLING OR  MAINTAINING THE FENCE
       A.   If fence already exists  at  your facility, describe required
           maintenance at closure  to ensure it  is in good  condition
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B.  If fence is to be Installed:
    1.  Area to he enclosed
    2.  Type of materials used
    3.  Dimensions of fence
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         4.4 SAMPLE CLOSURE PLAN OUTLINE:  SURFACE IMPOUNDMENTS
                 IN WHICH WASTES ARE REMOVED AT CLOSURE
EPA Facllttv ID No.
Owner's or Operator's Name
Address & Phone No. 	
Facility Address
    FACILITY CONDITIONS
    A.  General information
        1.  Size of impoundment facility (include reference map)
        2.  Volume of impoundment
        3.  Type of treatment
        4.  Copy of NPDES water pollution control permit if you
            discharge through a point source to U.S. waters
        5.  Schedule of dredging, if applicable
            a.   Volume of waste dredged
            h.   Frequency of dredging
            c.   Procedures for dredging
            d.   Method of disposal of dredged materials
    B.  Schedule of partial closures, if applicable (milestone chart)
        1.  Size of each area partially closed
        2.  Methods for partial closure (cover or removal of wastes)
        3.  Maintenance of partially closed areas
    C.  Maximum amount of waste ever on-site in any stage of processing
        1.  Maximum volume of waste in impoundment
        2.  Maximum volume of waste in storage awaiting impoundment
    D.  Inventory of auxiliary equipment
    E.  Schedule of final closure (milestone chart)
        1.  Final date wastes accepted
        2.  Date all treatment completed
        3.  Date all free liquids removed
        4.  Date all sludges removed
        5.  Date facility decontaminated

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         6.  Final date of completed closure
         7.  Total time required to close facility                                  I
         8.  Justification if closure is longer than six months

II.  REMOVING ALL INVENTORY
     A.  Maximum amount of waste on-site in any stage of processing
         1.  Total amount of wastes in drums and number of drums in
             storage,  if applicable
         2.  Volume of bulk wastes in any stage of processing including
             storage
         3.  Total amount of residues from processing
         4.  Maximum quantity of liquid in impoundment
         5.  Maximum quantity of sludge in impoundment
     B.  Procedures for treating or disposing of inventory, including
         free liquids, on~site
         1.  Amount of inventory treated on-site
         2.  Method of treatment (e.g., package treatment facility,
             evaporation, biological treatment)
         3.  Method of discharge or disposal, if disposed in a landfill             M
             on-site
         4.  Time estimate for treatment
     C.  Procedures for removal of all liquids not treated and disposed
         on-site
         1.  Quantity of liquids not treated and discharged on-site
         2.  Method of off-site treatment or disposal
         3.  Approximate distance to off-site TSDF
     D.  Removing sludge
         1.  Volume of sludge to he removed
         2.  >fethod for removing sludge and residuals
             a.  Is equipment on-site or rental required?
             b.  Owner or operator labor or contractor?
         3.  Treating sludge
             a.  If treatment is performed on-site, describe treatment
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              b.  Stabilizing sludge
                  (1)  Type of bulking agent used
                  (2)  Amount of bulking agent required
                  (3)  Source of material
                  (4)  Equipment required
                  (5)  Availability of equipment
          4.  Disposing of sludge
              a.  If on-site disposal, provide map of disposal location
                  (1)  Quantity disposed on-slte
                  (2)  Size of area needed for disposal
                  (3)  Procedures for disposal
              b.  If off-site treatment or disposal
                  (1)  Quantity removed to an off-site TSDF
                  (2)  Method of treatment or disposal (e.g.,  landfill,
                       etc.)
                  (3)  Approximate distance to TSDF

III.   DECONTAMINATING THE FACILITY
      A.   Area of facility with potential soil contamination (so.  vd.)
          1.  List areas  with potential contaminated  soil
              a.  Number  of soil samples, if necessary
              b.  Criteria for determining contamination
          2.  Estimated depth of soil requiring removal
          3.  Total  amount of contaminated soil (cu.  yd.)
              a.  Amount  of contaminated soil disposed on-site
                  (1)  Method of disposal
                  (2)  Construction required if applicable
                  (3)  Size,  location and design of on-site  disposal
                       method
              b.  Amount  of contaminated soil disposed off-site
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     B.  All equipinent and/or facilities (e.g.,  tanks,  basins,  earth-                .
         moving equipment,  piping and  containers) requiring                          "
         decontamination
         1.   Name  each piece  of equipment and/or storage  facilities and
             procedures for cleaning (e.g.,  steam cleaning, hydro-
             blasting, etc.)
             a.  Owner or operator labor or  contractor
             b.  Quantity of  residues  from cleaning
         2.   Number of containers to be disposed or decontaminated
             a.  Method of  cleaning arid/or disposing of containers
             b.  Volume of  residues
         3.   Method for disposing of residues from decontamination
             (Including wastewater and liquid wastes)
             a.  Quantity managed on-site
                 (1)  Method  of treatment or disposal method
                 (2)  Size, location and design  of on-site disposal
                      method
                 (3)  Disposal plans for liquid  waste                               ~"
             b.  Quantity disposed off-site                                           •
         4.   Estimated amount of water on-site requiring  removal (e.g.,
             snow and rain  accumulation)
             a.  Methods for  removal
             b.  Source of  treatment or disposal (on~sit€i versus off-
                 site)
                 (1)  If on-site, describe procedures

IV.  GROUND-WATER MONITORING
     A.  Analyses required  during closure
         1.   Maximum number of ground-water  quality analyses required
             during closure
         2.   Maximum number of ground-water  contamination analyses
             required during  closure
         3.   Details of ground-water monitoring  program (Include copy of
             ground-water sampling and analysis  program when available)

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    B.  Maintenance of monitoring equipment
        1.  Number of wells requiring redrilline
        2.  Number of wells requiring replacement
        3.  Need for replacement parts to system (name parts, e.g.,
            pumps, seals, caps)
        4.  Required routine maintenance

V.  CLOSURE CERTIFICATION
    A.  Approximate number or schedule (e.g.,  every two weeks) of
        periodic inspections
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                     5.0  LAND TREATMENT FACILITIES:
                  GUIDANCE FOR DEVELOPING CLOSURE PLANS

 5.1  INTRODUCTION

     Land treatment Is a waste management practice  that involves apply™
 ing and incorporating waste into the surface soil.  In effective land
 treatment this surface layer of soil acts as a biochemical  "reactor"
 where, ideally, soil micro-organisms consume the organic components of
 the waste and transform them into cellular matter and harmless materials
 such as carhon dioxide.  The nondegradable portion  of the wastes applied
 to land treatment facilities (e.g., metals, complex organics) are immo-
 bilized by chemical reactions in the soil.  These nondegradable waste
 constituents, over a period of time, accumulate in  the surface soil.

     The following material provides instruction for the EPA Regional
 Offices and the regulated community concerning the  preparation of
 closure plans.  Following the instructions is a sample closure plan
 outline which illustrates the concepts and intentions of the plan.  This
 document and the accompanying outline are intended merely as guidance
 and many parts of them may not be applicable to any given facility.
 This guidance is based on the assumption that the land treatment facil-
 ity has been operating properly, and that no special requirements will
 be necessary to ensure adequate closure.  The purpose  of this document
 is not to provide guidance for remedial measures, but  rather to provide
assistance to owners or operators of well-operated facilities in devel-
 oping closure plans.  A general discussion of conceivable problems that
might exist at some  land disposal facilities and the kinds of measures
 that might be needed is included in Chapter 9.0, "Closure and Post-
 Closure Activities Required  at Some Disposal Facilities."
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     The Instructions for developing closure plans and the accompanying
outline include all types of activities which may be applicable to the
following three possible closure scenarios for land treatment
facilities:

     (1) Land treatment facility in which, at the completion of
         closure, no hazardous constituents remain in the soil;
     (2) Land treatment facility in which hazardous constituents
         remain at closure and the contaminated soil is removed;
         and
     (3) Land treatment facility in which hazardous constituents
         remain at closure and the facility is stabilized to
         control the migration of wastes.

     When developing a closure plan during interim status, the owner or
operator should assume that the facility's treatment operations will be
successful if the facility has been operating properly to date.  If the
treatment is expected to render all wastes non-hazardous and, at the
time the plan is written, the treatment is working as anticipated, the
owner or operator should base his closure plan on the assumption that no
wastes will remain at closure.  An owner or operator of a land treatment
facility in which no wastes will remain at closure must include in the
closure plan provisions for the continued degradation of any remaining
degradable components and provisions for testing to demonstrate compli-
ance with the closure regulations specified in §265.280.  If no wastes
remain at the completion of closure, post-closure care will not be
required.

     An owner or operator of a treatment facility which renders wastes
less hazardous must base his closure plan on the assumption that, at
closure, he will either remove the remaining contaminants or stabilize
the facility to control waste migration.  If he does not plan to remove
the contaminated soil, he must also prepare a post-closure plan provid-
ing for soil and ground-water monitoring and maintenance.

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     The owner or operator nay assume that the land treatment will he
successful and that only routine closure activities will be required.
If, however, during the course of operations, he finds that the treat-
ment is not rendering the wastes non-hazardous, he must change his
assumptions and develop a new closure plan.  The owner or operator
should always be sure that the closure plan is appropriate for the
conditions L'iat exist at the time the plan is written.

     In preparing the closure and, if applicable, post-closure plans,
the owner or operator must address how the facility will be closed "in a
manner that (a) minimizes the need for further maintenance, and (b)
controls, minimizes or eliminates, to the extent necessary to protect
human health and the environment, post-closure escape of hazardous
waste, hazardous waste constituents, leachate, contaminated rainfall, or
waste decomposition products to the ground water, or surface waters, or
to the atmosphere."*

     The terms "human health," "environment" and "control" are all
relative terms.  In some cases, protection of human health and environ-
ment may mean no discharge, while in other cases, some escape may be
acceptable.  To meet these objectives, the owner or operator must
develop as part of his closure and post-closure plans, an adequate
analysis of the effectiveness of the proposed closure and post-closure
procedures.

     The instructions and the outline are separated into the following
major headings:

     •   Facility Conditions
     •   Removing Inventory
     •   Material in Treatment
*EPA Interim Status Standards,  40 CFR §265.112(a).
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     •   Decontaminating the Facility
     •   Removing Contaminated Soil                                                    *
     •   Cover and Vegetation
     •   Monitoring Operations
     •   Closure Certification
     •   Food Chain Crops

     The closure plan for a land treatment facility will differ depend-
ing on how the facility is closed, as discussed above.  The instructions
are meant to he inclusive, and therefore, all section will not he
applicable to all land treatment facilities.

5.2  FACILITY CONDITIONS

     The primary purpose of this portion of the closure plan is to
provide the Regional Offices with the information for an initial check
of the adequacy of the closure plan.  This section of the plan contains
a description of the key factors determining the condition of the facil-
ity; that is, a general description of the facility, the maximum extent                •
of the acreage that will be unclosed during the active life of the
facility, the maximum amount of inventory ever on~site during opera-
tions, a description of equipment, and a complete schedule of closure
activities.  With this information readily available, an Inspector can
quickly evaluate the closure plan using a visual inspection to confirm
that facility conditions never exceed the specifications in the first
part of the closure olan.

5.2.1  General Information

     The closure plan should include a general description of the facil-
ity, including:
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     •   Facility size;
     •   Topography;
     •   Soil type;
     •   Storage facilities (including all tanks, surface
         impoundments, drainage pits, etc.);
     •   Other waste facilities on-site, if applicable; and
     •   Waste characterization.

5.2.2  Maximum Extent of Operation

     According to the regulations, the description of closure activities
"must identify the maximum extent of operation which will be unclosed
during the life of the facility."*  In the case of land treatment facil-
ities, the extent of operation is a function of the types of wastes
which are treated, the rate of waste decomposition, and the amount of
treatment required during the closure period.  Particular areas of the
facility will likely require different kinds of activities at closure,
depending on the wastes that are being treated in each particular area,
their decomposition rate, and how recently the wastes have been land-
spread.  The more recently the wastes have been spread, the more exten-
sive the treatment activities that are needed.  Therefore, in order to
assume the maximum extent of operation in the closure plan, the owner or
operator should assume that:  (1) the largest area ever containing
wastes in any stage of treatment over the life of the facility is in
operation; and (2) the largest area ever spread at one time has most
recently been spread with the wastes that require the most extensive
treatment.
*EPA Interim Status Standards,  40 CFR §265.112(a)(1).
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5.2.3  Maximum Inventory

     The owner or operator must Include in the closure plan "an estimate
of the maximum inventory of wastes in storage or in treatment at any
given time during the life of the facility."*  The amount of waste
stored on-site awaiting landspreading in the land treatment fields is a
key factor influencing the amount of activity and the length of time
needed to achieve closure.  The estimate of maximum inventory enahles
the Regional Office to evaluate this portion of the closure plan based
on a visual inspection of the facility.

5.2.4  Equipment and Facilities

     The owner or operator should descrihe in the closure plan the kinds
of equipment and facilities on-site to enahle an inspector to quickly
evaluate the proposed plans for facility decontamination.

5.2.5  Schedule of Activities
     The closure plan must include "a schedule for final closure which
must include, as a minimum, the anticipated date when wastes will no
longer be received, the date when completion of final closure is antici-
pated, and intervening milestone dates which will allow tracking of the
progress of closure.  (For example, the expected date for completing
treatment or disposal of waste inventory must be included, as must the
planned date for removing any residual wastes from storage facilities
and treatment process?s.)"**
*EPA Interim Status Standards, 40 CFR §265.112(a)(2).
**EPA Interim Status Standards, 40 CFR §265.112(a)(4),

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     The closure period begins with the final acceptance of wastes and
concludes when closure has been certified by the professional engi-
neer.*  The schedule of closure activities for a land treatment facility
should include:

     •   Final date wastes accepted;
     •   Date all landspreading completed;
     •   Final date all waste decomposition completed;
     •   Final date facility decontaminated;
     •   Final date all decontaminated soil removed, if applicable;
     •   Date final cover completed, if applicable;
     •   Final date vegetative cover planted, if applicable (this
         date should he the date that planting is completed);
     •   Final date of closure and the effective date of post-
         closure, if applicable (the date when closure has been
         certified by the professional engineer);
     •   The total time required to close the facility (the time
         from the final acceptance of waste to completion of all
         treatment); and
     •   Justification if closure will take longer than six months
         from the date of the final acceptance of wastes
         (§265.1I3(b)).  A further discussion of closure schedules
         is in Section 2.2.6.

     The Agency anticipates that: the closure period, i.e.,  the period
from the final acceptance of waste to the professional engineer certifi-
cation, for most land treatment facilities will extend bevond the  nan-
dated six-month limit due to the relatively slow rate of waste
*The final date of closure referred to here is the date that the
 closure technical requirements have been certified by the  professional
 engineer.  The final date of closure for purposes of financial
 responsibility requirements is the date that the Regional  Admin-
 istrator releases the closure fund to the owner or operator.   A
 discussion of the legal implications of closure certification is in
 Section 2.2.8.

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decomposition.  The Agency will favorably receive any reasonable
requests for a longer closure period for a land treatment facility "if
the owner or operator can demonstrate that:  (1) the1 required or planned
closure activities will, of necessity, take him longer than six months
to complete, and (2) that he has taken all steps to eliminate any sig-
nificant threat to human health and the environment from the unclosed
but inactive facility."*  During this extended closure period, the moni-
toring program will continue.  After the decomposition of the waste has
been completed, the closure period will be completed.  If all materials
have been rendered non-hazardous, no post-closure care will be
required.  If the treatment has not rendered the material non-hazardous,
the owner or operator must either remove the material or stabilize the
land and provide some post-closure care.

5.3  REMOVING ALL INVENTORY

     An owner or operator of a land treatment facility must include in
the closure plan:

     •   An estimate of the maximum amount of inventory reasonably
         expected on-site at a given time;
     «   Methods and procedures for disposal of all inventory,
         including any residues from processing; and
     •   Time schedule.

5.3.1  Maximum Inventory
     The closure plan must include "an estimate of the maximum inventory
of wastes in storage or in treatment at any given time during the life
of the facility."**  Inventory, in the case of land treatment
*EPA Interim Status Standards, 40 CFR §265.113(h).
**EPA Interim Status Standards, 40 CFR §265. 112(aX2).
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facilities, includes all wastes in storage and pretreatment.  It should
be noted that, in some cases, an owner or operator may never accumulate
inventory or have wastes in pretreatment if wastes are always landspread
directly from the transport truck.  If an owner or operator expects that
he will accumulate inventory at any time over the life of the facility,
the estimate of the quantity of wastes in storage and pretreatment must
be included in the plan.  The estimate must he based on the ,-,aximum
amount that would ever be on-site during the life of the facility.  It
should always be high enough to ensure that if an inspector came onto
the facility, the amount of wastes in storage as well as in pretreatment
should not exceed the estimate in the plan, assuming normal operating
conditions.  If the amount of wastes in storage ever exceeds the closure
plan estimate, the owner or operator must revise the plan to reflect
actual conditions, unless the owner or operator can justify to the
Regional Administrator that the excess inventory is a result of unex-
pected operating conditions and the original estimate of maximum inven-
tory can be restored quickly.

5.3.2  Procedures for Landspreading Wastes in Storage and Treatment

     The procedures to be followed are site-specific and must be
described in the closure plan.  It is expected that procedures will
likely be a continuation of normal operating activities.  The closure
plan should include an estimate of the quantity of wastes requiring
pretreatment and a description of pretreatment procedures,  if appli-
cable.  The plan should also include a description of landspreading
procedures, including application rate and acreage required.

5.3.3  Other Methods of Removing Inventory

     At the time of closure, especially if operating problems occur,  an
owner or operator may choose to either utilize an on-site  alternative
method of treatment or disposal,  such as landfilling,  if a  permitted  one
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or one with interim status is oil-site, or remove some or all remaining
inventory to an off-site TSDF.  In either of these cases, the plan
should include the quantity of wastes to he removed and how the wastes
will be treated or disposed.  If the wastes are to he treated or dis-
posed on-site, the facility must be permitted or have interim status.
The owner or operator must have prepared a closure plan, and in the case
of disposal facilities, a post-closure plan, accounting for these
wastes.  If the wastes are to be removed to an off-site TSDF, the plan
should also state how the wastes will he treated and include an estimate
of the approximate distance to a permitted operating facility or one
operating under interim status.

5.3.4  Time Schedule
     The accumulation of inventory over long periods of time has often
been the cause of serious environmental damage; thus, the regulations
restrict the amount of time allotted during closure for disoosal of all
wa s te s :

     "Within 90 days after receiving the final volume of hazardous
     wastes, the owner or operator must treat all hazardous wastes
     in storage or in treatment, or remove them from the site, or
     dispose of them on-site, in accordance with the approved
     closure plan."*

     In the case of land treatment facilities, although the completion
of the treatment process (i.e., rendering wastes either non-hazardous or
less hazardous) will likely take longer than 90 days, all wastes should
be landspread and mixed within the 90-day period.  In some situations,
however, a longer period may be necessary; for example, in northern
climates,  three to four months may be needed to spread all of the wastes
*EPA Interim Status Standards, 40 CFR §265.113(3),
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because of adverse weather conditions.   In most  cases,  the  owner  or
operator should state In the plan how all of the Inventory  will be
spread within 90 days which ensures that he either has  the  capability  to
spread all wastes within 90 days or has an alternate on-site or off-site
facility available.  If the owner or operator can justify that a  longer
period is necessary (e.g., climatic conditions), the owner  or operator
should provide justification in the plan and an  estimate of the time
required to complete the spreading.

5.4  MATERIAL IN TREATMENT

     The closure plan must include a description of all procedures
necessary to complete land treatment of all areas which contain
hazardous wastes at the time of closure.  The closure plan  will include:

     •   An estimate of the maximum extent of operation;
     •   Procedures required for completion of all treatment; and
     •   Time required for land treatment.

5.A.I  Maximum Extent of Ooeration
     The closure plan must account for the maximum amount of treatment
likely to he required over the life of the facility.  The plan, there-
fore, will include an estimate of the largest area ever spread with
wastes over the life of the facility.  In addition, the owner or
operator should assume that, at closure, the largest area ever spread at
one time will have been recently spread with wastes requiring the most
extensive treatment.  The estimate should always be high enough to
ensure that, if an inspector came onto the facility, the actual condi-
tions would not exceed the estimate in the plan.  If conditions do
exceed the estimate in the plan, the owner or operator must revise the
plan, unless he can demonstrate to the Regional Office that the
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conditions are a result of unusual operating conditions and that the
specifications of the plan will he restored quickly.

5.4.2  Procedures Required to Complete Treatment

     The procedures to be followed are expected to he a continuation of
normal operating activities.  The plan should include a description of
the procedures necessary to operate the facility in a routine manner for
the completion of all treatment.  The plan should include the kinds of
activities required (e.g., tilling, soil pH, addition of nutrients) and
the frequency that these activities are performed.  If completing treat-
ment will take longer than six months, the owner or operator should
provide for periodic facility inspections to ensure that the facility is
in proper operating condition.

5.4.3  Time Schedule
     The closure plan should include an estimate of the time required to
complete all waste decomposition.  As discussed above in Section 5.3.4,               M
the regulations stipulate that all wastes be treated, disposed, or
removed within 90 days.

     In the case of land treatment facilities, it is intended that all
wastes be landspread within 90 days if possible, and that additional
time will he allowed for the completion of treatment, if necessarv.  If
an owner or operator requires more than 90 davs to complete treatment,
he should demonstrate in the closure plan that the longer period is
required to perform closure according to routine operating procedures
and that all necessary steps have been taken to eliminate any threat to
human health and the environment.  He should also provide an estimate of
the time required to complete treatment.  In cases where completing
treatment requires more than six months, which is the allotted time for
all closure activities (i.e., the time from the final acceptance of
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waste to closure certification, which includes completion of  treatment,
decontamination procedures, vegetation if necessary, etc.), a
justification for an extended closure period would  include the
justification for an extension of the 90-day period allotted  for
treating, disposing or removing inventory.

5.5  REMOVING CONTAMINATED SOIL REMAINING ON THE LAND TREATMENT FIELDS

     Some land treatment facilities, either by design (e.g., nondegrad-
able waste constituents) or due to some operating problems, will not
render the hazardous wastes non-hazardous.  If hazardous wastes remain,
the owner or operator may choose to remove all or part of the contami-
nated soil at the time of closure.  (If he does so, he becomes a
generator of hazardous waste.)  If all wastes are removed, the owner or
operator does not have to provide for post-closure care.

     The owner or operator will discuss in the closure plan the types of
soil testing and criteria to be used to determine whether the soil is
contaminated and whether removing the contaminated soil is an
appropriate closure method.  If, based on previous operating experience,
an owner or operator anticipates that the wastes will not he rendered
non-hazardous, he should include in the plan an estimate of the quantitv
of hazardous wastes expected to remain in the surface soil at closure
and the characteristics of these constituents.  If the owner or operator
deems it appropriate to remove all or part of the contaminated soil, he
may choose to place all of the soil in one area of the land treatment
field designated as a permanent waste repository.  He also may dispose
of the soil on-site in a landfill if one with interim status or a permit
is available, or remove it to an off-site TSDF.  Regardless of the
option chosen, the closure plan should include a description of the
quantities of soil removed,  procedures used  to treat or dispose of the
soil on-site, if applicable,  and the approximate distance to an off-site
facility if the  soil is sent off-site.
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5.6  DECONTAMINATING THE FACILITY

     The closure plan must Include "a description of the steps needed to
decontaminate facility equipment during closure."*  According to the
regulations, "when closure is completed, all facilitv equipment and
structures must have been properly disposed of, or decontaminated by
removing all hazardous waste and residues."**  The closure plan should
include a description of the cleaning, testing and/or disposing of all
items so that no hazardous materials remain undisposed on-site.  This
will include cleaning or disposing of contaminated equipment, soils and
residues.  The degree of cleanup required at a given facilitv at the
time of final closure will vary according to the owner's or operator's
operating practices.

5-6.1  Decontaminating the Soil

     The closure plan will list all areas (outside of the active land
treatment fields) with potentially contarvLnated soil and include a
description of removal and/or disposal methods.  Cleaning hazardous
waste drips and spills will be a part of routine operating practices.
The residues included in the closure plan are those on the surrounding
soil as a result of closure operations or those not previously cleaned
up.  Soil testing mav he necessary depending on the facility conditions;
the owner or operator should state in the plan the criteria used to
determine the amount of contaminated soil to he disposed.  An owner or
operator will need to refer to Section 261 of these regulations, "Iden-
tification and Listing of Hazardous Wastes," for the criteria for
identifying the characteristics of hazardous wastes.  In most cases, an
owner or operator will spread the contaminated soils on the active
*EPA  Interim Status Standards, 40 CFR §265.112(a) (3).
**EPA  Interim Status Standards, 40 CFR §265.114.

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 fields.  The hazardous components in the soil should he decomposed  hy
 the biological activity in the soil of the field.  If any soil will be
 removed  to a facility off-site, it should be so stated in the closure
 plan.

 5.6.2  Decontaminating the Equipment and Facility

     The closure plan should include a description of procedures used to
decontaminate or dispose of the following:

     •   All transport and storage containers, tanks and ancillary
         facilities;
     •   All equipment, including that used for transport, landspread-
         ing, tilling, waste-mixing, and cleaning processes; and
     •   Cleaning wastes and residues from cleaning.
     The owner or operator must include in the closure plan a descrip-
tion of procedures for cleaning all equipment and facilities, an
estimate of the amount of residues resulting from cleaning (e.g.,
residues from the cleaning process, hazardous cleaning fluids, waste-
waters, containers), and plans for their treatment, disposal or
removal.  This description may be relatively simple for the typical land
treatment facility, if many of the land treatment facility's fixed
facilites such as tanks or surface impoundments (for inventory storaee
and possible runoff water containment) have independent closure plans.
If these facilities do not have independent closure plans,
decontamination procedures must he described in the land treatment
facility's closure plan.

     The mobile equipment for spreading and mixing the waste with the
soil would have to be decontaminated.   The closure plan should include
quantitative information about the amount of decontamination activity
required and the estimated amounts of  hazardous wastes resulting from
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the decontamination.  The plan should include provisions for treating or            ,
disposing of residues.  It is likely that many residues (e.g., waste-
waters) nay be disposed on the land treatment fields.  The plan should
include a description of the methods and quantity of wastes treated or
disposed on- and off-site.

5.7  COVER AND VEGETATION

     At the completion of the land treatment process, if there are still
hazardous materials at the facility, an owner or operator may choose to
stabilize the land treatment fields to control the migration of hazard-
ous constituents rather than remove the contaminated soil.  If the haz-
ardous wastes are not removed, the owner or operator must also provide
post-closure care.

     In the closure plan, "the owner or operator must address the
following objectives and indicate how they will be achieved:

     (1) Control of the migration of hazardous waste and hazardous                  V
         waste constituents from the treated wastes into the
         ground water;
     (2) Control of the release of contaminated run-off from the
         facility into surface water;
     (3) Control of the release of airborne particular?
         contaminants caused by wind erosion; and
     (4) Compliance with $265.276 concerning the growth of food-
         chain crops."*

     To meet these objectives without removing the contaminated wastes,
an owner or operator may consider the use of cover materials, vegetation
or other stabilizing methods to control migration of containments.  In
*EPA Interim Status Standards, 40 CFR §265.280(a)

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controlling  the migration of pollutants,  the Agency Hoes not  intend  that
all facilities be required to maintain a  zero discharge; in some cases,
some escape  could he acceptable.  The closure plan must include a
description  of the proposed measures based on the owner's or  operator's
assessment of the technical needs of his  facility.  For example, if  at
closure, inorganics or organics recalcitrant to biological breakdown
still reamin on the land, a stabilizing vegetative cover would likely
retard runoff flow and adequately prevent soil and wind erosion and
migration of the wastes.  In many cases,  an elaborate clay cap, which
may he appropriate for a landfill, will be unnecessary to meet these
objectives.  An owner or operator may choose to add an admixture to  the
zone of incorporation to fix contaminants from leaching instead of
planting vegetation.

     The discussion in the closure plan should include:

     •   The area of the facility that requires some form of control;
         and
     •   Characteristics of proposed control method.

5.7.1  Area of the Facility Requiring Cover and Vegetation

     An owner or operator must include in the closure plan an estimate
of the maximum area of the facility that will retain hazardous waste
constituents after closure.   The area may include areas in which treat-
ment did not render the  wastes completely non-hazardous,  as well as
areas designated for disposal of contaminated soils transferred from
other portions of the  facility to reduce the  size of the  area requiring
containment.  An owner or operator will likely be able to estimate the
extent of the operation  requiring some kind of containment at closure
based on previous operating  experience; that  is,  he will  know which
wastes are  not rendered  non-hazardous by land treatment.
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5.7.2  Characteristics of Pro'posed Cover and Vegetation

     In determining the applicability of various closure methods (e.g.,
final cover, admixture, diversion structures, runoff collection and
treatment), an owner or operator will consider site-specific factors
such as the wastes remaining in the soil, location, soil type, and depth
to ground water.  The closure plan will include a description of the
proposed cover and vegetation which may include some of the following,
if applicable:

     •   Type of soil used for a final cover;
     •   Design of cover;
     •   Type of vegetation planted;
     •   Total amount of materials required;
     •   Source of materials;
     •   Type of admixture used; and
     •   Diversion structures.

5.8  MONITORING OPERATIONS

     The monitoring operations, i.e., unsaturated zone monitoring and
ground-water monitoring, which are conducted during the active operation
of the facility will he continued throughout the clos;ure period until
closure is certified by the professional engineer.  The closure plan
will include a description of the types of monitoring and the frequency
of monitoring that will he conducted during closure.  The monitoring
program will likelv be a continuation of that conducted during routine
operation of the facility.

5.8.1  Soil Monitoring

     The owner or operator of a land treatment facility is required to
conduct a soil sampling program and "must have in writing, and must
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implement, an unsaturated zone monitoring plan."*  This testing is of
great importance because it monitors the effectiveness of the land
treatment facility's containment of hazardous wastes and the progress of
the decomposition process.  A land treatment facility cannot be operated
properly without a reliable program of soil testing.  This soil testing
program must he continued throughout the closure period.  It will
provide the measurement basis for discontinuing the closure period when
the hazardous waste is decomposed.

     The owner or operator should include in the closure plan a descrip-
tion of the monitoring to be conducted during the closure period based
on his unsaturated zone monitoring plan, as required by §265.278. "The
unsaturated zone monitoring plan must include, at a minimum:

     (1) Soil monitoring using soil cores, and
     (2) Soil-pore water monitoring using devices such as
         lysimeters."**

These samples are required to he taken below the depth at which the
waste is Incorporated into the soil.   It is recommended that some soil
tests be made in the mixed soil as well.

     The frequency and location of these tests are determined on a site-
specific basis based on variables such as waste application rates, soil
permeability, and the proximity to the ground water.   At some
facilities, soil and soil-pore water  sampling may be  less frequent
during the closure period than during the facility's  active life,  if no
more wastes are being applied and monitoring during operations has
indicated no contamination.   When developing the closure plan,  the owner
*EPA Interim Status Standards, 40 CFR §265.278(a).
**EPA Interim Status Standards,  40 CFR §265.278(b),

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or operator should use his judgment in describing an appropriate moni-
toring schedule and revise it if future operational experience deems it
necessary.

     The closure plan should include:

     •   Details of the proposed monitoring (e.g., depth of
         monitoring, criteria and parameters of analyses);
     •   Frequency of sampling; and
     •   Maximum number of analyses required during the closure
         period.

5.8.2  Ground"Water Monitoring

     Ground-water monitoring "must be carried out during the active life
of the facility and for disposal facilities, during the post-closure
care period as well."*  Monitoring will he in accordance with the
requirements specified in §265.90 et seq.  of these regulations.  A des-
cription of a monitoring program to be included in the closure plan
would include:

     •   The types of analyses required during closure, i.e., from
         the date that final wastes are received until closure is
         certified by the professional engineer; and
     •   Maintenance that is reqxiired of the ground-water
         monitoring system to ensure that it is in working
         condition for the post-closure period, if post-closure
         care is required.

     The simplest way to describe the monitoring to be performed during
closure is to include a copy of the facility's ground-water sampling and
*EPA Interim Status Standards, 40 CFR §265.90.

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analysis program.  Since this program will not be implemented until one
year after the effective date of these regulations, the Agency will he
developing guidance for preparing monitoring plans.  This document is
not intended to provide guidance in this area; therefore, it is expected
that, in developing the closure plan, an owner or operator will use his
judgment in describing appropriate ground-water monitoring as required
by §265.90 et seq. and revise the plan when more data and guidance
become available.  The closure plan should include a copy of the
facility's ground-water sampling and analysis program when it is
available.

                    Analyses Required During Closure

     According to the ground-water monitoring regulations, samples
collected to establish ground-water quality must be obtained and
analyzed for the following parameters at least annually:

     •   chloride
     t   iron
     •   manganese
     •   phenols
     •   sodium
     •   sulfate

Samples collected to indicate ground-water contamination must be
obtained and analyzed  for  the following parameters at least  semi-
annual ly:

     •   pH
     •   specific conductance
     •   total organic carbon
     •   total organic halogen
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     The closure plan should include the maximum number and the types of
ground-water analyses required during the closure period.  The nutnher
and types of sampling and analyses required during closure depend on the
length of the closure period.   For example, if one set of analyses are
required annually and the others are required semi-annually, the owner
or operator should allow in his plan the possibility that both sets of
analyses will be required within the closure period, in order to make
provisions for the maximum number of analyses.  For this reason, the
closure plan may include a schedule of more analyses than actually will
be needed during closure.

                               Maintenance
     If post-closure care is required, the closure plan will also
include a description of the maintenance activities necessary to ensure
that the ground-water monitoring system is in working condition for the
post-closure period, which may include replacing or redrilling wells,
replacing seals and caps, pumps, etc., and required general
maintenance.  Since ground-water monitoring during closure is a continu-
ation of monitoring performed during facility operations, most of this
information will be based on past operating experience.

5.9  CLOSURE CERTIFICATION

     "When closure is completed, the owner or operator must submit to
the Regional Administrator certification both by the owner or operator
and by an independent registered professional engineer that the facility
has been closed in accordance with the specifications in the approved
closure plan."*
*EPA Interim Status Standards, 40 CFR §265.115.
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     An independent professional engineer is required  to certify that
closure activities *«re performed in accordance with the approved
closure plan.  It is not expected that an engineer will perform detailed
tests.  The owner or operator will include in the closure plan an
estimate of the number of periodic inspections to be made by an
engineer.  The plan need not include the name and state professional
engineer license number of the engineer, although this will be required
later as documentation.

5.10  FOOD CHAIN CROPS

     "During the post-closure care period, the owner or operator of a
land treatment facility must assure that growth of food chain crops
complies with §265.276."*

     The regulations state that during post-closure an owner or operator
must comply with the same regulations as during operation regarding the
growth of food chain crops.   For the purposes of this document, it is
assumed that the owner or operator will continue to follow the same
policies as during operation.

5.11  INSTALLING OR MAINTAINING FENCES

     At some facilities, it may be desirable to restrict access, in
accordance with the security regulations, Subpart B, §265.14,  even after
the facility has been closed.  Although this requirement is at the
Regional Administrator's discretion,  the owner or operator  should use
his judgment,  considering factors such as facility location, surrounding
land use, and types of wastes buried  to decide whether to include a
security provision in the plan.  At facilities in which access will he
restricted during the post-closure care period,  an owner or operator
*EPA Interim Status Standards,  40 CFR §265.280(d)(3),
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will address either the maintenance of security equipment used during
the active life of the facility or installation of appropriate security
equipment.  In most cases, this will likely mean that an owner or
operator will install a fence or ensure that the existing; fence is in
good condition at the time of closure.

     If an owner or operator plans to install a fence at closure, the
closure plan should state the area of the facility that will be enclosed
by the fence, the type of materials to he used, and dimensions of the
fence.  If a fence is already installed at the facility, the plan will
describe the types of repairs expected to be needed to ensure that it is
in Rood condition when post-closure begins.
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       5.12   SAMPLE CLOSURE  PLAN OUTLINE:   LAND  TREATMENT  FACILITY
EPA Facility ID No.
Owner's or Operator's Name
Address & Phone No.  	
Facility Address  	
I.   FACILITY CONDITIONS
    A.  General information
        1.   Facility size (acres)
        2.   Topography of facility
        3.   Soil type
        A.   Storage facilities
            a.   Type (pile,  surface  impoundment,  etc.)
            b.   Capacity of  each type
        5.   On-site facilities
            a.   Waste disposal facilities (landfills,  incinerators,
                etc.)
            h.   Pretreatment facilities
            c.   Facility capacity  (by  type  of  facility)
        6.   Waste  characterization (for  each major  type  of  waste  land-
            spread)
            a.   Chemical composition
            b.   Physical state
            c.   Quantity
            d.   Decomposition rate of  each  waste  spread
    B.   Maximum extent  of operation
        1.   Largest area ever spread with wastes  over  the life  of  the
            facility (acres)
        2.   Largest area ever spread at  one  time
        3.   Type of wastes requiring most extensive  treatment
    C.   Maximum amount  of inventory  ever  on-site
    D.   Inventory  of equipment (e.g.,  spreaders,  tillers, transport
        equipment)

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     E.  Schedule of ftm]  closure (milestone chart)
         1.   Final date wastes accepted                                            *
         2.   Date all landspreading completed
         3.   Final date all waste decomposition completed
         4.   Final date facility decontaminated
         5.   Final date all contaminated soil removed, if applicable
         6.   Date final cover completed, if cover is applicable
         7.   Final date vegetative cover planted, if applicable
         8.   Date that treatment fields have been stabilized if
             applicable
         9.   Final date closure completed
        10.   Total time required to close the facility
        11.   Justification  if closure is longer than six months

II.  INVENTORY DISPOSAL
     A.  Maximum amount of  wastes on-site
         1.   Maximum amount of wastes in storage
         2.   Maximum amount of wastes in pretreatment                              _
     B.  Pretreatment required prior to landspreading                               •
         1.   Quantity requiring pretreatment
         2.   Pretreatment procedures
     C.  Procedures for landspreading
         1.   Application rate
             a.  Approximate quantity of waste per application
             b.  Approximate acreage covered per application
             c.  Total acreage required for landspreading of all
                 inventory
         2.   Equipment and  labor required
     D.  Other disposal methods, besides landspreading
         1.   Quantity disnosed on-site but not in land treatment fields
             a.  Method of  disposal
         2.   Quantity disposed off-site
             a.  Method of  disposal
             b.  Approximate distance to disposer

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      E.   Time required  to complete  landspreading of all wastes

III.   MATERIAL IN TREATMENT
      A.   Maximum extent of operation
          1.   Largest  area ever  spread  with wastes over  the  life  of  the
              facility (acres)
          2.   Largest  area ever  spread  at  one  time
          3.   Type of  wastes  requiring  most extensive  treatment and  decom-
              position rate
      B.   Procedures required for  materials in treatment
          1.   Frequency  of activities performed  (e.g., tilling, waste-
              mixing)
          2.   Equipment  and labor  required
      C.   Time schedule  for decomposition  of materials in  treatment

 IV.   SOIL TESTING AND REMOVING  CONTAMINATED SOIL
      A.   Soil testing performed
          1.   Number of  soil  samples
          2.   Criteria for determining  if  hazardous  materials remain  at
              closure
      B.   Hazardous wastes remaining, if anplicahle
          1.   Name and characteristics  of wastes
          2.   Quantity of  wastes
      C.   Quantity of  hazardous  soil  to be  removed,  if applicable
      D.   >fethod  of treatment or disposal
          1.   On-site  disposal
              a.   Size of  area of  land  treatment  field designated as
                  disposal area
              b.   Size and location of  landfill
          2.   Off-site treatment or disposal
              a.   Method of treatment or disposal
              b.   Approximate distance  to facility
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 V.   DECONTAMINATING THE FACILITY
     A.   Area of facility with potential  soil  contamination  (excluding            *
         land treatment  fields)
         1.   List areas  with  potential  contaminated  soil
             a.   Number  of soil  samples,  if  necessary
             b.   Criteria for determining contamination
         2.   Estimated depth  of  soil  requiring removal
         3.   Total amount of  contaminated soil (cu.  yd.)
             a.   Amount  of contaminated  soil treated or disposed  on-site
                 and method of treatment  of  disposal
             b.   Amount  of contaminated  soil removed off-site,  if
                 applicable
                (1)  Method of treatment  or  disposal
                (2)  Approximate  distance to facility
     B.   All equipment and/or facilities  (e.g.,  landspreading,  tilling
         and transport equipment) requiring  decontamination
         1.   Name each piece  of  equipment and/or storage  facilities  and
             procedures  for cleaning  (e.g.,  steam-cleaning,  hydro-               _,
             blasting, etc.)                                                       fl
             a.   Owner or operator labor  or  contractor
             b.   Quantity of  residues from cleaning
         2.   Treatment or disposal method for  residues from  decontamina-
             tion (including  wastewater and  liquid wastes)
             a.   Quantity of  residues
                (1)  Quantity treated or  disposed on-siite
                (2)  Method of treatment  or  disposal
             b.   Quantity removed off-site
                (1)  Method of treatment  or  disposal
                (2)  Approximate  distance to TSDF

VI.   WASTE CONTAINMENT SYSTEM (if no  hazardous materials  remain when
     treatment is completed or all contaminated  soils have been removed,
     omit this section)
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      A.  Total area requiring stabilization
      B.  Characteristics of contaminated system
          1.  Final cover,  if applicable
              a.  Cover design
              b.  Type of soil
              c.  Depth of  cover
              d.  Characteristics of vegetation
              e.  Total amount of material required
              f.  Source of material
                 (1)  Quantity available on-site
                 (2)  Amount purchased off-site, if applicable
          2.  Characteristics of admixture chosen,  if applicable
              a.  Quantity  required
              b.  Source of materials
          3.  Diversion structure,  if applicable
              a.  Design
              b.  Construction activities required

VII.   MONITORING OPERATIONS
      A.  Types of monitoring required during closure
          1.  Soil monitoring
              a.  Details of monitoring program
                 (1)  Distribution  of sampling stations
                 (2)  Criteria and  parameters of analvses
              b.  Frequency of sampling
              c.  Maximum number of analyses required during  closure
          2.  Ground-water  monitoring
              a.  Maximum number of ground-water oualitv analvses required
                  during closure
              b.  Maximum number of ground-water contamination analyses
                  required  during closure
              c.  Details of ground-water monitoring program  (include  copv
                  of ground-water sampling and analysis  program when
                  a va 11 a h 1 e )

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       B.  Maintenance of monitoring equipment,  if post-closure care
           required                                                                     (
           1.   Number of ground-water wells requiring redrilling
           2.   Number of ground-water wells requiring replacement
           3.   Need  for replacement parts to all monitoring systems (name
               parts, e.g.,  pumps,  seals, caps)
           4.   Required routine maintenance

VIII.   CLOSURE CERTIFICATION
       A.  Approximate number or schedule of periodic inspections by
           certifying engineer

  IX.   FOOD CHAIN CROPS
       A.  Describe  plans for compliance witb 5265.276.

   X.   INSTALLING OR MAINTAINING THE FENCE
       A.  If  fence  already exists  at your facility,  describe required
           maintenance at closure to ensure it is in  good condition
       B.  If  fence  is to be installed                                                 4
           1.   Area  to be enclosed
           2.   Type  of materials used
           3.   Dimensions of fence
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          6.0  LANDFILLS:  GUIDANCE FOR  DEVELOPING  CLOSURE  PLANS

 6.1  INTRODUCTION

     The  following material provides  instruction for  the EPA  Regional
 Offices and the regulated community concerning the preparation of
 closure plans.  The instructions are  followed by a sample  closure  plan
 outline which illustrates the concepts  and intentions of the  plan.   This
document and the accompanying outline are intended merely  as  guidance
and many parts of them may not he applicable to any given  facility.
This guidance is based on the assumption that the  landfill has been
operating properly, and that no special requirements will  he  necessary
 to ensure adequate closure.  The purpose of this document  is  not to
provide guidance for remedial measures  but rather to provide  assistance
 to owners or operators of wall-operated facilities in developing closure
plans.  A general discussion of conceivable problems that  might exist at
some facilities and the kinds of remedial measures that might be needed
is included in Chapter 9.0, "Closure and Post-Closure Activities
Required at Some Disposal Facilities."

     In preparing the closure and post-closure plans, the  owner or
operator must address how the facility will be closed "in  a manner that
 (a) minimizes the need for further maintenance,  and (b) controls, mini-
mizes or eliminates, to the extent necessary to protect human health and
the environment, post-closure escape of hazardous waste, hazardous waste
constituents, leachate, contaminated rainfall, or waste decomposition
products to the ground water, or surface waters,  or to the atmosphere."*

     The terms "human health," "environment" and  "control" are all
relative terms.   In some cases,  protection of human health and environ-
ment may mean no discharge,  while in other cases, some escape may be
*EPA Interim Status Standards, 40 CFR §265.112(a).
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acceptable.  To meet these objectives, the owner or operator must
develop, as oart of his closure and post-closure plan, an adequate
analysis of the effectiveness of the proposed closure and post-closure
procedures.

     The instructions and the outline are separated into the following
major headings which, in most cases, correspond with the closure regula-
tions applicable to landfills:

     •   Facility conditions
     •   Maintaining partially closed areas of an active facility
     •   Removing of inventory
     •   Decontaminating the facility
     •   Cover and vegetation
     •   Ground-water monitoring
     •   Closure certification
     •   Collecting, removing and treating leachate
     •   Gas collection
     •   Installing or maintaining fences

     The closure plan for landfill facilities should include a general
description of facility conditions and, at a minimum, a description of
the activities required to comply with the following closure
requirements:

     •   Treating, disposing or removing inventory
     •   Decontaminating the facility
     •   Controlling pollution migration
     •   Ground-water monitoring
     •   Closure certification

     It is expected that the majority of facility owners or operators
will also partially close portions of their facility as part of normal
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operations.   In  these  cases,  the  closure  plans  will  need  to include  a
description of a maintenance  program  for  these  inactive  portions.   Some
landfill operations will  be outfitted with  a  leachate  collection,
removal and treatment  system; if  a facility had such a system  installed
and operating before the  closure  period,  then the  closure  plan must
include a description  of  the  program assuming similar operating  condi-
tions as during  facility  operation.   Similarly, if gas monitoring  is
installed at a landfill during operation, a plan for monitoring  through-
out the closure  period should be  included in  the closure plan.   An owner
or operator must also  include a description of any security measures
(e.g., fence) deemed necessary to restrict  access  to the facility after
closure.

6.2  FACILITY CONDITIONS

     The primary purpose  of this  portion of the closure plan is  to
provide the Regional Offices with the information  for an initial check
of the adequacy of the closure plan.  This  section of the  plan contains
a description of the factors determining the  conditions of  the facility,
Including the largest area of the facility ever open at a  given  time
which varies according to the partial closure schedule, the maximum
amount of inventory ever  on-site during operations, a description of
equipment and facilities, and a complete schedule of closure
activities.  With this information readily available, an EPA inspector
can quickly evaluate the closure plan using a visual inspection to
confirm that facility conditions never exceed the specifications
described in the  first  part of the closure plan.

6.2.1  General Information

     General information that would be useful in a closure  plan
includes:
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     •   Facility size;
     •   Description of liner if one exists at the facility (e.g.,
         liner material);
     •   Description of underlying soil;
     •   Leachate collection system, i.e., state whether one is
         installed at the facility; and
     •   Copy of NPDES permit if the facility discharges through a
         point source to U.S. waters.

6.2.2  Partial Closure
     The closure plan must include "a description of how and when the
facility will be partially closed, if applicable, and ultimately
closed."*  An owner or operator does not have to perform partial
closures during the life of the facility, although partial closures are
desirable, to avoid potential pollution.  If an owner or operator does
intend to include partial closures as part of routine operating
procedures, the closure plan must include a schedule of these activities
and a description of:

     •   The size of the area partially closed;
     •   The frequency of partial closures;
     •   Proposed methods for partial closure including, where
         applicable, type of cover (e.g., type of soil used, depth
         of cover, soil permeability, slope, etc.);
     •   Source of cover materials (on-site, off-site or some
         combination); and
     •   Vegetation chosen for the area partially closed.

     Partial closure, i.e., partial fulfillment of the closure require-
ments, includes any activity that reduces what must he done at final
4
*KPA Interim Status Standards, 40 CFR $265.112(a)(I).
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closure and will  therefore reduce  the estimate  of  the maximum extent  of
operation.  It involves all or some of the  following activities:   final
cover; vegetation; terracing; sloping; and  maintenance  throughout  the
life of the facility.  It is obvious that if a  portion  of a well-
operated  landfill receives a final cover, vegetation, other types  of
control technologies, proper terracing and  proper continual maintenance,
little may need to be done to that portion  at closure.  Although not  all
partial closures involve such extensive activities, it  is likely that a
landfill  owner or operator will perform some of these activities as part
of routine operations which will reduce requirements at final closure.
For example, it is common practice for a landfill owner or operator to
cap cells as they are properly filled and plant grass on the area at a
later date.  If the cells have been properly partially  closed, and the
area is properly maintained until final closure, that area will only
require vegetation at closure, assuming vegetation is necessary and had
not previouslv been planted.

     The key factor about partial closure which must be made clear in
the closure plan is that partial closure procedures (i.e., activities
which reduce the requirements at final closure) must be in accordance
with the closure requirements of §265.310 and consistent with the plans
for final closure.  For example,  if an owner or operator fills a 1-acre
cell and covers it with an inadequate cap which will either require
reworking or replacement at the  time  of final closure,  the closure plan
must still account for all of the  activities required  to prooerly close
this portion of the facility.  Similarly, if the activities stipulated
for final closure  include  a cap  with  2 feet of clay with a permeability
of 10   cm/sec and 2 more  feet of  a more permeable material,  the entire
facility, including areas  that have been partially closed, must have
this kind of cover.
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6.2.3  Maximum Inventory
                                                                                       (
     The owner or operator must include in the closure plan "an estimate
of the maximum inventory of wastes in storage or in treatment at any
given time during the life of the facility."*  This estimate of the
maximum amount of inventory ever expected over the life of the facility
should enable an inspector to evaluate this portion of the plan based on
a visual inspection of the facility.

6.2.4  Equipment and Facilities

     The owner or operator should describe the kinds of equipment and
facilities on-site (e.g., transport vehicles, excavation equipment,
spreaders, etc.) to enable an inspector to evaluate quickly the proposed
plans for facility decontamination.

6.2.5  Schedule of Activities

     The closure plan must include "a schedule for final closure which                  M
must include, as a minimum, the anticipated date when wastes will no
longer be received, the date when completion of final clozsure is antici-
pated, and intervening milestone dates which will allow tracking of the
progress of closure.  (For example, the expected date for completing
treatment or disposal of waste inventory must be included, as must the
planned date for removing any residual wastes from storage facilities
and treatment processes.)"**
*EPA Interim Status Standards, 40 CFR  5265.1 I2(a)(2).
**EPA Interim Status Standards, 40 CFR  §265.112(a)(4),

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     The closure period begins with the final acceptance of waste and
concludes when closure has been certified by the professional engi-
neer.*  The schedule of closure activities for a landfill must  include:

     •   Final date wastes will be accepted;
     •   Date all wastes treated or disposed or sent off-site,
         including:
         -  Date all on-site treatment completed,
         -  Date all on-site disposal completed, and
         -  Date all remaining inventory removed to an off-site
            facility;
     •   Final date facility decontaminated;
     •   Date final cover completed (this date is largely affected
         by the size of the area to he covered and climatic condi-
         tions which may halt construction activities);
     •   Final date vegetation planted or other material used to
         control erosion placed; the date to be listed here is the
         date that planting has been completed;
     •   Final date of closure, and the effective date of post-
         closure, which is the date that closure has been
         certified by the professional engineer;
     •   Total time required to close the facility; and
     •   Justification if closure will take longer than six months
         from the date of the final acceptance of wastes
         (§265.113(b)).  If an owner or operator requires more
         than six months to complete closure, the closure plan
         must include a justification for an extension as well as
*The final date of closure referred to here is the date that the
  closure technical requirements have been certified by the professional
  engineer.  The final date of closure for purposes of the financial
  responsibility requirements is the date that the Regional Adminis-
  trator releases the closure fund to the owner or operator.  A discus-
  sion of the legal implications of closure certification is in Section
  2.2.8.
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         proof that all steps have been taken to eliminate any                     t
         significant threat to human health and the environment.
         A further discussion of closure schedules is in Section
         2.2.6.

6.3  MAINTENANCE OF PARTIALLY CLOSED AREAS

     If partial closures are performed in order to reduce the activities
necessary at final closure, the owner or operator will need to justify
why these areas will he In good condition at final closure and will not
require additional work at closure.  To ensure that they remain in good
condition, these inactive portions should be properly maintained as part
of the facility's routine operations to prevent water infiltration and
runoff, to control soil and wind erosion, and to mitigate problems
caused by subsidence.  The closure plan includes a discussion of
maintenance of partially closed areas until the entire facility has been
ultimately closed.  Although the maintenance activities are similar to
post-closure care activities, the post-closure care plan does not aoplv          ~
until the entire facility has been closed.                                         V

     The key elements of a maintenance program which must be described
are (not all partial closures include all activities associated with
final closure, e.g., not all partially closed areas have vegetation, so
maintenance programs will vary):

     •   Visual inspections;
     •   Ground-water monitoring;
     •   Maintaining the cover and vegetation, if applicable; and
     •   Controlling erosion.

6.3.1  Visual  Inspections

     Visual inspections are the simplest component of maintaining closed
portions of an active facility.  Inspections should be made at periodic

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intervals and after all major  storms  to  detect  any  signs  of erosion or
subsidence, to examine the condition  of  the  cover and  vegetation,  if
applicable, and  to inspect the  condition of  ground-water  monitoring
equipment.  The  frequency of these  inspections  should  be  a  function of
the climate and  topography of  the facility.

6.3.2  Ground-water Monitoring

     The ground-water monitoring of the  partially closed  portions  of a
facility will be part of the facility's  routine ground-vater monitoring
program in accordance with the  requirements  of  S265.90 et seq. of  these
regulations.

6.3.3  Maintaining the Cover and Vegetation

     The closure plan must contain a description of how the  cover  of
partially closed areas will be maintained, if applicable.   These proce-
dures may include:

     •   Preventing ponding;
     •   Maintaining slope and grade;
     •   Fertilizing schedule;
     •   Mowing  schedule;
     •   Sprinkling schedule;
     •   Replanting schedule; and
     •   Controlling rodents and insects.

     The amount of maintenance required will depend largely on the
extent to which the soil and clay cover are  protected against erosion
damage by vegetation.   Some facilities, especially in arid regions, may
be covered with gravel to prevent erosion.  Routine repairs of the cover
and maintenance of the slope and grade may be needed to prevent ponding
and drainage problems.  If there is  vegetation,  it will require periodic
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applications of fertiliser and mulch and seed for bald spots.  Mowing is
recommended because It promotes the growth of desired vegetation and it
blocks the growth of trees or shrubs which could oenetrate the cover
soil with their roots.  If mowing is not performed, the facility must be
inspected periodically, and any shrubs or trees that have the potential
to penetrate the cover soil must he removed.  Depending on the location
of the facilitv (e.g., areas that experience periodic droughts), the
vegetation also may require sprinkling.  The closure plan must contain a
description of the types and frequency of activities required to main-
tain the inactive portions at that particular facility.  It is likely
that areas not covered with vegetation will require more maintenance to
protect them against erosion.  It also may be necessary for owners or
operators of some facilities to develop a program to nrotect the cover
against burrowing rodents and insects.  If needed, th« plan will include
a description of the tvpe of program to be instituted (e.g., poisoning
program, professional extermination).

6.3.A  Erosion Control

     Maintenance is required for the upkeep of the drainage and diver-
sion systems of the inactive areas.  These drainage channels are usually
earthen structures, and frequent repairs will likely be needed to
prevent erosion.  The closure plan will include a description and
frequency of activities required to prevent erosion, Riven the type of
cover, type of vegetation, if applicable, climate, location, etc.  This
will be particularly important for areas without a protective vegetative
c ove r.

6.4  TREATING, DISPOSING OR REMOVING INVENTORY

     An owner or operator of a landfill must include in the closure
plan:
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     •   An estimate of the maximum amount of  inventory reasonably
         expected on-site over the life of the facility;
     •   Methods and nrocedures for treating,  disposing, or
         removing all inventory, including residues  from
         processing; and
     •   Time schedule.

6.4.1  Maximum Inventory

     The closure plan must include "an estimate of the maximum inventorv
of wastes in storage or in treatment at any given time during the life
of the facility."*  Inventory includes all wastes in all stages of
processing, including wastes in storage and residues from processing.

     The estimate of inventory must he hased on the maximum amount ever
expected to he on-site over the life of the facilitv, assuming normal
conditions.  It should always he high enough to ensure that if an
inspector came onto the facility, the amount of inventory would not
exceed the estimate in the plan, assuming normal operating conditions.

     Since accumulating inventory has often been the cause of severe
environmental damage, an owner or operator should keep the amount of
wastes in storage at a minimum.  Requiring in  the closure plan an
estimate of the maximum inventory ever on-site alerts the Regional
Administrator to a potential hazard if a visual inspection shows more
wastes on-site than the plan indicated.  If the amount of inventory on-
site ever exceeds the estimate in the plan, the owner or operator must
revise the plan to reflect actual conditions; however,  if the owner or
operator can justifv to the Regional Administrator that the excess
inventorv is a result of unexpected operating contingencies and the
original estimate of maximum inventory can he restored  quick.lv, the
*EPA Interim Status Standards, 40 CFR §265.112(a)(2).

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Regional Administrator mav not require the owner or operator  to revise
the plan.  A further discussion of maximum inventory is in Section
2.2.4.

6• **' 2  Methods and Procedures for Removing Inventory

     The procedures to be followed for treating, disposing or removing
inventory are very site-specific and depend largely on wheither on-site
or off-site disposal Is used, the quantity of inventory, and methods of
disposal.  The choice of on-site or off-site disposal may vary according
to the quantity and type of wastes involved and the operating conditions
of the facility at the time of final closure.  Since it is much cheaper
to dispose of wastes on-site, it can he expected that most: inventory
will he disposed on-site according to normal operating procedures.  The
closure plan will include a description of the procedures necessary to
complete the following activities:

     •   Operating the facility in a routine manner while
         disposing of all inventory to be disposed on-site,
         including all stages of construction and waste processing
         required prior to landfilling, if necessary; and
     •   Removing and transporting all inventory, for which
         disposing on-site in the normal manner is not feasible,
         to an operating permitted disposal facility or a facility
         operating under interim status.

                    Procedures for Disposing On-Site

     It is expected that most, if not all, inventory will he disposed
on-site.  If inventory 1s to he disposed on-site, the closure plan must
include an estimate of the amount of waste to he disposed on-site taking
into account all residues from processing, if applicable.  The plan will
he hased on the owner's or operator's estimate of the maximum numher of
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drums and  Che naximum quantity of bulk waste and residues  on  hand  at  any
time.

     The plan will contain a discussion of the kinds of activities
necessary  to operate the facility in a routine manner for  the complete
disposal of all inventory to be disposed on-site.  The type and quantity
of wastes  to be disposed will greatly affect the procedures followed.
The type of wastes will affect the kind of pretreatment required prior
to disposal (e.g., chemical fixation, volume reduction, waste segrega-
tion, detoxification/degradation, encapsulation) as well as the method
for disposal (e.g., incompatible wastes may require special types of
landfilling techniques).  The quantity of waste that is disposed on-site
will determine the number and size of trenches necessary and the extent
of construction required if trenches have not previously been dug.  The
plan will  therefore include plans for design and construction of the
trench, if disposal areas have not been excavated and prepared prior  to
closure, and procedures required for landfilling the wastes.  Again, it
is assumed that procedures will be routine operations.  The closure plan
must also  contain a description of any procedures that are required at
closure that are not part of normal operating procedures.

                   Removing Wastes to an Off-Site TSDF

     Although it is anticipated that most, if not all, inventory will be
disposed on-site, there are circumstances when removal to an off-site
TSDF mav he required.   For example,  if an owner or  operator accumulated
a large amount of inventory because of equipment breakdowns, severe
weather conditions, or other  operating problems at  closure, making it
difficult  or impossible to dispose of the inventory on-site within a
Cine period acceotable Co the Regional Administrator, removing some of
the wastes to an off-site TSDF might he required.  It is also possible
that if an owner or operator  had  a small  quantity of incompatible  wastes
to dispose, it might he more  convenient to remove them off-site.  The
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plan will include an estimate of the quantity of wastes to be removed  to
an off-site TSDF and the approximate distance to the off-site facility.

6.4.3  Time Schedule
     Accumulating inventory over long periods of time has often been  the
cause of serious environmental damages; thus, the regulations restrict
the amount of time allotted during closure for treating, disposing or
removing all wastes:

     "Within 90 days after receiving the final volume of hazardous
     wastes, the owner or operator must treat all hazardous wastes
     in storage or in treatment, or remove them from the site, or
     dispose of them on-site, in accordance with the approved
     closure plan."*

     The owner or operator should state in the plan how all of the
inventory will be disposed within 90 days.  This ensures that an owner
or operator must always have either the capacity available to dispose of
wastes quickly on-site or have made preparations for removing the waste
to an off-site TSDF.

6.5  DECONTAMINATING THE FACILITY

     The closure plan must include "a description of the steps needed to
decontaminate facility equipment during closure."**  According to the
regulations, "when closure is completed, all facility equipment and
*EPA Interim Status Standards, 40 CFR §265.113(a).
**EPA Interim Status Standards, 40 CFR §265.112(a)(3).

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structures must have been properly disposed of, or decontaminated by
removing all hazardous waste and residues."*  The closure plan should
include a description of the cleaning, testing and/or disposing of all
items so that no hazardous materials remain undisposed of on-site.  This
will include cleaning up or disposing of contaminated equipment, soils
and residues.  The degree of cleanup required at a given facility at the
time of final closure will vary according to the owner's or operator's
operating practices.

6.5.1  Decontaminating the Soil

     The closure plan will include a list of all areas with potentially
contaminated soil requiring removal and disposal, an estimate of the
quantity of contaminated soil to be disposed, and a description of
disposal methods.  Cleaning up hazardous waste drips and spills will be
part of routine operating practices.  The residues included in the
closure plan are those on the surrounding grounds as a result of closure
operations and those not previously cleaned up (e.g., residues on dikes,
storage areas, trenches, diversions, spill containment areas).  Soil
testing may or may not be necessary depending on the facility condi-
tions; the owner or operator should state in the plan the criteria used
to determine the amount of contaminated soil to be removed and disposed.
An owner or operator will need to refer to Section 261 of these regula-
tions, "Identification and Listing of Hazardous Wastes," for the
criteria for identifying the characteristics of hazardous wastes.

     The amount of contaminated soil which must be removed and disposed
will be a major factor in determining whether disposal will be on- or
off-site.  If readily available disposal capacity is not available at
the facility and the closure plan does not include plans to build  an
additional cell for disposal, the owner or operator must describe  plans
for removing the waste to an off-site TSDF.
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6-5.2  Decontaminating the Equipment and Facility

     The closure plan may Include a description of procedures used to
decontaminate or dispose of the following:

     •   All transport and storage containers, tanks and ancillary
         facilities;
     •   All equipment, including that used for transport,
         storage, treatment, disposal, earth-moving, and cleaning
         processes;
     •   Cleaning wastes and residues from cleaning; and
     •   Any remaining water on-site from rain or snow.

     The owner or operator must Include in the closure plan a descrip-
tion of procedures for cleaning all equipment and facilities, an
estimate of the amount of residues resulting from craning (e.g.,
residues from the cleaning process, hazardous cleaning fluids, waste-
waters, containers), and plans for their disposal or removal.  If
residues are to he disposed on-site, a trench for disposal must be
available.  For facilities at which it ia common for water to accumulate
as a result of rain or snow, the plan must provide for removing excess
water at closure.

6.6  COVER AND VEGETATION

     According to the regulations, "in the closure and post-closure plan
under §265.118, the owner or operator must address the following objec-
tives and inrllcatp how thev will be achieved:

     (1) Control of pollutant migration from the facility via
         ground water, surface water, and air;
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      (2) Control of  surface water  infiltration,  including
         prevention  of pooling; and
      (3) Prevention  of erosion."*

      An owner or operator of a landfill  must demonstrate  in  the  closure
and post-closure plans that the post-closure escape  of hazardous  waste
constituents to ground water, surface water or  the atmosphere  will  He
controlled in a manner so as not to  pose a threat to human health .i-^
the environment.  In addressing these objectives, the owner  or opera "-n
must  consider, at a minimum, the site location,  topography and lan^ use,
climate, hydrogeological conditions  and  characteristics of the presold
final cover.  The closure plan should include a description  of the
natural or synthetic liner system, final cover, and  vegetation.   The
type  of cover and vegetation required will vary on a site-specific  basis
depending on what is necessary to  orotect human health and the
environment.  In some cases, this  protection may mean that no discharge
is acceptable from a particular facility, while in other  cases, sor-
escape could he acceptable.  For example, the level of discharge
acceptable from a facility located near  a drinking water  source wou! :  .<=
significantly less than from a facility  that only discharges into a
completely nonpotahle water source.

      It is expected that most well-operated facilities will  require, at
a minimum,  a final cover and vegetation or other material to stabilir^
the cover to ensure adequate control.  A general discussion  of othe--
kinHs of control technologies that might he needed to adequately cluSt? ^
facility Is in Section 9.0, "Closure and Post-Closure of  Disoosal
Facilities Designed With Less Than Optimum Control Technology." The
following sections include a general discussion of the needs associate^
with  final  cover and vegetation.
*EPA Interim Status Standards, 40 CFR §265.310(a) and (b)
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6.6.1  Final Cover
     The final cover refers to the materials and surface contours  used
to cover the landfill at closure to control surface water infiltration
and pollutant migration.  In most cases, vegetation or  some other
material will he required to stahilize the final cover.  The integrity
of the final cover is an important closure requirement  for a landfill.
Since there are so many site-specific factors, the cover design may
vary; the owner or operator, therefore, must describe in the closure
olan the type of cover (e.g., material and final surface contours) most
appropriate for that facility, taking into account the  functions of  the
cover (e.g., infiltration control, erosion and run-off  control and wind
erosion control) and characteristics of the cover.  The owner or oper-
ator will also need to demonstrate the adequacy of the  particular  cover
chosen in meeting the objectives of the regulations. The description  of
the final cover in the closure plan should include:

     •   The area of the facility that requires a final cover;
     •   Characteristics of cover (e.g., type of soil,  thickness,
         permeability);
     •   Cover design; and
     •   Prevention of ponding.

These site-specific specifications of the cover included in the closure
plan also apply to all previous partial closures (see discussion of
partial closures in Section 6.2.2).

               Area of the Facility Requiring Final Cover

     An owner or opprator must include in the closure plan an estimate
of the maximum area of the facility that will ever require a final
cover.  The area of the facility that requires a final  cover at closure
depends on the size of the areas that have been partially closed in
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accordance with  the  closure  plan  and  the  extent  to which these  inactive
areas have heen  properly maintained.   The  closure  plan  is  to  include  an
estimate of  the  maximum area that could ever  require  cover at any time
during the life  of the facility.   For  example, if  no  more  than  2 acres
of a landfill are ever open  at one  time and all  of the  areas  that have
been partially closed require no  reworking, the  maximum area  requiring  a
cover would  be 2 acres.  This estimate must always be high enough so
that if an inspector came onto the  facility,  no  area  larger than the
amount stated in the plan would ever require  a cover; therefore,  this
estimate must also account for portions of the facility that  will be
open at closure  for  purposes of residue disposal,  areas that  had been
partially closed and require some reworking,  and areas  that are  inactive
but still open because of operating problems  (e.g., poor weather condi-
tions halting construction).

                        Characteristics of Cover
     In describing the characteristics of the final cover, the closure
plan will include:

     •   The type(s) of material(s) used for the cover (e.g.,
         density, porosity, permeability, compatibility with waste
         to ensure wastes will not corrode cover);
     •   The thickness of each material chosen;
     •   Total amount of material required, which is a function of
         the size of the area to be closed and depth of cover;
     •   Amount and type of soil additives, If applicable; and
     •   Source of materials.

     It is likely chat at most facilities the final cover will be of a
material with low permeability to protect against surface water infil-
tration.  This material may be compacted clay (e.g., soil with 10
cm/sec permeability) or may be a barrier membrane liner over a buffer
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layer of soil, depending on soil availability and  the site-specific
conditions of the facility.  If vegetation is to be planted on the final
cover to control erosion, a sufficiently thick topsoil layer capable of
supporting vegetation will be required.  In artd regions of the country,
gravel may be preferable to vegetation for controlling erosion.

     The materials to be used will depend on the types of soil available
on-site as well as the conditions of the facility.  Since purchasing
soil off-site is costly, it Is likely that most owners or operators will
use soil available on-site, if at all possible, for the final cover,
i.e., the layer with low permeability and the layer capable of support-
ing vegetation, if applicable.  It is possible to  improve the quality of
available soil by blending various soils, using soil additives, or
making other provisions which would provide equivalent protection.  For
example, soil blending and synthetic additives may decrease the perme-
ability of the on-site soil as well as make certain soils more capable
of supporting vegetation.  In addition to improving the quality of
available soil, the Agency anticipates that many owners or operators may
use membrane liners protected above and below by buffer soil layers
instead of compacted clay for a cover of low permeability. These
membrane liners may be cost-effective if adequate on-aite soil material
is unavailable or an acceptable degree of compaction is not possible at
a particular facility, given the wastes disposed or facility conditions.

     If the owner or operator intends to use soil available on-site for
the final cover, he should state in the plan whether the soil has
previously been excavated and stockpiled or whether excavation will be
required at closure.  The hauling distance of the  soil should also be
included.  The plan will include an estimate of the qua.ntity of
materials to be purchased off-site, if applicable.  If a membrane liner
is to be used, the owner or operator should state  the type of liner to
be used and describe the sub-base preparation and  the protective cover
of the liner in the closure plan.
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                              Cover Design

     The closure plan shall contain descriptions of  the  proposed  grading
and terracing for purposes of erosion control.  The description will
include:

     •   Slope of cover which must be great enough to prevent
         water pooling but not encourage erosion;
     •   Length of run of slope; and
     •   Drainage and diversion structures to channel water away
         from the waste area.

The owner or operator should also state whether a contractor or the
owner or operator will do the earthwork activities and whether the
necessary equipment is available on-site.

6.6.2  Vegetation

     Most landfills will require good vegetation to stabilize slopes and
retard runoff flow, thus providing effective erosion control and mini-
mizing the need for further maintenance*  Other materials besides
vegetation may be used for this purpose; for example, facilities located
in very arid regions may use a gravel layer to stabilize the cover
soil.  In describing the vegetation to be used, the owner or operator
should include in the closure plan:

     •   Surface area requiring vegetation or other stabilizing
         material;
     •   Characteristics of vegetation to be planted, if
         applicable;
     •   Soil preparation procedures,  if applicable;  and
     •   Description of alternative stabilizing cover if
         vegetation will not he planted.

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If vegetation is to he planted, the closure plan need only include
provisions for planting once during the closure period.  Any necessary
replanting will be carried out during the early years of the post-
closure care period and will be discussed in the post-closure plan.

     Surface  Area  Requiring  Vegetation  or  Other Stabilizing Material

     The estimate of the area requiring vegetation or other stabilizing
material at closure will be the maximum amount ever required during the
life of the facility, including:

     •   Area of the facility being closed at closure;
     •   Area of the facility that was capped as part of partial
         closure but was not vegetated, if applicable; and
     •   Area of the facility that was previously vegetated but
         requires some replanting.

                      Characteristics of  Vegetation

     The type of vegetation chosen to prevent erosion and minimize  the
need for further maintenance will vary according to the type of soil
used for the final cover (e.g., depth,  nutrients, pH, moisture),
climate, amount of rainfall, and other  site-specific factors.  Infor-
mation that would be helpful in the closure plan includes the type  of
vegetation chosen; climatic, soil, and maintenance requirements (e.g.,
temperature, rainfall, nutrients, pH, depth and moisture of soil,
frequency of replanting, watering, fertilizing); and the depth of the
root structure to ensure that the roots could not penetrate through the
cover into the buried wastes.
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                       Soil  Preparation Procedures

     A description of soil preparation activities may include:

     •   Type and quantity of fertilizer required;
     •   Quantity of seed required;
     •   Type and quantity of mulch required; and
     •   Procedures for soil preparation (e.g., disking).

     If an alternative to vegetation is to be used, the closure plan
should include the type and quantity of materials to be used and an
explanation of how it will protect the integrity of the cover.  The
owner or operator should state whether or not a contractor will be
responsible for planting the vegetation or an alternative cover.  If
planting vegetation has been part of partial closure procedures, much of
this information will be known from operating experience.

6.7  GROUND-WATER MONITORING

     Ground-water monitoring "must be carried out during the active life
of the facility, and for disposal facilities, during the post-closure
care period as well."*  Monitoring will be performed in accordance with
the requirements specified in §265.90 et seq. of these regulations.  It
is expected that the monitoring program carried out during closure and
post-closure will he similar to that conducted during facility
operations.  A description of a monitoring program to be included in the
closure plan would include:

     •   The types of analyses required during closure, i.e., from
         the date that final wastes are received until closure is
         certified by the professional engineer, assuming the
         manner and frequency as required during operation; and
*EPA Interim Status Standards, 40 CFR §265.90(b).
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     •   Maintenance that is required of the ground-water
         monitoring system to ensure that it is in working
         condition for the post-closure period.

     The simplest way to describe the monitoring to be performed during
closure is to include a copy of the facility's ground-water sampling and
analysis program.  Since this program will not be implemented until one
year after the effective date of these regulations, the Agency will be
developing guidance for preparing monitoring plans.  This} document is
not intended to provide guidance in this area; therefore,, it is expected
that,  in developing the closure plan, an owner or operator will use his
judgment in describing appropriate ground-water monitoring as required
by §265.90 et seq. and revise the plan when more data and guidance
become available.  The closure plan should include a copy of the facil-
ity's  ground-water sampling and analysis program when it is available.

6.7.1   Analyses Required During Closure

     According to the ground-water monitoring regulations, samples
collected to establish ground-water quality must be obtained and
analyzed for the following parameters at least annually:

     •   chloride
     •   iron
     •   manganese
     •   phenols
     •   sodium
     •   sulfate

Samples collected to indicate ground-water contamination must be
obtained and analyzed for the following parameters at least semi-
annual ly:
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     •   pH
     •   specific conductance
     •   total organic carbon
     •   total organic halogen

     The closure plan should include  the maximum number  and  the  types  of
ground-water analyses required during the closure period.  The number
and types of sampling and analyses required during closure depend  on the
length of the closure period.  For example,  if one set  of analyses are
required annually and the others are required semi-annually,  the owner
or operator should allow in his plan for the possibility that both sets
of analyses will be required within the closure period,  in order to make
provisions for the maximum number of analyses.  For this reason, the
closure plan may include a schedule of more analyses than actually will
be needed during closure.

6.7.2  Maintenance
     The closure plan will also include a description of maintenance
activities necessary to ensure that the ground-water monitoring system
is in working condition for the post-closure period, which may include
replacing or redrllling wells, replacing seals and caps, pumps, etc.,
and required general maintenance.  Since ground-water monitoring during
closure is merely a continuation of monitoring performed during facility
operations, most of this information will he based on past operating
experience.

6.8  CLOSURE CERTIFICATION

     "When closure Is completed, the owner or operator must submit to
the Regional Administrator certification both by the owner or operator
and by an independent registered professional engineer that the facility
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has been closed in accordance with the specifications in  the approved
closure plan."*

     An independent professional engineer is required to  certify  that
closure activities were performed in accordance with the approved
closure plan.  It is not expected that an engineer will perform detailed
tests.  The owner or operator will include in the closure plan an
estimate of the number of periodic inspections to be made by an
engineer.  The plan need not include the name and state professional
engineer license number of the engineer, although this will be required
later as documentation.

6.9  REQUIREMENTS FOR SOME FACILITIES

     Some facilities, because of their site-specific characteristics,
e.g., facility design or location, may require additional activities at
closure.  These additional requirements include:

     •   Collecting, removing and treating leachate;
     •   Gas collection; and
     •   Installing or maintaining fences.

6.9.1  Collecting, Removing and Treating Leachate

     If a system for collecting, removing and treating leachate is
present at a landfill, the owner or operator must include plans for its
operation during the closure period.  Procedures will be similar  to
those during operation and include monitoring, collecting, removing,
treating, and disposing of leachate.  Since these procedures are only
required at facilities that have such a system in place, it is expected
that an owner or operator will continue to operate as he has done during
facility life.
*EPA Interim Status Standards, 40 CFR §265.115.
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     For facilities with such a system, a description of  procedures
might include:

     •   Procedures for collecting and pumping leachate (e.g.,
         leachate may collect in a sump and be pumped to  a holding
         tank or pond or collected by portable equipment  such as a
         vacuum truck;
     •   Monitoring program;
     •   Approximate volume of leachate collected during  closure
         which will be a function of the length of closure;
     •   Location and procedures for leachate treatment (including
         methods for storing, pretreating and treating, e.g.,
         biological or physical-chemical treatment, evaporation,
         package treatment facility);
     •   The design objectives of the treatment chosen and all
         materials and equipment required;
     •   Procedures for treating and disposing of leachate (e.g.,
         transport/pumping procedures, procedures for discharging,
         including NPDES permit number as required under  the Clean
         Water Act, if applicable, or off-site services);
     •   Procedures for disposing or removing residuals from
         treatment (e.g.,  on-site or off-site); and
     •   Maintenance required during the closure period to ensure
         that the system is operating properly before post-closure
         begins, which may include:
         -  Repairs to parts of the system,
         -  Replacement and reinstallation of parts, and
         -  Routine maintenance.

6.9.2  Gas Collection

     If a gas collection system is required  during operation, an owner
or operator should  include  in the  closure  plan the monitoring procedures
to be followed during the  closure  period.   It can be assumed that moni-
toring will be similar to  that  required  during operation,  and the
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details can therefore he based on the owner's or operator's operating
records.  The closure plan will include:

     •   Procedures for collecting gas including:
         -  Design objectives of system, and
         -  Materials and equipment required;
     •   Details of monitoring required during closure which will
         be based on the length of the closure period, including
         the type and number of samples and analyses and whether
         analyses are done on- or off-site; and
     •   Maintenance required durJng the closure period to ensure
         that the system is operating properly before post-closure
         begins, which may include:
         -  Repairs to parts of the  system,
         -  Replacement and reinstallation of parts, and
         -  Routine maintenace.

6-9.3  Installing or Maintaining Fences

     At some facilities, it may be desirable Co restrict access, in
accordance with the security regulations, Subpart B, §265.14, even after
the facility has been closed.  Although this requirement is at the
Regional Administrator's discretion, the owner or operator should use
his own judgment, considering factors such as facility location,
surrounding land use and types of wastes buried, to decide whether to
include a security provision in the  plan.  At facilities in which access
will be restricted during the post-closure care period, an owner or
operator will address either the maintenance of security equipment used
during the active life of the facility or installation of appropriate
security equipment.  In most cases,  this will likely mean that an owner
or operator will install a fence or  ensure that the existing fence is in
good condition at the time of closure.
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     If an owner or operator plans to install a  fence at closure,  the
closure plan should state the area of the facility that will be enclosed
by the fence, the tvpe of materials to be used,  and dimensions of  the
fence.  If a fence is already installed at the facility, the plan  will
describe the types of repairs expected to be needed to ensure that it is
in good condition when post-closure begins.
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              6.10  SAMPLE  CLOSURE  PLAN OUTLINE:   LANDFILLS
EPA Facility ID No.
Owner's or Operator's Name
Address & Phone No. 	
Facilitv Address
 I.  FACILITY CONDITIONS
     A.  General information
         1.  Size of facility (acres)
            2.  Description of liner, if applicable
            3.  Do vou have a leachate collection system?
            4.  Copy of NPDES water pollution control permit if
                discharge through a point source to U.S. waters
     B.  Schedule of partial closures, if applicable (milestone chart)
            1.  Size of each area partially closed
            2.  Type of cover
            3.  Source of cover materials
            4.  Vegetation
     C.  Maximum amount of inventory ever on-site in any stage of
         processing
            1.  Maximum number of drums
            2.  Maximum amount of wastes in any stage of processing
            3.  Other inventory
     D.  Inventory of auxiliary equipment (e.g., excavation machinery,
         spreaders, bulldozers, etc.)
     E.  Schedule of final closure (milestone chart)
            1.  Final date of wastes accepted
            2.  Dates for treating, disposing, or removing all wastes
                (including intervening milestones)
              a.  Date all preprocessing completed
              b.  Date all on-site disposal completed
              c-  Date that all inventory has either been disposed on-
                  site or removed to an off-site TSDF
            3.  Final date facility decontaminated
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             4.  Date final cover completed
             5.  Final date vegetation planted or other material placed
             6.  Final date closure completed
             7.  Total time required to close the facility
             8.  Justification if closure is longer than six months

 II.  MAINTENANCE OF PARTIALLY CLOSED AREAS OF AN ACTIVE FACILITY
      A.  Inspection frequencies
      B.  Ground-water monitoring specifications if different from active
          portion of the facility (include any appropriate amendments to
          ground-water sampling and analysis plan)
      C.  Cover maintenance
             1.  Fertilization rate
             2.  Replanting frequency
             3.  Mowing frequency
             4.  Sprinkling rate and frequency
             5.  Rodent and insect control program
      D.  Erosion control program
             1.  Maintenance program for  drainage and diversion systems
             2.  Activities required to repair expected erosive damage

III.  TREATING, DISPOSING OR REMOVING ALL INVENTORY
      A.  Maximum volume of waste on-site in any stage of processing
             1.  Total amount of wastes in drums and number of drums
             2.  Volume of bulk wastes in any stage of processing
                                       o
                 (including storage) (yd  )
             3.  Total amount of residues from processing
                                                            •i
      B.  Total volume of waste to be landfilled on-site (yd )
                                                       o
             1.  Quantity of waste already in drums (yd ) and number of
                 drums
             2.  Amount of bulk waste (i.e., not contained) (yd  ) to be
                 disposed  after all  treatment has been completed
             3.  Total quantity of waste  disposed on-site (including
                 waste  in  drums,  all waste  that  required treatment,  and
                 residues from treatment)
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     C.  Describe procedures for disposing of inventory on-site
                                                          o
            1.   Amount of  waste  requiring pretreatment (yd )
                a.   Describe each treatment process required and  the
                    amount of waste  requiring each treatment process
                (1)  For each process,  include:
                         (a)  Equipment (on-site  availability)
                         (b)  Materials needed
            2.   Size of area, or number of cells  and size  of cell
                necessary  for disposing of inventory (including site map
                of  disposal area)
                 a.  Construction required for landfilling if not
                     completed before closure (e.g., design and
                     construction of cell, excavation, lining, etc.)
            3.   Procedures for landfilling (Including procedures  for
                disposing  containerized and bulk  wastes)
                 a.  Types of equipment required
                 b.  Availability (on-site or rental)
                 c.  Materials required (e.g., soil for layering
                     barrels)
                    (1)  Quantity
                    (2)  Availability
     D.  Total  volume of waste removed  off-site  (number of barrels;
         volume of  containerized wastes)
            1.   Method of  off-site treatment or disposal
            2.   Approximate distance to off-site  TSDF

IV.   DECONTAMINATING THE FACILITY
     A.  Area of facility  with potential soil contamination (sq.  yd.)
            1.   List areas with  potential contaminated soil
                 a.  Number of soil  samples, if necessary
                 b.  Criteria for determining contamination
            2.   Estimated  depth  of soil requiring removal
            3.   Total amount of  contaminated soil (cu. yd.)
                 a.  Amount of contaminated soil  disposed  on-site
                 b.  Amount of contaminated soil  disposed  off-site
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    B.  All equipment and/or facilities (e.g., tank, earth-moving
        equipment, piping and containers) requiring decontamination
           1.  Name each piece of equipment and/or storage facilities
               and procedures for cleaning (e.g., steam cleaning,
               hydroblasting, etc.)
                a.  Owner or operator labor or contractor
                b.  Quantity of residues from cleaning
           2.  Number of containers requiring disposal or
               decontamination
                a.  Method of cleaning and/or disposing of containers
                b.  Volume of residues
           3.  Method for treating or disposing of residues from
               decontamination (including wastewater and liquid wastes)
                a.  Quantity disposed on-site
                   (1)  Is trench available for residues?
                   (2)  If plan to dig a small trench, give size,
                        location, design
                   (3)  Plans for disposing of liquid waste
                b.  Quantity removed  to an off-site TSDF
           4.  Estimated amount of water on-site requiring removal
               (e.g.,  snow and  rain accumulation)
                a.  Methods for removal
                b.  Source of disposal (on-site versus off-site)
                   (1)  If on-site disposal area
                         (a)  Procedures

V.  COVER AND VEGETATION
    A.  Final cover
           1.  Total area to be covered (sq.  yd.) (line a + line b)
                a.  Area of facility  not previously partially  closed
                    with appropriate  cover
                b.  Area of any portions of facility open for  disposing
                    of inventory and  wastes from decontamination
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       2.  Characteristics of final cover
            a.  Type(s) of material(s) (e.g.,  soil of 10"' cm/sec
                permeability)
            b.  Depth of material(s)
            c.  Total amount of material(s) required
            d.  Amount and type of soil additives, if applicable
            e.  Source of material(s)
                (1)  Quantity available on-site
                     (a)  Excavation required
                     (b)  Approximate hauling  distance
                (2)  Amount purchased off-site
                     (a)  Approximate hauling  distance
       3.  Final cover design
            a.  Slope of cover
            b.  Length of run of slope
            c.  Type of drainage and diversion structures
       4.  Earth-moving procedures
            a.  Contractor or owner or operator to lay cover?
            b.  Equipment needed for hauling,  spreading,  grading,
                compacting
            c.  Available on-site or rental?
B.  Vegetation (if not planting vegetation, omit  parts 1  through 3)
       1.  Total area requiring vegetation (acres)
            a.  Area receiving final cover which  will have
                vegetation (acres)
            b.  Area partially closed but never vegetated (acres)
            c.  Area previously vegetated but  requiring some
                replanting (acres)
            d.  Percentage of total area assumed  to require
                replanting during closure (2)  (acres)
       2.  Characteristics of vegetation
            a.  Name or tvpe of vegetation (e.g., rye grass)
            b.  Climatic, soil and maintenance requirements (e.g.,
                temperature, moisture and nutrients requirements,
                replanting frequency)
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                   c.   Root  structure  (expected  pane(ration depth  ot
                      roots)
             3.  Soil  preparation procedures
                   a.  Type and quantity of fertilizer required per acre;
                      total required
                   b.  Quantity of seed required per acre; total required
                   c.  Type and quantity of mulch required per acre; total
                      required
                   d.  Contractor labor or owner or operator labor?
             4.  Procedures for controlling cover erosion if vegetation
                 is not to be planted
                   a.  Type and quantity of materials to be used
                   b.  Justification for materials chosen

 VI.  GROUND-WATER MONITORING
      A.  Analyses required during closure
             1.  Maximum number of ground-water quality analyses required
                 during closure
             2.  Maximum number of ground-water contamination analyses
                 required  during closure
             3.  Details of ground-water monitoring program (include copy
                 of ground-water sampling and  analysis program when
                 available)
      B.  Maintenance of monitoring equipment
             1.  Number of wells requiring redrilling
             2.  Number of wells requiring replacement
             3.  Need for  replacement parts to system (name  parts, e.g.,
                 pumps, seals, caps)
             4.  Required  routine maintenance

VII.  CLOSURE CERTIFICATION
      A.  Approximate number or schedule (e.g.,  every two weeks)  of
          periodic  inspections expected  by the certifying professional
          engineer
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VIII.  COLLECTING, REMOVING AND TREATING LEACHATE                                    .
       If a leachate collection, treatment and removal system is installed
       at your facility, complete this section.
       A.  Describe your leachate collection system (i.e., pumping and
           collecting procedures)
              1.  Describe the monitoring system
              2.  Estimated volume of leachate collected per month
       B.  Describe leachate treatment process
              1.  Is treatment on-site or off-site?  If on-site treatment,
                  describe process for treatment
                   a.  Design objectives
                   b.  Materials and equipment required
       C.  Disposing of leachate
              1.  If discharged to public waters, refer to water pollution
                  control permit number in Section I - "Facility
                  Conditions"
              2.  If hauling off-site, distance to TSDF
              3.  Disposing of residuals                                             ^
                   a.  Quantity of residuals                                         ™
                   b.  Characteristics
                   c.  If disposed on-site, where?  (include drawing of
                       disposal area)
                   d.  If off-site, distance to TSDF
       D.  Maintaining equipment
              1.  Repairs and replacements required
              2.  Regular maintenance required over the duration of
                  closure

  IX.  GAS COLLECTION
       If a gas collection system is required at your facility, complete
       this section.
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    A.  Procedures for collecting gas
           1.  Design objectives of system
           2.  Materials and equipment required
    B.  Monitoring requirements
           1.  Type of monitoring samples
           2.  Number of samples
           3.  Type of analysis
           4.  Where are analyses performed?
    C.  Maintenance of monitoring equipment
           1.  Repairs required during closure
           2.  Replacements required during closure
           3.  Routine maintenance required during the closure period

X.  INSTALLING OR MAINTAINING THE FENCE
    A.  If a fence already exists at your facility, describe required
        maintenance at closure to ensure it is in good condition
    B.  If fence  is to be installed:
           1.  Area to be enclosed
           2.  Type of materials used
           3.  Dimensions of fence
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        7.0  INCINERATORS:  GUIDANCE FOR DEVELOPING CLOSURE PLANS

7.1  INTRODUCTION

     The following material  provides detailed  instruction  for  the  EPA
Regional Offices and the regulated community concerning  the  preparation
of closure plans for the  treatment of  hazardous  waste  by incineration.
The instructions are followed by a sample closure  plan outline  which
illustrates the concepts and intentions of  the plan.   This document and
the accompanying outline are intended  merely as  guidance; many  parts  of
them may not be applicable to any given facility.  The discussion  of
closure plans provided in this document is  based on the  assumption that
the incinerator has been operating properly and  that no  special require-
ments will be necessary to ensure adequate  closure.  The purpose of this
document is not to provide guidance for remedial measures but rather  to
provide guidance to owners or operators of  well-operated facilities.
The instructions and the closure plan  outlined in  this Section  are
separated into the following major headings which, in most cases,
correspond with the closure regulations applicable to  incinerators:

     •  Facility Conditions
     •  Removing Inventory
     •  Decontaminating the Facility
     •  Air Quality Monitoring
     •  Closure Certification

7.2  FACILITY CONDITIONS

     The primary purpose of this portion of the closure  plan is  to
provide the Regional Offices with the information for an initial check
of the adequacy of the  closure plan.  This  section of the plan  includes
a description of the factors determining the condition of the facility;
that is, a description of the facility, a list of equipment, a


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characterization of the wastes currently stored, the maximum amount of
inventory ever on-site during operations, and a complete schedule of
closure activities.  With this information readily available, an
inspector can quickly evaluate the closure plan using a visual inspec-
tion to confirm that facility conditions never exceed the specifications
described in the first part of the closure plan.

7.2.1  General Information

     General information that would be useful in a closure plan
includes:

     •  Facility size;
     •  Incinerator operating specifications (e.g., capacity,
        emission control system, etc.);
     •  Storage facilities (including all tanks, surface
        impoundments, drainage pits, etc.);
     •  Other treatment and disposal facilities on-site, if
        applicable; and
     •  Waste characterization.

7.2.2  Maximum Inventory

     The owner or operator must include in the closure, plan "an estimate
of the maximum inventory of wastes in storage or in treatment at any
given time during  the life of the facility."*  This estimate of the
maximum amount of inventory ever expected over the life of the facility
should enable an inspector to evaluate this portion of the plan based on
a visual inspection of the facility.
*EPA Interim Status Standards, 40 CFR §265.112(a)(2),
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7.2.3  Equipment and Facilities

     The owner or operator should  list the kinds of equipment  and  facil-
ities on-site to enable an inspector to evaluate quickly the proposed
plans for decontaminating the facility.

7.2.4  Schedule of Activities

     The closure plan must include "A schedule for final closure which
must include, as a minimum,  the anticipated date when wastes will no
longer be received, the date when completion of final closure  is antici-
pated, and intervening milestone dates which will allow tracking of the
progress of closure.  (For example, the expected date for completing
treatment or disposal of waste Inventory must be included, as  must the
planned date for removing any residual wastes from storage facilities
and treatment processes.)"*

     The closure period begins when the owner or operator accepts the
final wastes and concludes when closure has been certified by  a
professional engineer.**  The schedule of closure activities for an
incinerator must include:

     •  Final date for accepting wastes;
     •  Final date for all pre-incineration processing and
        treatment;
     •  Final date for treating inventory;
*EPA Interim Status Standards, 40 CFR §265.112(a)(4).
**The final date of closure referred to here  is the date that the
  closure technical requirements have been certified by the professional
  engineer.  The final date of closure for purposes of financial respon-
  sibility requirements is the date that the  Regional Administrator
  releases the closure fund to the owner or operator.  A discussion of
  the legal implications of closure certification is in Section 2.2.8.
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     •  Final date facility decontaminated;
     •  Final date closure completed which is the date that
        closure has been certified by the professional engineer;
     •  Total time required to close the facility;; and
     •  Justification if closure will take longer than six months
        from the date of the final acceptance of wastes
        (§265.113(a)).  If an owner or operator must take longer
        than six months to complete closure, the closure plan must
        include a justification for an extension as well as proof
        that all steps have been taken to eliminate any signif-
        icant threat to human health and the environment.  A
        further discussion of closure schedules is in Section
        2.2.6.

7.3  REMOVING INVENTORY

     An owner or operator of an incinerator must include in the closure
plan:

     •  An estimate of the maximum amount of inventorv reasonably
        expected on-site over the life of the facility;
     •  Procedures for any necessary pretreatment;
     •  Methods and procedures for disposing, treating, or
        shipping off-site all inventory, including residues from
        processes; and
     •  Time schedule.

7.3.1  Maximum Amount of Inventory

     The closure plan must include "an estimate of the maximum inventory
of wastes in storage or in treatment at anv given time during the life
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 of  the  facility."*  The  term  "inventory"  includes all wastes in all
 stages  of processing,  including  storage and  residues  from incineration
 processing.  In most cases, removing  all  inventory should simply repre-
 sent normal operating  procedures.

     The estimate of inventory must be based on  the maximum amount that
 would ever likely be on-site during the life of  the facility.   It  should
 always  be high enough  to ensure  that  if an inspector  came onto  the
 facility, the amount of inventory would not  exceed  the estimate  in the
 plan, assuming normal  operating  conditions.

     Since accumulating inventory has often  been  the  cause  of severe
 environmental damage,  an owner or operator should keep the  amount  of
 wastes  in storage at a minimum.  Requiring in the  closure plan an
 estimate of the maximum inventory ever on-site alerts the Regional
 Administrator of a potential hazard if a visual  inspection  shows more
 wastes  than the plan indicated.  If the amount of  inventory on-site ever
 exceeds the estimate in the plan, the owner  or operator must revise the
 plan to reflect actual conditions; however,  if the owner  or operator can
 justify to the Regional Administrator that the excess inventory is a
 result  of unexpected operating contingencies and  the  original estimate
 of maximum inventory can be restored quickly, the  Regional  Administrator
 may not require the owner or operator to revise  the plan.   A further
 discussion of maximum inventory is in Section 2.2.4.

 7-3.2   Pre treatment

     The closure plan must include a description of all pre-incineration
 processing and treatment of inventory.  Waste analyses and  actual  tests
 may be required if waste treatment; processes not normally used will be
necessary.  The plan should also specify the  quantity of  wastes
*EPA Interim Status Standards, 40 CFR §265.112(a)(2).
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requiring pretreatraent and the quantity resulting from pretreatment.
The type of waste will affect the kind of treatment required prior to
incineration, as well as the type and quantity of residues which will
require disposal.

7.3.3  Methods and Procedures for Treating Inventory

     The procedures to be followed for treating inventor}^ are site-
specific and depend largely on whether on-slte or off-site capabilities
are available, the quantity of inventory, and methods of treatment or
disposal.  The choice of on-site or off-site treatment may vary
according to the quantity and type of wastes to be treated and the
operating conditions of the facility at the time of closure.  The
closure plan should include a description of the procedures necessary to
complete the following activities:

     •  Operating the facility in a routine manner for the
        complete treatment of all inventory to he disposed on-
        site, Including all stages of waste processing and
        treatment; and
     •  Removing and transporting all inventory for which on-site
        treatment is not feasible to an operating permitted
        facility or a facility operating under interim status.

                            On-Site Treatment
     On-site treatment is clearly the most convenient and least
expensive method of treating inventory.  Most inventory will probably be
treated on-site according to normal operating procedures.  If inventory
is to be treated on-site, the closure plan must include an estimate of
the amount of waste to be treated on-site, taking into account all
residues from processing, if applicable.  The plan will also include an
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estimate of  the maximum number of drums and  the maximum  quantity of hulk
waste and residues on hand at any time.

     The plan will include a discussion of the kinds of  activities
necessary to operate the facility in a routine manner  for  the  processing
and incineration of all inventory to be treated on-site.   The  type  and
quantity of wastes to be treated will greatly affect the procedures
followed.

                   Removing Wastes to an Off-Site  TSDF

     Although it is anticipated that most inventory will be  treated on-
site, there are circumstances when wastes must be removed  to an  off-site
TSDF.  For example, if an owner or operator accumulated  a  large  amount
of inventory because equipment breakdowns made it difficult or
impossible to treat it on-site within 90 days, removal to  an off-site
facility may be required.   In addition, incinerator residues (e.g.,  ash)
and residues generated by facility decontamination that  cannot be
incinerated will also need to be removed off-site if disposal facilities
are not available on-site.  If a permitted landfill or one with  interim
status is available on-site, the owner or operator should describe  the
landfill in the plan and estimate the quantity to be disposed.   He  also
must provide post-closure  care for the landfill.  If the owner or
operator removes wastes to an off-site TSDF,  the plan will include  an
estimate of the quantity of wastes and the approximate distance  to  the
off-site facility.

7.3.4  Time Schedule
     Accumulating inventory over long periods of time has often been the
cause of serious environmental damages; thus, the regulations restrict
the amount of time allotted during closure for treating all wastes:
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     "Within 90 days after receiving the final volume of hazardous
     wastes, the owner or operator must treat all hazardous wastes
     in storage or in treatment, or remove them from the site, or
     dispose of them on-site, in accordance with the closure
     plan."*

     The owner or operator should include an estimate of the time
required to dispose of the maximum amount of waste expected over the
life of the facility, which must be no greater than 90 days.  The esti-
mate of the time required to treat inventory should reflect normal
operating capacity and not theoretical throughput.  Thus, for example,
if experience has shown that the incinerator normally functions only 50
percent of the time, this should he reflected in the planned closure
schedule.  Requiring all inventory to be treated within 90 davs ensures
that an owner or operator either restricts his inventory to what the
incinerator can be expected to handle or has made preparations for
removing the inventory off-site.

7.4  DECONTAMINATING THE FACILITY

     The closure plan must include "a description of the steps needed to
decontaminate facility equipment during closure."**  According to the
regulations, "At closure, the owner or operator must remove all
hazardous waste and hazardous waste residues (including but not limited
to ash, scrubber waters, and scrubber sludges) from the incinerator."***
The closure plan should include a description of the cleaning, testing
and/or treating of all items so that no hazardous materials remain
undisposed on-site.  This will include cleaning up or disposing of
contaminated equipment, soils and residues.  The degree of cleanup
*EPA Interim Status Standards, 40 CFR §265.113(a).
**EPA Interim Status Standards, 40 CFR §265.112(a)(3).
***EPA Interim Status Standards, 40 CFR $265.351.

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required at a given facility at  the  time  of  final  closure  will  vary
according to the owner's or operator's operating practices.

7.4.1  Decontaminating the Soil

     The closure plan will include a list of all areas with  potentially
contaminated soil requiring removal and disposal,  an estimate of  the
quantity of soil to be disposed, and a description of disposal  methods.
Residues will be likely on the surrounding grounds as a result  of drips
and spills or storage (e.g., residues around storage ponds,  drainage
pits, and spill containment areas).  Soil testing  may be necessary
depending on the facility conditions; the owner or operator  should  state
in the plan the criteria used to determine the amount of contaminated
soil to be removed and disposed.  An owner or operator will  need  to
refer to the Section 261 of these regulations, "Identification  and
Listing of Hazardous Wastes," for the criteria identifying the  charac-
teristics of hazardous wastes.

     The closure plan should include a description of the disposal
methods for the contaminated soil.  An owner or operator of  an  inciner-
ator may remove the soil off-site because most incinerators  are not
equipped to deal with large quantities of contaminated soil  and the
incineration process of soil produces residues which would require
disposal.  An owner or operator may dispose of the soil on-site if  the
incinerator is part of a multiple process facility with a landfill  on-
site that has interim status or is permitted.  The closure plan will
include a description of plans to remove  the soil  off-site,  or  to
dispose of the soil in a landfill.

7.4.2  Decontaminating the Equipment and Facility

     The closure plan should include a description of procedures used to
decontaminate or dispose of the following:
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     •  All transport and storage containers, tanks, and ancillary
        facilities;
     •  Refractory liners;
     •  All equipment used preceding the incineration of wastes,
        such as waste feed systems, conveyors and containers;
     •  Piping, pumps, valves;
     •  Air pollution control equipment;
     •  Cleaning equipment; and
     •  Cleaning wastes and residues from cleaning.

     The owner or operator must include in the closure plan a descrip-
tion of procedures for cleaning all equipment and facilities, an
estimate of the amount of residues resulting from cleaning (e.g.,
residues on pollution control equipment, residues from the cleaning
process, hazardous cleaning fluids, wastewaters, residue containers,
etc.) and plans for their disposal.  As discussed above, these residues
will be either disposed off-site or on-site if a disposal area is avail-
able.  The plan should include a description of how these residues will
be properly disposed.

7.5  AIR QUALITY MONITORING

     If inventory is incinerated on-site, the owner or operator must
continue to practice all of the monitoring and inspections which are
part of normal operating procedures.  A description of these practices
must be included in the closure plan.

7.6  CLOSURE CERTIFICATION

     "When closure is completed, the owner or operator must submit to
the Regional Administrator certification both by the owner or operator
and by an Independent registered professional engineer that the facility
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has been closed in accordance with the specifications in  the approved
closure plan."*

     An independent professional engineer is required to  certify  that
closure activities were performed in accordance with the approved
closure plan.  It is not expected that an engineer will perform detailed
tests. The owner or operator will include in the closure  plan an esti-
mate of the number of periodic inspections to be made by an engineer.
The plan need not include the name and state professional engineer
license number of the engineer, although this might be required later as
documentation.
*EPA Interim Status Standards, 40 CFR §265.115.

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             7.7   SAMPLE  CLOSURE  PLAN OUTLINE:   INCINERATORS
EPA Facility I.D. No.
Owner's or Operator's Name
Address & Phone No.	
Facility Address
I.   FACILITY CONDITIONS
     A.  General information
         1.  Size of facility
         2.  Incinerator specifications
             a.  Capacity
             b.  Throughput
             c.  Emission control system
             d.  Estimated combustion efficiency
         3.  Storage facilities
             a.  Type (e.g., bulk or drums)
             b.  Capacity/volume
         4.  Other facilities on-site (if applicable)
             a.  Type (landfill, incinerator, surface impoundment, etc.)
             b.  Capacity
         5.  Waste characterization (to He filled out for each waste in
             inventory [e.g., phenolic wastewater, scruhher sludge,
             etc.] Including waste material at any stage of processing,
             and/or anv residue generated hv the normal processing of
             the waste before or during closure, including contaminated
             soil or containers).*
             a.  Chemical composition
             b.  Physical state (i.e., liquid, solid, gas or mixture)
*NOTE:  The Interim Status Standards note that "unless the owner or
operator can demonstrate...that any solid waste removed from his
incinerator is not a hazardous waste, the owner or operator becomes a
generator of hazardous waste and must manage it in accordance with all
applicable requirements of Parts 262, 263, and 265 of this Chapter"
(§265.351) (emphasis added).
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             c.  Combustion temperature
             d.  Quantity
     B.  Maximum amount of inventory ever on-site in anv stage of
         processing
     C.  Inventory of auxiliary equipment
     D.  Schedule of final closure (milestone chart)
         1.  Final date wastes accepted
         2.  Dates for completing the treatment of inventory
             a.  Date all preprocessing completed
             b.  Date all on-site incineration completed
             c.  Date all wastes not incinerated on-site removed
                 (1)  Date wastes disposed on-site
                 (2)  Date wastes removed to an off-site TSDF
         3.  Final date facility decontaminated
         4.  Final date of completed closure
         5.  Total time required to close the facilitv
         6.  Justification if closure is longer than six months

II.  REMOVING ALL INVENTORY (to be filled out for each type of waste in
     inventorv, including waste material at any stage of processing and
     or any residue generated by the normal processing of the waste
     before or during closure, including contaminated soil or
     containers) .*
     A.  Maximum amount of waste on-site in any stage of processing
         1.  Total amount of waste/residue in drums and number of drums
         2.  Total amounts of waste/residue In bulk storage (e.?.,
             tanks, hoppers, etc.)  Include tag number or other means
             identification for each tank or hopper.
     B.  Pretreatment
*NOTE:  The Interim Status Standards note that "unless the owner or
operator can demonstrate...that any solid waste removed from his
incinerator is not a hazardous waste,  the owner or operator becomes a
generator of hazardous waste and must  manage it in accordance with all
applicable requirements of Parts 262,  263, and 265 of this Chapter"
(§265.351) (emphasis added).
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         1.  Quantltv requiring pretreatment
         2.  Pretreatroent process (including chemicals necessary for
             pre-incineration treatment)
         3.  Total amount to he treated or disposed following
             pretreatment
     C.  Methods and procedures for treating, disposing or
         removing inventory
         1.  Procedures for on-site incineration
             a.   Quantity
             b.   Auxiliary fuel requirements
         2.  Procedures for on-site treatment or disposal of wastes
             not incinerated
             a.   Quantity
             h.   Method and procedures used
         3.  Off-site removal
             a.   Quantity
             h.   Method of treatment or disposal
             c.   Approximate distance to off-site TSDF

III.  DECONTAMINATING THE FACILITY
     A.  Area of facility with potential soil contamination (sq. yd.)
         1.  List areas with potential contaminated soil
             a.   Number of soil samples, if necessary
             b.   Criteria for determining contamination
         2.  Estimated depth of soil requiring removal
         3.  Total amount of contaminated soil (cu. yd.)
             a.   Amount of contaminated soil disposed on-site
             b.   Amount of contaminated soil removed off-site
     B.  All equipment and/or facilities requiring cleaning (e.g.,
         refractory liner, tanks,  surface impoundments, drainage pits,
         discharge control equipment, containers  tank trucks)
         1.  Name each piece of equipment and/or storage facilities and
             procedures for cleaning (e.g., steam-cleaning, hydro-
             blasting, etc.)
             a.   Owner or operator labor or contractor
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             h.  Quantitv of residues from cleaning
         2.  Disposal method for residues from decontamination
             (including wastewater and liquid wastes)
             a.  Quantity treated or disposed on-site and method
                 and procedures used
             b.  Quantity removed to off-site TSDF, method of treatment
                 or disposal,  and approximate distance to TSDF

IV.  AIR QUALITY MONITORING
     A.   Description of air monitoring activities
     B.   Inspection procedures

V.    CLOSURE CERTIFICATION
     A.   A schedule or estimate of the numher of periodic inspections hy
         the certifying engineer anticipated  during closure.
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                    8.0  MULTIPLE PROCESS FACILITIES:
                  GUIDANCE FOR DEVELOPING CLOSURE PLANS

8.1  INTRODUCTION

     As Is currently  the  practice  in  the  industry, many  hazardous  waste
facilities contain multiple process units.   For  example,  an  incineration
operation may be operated  in  conjunction  with an on-site  landfill  for
disposing of solid residues from the  incineration process.   These
residues may be classified as hazardous wastes,  depending on the  types
of materials consumed in  the  incinerator.  The on-site chemical waste
landfill also could accept wastes  from other off-site  generators.
Another example would be  an industrial wastewater processing plant  which
precipitated heavy metals  into a sludge which would  be landfilled.

8.2  CLOSURE PLAN FORMULATION

     Physical arrangement  of  multiple process waste  facilities will  vary
greatly.  Some facilities may he planned  to segregate operations into
designated areas which are planned to remain unchanged for the life  of
the facility; in fact, different portions of the facility may have
different planned lifetimes.  At facilities which include  permanent
disposal,  e.g., landfills and some surface impoundments,  plans may
include the movement of processing and storage units so  that maximum use
can be made of the available  area  for disposal.  For the  former case,
closure plans can be formulated for each distinct area or  sub-site.  In
the latter case, the closure  plan will have to be designed to integrate
all closure activities.   It would  be impossible  to enumerate  all pos-
sible combinations of disposal process units, physical arrangements, and
planned rearrangements; therefore, the closure plans will be required  to
be based on certain hypotheses covering normal operations  (e.g., inven-
tory disposal or treatment) and EPA's end-point objectives for TSDF
facilities.  The closure  plans must,  of course,  include the  closure
procedures specified for  each applicable treatment,  storage  or disposal
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facility contained in the multiple process unit.  The closure plan
should also be based on predesignated facility areas being planned for
either waste repository status (i.e., requiring post-closure monitoring
and a post-closure plan) or complete decontamination (i.e., left in a
state such that no hazardous wastes remain in these areas).  It is
recognized that in the actual event of closure these designations could
be revised.

8.3  SAMPLE FACILITY

     As a hypothetical example of a multi-purpose facility closure plan,
consider the following situation:

     On a 250-acre site, hazardous waste operations consist of:

    (1)  Incineration of waste hydrocarbons containing some
         chlorinated species, wastewaters containing traces of
         phenols, and some sludges from wastewater treatment
         plants;
    (2)  Separation of hydrocarbons (for incineration) and
         precipitation of heavy metals from industrial
         wastewaters;
    (3)  Landfilling in secure trenches of hazardous wastes,
         including solid residues from the incinerator, heavy
         metal sludges from wastewater processing and other
         suitable wastes from off-site generators.

     For this hypothetical example, it is assumed that the operator
predesignates 200 acres for repository status (including any required
buffer zones) and plans to construct a series of landfills in this
area.  The other 50 acres are to he decontaminated and returned to
usable industrial real estate after closure.  The incinerator with its
associated equipment (scrubber, scrubber liquor storage lagoons, waste
blending and storage tanks), the on-site laboratory, and the waste
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receiving facilities are assumed to be located on the 50 acres which are
to be decontaminated At closure.  The wastewater processing facility and
its associated equipment (storage tanks, mixing tanks, clarifiers,
filter presses for sludge dewatering) are initially placed on a portion
of the 200 acres designated for repository status, with the intention of
moving them to an area atop some completed landfills (after filling and
capping but before final grading, covering and revegetating) to make way
for later landfills.

     The closure plan for this facility would consist of three parts:

    (1)  Closing the incinerator and decontaminating the 50 acres
         to be returned to industrial use (follow the Guidance for
         Developing Closure Plans for incinerators);
    (2)  Closing the wastewater processing plant and decontam-
         inating and removing the associated  equipment to the
         extent necessary for closure of the  200^acre waste
         repository area.  For planning purposes,  it would be
         reasonable to assume that the wastewater processing
         facilities have been moved  to areas  overlying capped
         landfills (apply facility decontamination instructions
         for  impoundments or  tanks to this case,  making suitable
         adjustments for decontamination procedures unique to
         wastewater processing facilities);
    (3)  Closing the landfills, applying final cover,  and revege-
         tating disturbed areas in the 200-acre  portion of the
         facility which was predesignated as  a waste repository
         (follow the Otiidance  for Developing  Closure Plans for
         landfills).
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                9.0  CLOSURE AND POST-CLOSURE ACTIVITIES
                  REQUIRED AT SOME DISPOSAL FACILITIES

9.1  TYPES OF FACILITY PROBLEMS

     In the early years following Implementation of these regulations,
some hazardous waste disposal facilities may close which were not
designed with adequate technology and will require more extensive
closure activities than previously discussed in Chapters 3 through 8 to
ensure the protection of human health and the environment.  This
situation could arise from several causes, e.g.:

    •  The hydrogeology of the facility was not well understood at
       the time the facility was established;
    •  The waste being interred was originally thought to be non-
       hazardous but its classification has changed;
    •  The behavior of the waste in the disposal facility environ-
       ment was not well understood;
    •  The design and/or construction of the control barriers was
       defective by current standards; or
    •  The location of the disposal facility was poorly chosen.

In some cases, prudence may dictate dislnterment of the waste and
reburial or other disposal using more modern technology.  However, in
the vast majority of cases, the best course  will be to leave the wastes
in place and applv closure procedures which will minimize the amount of
hazardous waste material which may migrate from its burial position.
Post-closure activities for such facilities must include contingency
plans for problems which can be anticipated  as well as adequate mainte-
nance and surveillance.  (Note:  Random waste disposal or dumping
grounds are not included in the category of  facilities discussed here,
e.g., "The Valley of the Drums.")
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9.2  FACILITY CLOSURE

     Closure activities for each facility will, of course, have to be
tai]ored to the particular circumstances.  However, certain general
objectives can be stated:

    •  Control of pollution migration via ground water, surface
       water, and air environments;
    •  Minimization of leachate formations within the waste;
    •  Minimization of gas formation within the waste;
    •  Minimization of waste material mobility; and
    •  Protection of human health and the environment.

These objectives are, of course, also applicable to the design of new
facilities; however, possible methods of accomplishment are more complex
and indirect for facilities not originally planned with the best control
technology currently available.

     Control of surface water infiltration would include the use of a
cover material of low permeability, surface drainage to minimize
infiltration, vegetative cover to minimize erosion, etc.  However, in
some cases control of pollution via the ground water may require some
more exotic measures.  Obviously, the hydrogeology of the facility must
first be understood as well as possible.  This may require that borings
be made around the buried wastes or, in some cases, into the buried
wastes, if it is safe to do so.  Indeed, in some cases the boundaries of
waste burial may not be precisely known beforehand.  Such borings should
be made under competent supervision of hydrogeologists and coordinated
with state and local water supply agencies.  (Particular care must be
taken against Inadvertently penetrating aquicludes which are isolating
the waste from ground-water aquifers.)  Once the hydrology is
understood, design of perimeter barriers to ground-water movements and
ground-water diversion drains may be possible.  In situations where
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movement of ground water  is  slow and  the  amount  available  la  limited,
selective pumping of ground  water  to  influence gradients may  be a  useful
technique*  Construction  techniques can include  physical modification  of
the  subsoil by excavation and replacement, e.g., digging a  trench  and
refining it with low permeability  compacted  clay, or  by injection  of
slurries of clays or soil modification chemicals into  the subsoil.

     Minimization of leachate formation in the buried  wastes  is accom-
plished in the first instance by limiting infiltration of ground and
surface water into the wastes by the  aforementioned means.  If addi-
tional measures are required, consideration can be given to the
injection of absorbants, if  sufficient void  space is known  to exist, or
to the injection of cementitious mixtures which hydrate with additional
moisture upon hardening.  Alternatively, sumps for removal  of leachate
by pumping may he possible,  installed by drilling directly  Into the
waste mass, if it is safe to do so, or using directional drilling  tech-
niques from the perimeter of the buried wastes.

     Gas formation in buried wastes is so dependent on the  particular
mixture of waste interred that methods for its control, if  found to he
necessary, would be very particular to each case.  Injections of pH
control agents, such as lime, may he advisable to suppress or retard the
rate of anticipated reactions between waste components.  If large
amounts of municipal wastes were co-disposed with the hazardous wastes.
the  generation of considerable methane and carbon dioxide can be antici-
pated.  Installation of gas extraction wells, such as are used in
sanitary landfills, may be necessary, although the nature of the
hazardous wastes will have to be carefully considered beforehand; gas
wells which are operated under negative pressure (i.e., evacuated by
pumping) will  tend  to cause  air  to be drawn into the waste, which in
some cases may have adverse  effects.
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     Waste material mobility can sometimes be reduced by injection of
chemical modifiers.  An obvious cage is pH control agents in waste
containing heavy metals.  Other possibilities include cementitious
materials which can encapsulate wastes at the molecular level, and
materials to promote polymerization of organic wastes.  Again, the
treatment, if necessary, would have to be tailored to the particular
situation.

     In some cases, future uses of the land may have to be more severely
constrained to protect human health and the environment.  For example,
absolute securitv may have to be imposed using fencing and full-time
security personnel.  In most cases, such drastic measures will hopefully
not be required, and the land can be returned to some productive use.

9.3  POST-CLOSURE

     Monitoring of ground waters in the vicinity of the wastes and
detection of leachate escape from the buried wastes, are, of course,
even more necessary for facilities with less than adequate control
design than for the best designed facilities.  For facilities in which
control of pollution via ground water has been provided by ex-post facto
facility modifications, it is likely that there will be less confidence
in the effectiveness of this control than for facilities designed and
operated from the beginning with the best control technology.
Therefore, it would be prudent to seek out water supply wells which
could possibly be affected, even if the probability is small, and
establish long-term surveillance programs for possible contamination.
This will be particularly pertinent in areas of underlying bedrock
aquifers; typically, water flow in such aquifers is controlled by small
fissures and solution channels and is not uniform in all directions.  It
is possible that contamination of a well in such an aquifer could occur
even though it is some distance away and no contamination is detected in
the closure monitoring wells.  Maintenance of drainage facilities,
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vegetative cover,  leachate  withdrawal and  treatment  systems  (if
necessary) and other  facilities  are,  of  course, required as  described
elsewhere in this  document.
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             10.0  GUIDANCE FOR DEVELOPING  POST-CLOSURE  PLANS

 10.1  INTRODUCTION

     The following material provides instructions for the EPA Regional
 Offices and  the regulated community concerning the preparation of post-
 closure plans which are required for disposal facilities.  A discussion
 of other post-closure requirements, in addition to the  preparation of
 post-closure plans, is provided in Section 12.3.  The instructions are
 followed by an outline which will further illustrate the concepts and
 intentions of the plan.  It should be noted that this document and the
 accompanying outline are intended merely as guidance and many parts of
 them may not be applicable to any given facility.  This guidance is
 based on the assumption that the disposal facility has been adequately
 closed and that no special remedial measures will be required during
 post-closure to protect human health and the environment.  The purpose
 of this document is not to provide guidance for remedial measures but
 rather to aid owners or operators in developing post-closure plans for
 facilities requiring routine kinds of post-closure care.  A general
discussion of conceivable problems that might occur and the kinds of
 post-closure activities that might be appropriate to protect human
health and the environment is included in Section 9.0,  "Closure and
 Post-Closure Activities Required at Some Disposal Facilities."

     The instructions and the outline in this Section are separated into
 the following major headings which correspond with the post-closure
regulations:

     •   Ground-water Monitoring
     •   Maintenance of Monitoring and Waste Containment Systems

     Considerable site-to-site variation is expected  that will require
differences in the details of post-closure plans.   The Agency does not
require  detailed engineering drawings or specifications  in this
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document.  The outline of a post-closure plan Included in Section 10.5
illustrates some of the kinds of information that might be useful in
preparing such a plan.

10.1.1  Facilities Requiring Post-Closure Care

     A hazardous waste facility which is designed for the permanent
disposal of hazardous waste is designated by EPA as a "disposal
facility."  According to the regulations, a disposal facility is "a.
facility or part of a facility at which hazardous waste is intentionally
placed into or on any land or water, and at which waste will remain
after closure"* (emphasis added).  The post-closure care regulatory
requirements apply to the "owners and operators of all disposal facil-
ities."**  This includes:  hazardous waste landfills; surface impound-
ments in which hazardous wastes remain after closure (even if the owner
or operator had originally planned to remove the hazardous wastes); land
treatment facilities in which hazardous wastes are present at closure;
any on-site disposal of hazardous wastes resulting from facility decon-
tamination; and any other retention of hazardous wastes after the
termination of the closure period.

10.1.2  Post-Closure Care Period

     "The owner or operator of a disposal facility must provide post-
closure care in accordance with the approved post-closure plan for at
least 30 years after the date of completing closure."***  The interim
status standards do, however, permit the Regional Administrator, on a
site-specific basis, to entertain petitions for reducing or extending
*EPA Interim Status Standards, 40 CFR §260.10(a) (15).
**EPA Interim Status Standards, 40 CFR §265.110(a).
***EPA Interim Status Standards, 40 CFR §265.117(d)..

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the post-closure period if deemed desirable or necessary to protect
human health and the environment.  See Section 13.3.7 for a discussion
of the duration of the post-closure period.

10.1.3  Frequencies of Monitoring and Maintenance

     The post-closure plan must include provisions for the kinds of
monitoring and maintenance activities which will be required annually as
well as those required on an intermittent basis.  For example,
activities such as inspections may be monthly, especially in the early
years of post-closure, to ensure the integrity of the cover and the
control of erosion.  Maintenance such as mowing and fertilizing may be
required annually, while reseeding, mulching, monitoring well
replacement and major repairs to the drainage channels will likely be
needed less frequently.

10.2  GROUND-WATER MONITORING

     The post-closure plan must include a description of "ground-water
monitoring activities and  frequencies as specified in Subpart F [Ground-
Water Monitoring]  for the  post-closure period."*  Ground-water moni-
toring "must be carried out during the active life of the facility, and
for disposal facilities, during the post-closure care period as well."**
Monitoring will be in accordance with the requirements specified in
§265.90 et seq.  A description of the monitoring to be performed
annually during post-closure would include:

     •   The number and locations of the wells to be monitored;
     •   The frequency of  the monitoring for the  wells;  and
     •   The types of analyses required.
*EPA Interim Status Standards,  40 CFR §265.118(a)(1).
**EPA Interim Status Standards,  40 CFR §265.90(b).
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     The simplest way to describe  the monitoring during  the  post-closure
period is to include a copy of the facility's ground"water sampling and
analysis program.  Since this program will not be  implemented until one
year after the effective date of these regulations, the  Agency will be
developing guidance in this area;  therefore, it is expected  that  in
developing the post-closure plan, an owner or operator will  use his
judgment in describing appropriate ground-water monitoring as required
by §265.90 et seq. and revise the  plan when more data and guidance
become available.  The post-closure plan should include  a copy of the
facility's ground-water sampling and analysis program when it is
available.

10.3  MAINTENANCE ACTIVITIES

     The closure plan must include a description of all  activities
necessary to maintain the integrity of the cover and vegetation,  the
leachate and gas collection, treatment and removal systems,  where
applicable, and the function of the monitoring equipment.  The post-
closure plan should include maintenance provisions for any events that
could reasonably be expected to occur over a 30-year period„  For
example, the owner or operator should include provisions for repairs of
damage caused by storms, droughts, seismic activities, and subsidence if
historical data or the owner's or operator's experience  show that one or
more of these natural events will likely occur within 30 years.

     The significance of providing for such likely events is increased
by the long duration of the post-closure period.  It is possible  that
during the 30-year period surrounding land uses will change, important
records may be lost, and key personnel with memories of the actual waste
disposal practices will leave.  Community changes and loss of the actual
Information about the facility will increase the probability of an
accident resulting from inappropriate land use.  As a result of the
likelihood that there may be no one on-site full-tima after a hazardous
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waste disposal facility has been closed, the post-closure plan  should
include the name and address of the person to be contacted in case of an
emergency at the facility.

     It should be noted, however, that it is not the intention  of oost-
closure operations to establish the capability to handle extraordinary
calamities such as a total liner failure brought about by a major earth-
quake.  Such major catastrophic disasters are largely unpredictable and
could cause a rupture at even the best hazardous waste facilities.
Requiring each disposal facility to provide large amounts of money In
anticipation of events of low probability is not an efficient way of
solving this problem.

     The post-closure plan should include a description and schedule of
the following kinds of post-closure maintenance activities that will be
needed at most facilities:

     •   Inspecting the facility;
     •   Maintaining the function and integrity of the final cover
         and/or vegetation; and
     •   Maintaining the ground-water monitoring systems.

10.3.1  Inspecting the Facility

     The facility operator must make a periodic inspection of all of the
facility systems that he is should  maintain.   These systems may include:

     •   Final cover;
     •   Drainage and diversion systems;
     •   Ground-water monitoring system;
     •   Surveved benchmarks;
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     •   Leachate collection system (if present on-site);
     •   Gas venting system (if present on-site); and
     •   Security systems (if required by the Regional
         Administrator).

     The inspection of the condition of the cover and the drainage and
diversion systems is particularly important because erosive damage can
develop quite rapidly with little channels in the soil becoming large
gullies.  The employee making the inspection should carefully look for
any signs of erosion that could lead to loss of cover soil or to the
infiltration of runoff water into the waste cells.  The frequency of
this visual inspection should be a function of the viability of the
ground cover.  In addition, facilities that are prone to erosion due to
their topography should have more frequent examinations.  In general,
facilities with grades of over 5 percent will suffer additional water
erosion and facilities with large surfaces exposed to frequent winds of
over 30 mph will have some wind erosion occurring.*

     The regulations do not specify the frequency of the inspections
that are to be conducted by the owner or operator.  The primary guidance
in this case should be good engineering practice and the operating
experience at the particular facility.  It is recommended that
inspections be conducted after major rainstorms, as well as at periodic
intervals, in order to quickly detect erosion events.  Periodic
inspections of the monitoring systems will alert the owner or operator
if the systems are not functioning properly and prevent the possibility
of undetected pollution.  The benchmarks should be checked to be sure
they have not been displaced.  If an owner or operator is required to
have a fence to restrict access to the facility, inspections will be
necessary to ensure that the fence is in good condition.
*R.J. Lutton, et al.  Design and Construction of Covers for Solid Waste
 Landfills, U.S.E.P.A. - Municipal Environmental Research Laboratory,
 Cincinnati, Ohio, August 1979.  EPA-60012-79-165.
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 10.3.2  Maintaining  the Cover and/or  Vegetation

     The majority of  the routine maintenance  operations  are  directed  at
maintaining the integrity of the cover and vegetation and  controlling
erosion.  The vegetation provides  the primary protection for the  soil
and clay cover.  This vegetation must he maintained  for  it to  be  an
effective barrier against erosive  damage.  Facilities located  in  very
arid regions may use a gravel layer over the  cover soil  instead of
vegetation.

     The post-closure plan must contain a description of the types and
 frequencies of activities required to maintain the integrity of the
 final cover and/or vegetation.  A  schedule of  post-closure activities
may include:

     •   Maintaining  the cover;
     •   Mowing;
     •   Reseeding and mulching;
     •   Replacing soil;
     •   Fertilizing;
     •   Sprinkling; and
     •   Controlling rodents and insects.

 If vegetation has not been planted, the post-closure plan should  include
a description of procedures necessary to maintain the stabilizing cover.
Cover maintenance will include activities needed to repair damages to
the cover caused by routine weather conditions as well as periodic
natural events such as storms, droughts, frosts, seismic activity or
subsidence.  Rodent control measures, filling of rodent  burrows, and
applying insecticide will be required at some hazardous  waste facilities
during the post-closure period to counter major infestations.  Based  on
current operating experience and historical records,  an  owner or
operator should be able to include an estimate of the kinds  of
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maintenance and repairs that might be necessary (e.g., repairs to cracks
in the cover, pooling problems due to subsidence).

     Almost all facilities with vegetative growth on the cover will need
periodic mowing, reseeding and mulching of bald spots and eroded areas,
replacement of soil lost to erosion, and the periodic application of
fertilizer.  Fertilizer applications can be expecte;d to be more frequent
in the early years of post-closure when the vegetation has not become
firmly established.  The other components (e.g., reseeding, mulching,
replacing soil) may be acceptable at less than annual frequencies.
Mowing is recommended because it promotes the growth of the desired
vegetation and it blocks the growth of trees or shrubs which could
penetrate the cover soil with their roots.  If mowing is not performed,
the facility must be inspected periodically and trees or shrubs that
have the potential to penetrate the cover soil must be removed.  At some
facilities, the oost-closure plan will need to include provisions for
sprinkling during periods of drought and additional replanting if
vegetation is severely damaged by droughts or storms which can be
expected to occur within 30 years.

     The level of detail in the description of procedures, frequency of
activities and documentation included in the plan will vary according to
the activity.  For example, if fertilizer is to be applied to the vege-
tation, the approximate amount, type and frequency of the application
should be specified.  The EPA should encourage the owner or operator of
the hazardous waste facility to seek the advice of the U.S. Department
of Agriculture concerning the best practices for growing vegetation and
controlling erosion.

     Additional maintenance activities are required for the upkeep of
the facility's drainage channels and culverts.  This maintenance is
important because these channels direct surface water runoff away from
the disposal area where added surface water would infiltrate the soil
and promote leaching.  Since the drainage channels are usually earth

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structures designed for directing water flows, erosive damage will  be  a
frequent occurrence requiring repairs.  Related to this, drainage
considerations will often require adding soil to a hazardous waste
facility's surface sometime during the post-closure period.  This
building up of the soil would be especially important if subsidence has
occurred at the landfill.  Subsidence could change the desired  5 percent
grade for general drainage to a depression, trapping surface water above
the landfill's cover.  The post-closure plan should include a descrip-
tion of the types and frequency of activities required to  prevent
erosion, given the type of cover, type of vegetation, climate,  location,
etc.

10.3.3  Maintenance of the Ground-water Monitoring System

     The post-closure plan must include provisions for maintaining the
ground-water monitoring system.  Maintenance may include replacing or
redrilling monitoring wells, replacing seals and caps, repairing or
replacing pumps, and any other kinds of general equipment maintenance.
Some of these activities will occur at irregular intervals during the
post-closure period (e.g., well replacement).

     The plan should include a schedule for these kinds of maintenance
activities.  Since ground-water monitoring during post-closure is a
continuation of monitoring performed during facility operations, an
owner or operator will gain experience over the life of the facility and
be better able to predict future conditions and needs.  It is intended
that the owner or operator use his judgment when describing the
maintenance program required for the ground-water monitoring system and
revise the post-closure plan when more data become available.
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10.4  ACTIVITIES REQUIRED AT SOME FACILITIES

     The regulations do not require that disposal facilities have
leachate collection, removal and treatment systems or gas collection
systems.  However, facilities which have a leachate collection and/or a
gas collection system are required to monitor and maintain them through-
out post-closure.  In the post-closure plan, the owner or operator must
include a description of the systems' operations.  If the Regional
Administrator has required that the facility owner or operator employ
security measures or if the owner or operator thinks the Regional
Administrator will require security measures (as allowed under
§265.117(b) - Post-closure care and use of property; period of care and
§265.14 - Security), the post-closure plan should also include a
complete description of all security operations.

10.4.1  Leachate Collection, Removal and Treatment System;
        Maintenance and Operation

     If a leachate collection, removal and treatment system is present
at a hazardous waste facility, the owner or operator must include plans
for its operation during the post-closure period.  Procedures will he
similar to those during operation and include monitoring, collecting,
removing, treating and disposing leachate.  If a facility has such a
system, the owner or operator should include a description of procedures
and a schedule to be following during the post-closure period which may
include:

     •   Procedures for collecting and pumping leachate (e.g.,
         leachate is generally collected in a sump and pumped out
         by means of a vacuum truck);
     •   Monitoring procedures;
     •   Procedures for leachate treatment;
     •   Procedures for disposing of leachate, including any
         residues from leachate treatment; and

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     •   Maintenance required (e.g., piping replacement, repairs
         or replacement of sumps).

It is expected that an owner or operator will refer to operating records
for these data.

10.4.2  Gas Collection System:  Monitoring and Maintenance

     If a gas collection system is required during operation, an owner
or operator should include in the post-closure plan the monitoring and
maintenance procedures to be followed during the post-closure care
period.  It can be assumed that monitoring will he similar to that
required during operation, and the details can therefore be based on the
owner's or operator's operating records.

     The regulations do not specify the nature of this monitoring or the
frequency of the tests.  It is anticipated that the tests usually will
be conducted with a "sniffer" mechanism held near to the vent pipe or by
capturing the released gaaes in a balloon for subsequent laboratory
analysis.  The primary maintenance operations that will be needed will
be the clearing of obstructions within the gas system and repairing
damage to the system.  The closure plan should contain a description of
procedures and schedule to be followed during post-closure, and include:

     •   Procedures for collecting gas, including:
         -  Design objectives of the system,
         -  Materials and equipment required;
     •   Details of the monitoring program,  including:
         -  Types of samples,
         -  Number of samples,
         -  Types of analyses,
         -  Frequency of analyses; and
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     •   Maintenance required during the closure period to ensure
         that the system is operating properly before post-closure
         begins, which may include:
         -  Repairs to parts of the system,
         -  Replacement and reinstallation of parts, and
         -  Routine maintenance.

10.4.3  Security System Maintenance

     Some hazardous waste disposal facility owners or operators may he
required by the Regional Administrator to maintain security devices
(e.g., perimeter fences, warning signs) during the post-closure care
period.  Although this requirement is at the Regional Administrator's
discretion, the owner or operator should use his own best judgment,
considering factors such as facility location, surrounding land use, and
types of wastes buried to decide whether to include a security provision
in the plan.  The post-closure plan should include a description of the
maintenance required to ensure that the security system remains reliably
functional throughout the post-closure period.  For example, it is
likely that a fence will require periodic repair and replacement of
sections as a result of normal wear, severe weather conditions, and
vandalism.  The plan should also include an estimate oif the frequency of
the proposed maintenance activities.  If the owner or operator does not
intend to provide for security measures during the post-closure period,
he should explain in the plan why such provisions are not required to
ensure the protection of human health and the environment.
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                 10.5  SAMPLE POST-CLOSURE PLAN OUTLINE
EPA Facility ID No.
Owner's or Operator's Name
Address & Phone No. 	
Facilitv Address
 I.  GROUND-WATER MONITORING (include copy of ground-water sampling and
     analysis program, when available)
     A.  Number, location and depth of wells to be monitored during
         post-closure
     B.  Frequency of monitoring of these wells
     C.  Analyses required annually during post-closure
         1.  Types of analyses required
         2.  Procedures for monitoring and analyses

II.  MAINTENANCE ACTIVITIES
     A.  Facility inspections
         1.  List all structures and facilities to be inspected
         2.  Frequency of inspections for each
     B.  Maintaining cover and/or vegetation
         1.  Cover maintenance activities and schedule
         2.  Mowing schedule
         3.  Reseeding and mulching schedule
         4.  Soil replacement
             a.   Labor requirements
             h.   Soil requirements
         5.  Fertilizing schedule
         6.  Sprinkling schedule
         7.  Rodent and insect control program
     C.  Controlling erosion
         1.  Maintenance program for drainage and diversion system
             a.   Anticipated labor requirements
             b.   Anticipated soil requirements

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         3.   Activities required to repair expected erosive damage
             a.   Anticipated  labor requirements
             b.   Anticipated  soil requirements
         4.   Replacement cover soil
             a.   Amount to be stored on-site during the post-closure
                 period
             b.   Specification of alternative sources of cover soil, if
                 applicable (i.e., off-site purchase agreement or on-
                 site  excavation)
     B.   Maintenance of ground-water monitoring system
         1.   Number of wells  requiring redrilling during the 30-year
             post-closure period
         2.   Number of wells  requiring replacement during the 30-year
             post-closure period
         3.   Annual routine equipment maintenance (e.g., replacement of
             seals and caps,  grouting)
     C.   Planned  responses to probable occurrences (including those
         listed below)
         1.   Loss of containment integrity
         2.   Severe storm erosion
         3.   Drainage  failure
         4.   Drought

IV.  ACTIVITIES REQUIRED AT SOME FACILITIES
     A.   Collecting, removing and treating leachate
         If  a leachate collection, removal and treatment system is
         installed at  your facility, complete this section
         1.   Describe  your leachate collection system (i.e., pumping and
             collecting procedures)
             a.   Describe the monitoring system
             b.   Estimated volume of leachate collected per month
         2.   Describe  leachate treatment process
             a.   Is treatment on-site?  If so, describe process for
                 treatment

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       (3)  Design objectives
       (4)  Materials and equipment required
3.  Disposing of leachate
    a.  If discharged to public waters, include copy of water
        pollution control permit
    b.  If hauling off-site, distance to disposer
    c.  Disposing of residuals
       (1)  Quantity of residuals
       (2)  Characteristics
       (3)  If disposed on-site, where?  (include drawing of
            disposal  area)
       (4)  If off-site, distance to disposer
4.  Maintaining equipment
    a.  Repairs and replacements required
    b.  Regular maintenance required
Gas Collection
If a gas collection system is required at your facility,
complete this section
1.  Monitoring requirements
    a.  Type of monitoring samples
    b.  Number of samples
    c.  Type of analysis
    d.  Frequency of analyses
    e.  Location of analyses (e.g., off-site laboratory
        analysis),  if applicable
2.  Maintenance of  system
    a.  Anticipated frequency of repairs
    b.  Resource requirements (gravel, piping, etc.)
    c.  Regular maintenance required
Security and public access practices planned for  the post-
closure period
1.  Description of  security system
2.  Maintenance schedule
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              11.0  REVISING CLOSURE AND POST-CLOSURE PLANS

11.1  REVISING CLOSURE PLANS

     "The owner or operator may amend his closure plan at any  time
during the active life of the facility.  (The active life of the
facility is that period during which wastes are periodically received.)
The owner or operator must amend his plan any time changes in  operating
plans or facility design affect the closure plan."*

     Since closure plans must often be written up to 20 years  ahead of
the actual closure period, EPA expects that changes will occur during
facility operation that will affect such plans.  Additionally, the
closure plans must account for the activities required to close the
maximum extent of the operation ever open during the life of the
facility, which in many instances requires the owner or operator to
predict uncertain future operating conditions.  For example, an owner or
operator must account for the maximum area of a landfill ever  open,
including areas inactive but open because of operating problems, and
must account for the most extensive amount of inventory.  In sone cases,
predictions can be expected to be fairly accurate even over a  20-year
period (e.g., size of the facility, length of operations) while others
are much less predictable even over a somewhat shorter tine frame (e.g.,
maximum inventory on-site).

     Revisions may also be necessary if an owner or operator completely
changes his plans for closing the facility.  For example, if an owner or
operator of a land treatment facility finds during the course  of his
operations that treatment is not completely successful, he must revise
his plan to include provisions for removing all wastes or provisions for
appropriate closure activities if the facility is to become a disposal
*EPA Interim Status Standards, 40 CFR 5265.112(4)(b)
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facility, i.e., a facility at which wastes remain after closure.
Similarly, if an owner or operator decides to remove all wastes from a
surface impoundment instead of closing it like a disposal facility as
originally proposed in the closure plan, major revisions would be
required.

     The closure plan is the basis of the closure cost estimate and
determines the extent of the financial responsibility requirements.  It
is therefore important to ensure that the plan is accurate and reflects
the most extensive closure activities that are likely to he required
over the life of the facility.  The plan also serves as the basis for
evaluating closure procedures when all closure activities have been
completed.  The professional engineer's certification, which is the
final closure requirement, certifies that closure has been performed in
accordance with the approved plan; therefore, the owner or operator must
revise the closure plan during the closure period if changes in facility
conditions affect the procedures described in the original closure
plan.  Any revisions to the approved closure plan t'hat are needed must
be approved by the Regional Administrator.

     In preparing a closure plan, the owner or operator must describe
the activities necessary to close the maximum extent of the operation
unclosed at any time, assuming normal operating conditions.  Revisions
are required or may be desirable if the maximum extent of operation
changes.  Revisions may not be required if the maximum extent of opera-
tions changes because of unusual operating conditions.  For example, an
owner or operator is not expected to revise the plan to account for
conditions caused by the 50-year flood or a liner failure unless such
contingencies affect conditions at the time the plan is prepared.  In
the event of such unusual conditions, revisions may not be required if
the owner or operator can justify to the Regional Administrator that the
problems will be corrected and conditions, as described in the plan,
will be restored within a short time.  The closure plan must account for
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the effects of such unusual contingencies if  they affect  the  conditions
of the facility at the time the plan is prepared.  A general  rule  is
that the conditions at the facility at the  time  the plan  is prepared
should never exceed the specifications in the plan.  If the closure plan
must account for the effects of unusual operating problems, the  owner  or
operator can later revise the plan to reflect the maximum extent of
operations under routine operations, assuming normal operating condi-
tions are restored.

     The owner or operator should use his judgment in preparing  the
closure plan.  The EPA will also be continuing to develop improved
technical guidance to further assist the owners  and operators in
preparing closure and post-closure plans; therefore, the  owner or
operator will likely need to revise his plans as more guidance material
and engineering data become available.  For example, the  Agency will be
providing guidance material for a ground-water monitoring program which
is to be implemented one year after the effective date of these
regulations; therefore, an owner or operator will likely  need to revise
his original closure plan when these new data become available.  Since
many of the closure and post-closure activities are the same  or  similar
to procedures practiced during operation, the owner or operator will
also gain a better understanding as a result of experience and may need
to revise his plan to reflect such knowledge.

     The kinds of operating changes which might affect the closure plan
and necessitate revisions include:

     •   Change in facility size and/or capacity;
     •   Changes in technology that may affect disposal or
         decontamination techniques, type of cover chosen, etc.;
     •   Changes in the closure  schedule  which alter the length of
         the closure period by greater than one month (e.g.,
         severe weather conditions may halt construction
         activities and extend the closure period by more than one
         month);
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Changes in the schedule of periodic activities which
affect activities required at closure (e..g., failure to
partially close a facility would mean tha,t a larger area
than previously estimated would need to be closed at
closure; the closure plan must always account for the
maximum extent of the operation open at any time over the
life of the facility);
Changes in types or quantities of wastes that affect
activities required at closure (e.g., the type and/or
quantity of waste on-site at closure will affect the
choices of treatment and disposal; the amount of waste
taken off-site hy an owner or operator of an incinerator
depends on the types and quantities of residuals
remaining after the wastes have been burned.  The types
and quantities of waste can also affect monitoring
requirements and cover requirements);
Change in maximum quantity of inventory ever expected on-
site;
Change in cover requirements from what was originally
proposed;
Changes in ground-water monitoring requirements as a
result of an owner's or operator's operating experience
during operation or modifications required by the
Regional Office. The ground-water monitoring regulations
stipulate that all or part of the requirements may be
waived if there is a low potential for pollution and,
conversely, that a more stringent plan must be
implemented if the facility is affecting ground water
(§265.90 and §265.93).  Revisions will also be likely
when the EPA provides more guidance and technical
engineering data on the kinds of monitoring appropriate
for hazardous waste facilities; and
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     •   Operating contingencies during closure which may affect
         closure requirements  (e.g., inclement weather causes
         construction problems; more contaminated soil must be
         disposed at closure than anticipated as a result of
         problems during operation).

11.2  REVISING POST-CLOSURE PLANS

     "The owner or operator may amend his post-closure plan at any time
during the active life of the disposal facility or during the post-
closure care period.  The owner or operator must amend his plan any time
changes in operating plans or facility design affect his post-closure
plan."*

     The post-closure plan describes the monitoring and routine mainte-
nance required to ensure the integrity of the cover and vegetation and
monitoring systems.  Since the post-closure plan is prepared while the
facility Is still In operation, It will likely be revised both during
operation and during post-closure, if necessary, to reflect changes in
facility conditions and operating experience.  For example, if an owner
or operator performs partial closures, he will need to maintain these
areas and thus will gain experience in the kinds of maintenance
activities needed during post-closure.  Similarly, an owner or operator
will be better able to describe the ground-vater monitoring procedures
after more EPA guidance becomes available and he gains operating
experience.

     The post-closure plan is the basis for the post-closure cost
estimate which affects the extent of the financial responsibility
requirements for post-closure.  The plan therefore must be revised
during facility operation, if necessary, to reflect the actual post-
*EPA Interim Status Standards, 40 CFR §265.118(b).
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closure needs in order to ensure that adequate financial responsibility
is required.  In addition, the plan, together with the cost estimate,
serves as the basis for post-closure reimbursements.  The owner or
operator will be reimbursed for post-closure costs, assuming that the
activities were in accordance with the post-closure plan.  Therefore, it
is important for the owner or operator to revise the post-closure plan
during post-closure if monitoring and maintenance requirements change
during the period.  Any revisions made during the post-closure period
must be approved by the Regional Administrator.

     Possible changes which could affect the post-closure plan include
activities which are required on an annual basis as well as those
required on an intermittent basis.   Conditions which could affect the
post-closure plan include:

     •   Change in facility size which will affect the extent of
         maintenance required;
     •   Changes in monitoring requirements as a result of an
         owner's or operator's operating experience during
         operation or modifications approved by the Regional
         Administrator (e.g., changes in the number of wells
         monitored and sampled, the frequency of analyses, types
         of analyses required).  During the 30-year post-closure
         period, the owner or operator may petition t:he Regional
         Administrator to discontinue or alter the monitoring
         requirements; alternatively, under certain circumstances
         the Regional Administrator may require an owner or
         operator to continue monitoring beyond 30 years.
         Revisions will also he likely when the EPA provides more
         guidance and technical engineering data on the kinds of
         monitoring appropriate during post-closure;
     •   Changes in annual routine  maintenance, including changes
         in the nature of the activities required and in their
         frequency (e.g., a more extensive erosion control program
         may he required than originally anticipated);

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Changes in activities required on an intermittent basis
or changes in the frequency of these activities (e.g., an
accelerated replanting schedule, more frequent
replacement of wells than anticipated);
Operating contingencies which occur during the life of
the facility or post-closure which affect post-closure
activities (e.g., severe weather conditions affecting
activities required for erosion control, cover
maintenance, maintenance of diversion structures);
Changes in surrounding land use (e.g., if the population
density increases, the measures needed to maintain
facility security might change; ground-water monitoring
program might be affected);
Changes in monitoring and maintenance technology;  and
Modifications approved by the Regional Administrator; the
owner or operator may petition the Regional Administrator
to allow some or all of the requirements for post-closure
to be discontinued or altered before the post-closure
period is ended.  Any such changes can only be made after
the post-closure period begins and would constitute a
revision to the post-closure plan made during post-
closure.
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            12.0  ADEQUACY OF CLOSURE AND POST-CLOSURE PLANS

12.1  INTRODUCTION

     Faced with the range of site-specific variables and the host of
technical alternatives for satisfying the requirements of the regula-
tions, the EPA has opted for determining the most specific technical
ineasures on a. case-by-case basis.  No single engineering study can
address or provide a comprehensive guide to all of the variables
involved in this problem.  Given the site-specificity of the require-
ments, evaluating the adequacy of the closure and post-closure plans is
critical to ensure environmental protection.

     The Regional Administrator has the critical role of evaluating
technical procedures in approving closure and post-closure plans and
should use his best judgment to determine the adequacy of closure and
post-closure plans.  Although the adequacy of the plans are ultimately
determined by the Regional Administrator's judgment, there are some
checks that do not require detailed engineering expertise.  These checks
may be useful during interim status as methods of determining quicklv
whether or not the closure and post-closure plans are reasonable and
provide coverage for the activities that are obviously necessary.  These
checks can normally be accomplished with an hour or two on-site.

12.2  ADEQUACY OF SUBMITTED CLOSURE PLANS:  CRITERIA FOR APPROVAL

     The following discussion attempts to clarify and suggest possible
ways to evaluate closure plans.
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12.2.1  Inspecting the Facility

     The first step in evaluating the closure plan is to visually
inspect the facility and ensure that the conditions at the facility do
not exceed the maximum conditions described in the first part of the
closure plan.  For example, an inspector could readily determine whether
the number of drums and approximate amount of bulk waste on-site exceed
the estimate in the closure plan.  He could also see how much of the
facility was open at the time, which would determine whether or not the
owner or operator was complying with the operating schedule.  An inspec-
tion would also provide the Regional official with a general idea about
the extent of cleanup operations that would be required if the owner or
operator were to commence closure.

12.2.2  Plans for Treating, Disposing or Removing Inventory

     If an owner or operator includes a large estimate of inventory in
the closure plan, the closure plan must include detailed provisions for
its removal.  Since accumulating inventory is often a major cause of
large cleanup costs, it is essential that adequate procedures for
disposing, treating, or removing the inventory to an off-site TSDF be
specified in the closure plan.  In estimating the maximum amount of
inventory, the owner or operator should also include some estimate for
residues.  The plan must specify whether on-site or off-site treatment
or disposal or some combination will be used to remove the inventory.
If an owner or operator plans to treat or dispose of wastes on-site, the
Regional official should check to be sure that:

    •  The plan includes the actual procedures to be used for
       disposing or treating inventory, including residues;
    •  There is available space on-site specifically designated
       for disposing or treating inventory;
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    •   It  is conceivable  to dispose  or  treat  the  estimated  amount
        of  inventory on-site within 90 days;
    •   The facility accepts the kinds of wastes that  are  to be
        disposed or treated (e.g., an owner or operator of an
        incinerator might  have certain hazardous residues  which
        could not be landfllled at that  multiple process facility
        and would need  to  be removed  to  an off-site TSDF);
    •   An  owner or operator of a treatment or storage facility who
        proposes to dispose of wastes on-site  has  a facility with
        interim status or a permit; and
    •   The owner or operator has a post-closure plan  if any
        wastes, including hazardous residues, are  permanently
        disposed on-site.

 12.2.3  Plans for Decontaminating the Facility

     An evaluation of procedures for decontaminating a facility are
 site-specific and can best be judged with a visual inspection.  Facility
decontamination is not intended to be a highly complex technical
requirement; rather,  for a well-operated facility, it is intended to
 include routine cleaning  procedures to ensure that all hazardous
materials such as residues are removed from equipment and spills and
drips are cleaned up.  The proposed plans should always be  extensive
enough  to cover all activities that might be needed if an owner or
operator unexpectedly ceased operations and closed the facility.  In
most cases, a relatively small number of soil samples to determine the
degree  of contamination, accompanied by a visual inspection  of the
facility conditions,  should be sufficient to evaluate the proposed plans
 for decontaminating the facility.  An inspector should also  check to
ensure  that the equipment on-site matches the list included  in the
closure plan.  If,  upon visual inspection,  a facility appears to have a
contamination problem, the Regional Administrator  would be  justified in
demanding more detail in the closure plan,  including provisions for soil
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tests, for example, to ensure that the owner or operator has made
adequate plans for decontaminating the facility at closure.

     The plan should also include provisions for treating, disposing or
removing all hazardous residues, including contaminated soil, that
result from the decontamination processes.  If a facility is a permanent
repository of waste or part of a multiple process facility with a dis-
posal facility with interim status or a permit, it is likely that
residues will be disposed on-site.  If wastes are to be disposed on-
site, the facility must have available capacity, and the plan should
include a description of the procedures required for disposal.  If a
facility is not a permanent repository of waste, provisions must he made
to remove the residues to an off-site TSDF.

12.2.4  Evaluation of Proposed Cover and Vegetation

     All owners or operators of land disposal facilities, i.e., facil-
ities at which wastes have been intentionally placed  into land or water
and will remain after closure, must provide cover and usually vegetation
which will help to control, minimize or eliminate post-closure escape of
hazardous waste constituents which could pose a threat to human health
or the environment.  The specifications are on a site-specific basis,
and the adequacy of the system chosen must be demonstrated in the
closure plan.  The Regional Administrator must rely on his judgment and
future EPA engineering guidance.

12.2.5  Monitoring Plans

     The simplest way to evaluate ground-water monitoring procedures
that are required during closure and/or post-closure is to ensure that
the procedures are in accordance with §265.90 et seq. and that a copy of
the ground-water sampling analysis plan has been included in the closure
and post-closure plans.  Until the ground-water program is implemented,
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It is expected that the owner or operator will use his own  judgment  in
describing how he will comply with the ground-water monitoring
requirements in Section 265.90 et seq. of these regulations.  If a
leachate collection, treatment and removal system or a gas  collection
system is in place at a facility, the plans should reflect  a
continuation of present operating procedures.  A visual inspection of
the facility's monitoring system could provide some idea of the adequacy
of the proposed maintenance needs during closure and post-closure.

12.2.6  Closure Certification

     An independent licensed professional engineer must certify that
closure has been performed in accordance with the activities described
in the closure plan.  The Agency expects that certification will involve
several periodic inspections during the closure period, and the Agency
does not mean to imply that an engineer must be on-site throughout the
entire closure period.  The closure plan should include an estimate of
the number of inspections anticipated.

12.3  ADEQUACY OF SUBMITTED POST-CLOSURE PLANS:  CRITERIA FOR APPROVAL

     The Regional Administrator has the authority to approve or disap-
prove post-closure plans that are submitted.  This means that he should
have established general criteria for this decision.

     The primary criterion for post-closure plan adequacy is sound
engineering judgment.   Statements of an unusual or controversial nature
in the post-closure plan should be supported by some type of
justification or evidence.  In many cases, the owner or operator can
refer to his operating experience and records for documentation.  For
example, if an owner or operator performs partial closures as part of
routine operating activities, he will have experience in many of the
activities required during post-closure (e.g., mowing, fertilizing,
controlling erosion).

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     In addition, the post-closure plan must contain some  information  on
the monitoring and maintenance functions that are required by the regu-
lations to be in the post-closure plan.  This means that,  at the very
least, monitoring and maintenance operations must be discussed.  The
nature of the operations should be described and the planned frequencies
of the operations given.
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               II.0  IMPLEMENTING CLOSURE AND POST-CLOSURE
                          DURING INTERIM STATUS

 13.1  PROCEDURES REQUIRED PRIOR TO CLOSURE ACTIVITIES

 13.1.1  Submitting the Closure Plan

     "The owner or operator must submit his closure plan to the Regional
 Administrator at least 180 days before the date he expects to begin
 closure.  The Regional Administrator will modify, approve, or disapprove
 the plan within 90 days of receipt and after providing the owner or
 operator and the affected public (through a newsoaper notice) the oppor-
 tunity to submit written comments."'

     An owner or operator who closes a hazardous waste facilitv during
 the interim status period must submit the closure plan to the Regional
 Administrator at least 180 days prior to the expected date of closure.
 The closure period begins when the owner or operator accepts the ftnal
wastes.  An owner or operator is not allowed, under these regulations,
 to close without an approved closure plan.  It is essential, therefore,
 that an owner or operator who closes during interim status has an
adequate closure plan.  If he does not have an acceptable plan,  closure
activities may be forestalled long after operations have ceased  until an
acceptable plan is developed.  The purpose of this section is to discuss
 several problems that mav emerge during the approval process and pos-
sible alternative approaches to avoid the above situation.

     Upon receiving notification of pending closure, the Regional Admin-
istrator should send an inspector to the site to examine the facility
and review the proposed closure procedures, allowing sufficient  time to
make modifications to the plan if deemed necessary.   This is especially
*EPA Interim Status Standards,  40 CFR §265.112(c)
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Important if the plan has not been recently reviewed by the Regional
Office.  The Regional Administrator must approve, modify, or disapprove
the plan within 90 days as well as notify the public that the facility
will be closing and allow both the public and the owner or operator to
submit written comments.  The Regional Administrator must read all
written comments and address them in a prepared statement.

     During the interim status period, it is likely that the closure
plan will require some modifications.  Modifications may be necessary
if:

    •  The Regional Administrator's judgment differs from the
       owner's or operator's judgment;
    •  Ground-water monitoring plans are inadequate;
    •  The owner or operator falls to revise the plan to reflect
       current conditions; or
    •  Unexpected operating problems make it necessary to alter
       the closure plan to meet the closure performance standards.

Assuming that the plan is modified in a manner acceotable to both the
Regional Administrator and the owner or operator, the Regional
Administrator will approve the plan and the owner or operator can begin
closure procedures.

     If the Regional Administrator finds the olan totally inadequate,
he has three options:  (1) disapprove the plan and require the owner or
operator to submit a new one for approval; (2) present the owner or
operator with a modified plan that would be acceptable; or (3) request
Part B of the permit application and begin permitting procedures.

     If the Regional Administrator disapproves the plan, he must state
his reasons for disapproval and the owner or operator must submit a new
plan for approval.  Another possible approach to resolving the problems
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associated with an Inadequate closure  plan  is  for  the  Regional
Administrator to present the owner or  operator with a  modified closure
plan that would be approved if the owner or operator agreed  to comply
with its specifications.  The third option is  for  the  Regional
Administrator to request Part B of the permit  application and commence
the permitting process.  An approved closure plan  will therefore become
part of the permit conditions.

13.1.2  Submitting the Post-Closure Plan

     "The owner or operator of a disposal facilitv must suhmit his post-
closure plan to the Regional Administrator at  least 180 days before the
date he expects to begin closure.  The Regional Administrator will
modify or approve the plan within 90 davs of receipt and after providing
the owner or operator and the affected public  (through a newspaper
notice) the opportunity to submit written comments.  The plan may be
modified to include security equipment maintenance under §265.117(b)."*

     An owner or operator who closes a facility during interim status
must also submit the post-closure plan at least 180 days before closure
begins.  The Regional Administrator has 90 days in which to review the
plan and either approve,  modify, or disapprove it.  During interim
status, the post-closure  plans may not be frequently reviewed, and
therefore,  it is important that the plan be submitted well in advance of
closure to allow tiine for modifications,  if necessary.   Modifications of
the post-closure plan may be necessary if:
*EPA Interim Status Standards,  40 CFR §265.118(c)
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    •  The Regional Administrator's judgment differs from  the
       owner's or operator's judgment (e.g., disagreement  over the
       extent of maintenance required for the cover,, replanting
       schedules);
    •  The ground-water monitoring program is inadequate;
    •  The Regional Administrator requires maintenance of  any or
       all of the security systems needed during operation which
       were not included in the post-closure plan;
    •  The owner or operator fails to include provisions for
       additional maintenance required on a periodic basis (e.g.,
       repairs needed as a result of predictable adverse weather
       conditions, well replacements); or
    •  Other problems which may result.

The same procedures apply to the approval process of post-closure plans
as to closure plans.

13.1.3  Inspecting the Facility

     During interim status, the closure and post-closure plans must he
available at the facility at all times and are subject to  inspection by
an EPA official administering Subtitle C of these regulations or an
approved state program official.  The official should, make periodic
inspections to check the plans to help reduce the number of inadequate
plans submitted at the time of closure.  Since the closure plan must be
based on the maximum extent of operation unclosed at any eiven time and
must include an estimate of the maximum amount of inventory expected to
accumulate over the life of the facility, assuming normal  operating
conditions, an inspector can check these portions of the plan by looking
at the facilitv conditions.

     Periodic inspections can also eliminate some of the nroblems that
are caused by misunderstandings and confusion about the intent of the
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regulations.  The official making the inspections should review  the
ground-water monitoring plans described in the closure and post-closure
plans.  Since the implementation of the ground-water monitoring  program
will not he required until one year after the effective date of  the
regulations and the owner or operator may have no previous operating
experience, it is likely that the program described in the closure plan
nay require some mortifications.  If an inspection of the plans shows
that the activities described are not appropriate for that facility, the
Regional Office should discuss with the owner or operator the problems,
explain the intent of the requirements, if necessary, and advise him to
revise the plans.  If the owner or operator fails to prepare an  adeauate
plan, the Regional Office has the option to begin permit proceedings
immediately, which involves the procedures discussed In Sections 13.1.1
and 13. 1.2.

13.2  CLOSURE PROCEDURES

13.2.1  Closure Schedule

     The closure period begins with the final acceptance of wastes.
"Within 90 days after receiving the final volume of hazardous wastes,
the owner or operator must treat all hazardous wastes in storage or in
treatment, or remove them from the site, or dispose of them on-site, in
accordance with the approved closure plan."*

     In order to help prevent the possibility of environmental damages
caused by the accumulation of wastes without proper plans for timely
management, the regulations require that all wastes be treated, disposed
or removed within 90 days after receiving the final volume of hazardous
wastes.  An owner or operator must either complete whatever treatment
processes are needed, if any, and disnose all wastes on-site  within 90
*EPA Interim Status Standards §265.113(a).

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days or make arrangements to remove all wastes, or any that cannot be
managed on-site within the allotted time, off-site within 90 days.  A
Regional Administrator may grant an owner or operator a longer period of
time to manage inventory if routine treatment processes, of necessity,
take longer than 90 days.  This is an especially likely situation for
some kinds of treatment facilities.  For example, if the most approp-
riate method for removing free liquids from a surface impoundment is
evaporation, treatment may take longer than 90 days.  Similarly,  a
surface impoundment which relies on biological treatment and is only
seasonally aerobic may require more than 90 davs to complete treatment
of inventory.  The 90-dav limitation presents special problems to an
owner or operator of a land treatment facility.  If the facility  con-
tains no hazardous wastes at the time of closure, as is intended  at some
facilities, post-closure care is not required.  The treatment processes,
however, take much longer than 90 davs to complete; therefore, it is
important for an extension to he granted to allow the facility to
operate as intended and render the wastes non-hazardous or less
hazardous.

     "The owner or operator must complete closure activities in accor-
dance with the approved closure plan and within six months after
receiving the final volume of wastes.  The Regional Administrator may
approve a longer closure period under §265.112(c) if the owner or
operator can demonstrate that:  (1) the required or planned closure
activities will, of necessttv, take him longer than six months to
complete, and (2) that he has taken all steps to eliminate any signif-
icant threat to human health and the environment from the unclosed but
inactive facility."*

     The Regional Administrator should use his discretion in determining
an appropriate closure period.  For example, if a substantial amount of
*EPA Interim Status Standards, 40 CFR §265.113(b).

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construction activity is required at a large landfill at  the time of
closure, adverse weather or other unexpected conditions may make a six-
month closure period impossible.  This six-month closure  period presents
particular difficulties to an owner or operator of a land treatment
facility.  The objective of land treatment is to apply hazardous wastes
to the soil in order for biological degradation or chemical reactions
occurring in or on the soil to render the wastes less hazardous or non-
hazardous.  This process, which includes periodic refilling of the soil,
will frequently take longer than six months to complete.  Assuming that
the facility is operating properly and the Regional Administrator is
satisfied that the owner or operator is acting in good faith, an
extended closure period would be justified.

     If an owner or operator must take longer than six months to
complete closure, he must ensure that all steps have been taken to
eliminate any significant threat to human health and the environment
from the facility.  The Agency intends that an owner or operator of a
well-operated facility will continue the kinds of standard ooerating
procedures routinely used to eliminate the threat of pollution.  The
provision has been included as a specific requirement in  the regulation
to allow for certain emergency measures that the Regional Administrator
may deem necessary.  For example, if at closure the hazardous wastes are
leaching into the ground water, the Regional Administrator will likely
require more extensive Dumping and other activities as part of closure
procedures to mitigate the problems.

13.2.2  Revising Closure Plans During Closure

     The professional engineer's certification certifies  that closure
has been performed in accordance with the closure plan.  Therefore,  if
during the closure period the owner or operator finds it necessary to
alter some of the procedures,  the owner or operator must revise the
closure plan to reflect these changes.  Any such changes  that the owner
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or operator deems necessary during the process of closing the facility
must he approved by the Regional Administrator.  Possible changes
include:

     •   Changes in the closure schedule which affect the length
         of the closure period hy greater than one month (e.g.,
         severe weather conditions which halt construction
         activities, equipment breakdowns); and
     •   Contingencies which affect what needs to he done to
         adequately close the facility.

13.2.3  Closure Certification Procedures

     "When closure is completed, the owner or operator must submit to
the Regional Administrator certification hoth by the owner or operator
and by an independent registered professional engineer that the  facility
has been closed in accordance with the specifications in the approved
closure plan."*

     The required certifications only represent a guarantee that closure
activities have been performed in accordance with the approved closure
plan.  The certification applies to all activities performed as part of
the closure including all partial closures.  Official inspectors should
also periodically check the facility during the closure period,  as well
as after receiving the orofessional engineer's certification, to
increase the Regional Office's confidence that the facility has been
adequately closed.  In the event that the Regional Administrator finds
that closure has not been performed in accordance with the approved
plan, he has the authority to require the additional activities
necessary to comply with the plan.
*EPA Interim Status Standards, 40 CFR §265.115.
                                 13-8

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                     Owner or Operator Certification

     The owner or operator must certify that  the activities  performed  in
closing the facility are in accordance with the specifications of the
closure plan previously approved by the Regional Administrator.  The
owner or operator is not guaranteeing the technical adequacy of closure,
but rather that the closure plan, as approved by the Regional Adminis-
trator, was carried out.  Accordingly, the certification will he
straightforward, no matter how complex closure itself will be.  An
example of a certification follows.

     I, 	, of
                        owner or operator

        name and address of hazardous waste facility
hereby state and certify that, to the best of my knowledge and belief,
the above-named hazardous waste facility has been closed in  accordance
with the attached approved closure "Ian, and that the closure was
completed on the  	day of 	, 19	.
         signature                                   date

               Professional  Engineer  Closure  Certification

     An independent registered professional engineer(s) must certify
that the facility has been closed in accordance with the approved
closure plan.  The engineer is not certifying the adequacy of the
activities or the plan; he is certifying only that, in his judgment, the
activities performed were in accordance with the specifications in the
approved plan.  EPA does not expect that the engineer will spend large
periods of time on the site, observing all partial closures and final
closure.  Rather, the Agency expects that the engineer will periodically
visit the site and inspect the closure activities.  Since all closure
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activities, including partial closures, must be certified  by a
professional engineer, and a professional engineer will generally need
to observe the activity while it is being performed, an owner or
operator may find it most practical to have a professional engineer
certify partial closures as they are completed.  At final,  closure the
professional engineer who certifies that closure has been  completed can
rely in part on earlier certifications of partial closures and  in part
on his inspections of the facility as a whole to ensure that the
partially closed areas have been maintained.  The following is  a sample
professional engineer certification:
certified professional engineer, hereby certify, to the best of my
knowledge and belief, that 1 have verified that Professional Engineer
Closure Certificates were issued for all prior closure activities at
 _   _                                                      	  and
                 hazardous waste facility
that I have made visual Inspection(s) of the aforementioned facility,
and closure of the aforementioned facility has been performed in
accordance with the closure plan for the facility approved by the
Regional Administrator for Region	of the United States
Environmental Protection Agency.
          signature                                    date

      State Professional Engineer License No., issued by the State of

               business address and telephone number
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13.3  POST-CLOSURE PROCEDURES

13.3.1  Effective Date of Post-Closure

     The date that the independent professional engineer signs  the
closure certificate is the effective date of post-closure.  The owner or
operator should begin post-closure activities on that date in accordance
with the approved post-closure plan.

13.3.2  Notice to Local Land Authority

     "Within 90 days after closure is completed, the owner or operator
of a disposal facility must submit to the local land authority and to
the Regional Administrator a survey plat indicating the location and
dimensions of landfill cells and other disposal areas with respect to
permanently surveyed benchmarks....The plat filed with the local land
authority must contain a note, prominently displayed, which states the
owner's or operator's obligation to restrict disturbance of the site as
specified in §265.117(c)."*

     Within 90 days from the date that the professional engineer has
certified closure, the owner or operator must submit to the local land
authority and to the Regional Administrator a survey plat prepared and
certified by a professional land surveyor.  The surveyor is responsible
for preparing and certifying a plat, which indicates the location and
dimensions of cells or trenches.  The plat can be prepared from the
operating log of the facility.  The purpose of the survey plat is to
provide information if problems arise after the operating period, if
resources are to be recovered, or if it is necessary to locate water
mains, power lines, etc.  The plan also must contain a note, prominently
displayed, which states the owner's or operator's obligation to restrict
*EPA Interim Status Standards 40 CFR §265.119,
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disturbance of the  fad1 try as  rfpec.lt i».i  i-,, 4''ft;  i!7(c}«   The  plat and
note are  filed with  the "local land authotlry,, !.«,,  the  authority  that
keeps  records of all  deeds so that t'utur-i  n&«t*i ^.j^  csrrr.hasc'c   ••>|,ver ••>>: op^/alo'." <:v;'ji also
submit a  record of  the tvpe, location and  viu-ur- >', i\', ot  •,--« 5-fe s disposed
within each area of  the facility.  this  ! >-f o., ma t irn,  should be  obtained
from operating records; for wastes t^eatf-..*  o>  ^ sr\-^d t'sfcre  the
promulgation of the  regulations,.,  the f>*nei-.  ••;' o,"-...:•,<'.<'•,•  BiiOuAt'  provide
the information to  the best of  his
      A sample note  to accomptiny  tiie
      This plat describes real  orop«»v c i'  in  .;.i, - ;•..  i-:.f-lGuii v®oi;ss  have
been  disposed and  hurled in accordance  i^i i !i ,^ J '':>'^v u^:^, c;F •'"*' CT'iJ §265
Although the hazardous wjsste disposal Hnc L'L •.•:•:• ." :; ,iov  -•..ioss»'J j public
health,  environmental safetv,  aud V2#.ij.?i tt o'.-.-i J.-;a".^ri  hf •. hi: Ui.'tad
States  Environmental  Protection  Agency  a.  •-• J i.5''-: l/^ "•- ' " -';'c, ) require
that  post-closure  use of the prop-arfr u.'5->>:;  -.  •.• .-:•.' ...vx,- j  !:c -•*'. at.irb tite
integrity of the final cover,  linei(sj  ox  i>ii-.  .-i /cacisen  co - •"& I iiresti t
system  unless it can  be demonstrated  uha I  au1-' su ••')•.. rjtd  d ;. st vb^m ,« c.n L !
not increase any risk to the public or  ihc t ^-.l .:c/:, ,&: i •:
      Your attention  is directed  Lo the accowtJi^av - vh  J,.i.3k  of wastes,
described by type  and location^  buri.xd At  t'li--. ;)hcn «--de sex ibc--d  rar.i.i itv,
                                                       ,-pe-ai'iot1 ss signature
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13.3.3  Revising Post-Closure Plana During Post-Closure

     Any modifications and revisions to post-closure care made during
the post-closure period must be approved by the Regional Administrator
and reflected in a revised post-closure plan.  See Section  11.2,
"Revising Post-Closure Plans," for a discussion of plan revisions.

13.3.4  Notice in Deed to Property

     "The owner of the property on which a disposal facility is located
must record, in accordance with State law, a notation on the deed to the
facility property — or on some other instrument which is normally
examined during title search — that will in perpetuity notify any
potential purchaser of the property that:  (1) the land has been used to
manage hazardous waste, (2) its use is restricted under §265.117(c), and
(3) the survey plat and record of the type, location and quantity of
hazardous waste disposed of within each cell or area of the facility
required in Section 265.119, is on file with the local land authority
and the Regional Administrator of the Environmental Protection Agency."*

     The difficulties at Love Canal in New York were compounded by the
fact that individual owners of the land containing the leaching chemical
wastes had no knowledge prior to their purchase of the land that there
was anything untoward burled beneath its surface.  To prevent this from
happening again, the EPA in §265.120 of tue regulations has required
owners of property where hazardous wastes are disposed to record a
notation on the deed or other instrument that is normally examined
during title search that will alert all future purchasers of the land
that hazardous waste has been disposed on the property, and that the use
of the property is restricted under §265.117(c), and that the survey
*EPA Interim Status Standards, 40 CFR §265.120.
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plat recording  the types, location and  quantit**s of disposed wastes  is
on file with  the  local land authority and  the  Regional Administrator.

     Conceptually, the problem and the  solution ats straightforward • —
any facility  owner or operator dis oosins, or  rrcHtirr rs?:,'3fdous wastes
under  the regulations must give sufficient \n i 1 1 <•-, :  ncttca to  the  local
land authorities  to alert any subsequent o ;•> ••"•• -*.-t •, t ' f the land of Its
contents and  restrictions on Its use.   Artinlnis; ., ,-: ."!on of chj s require-
ment cannot be  as straightforward as the ce^csj-.i"  >s.:-.^u?e local property
law and local recording requirements vary  from jurJ sdicticm to jurisdic-
tion across the country.   The form of the  •><>(•!•<.:*.  :.'.• ,\. ,-^r •- 1 CHH  ha
expected  to  vary state by state and eveii  wt ts"'< -;- ,jti-t;':t;r  it. Is up  to the
Regional  Offices to ensure that the .h~-  .. c?r-:;;« t- .: f rne notice  does
not vary.

     The  minimum requirements of notice  un.-iei  •;!..", !?J arc as follows:

     TO WHOM IT  MAY CONCERN:
     __ _  __ __   _ __    __  _^            che tinder signed ,
of _  ______        ____                        ,  C1 fy
                      street addres?s
of __ __ _ „__._„» County of ^         __._„ _ __ »  State
of _ ___„_„, _ _» hereby g:lvaa r,h*s following  notice as
required  by  40 CFR §265.120:

      1.   I am, and since  ____ ,  19_    ha/e hee« in possession  in fee
simple of the  following described  lands
                       (legal description)

     2.   Since	,  19_   ,  1 have  di s^ost-d of hazardous  chemical
wastes  under  the  terms of regulations  promu! c,3 i"e ' i;y f'ha UirLted  States
Environmental Protection Agency  on/in  the  Above•••'e-c;c r1 h
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     3.  The future use of the above-described land  is restricted under
the terms of 40 CFR §265.H7(c).

     4.  Any ard all future purchasers of this land  should  inform them-
selves of the requirements of the regulations and ascertain the amount
and nature of wastes disposed on the above-described property.

     5.  I have filed a survey plat with the local land authority and
with the Regional Administrtor of EPA showing the location  and
dimensions of landfill cells and a record of the type, location and
quantity of waste disposal within each area of the facility.

     The notice should be signed by the owner of the land, and the
signature notarized.  The Regional offices of the Agency should make
sure that such notice is filed in accordance with local recording
requirements by obtaining a duly stamped as received copv from the local
land authority.  The Regional Offices should be aware that different
jurisdictions have different technical requirements  for acknowledging
documents relating to land or verifying them.  The outline above is only
a skeleton reflecting the gist of §265.120, and will necessarily be
fleshed out by local requirements.  Variations in language and structure
which do not affect the information to be conveyed in the form above
should be acceptable to the Regional Offices if there is proof that the
local land authority in question has accepted and filed the notice in
the index most likely to be checked by later purchasers.

13.3.5  Post-Closure Security Requirements

     Section 265.117(h) of the interim status regulations states that:

     "The Regional Administrator may require maintenance of any or
     all of the secxirity requirements of §265.14 during the post-
     closure period, when:
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     v.
(1)  Wastes may remain exposed after completion of closure;
     or
(2)  Short term, incidental access by the public or domestic
     livestock may pose a hazard to human health."
The interpretation of this section is up to the discretion of Che
Regional Administrator.  However, it may be noted that the situation in
which wastes remain exposed after the completion of closure will he
rather unusual, since this would imply that closure would have been
completed without anv cover.  Even a land treatment facility would not
normally commence post-closure until all possible treatment was
completed and at least a vegetative cover had been established*  The
prevention of short-term incidental access may normally be accomplished
through the use of a posted fence.  In most cases,, this will he neces-
sary to prevent Incidental access and may be necessary in any situation
where the burial of hazardous waste is relatively shallow.  This would
particularly be the case for a land treatment facility which still
contained hazardous wastes under only a vegetative cover.  It would also
be desirable to have this level of security for a surface impoundment or
landfill in which the burial of the wastes was relatively shallow (i.e.,
under, at most, 2 to 3 feet of cover).  The requirement for security
might, however, be foregone in situations where the containment is
extremely stringent and where the wastes are buried so deeply that it
would be extremely unlikely for surface vegetation to contain any
haEardous wastes or for incidental contact to cause potentially serious
erosion problems or other uncovering of the hazardous wastes.

13.3.6  Post-Closure Property Use

     The regulations require that, whatever the property use, there must
be assurance that the use of the property "never be allowed to disturb
the integrity of the final cover, liner(s), or any other components of
any containment systems or the function of the facility's monitoring
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systems unless the owner or operator can demonstrate  to  the Regional
Administrator either in the post-closure plan or by petition  that  the
disturbance:  (1) is necessary to the proposed use of the  property, and
will not increase the potential hazard to human health or  the
environment; or (2) is necessary to reduce a threat to human  health or
the environment."*

     In general, the post-closure plan should indicate the proposed
post-closure property use, and either demonstrate that such use will not
disturb the integrity of the containment system or demonstrate  the
necessity of such disturbance.  If this has not been covered  in the
post-closure plan, it may later be altered by a petition.  In general,
this requirement should be interpreted stringently; any  property use
with the potential to cause erosion of the final cover should be
prevented unless the owner or operator can demonstrate that the
disturbance is necessary and that adequate provision has been made in
the post-closure plan for erosion control measures.  The integrity of
the final cover may, of course, also be disturbed if it  is necessary in
order to contain potential threats to health or the environment; how-
ever, even in these situations, the necessity must be firmly demon-
strated to the Regional Administrator.

12.3.7  Duration of Post-Closure Requirement

     Section 265. I17(d) states that "the owr.jr or operator of a disposal
facility must provide post-closure care in accordance with the approved
post-closure plan for at least 30 years after the date of completing
closure."  However, two kinds of exemptions to this requirement are
provided for in the regulations.  First, the owner or operator may
"petition the Regional Administrator to allow some or all of the
requirements for post-closure care to be discontinued or altered before
*EPA Interim Status Standards, 40 CFR §265.117(c),

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Che end of the post-closure period."   It  should  be  noted  that  some  of
the requirements may he discontinued without discontinuing  all post-
closure requirements.  The period of post-closure ;istt-closure care
period hased on cause.  These petitions will he considered  by  the
Regional Administrator at the time the post-"<*,','ns1.!'- ;.!ar<  is subi-a ^e.i
and at five year intervals after the completion of  closure.''  To
summarize, while the post-closure care period is SRC for  30 years,,
either all or a portion of the requirements may be  shortened through a
petition to the Regional Administrator, or len^Lhened  for soecified
periods either as a result of petition or at ch?; direction  of  the
Regional Administrator.

     The most obvious situation in which  a reasonable  case  could be made
for discontinuing post-closure care requirements would 1-f: thjt 1 n  which
it could be demonstrated that the wastes  have been  wondered non--
hazardous or that they have been removed.  In ths case of organic
hazardous wastes, natural soil processes  could have the effect of
rendering the wastes non-hazardous.  This could  be  demonstrated by a
suitable statistical sample of soil probes.  Such a situation would
probably be most likely to occur at a  land treatment facility, where
organic wastes were not fully rendered non-hazardous at the time closure
was completed, or at a surface impoundment which wa3 closed as a dis-
posal  facility and where the remaining waste materials were organic*

      It is also possible, under some circumstances, that  wastes might be
removed.   Wastes might he removed  if:  fl) problems at the facility
made  it less expensive to remove wastes  to another  facility than to
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continue waste disposal on-site; (2) improvements in technology allowed
methods of rendering the wastes non-hazardous that were less expensive
than continuing post-closure care; and (3) changes in costs of material
or recycling technology made it more advantageous to mine and recycle
material that had previously been treated as hazardous wastes.

     If hazardous wastes are not rendered non-hazardous or removed, the
question of the proper duration of post-closure requirements is
extremely difficult to answer.  The same problems occur when one is
dealing with a petition to shorten the post-closure care period or when
deciding whether the post-closure care period should be extended beyond
30 years.  A demonstration that no leaks have occurred to date cannot,
in and of itself, be considered adequate grounds for eliminating all or
a portion of post-closure care requirements.  The absence of leaks or
runoff problems does not demonstrate the absence of need for post-
closure care for two reasons:

     1.  Future events may occur such that past performance may not be
repeated.  One problem that should be given specific attention in this
line is that of wastes that have been disposed of in drums.  It may be
that it is the barrels themselves, rather than the cover, vegetation,
and underlying soil, which has prevented leakage in the past.  However,
barrels underground can be expected to decay and begin leaking 10 to 30
years after original placement.  As a result, when waste has been
disposed of in containers, even an extended period of no leaks does not
provide proof of the adequacy of the larger containment svstem.  A
second possible problem is that the viability of various kinds of
synthetic membranes over long periods of time in the ground remains
uncertain.

     2.  The absence of leaks may be the direct result of post-closure
care, and the absence of this care may lead directly to environmental or
health damages.  In the absence of some experiments, with the approval
of the Regional Administrator, it is difficult to determine to what

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extent control has been maintained precisely because of the post-closure
care.  For example, post-closure care will typically include extensive
measures to prevent erosion and the development of deep rooted
vegetation.  It may be unclear, in the absence of some experiments,  to
what extent erosion or deep rooted vegetation would cause problems  in
the absence of post-closure care.  The Regional Administrator may thus
wish to consider the possibility of allowing the owner or operator  to
forego certain steps in his post-closure care plan while continuing
inspections, with the possibility that these steps may need to  be
restored if inspection shows problems developing i;n their absence,

     It should be noted that even if the Regional Administrator decides
to discontinue some requirements of post-closure care, as long as
hazardous wastes remain, post-closure use of property must not  be
allowed to deter the integrity of the containment system, the notice to
local land authorities must remain in effect, and the notice in the  deed
to property must remain in effect.

     The Regional Administrator must consider and resoond to any
petition for an extension or reduction of the nost-closure care period.
Any letter from the general public or the owner or operator requesting
an extension or reduction of the post-closure care period, or one from
the owner or operator requesting a reduction in post-closure care
requirements, must be considered as a petition.  In response to the
petition, the Regional Administrator must, at a minimum, file a formal
written response as pare of the public record for the facility  con-
cerned.  He may, but is not required to, seek public comment on the
suggestions offered in any petition.

     A  petition from the owner or operator to alter some of the post-
closure requirements can take any form, but should include at a minimum,
the  following information:
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     •   Identification of the facility;
     •   Identification of the current post-closure requirements
         for which an alteration is proposed;
     •   The proposed alterations (the description of the current
         requirements and the proposed changes should he presented
         in the petition so they can be readily compared); and
     •   Technical justification, as detailed as possible, demon-
         strating that the proposed alterations will not cause a
         threat to human health or the environment.

     A petition from the owner or operator or the general public to
reduce the length of the post-closure care period should include, at a
minimum, the following information:

     •   Identification of the facility;
     •   Suggested extension or reduction (in years); and
     •   Justification for the alteration
            If the request is to extend the time period, the
            petition should provide evidence that either the
            facility Is not complying with applicable standards or
            requirements, or will pose a specific threat to human
            health or the environment if the post-closure care
            period is not extended; or
            If the request is to reduce the time period, the peti-
            tion may demonstrate that:  the material is no longer
            hazardous either because it has been removed or trans-
            formed; the control system is adequate in the absence
            of specific care measures; or the facility poses no
            threat even if containment should prove less than
            ideal.
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     When considering an extension to the post-closure care period  or
responding to such a petition, the Regional Administrator has the
following options:

     1.  He may extend the post-closure care period for a specified
period of time, which is at his discretion, with the possi*>L.li±y of
further extensions.  This extension must be justified by either evidence
that the facility has not complied with standards or requirements,,  or
specific identification of the possible threats to human health or  the
environment which make this extension necessary.

     2.  The Regional Administrator may choose not to extend the period
of care and/or deny a petition for this purpose if no one has adequately
demonstrated that the facility is not in compliance or there is inade-
quate proof that the facility would pose a threat to human health and
the environment if the post-closure care period were not extended.

     The Regional Administrator may respond to a request for a reduction
in care requirements during the 30-year period in ona of the following;
ways:

     1.  He may grant a temporary or experimental alteration of require-
ments.  No change in the cost estimate or financial responsibility
requirements would be required, but it must be demonstrated that a
temporary stay would not pose a threat to human health or the
environment.

     2.  The Regional Administrator may grant a permanent alteration  to
post-closure care requirements.   In this case, the post-closure cost
estimate and resulting post-closure financial responsibility would  have
to be changed and accompanied by  evidence that the alteration would not
result  in a  threat to human health or the environment.
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     3.  The request  could  he rejected on the grounds that  inadequate
proof had been offered  to demonstrate that the proposed alteration
provided adequate  protection to human health and the environment.

     It should he  noted  that in all cases it is the petitioner that  must
demonstrate that the  proposed alterations, including a reduction in  care
requirements and a reduction in the time  period, do not increase the
threat to human health  and  the environment.
                                                             yo- 1992
                                                             SW-912
  U.S. Environmental Protection Agency
  Region 5, Library (PL-12J)
  77 West Jackson Boulevard, 12th Ftonr
  Chicago, IL  60604-3590
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