United States        Office of Solid Waste     SW-968
            Environmental Protection    and Emergency Response    October 1983
            Agency          Washington DC 20460


            Solid Waste
»EPA      Permit Applicants'
            Guidance Manual for the
            General Facility Standards of
            40 CFR 264

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      PERMIT APPLICANT'S GUIDANCE

    MANUAL FOR THE GENERAL FACILITY

        STANDARDS OF 40 CFR 264
     This publication (SW-968) was
prepared for the Office of Solid Waste
     under contract no. 68-02-3168.


             Final Report
                          SU -
 U.S. ENVIRONMENTAL PROTECTION AGENCY
                 1983

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                                   DISCLAIMER
     This Final Report was furnished to the Environmental  Protection Agency by
the GCA Corporation,  GCA/Technology Division,  Bedford,  Massachusetts 01730, in
fulfillment of Contract No. 68-02-3168, Assignment No.  95-(3).   The opinions,
findings, and conclusions expressed are based on the best  information
currently available.   As new data and information are obtained,  the manual may
be revised to reflect that situation.  Mention of company  or product names is
not to be considered as an endorsement by the Environmental Protection Agency.
                                       11

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                             ACKNOWLEDGMENTS
     The authors, Stephen V.  Capone, Charles W.  Young, Nancy H.  Krusell,
John P. Patinskas, Arlene W.  Levin, and Barbara J.  Bosy, express their
appreciation to several key people at the EPA,  Office of Solid Waste who
provided valuable guidance and assistance in the preparation of this report.
They include the Project Officer, Mr. Jon R. Perry; our technical contact,
Ms. Melissa Friedland; and Mr. Arthur Day.  Others  who provided assistance
are Tony Baney, Dan Derkics,  David Friedman, Terry  Grogan, Myles Morse,  and
Florence Richardson.  We would also like to acknowledge the useful assistance
and information provided to us by Messrs. Dick Boynton and Rich Cavagnero
of EPA, Region I.  Others at GCA who assisted in preparation of this document
include Messrs. Thomas Fitzgerald, Brian Hobbs,  Michael Kravitt, Patrick Ford,
Douglas Seely, and the staff of our Technical Publications Department.
                                  iii

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                                    CONTENTS
Section

  1.0     INTRODUCTION

          1.1   Purpose
          1.2   Provisions of the Manual
          1.3   Organization of the Manual
          1.4   Other Guidance Manuals
          1.5   Procedures for Updating and Revising

  2.0     THE LAW                                                         2-1

          2.1   Introduction                                              2-1
          2.2   The Federal Register                                      2-4
          2.3   The Code of Federal Regulations                           2-8
          2.4   Availability of Copies                                    2-10

  3.0     THE PERMITTING PROCESS                                          3-1

          3.1   Introduction                                              3-1
          3.2   The Permit Application and the Permit                     3-2
          3.3   Where to Submit Applications                              3-2
          3.4   Confidentiality                                           3-2
          3.5   Appeals                                                   3-6

  4.0     OVERVIEW OF PARTS 270 AND 264 AND USEFUL  INFORMATION  SOURCES    4-1

          4.1   Introduction                                              4-1
          4.2   Overview of Parts 270 and 264                             4-1
          4.3   Information Sources                                       4-2
                4.3.1   Documents/Reports                                 4-2
                4.3.2   Regional EPA Offices and  State  Offices            4-5
          4.4   References                                                4-5

  5.0     GUIDANCE FOR PERMIT APPLICATION PREPARATION                     5-1

          5.1   Facility Description                                      5-3
                5.1.1   Regulatory Citations                              5-3
                5.1.2   Guidance to Achieve the Standards                 5-3
                5.1.3   List of Major Points                              5-3
          5.2   Chemical and Physical Analyses of Hazardous  Waste         5-4
                5.2.1   Regulatory Citations                              5-4
                5.2.2   Guidance to Achieve the Part 264 Standards        5-4
                5.2.3   List of Major Points                              5-7
          5.3   Waste Analysis Plans                                      5-8
                5.3.1   Regulatory Citations                              5-8
                5.3.2   Guidance to Achieve the Part 264 Standards        5-9

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                              CONTENTS (continued)
Section
                5.3.3   Guidance for Preparation of Waste Analysis Plans
                          for All Facilities
                5.3.4   Guidance for Preparation of Waste Analysis Plans
                          for Offsite Facilities
                5.3.5   Guidance on Preparing Waste Analysis Plans for
                          Specific Facility Types
                5.3.6   Waste Analysis Plan Examples
                5.3.7   List of Major Points
                5.3.8   References
          5.4   Security
                5.4.1   Regulatory Citations
                5.4.2   Guidance to Achieve the Part 264 Standards
                5.4.3   List of Major Points
          5.5   Inspections
                5.5.1   Regulatory Citations
                5.5.2   Guidance to Achieve the Part 264 Standards
                5.5.3   List of Major Points
                5.5.4   References
          5.6   Preparedness and Prevention
                5.6.1   Regulatory Citations
                5.6.2   Guidance to Achieve the Part 264 Standards
                5.6.3   List of Major Points
          5.7   Contingency Plan and Emergency Procedures
                5.7.1   Regulatory Citations
                5.7.2   Guidance to Achieve the Part 264 Standards
                5.7.3   List of Major Points
          5.8   General Hazard Prevention
                5.8.1   Regulatory Citations
                5.8.2   Guidance to Achieve the Part 264 Standards
                5.8.3   List of Major Points
          5.9   Prevention of Ignition or Reaction of Wastes
          5.10
          5.11
           5.12
5.9.1
5.9.2
5.9.3
Traffic
5.10.1
5.10.2
5.10.3
                        Regulatory Citations
                        Guidance to Achieve the  Part  264  Standards
                        List of Major Points
        Regulatory Citations
        Guidance to Achieve the Standards
        List of Major Points
Location Information
5.11.1  Regulatory Citations
5.11.2  Guidance to Achieve the Part 264 Standards
5.11.3  References
Personnel Training
5.12.1  Regulatory Citations
5.12.2  Guidance to Achieve the Part 264 Standards
5.12.3  List of Major Points
5-11

5-19

5-2.0
5-4-0
5-58
5-65
5-66
5-66
5-67
5-73
5-74
5-74
5-75
5-96
5-96
5-97
5-97
5-99
5-107
5-108
5-108
5-111
5-124
5-125
5-125
5-125
5-127
5-128
5-128
5-129
5-134
5-136
5-136
5-136
5-138
5-139
5-139
5-141
5-162
5-163
5-163
5-164
5-169
                                  VI

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                              CONTENTS (continued)
Section                                                                   Pag(

          5.13  Topographic Map Requirements                              5-1
                5.13.1  Regulatory Citations                              5-1
                5.13.2  Obtaining Topographic Maps                        5-1
                5.13.3  Topographic Map Features                          5-1
                5.13.4  Obtaining Climatological  Information              5-1
                5.13.5  Flood Plain Area Maps                             5-1
                5.13.6  Other Required Information                        5-1
                5.13.7  List of Major Points                              5-1
          5.14  Manifest System, Recordkeeping, and  Reporting             5-1
                5.14.1  Regulatory Citations                              5-1
                5.14.2  Guidance to Achieve the Part  264  Standards        5-li
                5.14.3  List of Major Points                              5-1!

  6.0     COMPLETENESS CHECKLIST                                          6-1

Appendices

   A      FEDERAL AND STATE AGENCY ADDRESSES AND  TELEPHONE  NUMBERS        A-l
   B      SYNOPSIS OF TECHNICAL REPORTS                                   B-l
   C      ADDRESSES OF GEOLOGICAL AGENCIES                                C-l
   D      AERIAL PHOTOGRAPHS                                              D-l
   E      AERIAL RECONNAISSANCE FLIGHT PLANNING                           E-l
   F      QUALITY ASSURANCE/QUALITY CONTROL                               F-l
                                  VII

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                                     FIGURES







Number




 3-1      Flow diagram of the EPA's RCRA permitting process




 5-1      Example waste characterization scheme




 5-2      Sequence of procedure sets designed by Acurex




 5~3      Seismic standard requirements




 5-4      Floodplain location requirements




 5-5      Site located on 100-year  floodplain




 5-6      Sample (JSGS map order form
Page




3-3




5-28




5-32




5-143




5-152




5-155




5-174
                                  vi 11

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                                     TABLES
Number                                                                      Page
 2-1      The RCRA Table of Contents                                        2-2

 2-2      Example Federal Register Notice                                   2-5

 2-3      Parts of Title 40 of the CFR Regarding Permitting and
            Hazardous Waste Handling and Disposal                           2-9

 3-1      EPA Regional Hazardous Waste Program Offices                      3-4

 5-1      Sections of Parts 270 and 264 Addressed in This Manual            5-2

 5-2      Example Waste Characterization Data for a Waste Received  at
            an Offsite Solvent Recovery Plant                               5-6

 5-3      Sampling Equipment for Particular Waste Types                     5-17

 5-4      Sampling Requirements to Adequately Characterize Waste
            Movements                                                       5-24

 5-5      Reactivity Group Definitions                                      5-29

 5-6      Procedure Sets for Classifying Hazardous Wastes by  Reactivity
            Group Number                                                    5-31

 5-7      Objectives of the Waste Analysis Plan Based on General  and
            Specific Regulations                                            5-33

 5-8      Summary of Specific Requirements for Waste Analysis  Noted in
            Subparts 1 Through N                                            5-39

 5-9      Disposition of Major Classes of Wastes Received Onsite            5-42

 5-10     Analytical Parameters Selected for Given Waste Classifications    5-43

 5-11     Summary of Waste Survey Analysis                                  5-4t>

 5-12     Definition of Sample Types for Analysis of Fingerprint
            Parameters                                                      5-50

 5-13     Results of Initial Analysis of Pharmaceutical Waste               5-51

 5-14     Criteria for a Determination of Exemption                         5-72

 5-15     Equipment, Structures, Areas to be Considered for  Inclusion
            in an Inspection Schedule                                       5-77
                                   IX

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                               TABLES (continued)


Number                                                                     Page

 5-16     Example Raw Material Inspection Form                             5-87

 5-17     Example Items for Surface Impoundment  Inspection Plan            5-88

 5-18     Example List of Items for an Inspection Plan for an Operating
            Surface Impoundment                                            5-90

 5-19     Example List of Items for an Inspection Plan for an Operating
            Waste Pile                                                     5-93

 5-20     Sample Table of Contents for a Contingency  Plan                  5-114

 5-21     Emergency Coordinators List                                      5-117

 5-22     Emergency Evacuation Procedures                                  5-119

 5-23     Appendix VI Political Jurisdictions                              5-144

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                                1.0   INTRODUCTION
1.1  PURPOSE

     This manual is intended for use by owners and operators of existing and
new hazardous waste management facilities who are required to submit Part B of
their permit applications to illustrate compliance with the standards of
40 CFR 264.""  If you are currently operating an existing facility under
interim status (40 CFR 265), you will have submitted Part A of your
application.  Owners and operators of new facilities must submit Parts A and B
together.

     The Part 264 standards have been adopted under the Resource Conservation
and Recovery Act and will be used by the EPA to issue permits to facilities
that treat, store, or dispose of hazardous waste.  The standards identify
general requirements that all hazardous waste management facilities must meet.
and specific requirements applicable to specific types of facilities.  This
manual presents guidance on methods that you should use in preparing your
Part B permit application to demonstrate compliance with the general
requirements of 40 CFR 264 listed in Subparts A through E of that Part.  The
guidance is applicable to owners and operators of facilities regulated under
40 CFR 264, namely; tanks, containers, surface impoundments, waste piles, land
treatment facilities, and landfills.  Although much of the guidance is
applicable to hazardous waste incinerators, it is not the primary intent of
this manual to address application requirements for incinerators.  A separate
manual on permitting of incinerators is available through the EPA Regional
Offices and is entitled:  "The Guidance Manual for Hazardous Waste Incinerator
Permits,"  (July 1983).

1.2  PROVISIONS OF THE MANUAL

     The information which you are required to submit in the Part B permit
application to demonstrate compliance with the land disposal standards is
stipulated in 40 CFR 270 which establishes the requirements of the EPA's
permit program for hazardous waste management facilities.  The general
information requirements which you must address are contained in §270.14(b) of
that Part.  The information required under that section includes:

     (1)  general facility description

     (2)  chemical and physical analysis of hazardous wastes to be handled

     (3)  waste analysis plan
*If you are unfamiliar with RCRA and associated regulations and/or conventions
 used for referencing them, it is suggested that you refer to Sections 2.0 and
 3.0 of this manual for a full explanation.
                                      1-1

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     (4)   security  procedures

     (5)   inspection plans

     (6)   plans  for preparedness  and  prevention

     (7)   contingency plans

     (8)   procedures and  equipment  to prevent  or  mitigate  hazards

     (9)   precautions taken  to prevent ignition or  reaction  of  wastes

     (10)  planned traffic patterns

     (11)  facility  location  information

     (12)  training  programs

     (13)  facility  closure  plans

     (14)  facility  deed documentation

     (15)  closure cost estimates  and  financial assurances

     (16)  post-closure cost  estimates and financial assurances

     (17)  insurance policies

     (18)  coverage  by State  financial mechanisms

     (19)  topographic map for  the facility and environs.

     In this manual, guidance  is  provided to illustrate means of addressing
the first  12 information  requirements as well  as  the 19th, topographic map
information.  Each  of the 13 information requirements is addressed
individually.  For  each one, the  information presented includes the applicable
regulatory citations, guidance on achieving the  information requirements and
referenced standards, examples of suitable application information, and major
points to  address in preparing your application.   Guidance on the manifest
requirements noted  in Subpart  E of Part 264 is also provided.

     Although the guidance noted  above is the  main intent  of this manual,
introductory and background  information is also  included to provide better
understanding of the regulations  and  the permitting process.  Several
appendices which augment  the information in the  main text  are also included.
If you prepare your application in conformance with the guidance presented
here on the general information requirements,  it  will, at  a minimum, expedite
agency review of your application,  and should  markedly improve the likelihood
of being granted a  permit.
                                        1-2

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1.3  ORGANIZATION OF THE MANUAL

     Introductory Sections 2.0 and 3.0 explain the Resource Conservation and
Recovery Act (RCRA), regulations implemented under RCRA,  format and use of the
Federal Register, and the RCRA permitting process employed by EPA.   In
Section 4.0, we discuss useful sources of information that will assist you in
preparing your application and provide an overview of the requirements of
40 CFR Parts 264, 265,  and 270.  If you are unfamiliar with any of  the noted
topics, these sections  are essential reading before proceeding to the guidance
presented in Section 5.0.

     As noted, you should use the guidance on procedures  and methods in
Section 5.0 to prepare  those parts of your Part B application which support
the information requirements of §270.14(b), paragraphs (1) through  (12) and
(19).  Each information requirement is addressed separately in a subsection of
Section 5.0.

     Six appendices are included at the end of the manual to provide
supplementary information such as names and addresses of  state and  federal
regulatory agencies, and locations where you can request  pertinent
documentation, reports, and maps.  Other appendix information of a  more
technical nature is also included.

1.4  OTHER GUIDANCE MANUALS

     Several other guidance manuals exist or are in preparation and will be of
use to you in preparing your overall Part B permit application.  These include
RCRA guidance manuals published with the Part 264 standards in July 1982; a
series of Technical Resource Documents which have been prepared over the last
5 years, and other guidance manuals specific to preparing permit applications
in support of the land  disposal regulations and specific  subparts of those
regulations.  Section 4.0 and Appendices A and B provide  a list of  pertinent
documents, locations where they can be reviewed or purchased, and a synopsis
of each document.  It is recommended that you become familiar with  the
available literature, because in total, this body of information will be of
great assistance in preparing a permit application.

1.5  PROCEDURES FOR UPDATING AND REVISING THIS MANUAL

     This manual is published in loose leaf format to allow for future
updating or revision.  When you receive your copy, your name will be kept on
file and the Agency will notify you of the availability of new or amended
pages for incorporation into the manual.
                                      1-J

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                                  2.0  THE LAW
2.1  INTRODUCTION

     In 1976, the Resource Conservation and Recovery Act was passed by the
Congress to regulate the handling and disposal of hazardous waste.  That act,
widely known by the acronym RCRA, mandated the development of regulations
governing the actions of owners or operators who generate, transport,  treat,
store, or dispose of solid wastes.  Although most readers of this guidance
manual will be aware of RCRA because of the extensive regulations developed
under its authority governing hazardous waste, the Act, in fact, addresses all
solid wastes.

     The Congress passed a second Act which addresses the problems associated
with the handling and disposal of solid wastes, especially hazardous wastes.
The "Comprehensive Environmental Response, Compensation, and Liability Act of
1980" (CERCLA) is the Act that established the "Superfund" (called the
Hazardous Substance Response Trust Fund in the Act).  This Act, in general,
addresses the release, or imminent release, of hazardous substances to the
environment  and the established mechanisms for responding to those releases
and assessing liabilities.  As such, Superfund is not applicable to permitting
of hazardous waste management  facilities.

     The complete texts of RCRA and its associated amendments are too long for
inclusion in this document.  The end of this section includes information on
where interested parties may obtain copies of the Act and other related laws
and regulations.  Additionally, regulatory citations are  included in
Section 5.0  to help define the permit application information requirements.

     RCRA, as amended by tne Quiet Communities Act of 1978, the Used Oil
Recycling Act of 1980, and the Solid Waste Disposal Act Amendments of 1980,
is, itself,  an amendment of Title II of the Solid Waste Disposal Act.  The
beginning of the Act and its Table of Contents are shown  in Table 2-1.

     As Table 2-1 shows, RCRA  consists of eight parts, called Subtitles,
identified as A through H.  Each Subtitle contains parts called Sections which
are numbered consecutively within each Subtitle.  Table 2-1 is actually a
reproduction of Section 1001 of Subtitle A of the Act.

     "Subtitle C—Hazardous Waste Management" incorporates 13 sections which
serve as the basis  for the development of the hazardous waste regulations
which have been promulgated by the EPA.  Subtitle C states what the EPA must
do to govern hazardous waste handling and disposal and provides the EPA with
the authority to carry out the provisions of the Act.  Specifically,  the
various Sections of Subtitle C of RCRA state that "the Administrator* .  .  .
shall promulgate regulations  .  .  ."  Thus, the Legislative Branch passed a  Law
^Defined  in  Section  1004 of Subtitle A of RCRA as "the Administrator of the
  Environmental Protection Agency."

                                      2-1

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             TABLE  2-1.    THE  RCRA  TABLE OF  CONTENTS
                 RESOURCE  CONSERVATION  AND RECOVERY AC I  OF I97o,

   As  Amended  by  the  Quiet  Communities  Act of 1978, tne  I'sed Oil  Recycling Act
           at  I960  and  the  Solid  Waste  Disposal Act Amendment.-, ot 1981)

                                     Ail Act

                                   Short  Title

Section 1.  This Act may be cited as the  "Resource  Conservation  and  Recovery
Act of 1976"

                     AMENDMENT OF  SOLID  WASTE  DISPOSAL  AC 1

Section 2.  The Solid Waste Disposal Act  (-t2 U . b>. C .  i2ll  and  following)  is
amended to rejd as follows.

                        T1LLE  11 -  SOLID WASTE DISPOSAL

                        "Subtitle  A--General Provisions

                       "Short  Title and  Table ot contents

     "Sec. 1001.   This  title (hereinafter  in tins  title  referred  to  as   this
Act1), together with the following  table  ot  contents, may be  cited as  the
'Solid Waste Disposal Act1:

                        "Subtitle  A-~General Provisions

"Sec.  1001.    Short title and table ot contents.
"Sec.  1002.    Congressional findings.
"Sec.  1003.    Objectives.
"Sec.  1004.    Definitions.
"Sec.  1005.    Governmental cooperation.
"Sec.  1006.    Application ot  Act and  integration  with  other  Acts.
"Sec.  1007.    Financial disclosure.
"Sec.  1008.    Solid waste management  information  and guidelines.

       "Subtitle--0lfice of Solid Waste;  Authorities  ot  the Administrator

"Sec.  2001.    Office ot Solid Waste and  Tnteragency  Coordinating  Committee.
"Sec.  2002.    Authorities of  Administrator.
"Sec.  200j.    Resource recovery  and conservation  panels.
"Sec.  2004.    Grants for  discarded tire  disposal.
"Sec.  200r>.    Labeling of certain oil.
"Sec.  2006.    Annual report.
"Sec.  2007.    General  authorization.

                     "Subtitle  C—Hazardous Waste Management

"Sec.  3001.    Identification and listing  of hazardous  waste.
"Sec.  3002.    Standards applicable to generators  of  hazardous waste.
"Sec.  3003.    Standards applicable to transporters  of  hazardous  waste.
"Sec.  3004.    Standards applicable to owners and  operators ot hazardous waste
               treatment,  storage,  and disposal  facilities.
"Sec.  3005.    Permits  for treatment,  storage, or  disposal  of hazardous  waste.
"Sec.  3006.    Authorized  State  hazardous  waste  programs.
"Sec.  3007.    Inspections.
"Sec.  3008.    Federal  enforcement.
"Sec.  3009.    Retention of State authority.
"Sec.  3010.    Effective date.
"Sec.  3011.    Authorization of  assistance to  States.
"Sec.  3012.    Restrictions on recycled oil.
"Sec.  3013.    Monitoring, analysis, and  testing.
                                   (continued)
                                       2-2

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                           TABLE  2-1  (continued)
                        « h  o t  subc 11ie -
                Federal guidt-Unefa  lor  plans.
                Min.j_[iumi reqiu re me ill s  for  ap prova i  ;jl  p id as .
                (,r L t e r L a  lor »tip. 11 d ry  i and i i 1 Is ,  s ;m i l. a ry 1 a nil t 1.1 i ^ requ L rr d
                tor all d i i> p o ,s a I. .
"Sue , 400^>.     Upgrad ing  o t open  dumps ,
"but. , 4UOO .     Procedure  lor  dtf ve 1 opiwnt  and imp 1 rim1 iU at ton oi  State p Idn .
"Sec , AOU ? .     Approva i  ol btatr  plan ,  Fed era L  a^s i b Lajic e .
"Sec , 4 (JOB.     Fed era 1 a*js i s C dat, «j *

    "Subtitle !'--Duties  ot  tf) spons i b i 1 t L i e s

"Sec . bUUl.     Apj) i i t-dl ion ui Fed« i ,* I -,  State, and  IOL a 1 idw Co  Federa 1
                tac i L it it* & ,
"Sft . 6UU2.     Federal promrfp.K-nL .
                Loupe r  •
                i.oord i nat- Lon ,  co 1 ie^ L i on ,  and d i s^euutn* 1 1 on ot  i, nt oncia t i on .
                Ki 1 1 ?»ca Le  d«ti'»uust r at ion  1 at 1 1 1 1 it; s .
                Spt'i ia 1  •> C udy  and detiionsL ra L ion projects  on ret ove ry  ot  use t LI 1
                •' ne rje;y and  matt rials,
                (/rant s tor  re cove E y ;-, y b t ems  and improved  solid  was t e  disposal
                t dc i 1 1 1 i e s .
                Ant ho r i 2 a 1 1 on  o i ,ap p r op r i. a t L ;ms .
                                            2-3

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requiring the Executive Branch to develop and implement regulations governing
hazardous waste.  This is done by publishing the regulations in the Federal
Register and subsequently incorporating them into the Code of Federal
Regulations.

2.2  THE FEDERAL REGISTER

     The Executive Branch implements the intentions of Laws passed by the
Legislative Branch by developing and enforcing Rules or Regulations.  RCRA
specifically required the EPA to promulgate those regulations only after
public notice, the opportunity for public hearings, and consultation with
appropriate Federal and State agencies.  The EPA meets these requirements by
publishing notices of its intentions to promulgate regulations in the Federal
Register.  Once promulgated, the regulations become part of the Code of
Federal Regulations (CFR).

     The Federal Register is published every business day by the Federal
Government.  It contains notices, announcements, and descriptions of the
activities of the Federal Government.

     In the process of implementing the Congress" intentions as contained in
RCRA, the EPA developed regulations, published them in the Federal Register as
proposed regulations, received and reviewed comments on the proposed
regulations, revised the regulations as appropriate in light of the comments,
and  then published the final regulations in the Federal Register.  Thus, by
publishing in the Federal Register, the EPA announces its activities to the
public a minimum of twice; once via a Notice of Proposed Rulemaking (NPR) and
once by publishing the final, promulgated rule.*  This is the general
rulemaking procedure  followed by the EPA.  However, because of the complexity
of the hazardous waste regulation development efforts, the EPA made numerous
other announcements in the Federal Register in addition to the proposed and
final rule announcements.

     A list and description of all the types of Notices that EPA published in
the  Federal Register relative to the hazardous waste regulations is much too
lengthy and complex to serve any purpose in this document.  The EPA began
publishing notices regarding the hazardous waste regulations in 1978 and
announcements regarding  those regulations continue  to appear regularly  in  the
Federal Register.  The types of Notices that are likely to be of most value to
readers of  this manual are Proposed Rules, Final Rules, and Amendments  to
Rules.  The format and purpose of these Notice types are discussed here.

     A Federal  Register  Notice of Proposed, Final,  or Amended Rules will
always be  in  a  format that consists of three major  parts; heading, preamble,
and  text.   Table 2-2  is  a photocopy of two pages of an actual multiple-page
Federal Register Notice.  The part of  that Notice designated by a  (1) is the
heading,  by a  (2)  is  the preamble, and by a (3)  is  the text of the actual  rule
 *A  regulation  is  "promulgated" when  it  is  published  as  a  Final  Rule  in  ttu
  Federal  Register.

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      5872
   TABLE  2-2.    EXAMPLE  FEDERAL  REGISTER NOTICE

Federal Register / Vol. 48, No. 27 / Tuesday, February 8, 1983 / Proposed Rules
     ENVIRONMENTAL PROTECTION
     AGENCY

     40 CFR Part* 122,123 ami 264

     [SW FRL 2039-2]

     Hazardous Waste Management
     System; the Hazardous Waste Permit
     Program; Standards ApplicaM* to
     Owners and Operators of Hazardous
     Waste Management FacWHee

     AGENCY: Environmental Protection
     Agency.
   ^ACTION: Proposed ruie.
(T)
     SUMMARY: On February 26,1980 and
     May 19,1980, the Environmental
     Protection Agency (EPA) published
     regulations which established a system
     to manage hazardous waste. Those
     regulations provide that permits issued
     by EPA (and Slates with authorization to
     issue permits under the Resource
     Conservation and Recovery Act (RCRA)
     for hazardous waste treatment, storage
     and disposal facilities will be effective
     for a fixed term not lo exceed 10 y««rs
 authorized Slates have Untied
 opportunities for reopening a permit to
 make changes in permit conditions.
  EPA is today proposing to amend the
 regulations to provide that RCRA
 permits will be effective for the
 designated operetinyWe ef eeeh facility,
 and the period of post-eJoswe care fur
 land disposal facilities. Under this
 proposal B»A mmd authorised Status
 would have tenased opportunities for
 reopening permits during their terms.
 EPA is proposta* due chenfe in an effort
 to streainline the RCRA permitting
 procedure, reduce paperwork, and to
 respond to sertletMnt Msjottrttana IB a
 lawsuit iavoMs*j the RCRA regulation*.
  EPA anticipate* that protector of
 human health and the environment
 would not be affected by this section.
 EPA also estimates that this action
 would result in a savings to the
 regulated community of approximately
 (88.5 million if EPA promulgate* this
 rule and if States with authorization to
 issue RCRA permits elect to issue those
 permits effective for the designed
 operating life of each  facility plug the
 post-closure period.
 OATO: EPA will accept public
 comments on the proposed amendment
 until April 11.1983.
AMMUtts: Comments should be
 addressed to the Docket Clerk, Office of
Solid Waste (WH-562). US,
 Environmental Protection Agency,
Washington. D.C. 20480.
Communications should identify the
  regulatory docket number as "Section
  122.9—Duration of Permits".
    The public docket for this proposed
  rule is located in Room S-269C, U.S.
  Environmental Protection Agency, 401 M
  Street. SW, Washington, D.C., and is
  available for viewing from 9:00 a.m. to
  4:00 p.m. Monday through Friday
  excluding holidays.
  FOR FURTHER INFORMATION CONTACT:
  Amy Mills, Office of Solid Waste (WH-
  S63). U.S. Environmental Protection
  Agency, Washington, D.C. 20460, or call
  [202] 382-4755. or the RCRA Hotline at
  (800) 424-9348 or (202) 382-3000.
  SUfVLEMtNTAMY MFOMMATION:
  I. Background
    On February 28.1080 and May 10.
  I960, EPA promulgated regsdettona
  pursuant to the Solid Wasta Disposal
  Act as amended by the Resource
  Conservation and Recovery Act ef 1B78
  (RCRA). as amended, 42 U.S.C W01 et
  seq. The regulations establish a system
  to manage hazardous waste, and Include
  provisions under which EPA issaes
.  permits to owners or operators of
  facilities that treat, store or dispose of
  baxaidoua wasta (40 CFR Part 122.45 FR
  33418).' Section 122.9 of those
  regulations specifies that permits Issued
  to hazardous waste management
  facilities will be effective for a fixed
  term of 10 years or less. At the end of
  each permit term, the permittee Bust
  apply for and receive a new permit if he
  plans to continue his operation. The
  purpose of this requirement is to assure
  changes ia regulation* or available
  technology are integrated into permits
  on a periodic basis.
    The May 19 rule also contains a
  provision which gives EPA the
  opportunity to revise permit conditions
  daring tha term of the permit (1122,15).
  For noat of the allowable causes for
  permit modification*. EPA may knlttataj a
  change with or without the consent of
  the permittee (| 122.1S(a) (1), (2), and (5)
  and 122.l5(b)). However, in an attempt
  to provide permittees with greater
  certainty during the terms of their
  permits, the May 19 regulations limited
  the  cause for permit modifications
  resulting from changes to EPA
  reguiationg lo instances when
                                              ' The RCRA permitting requirement* are
                                            contained in EPA • coraalldeted permit
                                            angfnallir promulgated on May II, 1MO and codified
                                            In 40 CFR Peru 122-124 Theee refutation* b*v*
                                            been continuously eupplemented and amended The
                                            moat Important amendroenta occurred on (Miury
                                            12. IBM, when EPA promulgated permitting
                                            regulation! for aforagt and treatment faciltttea (4S
                                            FR 2S02). on (inuary a 1«S1. whan EPA
                                            promulgated permitting refulatioiie for tadaMnton
                                            {« Fl TtSt). and July 29.1SSZ. wben EPA
                                            promulgated parmtling ragulaliona for land dta explanation of tha procedural
                                                             •«MCU of the NKX r gPA anil. CM the preamble
                                                             *• the technical amendment* lo «0 CPU Part* 122
                                                             aad U4 In the April s, tosz FedateJ rrglilii (4? FR
                                                             ISSM;
                                                           2-5

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5876
                           TABLE  2-2  (continued)
Federal  Register / Vol. 48, No.  27  / Tuesday, February 8, 1983  /  Proposed Rules
years or less. The Agency believes that
this is not the type of regulation revision
that Congress had in mind when it
provided a delay between the
promulgation and the effective date of
revisions to regulations. Therefore, the
Agency plans to make these
amendments effective immediately if
and when they are promulgated in final
form, but requests comments on whether
such action would cause hardship for
the regulated community or otherwise
be inappropriate.
Compliance With Executive Order 12291
  Under Executive Order 12291, EPA
must judge whether a regulation is
"major" and therefore subject to the
requirement of a Regulatory Impact
Analysis. This proposed regulation is
not major because it will not result in an
effect on the economy of $100 million or
more, nor will it result in an increase in
costs or prices to industry. There would
be no adverse impact on the ability  of
U.S.-based enterprises to compete with
foreign-based enterprises in domestic or
export markets. Because this
amendment is not a major regulation, no
Regulatory Impact Analysis is being
conducted.
  These amendments were submitted to
the Office of Management and Budget
for review as required by Executive
Order 12291. Any comments from OMB
to EPA and any response to those
comments are available for viewing at
the Office of Solid Waste docket. Room
S-269C, U.S. E.P.A., 401 M St. SW,
Washington, O.C. 20460.
President's Task Force on Regulatory
ReUef
                         Regulatory Flexibility Act

                          Under the Regulatory Flexibility Ai,i. 5
                         U.S.C. 601 et seij.. Federal agencies must
                         prepare a regulatory flexibility anHlysis
                         for all proposed rules to assess their
                         impact on small entities No regulatory
                         flexibility analysis is required, however.
                         where the head of the agency certifies
                         that the rule will not have a significant
                         economic impact on a substantial
                         number of small entities.
                          The economic impact of this
                         regulation would be to reduce the costs
                         of complying with EPA's hazardous
                         waste management regulations for
                         owners and operators of hazardous
                         waste management facilities (including
                         those which are small entities).
                         Accordingly, I hereby certify, pursuant
                         to 5 U.S.C. 601(b), that this proposed rule
                         would not have a significant economic
                         impact on a substantial number of small
                         entities.

                         List of Subjects

                         40 CFR Part 122

                          Administrative practice and
                         procedure, Air pollution control.
                         Confidential business information,
                         Hazardous materials, Reporting and
                         recordkeeping requirements. Waste
                         treatment and disposal, Water pollution
                         control, Water supply.

                         40 CFR Part 123
  The President's Task Force on       <
Regulatory Relief designated the
Consolidated Permit Regulations (40   '
CFR Parts 122-124) for review by EPA.  «
This proposal supports the goals of the '
Task force by reducing burden on the
regulated community,This proposal also
fulfills EPA's obligations in the
settlement of industry litigation on the
Consolidated Permit Regulations. In
addition to settling the litigation, the
Agency also plans to:
  • Propose other jubstantive changes
to further streamline the Agency's
permitting process, and
  • Deconsolidate the regulations  to
make them more easily usable by the
public.
As a result of deconsolidation, there wil
be some reorganization of the
regulations. Thus, this proposed
amendment may be finalized in a
different format and location than it
appears in the current regulations and
the settlement agreement.
     V S C 1251 et sn/. Clean Air Acl 42 LI S C
     1857 rl SCQ
      2  Section 122 9 is amended by
     revising paragraphs (b) and (e) to rend
     .'is fallows:

     § 122.9  Duration of permits.

      (b) RCRA. Except as provided in
     paragraph (e) of this section and
     § 122 30, RCRA permits shall be
     effective for the fixed term of the
     designed operating life of the facility |m
     the case of an new facility) or the
     remainder of the designed operating life
     of the facility (in the case of an existing
     facility}. For land disposal facilities, the
     term of RCRA permits shall include the
     post-closure care period or compliance
     period,  whichever is longer, in addition
     to the designed operating life of the
     facility. The designed operating life of
     the facility is the period of time,
     estimated by the owner or operator and
     approved by EPA, for which the facility
     is designed to operate, and during which
     operation is expected to continue. The
     estimate should reflect consideration of
     the construction materials of the facility,
     the volume and type of waste the facility
     expects to handle, and the processes the
     facility will employ.
                          Confidential business information,
                         Hazardous materials. Indian lands,
                         Intergovernmental relations; Penalties,
                         Reporting and recordkeeping
                         requirements, Waste treatment and
                         disposal, Water pollution control. Water
                         supply.
                         40 CFR Part 2S4                      !
                          Hazardous materials. Insurance.
                         packaging and containers, Reporting
                         and recordkeeping requirements,       _
                         Security measures. Surety bonds. Waste f
                         treatment and disposal.
                          Dated: January 28.198,1
                         Anne M. Gorsuch.
                         Administrator
       (e) The Regional Administrator may
     issue any NPDES, UIC or 404 permit for
     a duration that is less than the full
     allowable term under this section; for
     RCRA permits only, the Regional
     Administrator may issue a permit for a
f 2)duration that is less than the full
     allowable term under this section only
     when the permit applicant so requests.
       3. Section 122.15 is amended in
     paragraph (a)(3) by revising the
     introductory text and paragraph
     (a)(3)(i)(A) and adding paragraph
     |a)(7)(ix) to read as follows:
                           It is proposed that Title 40 of the Code
                         of Federal Regulations be amended as
                         follows:

                         PART 122—EPA ADMINISTERED
                         PERMIT PROGRAMS: THE
                          AZARDOUS WASTE PERMIT
                         PROGRAM

                           1. The authority citation for Part 122
                         reads as follows:
                           Authority: Resource Conservation Hnd
                         Recovery Act, as amended, (RCRA), 42 U.S C
                         6901 et seq.: Sate Drinking Water Act. 42
                         U.S.C. 300f et seq.: Clean Water Act. 3i
     §122.15  Modification or revocation and
     relMuanc* of permit*.
       (a)'  '  '
       (;i) New Regulations The standards or
     regulations on which the permit was
     based have been changed by
     promulgation of new or amended
     standards or regulations or by judicial
     decision after the permit was issued
    rPermits for RCRA facilities and UIC
     Class II or III wells may be modified
     (hiring their terms for this cause  without
     following the conditions of paragraphs
     |a)(3)(0 and (ii) of this section. All other
     permits may be modified for this cause
     only as follows:
       (i) For promulgation of amended
     standards or regulations, when.
       (A) The permit condition requested to
     be modified was based on a
                                                             2-6

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     The heading of the Notice supplies some identifying and descriptive
information.  As shown in Table 2-2,  this particular notice has been published
by the EPA, the regulations affected  by the Notice are identified (40 CFR
Parts 122, 123, and 264) and a descriptive title of the programs addressed is
provided  (Hazardous Waste Management  System; the Hazardous Waste .  . ,).
Importantly, the type of Notice is identified;  in this case, "Action:
Proposed  Rule".  The type of Notice can always  be identified by the phrase
next to "Action:" in the heading.   Other phrases typically used are:

          Final Rule
          Interim Final Rule
     -    Proposed Amendments
     -    Amendments to Final Rule
          Interim Final Amendments

Any phrase used in the heading of a Notice that contains the words  Rule or
Amendment and does not include the word Proposed, means that the Notice is
promulgating a new, or changed, regulation.  This is important since all
persons affected by the regulation in the Notice will have a finite time
period to comply with that regulation and that  time period often begins on the
date the  Notice is published in the Federal Register.  Proposed Rules and
Amendments are published to inform the public of their content and  these types
of Notices usually establish a time period during which the public  is invited
to comment on the Proposed Rules and Amendments.

     The  preamble of  the Notice contains a significant amount of information.
It begins with a  summary of the action being taken.  It will also contain
dates, addresses, and contacts  for additional information.  The major portion
of  the  preamble contains  information explaining  the  purpose and  intent of the
regulations, why  they are written as they  are,  who or what  they are  intended
to affect,  and other  information used  in  support of  and as  a basis  for  the
regulations.   The preamble  is  always written in  "non-regulatory" language and,
most jjuportantly, although  it  explains  the  intent of the  regulatory  language,
nothing  in  the preamble carries the force  of the law.

     As  shown  in  Table  2-2, the preamble will always conclude with  the date
and name  of  a  high-ranking  EPA official.   The preamble  is  then  followed by the
text of  the  actual  regulations as either  proposed or promulgated.   This part
of  the  Notice  is  very important because  it  contains  the regulations  as  they
will read when they become  effective after promulgation as  a  final  rule.  When
promulgated  they  become part of the Code of Federal  Regulations  (CFR) and
carry  the full  Eorce  of the law.

     A  discussion of  the organization  and  format of  the CFR follows.  However,
at  this  point  a description of the organization  of  the Federal_Reg i s ter will
assist  those who  wish to  locate any specific Notices pertaining  to  hazardous
waste which  have  been or will  be published.

     As  mentioned earlier  in this discussion, the Federal  Register  is
published every business day,  except Federal holidays, throughout  the year.
All of  these daily  documents are part  of  a  single "Volume"  of  the  F_ederal
                                       2-7

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Register for a specific calendar year.  For example, all of the daily issues
of the Federal Register published during 1983 are part of the "Volume 48 of
the Federal Register".  Volume 47 of the Federal Register is comprised of all
daily issues of 1982 and so on.

     Each volume of the Federal Register is consecutively page numbered and
each daily issue receives a consecutive number.   This numbering system is most
easily explained by reference to the example page from the Federal Register in
Table 2-2.  Across the top of that reproduced page is the following heading:

"5872 Federal Register/Vol. 48, No. 27/Tuesday,  February 8, 1983 Proposed Rules."

That heading indicates that the daily issue of the Federal Register from which
that page was copied was published on Tuesday, February 8, 1983; it is tVie
27th daily issue published in 1983; it is part of Volume 48 (the 1983 volume);
it is from the Proposed Rules section of that day's issue; and it is page
5872.  The accepted notation for identifying this page for reference purposes
is 48FR5872.  However, since that notation does not identify which daily issue
that page is contained in, the date is often included, i. e., 48FR5872
(2/8/83).  The use of this notation is exemplified in footnote 1 at the bottom
of the center column  in the example Federal Register page.

2.3  THE CODE OF FEDERAL REGULATIONS

     The Code of Federal Regulations, often denoted by the acronym CFR, is  the
compilation of all regulations in effect in the United States.  The full text
of every regulation promulgated by all Federal government agencies is included
in the CFR.

     The regulations  are grouped under "Titles" in the CFR and each Title  is
divided into "Chapters".  The hazardous waste regulations can be found in
"Title 40-Protection  of Environment,  Chapter I-Environmental Protection
Agency".  Title 40 is generally identified or annotated as "40 CFR".

     Each Chapter of  Title 40  is divided into numerous "Parts".  Each Part  is
further divided into  "Subparts".  The Subparts are comprised of "Sections"  and
each Section consists of numerous  "paragraphs".

     "Parts" of 40 CFR are always  identified by the word Part followed by  a
number  in Arabic numerals  i.e., Part  260.  The Parts  of a Chapter of a Title
are numbered consecutively within  the Chapter.  Parts are also identified  by
the notation 40 CFR 260.  That notation means "Part  260 of Title 40 of the
Code of Federal Regulations."  A list of the Parts  in Chapter I of Title 40
which deal with hazardous waste are  listed in Table  2-3.

     Each Part  is divided  into Subparts.  Subparts are identified by the word
Subpart  followed by an upper  case  alphabetic character,  i.e., Subpart A.   The
first Subpart of a  Part  is always  "A",  the second "B", and so on.  There can
be  as many  Subparts as necessary  in  a Part to properly organize and present
in formaton.
                                        2-8

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TABLE  2-3.   PARIS  OF  TITLh  40  OF  IHh  CFR REGARDING PERMITTING AND HAZARDOUS
             WASTE  HANDLING  AND DISPOSAL
Part
         Title
Notation
 261
 262
 263
 264
 265
 266

 267



 270


 271


 124
Hazardous Waste Management             40GFR260
  System:  General

Identification and Listing of          40GFR261
  Hazardous Waste

Standards Applicable to Generation     40CFR262
  of Hazardous Waste

Standards Applicable to                40GFR263
  Transporters of Hazardous Waste

Standards for Owners and Operators     40CFR264
  of Hazardous Waste Treatment,
  Storage, and Disposal Facilities

Interim Status Standards for Owners    40CFR265
  and Operators of Hazardous Waste
  Treatment, Storage, and Disposal
  Facili ties

Reserved                               40CFR266

Interim Standards for Owners and       40CFR267
  and Operators of New Hazardous
  Waste Land Disposal Facilities

EPA Administered Permit Programs:      40CFR270
The Hazardous Waste Permit Program

Requirements for Authorization of      40CFR271
State Hazardous Waste Programs

Procedures for Decisionmaking          40GFR124
                                      2-9

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     Each  Subpart  is  comprised of  Sections  which  are  designated  by  the  symbol
"§" followed by a  number  in  Arabic numerals,  i.e.,  §260.135.   The number which
follows the Section symbol always  has  .1 decimal  point.   The  Arabic  numerals  to
the left of the decimal point always  Identify the Part  that  the  Section is
included in and the Arabic numberals  to the right of  the decimal are a
consecutive series within each Part.   For example,  §264.15  is the  fifteenth
Section of Part 264 and §264.198 is the one-hundred and ninety-eighth Section
of Part 264.

     The numbering of Sections within  a Part has no correlation to  the  Subpart
Ln which the Section may appear.  For  example,  §261.30  is the thirtieth
Section of Part 261 and appears in Subpart  D of  Part  261, but §264.30 is the
thirtieth Section  of Part 264 and  it  appears in  Subpart C of Part  264.   As
noted above, Sections are numbered consecutively within each Part,  beginning,
for example, with  .§260.1 (the first Section of  Part 260), and proceeding to  as
high as §260.999.

     Within each Section, each and every paragraph  is identified by alphabetic
or numeric characters in outline format.  The outline format used  is:

     (a)           lower case alphabetic
       (1)         Arabic numerals
         (i)       lower case Roman numerals
           (A)     upper case alphabetic
              (1)   italic Arabic numerals

The outline  format is started  from the beginning in each Section.   The term
"Subparagrapt/'  is not used.  The designation §260.ll(a)(2)(iv)  is called
paragraph  (a)(2)(iv) of  Section 260.11.  The parentheses are always used in
paragraph  designation.

     In addition  to  Subparts,  a Part may have one  or more Appendices.  These
Appendices are  identified by either upper case alphabetic characters or upper
case Roman numerals  and  a title.   All  Appendices of  the  Parts listed in
Table  3 use  upper case Roman numerals,  i.e., Appendix  I  - Representative
Sampling Methods  (the  first  Appendix of  Part 261).  There is no formalized or
required organizational  format  for Appendices of a Part.  They  are organized
internally as  best suits  the material  each  contains.

2.4  AVAILABILITY OF COPIES

     Applicants may  find it  useful to  refer  to copies  of the Act (RCRA), the
Federal Register  (FR), and  the  Code of  Federal Regulations  (CFR).   These
documents  are  available  to  the  public  and  readers  of this manual are
encouraged to  obtain them.

     One  should start  by calling  the  RCRA  Hotline  in Washington, DC.   Guidance
is offered as  to  which documents  may be appropriate  and  which are currently
available.  Appendix A lists the  Hotline number.
                                       2-10

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     Copies of the RCRA might be obtained free of charge through the Regional
EPA offices.  Appendix A lists the addresses and telephone numbers  of the
branch of each Regional office which may be able to provide a copy  of the
Act.  As the authority for RCRA has been delegated to each state,  the
availability of these copies has become increasingly limited.

     State agencies may be another source where copies of RCRA may be obtained
free of charge.  The addresses and telephone numbers of the appropriate agency
in each state is given in Appendix A.

     Copies of the Act, the Federal Register, and the Code of Federal
Regulations may be purchased from the closest Governmental Printing Office
(CPO) bookstore.  A list of these has been provided in Appendix A.   The GPO
bookstores are the only available source of the FR and CFR to the public.
Should these documents be unavailable through the closest bookstore, they may
be ordered through the Superintendant of Documents office in Washington,  DC.

     In addition to the sources given in Appendix A, there are a variety of
locations where copies of these documents may be available.  The Regional EPA
library should have all documents pertinent to RCRA and many University and
Public libraries also have copies of these documents.  Many  large companies
subscribe to the Federal Register and might make copies available to smaller
businesses in their area.  The current  (1983) subscription cost for 1-year of
the Federal Register is $300.  Subscriptions are available from the GPO in
Washington, D.C.
                                      2-11

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                          3.0  THE PERMITTING PROCESS
3.1  INTRODUCTION

     There are two Parts of Title 40 of the  Code  of  Federal  Regulations  that
contain information on the RCRA permitting  process.   Part  270 contains
information on what an applicant and the EPA must do regarding a  permit.   That
Part contains basic permitting requirements  for EPA-administered  RCRA
programs, such as application requirements,  standard permit  conditions,  and
monitoring and reporting requirements.   Part 124 establishes the
decisionmaking procedures for EPA issuance  of RCRA permits.   That Part  also
establishes the procedures for administrative appeals of EPA permit  decisions.

     This section of the manual presents a  simplified description of the  major
steps that must be taken by both an applicant and the EPA during  the RCRA
permitting procedure.  It also identifies those Parts of Title 40 that  are
of importance to an owner or operator seeking a RCRA permit.

     The overall RCRA permitting process can be summarized into the  following
steps:

     Step 1.   The owner or operator of a hazardous waste management facility
               completes Parts A and B of a RCRA permit application  and
               submits the application to the appropriate EPA office.

     Step 2.   The EPA reviews the application for completeness.   If
               incomplete, the EPA sends a list of deficiencies,  in  writing,
               to the applicant.  If complete, the applicant is so informed  in
               writing.

     Step 3.   When  necessary, the applicant prepares and submits the
               additional information requested.

     Step 4.   If not done in Step  2,  the EPA reviews original and additional
               submittals and notifies the applicant in writing of the
               completeness  of the application.  The date that the EPA makes
               this  notification  is  the effective date of the application.

     Step 5.   The EPA  reviews the application and either prepares a draft
               permit or  issues  a notice of  intent to deny  the application.
               In either  case, the EPA simultaneously prepares and  issues a
               statement  of  basis or a fact  sheet.

     Step 6.   The EPA  sends copies  of the documents in Step  5 to the
               applicant  and others, and simultaneously makes  a public notice
               that  they  have been  prepared.  The public notice will provide
               45 days  for public  (or  applicant) comment.
                                       3-1

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     Step 7.    If  at  the  time  of  public  notice,  or  at  any  time during  the 45
               day comment  period,  anyone,  including the EPA, requests  a
               public hearing,  one  will  be  scheduled and announced  a minumum
               of  30  days before  the  scheduled date.

     Step 8.    The EPA prepares and issues  a  final  permit  decision.

These eight steps  are a simplified  description.   The overall  process is
presented in more  detail  in Figure  3-1  and  a  full description of  the steps
which EPA mus t take after receiving a complete  RCRA permit application is
contained in Subpart  A of Part 124  in §§124.3 through  124.21.

3.2  THE PERMIT APPLICATION AND THE PERMIT

     The RCRA permit  application consists of  two parts;  a  Part A, which is  a
form requiring completion,  and a Part B, which  is not  a  form.  This manual  is
designed to assist applicants  in preparing  the  informational  submittal which
is the Part B of an application for a RCRA  permit.

     Part 270 of Title 40 of the CFR provides the informational  requirements
necessary for a complete RCRA permit application (Part A and  Part B).   All  of
the Sections of Subpart B of Part 270 should be read  and understood by any
owner or operator who is applying for a RCRA permit for  the first time.

     The actual permit will consist of written approval  of the  contents of  the
complete permit application.  It will require the applicant to  adhere  to all
statements made in the application and will also include conditions which must
be complied with  in addition to the application statements.  Applicants
interested in the types of conditions that  may be contained in  a permit are
referred to §270.30-"Conditions applicable  to all permits" and
§270.32-"Establishing permit conditions."

3.3  WHERE TO SUBMIT APPLICATIONS

     Table 3-1 lists the mailing addresses and the telephone  numbers  o IE the
EPA offices in each of the ten EPA Regions  where permit  applications  should be
submitted.  Personnel in these offices  should be contacted with any questions
that may arise during preparation of a  permit application.

     Many  states  have their own hazardous waste permitting program.  Their
programs may be in addition to or in lieu of the EPA RCRA program.   State
program  offices are  listed in Appendix  A.  Any applicant who is  unsure of
which agency an application should be submitted to should contact the  Regional
EPA office  (Table 3-1) for clarification.

3.4  CONFIDENTIALITY

     An  applicant may find it necessary, or may be required,  to include
confidential  information in an application.  All applicants are referred to
§270.12-"Confidentiality of information" in  Subpart B of Part 270.   Of
particular note are  the  items  in §270.12(b) which cannot be claimed as
conf idential.

                                        3-2

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UJ

UJ
                                            i r unia 3 IUNb
                                           OR DEFICIENCIES
                                          ARE NOTED, ISSUE
                                              NOTICE OF
                                             DEFICIENCY
                             EPA RECEIVES
                              AND LOGS IN
                               PART B
                             STATEMENT OF
                               BASIS OR
                              FACT SHEET
ADM I N I STRATI
   RECORD
VE
 PUBLIC NOTICE
   OF DRAFT
PERMIT, COMMENT
  PERIOD,  AND
    HEARING
  PUBLIC
 COMMENTS;
 REQUESTS
FOR PUBLIC
 HEARING
                                     NEW STATEMENT OF BASIS;  FACT SHEET;  OR  DRAFT  PERMIT
                                            AOMIN 1STRAT
                                                RECORD
                              PUBLIC
                             NOTICE OF
                              HEAR!NG;
                           EXTENSION  OF
                              COMMENT
                              PERIOD
                           Figure 3-1.   Flow diagram of the  EPA's RCRA permitting process

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            TABLE 3-1.   EPA REGIONAL HAZARDOUS WASTE PROGRAM OFFICES
Region I:
OFFICE OF THE DIRECTOR
State Waste Programs Branch
Waste Management Division
John F.  Kennedy Federal Building
Boston,  MA  02203
(617) 223-6883
Region II:
OFFICE OF THE DIRECTOR
Solid Waste Branch
Air and Waste Management Division
26 Federal Plaza
New York, NY  10007
(212) 264-0505
Region III:
OFFICE OF THE DIRECTOR
Waste Management Branch/RCRA Permit Section
Air and Waste Management Division
Curtis Building, 6th and Walnut Streets
Philadelphia, PA  19106
(212) 597-9118
Region IV:
Region V:
Region VI:
OFFICE OF THE DIRECTOR
Residuals Management Branch/Waste Engineering Section
Air and Waste Management Division
345 Courtland Street NE
Atlanta, GA  30308
(404) 881-3433

OFFICE OF THE DIRECTOR
Waste Management Branch
Waste Management Division
Federal Building
230 South Dearborn
Chicago, IL  60604
(312) 886-7579

OFFICE OF THE DIRECTOR
Hazardous Materials Branch
Air and Waste Management Division
First International Building
1201 Elm Street
Dallas, TX  75270
(214) 729-2645
                                   (continued)
                                       3-4

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                             TABLE  3-1  (continued)
Region VII:
Region VIII:
Region IX:
Region X:
OFFICE OF THE DIRECTOR
Waste Management Branch
Air and Waste Management Division
324 East llth Street
Kansas City, MO  64106
(816) 374-6531

OFFICE OF THE DIRECTOR
Waste Management Branch
Air and Waste Management Division
Suite 900, 1860 Lincoln Street
Denver, CO  80203
(303) 837-6238

OFFICE OF THE DIRECTOR
Programs Branch
Toxics and Waste Management Division
215 Fremont Street
San Francisco, CA  94105
(415) 974-7411/974-8391

OFFICE OF THE DIRECTOR
RCRA Branch
Air and Waste Management Division
1200 6th Avenue
Seattle, WA  98101
(206) 399-2782
                                       3-5

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     To assert a claim,  the provisions of 40 CFR 2  require that the  applicant
must attach a cover sheet to the information,  or stamp or  type  a notice  on
each page of the information,  or otherwise identify the confidential portions
of the application.  Words such as "trade secret",  "confidential business
information", "proprietary", or "company confidential" should be used.   The
notice should also state whether the applicant desires confidential  treatment
only until a certain date or a certain event.

     Whenever possible,  the applicant should separate the  information
contained in the application into confidential and nonconfidential units and
submit them under separate cover letters.  Claiming confidentiality  for  a
large portion of the information in the permit application and failing  to
separate the application into confidential and nonconfidential units may
result in significant delays in processing the permit application because  the
EPA Lacks the in-house resources for expeditiously isolating the confidential
information  from the nonconfidential items.

     If it becomes necessary to send confidential information through the
mail, the applicant should consider the following precautions in addition to
those in §270.12.

     1.   Place the material in a sealed envelope or container and
          conspicuously mark that envelope or container as containing
          confidential information.

     2.   Place the sealed, marked envelope or container inside an outer
          envelope or container which is properly addressed but not marked as
          confidential and  seal this outer envelope or container.

     3.   Mail  (or otherwise ship) the material with return receipt (or
          equivalent) requested.

     The EPA is not liable  for  release of  information which an  applicant has
submitted, but  failed to  identify as confidential.  Additional  information on
the  EPA's handling of confidential  information  can be  found in  Part 2 of
Title  40 of  the CFR.

3.5  APPEALS

      It  is possible to  appeal  the  contents  of a  final  RCRA permit.  The
procedure  for petitioning  the  EPA  to  review any  condition of a  permit decision
is contained in § 124.19-"Appeal of  RCRA,  UIC, and  PSD  permits."   In addition,
the  EPA  can  decide on its  own  initiative  to review a  final permit.  In either
case,  a  petition  or decision  to review a  final  permit must be made  within 30
days after  a RCRA final  permit  decision  has been made under §124.15.
                                       3-6

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       4.0  OVERVIEW OF PARTS 270 AND 264 AND USEFUL INFORMATION SOURCES
4.1  INTRODUCTION

     This section provides an overview of Parts 270 and 264 and discusses
sources of information that may be useful to the permit applicant.   An
overview of Parts 270 and 264 is presented because this manual does not
provide guidance on all of the information you must develop,  compile and
submit in Part B of your permit application.  The overview identifies what
requirements are discussed here and discusses how these relate to other
requirements in the regulations.  Sources of additional information are
provided to identify where you can get answers to specific questions which may
arise during application preparation.

     The guidance provided later in Section 5.0 is intended to provide you
with a discussion and examples of the  information content and detail that the
Agency expects in your Part B submittal.  There is no specific format for
Part B, but in some cases, example formats are presented for your
consideration.  The majority of the discussion has been developed based on
research of referenced documents and reports, familiarity with the preamble
discussions presented in Federal Register promulgations of these regulations,
md extensive discussions with EPA personnel.

f.2  OVERVIEW OF PARTS 270 AND 264

     On April 1, 1983, the EPA established, by publication in the Federal
Register, Part 270 of Title 40 of the  Code of Federal Regulations.   That new
Part (see 48FR14146, 4/1/83) is titled "EPA Administered Permit Programs: The
iiazardous Waste Permit Program".  That Part was established to gather all the
requirements applicable to RCRA permits into one location in the CFR.
Information now contained in Part 270  was scattered throughout Part 122.  The
\pril 1, 1983 Federal Register contains a cross-reference index of RCRA
related sections in Part 122 that correspond to the new Part 270 sections at
f8FR14152.

     The regulations in Part 270 present the basic EPA permitting requirements
ror a RCRA permit.  Permit application requirements, standard permit
conditions, and monitoring and reporting requirements are all presented in
('art 270.  Subpart B of Part 270 is titled "Permit Application".  The sections
in that Subpart identify all the items of information that must be submitted
v/ith a permit application.  Section 5.0 of this manual focuses on the general
information requirements that must be contained in Part B of a permit
application.  These requirements are contained in §270.14.  Additional
facility-type specific information requirements are contained in §§270.15
ihrough 270.21.
                                        4-1

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     In addition to the requirements in Part 270, separate technical
permitting regulations are stipulated in Part 264.  The Part 264 regulations
establish minimum Federal standards which define the acceptable management of
hazardous waste.  The text of Part 270 refers the reader to the sections of
Part 264 which contain the standards that a permit applicant must demonstrate
compliance with by submittal of information in Part B of a permit
application.  Section 5.0 of this manual addresses 14 of the required
informational items identified in Part 270, identifies the corresponding
standards in Part 264, and provides guidance on how to obtain, prepare, and
present information required by part 270 that will demonstrate to the EPA that
the facility complies with the Part 264 standards.

4.3  INFORMATION SOURCES

4.3.1  Documents/Reports

          (a)  RCRA Technical Guidance Documents
               Each Regional office of the EPA should have available in their
          library a series of guidance documents which are directly related to
          the Part 264 regulations governing land based storage, treatment,
          and disposal facilities.  Currently, there are four Technical
          Guidance Documents available:

               (1)  "Surface Impoundments - Liner Systems, Final Cover, and
                    Freeboard Control".

               (2)  "Waste Pile Design - Liner Systems".

               (3)  "Land Treatment Units".

               (4)  "Landfill Design - Liner Systems and Final Cover"

          These volumes may be ordered from the Government Printing Office,
          through a local GPO bookstore, or from  the Superintendant of
          Documents Office listed in Appendix A.

               The purpose of the Technical Guidance Documents is to present
          details of design concepts that the EPA believes will satisfy the
          Part 264 standards (for surface impoundments, waste piles, land
          treatment units, and landfills).  A few contain examples of various
          unit designs, and as more information  is acquired, more models will
          be included.  In all likelihood, a facility meeting these design
          requirements should qualify  for a draft permit.1

               Appendix B contains a synopsis of  each of the Technical
          Guidance Documents.
                                         4-2

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(b)  Technical Resource Documents (TRDs)
     Eight Technical Resource Documents have been developed (as of
May 1983) to assist the regulated community and the permitting
authorities.  In contrast to the Technical Guidance Documents, the
TRDs are not directly related to the Part 264 regulations.  The
current Technical Resource Documents are:

     (1)  "Evaluating Cover Systems for Solid and Hazardous Waste"
          (SW-867); GPO Stock #; 055-000-00228-2.

     (2)  "Hydrologic Simulation on Solid Waste Disposal"
          (SW-868); GPO Stock #; 055-000-00225-8.

     (3)  "Landfill and Surface Impoundment Performance Evaluation"
          (SW-869); GPO Stock #; 055-000-00233-9.

     (4)  "Lining of Waste Impoundments and Disposal Facilities"
          (SW-870); GPO Stock #; 055-000-00231-2.

     (5)  "Management of Hazardous Waste Leachate"
          (SW-871); GPO Stock #; 055-000-00224-0.

     (6)  "Guide to the Disposal of Chemically Stablilized and
          Solidified Waste"
          (SW-872); GPO Stock #; 055-000-00226-6.

     (7)  "Closure of Hazardous Waste Surface Impoundments"
          (SW-873); GPO Stock #; 055-000-00227-4.

     (8)  "Hazardous Waste Land Treatment"
          (SW-874); GPO Stock #; 055-000-00232-1.

These documents are intended to serve as a resource for the
applicant and present the most current state-of-the-art in
technologies and methods for evaluating the performance of a
disposal facility design.  A synopsis of each of the TRDs is
presented in Appendix B.

     The EPA plans to update these documents to reflect the latest
information, and also plans to introduce several new documents
dealing with related topics including:

     (9)  "Evaluation of Closure and Post-Closure Care Plans for
          Hazardous Waste Landfills",

     (10) "Soil Properties, Classification, and Hydraulic
          Conductivity Testing".

     (11) "Solid Waste Leaching Procedure Manual".2
                               4-3

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(c)  Other Guidance Manuals
     There exist several other publications which deal with topics
specific to land disposal.  These are also available from the GPO in
the locations given in Appendix A.  The other available guidance
manuals are:

     (1)  "Test Methods for Evaluating Solid Wastes" (SW-846)

     (2)  "A Method for Determing the Compatibility of Hazardous
          Wastes" (EPA-600/2-80-076)

     (3)  "Handbook for Remedial Action at Waste Disposal Sites"
          (EPA-625/6-82-006)

     (4)  "Permit Writer's Guidance Manual for Subpart F" (Prepared
          by GeoTrans; currently in draft form)

     (5)  "Ground-Water Monitoring  for Owners and Operators of
          Interim Status Facilities" (SW-963)

     (6)  "Financial Assurance for  Closure and Post-Closure Care:
          Requirements for Owners and Operators of Hazardous Waste
          Treatment, Storage, and Disposal Facilities - A Guidance
          Manual" (SW-955)

     (7)  "Liability Coverage:  Requirements for Owners or Operators
          of Hazardous Waste treatment, Storage, and Disposal
          Facilities - A Guidance Manual" (SW-961)

     (8)  RCRA Personnel Training Guidance Manual September 1980
          (Updated version available May  1983)

     (9)  Regional Guidance Manual  for Selected Interim Status
          Requirements - September  22, 1980

     (10) Draft Guidance for Subpart G of the Interim Status
          Standards - October 6,  1981

     (11) Draft Guidance for Subpart H of the Interim Status
          Standards, August 29,  1980

     (12) Guidance Manual  for Evaluating  Permit Applications  for  the
          Operation of Hazardous  Waste Incineration Units

     (13) Guidance Manual  for the Closure of Hazardous Waste  Surface
          Impoundments - May 1980

     (14) Guidance Document for  Subpart F—Ground Water Protection

     (15) Guidance Document for  Evaluation and Monitoring of  Toxic
          Air  Emissions  from Land Disposal Facilities
                               4-4

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               (16) RCRA Inspection Manual3

               Appendix B also presents a synopsis of some of these documents,

4.3.2  Regional SPA Offices and State Offices

     Permit applicants may purchase or study library copies of any of the
Technical Resource Documents or the other guidance manuals described in the
preceding section.  Information regarding these documents, as well as any
matter of technical guidance in the RCRA permitting process, is readily
available at the EPA Regional offices and the state waste management program
offices which are listed in Appendix A, and users of this manual are
encouraged to contact them.

•'t.4  REFERENCES

     1.   Draft Report: Permit Applicants Guidance Manual for Landfills,
          Surface Impoundments, Land Treatment and Waste Piles.  Prepared by
          the U.S. EPA.  p. 32.

     2.   Ibid,  p. 34.

     3.   Ibid.  pp. 37-39.
                                         4-5

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                5.0  GUIDANCE FOR PERMIT APPLICATION PREPARATION
     This manual is specifically intended to assist permit applicants  in
addressing the general requirements for a Part B RCRA permit application.
Those requirements are all found in §270.14 of Subpart B of Part 270.   The
permit application information requirements in §270.14 identify the specific
Part 264 technical requirements with which an applicant's facility must
comply.  That compliance must be demonstrated by the information submitted in
the Part B application.  Table 5-1 shows the Part 270 requirements for which
guidance is supplied in this manual and identifies corresponding Part  264
standards for which guidance is also supplied.  In addition to the Part 270
requirements identified in Table 5-1, this manual provides guidance relative
to the Part 264, Subpart E manifest system, recordkeeping, and reporting
requirements.  Additional recordkeeping and reporting requirements can be
found in §§270.30(j),  (1), and 270.31.

     In this section of the manual, each of the identified Part 270
requirements is separately addressed.  The discussion of each of the
requirements includes the wording of the specific regulatory citations, an
explanation of the intent of the requirement, and guidance and examples of how
applicants can demonstrate compliance with permitting and technical
requirements in their RCRA Part B permit applications.
                                        5-1

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       TABLE 5-1.   SECTIONS OF PARTS 270 AND 264 ADDRESSED IN THIS MANUAL
         Part 270 Sections
   Corresponding Part 264 Sections
§270.14(b)(l)  Facility Description

§270.14(b)(2)  Waste Analysis

§270.14(b)(3)  Waste Analysis Plan

§270.14(b)(4)  Security

§270.14(b)(5)  Inspection Schedule
§270.14(b)(6) Preparedness and
              Prevention

§270.14(b)(7) Contingency Plan
§270.14(b)(8) Prevention Equipment

§270.14(b)(9) Ignition/Reaction
              Precautions

§270.14(b)(lO) Traffic Control

§270.14(b)(11) Location Information

§270.14(b)(12) Personnel Training

§270.14(b)(19) Topographic Map
None

None specific

§264.13

§264.14

§§264.15(b), 264.174, 264,194,
264,226, 264.254, 264.273, 264.303,
264.273(g)

Part 264, Subpart C, §§264.30
through 264.37

Part 264, Subpart D, §§264.50 through
264.56, §264.227 and §264.255

None specific

§264.17


None specific

§264.18

§264.16

None
                                        5-2

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5.1  FACILITY DESCRIPTION

3.1.1  Regulatory Citations

     A description of the facility must be included with Part B of the permit
application, as specified in:

     "§270.14(b)(D  A general description of the facility."

     Part 264 of the regulations does not specify any regulatory standards
with which the facility description must comply.

5.1.2  Guidance to Achieve the Standards

     The requirement that a general description of the facility be included in
che permit application is straightforward and requires little explanation.
The intent is to provide enough information to identify the type and size of
facilities for which a permit  is being sought.  The description can be brief
and general.  The following is a list of information items which should be
:onsidered for mention in the  facility description:

     •    Type of facility (onsite, offsite;  storage, treatment, disposal)

     •    New or existing

     •    Size (acres, number of units)

     •    Location

     •    Name of company

     •    Name of owner

     •    Activities conducted

     •    Wastes types and quantities stored, treated, and/or disposed of

5.1.3  List of Major Points

     1.   Has a general description of the facility for which a permit is
          sought been provided?

     2.   Have the items noted above been addressed?
                                        5-3

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5.2  CHEMICAL AND PHYSICAL ANALYSES  OF HAZARDOUS  WASTE

5.2.1  Regulatory Citations

     Information on chemical and physical  analyses  of  the  hazardous waste  to
be handled at the facility must be included in Part B  of  the  permit
application,  as specified in:

               "§270.14(b)(2)   Chemical and physical analyses of  the  hazardous
          waste to be  handled at the facility.  At  a minimum, these analyses
          shall contain all the information which must  be  known to  treat,
          store, or dispose of the wastes  properly  in  accordance  with
          Part 264."

     The regulatory requirements regarding chemical and physical  analyses  of
hazardous waste are contained in §264.13.   They are:

               "§264.13(a)(1)  Before an owner or operator  treats,  stores,  or
          disposes of  any hazardous waste, he must  obtain  a detailed  chemical
          and physical analysis of a representative sample of the waste.   At  a
          minimum, this analysis must contain all the  information which must
          be known to  treat, store, or dispose of the  waste in accordance  with
          the requirements of this Part or with the conditions of a permit
          issued under Part 270 and Part 124 of this Chapter.
                (2) The analysis may include data developed under  Part 261  of
          this Chapter, and existing published or documented data on  the
          hazardous waste or on hazardous  waste generated  from similar
          processes...."

Further, the specific  information requirements of §270.14 for several facility
types require the owner/operator to document in his application a list of
hazardous wastes handled at his facility.

5.2.2  Guidance to Achieve the Part 264 Standards

     The concept and objectives of waste analysis are  discussed in detail  in
Section  5.3, Waste Analysis Plans.  The essential item to note here,  however,
is that  you must submit the waste analysis data that is necessary to
adequately handle each waste at your facility.  Sources of this information
include  analytical data based on analysis of representative samples of the
waste, published or historical data, and data provided by  waste generators (in
the case of offsite facilities).  In all likelihood, some  combination of  these
information sources will be required to fully characterize most wastes.

     Subsection 5.3.4 discusses the concept of a generator audit which is
designed to retrieve generator supplied waste data, witness first-hand the
waste generating process, or collect representative waste samples for
analysis.  It may be appropriate for you to refer to that discussion  now if
you operate an  offsite  facility that accepts wastes from several different
sources  and you intend  to rely on data provided by waste generators.    In any
                                       5-4

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event, it may be appropriate for you to read all of Section 5.3 before  you
formulate your response to the information requirements of § 270.14(b)(2)  in
your permit application.

     The Part 270 information requirements specify that the submitted
hazardous waste analyses must contain the information required to properly
treat, store, or dispose of the waste.  Thus, analytical parameters must  be
selected based on waste type, facility type, and management procedure.   If a
relatively homogeneous waste is stored onsite in tanks, the selected list of
waste analysis parameters may not necessarily be as comprehensive as that
associated with an offsite treatment facility accepting hazardous inorganic
sludges for treatment to render the wastes nonhazardous.

     In the first case, the owner/operator would select analytical parameters
such as ignitability and reactivity to illustrate that he can safety store the
waste and to expedite agreements with an offsite facility that accepts  the
waste for further storage, treatment, or disposal.  The owner/operator  would
also be concerned with waste/tank compatibility and waste/waste compatibility
and would present waste analysis data to assure that compatibility exists.

     In the case of the offsite treatment facility, the owner/operator  should
have sufficient waste analysis data to allow for proper facility operation and
assure that the waste is adequately treated and no longer hazardous. Possibly
the inorganic waste of concern is a metal plating sludge which demonstrates
the EP toxicity characteristic because of high chromium concentration.   An
applicable treatment process might consist of hydroxide precipitation of
chromium, followed by sludge drying and solidification using a cement or
pozzolan based stabilization process.  The waste characteristics of concern
would probably include chromium, other heavy metals, and cyanide (used  in
alkaline plating baths), which could interfere with reagents used throughout
the treatment and stabilization system.  Thus, the waste analysis data  should
include these characteristics.

     Regardless of facility type and waste, to fulfill the information
requirements of §270.14(b)(2), you should present waste analysis data  in
tabular form for each waste handled or to be handled at your facility.   An
example is noted in Table 5-2.

     The specific information requirements call for a list of hazardous wastes
to be submitted in Part B applications for landfills, surface impoundments,
and waste piles.  The specific information requirements for land treatment
facilities require a listing of wastes to accompany plans for a treatment
demonstration.  To fulfill the waste listing requirements for these types of
facilities, you should indicate the following general information:

     •    Name of the waste

     •    EPA hazardous waste ID number (if assigned), and

     •    Location where the waste will be stored, treated, or disposed of at
          the facility.


                                       5-5

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          TABLE 5-2.   EXAMPLE WASTE ANALYSIS DATA FOR A WASTE RECEIVED
                      AT AN OFFSITE SOLVENT RECOVERY PLANT
           Waste No.  346A (EPA ID F002):   1,1,1-trichloroethane from
                                          degreasing of cutting tools
     Characteristics
Concentration
           Comments
1,1,1-trichloroethane


Priority pollutant metals
  Chromium
  Copper
  Lead
  Nickel
  Silver

Viscosity

Flash point

Specific gravity
   83 + 5%
210 _+ 30 rag/I
650 +_ 80
 40 +_ 10
800 +_ 100
 25 +_ 5

  0.85 cp

   65°C

   1.30
More than 40% required to be
recoverable
Metal sludge is centrifuged
and landfilled
Measured to assure pumpability

Measured for safety in handling

Measured to assess separability
of phases
                                       5-6

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If you are also submitting a new or  revised  Part  A application,  you are
reminded that additional waste analysis information is  required  in the Part  A
application to meet the requirements of §270.13.   A Part  A application must  be
submitted along with Part B if the facility  is  new or  if  the  facility is
existing and the wastes have changed since  the  first Part A submittal.  The
Part A application must include:

     •    Specification of the hazardous wastes to be  stored,  treated, or
          disposed of

     •    the quantity of wastes to  be stored,  treated, or disposed of
          annually at the facility,  and

     •    a general description of processes to be used for such wastes.

5.2.3  List of Major Points

     1.   If you are submitting a new or revised Part  A application,  does  it
          include a list of wastes;  quantities  to be stored,  treated, or
          disposed of on an annual basis; and a general description of the
          processes used for such wastes?

     2.   If a new or revised Part A application is being submitted,  does  all
          waste analysis data and other waste related  information correspond
          precisely with waste analysis data and information presented in  the
          Part B application?

     3.   In the Part B application, have you identified all hazardous wastes
          to be handled and any applicable  EPA ID numbers?

     4.   Most importantly, have you denoted the chemical and physical waste
          analysis data which must be known to  adequately store, treat, or
          dispose of the wastes at the facility?

     5.   Have you noted the locations where each waste will be  handled at
          your facility?

     To fully address some of these  questions and assure that this part of the
application is adequate and complete, you should review the guidance  in the
next subsection on preparation of the waste analysis plan.
                                       5-7

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5.3  WASTE ANALYSIS  PLANS

5.3.1  Regulatory Citations

     The information required in the permit  application  for  waste  analysis
plans is specified under §270.14(b)(3)  as  follows:

          "A(copy of the waste analysis plan required by §264.13(b)  and,  if
     applicable §264.13(c)."

     The standards specified  in §264.13 are  applicable to all  facilities  that
treat, store, or dispose of hazardous wastes,  and  are reprinted  below:

          "264.13  General waste analysis.
               (a)(l) Before  an owner or operator  treats, stores,  or disposes
          of any hazardous waste, he must obtain a detailed  chemical and
          physical analysis of a representative sample of the  waste.  At  a
          minimum, this analysis must contain all  the information  which must
          be known to treat,  store,  or  dispose of  the waste  in accordance with
          the requirements of this Part or with the conditions of  a  permit
          issued under Part  270, and Part 124 of this Chapter.
               (2) The analysis may include  data developed under Part 261 of
          this Chapter, and existing published or  documented data  on the
          hazardous waste or  on hazardous waste generated from similar
          processes.
               (3) The analysis must be repeated as necessary  to ensure  that
          it is accurate and  up to date.  At a minimum,  the  analysis must be
          repeated;
               (i) When the  owner or operator is notified, or  has  reason  to
          believe, that the  process or  operation generating  the  hazardous
          waste has changed;  and
               (ii)  For offsite facilities,  when the results of  the
          inspection required in paragraph (a)(4)  of this Section  indicate
          that the hazardous  waste received  at the facility  does not match  the
          waste designated on the accompanying manifest or shipping  paper.
               (4) The owner  or operator of  an offsite facility  must inspect
          and, if necessary,  analyze each hazardous waste movement received  at
          the  facility to determine whether  it matches the identity  of the
          waste specified on  the accompanying manifest or shipping paper.
               (b) The owner  or operator must develop and follow a written
          waste analysis plan which describes the procedures which he will
          carry out to comply with paragraph (a) of this Section.   He must
          keep this plan at  the facility.  At a minimum, the plan  must specify:
               (1) The parameters for which  each hazardous waste will be
          analyzed and the rationale for the selection of these  parameters
          (i.e., how analysis for these parameters will provide  sufficient
          information on the waste's properties to comply with paragraph  (a)
          of this Section;
               (2) The test methods which will be used to test for  these
          parameters;
                                       5-£

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               (3)  The  sampling  method  which will  be  used  to  obtain  a
          representative sample  of the  waste to be analyzed.   A  representative
          sample may  be obtained using  either:
               (i)  One  of the sampling  methods  described  in Appendix I  of
          Part  261  of this  Chapter;  or
               (ii) An  equivalent sampling  method.
               (4)  The  frequency with which the initial analysis of  the waste
          will  be reviewed  or repeated  to ensure that the  analysis  is accurate
          and up to date; and
               (5)  For  offsite facilities,  the  waste  analyses that hazardous
          waste generators  have  agreed  to supply.
               (6)  Where applicable, the methods which will be used  to  meet
          the additional waste analysis requirements  for  specific waste
          management  methods as  specified in §264.17  and  264.341.
               (c)  For  offsite facilities,  the  waste  analysis plan required  in
          paragraph (b) of  this  Section must also specify  the procedures which
          will  be used  to inspect and,  if necessary,  analyze  each movement of
          hazardous waste received at  the  facility to ensure  that  it matches
          the identity  of the waste designated  on the accompanying manifest  or
          shipping paper.  At a  minimum, the plan must describe:
               (1)  The  procedures which will be used  to determine  the identity
          of each movement  of waste managed at  the facility;  and
               (2)  The  sampling  method  which will be  used  to  obtain  a
          representative sample  of the  waste to be identified, if  the
          identification method  includes sampling.

5.3.2  Guidance to Achieve  the Part 264 Standards

     In response to public  comment, the standards of  §264.13  were  stated  in
somewhat general terms  to be comprehensive  enough to  account  for the variety
of conditions and waste analysis requirements which arise  from site  to
site.l  The requirements for waste analysis that each owner/operator will
have to meet will be  specified in the  facility  permit after administrative and
technical review of the permit application. The scope of  the waste  analysis
plan is expected to differ  significantly from site to site, so that  the
owner/operator must successfully demonstrate through  his  proposed  procedures
that the intent of the  §264.13 waste analysis requirements are met  and  that
the specific requirements for his facility  type (Subparts  I through  N)  are
also supported.  Waste  analysis  is implicitly required in  those  Subparts  to
comply with waste related standards for these different types of treatment,
storage, and disposal facilities.  In  essence,  the objective  of  the  waste
analysis plan is to assure  successful  treatment, storage,  or  disposal of
wastes at the facility  through recognition  and  implementation of specific
waste analysis  procedures selected based on waste type, facility type,  and
waste management procedures.

     In providing the information to meet this  permitting  requirement,  the
applicant should rigorously consider what he is doing with the waste at his
facility to formulate an appropriate plan of sampling and  analysis.  The
applicant should view this  plan  as essential to successful and safe  operation
of the facility, as opposed to a regulatory requirement to generate  analytical
                                      5-9

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data for simple recordkeeping purposes.   A well  designed  comprehensive waste
analysis plan will help the owner/operator prevent  adverse  incidents  and  the
expense of associated cleanup or litigation.

     An acceptable waste analysis plan must encompass  the following aspects
for all facilities:

     •    Procedures and methods for obtaining waste analysis data  to assure
          that the wastes can be successfully treated,  stored,  or disposed of.

     •    Methods of collecting representative samples.

     •    Procedures for reviewing or repeating the initial analysis  of  the
          waste on a routine and as-needed basis.

     •    Quality assurance/quality control for waste  sampling and  analysis  in
          all phases.

     •    Procedures and methods of waste analysis  for  characterizing
          incompatible:, ignitable, and reactive wastes,  as  well as  methods  to
          show that such wastes have been rendered  compatible,  nonignitable,
          or nonreactive.

     Additionally, the waste analysis plan must incorporate procedures and
methods to support waste analysis requirements associated with specific  onsite
and offsite facility types (containers,  tanks, waste piles, surface
impoundments, land treatment facilities, and landfills)  and specific waste
management procedures (treatment, storage, or disposal).   Some of  these  added
requirements for offsite facilities include:

     •    Procedures to inspect and, if necessary,  analyze each movement of
          waste received to ensure consistency with the manifest form.

     •    Procedures for documenting that the received waste is as  expected
          from each particular waste generator within established  tolerance
          bands.

     •    Procedures for resampling, reanalyzing, and accepting or rejecting
          received wastes.

     Additional procedures that must be represented for yet other types of
facilities include:

     •    Methods  of characterizing or analyzing existing wastes in waste
          receiving  facilities  to assure compatibility with incoming waste.

     •    Methods  of waste analysis to assure compatibility of wastes with
          equipment  surfaces,  facility liners, and leachate collection system
          materials.

     •    Methods  of determining  that storage facilities and equipment are
          decontaminated at  closure.

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     •    Methods to determine the presence of  liquids  or  free  Liquids.

     •    Methods of determining whether collected leaks,  spills,  run-off,  or
          leachate are hazardous or nonhazardous.

     The remainder of this section presents guidance on achieving  the general
standards for waste analysis specified in §264.13  and for  achieving the
facility specific standards (Subparts I through N) which implicitly require
waste analysis.  Examples are provided in Section  5.3.6 to illustrate the  type
of information that an owner/operator should incorporate in his waste analysis
plan.

     The Environmental Protection Agency is preparing a Waste Analysis Plan
Guidance Manual (draft expected in Spring 1984) which will provide detailed
guidance on waste analysis plans for all types  of  facilities.   That document
is intended to supplement the concepts and guidance presented in this manual
and will include model waste analysis plans for a  wide variety of  different
facility types.

5.3.3  Guidance for Preparation of Waste Analysis  Plans for All Facilities

     Waste analysis requirements will differ depending on  the type of
facility, type of waste, and specific waste management practices.   However,
certain aspects of the general waste analysis requirements are common to all
facilities and waste types.

5.3.3.1  Analysis of Wastes to be Treated, Stored, or Disposed Of—
     Waste analysis is required to ascertain that  wastes can be successfully
treated, stored, or disposed of.  This waste analysis can  be based on analysis
of representative waste samples or on historical or available scientific data.
Except for simple cases, it is expected that both  types of documentation will
be necessary.

     Analytical parameters must be selected based  on waste type, facility
type, and management procedure.  If a relatively homogeneous waste is stored
onsite in tanks, the list of parameters selected for analysis will be much
less comprehensive than that associated with an offsite treatment  facility
accepting hazardous inorganic sludges to be rendered nonhazardous.  In the
first case, the owner/operator would select analytical parameters  such as
ignitability and reactivity to allow for safe storage and  to expedite
agreements with an offsite facility that would  later accept the waste for
further storage, treatment, or disposal.  In this  case, the owner/operator
would also be concerned with waste/tank compatibility and  waste/wasce
compatibility and would select analytical parameters to assure that
compatibility exists.

     In the second case, in addition to recognizing issues of waste
compatibility and safety in handling, the owner/operator of the offsite
treatment facility would need to select waste analysis parameters  sufficient
to allow for adequate treatment of the waste to assure that it is  no longer
hazardous.  Suppose that the inorganic waste of concern is generated by
production of titanium oxide pigment and demonstrates the  EP toxicity

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characteristic because of high concentrations of heavy metals.   Such a waste
might: also be contaminated with cyanide.  An applicable treatment process
might consist of chemical oxidation of cyanide followed by hydroxide
precipitation of heavy metals.  Ultimately,  the resulting sludge might be
dried and solidified or otherwise stabilized.  In this instance, the
owner/operator's waste analysis plan should  specify analytical  parameters for
the waste feed, treated stabilized waste product, and intermediate streams in
the treatment process.  The waste feed analytical parameters might include pH,
cyanide, a variety of specific heavy metals, total solids, and  others to
assure proper treatment.  Other constituents that are incorporated in the
waste which could interfere with reagents used throughout the treatment: and
stabilization system might also be designated for analysis.  The stabilized
product could conceivably be subjected to the EP toxicity test  and leachate
analyzed for heavy metals and metal cyanides to document that the stabilized
waste is no longer hazardous.

     Other examples are provided in later sections.  The point  to be made here
is that there is no universal set of parameters to be analyzed  for.  The
parameters selected will be strongly site and waste specific".  Therefore, the
applicant must carefully evaluate and present a rationale for selection of
waste analysis parameters in all cases.

5.3.3.2  Procedures for Collecting Representative Samples —
     Regardless of the purpose of the analysis, the applicant must demonstrate
his procedures for collecting representative samples for analysis.  These
procedures will depend on the nature of the  waste, its variability over time,
and the waste generating process.  Samples are representative if they allow
for accurate and precise quantification of the average characteristics of the
waste.  An accurate sample is one which will provide a measured value close to
the true value.  A precise sample is one which will provide a measured value
close to the measured value of other replicate samples.   In-depth discussion
of representative sampling procedures is provided in SW-846—Test Methods for
Evaluating Solid Wastes.2  The applicant should obtain a copy of that
document (see Appendix A for  locations where it is available) because of its
comprehensive treatment of waste sampling and analysis and because much of the
discussion and guidance in this document is  based on its contents.  In
addition to SW-846, other reference sources  of value in understanding
representative sample collection procedures   for hazardous waste include:

     •    Ford, P. J., P. J.  Turina, and D.   E. Seely.  Characterization of
          Hazardous Waste Sites - A Methods  Manual.  Volume  II  - Available
          Sampling Methods.   Prepared for Lockheed Engineering  and Management
          Services under EPA  Contract No. 68-03-3050.  Environmental
          Monitoring  Systems  Laboratory, Office of Research  and Development,
          U.S. Environmental  Protection Agency.  March 1983.3

     •    U.S. Environmental  Protection Agency.  Samplers and Sampling
          Procedures  for Hazardous Waste Streams.  U.S.  EPA  Municipal
          Environmental Research Laboratory.  Cincinnati, Ohio.
          EPA-600/2-80-018.4
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Further,  40 CFR 261  Appendix I  lists  certain  ASTM  standard methods  for
collecting representative samples,  as follows:

               "Extremely viscous  liquid—ASTM  Standard  D140-70,  Crushed  or
          powdered material—ASTM  Standard D346-75,  Soil  or  rock-like
          material—ASTM Standard  D420-69, Soil-like material—ASTM Standard
          D1452-65
               Fly ash-like material—ASTM Standard  D2234-76 (ASTM  Standards
          are available from ASTM,  1916 Race  St.,  Philadelphia,  PA   19103).
               Containerized liquid wastes—'COLIWASA1 described in [SW-846].
               Liquid waste in  pits,  ponds, lagoons, and  similar reservoirs —
          'Pond Sampler1  described in [SW-846]."

     5.3.3.2.1  Statistical Concepts  Used  in  Collecting  Representative
Samples—Statistical techniques must  be used  to collect  accurate and precise
samples.   Your waste analysis plan should  be  clear and specific  with regard  to
this issue because statistical  sampling techniques are not  always simple  to
implement in spite of the fact  that they are  fairly  clear to understand.

     Sampling accuracy is usually  achieved by some form  of  random sampling.
This is particularly true for sampling of  heterogeneous  wastes.   In random
sampling, every unit in the population has a  theoretically  equal chance of
being sampled and measured.  Consequently, statistics generated  (mean,
standard  deviation)  by analyzing the sample are accurate estimators of  the
true population parameters, i.e.,  the sample  is representative of the
population.  One method of selecting a random sample is  to  divide the
population by an imaginary grid, assign a  series of  consecutive  numbers to the
units of  the grid, and select the  numbers  (units)  to be  sampled  through the
use of a  random numbers table.   Note  that  a haphazardly  selected sample is not
a suitable substitute for a randomly selected sample. Samples collected  in
other than a random  fashion may be skewed  because  of sampling  bias; for
instance  by the collection of the  most easily accessible samples.

     Sampling precision is most commonly achieved  by taking  an appropriate
number of samples from the population.  Sampling  precision  can be increased by
maximizing the physical size (weight  or volume) of the samples.   Increasing
the number or size of samples taken from a population, in addition  to
increasing sampling  precision,  has the secondary effect  of  increasing sampling
accuracy.

     More complex stratified random sampling  is appropriate  if a waste  is
known to  be randomly heterogeneous in terms of  its chemical  properties and/or
nonrandom chemical heterogeneity is known  to  exist from  batch  to batch.   In
such cases, the population should  be  stratified during sampling  to  isolate the
known sources of nonrandom chemical heterogeneity.  After stratification,
which may occur over space and/or  time, the units  in each stratum are
numerically identified, and a simple  random sample is taken  from each
stratum.   The advantage of stratified random  sampling over  simple random
sampling  is that, for a given number  of samples and  a given  sample  size,  the
former technique often results  in  a more precise estimate of chemical
properties of a waste than the  latter technique.   However,  greater  precision
is likely to be realized only if a waste exhibits  substantial  nonrandom

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chemical heterogeneity and stratification efficiently  "divides"  the waste  into
strata that exhibit maximum between-strata variability and  minimum
within-strata variability.  If that does  not  occur,  stratified random  sampling
can lead to analytical results that are  less  precise than those  which  result
from simple random sampling.  Therefore,  it is  reasonable to  select stratified
random sampling over simple random sampling only if  the distribution of
chemical contaminants in a waste is sufficiently known to allow  an intelligent
identification of strata and at least two or  three samples  can be collected in
each stratum.

     Another type of probability sampling is  systematic random sampling,  in
which the first unit to be collected from a population is randomly selected,
but all subsequent units are taken at fixed space or time intervals.   An
example of systematic random sampling is the sampling  of a  movement of drums
received at an offsite facility wherein the first drum sampled is selected on
a random basis and every fourth drum is sampled thereafter.  The advantages of
systematic random sampling over simple random sampling and  stratified  random
sampling are the ease in which samples are identified  and collected.   One
disadvantage of systematic random sampling is the inaccuracy  that may  result
if trends or cycles in waste variability are not recognized and  they coincide
with the sampling routine.

     The foregoing statistical sampling techniques are contrasted with
authoritative sampling, in which an individual  who has knowledge of  the  solid
waste to be sampled selects a sampling scheme using his own judgement.  The
validity of data gathered is completely dependent on the knowledge of  the
sampler and although valid data can sometimes be obtained,  authoritative
sampling is not recommended for characterization of  most wastes.

     To summarize, if little or no information is available concerning the
distribution of chemical contaminants of a waste, simple random  sampling  is
the most appropriate sampling strategy.  As more information  is  accumulated
for the wastes and contaminants of concern, consideration  can be given to
stratified random sampling, systematic random sampling, and,  perhaps,
authoritative sampling.

     Test Methods for Evaluating Solid Waste (SW-846)  provides much  more
detail on representative  sampling procedures and sampling  strategies.
Hypothetical examples are provided to illustrate statistical  procedures  used
in designing sampling strategies.

     5.3.3.2.2  Grab and  Composite Samples2,3—A grab  sample is  defined as a
discrete aliquot representative of a specific location at  a given point  in
time.  The sample is collected  in its entirety at one point in the  sample
medium.  The representativeness of such samples is defined  by the nature of
the materials being  sampled.   In general, as sources vary  over time and
distance, the representativeness of  grab samples will  decrease.

     Composite samples are  nondiscrete samples composed of  more  than one
specific aliquot collected  at various sampling locations and/or  different
points  in time.  Analysis of  this type of sample produces  an average value and
in certain instances  is a viable alternative to analyzing a number  of

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individual grab samples and calculating an  average  value.   It  should be  noted,
however,  that compositing can mask low concentrations  of  constituents  that  may
exist in samples taken at specific locations  or  times.

     For sampling situations involving hazardous wastes,  grab  sampling
techniques are generally preferred because  grab  sampling  minimizes  the amount
of time sampling personnel must be in contact with  the wastes,  reduces risks
associated with compositing unknowns, and eliminates chemical  changes  that
might occur due to compositing.  Compositing, however,  may  be  used  for
hazardous samples under certain conditions.  For example, compositing  of
hazardous waste is often performed (after compatibility tests  have  been
completed) to determine an average value over a  number of different locations
such as a group of drums.  This procedure provides  data that  can be useful  by
providing an average concentration within a number  of  units,  can help  keep
analytical costs down, and can provide information  useful to  the
owner/operator.

     Some valuable insight on composite sampling is provided  in a study
prepared for EPA Region I by A. T. Kearney, Inc.5  xhe report  points out the
disadvantages of composite samples by first noting  the natural  heterogeneity
of hazardous wastes and then by reference to  measurement  of waste
ignitability, corrosivity, reactivity, and  EP-toxicity.  With  respect  to
ignitability, it is noted that otherwise ignitable  wastes such  as waste  ether
or acetone may be rendered nonignitable if  mixed (i.e., composited) with a
sufficient quantity of aqueous waste.  Corrosive wastes are generally  either
strongly caustic or acidic.  Clearly, compositing diverse,  otherwise corrosive
wastes may result in a neutral, noncorrosive  composite waste,  analysis of
which will not indicate the corrosive wastes  which  may exist  in the waste
population.  Additionally, compositing of reactive  hazardous  wastes must be
avoided to prevent generation of toxic gases  or  fumes.  Further, if several
dissimilar wastes are composited, dilution  effects  may result  in a  waste
sample which does not exhibit EP-toxicity,  despite  the possibility  that
individual samples and associated wastes may  be  EP-toxic.  In  summary,
complicating factors which must be considered in compositing  samples include
neutralization upon compositing, precipitation of hazardous constituents,
reactions or explosions, waste dilution, and  other  phenomena.

     Although analysis of discrete or grab  samples  is  superior to composite
samples in assuring measurement of representative waste characteristics, the
disadvantages of cost and time must be considered in selecting sampling
procedures.

     5.3.3.2.3  Multiple Samples3—The concept of multiple  samples  is
applicable to both grab and composite samples.  It  is  recommended that
multiple samples be collected whenever possible. They are  essential for
quality control and they assist in reducing costs associated  with resampling
as a result of container breakage or errors in the  analytical  procedure.
Multiple samples include duplicates, blanks,  split  samples, or spiked  samples.

     Duplicate samples are identical samples  collected at the  same  time  in  the
same way, and contained, preserved, and transported in the  same manner.   These
samples are often used to verify the sampling precision.  Sample blanks  are

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samples of deionized/distilled water,  rinsed collection  devices  or  containers,
sampling media (e.g.,  sorbent), etc.  that  are handled  in the  same manner  as
the sample and subsequently analyzed  to identify possible sources of
contamination during collection,  preservation,  handling, or  transport.  Split
samples are those collected in duplicate fashion for the purpose of separate
analysis.  Spiked samples are duplicate samples that have a  known amount;  of a
substance of interest added to them.   These samples  are  used  to  corroborate
the accuracy of the analytical technique and could be  used as an indicator of
sample quality change during shipment  to the laboratory.

     5.3.3.2.4  Applicable Hazardous Waste Sampling  Equipment—Sampling of
various types of hazardous wastes requires a variety of  sampling equipment.
Although much of the applicable sampling equipment is  commercially  available,
some may have to be custom made for a  given sampling routine. Table  5-3,  from
SW-846, provides a summary of sampling equipment which may be used  for
different classifications of waste.

5.3.3.3  Quality Assurance/Quality Control—
     As noted in SW-846, Section Ten  (incorporated here  in Appendix F):

               "Quality assurance (QA) is  a system  for ensuring  that  alL
          information, data, and resulting decisions compiled under a specific
          task are technically sound,  statistically  valid, and properly
          documented.  Quality control is  the mechanism  through  which quality
          assurance achieves its goals.  Quality control programs define  the
          frequency and methods of checks, audits,  and reviews necessary  to
          identify problems and dictate corrective action, thus  verifying
          product quality.

The facility's implemented QA/QC program will determine  the  accuracy,
precision, and overall integrity of the sampling and analysis program.   An
incomplete, unsound, or poorly planned QA/QC program will be judged deficient
during review of your permit application.   Therefore,  if an  outside laboratory
is contracted, the applicant should carefully review their current  QA/QC
program.  Similarly, the applicant should review and augment his own  QA/QC
procedures, if the owner/operator plans to conduct  all necessary sampling and
analyses with his own resources.

     As noted in SW-846, an acceptable QA/QC plan will denote:

     "1.  The intended use(s)  for the data, and the necessary level of
          precision and accuracy of the data for these  intended uses.

     "2.  A representative sampling plan that  includes  provisions  for:

          -    selecting appropriate sampling  locations, depths, etc.

               providing a statistically sufficient number of sampling sites.

               measuring all necessary ancillary data.

               determining which media are  to  be sampled  (e.g.,  solid, liquid,
               sludge).
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                       TABLE 5-3.   SAMPLING EQUIPMENT FOR PARTICULAR WASTE TYPES

                                    Source:  Reference 2 (SW-846).

Waste type
Free flowing
liquids and
slurries
Sludges
I
£ Moist
powders
or granules
Dry powders
or granules
Sand or packed
powders and
granules
Large
grained
solids

Sacks
Drum and bags
COLIWASA N/A
Trier N/A
Trier Trier
Thief Thief
Auger Auger
Large Large
Trier Trier
Waste location
Open bed Closed
truck bed truck
N/A COLIWASA
Trier Trier
Trier Trier
Thief Thief
Auger Auger
Large Large
Trier Trier
or container
Storage
tanks Waste
or bins piles
Weighted N/A
bottle
Trier a
Trier Trier
Thief Thief
a a
Large Large
Trier Trier

Ponds,
lagoons,
& pits
Dipper
a
Trier
Thief
a
Large
Trier

Conveyor
belt Pipe
N/A Dipper

Shovel Dipper
Shovel Dipper
Dipper Dipper
Trier Dipper
aThis type of sampling situation can present significant logistical sampling problems.  Therefore
 sampling equipment must be specifically selected or designed based on site and waste conditions.

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               determining which parameters are to be measured (and where).

               selecting appropriate sample containers.

               selecting the  frequency of sampling and length of sampling
               period.

               selecting the  types of sample  (e.g., composites vs. grabs) to
               be  collected.

          -    sample  preservation procedures.

          -    chain-of-custody.

     "3.   An analytical plan  that includes:

               chain-of-custody  procedures.

               appropriate sample preparation methods.

          -    appropriate analytical methods.

               appropriate calibration and analytical  procedures.

               procedures  for data handling,  review and reporting.

     "4.   Planning for the inclusion of  proper and sufficient QA/QC
          activities,  including  the use  of QC samples  throughout all phases of
          sampling and analysis  to ensure that the level  of  quality of  the
          data will meet the  requirements of  the  intended use(s) of the data."

Further more detailed  guidance is provided in Section  10  of  SW-846 as reported
here in Appendix F.

5.3.3.4  Procedures for Reviewing or Repeating the Initial Analysis of  the
         Wastes —
     The applicant should  develop a  scheme  for reviewing  or  repeating the
initial analysis of the wastes during  facility operation  on  a routine basis
and on an as-needed basis.   Waste characteristics will vary  depending on the
nature of the waste generating process.   For  instance, the process may  operate
using different feedstocks at different  times of  the year (e.g.  petroleum
distillation bottoms)  and  may incorporate different downstream  processing
components or additives as a consequence of  the change in feedstock.  Thus,
the applicant should actively account  for these routine changes  in the
generated waste by incorporating intermittent reanalysis  of  the  waste into his
waste analysis plan.

     In addition,  the  owner/operator  should  develop a  plan to reanalyze wastes
on a contingent basis  if he  suspects  that the waste characteristics have
changed.  Such contingent  reanalysis might be signaled as a  result of visual
inspection during handling,  as a result  of measured changes  in waste
treatability, or as a result of incidents during  handling such  as  fume

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generation.  Additionally, wastes should be reanalyzed if a  generator notifies
the owner/operator that the waste generating process  has  changed  or  if he
knows of a specific change in the waste.  The applicant's waste analysis  plan
must propose criteria and schedules for reanalysis  and must  specify  the
parameters to be analyzed during recharacterization of the waste  in  each
instance.

5.3.4  Guidance for Preparation of Waste Analysis Plans for  Offsite  Facilities

     This subgroup of facilities is addressed next  because requirements for
waste analysis plans for offsite facilities are incorporated in the  general
waste analysis requirements of §264.13.  Offsite facilities  are those storage,
treatment, and disposal facilities which accept waste from remote generator
locations after waste transport.  Offsite facilities  are  required to:

     •    document the waste analysis data that generators have agreed to
          supply; and

     •    specify procedures to inspect and, if necessary, analyze each
          movement of waste received to assure consistency with the  manifest
          form.

The remainder of this subsection presents guidance on meeting these
requirements and discusses applicable methods to assure that received wastes
are as expected from particular waste generators and methods to screen for
restricted wastes.

5.3.4.1  Waste Analysis Data Provided by Generators—
      It  is  the owner/operator's responsibility to obtain waste analysis data
for all  wastes to be received at his facility.  Although the generator can not
be  forced  to provide waste analysis data, the owner/operator can request it.
Additionally, the owner/operator can not be prevented  from charging  the waste
generator  for the full cost of handling his waste which would include the cost
of  analyzing the waste.   The most  prudent waste generators will provide
accurate analytical data  in recognition of this fact and frequently as a
result of having previously generated this information for purposes of safely
storing  the wastes onsite prior to transport to the offsite  facility.

      In  formulating and implementing the waste analysis plan for an offsite
facility,  the preliminary work and agreements between  the owner/operator and
generator will be the key to success.   The owner/operator should consider the
nature of a potential customer's waste, the variability of that waste, the
chance that other waste components could be inadvertently or otherwise mixed
in  the expected waste, and the chance of errors during shipment of the waste
from  the generator's plant.  To guard against the adversities associated with
errors or  intentional changes in the waste, the owner/operator should do the
following during early negotiations with waste generators:

      •    request representative waste  samples for testing;

      •     request as much data as  exists on the waste  stream, including
          expected quantities, processes generating the waste, waste

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          classification,  specific  waste  characteristics, known health or
          environmental effects  of  the  waste,  and known hazards in handling or
          disposing of  the wastes;

     •    ask the generator how  he  proposes  to assure  that  the waste shipped
          will be as specified  in  the original contract; and

     •    visit the generating  facility to gain first  hand  knowledge of  the
          waste generating process, other waste materials onsite which could
          potentially be mixed with the contracted waste, and the chances  for
          error in waste shipment.

     It is recommended that requests for  waste analysis data  from the
generator be formalized by use  of  a standard and detailed questionnaire
developed by the owner/operator.  Additionally, if  the owner/operator proposes
to use such a questionnaire, its incorporation in this part of the application
will expedite the permit review process.   If the owner/operator has not  yet
produced such a form, he should  consider  requesting  the following types  of
information, subject to the type of storage, treatment, or  disposal that he
proposes.

     •    Generator name, address,  and  company representative;

     •    waste name, industry  or  EPA hazardous waste  number, and process
          generating waste;

     •    waste analysis data,  such as:

               PH

               physical state

               liquids or solids content

          -    specific gravity

          -    flash point

     •    specific waste components, such as:

          -    specific organic compounds

               specific inorganic compounds

               heavy metals

     The  form might also request the generator to  provide  a general  ranking  of
the waste in terms of its reactivity or ignitability.   Additionally,  if  the
generator knows of specific wastes that are  incompatible  with the  candidate
waste, he should be asked to list  them.  In  essence, the  generator  should  be
requested to provide any information possible to promote  successful  handling
of the candidate waste.

                                       5-20

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5.3.4.2  Generator Audits—
     Waste analysis is of utmost importance to successful operation  of  an
offsite facility.  In addition to requesting the generator to supply waste
analysis data or representative samples for analysis,  it  is recommended that
the facility owner/operator conduct an "audit" of the  waste generator's
facility.  A generator audit is possibly one of the most  thorough  and rigorous
methods of obtaining knowledge of the candidate waste  and its potential
variability.  The audit should be formulated to allow  the owner/operator to
inspect the waste generating process and plant and to  independently  assess
potential variability of the waste stream and chances  for errors or
inconsistencies in shipment.  The owner/operator should consider the results
of the audit in defining the stringency of contracts (i.e., allowable
tolerances for given waste characteristics) or other formal agreements  made
with the generator.  Although the scope of the audit will depend on  the waste
generating process and offsite facility design and operation, a  list of
applicable information which should be retrieved during an audit is  presented
below:

     •    Characterization of the waste generating process, including

               types and quantities (batch or rate) of raw materials,
               catalysts, and reagents

          -    processing information such as operating parameters and
               schedules

          -    contingency operating plans or use of other hazardous or
               nonhazardous materials which generate other hazardous
               components in the waste product

          -    routine variations in process operation

     •    Characterization of the waste

          -    average rate of production and variability of rate

               storage time onsite before shipment

          -    controlled or uncontrolled changes to waste during  storage

          -    method of waste shipment and provisions for access  to samples
               upon receipt at offsite facility

          -    all known waste analysis data or sources of data

               previous history of waste handling and  any remarkable incidents

     •    Characterization of other influencing factors at the plant

               other sources of waste which could be intentionally or
               accidently mixed with the intended waste product
                                      5-21

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               adequacy  of  procedures  currently used to manage other wastes
               generated onsite

          -    practices currently  implemented to avoid cross-contamination

     As part of the audit,  representative  samples should be collected and
analyzed.  For best results,  replicate samples should also be collected and
the number of replicates should  be  determined based on expected waste
variability.

5.3.4.3  Agreements Between Owner/Operator and Generator—
     Once the question of waste  variability has been answered by means of
sample analysis, the generator audit,  or by acquisition of historical or
published data, the affects of such variability on offsite facility operation
must be evaluated.  The magnitude of these impacts will depend on  the
constituents which vary, the range  of  variability, and the design  and
operation of the facility.   The  range  of potential effects to be considered
will expand with the complexity  of  the facility.

     Tolerance limits should be  specified  for measured waste components that
may adversely affect plant  operation.   These parameters or suitable indicator
parameters should then be considered for analysis upon receipt of  each
movement of waste from that particular generator.  Agreements made between the
generator and owner/operator should specify allowable  tolerances for accepting
the transported waste.  Additionally,  the  agreement should specify the steps
to be taken when the results of  waste  analysis at receipt  indicate waste
characteristics outside allowable tolerances.  For instance, procedures for
resampling and reanalyzing  the waste,  contacting  the generator, or rejecting
waste shipments should be specified in the agreement and  in the waste analysis
plan.

5.3.4.4  Characterization of Each Movement of Waste--
     The waste analysis plan must address  each movement of waste received at
your facility to assure consistency between the manifest  information and  the
waste movement; to assure that the  waste you receive from a particular
generator is the waste that you  expect to  receive, and to  assure that you
detect restricted wastes.  In the first case,  inconsistencies between waste
and manifest information may arise because of  accidental  or  intentional
mixups.  Since a waste movement  could  contain  a significant amount of waste
units (e.g., a flat bed truck carrying drums), the question arises as to  the
proportion of the waste which should be somehow screened  to determine
consistency of waste and manifest information.

     Wastes are typically nonhomogeneous.   Additionally,  waste  streams at  a
given generator location may be inadvertantly  or  intentionally  mixed, thus
causing  further uncertainty in waste characteristics.   Therefore,  each
movement of waste must be subjected to some degree of  waste  analysis  to verify
that it  possesses the characteristics  that the waste  from that  particular
generator is expected to possess.  Therefore,  the concept of  "fingerprint
analyses" is introduced in this section.
                                      5-22

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     You may have decided to restrict certain wastes  or waste  constituents
from your facility.  In all likelihood,  those which may have been selected  for
restriction typically exist is small concentrations or may be  easily masked by
mixing in other wastes.  Guidance is provided here to help plan for screening
to detect restricted wastes.

     5.3.4.4.1  Screening to Determine Consistency of Waste and Manifest
Information—One of the most important aspects of waste analysis at offsite
facilities is the need to characterize each movement of waste  to assure that
the information provided on the waste manifest correctly identifies the
waste.  The questions of most concern are the amount of sampling which must be
done and the inspections or analyses which should be conducted to assure that
these goals are achieved for each waste movement.

     The previously noted report by A. T. Kearney^ provides perspective on
this issue.  They report the results of a telephone survey conducted by
Mittelhauser Corporation to characterize sampling procedures used by
treatment, storage, and disposal facilities.  A summary of the responses
received from 10 sites is discussed below.

     Each facility sampled every shipment of waste received, and in fact, the
majority of facilities sampled every drum and bulk shipment received.  One
site samples 1 to 5 or more drums from each shipment depending on the total
number of drums.  Another site whose policy was to sample only 10 percent of
incoming waste indicated that 100 percent of the waste would be sampled
starting in 1983.  The purpose noted was to provide more safety in handling
and assure successful treatment in new treatment processes.

     The facilities noted that analytical parameters selected are heavily
dependent on the type of waste and the available waste treatment process.
Some representative parameters included TOG, pH, heavy metals, and solids
concentration.  To assess consistency between waste and manifest you should
consider visually inspecting the wastes for physical state, phase separation,
texture, color, and odor.  Applicable analytical procedures that may be
informative include pH and specific gravity.

     The A. T. Kearney report^ provides further perspective on the
advantages of sampling 100 percent of the wastes in question.   Clearly, any
time less than 100 percent of all wastes are sampled (for instance, less than
all of the drums in a single waste movement), there is a finite probability
that the unsarapled waste is different than expected, different from manifest
documentation, and/or different from the sampled wastes.  In the context of
drum sampling at offsite facilities, the report provides tabulated statistics
to determine the number of drums which must be sampled to estimate p, the
proportion correct (i.e., consistent with the manifest), with a confidence
level of A percent and an error bound of B percent assuming that an estimate
of the actual number correct, C, is known based on historical information.
The statistics ignore waste lot size (a method of correcting for waste lot
size is discussed below) and are reproduced here in Table 5-4 for the
conditions of 95 percent correct and 99 percent correct.  These percentages
correct are selected for the purposes of discussion only.


                                      5-23

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   TABLE  5-4.   SAMPLE SIZE REQUIREMENTS FOR  IDENTIFICATION OF WASTE MOVEMENTS
                             Source:  Reference 5.
                           Required Sample Size When
                          Proportion  Correct  (C)  =  95%
A
(Confidence
Level)
95%
96%
97%
98%
99%
B (Bound on Error)

10%
18
20
22
26
31

9%
22
25
28
32
39

8%
28
31
35
40
49

7%
37
41
46
53
64

6%
51
56
62
72
87

5%
73
80
89
103
126
                           Required Sample Size When
                          Proportion Correct  (c)  = 99%
A
(Confidence
Level)
95%
96%
97%
98%
99%
B (Bound on Error)

10%
4
4
5
5
7

9%
5
5
6
7
8

8%
6
6
7
8
10

7%
8
8
9
11
13

6%
11
12
13
15
18

5%
15
17
19
22
26

4%
24
26
29
34
41

3%
42
46
52
60
73

2%
95
104
116
134
164
     The data presented in the table serve to  illustrate the degree  of
certainty sacrificed if a decision is made to  sample and analyze less  than all
discrete units of waste in a waste movement.   Consider the statistics
presented in Table 5-4 for the required sample size when the proportion
correct is known to equal 99 percent.  If the  owner/operator were to sample
24 drums in the waste movement and find that  all tested were in conformance
with the manifest, he would then have 95 percent confidence that no  more than
4 percent (the bound on error) of the drums in the movement were inconsistent
with the manifest.  If 1 of the 24 tested drums proved inconsistent  with the
manifest, the proportion incorrect could then  be as high as 8.2 percent, i.e.,

[100 percent - (percentage correct (23/24 x 100) + bound on error (4 percent))].

In the case where 95 percent of the units are  historically correct,  the error
bounds for the noted conditions would be even  greater, between 8 to  9 percent.
To determine if abbreviated sampling or screening schemes are acceptable, the
owner/operator must show proof that the associated increased levels  of error

                                      5-24

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will not jeopardize adequate or safe operation of his facility.  If such an
abbreviated scheme is proposed, it should be fully documented and supported in
the permit application.

     It should be noted that these tables have been calculated assuming very
large shipments of drums.  A correction factor must be applied to determine
the required sample size for smaller shipments.  The adjusted sample size
required is computed as:

                                 , _ (N + l)n
                                nw - —-	
                                      N + n
where n* = adjusted sample size
      n = sample size for large shipments (from tables)
      N = number of drums in shipment.

Thus, for the example presented above, the required sample size of 24 drums
would be adjusted to 17 drums if the total shipment were only 50 drums, i.e.,

        (50 + 1)24   ,, _,
   i* = 	 = 16.54
        50 + 24
     5.3.4.4.2  Selection and Measurement of "Fingerprint Parameters"—To
determine that the wastes received are the expected wastes it is useful to
select  "fingerprint parameters" based on the initial waste characterization
for analysis after receipt of waste.  We refer to these parameters as
"fingerprint parameters" because we envision that they will be selected from
the more comprehensive population of analytical parameters originally tested
for, would be fairly simple to test during facility operation and receipt of
waste,  and testing of them would provide confidence that the waste is the
expected waste, meets all necessary specifications, and the waste can be
adequately stored, treated, or disposed of.  Fingerprint parameters should be
selected based on their unique ability to identify a waste, their variability
as noted during initial analysis, the affect of that variability on your
operation, and ease of detection.

     Sameness will be assessed based on expected variability, as well as waste
handling tolerances of the offsite facility, that is, the range of constituent
concentrations for a given waste that a facility can accept.  This allowable
range of concentrations will be determined based on the nature of the waste.
For instance, an inordinately high level of an otherwise acceptable
constituent may make the waste reactive or otherwise incompatible with wastes
disposed of in a given landfill cell.  Alternatively, if the pH of the waste
is greatly different than agreed upon (in a facility-generator agreement or
contract), the waste may be incompatible with storage tank materials or
surface impoundment liners.  A given movement of semisolid waste found to
contain free liquids may be unacceptable for receipt at a landfill which does
not operate with a liner and leachate collection system.

     Each movement of waste must be analyzed to the extent necessary to assure
that wastes received are consistent with conditions and characteristics
specified under agreements with the waste generator.  Attainment of this goal
rests on:

                                      5-25

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     •    Accurate  and  precise waste analysis before acceptance and receipt of
          waste;

     •    Accurate  knowledge  of  the range of variability of characteristics of
          a given waste;

     •    Sound knowledge  of  the impact  of waste  characteristic variability on
          facility  operation; and,

     •    Establishment of workable agreements  between waste  generator and
          owner/operator.

     To meet these  needs,  the applicant  should  implement a  strategy to select
and analyze "fingerprint parameters"  in  representative waste  samples collected
from waste movements during facility  operation.   In  Subsection  5.3.6.1.8, we
provide a detailed  example of the selection of  fingerprint  parameters for
testing of a pharmaceutical waste received at an  offsite landfill.  The
rationale for selecting the parameters  is presented  and  is  based  on the
initial waste analysis, the waste management  technique,  and ease  of analyzing
for the selected parameters.

     5.3.4.4.3  Screening for Restricted Wastes—Proposed  procedures  for
screening for restricted wastes  are an  important  aspect  of  your waste analysis
plan.  Apart from the issue of health hazard  that may  be induced  in the event
of an incident; for success in operation, you should consider the adverse
affect that restricted wastes might have on given operations  at your  plant.
For instance, if you operate a biological  treatment  plant  you would restrict
highly toxic constituents that would  upset  the  process,  or  you would  handle
such constituents in another manner.   The  selection  of restricted components
will depend on the  capabilities  and  limitations of operations at  your
facility, the existence or likelihood of highly toxic  or other undesirable
wastes in your market area; and  other factors such as  public  concern  or
comment.  In general, as the variety  of wastes  accepted  and the number of
waste sources increase, the concern  over and  control of  restricted wastes must
also increase accordingly.  In  developing  a  plan  for screening of restricted
waste, you should consider the  statistics  noted in subsection 5.3.4.4.1.   If
there is a waste constituent highly  likely  to be  generated  in your market area
and if your operation would be highly sensitive to unknowingly receiving  that
waste component, then it would be prudent  to  institute a screening procedure
for that component which includes sampling of all discrete waste  units
received in waste movements which have  any  likelihood  of containing  that  waste
component.  To determine the cost-effectiveness of instituting the complete
screen, you might balance the cost of sampling  and analysis versus revenue
lost if an incident were to occur at  your  facility or  if you were to  restrict
receipt of all waste from a generator whose waste might  be contaminated with
the unwanted constituent.  The  estimated cost of  sampling  and analysis  should
consider whether there is an applicable simple  indicator parameter for  the
restricted constituent or whether the specific  constituent must be detected
using a particularly sensitive  analytical  technique.  You  should  also consider
whether sample compositing would mask detection of the constituent,  thus
requiring collection and analysis of grab samples.


                                      5-26

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5.3.4.5  Waste Analysis Requirements for Ignitable,  Reactive,
         or Incompatible Wastes—
     As noted in §264.13, the applicant is required  to demonstrate waste
analysis methods he will use in showing compliance with §264.17, General
requirements for ignitable, reactive, or incompatible wastes.  Waste analysis
procedures for determining waste ignitability are fairly straightforward.
SW-8462 describes two methods for measuring waste ignitability, both of
which measure the flash point of the tested waste.  Method 1010 uses the
Pensky-Martens closed cup tester to determine flash  point for fuel oils, lube
oils, suspensions of solids, liquids that tend to form a surface film under
test conditions, and other liquids.  Method 1020 uses the Setaflash  Closed
Tester to determine the flash point of paints, enamels, lacquers, varnishes,
and related products.  It is important for the applicant to note the exact
procedure he will use to test flash point as a function of the waste type.
More importantly, however, he must present a logical plan for testing the
ignitability of generated wastes, or wastes received, to assure that no
adverse reactions will occur in handling ignitable wastes.  If ignitable
wastes will be accepted and rendered nonignitable, the applicant's plan must
be capable of documenting that treated wastes are, in fact, nonignitable.  The
plan must also account for specific requirements for ignitable wastes which
are noted in Subparts I through N of Part 264.  These requirements are
discussed further in remaining subsections.

     The applicant's planning for analysis of reactive or otherwise
incompatible wastes must be well conceived because of the enormity of waste
combinations which may be reactive.  Some of the best guidance currently
available on testing of waste compatibility are test plans and procedures
which have been developed to manage and handle potentially incompatible or
reactive wastes removed from CERCLA sites.  One such scheme, shown in
Figure 5-1,6 was implemented by GCA at an uncontrolled hazardous waste site
to characterize unknown wastes and could be used for segregating otherwise
reactive or incompatible wastes.

     Although this scheme, or some modification of it, may be applicable to
RCRA facilities, its primary purpose is to assure safety when dealing with
unknown wastes.  A complex facility which handles a  variety of wastes and
stores or treats these wastes in common locations may require more definitive
procedures for waste compatibility or reactivity testing.  Such a scheme is
currently under development by Acurex in support of  the EPA's Municipal
Environmental Research Laboratory.?  Test procedures and a test kit are
being developed to classify waste materials into reactivity groups (RGNs).
These reactivity groups are as specified by Hatayama, et al., in
EPA-600/2-80-076, A Method for Determining the Compatibility of Hazardous
Wastes.^  Once a waste is classified by its Reactivity Group Number, the
matrix provided in EPA-600/2-80-076 can be used to identify compatible and
incompatible waste combinations.  The currently defined reactivity groups are
shown in Table 5-5.  The compatibility chart is not  shown here, one reason
being that it is currently under revision.  Copies of the updated report will
be available from NTIS, the National Technical Information Service in
Springfield, Virginia.
                                      5-27

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                                             o
                                 WASTE
                                 CATEGORY
                                             O
                                                WASTE
                                                CATEGORY
                                 WASTE
                                 CATEGORY
1
SOLIDS
1
COMPOSITE
FOR FURTHER
ANALYSIS
p
QUEOUS
LIQUIDS
COMPOSITE
FOR FURTHER
ANALYSIS

1
OTHER LIQUIDS
1
TOX
ANALYSIS
Figure 5-1.
Example waste  characterization scheme.

Source:  Reference 6.
                             5-28

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                    TABLE 5-5.  REACTIVITY GROUP DEFINITIONS

                              So u re e :   Re f e re nc e  8.
React ivity
Group No.                             Reactivity Group Name
     1         Acids, mineral, nonoxidizing
     2         Acids, mineral, oxidizing
     3         Acids, organic
     4         Alcohols and glycols
     5         Aldehydes
     6         Amides
     7         Amines, aliphatic and aromatic
     8         Azo compounds, diazo compounds, and hydrazines
     9         Carbamates
    10         Caustics
    11         Cyanides
    12         Dithiocarbomates
    13         Esters
    14         Ethers
    15         Fluorides, inorganic
    16         Hydrocarbons, aromatic
    17         Halogenated organics
    18         Isocyanates
    19         Ketones
    20         Mercaptans and other organic sulfides
    21         Metals, alkali and alkaline earth, elemental and alloys
    22         Metals, other elemental and alloys in the form of powders,
                 vapors, or sponges
    23         Metals, other elemental and alloys as sheets, rods, moldings,
                 drops, etc.
    24         Metals and metal compounds, toxic
    25         Nitrides
    26         Nitriles
    27         Nitro compounds
    28         Hydrocarbons, aliphatic, unsaturated
    29         Hydrocarbons, aliphatic, saturated
    30         Peroxides and hydroperoxides,  organic
    31         Phenols and cresols
    32         Organophosphates, phosphothioates, phosphodithioates
    33         Sulfides, inorganic
    34         Epoxides
   101         Combustible and flammable materials,  miscellaneous
   102         Explosives
   103         Polymerizable compounds
   104         Oxidizing agents, strong
   105         Reducing agents, strong
   106         Water and mixtures containing water
   107         Water reactive substances
                                     5-29

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     In addition to determining the reactivity characteristics  noted  in the
scheme shown in Figure 5-1,   the test procedure recommended by  Acurex will
define specific waste classes and allow for complete categorization of wastes
according to chemical functionality.  Any or all of these procedures  can be
employed, depending upon the discretion of the analyst and the  completeness of
information required.

     The test procedures are organized into six series of tests,  each included
to provide specific information about the waste material.  In several cases,
results obtained at a specific stage in the testing sequence can  sufficiently
define the chemical characteristics of the waste material so that the need for
further testing is eliminated.  Each of the six procedure sets  is summarized
with a flow diagram which provides an overview of procedures involved in that
particular procedure set.  The six procedure sets are summarized  in Table 5-6.

     The full sequence of implementing these procedure sets to  identify
specific waste classifications is summarized in Figure 5-2.  The  Acurex
manual7 provides analogous diagrams for each procedure set along  with
descriptions and directions  for implementing specific test procedures.

5.3.5  Guidance on Preparing Waste Analysis Plans for Specific  Facility Types

     This subsection provides guidance on preparing waste analysis plans
suitable for specific facility types and suitable to address the  specific
waste analysis requirements  of regulations specified in Part 264, Subparts I
(Containers), J (Tanks), K (Surface Impoundments), L (Waste Piles), M (Land
Treatment), and N (Landfills).  Examples are presented in Section 5.3.6 to
illustrate the level of detail that the applicant is expected to  provide in
the waste analysis plan.  Although presented for specific facilities, the
discussions and examples cover the general requirements specified in  §264.13
for all facilities and for offsite facilities.

     Table 5-7 summarizes the waste analysis requirements for §264.13 and
identifies the objectives that the waste analysis plan must fulfill to assure
support of the facility specific standards  (Subparts I to N).  These  specific
standards implicitly require some type of waste analysis to identify
incompatible, reactive, or ignitable wastes; determine that wastes are
compatible with facility equipment liners, and surfaces; determine that
storage facilities are decontaminated at closure; and to fulfill several other
specific objectives noted in the table.  To illustrate the commonality and
overlap of these  specific facility standards and  to  indicate where
similarities in waste analysis plans will exist  for  different facility types,
we have summarized the noted regulations in Table 5-8.

     An abundance of  facility  specific scenarios  exist and cannot all be
specifically addressed by examples.  However,  review of  the examples presented
here should assist in preparing waste analysis plans for other types of
facilities not specifically addressed.  As  noted  earlier, the EPA is preparing
a Waste Analysis  Plan Guidance Manual which builds on the concepts and
examples presented here.  That manual will  be  available  in the spring of 1984.
                                       5-30

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        TABLE 5-6.  PROCEDURE SETS FOR CLASSIFYING HAZARDOUS WASTES BY
                    REACTIVITY GROUP NUMBER

                              Source:   Reference  7.
Procedure
  Set
Title
Information Obtained
           pH and Redox Tests
           Solution-Reactivity and
           Special Functionality Tests
           Flame Test
           Sodium Fusion and
           Ferrox Tests
           Organic Functionality Tests
           Inorganic Functionality Tests
                   Acidity, basicity, oxidizing and
                   reducing potential

                   Identification of sulfides and
                   cyanides,  reactivity and solubility
                   in acids and solvents, reactivity
                   with water, presence of water

                   Combustibility, classification as
                   organic or inorganic, identification
                   of explosives

                   Identification of oxygen, nitrogen,
                   phosphorous, sulfur, and halogen in
                   organic waste materials

                   Presence of specific organic
                   functional groups

                   Presence of elemental metals, heavy
                   metal compounds,  and inorganic
                   fluorides
                                     5-31

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Y
u>
                     LIQUID    ^\


                  SLUfm,  SLUDGE    j
                          ^
                  PROCEDURE SET 1
                  PROCEDURE SET ?
                  PROCEDURE SET 3
PROCEDURE
SET 6
                                                                         PROCEDURE SET 4
1
t
PROCEDURE
SET 6
                                                                         PROCEDURE SfI  5
                                 Figure  5-2.   Sequence of  procedure sets designed by  Acurex.



                                                 Source:   Reference 7.
START


SI OP

CONTINUE





PROCEDURE
                                                                                                                               RESULT

-------
    TABLE 5-7.   OBJECTIVES OF THE WASTE ANALYSIS PLAN BASED ON GENERAL AND
                SPECIFIC REGULATIONS
       Part 264 Citation
  Objectives of the Waste Analysis Plan
General Waste Analysis

    §264.13
•  Characterize the waste to assure that,
   after receipt,  the waste can and will
   be successfully treated, stored, or
   disposed of.

•  For offsite facilities, demonstrate
   waste analysis procedures for each waste
   movement to check for consistency between
   the waste and the waste manifest.

•  Assure that the initial waste analysis
   is reviewed or repeated on a routine
   basis, and on an as-needed basis if a
   change in waste characteristics is
   suspected.

•  Document waste analysis methods for
   characterizing incompatible, ignitable,
   or reactive wastes.
Subpart I -  Containers

    §264.172
•  Assure compatibility between the waste
   and the container.
    §264.175
    §264.176
    §264.177
•  Characterize leaks, spills, or accumula-
   ted precipitation in containment systems.

•  Document that wastes do not contain
   free liquids and, therefore, containment
   systems may not be necessary.

•  Identify containers holding ignitable or
   reactive wastes so that they can be
   located at least 15 meters (50 feet) from
   the property line.

•  Identify incompatible wastes so that they
   will not be placed in the same container
   unless the provisions of §264.17(b) are
   complied with.
                                   (continued)

                                      5-33

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                             TABLE  5-7 (continued)
       Part 264 Citation
Objectives of the Waste Analysis Plan
    §264.177
    §264.178


Subpart J - Tanks

    §264.192


    §264.197



    §264.198
    §264.199
Subpart K - Surface Impoundments

    §264.221
 Assure that containers to be used to
 store different wastes are adequately
 washed of previously held incompatible
 waste s.

 Demonstrate decontamination of containers
 and related equipment at closure.
 Assure compatibility between the waste
 and the tank.

 Demonstrate that all hazardous wastes and
 hazardous waste residue are removed from
 tanks and related equipment at closure.

 Demonstrate that ignitable or reactive
 wastes are no longer ignitable or
 reactive if placed in a tank and that
 §264.17(b) is complied with.

 Identify ignitable and reactive wastes to
 be stored in covered tanks in compliance
 with NEPA buffer zone requirements.

 Identify incompatible wastes so that they
 will not be placed in the same tank
 unless the provisions of §264.17(b) are
 complied with.

 Assure that tanks to be used to store
 different wastes are adequately washed
 of previously held incompatible wastes.
 Assure compatibility of wastes and
 leachates with liner materials.
                                   (continued)
                                      5-34

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                             TABLE 5-7 (continued)
       Part 264 Citation
  Objectives of the Waste Analysis Plan
    §264.228
•  Demonstrate removal or decontamination
   of waste residues and any contaminated
   components, soil, or other equipment at
   closure.
                                      Demonstrate the absence of free liquids
                                      if wastes are solidified at closure
    §264.229
    §264.230
Subpart  L - Waste  Piles
    §264.250
    §264.251
    §264.256
    §264.257
•  Document whether waste residues or
   contaminated materials are left in place
   at closure to determine if the post
   closure care requirements of §§264.117-
   264.120 apply.

•  Demonstrate that ignitable or reactive
   wastes are no longer ignitable or reac-
   tive if placed in a surface impoundment
   and that §264.17(b) is complied with.

•  Identify incompatible wastes so that they
   will not be placed in the same surface
   impoundment unless the provisions of
   §264.17(b) are complied with.
   Identify the presence of liquids or free
   liquids and determine if leachate can be
   generated through decomposition or other
   reactions if any exemption from §264.251
   is sought under §264.250(c).

   Assure compatibility of wastes and
   leachates with the liner and leachate
   collection system materials.

   Demonstrate that ignitable or reactive
   wastes are no longer ignitable or reac-
   tive if placed in a surface impoundment
   and that §264.17(b) is complied with.

   Document that incompatible wastes and
   materials are not placed in the same pile
   unless §264.17(b) is complied with.
                                   (continued)

                                      5-35

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                             TABLE 5-7  (continued)
       Part  264  Citation
  Objectives  of  the Waste  Analysis  Plan
    §264.257
    §264.258
SubpartM- Land Treatment

    §264.272
    §264.273
    §264.276
   Determine  if  wastes  and materials  in
   one  pile are  incompatible with  those  of
   another  pile  or  other  containment  facil-
   ity  so that  suitable physical separation
   can  be implemented.

   Assure that bases  to be used  to store
   wastes are decontaminated of  previously
   stored incompatible  wastes.

   Demonstrate  removal  or decontamination
   of waste residues  and  any contaminated
   components,  soil,  or other  equipment  at
   closure.

   Document whether waste residues or
   contaminated  materials are  left in place
   at closure to determine  if  the  post
   closure  care  requirements of  §264.310
   apply.
*  As part of the treatment demonstration,
   obtain waste analysis data to
   characterize the wastes and identify
   constituents listed in Appendix VIII of
   Part 261.

*  Obtain waste analysis data to assure
   proper control of soil pH, enhancement
   of microbial or chemical reactions, and
   control of moisture content in the
   treatment zone.

*  For facilities proposing growth of food
   chain crops, identify Part 261,
   Appendix VIII constituents reasonably
   expected to be in or derived from wastes.

*  Similarly, document the presence and
   concentration of cadmium in the waste
   and the pH of the waste and soil mixture,
                                   (continued)

                                      5-36

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                              TABLE  5-7  (continued)
       Part 264 Citation
Objectives of the Waste Analysis Plan
    §264.281



    §264.282



Subpart N - Landfills

    §264.301



    §264.312
    §264.313
    §264.314
 Demonstrate that ignitable or reactive
 wastes are no longer ignitable or reac-
 tive after incorporation into the soil.

 Assure that incompatible wastes are not
 placed in or on the same treatment zone
 unless §264.17(b) is complied with.
 Assure compatibility of wastes and
 leachates with the liner and leachate
 collection system materials.

 Demonstrate that ignitable or reactive
 wastes are no longer ignitable or reac-
 tive if placed in a landfill and that
 §264.17(b) is complied with.

 Determine if wastes in containers are
 ignitable.  If containers holding igni-
 table wastes are disposed of, determine
 that the disposal cells do not and will
 not contain wastes that generate heat
 sufficient to ignite the containerized
 ignitable waste.

 Assure that incompatible wastes are not
 placed in the same landfill cell unless
 §264.17(b) is complied with.

 Determine whether wastes are liquids or
 contain free liquids.

 Determine that liquid  wastes or wastes
 containing free liquids no longer contain
 free liquids if disposed of in a cell
 without a leachate collection and removal
 system.
                                   (continued)
                                      5-37

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                         TABLE 5-7 (continued)
   Part 264 Citation              Objectives  of  the  Waste  Analysis  Plan
§264.314 (cont.)                •   Determine  that  containers  which  once  held
                                  free  liquids  can be  placed in a  landfill
                                  cell  by  demonstrating  that free  standing
                                  liquids  have  been removed, that  they  have
                                  been  mixed with absorbent  or  solidified,
                                  or that  they  have been otherwise elimin-
                                  ated.

§264.315                       •   Determine  that  containers, other than
                                  small ones such as ampules, are  at  least
                                  90 percent full before disposal.

§264.316                       •   Demonstrate that wastes in lab packs  are
                                  compatible with the  inside containers of
                                  the lab  pack.

                               •   Determine  the  liquid contents of the
                                  wastes or  inside containers so that a
                                  sufficient quantity  of absorbent material
                                  can be placed  in the lab pack.

                               •   Demonstrate that the contained waste  and
                                  absorbent  material are compatible.

                               •   Demonstrate that incompatible wastes  are
                                  not placed in  the same outside container.

                               •   Determine  whether wastes in lab  packs are
                                  ignitable  or  reactive  and  if  so, whether
                                  they  are cyanide or  sulfide bearing
                                  wastes.
                                   5-38

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            TAB1,K  5-8.    Sl"MMARY  OF SPFT
                                                                         TOR WASTF  ANALYSIS  NOTED  IN  SUBPARTS  1  THROUGH  N
Corapat ibi L ity

  Waste and faci L itv mater i «
  Was to and wast f ( s * in •sarae
  Wa «;t P a rid w.g stel s ) nl , A-ppendix VI I L constituents
         Obtain  waste  analysis data to assure proper control  of
           pH, enhancement of microbia i or chemical  react ions,
           and control  of raoi st ut6 content in the treat me nt  zone
         For f ac 1 1 it les proposing growth of food chain crops,
           identify  Part 261, Appendix V LI I constituents
         Document  pre senc e and cortcentration of cadmiura  i n the
           was t e t  and  the pH of the waste and soi i ra ixt urc
         Document  that  containers, other than sma 11  ones  such  as a
           are 90% full before disposal
         Identify  cyanide- or sulf ide-heariog reactive wastes
                                                                                                                                    264,272
                                                                                                                                                   264.315

                                                                                                                                                   264.316

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5.3.6  Waste Analysis Plan Examples

     Examples are provided here to indicate the type of information permit
applicants should provide as well as the level of detail necessary to
interpret the adequacy of their proposed plans.  The examples provided are for
a hypothetical offsite landfill unit (part of a larger TSD facility), and an
onsite container storage facility.

5.3.6.1  Example:  New Offsite Landfill—
     It is expected that a high percentage of Part B applicants will be
pursuing permits for new offsite landfill units.  Therefore, we have
incorporated the following example to illustrate the associated waste analysis
plan application information requirements.  This example mirrors the level of
detail required to support the general facility standards for waste analysis
included in §264.13.  The landfill unit considered in the example is part of a
new offsite treatment, storage, and disposal facility.

     The example provided is not meant to be an entire waste analysis plan.
Components for which we provide examples include:

     •    Waste analysis parameters and rationale for selection

     •    Rationale for selection of additional parameters for specific waste
          streams

     •    Procedures for reviewing or repeating the initial waste analysis

     •    Waste analysis procedures for each waste movement, including:

          -    screening of all wastes for consistency with manifest and
               associated sampling methods

          -    procedures for documenting that  the received waste is the
               expected waste (fingerprint analyses and associated sampling
               methods)

          -    procedures for screening restricted wastes and associated
               sampling methods

     •    Procedures for accepting or rejecting waste movements

Other  important  components of a waste analysis  plan for this facility  that are
not  specified here  include:

     •    Specific  Quality Assurance/Quality  Control  Procedures

     •    Waste  Analysis Procedures for  Ignitable, Reactive, and  Incompatible
          Wastes

     •    Waste  Analysis Procedures for  Demonstrating Compatibility  of Wastes
          and Leachates with Landfill Liners
                                       5-40

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     5.3.6.1.1  Waste Analysis Parameters and Rationale for Selection—The  XYZ
Landfill is planned for location in East St.  Louis,  Missouri.   We expect  a
broad gamut of wastes; solid, sludge,  and bulk liquids; inorganic and organic
in nature.  As noted in our facility description,  our landfill units  will be
used for disposal of solids and semi-solids as they are received at the site
as well as residuals which are generated by our onsite waste treatment
processes.

     Disposition of wastes to different units at our facility will depend
primarily on generic waste classification as  noted in Table 5-9.  Most wastes
will undergo treatment of some type before landfilling.  However, solids  and
aqueous wastes with less than 40 percent water content will be directly
landfilled.

     [Note:  The applicant should include a detailed diagram to illustrate  all
     operations at the facility and the relationship of other units with  the
     landfill cell.]

     Waste parameters we will analyze for will depend on the classification of
the waste, disposition at our facility, and the specific industry generating
the waste.  Parameters that we have selected based on the first two factors
are presented in Table 5-10.  The rationale for selection of these parameters
is discussed below.  Additional parameters will be selected based on specific
waste types.  Discussion of selection of parameters for specific wastes also
follows.

     The parameters noted in Table 5-10 have been selected on the following
basis:

     •    pH, alkalinity, and acidity—These parameters will be tested in
          aqueous wastes, and sludges and slurries to determine the amount  of
          neutralizing agent required for treatment and the applicability of
          recovering acids or bases.  These parameters will be measured in  1:1
          water mixtures for solid wastes to determine compatibility of wastes
          and leachates with the PVC membrane liners to be used in our
          landfill cells.  Additionally, solid wastes with appropriate
          characteristics might also be used as reagents in portions  of our
          treatment system.  Significant changes in the pH, alkalinity, or
          acidity of aqueous wastes and sludges or slurries will influence
          treatability, cost of treatment, and types of residuals remaining
          after treatment.

     •    Specific anions and cations—These parameters will be characterized
          in aqueous wastes, slurries, sludge, or inorganic solid samples to
          account for major constituents or type of acid/base/salts present.
          Cyanide and sulfide will be measured at the ppm level because of
          possible reactivity during storage or treatment.  Changes in levels
          of specific anions and cations will affect treatment and disposal
          options.
                                      5-41

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                     TABLE 5-9.  DISPOSITION OF MAJOR  CLASSES OF WASTES  RECEIVED  ONSITE
Waste classification
                                                           Disposition
  Storage tanks
 for testing  and
further processing
Physical/chemical
    treatment
Incineration
Landfill
Aqueous

  >40% water
  [acidic, alkaline,
   and metallic]
  <40% water

Organic Liquids

  flammables
  combustibles
  solvents/degreasers

Sludges and Slurries

  organic
  inorganic

Solids
                     X [sludge  to  landfill]
                     X  [residue  to  landfill]
                    X  [residue  to  landfill]
                                               X [ash to  landfill]
                                               X [ash to  landfill]
                                               X [residue  to  landfill]
  organic
  inorganic
                                                                             X
                                                                             X

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TABLE 5-10.  ANALYTICAL PARAMETERS SELECTED FOR  GIVEN WASTE CLASSIFICATIONS
Waste classification
Waste analysis parameters
pH
Acidity/alkalinity
Anions /cat ions
Heavy metals
Solids/volatile solids
Water or liquid content
Free liquids
Viscosity
Specific gravity
Flash point
Reactivity group
TOX/TOC
Selected organics
Ash
Higher heating value
Aqueous
X
X
X
X
X
X

X
X
X
X
X
X


Organic
liquids



X
X


X
X
X
X

X
X
X
Sludges and
slurries
X
X
X

X
X
X
X
X
X
X
X
X
X
X
Solids
X
X
X


X
X


X
X

X
X
X
                               5-43

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Heavy metals--Heavy metals such as chromium, zinc,  copper,  lead,  and
others will be measured in aqueous and organic liquids to ppm levels
to determine treatability using hydroxide precipitation.   Sludge
from this treatment will be landfilled.

Solids and volatile solids—Type and concentration  of solids are
important for aqueous and slurry/sludge samples to  determine
treatability (i.e., incineration, biological, or phase separation)
and pump ing/Viand ling characteristics.  Significant  changes in solid
concentrations will affect treatment efficiency and may reflect a
change in the waste chemical composition.

Water content:—Water concentration will be measured to determine
whether wastes will be treated (>_40 percent water)  or directly
landfilled (<40 percent water).

Free liquids—Free liquids will be measured in drummed wastes to
determine handling procedures we should expect to implement if the
wastes are accepted.  If free liquids are present,  we will decant
and treat the liquids, or add absorbent to the containers holding
free liquids so that they are no longer in evidence.

Viscosity—Viscosity values will help determine the method of waste
handling, blending, and storage.  Highly viscous wastes may require
heating or special pumps for transfers.  Changes in viscosity may
affect handling and storage requirements or may indicate a change in
other waste characteristics.

Specific gravity—Specific gravity is selected because significant
changes are strongly indicative of changes in waste characteristics.
Specific gravity is important in determining settleability or
buoyancy of wastes in suspension, as well as treatability in other
process units.

Flash point—Flash point will be measured to determine waste
ignitability and, thus, necessary waste handling practices.  Bulk
ignitable solids will be rendered nonignitable before landfilling.
Ignitable wastes in containers will be landfilled in comformance
with the container disposal standards of §§264.312-264.316.
[Although incinerators are not specifically addressed in this
manual, ignitable organic wastes will be incinerated at this
hypothetical site and ash will be landfilled.]

Reactivity group—At full operation, we expect to receive a wide
variety of wastes at our facility.  Therefore, as a determinant of
waste acceptability (i.e., to assure that incompatible wastes are
not mixed) we will classify each candidate waste by reactivity group
(see Hatayama, et al., EPA-600/2-80-076).  Some of  the reactivity
groupings can be identified as a result of the parameters already
selected for analysis such as pH and flash point.   Thereafter,
however, other specific procedures must be implemented to classify a
                              5-44

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          waste into one of the current 41  reactivity  groups.   We  will  follow
          the test protocols currently recommended by  Acurex?  to determine
          waste reactivity groupings.

     •    TOX,  TOG—Wastes which are predominantly inorganic in nature  will be
          tested for total organic halogen  and total organic carbon content as
          an additional waste identification method.   Changes  in the organic
          content of inorganic waste may signal changes in the waste and may
          influence waste treatability.

     •    Selected organics—We will test all wastes which are potentially
          contaminated with PCBs or dioxins for PCBs and dioxin to determine
          if the wastes should be accepted  or rejected.  Other specific
          organics will be selected for analysis based on the waste under
          consideration, existing knowledge of the waste, information provided
          by the generator, and information gained during our visit and
          inspection of the generating facility.  Chlorinated and halogenated
          solvents or degreasers must be carefully screened to assure
          compatibility with our biological treatment  process.

     5.3.6.1.2  Rationale for Selection of  Additional  Parameters for
Characterization of Specific Waste Streams—To assure  that our waste analysis
plan is comprehensive enough to assure successful handling of all wastes, we
must select parameters for analysis based on specific  waste types.  We  have
attempted to determine the specific waste categories  and types that we  may
encounter by reviewing and compiling existing industry/waste statistical data
for the East St. Louis market area.  We have reviewed  results of surveys
conducted by the East St. Louis Waste Commission (ESWC) and the State of
Missouri Hazardous Waste Board (MHWB).  The results of our review are
presented in matrix form in Table 5-11, illustrating waste types and
associated industrial generators by 2-digit SIC code.

     Analytical parameters will be selected for specific wastes as a means of
identifying each waste by setting specification limits or tolerances on waste
components.  For instance, trichloroethylene sludge from an electrical
machinery manufacturer (SIC Code 34) will be tested for those parameters noted
earlier in Table 5-11, as well as for metallic species which are used in the
manufacturing process.  These constituents  will then be considered for  use in
identifying the waste based on their intrinsic variability, concentration,
ease of detection, and impact on sludge treatability.

     [Note:  The applicant should identify  test parameters for all specific
     wastes and the rationale for their selection if he currently knows or has
     foreknowledge of the identity of specific candidate wastes.  A tabular
     format is suggested to provide a concise presentation.]

     5.3.6.1.3  Procedures for Reviewing or Repeating  the Initial  Waste
Analysis—We routinely reanalyze generator's wastes on a quarterly basis.
Wastes which we receive less frequently than once every 3 months are
reanalyzed upon receipt.  Any time we repeat the initial waste analysis, we
analyze for all parameters originally selected.
                                      5-45

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                       TABLE  5-11.   SUMMARY OF WASTE SURVEY  ANALYSIS
       Waste categories and types
                                          Waste classification
                                                                             Two Digit SIC Code

                                                                  20   24   26  27  28  JO  33  34  35  36  39
Explosives

Flaromables

  Acetone
  Methyletnyl Ketone  (MKK)
  Isopropyl Alcohol
  Toluene
  Xylene
  Paint Solvent  & Thinner
  Stoddard Solvent
  Mixed Solvents & Oils
  Solvents
  Kerosene
  Turpentine
  Varnish
  Solvents & Solidified Faint
  Printers Ink
  Paint Filters

Combustibles

  Oils
  Oils Mixed with Halogenated Solvents
  Grease & Oils
  Paint Sludge
  Oil Sludge
  Solidified Paint
  Solidified Phenolic  Compounds
  Ink Residue

Halogenated Solvents & Degreasers

  Freon
  Hethylene Chloride
  Trichloroethylene
  Trichloroethylene Sludge

Chlorinated Hydrocarbons and Other
Synthetic Organics

  Herbicides
  Pest ic ides
Organic liquids
and sludges
Organic liquids
sludges, and solids
Organic liquids
and sludges
Organic liquids
                         X       X
                             X       X
                                                    X   X   X
                                                    XXX
                                                        X   X
                                                    XXX
                                                    XXX
                                                    XXX
                                                        X   X
                                                            X
                                         X    X   X   X   X   X   X
                                         XXX
                                         X    X   X   X   X   X
                                         X    X
                                         X    X       X   X       X
                                                    X
                                         X    X   X   X   X   X
                                                        X
                                                        X   X
                                                X   X   X   X
                                                    X
                                                 (continued)

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TABLE 5-11 (continued)

Waste categori.es and types
Cyanides & Isocyanates

Sodium Cyanide & Sludge
Acidic Hastes
Chromic Acid
Hydroflouric Acid
Hydrochloric Acid
Nitric Acid
Su If uric Acid
Acetic Acid
Ferric Chloride
Ammonia Persulfate
Solder Stripper
Acids
Alkaline Wastes
Spent Caustic
Alkaline Etchant
Spent Ammonia
Detergents
Metallic & Inorganic Compounds

Mercury
Heavy Metal Solution
Electro less Copper
Heavy Metal Sludge
Lead Compounds
Chromate Compounds
Zinc Compounds
Aluminum
Phosphorous Compounds
Sulfur Compounds
Two Digit SIC Code
Waste classification 20 24 26 27 28 JO 33 34 35 36 39
Inorganic liquids
and sludges
X X X X
Aqueous Inorganic
X X
X X X X
X
X
X
X
X
X
X
XX XXX
Aqueous Inorganic
X X X X X X X
X X
X
X
Aqueous Inorganic &
Inorganic Sludges &
Solids X XX
X
X
X XXX
X XX
X X
X X X X
X X
XX X
X

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     We also repeat the initial waste  analysis  on  a  contingent  basis  if we  are
informed by the generator that his production process  has  changed  or  if he
indicates a known change in the waste.  If we are  notified that the production
process has changed, we conduct a new  generator audit  and  reevaluate  our
original listing of analytical parameters for the  waste.   We then  conduct
applicable analyses, decide whether to continue to accept  the waste and define
new fingerprint parameters and tolerance bands, if necessary.

     If the generator informs us of a  known change in  his  waste, we will
conduct a new generator audit depending on the nature  of  the change.   In  any
€:vent,  we repeat all analyses which were conducted to  initially characterize
the waste and test for any new parameters which would  reflect the  known change
in the  waste.  We then reevaluate the  acceptability of the waste and  the  list
of fingerprint parameters and established tolerance bands.

     If any abnormality occurs at our  facility during  waste handling, such  as
fume generation or equipment deterioration or other incidents,  we  will repeat
the initial waste analysis for any waste or wastes which  are suspected to have
caused  the incident.

     5.3.6.1.4  Waste Analysis Procedures for Each Waste Movement—We will
implement a variety of waste analysis  procedures to characterize each waste
movement to document consistency between the waste and manifest, assure that
the waste we receive from a generator  is the waste we  expect to receive,  and
to screen out restricted wastes.  Although we require  all  generators  to notify
us of changes in wastes and although we fully reanalyze all wastes on the
basis noted above, we will implement a variety of  screening tests  applicable
to all  wastes, and specific tests dependent on waste type, on a routine basis
to assure fulfillment of these objectives.

     5.3.6.1.5  Waste Screening Procedures—To screen wastes and assure
consistency between a waste movement and the accompanying manifest,  we will
count all discrete units in the movement or weigh the entire movement,
depending on  the  type of containment used and the waste description  on the
manifest.  We will then visually  inspect and test all discrete  units  of  waste
in each waste movement.  We will  inspect all waste units   for physical state,
texture, visible  liquids, and  odor.  We will test all waste units by
collecting grab samples and analyzing them  for pH and specific  gravity.   Each
waste unit of a waste movement means  the  following:

     •     all drums or containers on  a  truck

     •     all accessible ports on a tank  truck

     •     all compartments  of  a  truck carrying bulk solids or  sludges

We will  collect representative samples  from all types of  waste  containers  upon
delivery using  the following  sampling equipment:
                                       5-48

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                     Waste type                   Sampling equipment

            Liquids and slurries                      COLIWASA

            Sludges                                   Trier

            Loose powders or granules                 Thief

            Packed powders or granules                Auger

            Large grained solids                      Large Trier

     5.3.6.1.6  Fingerprint Analyses and Sampling Methods—We will select
indicator or fingerprint parameters for specific wastes pending the results  of
the initial waste analysis.  Fingerprint parameters will be selected based on
their perceived ability to provide rapid and reliable evidence that the waste
received is the same as the waste expected within defined tolerance limits.
As a matter of course, any time we have not received a specific generator's
waste for more than 3 months, we will repeat the initial full analysis on a
representative sample taken from the waste movement.

     Sample types that we will collect for analyzing fingerprint parameters
will be waste specific depending on the sampling technique that was used to
initially characterize the waste and on the form of waste shipment.
Table 5-12 presents our general approach to defining sample types depending  on
waste classification and type of waste containment used in shipping.
Depending on the specific waste and generator,  we may vary this procedure, but
generally only to implement more stringent procedures.

     To further illustrate our proposed procedures and rationale for selecting
fingerprint or indicator parameters, we present the following discussion.

     [Note:  We have selected one example waste below and present narrative
     discussion to provide a clear indication of the information required in
     applications.  The applicant should provide enough examples to cover the
     full range of wastes expected to be received.  Furthermore, if a
     multitude of different wastes are accepted, you should rely on tabulated
     data and accompanying discussion to present a comprehensive plan for
     checking all waste movements.]

     We have contacted one generator who produces pharmaceutical intermediates.
Information which he supplied to us indicated that his waste contained a high
concentration of methylene chloride and other components such as heavy metals
(zinc, iron), sodium sulfates and p-dichlorophenol.  We subsequently obtained
four replicate representative samples during our visit to his facility.  The
parameters we selected for analysis and the quantitative results are shown in
Table 5-13.  These samples were collected over a period of 2 weeks during
normal plant operation.  Clearly, the waste characteristics are relatively
constant and any wide variation in any of the parameters upon further testing
will be indicative of a change in the waste.  Therefore, we will select
fingerprint parameters from the list in Table 5-13 on the basis of speed and
                                        5-49

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                      TABLE  5-12.   DEFINITION  OF  SAMPLE  TYPES  FOR  ANALYSIS OF FINGERPRINT  PARAMETERS
          Waste classification
                                          Drums
                                Types  of  containment used for waste movement

                                Large  containers             Open bed trucks
                                                                                                                       Closed  or  tank  trucks
          Liquids
          Slurries or sludges
          Solids
in
O
Grabs from 3  levels are
taken from 10% of dram?5
and are composited into 3
total samples for analysis

Grabs from at least 2
levels are taken from 10%
of drums,  and are com-
posited into  a minimum of
4 samples  for analysis

Grabs are  taken from one
of three different levels
in 10% of  drums.  At least
3 samples  are composited
from grab  samples taken at
equal levels  in different
drums
COL1WASA samples  are  taken   Not applicable
from 25% of  the containers
and are analyzed
As for drums  containing
slurries and  sludges
                                                             As for drums containing
                                                             solids
The truck is  divided  into
a 5 x 10 grid and  a random
sampling procedure is  used
to collect 5  samples  for
analysis

As for open bed  trucks
carrying slurries  or
sludges
                            COLIWASA samples are
                            taken from 3 sampling
                            ports for analysis
A trier is used  to
collect 2 replicate
samples from 3  sampling
ports.  The pairs are
composited for  analysis

As for closed or tank
trucks carrying  slurries
or sludges

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  TABLE 5-13.  RESULTS OF INITIAL ANALYSIS OF PHARMACEUTICAL WASTE3
Analytical
Parameters
pH
Alkalinity
Sodium
Sulfate
Zinc
Iron
Total Solids
Water Content
Viscosity
Specific Gravity
Flash Point
Reactivity Group No.
TOG
Replicate Sample Number
1
7.9
116
12,500
23,000
1.2
2.7
31,500
98.5%
0.95cp
1.09
185°C
106
2,900
2
8.3
125
12,700
18,500
2.0
2.7
34,000
96.1%
0.97cp
1.06
198°C
106
2,950
3
8.1
130
12,100
18,500
1.9
4.0
32,100
98.0%
0.97cp
1.05
197°C
106
3,650
4
7.9
118
13,000
18,600
1.7
1.8
32,600
97.4%
0.95cp
1.08
213°C
106
3,050
aResults are reported in mg/1 except as noted.
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ease of measurement,  as  influenced  by the  selected waste handling method.
Based on the waste analysis,  we will  treat this  waste  in our
physical/chemical/biological  treatment system which  incorporates solids
sedimentation,  activated sludge, and  polishing using granular  activated
carbon.  Considering all factors, we  have  designated the following  parameters
for fingerprinting this  waste:
          Fingerprint Parameters

             pH
             Specific gravity
             Total solids
             TOG
             Zinc
Concentration Tolerances

       8 + 0.8
    1.07 + 0.06
  32,000 + 6,500 mg/1
   3,000 + 1,000 mg/L
     <2.5 mg/1
In addition to being easy to measure, these parameters were designated as
fingerprint parameters for the following reasons:

     •    pH

          -    avoid handling strong acids or bases,  associated neutralization
               costs, and possible corrosion or reactivity problems

     •    specific gravity

               assure efficient settling upon treatment

          -    reliable indicator of waste change

     •    total solids
          TOG
               avoid treatment process upsets
               acts as indicator for methylene chloride, p-dichlorophenol,  and
               other water soluble organics
          Zinc
          -    avoid high zinc concentrations which could be toxic to
               biological mass in activated sludge process

     5.3.6.1.7  Procedures for Screening Restricted Wastes—We do not accept
explosives, radioactive wastes, or wastes contaminated with PCBs or dioxin.
We screen all waste movements for such constituents.  If wastes from a
particular generator do not exhibit these characteristics either historically
or based on the initial waste characterization, we implement the following
waste screening procedures:
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     •    Explosives—Three random samples  from a  bulk  waste movement or  three
          composite samples from random sampling of  25  percent of  the discrete
          units in a  waste movement are each  tested  for flash point  and
          flammability.

     •    Radioactivity—A Geiger Counter  is  used  to count  each  discrete  waste
          unit in a waste movement.  We walk  around  the full circumference of
          bulk waste  movements  with the detector to  determine the  presence of
          radioactive material.

     •    Dioxin and  PCBs—Two  random grab  samples are  taken from  the waste
          movement and dioxin or PCBs are detected using GC/MS.

     If historical information  or initial waste characterization indicates
that wastes may be contaminated with any restricted  components,  we implement
the following waste screening procedures:

     •    Explosives—Five random samples  from  a bulk waste movement or grab
          samples from all discrete units  of  the movement are tested for
          flashpoint  and flammability.

     •    Radioactivity—A Geiger Counter  is  used  to count  each  discrete  unit
          in a waste  movement.   For bulk waste  movements, we collect five
          random grab samples  for counting  after an  initial pass around the
          circumference  of the  waste carrier.

     «    Dixoins and PCBs—For waste oils  and  other waste  types that may be
          contaminated,  we collect 12 random  samples and composite them into
          4 samples for  detection of dioxin and PCBs using  GC/MS.

     5.3.6.1.8  Procedures for  Accepting or Rejecting Waste Movements—We will
reject wastes for the following reasons in  the  noted order  of priority:

     (1)  the waste movement and/or included  waste units are found to be
          inconsistent with the manifest information

     (2)  the waste movement is a restricted  waste or includes waste units
          that are restricted

     (3)  fingerprint analyses  indicate off-specification conditions.

In support of (1), we first visually inspect  the waste  and  conduct analyses
for pH and specific gravity.  If visual inspection or analysis  indicate no
discrepancies we proceed to check each waste  for restricted wastes.  If
discrepancies seem apparent based on visual inspection, we  postpone  a decision
to reject until after the wastes are screened for  restricted components and/or
fingerprint analyses  are conducted.
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     As noted earlier we do  not  accept  any  explosive  or  radioactive wastes, or
any wastes contaminated with dioxin  or  PCBs.   If  any  screening  test results
are positive for these components,  the  wastes  are immediately considered  for
rejection.  General procedures we  implement to reject a  waste are noted under
the discussion below for fingerprint analyses.

     Our last waste acceptance  test  procedure  is  testing for  fingerprint
parameters.  To illustrate our  overall  plan for selecting fingerprint
parameters, collecting samples,  conducting  analyses  and, ultimately, accepting
or rejecting the wastes based on the fingerprint analyses,  we continue the
example for the pharmaceutical  waste initiated earlier.

     [Note:  In your application,  you should include several  examples  to
     indicate procedures for a  representative  cross-section of  waste types.]

     After selecting the fingerprint parameters (pH,  specific gravity,  solids,
TOC, and zinc) for the pharmaceutical waste, we negotiated  a  contract  with the
generator which, among other things, set out requirements for information to
be noted on the manifest accompanying his waste.   We  have requested the
generator to identify his waste  as "aqueous pharmaceutical  waste—Control
No. AP974", to note the concentration tolerances  for  the selected five
fingerprint parameters, and to  specify  the  color (aqueous-turbid) and  odor
(solvent-methylene chloride) of  the  waste.   On a routine basis,  we ask all
generators to note on the manifest any  hazards in visually inspecting  wastes.
While one laboratory technician  visually inspects the waste,  a  copy of the
manifest will be taken to our onsite laboratory to assist in  locating  the
generator file and all necessary information  for conducting the fingerprint
analyses.  While visually inspecting the waste, collecting representative
samples, and analyzing collected samples, the  transport  vehicle is located in
a designated waste holding area until all fingerprint parameters have  been
analyzed and the acceptability  of  the waste shipment  is  determined.

     Waste AP974 is delivered in tank trucks.   To collect a representative
sample we use a COLIWASA sampler to collect three samples along three  vertical
transects located at the three  roof hatches on the tank  truck.   Two  of these
samples are analyzed for the noted fingerprint parameters and the third is
held for confirmatory testing if necessary.  If tested components are  within
specified tolerances for both samples,  the  waste is  accepted.   If any
components are outside allowable tolerance  bands, further analytical  testing
is required.  If only one of the tested samples shows a  deviation, an  aliquot
of that sample is tested along with the third  sample previously held aside.
If both samples are within tolerance bands, the waste is accepted; otherwise
the shipment is rejected and the generator  is  contacted  to resolve  the problem.

     If during original testing of the  first two of three collected  samples,
both tested samples indicate analytical results outside  the specified
tolerance bands for the fingerprint parameters, the waste shipment  is  rejected
and the generator  is contacted.
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     Once a generator is contacted for resolution of such a problem, we advise
him that his waste has been rejected because of determination of
off-specification conditions based on analysis of two or more representative
samples of his waste.  We will resample and reanalyze the waste only if
discussions with the generator present strong evidence that the waste has not
changed and that errors in shipment are unlikely.  Only then will we accept
the possibility that the originally collected samples were not representative
or that laboratory analyses may have been in error.  The shift supervisor will
then consult with the laboratory director on the advisability of resampling
and reanalyzing the waste as opposed to simply rejecting the shipment.

5.3.6.2  Example—Existing Onsite Containers—
     This example is provided to illustrate certain components of a waste
analysis plan for an existing onsite facility which stores wastes in
containers.  It is less comprehensive that the first example partly because
waste analysis plans for onsite facilities will generally be more
straightforward and concise than for offsite facilities.  This is envisioned
because onsite facilities will typically handle one waste type which they have
experience handling and whose characteristics they know fairly well.  In the
following example, we have highlighted components of the waste analysis plan
which support the specific facility standards of Subpart I, Use and Management
of Containers.  The example is intended to illustrate how related standards
would be supported in waste analysis plans for other facility types.  The
components addressed in the example include:

     •    Waste Analysis Parameters and Rationale for Selection

     •    Procedures for Reviewing and Repeating the Initial Waste Analysis

     •    Procedures for Characterizing Collected Leaks, Spills, and Runoff

     •    Procedures for Assuring Compatibility of Wastes with Container
          Materials and Equipment

     •    Procedures for Assuring Compatibility of Wastes with Water Residues
          in Previously Used Unwashed Containers

     •    Procedures for Documenting Waste Ignitability

     •    Procedures for Assuring Container and Equipment Decontamination at
          Closure

Other components that would be required in an actual waste analysis plan for
such a  facility include overall quality assurance procedures and specific
sampling and analytical methods.

     5.3.6.2.1  Waste Analysis Parameters and Rationale for Selection—The ABC
Company in Akron, Ohio is a chrome leather tanning operation.  Our plant
conducts "through the blue tanning" wherein we process raw and cured hides
into the blue tanned state but do not conduct retanning or wet finishing.  We
store solid wastes (more than 90 percent solids) generated in the process in


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eight butyl rubber lined portable containers  that  are  picked  up  and
transported to an offsite landfill once every 6 months.   The  solid wastes  are
a mixture of chrome trimmings,  shavings, and  buffing dust.  The  wastes  result
from manual trimming,  shaving,  and sanding of chrome tanned hides and contain
high concentrations of chromium and lead.  Results of  EP toxicity testing  have
indicated the following concentrations of chromium and lead:

          chromium                     35 +_ 6 mg/1
          lead                         17 +_ 10 mg/1

     [Note:  In an actual plan  of this type,  the applicant  should incorporate
     a diagram to illustrate the waste generating process and its
     interrelationship with the waste storage containers.]

For the past 18 months we have  been shipping  these waste containers  to the DBF
landfill in West Akron.  As part of our agreement with the  disposal  facility
and to check the consistency of the waste stream (higher concentrations of
chromium and lead are  indicative of process upsets, use of  excessive chromium,
or still other problems which represent economic loss),  we  collect  and analyze
two replicate samples  from each container once per month and  one week before
shipment.  The samples are analyzed in our fully equipped laboratory
(constructed and operated to assure proper operation of our wastewater
treatment plant) using the extraction procedure and the leachate is  analyzed
using atomic absorption spectrometry for chromium and  lead.

     We test an aliquot of each raw solid sample to determine percent solids
content and we use the paint filter method (47FR8311)  to determine  the
presence of free liquids.  The  DEF landfill will not accept wastes  containing
free liquids nor waste solids with a moisture content  more than 10  percent.

     We maintain all analytical data in our operating record  and report the
latest analytical results on the manifest form accompanying each waste
shipment to DEF.

     5.3.6.2.2  Procedures for  Reviewing and Repeating the Initial  Waste
Analysis—As noted, we analyze  replicate samples from each waste container
once per month and one week before shipment.   On a daily basis,  we  visually
check the containers to assess  separation of the solid and liquid  phase which,
based on past experience, indicates a liquid content of greater than
10 percent.  If we find this condition, we mix sand with the  waste  to assure
the absence of free liquids upon delivery to the DEF landfill.  We  also
reanalyze the waste on a contingent basis if we notice any fumes or haze in
the vicinity of the containers or if we perceive uncharacteristic  odors during
our daily inspection.

     5.3.6.2.3  Procedures for Characterizing Collected Leaks, Spills, and
Runoff—The container area is diked and the container lids are closed except
when wastes are added..  We generally experience no leaks, spills,  or runoff.
However, if and when we do, we will collect three representative samples of
resulting liquids as soon as we can gain safe access after the event.  We will
test the samples  for chromium,  lead, pH, TOC, and total solids.  If acceptable,


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the waste liquid will be pumped to our onsite wastewater treatment facility
for treatment.  If unacceptable,  we will notify  Haz  Clean in  West  Akron,  a
local spill control company.

     [Note:  In an actual plan of this type,  it  would be appropriate to fully
     describe the treatment process, its permit  status,  and note the tolerance
     bands for the noted constituents to determine their acceptability for
     treatment.]

     5.3.6.2.4  Procedures for Assuring Compatibility of Wastes with Container
Materials and Equipment—We store and transport  our  solid waste (more than
90 percent solids) in containers lined with butyl rubber.  Butyl rubber is
used because of its strong resistance to abrasion and to acids  and bases.   It
is chemically compatible with the solid wastes produced, i.e.,  no ignition,  no
corrosion, and no reactions ensue from normal handling procedures  employed  at
ABC Company.

     As further proof of waste/liner compatibility,  we are submitting herewith
raw test data from conducting EPA Test Method 9090 on two specimens of the
butyl rubber over a 4-month period.  The specimens were suspended in tubs
containing waste leachate generated using the extraction procedure.  Before
and after immersion we tested these samples for  tear strength and  resistance,
puncture resistance, other tensile properties, and hardness.  You will note
from the raw test data that the only significant difference noted after the
4-month period was the butyl rubber hardness.  However,  we have tested butyl
rubber in the presence of rainwater with a pH of 4.8 (close to  the EP pH) and
have noted the same changes in hardness.  Since  we typically  keep the
container lids closed, we are confident that  the container liners are fully
compatible with the contained wastes.

     [Note:  In an actual plan of this type,  raw test data should be provided
     along with a diagram of the test apparatus, and a description of the test
     procedures.]

     On a weekly basis, we visually inspect the  container lining.   A check  is
made for holes, pock marks, creases, abrasion or other signs  of deterioration.
Containers which have defects are relined or  discarded.   On a quarterly basis,
tests are conducted to determine the presence of other metallic compounds.   We
use the extraction procedure to generate a leachate  and analyze the leachate
for priority pollutant metals using ICAP.

     5.3.6.2.5  Procedures for Assuring Compatibility of Wastes with Waste
Residues in Previously Used Unwashed Containers—When the containers are
returned from the DEF landfill, we visually inspect  them to assure that no
residuals are visible and that the interior container surfaces  are completely
dry.  As part of our agreement with DEF, any  containers found to contain
residual material are returned to the landfill,  cleaned and rinsed, and
returned to us within 24 hours, all at DEF's  expense.  Each container has an
index number associated with it;  thus, the previous  constituents are known and
control is exercised over unauthorized use of the containers.  Since our
process generates a fairly consistent solid waste, incompatibility is
generally not a consideration.
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     5.3.6.2.6  Procedures  for  Documenting  Waste  Ignitability—Based upon
historical information,  operating experience,  and data, we  are confident: that
the wastes handled at the ABC Company are not  ignitable under the  guidelines
established under 40 CFR 261.21(a).   On  a quarterly  basis,  however, flash
point testing is conducted  as a precautionary  measure.  One representative
sample is taken from each container  for  flashpoint testing.

     5.3.6.2.7  Procedures  for  Documenting  Waste  Reactivity—During our
quarterly testing, in addition  to measuring waste flash point, we  also test
for water reactivity and the presence of cyanides or free cyanides.  We
conduct these tests to determine the likelihood of toxic  fume generation  in
the event of accidental contact of water with  the stored  wastes.

     5.3.6.2.8  Procedures  for  Assuring  Container and Equipment
Decontamination at Closure—At  closure,  we  will analyze samples  of container
rinse water to determine that the containers are  decontaminated.   Two  samples
representative of rinsings from each container will  be subjected to EP
toxicity testing to measure the concentration  of  chromium and lead.  If  the
results are below the EP toxicity limit  of  5 rag/1 for each metal,  we will
consider the containers decontaminated and  suitable  for disposal or other
uses.  If the EP toxicity limits are not supported we will follow one  of two
alternative procedures.  In all likelihood  we  will ship the containers to DEF
or another licensed hazardous waste landfill for  crushing and disposal.
Otherwise, we will fully rinse the containers  clean, collect the rinse water
in the container dike area, and analyze  the collected liquid as  if it  were  a
leak or spill.  If the analytical results  are  within required tolerance
limits, we will treat the collected rinse water in our wastewater treatment
facility.

     [Note:  In an actual plan, these tolerance limits should be specified.]

5.3.7  Ljist qf_Major Point s

     This subsection acts as a summary and will be useful to you in assuring
the completeness of your submittal.   It  can be used  to help plan,  prepare,  and
check the adequacy of your submitted waste analysis  plan.  The  listings  are
organized according to the following topics:

     •    General

     •    Offsite Facilities

     •    Onsite Facilities

     •    Containers

     •    Tanks

     •    Surface  Impoundments
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     •    Waste Piles

     •    Land Treatment

     •    Landfills

5.3.7.1  General—
     Your submitted waste analysis plan should explain the following factors
and procedures, regardless of your facility type, to demonstrate compliance
with the general standards of §264.13:

     •    Procedures and methods to obtain waste analysis data and develop all
          information necessary to treat, store, or dispose of the waste.

     •    Plan for and frequency of reviewing and repeating initial waste
          analyses

               on a routine basis, and

               on a contingent basis when the waste generating process
               changes, when the waste changes, or when the waste is suspected
               to have changed based on visual inspection or other routine
               testing.

     •    Parameters analyzed for in each waste.

     •    Rationale for selecting waste analysis parameters.

     •    Analytical test methods used.

     •    Representative sampling methods including number of samples; grabs,
          composites; timing of sample collection, and related information.

     •    Waste analysis results and information provided by generators (for
          onsite facilities, the waste analysis information you provide in
          your application will fulfill this requirement).

     •    Waste analysis procedures and methods for waste ignitability,
          reactivity, or incompatibility.

     •    Methods of quality assurance and quality control including
          consideration of the following factors, certain of which may be
          applicable in specific instances only:

          -    QA Organization and Responsibilities

               Representative Sampling Procedures

          -    Chain of Custody Procedures and Documentation

               Instrument Calibration Procedures
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          -    Analytical Procedures

               Data  Analysis,  Validation,  Reporting,  and  Recording  Procedures

               Internal QC Checks

               Performance and System Audits

               Preventitive Maintenance Procedures  and  Schedules

               Specific Procedures to Routinely Assess  Precision, Accuracy,
               Completeness, Compatibility, and Representativeness

               Corrective Action

It is recommended that  you include:

     •    schematic  diagrams whenever possible,

     •    summary charts, tables,  and figures whenever  possible.

5.3.7.2  OffsiteFaciliti.es—
     Your submittal  must demonstrate  procedures and methods  covering  the
following waste analysis factors and  components:

     •    Initial Waste Characterization

               submit information  provided by  the generator  including
               completed questionaires

               provide  blank questionnaires  if  your facility is new and you
               have  not yet received  such  information

          -    define generator visit, audit,  inspection,  or other  survey
               procedures and examples of  existing  results

          -    note  whether generator or your  personnel collect  the samples

               indicate selected waste analysis parameters and rationale for
               selection

          -    identify and describe  representative sampling methods

          -    specify  analytical  test methods  for  each waste and measured
               component

               identify the laboratory that  conducts  the  analyses

               note  procedures for reviewing and repeating the initial waste
               analyses, on a routine basis and on  a  contingent basis
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     identify procedures and agreements for receiving prior notice
     from generators of changes in the waste generating process  or
     in other procedures which would or could change the nature  of
     the waste

-    identify waste analysis procedures and methods for determining
     waste compatibility, including:

          methods to show compatibility with other wastes

          methods to show compatibility with equipment surfaces

          methods to show compatibility with liners and leachate
          collection systems, and

          methods to show waste treatability if the treated waste is
          considered non-hazardous after treatment

     note procedures for specifying allowable ranges on waste
     constituent concentrations

     identify procedures for rejecting wastes with component
     concentrations outside of the established tolerance levels  or
     for rejecting otherwise restricted wastes

     describe all quality assurance and quality control procedures

Screening of Incoming Waste Movements

     indicate waste analysis procedures for determining consistency
     between waste and manifest

-    specify analytical parameters and rationale for selection

     indicate procedures for documenting that selected tolerance
     bands are supported

-    describe nonanalytical waste characterization procedures such
     as visual inspections

     indicate procedures for identifying restricted wastes

-    indicate procedures for identifying discrepancies in the number
     of drums or in the weight or volume of bulk waste movements

     fully define representative sampling procedures including
     identification of samples taken in grab or composite fashion;
     the number of samples taken; use of random sampling or sampling
     of all discrete waste units
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     •     Evaluation of Waste Movements and Associated Analytical Results

          -     identify sampling, analytical, and decision team personnel

               define  criteria  and  circumstances  for waste acceptance,
               rejection, or reevaluation

               define  documentation and recording procedures

               define  procedures  implemented during and after decision  to
               reject  a waste

               document waste unloading procedures after waste acceptance

5.3.7.3  Onsite Facilities—

     o     Initial  Waste Characterization

               describe waste production processes including raw materials,
               end products, and  other  intermittent sources of waste

               identify historical  or published  information on the waste

          -     identify waste parameters for analysis  and  rationale  for
               selection

               identify any tolerances  or  other  restrictions on waste
               constituents

               waste  analysis procedures and methods  for  ignitable,  reactive,
               or  incompatible  wastes

               representative sampling  methods,  including  identification  of
               samples taken in grab or composite fashion;  the number of
               samples taken, use of random sampling  or  sampling  of  all
               discrete waste units

               analytical procedures

               indicate  procedures  for  reviewing and  repeating  initial  waste
               analyses  on  a routine basis and  a contingent basis

               identify  procedures  for  waste handling if waste  analyses
               indicate  conditions  outside of  established tolerance  bands or
               the presence of  restricted  constituents or wastes

               describe  all quality assurance  and quality control procedures
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5.3.7.4  Containers—
     Waste analysis  plans for storage of containers must address the
additional specific  requirements listed below:

     •    procedures to assure and document compatibility of waste and
          container

     •    procedures to characterize accumulations in containment systems

     •    procedures to detect free liquids

     •    procedures to identify ignitable, reactive, and incompatible wastes

     •    procedures to determine if containers which previously held wastes
          are contaminated with wastes not compatible with present wastes

     •    procedures to demonstrate decontamination at closure

5.3.7.5  Tanks —

     •    procedures to assure and document compatibility of waste and tank

     •    procedures to identify ignitable, reactive, and incompatible wastes

     •    procedures to document that tanks have been sufficiently washed of
          previously held wastes if new wastes would be incompatible with
          residual wastes

     •    procedures to demonstrate decontamination at closure

5.3.7.6  Surface Impoundments —

     •    procedures to assure and document compatibility of wastes and
          leachates with liner materials

     •    procedures to identify ignitable, reactive, and incompatible wastes

     •    procedures to demonstrate decontamination at closure, residual
          contamination at closure, or the absence of free liquids if wastes
          are solidified at closure

5-3.7.7  Waste Piles—

     •    procedures to detect the presence of liquids or free liquids

     •    procedures to assure and document compatibility of wastes and
          leachates  with liner and leachate collection system materials
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     •     procedures  to  identify  ignitable, reactive, and  incompatible wastes

     •     procedures  to  demonstrate  that bases have been decontaminated of
          previously  stored wastes which would be  incompatible  with new wastes

     •     procedures  to  demonstrate  decontamination at  closure  or  residual
          contamination  at closure

5.3.7.8  Land Treatment—

     •     procedures  to  obtain  waste analysis data for  Appendix VIII
          constituents as part  of the treatment  demonstration

     •     waste analysis procedures  selected  to  allow  for  control  of  soil  pH,
          enhancement of soil/waste  reactions, and control of soil moisture

     •     procedures  to  identify  Appendix  VIII constituents in  or  derived  from
          wastes for  facilities growing food  chain crops

     •     procedures  to  quantify  cadmium concentration  in  waste and  the  pH of
          the waste/soil mixture

     •     procedures  to  identify  ignitable,  reactive,  and  incompatible wastes

5.3.7.9  Landfills —

     •     procedures  to  assure  and  document  compatibility  of wastes  and
          leachates with liner  and  leachate  collection  system materials

     •     procedures  to  identify  ignitable,  reactive,  and  incompatible wastes

     •     procedures  to  detect  the  presence  of  liquids  or  free  liquids in
          wastes or free standing liquids  in waste containers

     •     procedures  to  demonstrate  that wastes  in lab  packs are compatible
          with inside containers

     •     procedures  to  assure  and document  compatibility  of containerized
          wastes and  added absorbents

     •     procedures  to  determine whether  waste in lab packs are sulfide and
          cyanide bearing wastes
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5.3.8  References

 1.  U.S. Environmental Protection Agency.  Background Document for 40 CFR
     Parts 264 and 265, Subpart B—General Facility Standards.
     Section 264.13—General Waste Analysis and Section 265.13—Interim Status
     Standards for General Waste Analysis.  U.S. EPA Office of Solid Waste,
     January 12,  1981.

 2.  U.S. Environmental Protection Agency.  Test Methods for Evaluating Solid
     Waste.  Physical/Chemical Methods.  SW-846.  Second Edition.  July 1982.

 3.  Ford, P. J., P. J. Turina, and D. E. Seely.  Characterization of
     Hazardous Waste Sites—A Methods Manual.  Volume II—Available Sampling
     Methods.  Prepared for Lockheed Engineering and Management Services under
     EPA Contract No. 68-03-3050.  Environmental Monitoring Systems
     Laboratory,  Office of Research and Development, U.S. Environmental
     Protection Agency.  March 1983.

 4.  U.S. Environmental Protection Agency.  Samplers and Sampling Procedures
     for Hazardous Waste Streams.  U.S. EPA Municipal Environmental Research
     Laboratory.   Cincinnnati, Ohio.  EPA-600/2-80-018.

 5.  A. T. Kearney, Inc.  Final Report under Contract No. 68-01-6515, Work
     Assignment R01-007.  Prepared for the U.S. Environmental Protection
     Agency.  December 1982.

 6.  Correspondence from GCA Corporation, GCA/Technology Division to U.S. EPA
     Region II, Office of Hazardous Waste Response.  November 17, 1981.

 7.  Spannagel, U., R. Whitney, and D. Wolbach.  Field Scheme for Determination
     of Waste Reactivity Groups.  Prepared by Acurex Corporation for the U.S.
     Environmental Protection Agency.  Presented in the Proceedings of the
     Ninth Annual Research Symposium—Land Disposal, Incineration, and
     Treatment of Hazardous Waste.  Fort Mitchell, Kentucky.  May 1983.

 8.  Hatayama, H. K., et al.  A Method for Determining the Compatibility of
     Hazardous Wastes. Prepared for the U.S. Environmental Protection Agency,
     Municipal Environmental Research Laboratory by the California Department
     of Health Services.  EPA-600/2-80-076, April 1980.  (Currently under
     review and revision by the American Society of Testing and Materials.)
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5.4  SECURITY

5.4.1  Regulatory Citations

     Information on security must be included in Part  B of  the  permit.
application, as specified in:

               "§270.14(b)(4)  A description  of the  security procedures  and
          equipment required by §264.14,  or  a justification demonstrating the
          reasons for requesting a waiver of this requirement."

     The regulatory requirements regarding security are contained  in  §264.14.
They are:

          "§264.14  Security.
               (a)  The owner or operator must prevent the  unknowing  entry,
          and minimize the possibility for the unauthorized entry,  of persons
          or livestock onto the active portion of his  facility, unless  he can
          demonstrate to the Regional Administrator that:
               (1)  Physical contact with the waste, structures, or equipment
          within the active portion of the facility will not injure unknowing
          or unauthorized persons or livestock which may enter the active
          portion of a facility; and
               (2)  Disturbance of the waste or equipment,  by the unknowing
          or unauthorized entry of persons or livestock onto the active
          portion of a facility, will not cause a violation of the
          requirements of this Part.
               (b)  Unless the owner or operator has made a successful
          demonstration under paragraphs (a)(l) and (a)(2)  of this Section,  a
          facility must have:
               (1)  A 24-hour surveillance system  (e.g., television monitoring
          or surveillance by guards or facility personnel)  which continuously
          monitors and controls entry onto the active portion of the  facility;
          or
               (2)(i)  An artificial or natural barrier (e.g., a fence  in  good
          repair or a fence combined with a cliff), which completely  surrounds
          the  active portion of the facility; and
               (ii)  A means to control entry, at all times, through  the gates
          or other tintrances to the active portion of the  facility (e.g.,  an
          attendant, television monitors, locked entrance,  or controlled
          roadway access to the facility).
               (c)  Unless the owner or operator has made a successful
          demonstration under paragraphs (a)(l) and (a)(2)  of this Section, a
          sign with the legend, "Danger—Unauthorized Personnel Keep  Out,"
          must be posted at each entrance to  the active portion of a  facility,
          and  at other locations, in sufficient numbers to be seen from any
          approach to this active portion.  The legend must be written in
          English and in any other  language predominant in the area
          surrounding the  facility  (e.g., facilities  in counties bordering the
          Canadian province of  Quebec must post signs  in French; facilities in
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          counties  bordering Mexico  must  post  signs  in  Spanish), and must be
          legible from a distance  of at least  25  feet.   Existing signs with a
          legend other than "Danger—Unauthorized Personnel  Keep Out" may be
          used if the legend on the  sign  indicates that  only authorized
          personnel are allowed to enter  the active  portion,  and that entry
          onto the  active portiop  can be  dangerous."

5.4.2  Guidance to  Achieve the Part  264 Standards

5.4.2.1  General—
     The intent of  the §264.14 requirements  is to keep  unauthorized people and
livestock out of the active portion  of the facility.  In order  to comply with
the requirements of §264.14,  you must:

     •    Prevent unknowing entry  of persons or livestock  to active portions
          of the facility.

     •    Minimize  unauthorized entry of  persons  or  livestock to active
          portions  of the facility.

     In order to qualify as adequate, the security measures  described in your
application must include:

     •    A 24-hour surveillance system and  signs around the active portion of
          the facility, or_

     •    Artificial or natural barriers  with  controlled access points  and
          signs around the active  portion of the  facility.

     However, you may request a waiver of these requirements if you can make  a
demonstration in Part B of your permit application that unknowing  or
unauthorized persons or  livestock would not  injure themselves or  cause  a
violation of your permit upon entering the active portion of the  facility  (see
§264.14(a)(1) and  (2)).  Additional   information on exemptions or  waivers  is
presented later in this discussion.

5.4.2.2  Surveillance System or Barrier  and Controlled  Access—
     As indicated  in §264.14(b), the security  procedures and equipment  must
provide a means for controlling entry to  the active portion of the facility.
The  intent is that there should be a finite number of entrances into  the
facility and that  attempted or  inadvertent entry  to the facility at  points
other  than the identified, controlled entrances will be physically hindered
or,  at  least, immediately  identified.

     If some type  of 24-hour surveillance system is or  will be utilized to
monitor and control entry  to the active  portion of the  facility,  the  permit
application should describe it  in detail.  All related  structures and
equipment should be indicated on a plot  plan.   All facets of the  system,
including personnel, procedures, structures, and equipment used should  be
described, and if  possible, demonstrated  on the plot plan.
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     Example:

          "Security  at  this Company  is maintained by a staff of trained
     security  guards, who  primarily monitor entry and exit from the active
     portion of  the;  facility and provide security measures within the plant
     premises.   The  only authorized  entry point is at the east end of the
     facility.   Personnel  and vehicle entry at that point are controlled by
     gates operated  by  remote control from the guard house.  The guardhouse is
     occupied  by two armed guards  24 hours a  day, 7 days a week, except during
     plant shutdowns for holidays, at which time the gate remains locked and
     only one  guard  is  on  duty.  Guards normally work an 8-hour shift with a
     crew of six guards per day.   There is a  six-foot high chain-link fence
     along the entire eastern side of the  facility.  There are no physical
     barriers  on the north, south  and west sides of the facility.  Once each
     hour, a guard walks  the entire  facility  perimeter and makes a walkthrough
     of the facility.  The security  facilities and the guard's patrol route
     are shown on plot  plan xyz."

     If a fence or wall is used  to control entry,  the height,  type of material
and any locking devices should be  presented  in the permit application.  The
procedures and equipment  used  to control  entry must be presented in  your
application, and, if appropriate,  a  description of any natural barriers should
be provided.

     Examples:

     •    Barrier.  A 7-foot high, chain-link fence with  two  lockable gates  is
          constructed around  the container storage area  to restrict
          unauthorized entry  and to  prevent  drums  from being  washed  downstream
          in the event  of a minor  flood.   (See plot plan  xyz).

     •    Means to Control Entry.  Entry  to  the  facility  is  controlled  by  two
          armed guards  stationed at  the main entrance gate.   Employees  are
          required  to show identification cards when  reporting for work,  and
          visitors and  contractors entering  the plant must  sign  a  log sheet
          and obtain visitor  passes.  (See plot  plan  xyz).

     •    Use  of Natural  Barrier.   The  hazardous waste  facility  is located
          entirely within xyz's  operating facility.   The  facility  is enclosed
          by a  fence and the  Michigan River  with  limited  access  provided  by
          24-hour guarded gates.  (See  plot  plan  xyz).

     Although §270.L4(b)  mentions  specific equipment  and  procedures  that  must
be part of security at a facility, the  intent of  §270.14(b) (4)  is  that  a_ll_
procedures and  equipment which contribute to facility  security should be
described.

     Example:

          "In addition to the general security provisions of fencing,  gates,
     and  guards, several other features contribute to the safety and security
     of  the facility.  Ample lighting is provided throughout the site,  and
     guards and operators are equipped with hand-held,  two-way radios to

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     report upset conditions immediately.   In  addition to  the  two-way  portable
     radios carried by guards and  operators, a base  station  for  the public
     address system is located in  the plant manager's  office.  An  internal
     telephone system (with phones in most  plant  areas)  is provided.   The same
     telephone system is used for  communication outside the  plant."

     It is important to note that  the requirements of  §264.14(b) are satisfied
if the active portion is located within a  facility or  plant  which  itself has  a
surveillance system, or a barrier  and a means  to  control entry,  which  complies
with the requirements of §264.14(b).   Thus, a  separate security  system around
only the active portion may not be required.   However,  the requirements for
signs around the active portion, as discussed  below, would still be applicable.

5.4.2.3  Signs-
     Regardless of the methods employed to  limit  entry to  the  active portion
of the facility, the owner or operator must post  signs in  accordance with the
requirements of §264.14(c).  There are four requirements  for any signs.  They
are:

     •    A legend which makes it  plain that unauthorized  persons  are  in
          danger and are not allowed  into the  active portion of  the facility.

     •    Legibility from a distance  of at  least  25  feet.

     •    Visibility from any approach to the  active portion of  the facility.

     •    Legend in English and in any other language  predominant  in the area
          surrounding the facility.

In §264.14(c), the legend "Danger-Unauthorized Personnel Keep  Out" is
suggested.  However, any legend that  makes  it  clear  that  danger  exists and
entry authorization is required is acceptable.  A sign with  a  symbol alone  is
not sufficient, a written legend is also necessary.

     The legibility of any sign will  depend on the viewing conditions  and the
size and shape of the letters.  A  reputable industrial safety  sign
manufacturer is likely to be your  best source  of information on  the  legibility
of a particular sign or legend at  25  feet.   The American National  Standards
Institute's standard ANSI Z35.1 "Specifications for  Industrial Accident
Prevention Signs" may also be of assistance.   The sign colors, dimensions,  and
the height of the letters on the proposed  signs should be  identified  in the
application.  If the stroke-to-width ratio  of  the letters  is available it
should be considered for inclusion in the  application.

     The signs should be placed at all entries to the  active portion of the
facility.  In addition, they should be placed  at intervals around  the
perimeter of the active portion such that  they are visible from  all  angles  of
approach.  The spacing and location of the  signs should be stated  in  the
permit application.
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     The need to include the legend on the  sign in a  language  other  than
English will depend on the predominance of  another language  in the area  of  the
facility.  The posting of two signs in different languages close  together  is
acceptable, provided that they both meet the legibility and  visibility
criteria.  Facilities in counties  bordering Quebec Province  are required to
choose French as the second language and those bordering Mexico must choose
Spanish.  In some areas, it may be necessary to post  signs  in  English and  more
than one other language.

     Example:

          "The signs to be posted  will bear the legend 'Danger - Unauthorized
     Personnel Keep Out".  They are diamond-shaped and measure 10 inches on
     each side.  The letters will  be two inches high  and will  be red on  a
     reflective white background.   The manufacturer estimates  they are  legible
     in daylight at distances to 50 feet.  Identical  signs  bearing  the  same
     legend in French will be posted next to each English sign.  The signs
     will be posted at each vehicle and personnel access point and  attached to
     the facility perimeter fencing at corners and at 75-foot  intervals  (see
     plot plan xyz)."

5.4.2.4  Exemptions/Waivers —
     The provisions of §264.14(a)  provide that you may request an exemption/
waiver from the security provisions in §264.14(b) and (c).   If you  believe a
waiver of any of the requirements  of §264.14 is appropriate, you must
demonstrate that unknowing or unauthorized persons or livestock would not
injure themselves or cause a RCRA violation upon entering the active portion
of your  facility.  Both these points may be demonstrated by showing  that the
nature and duration oE the hazard  potential from the hazardous waste on site
does not warrant the required security procedure or equipment.  In  addition,
if you can show that your facility provides certain features,  such  as cover
materials or containers, that would prevent contact with equipment  or
structures, certain security procedures and equipment might  not be  needed.
Finally, a waiver justification could show that safety or operating practices
related  to equipment and structures would eliminate the potential for an
Intruder to cause a spill, mix incompatible wastes, ignite ignitable wastes,
damage containment or monitoring systems, etc.  The circumstances under which
a waiver will be granted are limited.

     The following are  two examples of facility scenarios where a waiver of
security has been requested.

     Example 1:

           The  permit applicant has stated that  the landfill does not have a
     security  system and has requested a waiver from that requirement.   The
     following  reasons have been provided as justification in  support of the
     request;
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     •    Landfill is in a remote,  relatively unpopulated  region.

     •    Six inches of  cover  material  is  applied  daily.

     •    Wastes are toxic as  determined by the extraction procedure  (EP)
          of Appendix II,  40 CFR 261, with greater than  100 times  the
          drinking water standard of chromium.

     •    Precautions have been taken at the facility to  protect
          equipment and  structures from unauthorized operation or
          tampering.

          It is likely that the EPA would  judge this demonstration to be
     inadequate.  Although the facility is located in a  remote area,  the
     potential still exists for a person or animal to gain access  to  the
     active portion of the facility. Such unauthorized  entry  may  be
     unlikely to result  in injury,  since chromium is not  usually  toxic on
     contact.  However,  the potential exists for the disturbance of cover
     materials, resulting in a hazard.   This would indicate the potential
     for violation of the permit.  The  facility could be  required  by  the
     Regional Administrator to install  adequate security  or increase
     depth of cover.

Example 2:

     The permit applicant has  stated that  the waste pile  does  not  have a
separate security system,  only the security system for the plant as a
whole, and has requested a waiver from  the requirement for a security
system.  The following reasons have been provided  as justification in
support of the request;

     •    Waste pile is  located onsite  at  a chemical manufacturing
          complex.

     •    Waste pile is  covered by a secured tarpaulin.

     •    Physical analysis shows that  waste dries to a  consolidated,
          concrete-like mass.

     •    Precautions have been taken at  the facility to  protect
          equipment and  structures from unauthorized operation or
          tampering.

          In this case,  it is  likely that  EPA would judge the
     demonstration to be adequate.   Although unknowing or unauthorized
     entry to the waste pile has not been  prevented, physical  contact
     with the waste material would be unlikely to  result  in injury of the
     intruder.  Further, due to the consistency of the waste,  it  is
     unlikely that tampering with the tarpaulin covering  the material
     will result in violation  of standards.

          For your convenience, Table 5-14 provides examples of criteria
     for determination of exemption.

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                                              TABLE  5-14.    CRITERIA FOR A DETERMINATION  OF EXEMPTION
                                                   Favorable  Factors                          Principa I Tools for
                    Category                         for  txenipt ion                               Determination                         Areas or  Judgement
            De term mat ion oi Haaard      Phy steal contact  with wast e will           Rev ie w of cheniica ± and physical            Evaluation of" class  of  hazard
            to Intruder                  not result HI in )ury                       analyses of waste sample                   and degradation

                                                                                   Identification of hazard properties
                                                                                   of waste based on available literature

                                                                                   Determination of length of t ime wast*;
                                                                                   is hazardous
            Det erm mat ion of Risk of     An i nt rude r could  no t c ause a spill        Re view ot pe nnit application for con-      Det e rminat ion tnac  i at ruder actions
            Vi olating Other Standard s                                              ditionssuchas.-  wasteeonsistsof        would not re suit  in a violation
                                                                                   3 soliditied and relatively immovable
                                                                                   mas s, or waste containers are securely
                                                                                   sealed and valves are protected from
                                                                                   taifipe ri ng

                                         An. intruder could  not nnx  i acoropat ib le     Review of permit application tor condi-
\j\                                       wastes nor ignite  ignitaolc wastes         tionn such dS   cue absence of these
 1                                                                                  typesofwastesatthefaciiity, or
                                                                                   ignitable wastes are covered in a
fs-S
                                                                                   manner tnat wouid prevent contact witn
                                                                                   ignited materials such as matches or
                                                                                   ciga ret tes

                                         An i n Cruder cou 1 d  not damage con tain-"      Review of permit application for con-
                                         iflent or monituri o^  equipraynt in a          difions such as   LnacCK^s^bility of
                                         marine t that would  c^use a  violation        structures to i nt rude rs -,  protection
                                                                                   ot rrsemttonng equipnent by locked
                                                                                   housing

                                         Genera i inaccessability ot wastes          Review of perm it application to de™
                                         reldting to management strategy            t ermine the presence of nat ura I and
                                         (e.g., deep hurialf covered tank)          man^m.-ide Carriers

                                         Vehic Les and structures are pro-           Review of pen\!it application tor           Determination that  contact with
                                         tected irora unauthori^ed operation         satety prac tice&, such as locKing          equipment or structures wouId not
                                         or tampering                              of vehicle ignitions or storage of         result in int ruQer  injury or vio~
                                                                                   vehicles in locked garages                 1 at ion of standards

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5.4.2.5  Post-Closure  Security—
     Subpart G of Part 264 contains security requirements  at  disposal
facilities during the  post-closure  period  in §264.117(b).   All  applicants
should read those requirements to determine if they are applicable to  their
facility.  Post-closure security  requirements should be addressed  in the
post-closure plan required by §264.118.

5.4.3  List of Major Points

     1.   Which option under §264.14(b)(1) or (2)  will be  used?

          (a)  Where is the gate  or barrier with means to  control  entry?   How
               is barrier situated  in relation to  the active  portion of the
               facility?  Provide plans.

          (b)  If 24-hour surveillance is  used,  describe in detail.  Provide
               plans.

     2.   Where are the Danger Signs posted - in what language, are they
          described?  (§264.14(c))

     3.   Will any other security procedures be used e.g., lights, dogs,  etc.
          (§270.14(b)(4))

     4.   If applying for a waiver, was  a  case made to demonstrate compliance
          with §264.14(a)(l) and  (2)?

     Additional background discussion on the security requirements of  §264.14
is available in the preamble on security in the  May 19, 1980  Federal Register
at page 33180.
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5.5  INSPECTIONS

5.5.1  Regulatory Citations

     Information on inspection schedules must be included  in Part  B  of:  the
permit application, as specified in:

               "§270.14(b)(5)   A copy of the general inspection schedule
          required by §264.15(b);  include where applicable;  as part  of  the
          inspection schedule, specific requirements in §§264.174,  264.194,
          264.226, 264.254,  264.273,  264.303, and 264.347."

     The regulatory requirements regarding inspections are contained in
§264.15(b) and, depending on the type of facility, additional requirements  are
in the sections of the regulations noted at the end of §270.14(b)(5).
Although §270.14(b) references only paragraph (b) of §264.15, the  entire
§264.15, General Inspection Requirements, is presented below, since the
requirements of all four paragraphs,  (a) through (d), will have to be
addressed in your  inspection plan.  The §264.15 regulatory requirements are:

          §264.15  General inspection requirements.
                (a) The owner or operator must inspect his  facility for
          malfunctions and deterioration, operator errors, and discharges
          which may be causing—or may lead to—(1) release of hazardous waste
          constituents to the environment or (2) a threat  to human health.
          The owner or operator must conduct these inspections often enough to
          identify problems in time to correct them before they harm human
          health or the environment.
                (b)(l) The owner or operator must develop and follow a written
          schedule for inspecting monitoring equiment, safety and emergency
          equipment,  security devices, and operating and structural equipment
          (such as dikes and sump pumps) that are important to preventing,
          detecting,  or responding to environmental or human health hazards.
                (2) He must keep this schedule at the facility.
                (3) The schedule must identify the types of problems (e.g.,
          malfunctions or deterioration) which are to be looked for during  the
          inspection  (e.g., inoperative sump pump, leaking fitting, eroding
          dike , etc.).
                (4) The frequency of inspection may vary for  the items on the
          schedule.   However, it should be based on the rate of possible
          deterioration of the equipment and the probability of an
          environmental or human health incident if the deterioration or
          malfunction of  any operator error  goes undetected between
          inspections.  Areas subject to spills, such as loading and unloading
          areas, must be  inspected daily when in use.  At a minimum, the
          inspection  schedule must include the terms and frequencies called
          for  in  §§264.174, 264.194, 264.226, 264.253, 264.254, 264.303, and
          264.347, where  applicable.
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               (c)  The owner or operator must  remedy any  deterioration  or
          malfunction of equipment  or structures which  the  inspection reveals
          on a schedule which ensures that  the problem  does not  lead  to an
          environmental or human health  hazard.  Where  a  hazard  is  imminent  or
          has already occurred, remedial action must be taken  immediately.
               (d)  The owner or operator must  record inspections  in an
          inspection log or summary.   He must  keep these  records  for  at least
          three years from the date of inspection.   At  a  minimum, these
          records must include the  date  and time of the inspection, the name
          of the inspector, a notation of the  observations  made,  and  the date
          and nature of any repairs or other remedial actions.

     The EPA will evaluate your inspection  schedule along with  the  rest of
your inspection plan and your entire  Part B submittal to  insure  that  it
adequately protects human health and  the environment.   As part of that  review,
EPA may request modification or amendment to the inspection schedule, as may
be necessary.

5.5.2  Guidance to Achieve the Part 264  Standards

5.5.2.1  General—
     The intent of the §264.15 requirements and  the facility-type specific
requirements on inspections is to insure that  all  owners  and operators  have
identified key pieces of equipment  and areas of  their operations  where
scheduled inspection will minimize  equipment failure which  could  lead to
endangerment of public health or the  environment.   By requiring  the
development and submittal of an inspection  schedule, the  Agency  intends to
insure that all hazardous waste facilities  are closely  monitored  by their
owners and operators so that they will continue  to function as designed
throughout the active lives and, when applicable,  the post-closure  periods.

     In order to comply with the requirements  of §264.15(b) you must;

     •    Have and follow a written inspection schedule.

     •    Keep the schedule at your facility.

     In order to qualify as an adequate  inspection schedule your  submittal
must;

     •    Identify the specific equipment to be  inspected.

     •    Identify how each item will be inspected.

     •    Contain a justifiable frequency for inspecting  each  item.

     •    Contain a schedule for additional inspections required  by the
          regulations depending on  the type of facility you are  operating.
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     The additional  inspection  requirements  for  specific  types  of  facilities
can be found in the  sections listed at  the  end of  §264.15(b)(4).   They  are;

     §264.174 - Inspection of Containers

     §264.194 - Inspections of  Tanks

     §264.226 - Inspections of  Surface  Impoundments

     §264.253 - Inspections of  Waste Pile Liners

     §264.254 - Inspections of  Waste Piles

     §264.303 - Inspections of  Landfills

     Although not specifically  called out in §264.15(b)(4),  there  are
additional inspection requirements for Land Treatment facilities.   Those
requirements are specified under §264.273,  Design  and Operating Requirements,
in paragraph (g) of that section.  If you are requesting  a  permit  for  a land
treatment facility you must address the requirements of §264.273(g) in  your
inspection plan.  Additional inspection requirements for  incineration
facilities are contained in §264.347.  However,  the  Agency  plans to discuss
those requirements in detail in a separate  document.

     Possibly the easiest and most straightforward way to satisfy  the
inspection schedule requirements is to develop an  inspection plan  in total  in
the form that it will be implemented and  include it with  your permit
application submittal.  In this way you will not only comply with  the
requirements of §270.14(b)(5),  but you will also demonstrate compliance with
all of the §264.15 requirements.

     Developing a Schedule—The first step in developing  a  schedule is
identification of all equipment, devices, and structures  that will be
inspected.  Identification can be organized either by equipment type (safety
equipment, security devices, monitoring equipment) or by  facility  operating
area (receiving area, treatment area, office area) or both.   If you are
grouping strictly by types of equipment,  remember  that areas of the facility
that have no equipment, such as roadways  or other  traffic areas, must  be
inspected.  Table 5-15 is a list of equipment and  operating areas  that  will
typically be a part of any hazardous waste management facility.  Use that list
as a starting point and add equipment, devices,  structures,  and areas  specific
to your facility.  The list is by no means exhaustive.  It  is intended to
guide your thinking of the types of equipment or areas that should be
identified and provide examples of the detail desired in  your submittal.
Further, the listing of items under topical headings in the table is not meant
to define the item.  You should organize your presentation in the most lucid
manner that is representative of your facility.
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TABLE 5-15.  EQUIPMENT, STRUCTURES, AREAS TO BE CONSIDERED FOR  INCLUSION
             IN AN INSPECTION SCHEDULE
Safety Equipment

Emergency Shower/Eyewash
Face Shields
Protective Glasses
Disposable Respirators
First Aid/Equipment Supplies
Protective Clothing
Gas Masks
Chemical Respirators
Signs
Emergency Equipment

Fire Blankets
Fire Extinguishers
Fire Alarm System
Generators
Emergency Lights
Portable Pumps/Hoses
Fire Fighting Wagon/Hoses
Self-Contained Breathing Apparatus
Absorbents
Containment Booms
Monitoring Equipment

Liquid Level Transmitters
Conservation Vents
Leak Detection System
Fire Detection System
Ground Water Monitoring System
Liquid Meters

Mobile Equipment

Tires/Tracks
Brakes
Hydraulics
Trailer Hitches
Lights-Running/Emergency
Horns/Sirens
Engine Conditions

Structures

Dikes
Berms
Ramps
Lifts (Elevators)
Tank Supports
Bases/Foundations
Roofs
Walls
Security Equipment

Fences-Facility/Area
Signs
Gates
Lighting
Locks
Areas

Loading Area
Unloading Area
Storage Area
Main Roadways
Gate Areas
Periphery
Communication Equipment

Telephones
Radios
Intercoms
Public Address System
TV Monitoring System
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     The detail with which you identify equipment  to be  inspected  is  very
important.  For example,  suppose you have a pump mounted on  a  trailer that
will be used to trcinsfer hazardous liquids in the  event  of an  emergency.  The
statement "check mobile emergency pump" is likely  to be  judged inadequate.
However, if you list specific parts of the apparatus that should be checked
under that heading, then you are providing the detail expected.  An example  of
the necessary detail is presented below:

     Check mobile emergency pump

     	 hitch operable

     	 tire inflation (between 	 and 	 Ib)

     	 inlet/outlet pump connections clean/operable

     	 hose connections clean/operable

     	 5-10 ft lengths of inlet hose on trailer

     	 5-10 ft lengths of outlet hose on trailer

     	 hose condition

     	 motor to pump shaft connections

Additionally, if the pump is gasoline-powered; then checks of spark-plug
condition and fuel tank level would be listed.  For electric-powered, power
cord condition and cord connector condition checks would be  indicated, and
so  on.  Other items which should be considered for inclusion in an inspection
plan for  all types of pumps include;1

     •    pump pad condition

     •    anchor bolt tightness

     •    pump/motor shaft alignment

     •    bearing  temperatures

     •    electrical conduit integrity

     •    bearing  oil reservoir  level

     •    vibration/noise

     *    seals/packing integrity

     •    primary  liquid availability
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     The above examples of items that should be considered for pump
inspections are indicative of the level  of detail  that  you should  provide  in
an inspection plan for any equipment, device,  or structure.   In essence,  the
level of detail required in the inspection varies  depending on the role of the
equipment or area inspected.  Emergency  equipment, such as the example pump
discussed above, should be thoroughly inspected to insure  that it  will perform
its contingency action and, thus, prevent dangerous conditions. The  detail
required in inspection of noncontingency equipment will in many cases be  as
stringent, but generally not as detailed.

     Inspection Procedures—Once you have identified all the equipment,
structures, or areas to be checked during the inspections, the next step  is to
document how each item on the list is checked or inspected.   Simply using
words like "check" or "observe" is inadequate.  Rather, use phrases such  as
"check 	 for 	 by 	" or "observe 	 for  signs of 	".   Using
the mobile emergency pump as an example, the applicant  should indicate in the
inspection procedures;

     •    Check tires for proper inflation by using a tire pressure gauge and
          record the reading for each tire.

     •    Observe hose connections for signs of rust, corrosion, or dirt
          buildup that might prevent a tight connection.

     Many structures or areas will not lend themselves  to a quantitative
measurement which is otherwise possible  for a piece of  mechanical  equipment.
In these cases, the inspection procedures should indicate a visual inspection,
as a minimum, but be certain that the procedures state  "what to look  for" and,
as specifically as possible, "where to look."  Examples are;

     •    "Walk along the top of the dike.  Look for erosion rivelets or
          slides on the slopes on either side.  Look for signs of  settling and
          unevenness along the top edge.  Look for signs of liquids (puddles,
          dampness) on the sloping sides of the dike and especially along the
          flat surfaces at the bottom of the dike  slope for a distance
          of 	 ft away from the bottom of the  dike  slope."

     •    "Walk along the roadway from the main gate to 	.  Look  at the
          roadway surface for signs of subsidence, bumps,  holes, cracks or
          other signs of damage.  Look for signs of spillage from  vehicles,
          especially around turns and corners.  Observe both edges of the
          roadway for materials that may have fallen from vehicles and
          collected there."

     Inspection Frequencies—The next step in preparing an adequate inspection
plan is determining a justifiable frequency for conducting the inspections of
each item.  The regulation (§264.15(b)(4)) states  that  the frequency "should
be based on the rate of possible deterioration ... and  the probability of an
... incident if the deterioration or ... operator error goes undetected
between inspections."  As will be discussed later, some of the facility-
specific regulations set daily, weekly,  or other periodic requirements for
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inspecting certain components of the facility.   In general,  equipment,
structures, or areas that are subjected to daily or continual use or stress
should be inspected more frequently than backup or emergency components.
Items inspected less frequently should be subjected to more rigorous
inspection.  However, if the failure of equipment used continuously would pose
a hazardous situation of any kind, the inspection should be rigorous,  as  well
as frequent.

     For example, a mobile emergency pump might receive a thorough inspection
in an inactive mode once per month, while active pumps might be visually
inspected once per day.  Where an emergency pump might be tested in operation
on a quarterly or semiannual basis to insure proper suction and discharge
pressures and a nonleaking condition, active pumps might be so tested on  a
weekly basis.

     Continual or frequent successful use of an area or equipment item does
not substitute for inspection.  For example, although plant communcations
equipment may be used at the facility for paging or indicating work-breaks,
that system should be inspected on a scheduled basis, if it will be used  to
signal emergency situations.

5.5.2.2  Inspections of Containers—
     The owner or operator of any facility that stores containers of hazardous
waste must, in addition to the inspection requirements of §264.15, comply with
the inspection requirements of §264.174, which are;

          "§264.174  Inspections.
               At least weekly, the owner or operator must inspect areas  where
          containers are stored, looking for leaking containers and for
          deterioration of containers and the containment system caused by
          corrosion or other factors."

These requirements are straightforward.  They state that you TIKISt^ inspect the
containers and their associated containment system every week.  The regulation
states what must be looked at (containers and containment system), the
frequency  (weekly), and, generally, what to look  for (leaks and
deterioration).  You must, therefore, address these three concerns in your
inspection plan, but you must also provide additional details specific to your
facility.  You should  indicate the locations where the  inspector will check
for leaks and deterioration; whether the inspection will be visual,
quantitative, or both; decision criteria for determining deterioration, and
follow-up action in the event of such leakage or  deterioration.

      For example;

      "Look at the concrete pad, check for cracks  in the  surface or curbs,
      flaking, chips or gouges and areas of wear.  Check  for liquid in the sump
      at  the northeast  corner of the  pad."

      Examples of the types of containers for which inspection  procedures
should be  provided  are drums, barrels,  pails, railroad  tank cars,  tank
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trailers, and other portable containers.  Examples of items that should be
considered for inclusion in an inspection plan for containers include checks
for:

     •    tightness of lids

     •    leaks in flanges

     •    high liquid level/overflow

     •    leaks in plug seals

     •    evidence of corrosion

Containers should be inspected before and during waste addition and storage.
Examples of inspection items before waste addition include:

     •    wheels properly braked/chocked

     •    drain valves closed tight

     •    inside walls/compartment dividers free of corrosion

     •    overfilling controls operative

     •    containers located so as to minimize potential for external puncture

During their use to receive and store wastes at your facility, tank cars, tank
trailers, and portable containers should be periodically inspected, not only
for the above items, but also to the same extent as a stationary tank.

     Storage areas for some types of containers will typically consist of an
impermeable pad made of a material such as concrete.  These pads should be
included in the inspection plan.  Procedures for inspecting them for chips,
cracks, wear, or general deterioration which may increase their permeability
are recommended for inclusion in the plan.

     Further, if the container storage area is covered, your inspection
procedures should include an examination of that cover.  If there is
mechanical equipment (e.g., a sump pump) it should also be included in the
list of items to be inspected in the storage area.

     The potential for leaks from containers depends on the waste material
contained, the type of container, storage conditions, and length of storage
time.  The regulation requires inspections "at least weekly."  More frequent
inspections may be appropriate depending on the facility location,  design, or
operation.  But there must not be more than 6 calendar days between inspection
dates.
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     Finally, the provisions of §§264.l5(c)  and 264.171  require  certain
remedial actions if containers  are  found  to  be  deteriorated  or leaking during
inspections.  Applicants should be  aware  of  these requirements.

5.5.2.3  Inspections of Tanks—
     Any hazardous waste facility that uses  tanks to treat or store  hazardous
wastes must, in addition to the inspection requirements  of §264.15,  comply
with the inspection requirements of §264.194, which are;

          "§264.194  Inspections.
               (a) The owner or operator  must  inspect;
               (1) Overfilling  control equipment (e.g.,  waste feed cut-off
          systems and by-pass systems) at least once each operating  day  to
          ensure that it is in  good working  order;
               (2) Data gathered from monitoring equipment (e.g.,  pressure  and
          temperature gauges) where present, at least once each  operating day
          to ensure that the tank is being operated according to its design;
               (3) For uncovered tanks, the  level of waste in the  tank,  at
          least once each operating day,  to  ensure compliance with
          §264.192(b)(2);
               (4) The construction materials  of the above-ground  portions  of
          the tank, at least weekly to detect  corrosion  or erosion and  leaking
          of fixtur€:s and seams; and
               (5) The area immediately surrounding the  tank, at least:  weekly,
          to detect obvious signs of leakage (e.g., wet  spots or dead
          vegetation).
               (b) As part of the inspection schedule required in  §264.15(b)
          and in addition to the specific requirements of paragraph  (a)  of
          this Section, the owner or operator  must develop a schedule and
          procedure for assessing the condition of the tank.  The  schedule  and
          procedure must be adequate to detect cracks, leaks, corrosion or
          erosion which may lead to cracks or  leaks, or  wall thinning to less
          that the thickness required under §264.191.  Procedures  for emptying
          a  tank to allow entry and inspection  of the interior must  be
          established when necessary to detect corrosion or  erosion  of  the
          tank sides and bottom.  The  frequency of these assessments must be
          based on the material of construction of the tank, type of corrosion
          or erosion protection used,  rate of  corrosion  or erosion observed
          during previous  inspections, and  the characteristics of the waste
          being treated or stored.
                (c) As part of the contingency plan required under Subpart D of
          Part 264, the owner or operator must specify the procedures he
          intends  to use to respond to tank spills or leakage; including
          procedures and timing  for expeditious removal of leaked or spilled
          waste and repair of the tank."

      The requirements of §264.194(a) are; daily inspection of overfilling
controls and monitoring equipment in  all tanks, daily inspection of freeboard
in  uncovered tanks, weekly inspection  of the tanks to detect leaks  from
fixtures and seams or corrosion/erosion of  the  tank materials, and weekly
inspection  of  the  surrounding area to  detect obvious signs of leakage.
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     The provisions of §264.194(b)  require  you to  develop a schedule  and
procedure that will provide a detailed  inspection  of  the  integrity  of the
tank.  This requirement is in addition  to the  more cursory weekly  tank
inspection required by §264.194(a)  and  is indicative  of  the need  for  a
thorough inspection of the tank walls and seams using appropriate
instrumentation or gauges.

     Storage tanks are similar to containers with  respect to the  items that
should be included in an inspection plan.  Thorough inspection  for  evidence  of
corrosion, which may lead to leaking, is particularly important.   In  addition,
the inspection plan should provide  that tanks  will periodically be  emptied and
the interior walls and seams inspected  for  signs of deterioration.  A detailed
description of this procedure is important.  The description should address
where the waste will be placed when the tank is emptied,  identify  the type of
equipment that will be used to conduct  the  inspection of  the tank  interior,
and explain the inspection that will be conducted  to insure that  the  tank  is
ready to be returned to service.

     Pressure/vacuum vents, vent seals, roof drains,  inlet/outlet  connections,
and seals are additional items that should  be  considered  for inclusion in  the
inspection plan.  Examples include;

     •    Determination of pressure/vacuum vent set-point

     •    Seating of vent seals

     •    Check for/remove foreign  materials in roof drains

     •    Check inlets/outlets for  blocking/corrosion

     •    Check seals on:

               manholes

               gauge hatches

               inlet/outlet nozzles or flanges

               weather shields

               level gauges

     Overfilling control systems will typically consist  of some type  of liquid
level monitoring device with an output signal  that is used to close an inlet
valve, open a by-pass valve, or sound an alarm.  In some cases, however,  the
overfilling control equipment may simply be a  hook gauge, tape-and-plumb bob,
or manometer which is periodically visually checked.  The regulation  requires
daily inspection of these control systems to insure their proper  operation.
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     The liquid level monitoring devices which provide a visual indication of
liquid level can usually be visually inspected to insure that their  mechanical
parts are not binding or "hung-up".   However,  inspection checks of manometers
may also include confirmation that the unit is level,  checks for blockage,
leaks and good seal connections on fluid lines,  and confirmation of  sufficient
level in fluid wells.  Periodic flushing of manometer  fluid lines should  also
be considered for Inclusion in the inspection schedule if warranted  by service
c on d i t i on s .

     The following are example items that could be included in inspections of
float actuated liquid level sensing  devices;

     •    check float for bouyancy/liquid infiltration

     •    check lever arm and interconnecting rods for integrity and freedom
          of movement.

     Inspections of electronic level sensing units could include checking of
wiring condition, probe position and condition,  and condition of seals.
Periodic calibration and checks in accordance with manufacturer's
recommendations should also be indicated in the inspection plan.

     In cases where the liquid level sensor, regardless of type, provides a
signal for valve control or alarm activation, the entire system must be
inspected on a daij.y basis.  The inspection plan should provide a detailed
description of how this will be done and what items will be inspected.  A
clear description of how a false high liquid level indication will be input to
the level sensor so that system operation can be confirmed is important.
Other items that should be confirmed during the inspection include;

     •    system activated at proper preset level

     •    valves operated properly

     •    visual and  audible alarms functioned properly

     •    there were no leaks in the system

     The provisions of §264.15(c) require you to remedy any leak, crack,  or
wall thinning in violation of §264.191, or equipment malfunction in violation
of  §264.192, which you may discover as a result of your inspections.  In
addition, the provisions of §264.194(b) may require personnel to enter tanks
during inspection.  The Occupational Safety and Health Administration
requirements relating to entry of tanks for inspection can be found at 29 CFR
§1910.94(d)(ll).

5.5.2.4  Inspection of Surface Impoundments—
     Any owner or operator of a facility that uses a surface impoundment  to
treat, store, or dispose of hazardous waste must,  in addition to the
inspection requirements of §264.15, comply with the inspection requirements of
§264.226, which are;
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          "§264.226   Monitoring  and  inspection.
               (a) During  construction  and  installation,  liners  (except  in
          the case of existing portions of  surface  impoundments  exempt  from
          §26A.221(a))  and cover systems  (e.g., membranes,  sheets, or
          coatings) must be inspected  for uniformity,  damage,  and
          imperfections (e.g., holes,  cracks,  thin  spots,  or  foreign
          materials).  Immediately after construction  or  installation:
               (l) Synthetic liners  and covers must be inspected to ensure
          tight seams and  joints and the absence  of tears,  punctures, or
          blisters; and
               (2) Soil-based and admixed liners  and covers must be inspected
          for imperfections including  lenses,  cracks,  channels,  root holes, or
          other structural non-uniformities that  may cause an  increase  in the
          permeability  of  the liner  or  cover.
               (b) While a surface impoundment  is in operation,  it must  be
          inspected weekly and after storms to detect  evidence of any of the
          following:
               (1) Deterioration, malfunctions,  or  improper operation of
          overtopping control systems;
               (2) Sudden  drops  in the  level of  the impoundment's contents; and
               (3) The  presence  of liquids  in  leak  detection  systems, where
          installed  to comply with §264.222; and
               (4) Severe  erosion or other  signs  of deterioration in dikes or
          other containment devices.
               (c) Prior to the  issuance of a  permit,  and after  any extended
          period of  time (at least six months) during  which the  impoundment
          was not in  service, the owner or  operator must obtain  a
          certification from a qualified engineer that the impoundment's dike,
          including  that  portion of  any dike which provides freeboard,  has
          structural  integrity.   The certification  must establish,  in
          particular, that the dike:
               (1) Will withstand the  stress of the pressure  exerted by the
          types and  amounts of wastes  to be placed  in  the impoundment;  and
               (2) Will not fail due to scouring or piping, without  dependence
          on any liner system included in the surface  impoundment
          construction."

     The provisions  of §264.226 require inspections at two distinct  times;
during and immediately after construction (paragraph(a)), and weekly during
operation (paragraph  (b)).  In addition, paragraph (c) requires  that a
qualified engineer  certify the unit's  integrity before a permit  will be issued
or at any time that  the impoundment  has been out of service for  6 months or
more.

     The intent of  paragraph (a) is  to insure that both the materials  and  the
construction of a surface  impoundment  comply with the  plans which have  served
as a basis for granting a  permit.  Although the material suppliers  and
construction contractors will employ quality assurance procedures and  tests,
you must include provisions in your  inspection plan for overseeing  and
reviewing the contractor or supplier procedures.   The  personnel  you  identify
to conduct these inspections should  represent only the owner's or operator's
interests.  The inspection procedures  should include a statement of when,


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during construction,  the inspections will be conducted and  should  provide  for
inspector approval before construction is allowed  to  continue.   It may  be
necessary to identify multiple inspectors to insure that qualified personnel
are conducting the inspections during the various  construction  phases.

     Paragraph (a) of §264.226 specifically mentions  liners and cover
systems.  However, any inspection plans submitted  to  comply with §264.226(a)
should provide for inspection of materials and construction of  all the  various
components of the surface impoundment.  The following paragraphs offer
examples of items that should be inspected during  and immediately after
construction.

     Raw materials—All materials that will be used to construct the surface
impoundment should be inspected upon receipt at the site.  These include soils
and aggregates, synthetic liner materials, pipes or trench  materials,  and  any
other materials that are purchased or delivered to the site. The  material
received should be compared to the shipping papers.  Shipping papers should be
compared to purchase orders and_ to the original plan  specifications.  Any
tests that may be conducted on the materials, in addition to visual
inspection, should be described.  The inspection procedures should identify
damaged shipping containers or wrappings.  If only samples  of a shipment will
be inspected, justification of the representativeness of this procedure should
be provided.  If materials are to be stored, the storage area should be
inspected before and during use, and all stored materials should be
periodically inspected.  Table 5-16 is an example  inspection form which
illustrates the type of information and level of detail that would constitute
an adequate inspection plan.

     Construction equipment and procedures—The inspection  plan should provide
for observation of surface impoundment construction.   The equipment  used and
procedures of operation should be observed.  As construction proceeds,  the
inspector should periodically check key dimensions of the impoundment  (e.g.,
height and thickness of berms and dikes) as a check on the  contractor's
surveyor.

     Post-construction inspections—Liner and cover systems are typically
constructed of multiple layers.  The inspection procedures  should indicate
that each of these layers will be inspected before any overlying layers are
placed.  The installation contractor should be conducting quantitative tests
to confirm that the constructed layers meet design specifications.  It is not
necessary for the inspector to independently conduct these  tests.  However,
the inspector should observe  them being conducted and review the results in
detail.

     The portion  of the  inspection  plan developed to comply with §264.226(a)
should address the following  topics; what will be inspected, when will it be
inspected, what will be  looked  for, how will it be inspected, and what
criteria establish failure and require corrective action.  Table 5-17  is a
summary  list of example  items that  should be considered  for inclusion  in an
inspection plan to satisfy §264.226(a).  The items in the  table are neither
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                TABLE  5-16.  EXAMPLE RAW MATERIAL  INSPECTION  FORM
Name/Type    Screened and washed sand
Quantity Received    100 cu yards
Received In    10 Truckoads
                    of    10 cu yards
Shipping Papers:   X  compared to material received

                   X  compared to purchase order

                   X  compared to plans specifications

Amount of Material Visually Inspected    All	
each
Samples Taken    3-from first, fifth, and last truckloads-all grab
Sample Analysis Performed    Sieve on all three
Analysis Results
  X   Sent to Storage in    rear-equipment shed No. 5	

	 Sent to Site for Installation

Visual Inspection Results

    Date       Location                   Comments

    4/8/83     Yard       Inspection at receipt-looked OK

    4/15/83    Storage    Erosion losses noted-sand bagged circumference
                          of pile
    4/23/83    Site
Moved from storage-installed, looked OK—last
load from each pile hand-raked
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                         TABLE 5-17.  EXAMPLE ITEMS FOR SURFACE IMPOUNDMENT  INSPECTION  PLAN
        What to inspect
  When to inspect
     What to look for
     How to inspect
     Raw materials
do
00
At receipt


In storage


At installation
     Construction procedures    During construction
     Finished components
At completion
Shipping damage
Off-spec items

Deterioration
Contamination

Deterioration
Contamination
Handling damage
Proper placement

Proper equipment
Proper execution
Lenses, holes, cracks, etc.
Permeability
Seam integrity
Dimensions
Repairs
Visual
Visual/grab samples

Visual
Visual

Visual
Visual/testing
Visual
Visual/check plans

Visual
Review with installer
Visual checks

Visual
Perform/review tests
Perform/review tests
Measurements
Visual/testing

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all inclusive nor detailed.  Your inspection plan should indicate what  type  of
deterioration to look for,  where to visually inspect  the material,  what
samples to take, and what tests to perform or review.   For example;

     •    "As the liner material is being unfolded,  check for  "blocking1  by
          looking for places where delamination has  occurred,  check for cracks
          by looking at places where the material was  folded," or

     •    "After the sand has been spread, and rough  graded,  but before final
          compaction or grading walk across it in a  'zig-zag1  fashion  looking
          for off-size or foreign materials."

     Paragraph(b) of §264.226 identifies four things  that must be inspected
weekly and after storms; overtopping control systems,  liquid  level,  leak
detection system (if present), and dikes and other containment devices.  These
inspections need to be conducted when the surface impoundment  is in operation,
or any time that it contains waste.  The requirement  for inspection after
storms is in addition to the weekly inspection requirement.

     The need to conduct inspections during a storm of extended duration will
depend on the location and design of the surface impoundment.   The permit
applicant should consider how to address the need for  inspections during a
storm when preparing the inspection plan.  Table 5-18  is a list which
illustrates the type of information and level of detail which  an adequate
inspection plan would generate.

     In some cases, a synthetic liner will be protected by a  layer of  soil
from potential damage due to sunlight or wind.  This  protective soil layer
should be included in the inspection plan.

     If mechanical equipment is used to remove sludge  from the bottom  of the
impoundment, checks of its operation and condition should be  included  to
insure that the liner is not being damaged.  When sludge removal equipment is
used in a synthetically lined impoundment, a layer of  protective soil  is
usually installed.  This protective soil liner should  be included in the
inspection plan to insure that its depth over the liner is maintained.

     Paragraph (c) of §264.226 requires that the structural integrity  of the
surface impoundment dike be certified by a qualified  engineer.  For a  surface
impoundment operating under interim status, part of  the certification  process
should be a site inspection of the dike.  For a new unit, the  certification
will be based on a review of the final design and specifications.  If  a
surface impoundment is not in service for any extended period  (at least
6 months), then certification is required before it  can resume operation.   In
any of these cases, the permit applicant should consider including,  as  part  of
the certification, any calculations conducted to establish that the dike
complies with § 264.226(c)(1) and (2).
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    TABLE 5-18.  EXAMPLE LIST OF ITEMS FOR AN INSPECTION PLAN FOR
                 AN OPERATING SURFACE IMPOUNDMENT
Inspector Name

Weekly/After Storm Inspection

Time of Inspection

Date of Inspection

Liquid Level Indicator/Controller Check

Inlet Flow Valve Check

High Level Alarm Check

By-pass System Check

Liquid Level Check/Record

Leak Detection/Containment System Check

          Evidence of liquid

          Pump operation

     -    Component integrity

Dike/Containment System Check

     -    Subsidence/erosion/corrosion

          Leaks

          Dampness
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5.5.2.5  Inspections of Waste Piles—
     Any owner or operator of a facility that stores or treats hazardous  waste
in piles must, in addition to the inspection  requirements  of §264.15,  comply
with the inspection requirements of §264.254.  If the pile qualifies  for
exemption from the Part 264,  Subpart F requirements, then  the owner or
operator must also comply with the inspection requirements of §264.253(a)(3).

     The inspection requirements for all waste piles are;

          "§264.254  Monitoring and inspection.
               (a) During construction or installation, liners (except in the
          case of existing portions of piles  exempt from §264.251(a))  and
          cover systems (e.g., membranes, sheets, or coatings) must be
          inspected for uniformity, damage, and imperfections (e.g.,  holes,
          cracks, thin spots, or foreign materials).  Immediately after
          construction or installation:
               (l) Synthetic  liners and covers must be inspected to  ensure
          tight seams and joints and the absence of tears, punctures,  or
          blisters; and
               (2) Soil-based and admixed liners and covers must be  inspected
          for imperfections including lenses, cracks, channels, root  holes,  or
          other structural non-uniformities that may cause an increase in the
          permeability of the liner or cover.
               (b) While a waste pile is in operation, it must be inspected
          weekly and after storms to detect evidence of any of the following:
               (1) Deterioration, malfunctions,  or improper operation of
          run-on and run-off  control systems;
               (2) The presence of liquids in leak detection systems,  where
          installed to comply with §264.252;
               (3) Proper functioning of wind dispersal control systems,
          where present; and
               (4) The presence of leachate in and proper functioning of
          leachate collection and removal systems, where present."

Additionally, for waste piles which qualify for exemption from the Part 264,
Subpart F requirements for ground water protection, the inspection
requirements are;

               "§264.253(a)(3)  The wastes in the pile must be removed
          periodically, and the liner must be inspected for deterioration,
          cracks, or other conditions that may result in leaks.  The  frequency
          of inspection will  be specified in  the inspection plan required in
          §264.15 and must be based on the potential for the liner (base) to
          crack or otherwise  deteriorate under the conditions of operation
          (e.g., waste type,  rainfall, loading rates, and subsurface
          stability)."

     The provisions of §264.254 require inspections at two distinct  times,
which are; during and immediately after construction (paragraph(a)),  and
weekly during operation (paragraph (b)).  In  addition, §264.253 requires  that
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owners or operators of piles which qualify for exemption  from Part  264,
Subpart F must periodically remove the wastes from the pile and conduct  an
inspection of the pile liner.

     The intent of paragraph (a) of §264.254 is to insure that both the
materials and the construction of a waste pile comply with the plans  which
have served as a basis for granting a permit.  Although the material  suppliers
and construction contractors will employ quality assurance procedures and
tests, you must include provisions in your inspection plan for overseeing and
reviewing the contractor or supplier procedures.  The personnel you identify
to conduct these inspections should represent only the owner's or operator's
interests.  The inspection procedures should include a statement of when,
during construction, the inspections will be conducted and should provide for
inspector approval before construction is allowed to continue.  It  may be
necessary to identify multiple inspectors to insure that  qualified  personnel
are conducting the inspections during the various construction phases.

     Paragraph (a) of §264.254 specifically mentions liners and cover
systems.  However, any inspection plans submitted to comply with §264.254(a)
should provide for inspection of materials and construction of all  the various
components of the waste pile.  The applicant should refer to the discussion of
inspection of surface impoundments for guidance on inspection plans for raw
materials, construction equipment and procedures, and post-construction
inspections.

     The portion of the inspection plan developed to comply with §264.254(a)
should address the following topics; what will be inspected, when will it be
inspected, what will be looked for, how will it be inspected, and what
criteria establish failure and require corrective action.  See Table  5-17 in
the preceding discussion on  surface impoundments for examples of items to
include in an inspection plan.

     Paragraph(b) of  §264.254 identifies  four  things that must be inspected
weekly and after storms; run-on and run-off control systems, liquids  in the
leak detection system (if present), wind  dispersal control system (if
present), leachate collection and removal systems (if present).  These
inspections only need to be  conducted when the waste pile  is  in operation, or
any time that it contains waste.  The requirement for inspection after storms
is in  addition to  the weekly inspection requirement.

     The need to conduct inspections during a  storm of extended duration will
depend on the location  and  design of the  waste  pile.  The  permit applicant
should consider how to  address the need for inspections during a storm when
preparing the inspection plan.  Table 5-19 is  a  list which illustrates the
type of information and level of detail which  an adequate  inspection plan
would  generate.

     The  inspection requirements of  §264.253(a)(3) must be compiled with only
if the waste pile  is  exempted from the ground  water protection requirements of
Part  264, Subpart  F by  meeting  the requirements  of  §264.253(a)(1) , (2),  (4)
and (5).  The inspection plan,  in these instances, should  indicate how the
wastes will be removed  from the pile, where  they will be  placed during liner

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         TABLE 5-19.  EXAMPLE LIST OF ITEMS FOR AN INSPECTION PLAN FOR
                      AN OPERATING WASTE PILE
Inspector Name

Weekly/After Storm Inspection

Time of Inspection

Run-on Control System Checks

          Checked for integrity

          Checked for clogging/blockage

     -    Mechanical parts checked for proper operation

Run-off Control System Checks

     -    Checked for integrity

          Checked for clogging/blockage

     -    Run-off collection system capacity confirmed

     -    Mechanical parts checked for proper operation

Leak Detection/Containment System Checks

          Evidence of liquid

     -    Pump operation

     -    Component integrity

Leachate Collection/Removal System Checks

     —    Flow checks

     -    Pump operation

     -    Component integrity

Wind Dispersal Control System Checks

     -    Damage/integrity

          Effectiveness

     -    Waste accumulation


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inspection, how the Liner will be inspected,  and how the wastes  will  be  placed
back onto the pile.  The inspection plan must also state the frequency that
the inspection procedure will be conducted.   You should be prepared  to justify
the frequency chosen based on your knowledge  of waste type,  rainfall,  loading
rates, subsurface stability,  or other operating or location  conditions.

5.5.2.6  Inspections of Landfills—
     Any owner or operator of a facility that disposes of hazardous  waste in a
landfill must, in addition to the inspection  requirements of §264.15,  comply
with the inspection requirements of §264.303, which are;

          "§264.303  Monitoring and inspection.
               (a) During construction or installation, liners (except in the
          case of existing portions of landfills exempt from §264.301(a)) and
          cover systems (e.g., membranes, sheets, or coatings) must  be
          inspected for uniformity, damage,  and imperfections (e.g.,  holes,
          cracks, thin spots, or foreign materials).  Immediately after
          construction or installation:
               (1) Synthetic liners and covers must be inspected to  ensure
          tight seams and joints and the absence of tears, punctures,  or
          blisters; and
               (2) Soil-based and admixed liners and covers must be  inspected
          for imperfections including lenses, cracks, channels,  root holes, or
          other structural non-uniformities  that may cause an increase in the
          permeability of the liner or cover.
               (b) While a landfill is in operation, it must be inspected
          weekly and after storms to detect  evidence of any of the following:
               (1) Deterioration, malfunctions, or improper operation of
          run-on and run-off control systems;
               (2) The presence of liquids in leak detection systems,  where
          installed to comply §264.302;
               (3) Proper functioning of wind dispersal control systems, where
          present; and
               (4) The presence of leachate  in and proper functioning of
          leachate collection and removal systems, where present."

     The provisions of §264.303 require inspections at two distinct  times,
which are; during and immediately after construction (paragraph(a)), and
weekly during operation (paragraph (b)).  The  intent of paragraph (a) is to
insure that both the materials and the construction of a landfill comply with
the plans which have served as a basis for granting a permit.  Although  the
material suppliers and construction contractors will employ quality  assurance
procedures and tests, you must include provisions in your inspection plan for
overseeing and reviewing the contractor or supplier procedures.   The personnel
you identify  to conduct these inspections should represent only the  owner's or
operator's interests.,  The inspection procedures should include a statement of
when, during  construction, the inspections will be conducted and should
provide  for inspector approval before construction is allowed to continue.  It
may be necessary to Identify multiple  inspectors to insure that qualified
personnel  are conducting the inspections during the various construction
ph a s e s.
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     Paragraph (a) of §264.303 specifically mentions liners and cover
systems.  However, any inspection plans submitted to comply with §264.303(a)
should provide for inspection of materials and construction of all the various
components of the landfill.  The applicant should refer to the discussion of
inspection of surface impoundments for guidance on inspection plans for raw
materials, construction equipment and procedures, and post-construction
inspections.

     The portion of the inspection plan developed to comply with §264.226(a)
should address the following topics;  what will be inspected, when will it be
inspected, what will be looked for, how will it be inspected, and what
criteria establish failure and require corrective action.  See Table 4 in the
preceding discussion of surface impoundments for a list of example inspection
items .

     Paragraph (b) of 264.303 identifies four things that must be inspected
weekly and after storms; run-on and run-off control systems, leak detection
systems (if present), wind dispersal control systems (if present), and
leachate collection and removal systems (if present).  These inspections only
need to be conducted when the landfill is in operation, or any time that it
contains waste.  The requirement for inspection after storms is in addition to
the weekly inspection requirement.

     The need to conduct inspections during a storm of extended duration will
depend on the location and design of the landfill.  The permit applicant
should consider how to address the need for inspections during a storm when
preparing the inspection plan.  See Table 6 in the preceding discussion of
waste piles for illustration of the type and detail of information that an
adequate inspection plan would generate.

5.5.2.6  Inspections of Land Treatment Facilities—
     Any owner or operator of a facility that treats or disposes of hazardous
wastes in land treatment units must, in addition to the inspection
requirements of §264.15, comply with the inspection requirements of
§264.273(g), which are;

          "§264.273(g)
               The owner or operator must inspect the unit weekly and after
          storms to detect evidence of:
               (1) Deterioration, malfunctions, or improper operation of run-on
          and run-off control systems; and
               (2) Improper functioning of wind dispersal control measures."

     The requirements of §264.273(g) are straightforward in requiring weekly
and after storm inspection of run-on, run-off, and wind dispersal control
systems.  Run-on and run-off controls which consist of diversion dikes/berms
and open channels or trenches are key to preventing the uncontrolled spread of
waste outside the actual land treatment facility.
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     Inspection items relative to run-on controls include confirmation that
channels and trenches are free of debris or other blockage and that  their
capacity remains as originally designed.  Inspection of run-on diversion dikes
and berms should include checks for erosion.  The erosion that should  be
checked for is that which results from water scouring at the sides of  the
dikes and berms and erosion that would reduce the structure's effective height
or length.

     Inspection items relative to run-off control system channels, trenches,
dikes, and berms are identical to those for run-on control systems.  However,
run-off control systems are likely to include some type of collection  area for
the run-off.  The inspection plan should include procedures for inspecting the
equipment associated with these collection areas.  If run-on is collected  in
tanks or surface impoundments, the inspection plan should provide procedures
identical to those discussed for these types of facilities in the preceding
pages.

     Wind dispersal control measures could be chemical, botanical, or  physical
treatment of the land treatment facility surface, or natural or manmade
wind-breaks.  Where the land treatment facility surface itself is treated or
covered in some manne:r to reduce wind dispersal, the inspection plan should
identify procedures to check these measures.  For example, if some type of
surfactant is applied, inspection should include checks of application rate
and coverage; if vegetation is planted the inspection should include checks of
its condition and coverage; and if some type of physical cover is used the
inspection should include checks of anchor points and cover integrity.

     Wind breaks can be rows of trees, shrubs, or fences around the land
treatment facility.  The inspection plan should povide for visual inspection
of these items for gaps or breakage.  It is also important to check around
these: items  for accumulated materials originating from the land treatment unit.

5.5.3  List of Major Points

      1.   Are all equipment, devices, and structures that will be inspected
          identified?

      2.   Are specific parts of the equipment, devices, and structures
          identified in detail  for inspection?

      3.   Is  the  frequency of  inspection for each item clearly indicated?

      4.   Are the facility-type specific terms and  frequencies included in the
          inspection schedule?

5.5.4  References

      1.   Hesketh, H. E., Handbook  for  the Operation and Maintenance of Air
          Pollution  Control Equipment,  Technomic, Westport, Connecticut,  1975.

      2.   Cheremisinoff, N. P., Process  Level  Instrumentation and Control,
          Marcel  Dekker, Inc.,  New York, 1981.

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5.6  PREPAREDNESS AND PREVENTION

5.6.1  Regulatory Citations

     Information on preparedness and prevention must be  included in Part  B of
the permit application, as specified in:

          "§270.14(b)(6)  A justification of any request for  waiver(s)  of the
     preparedness and prevention requirements of Part 264,  Subpart  C."

     The regulatory requirements regarding preparedness  and prevention  are
contained in Subpart C of Part 264.   They are:

          "Part 264 - Subpart C - Preparedness  and Prevention

          §264.30  Applicability.
               The regulations in this Subpart  apply to owners and  operators
          of all hazardous waste facilities, except as §264.4 provides
          otherwise.

          §264.31  Design and operation of facility.
               Facilities must be designed, constructed, maintained, and
          operated to minimize the possibility of a fire, explosion, or any
          unplanned sudden or non-sudden release of hazardous waste or
          hazardous waste constituents to air,  soil, or surface water which
          could threaten human health or the environment.

          "§264.32  Required equipment.
               All  facilities must be equipped with the following,  unless it
          can  be demonstrated to the Regional Administrator that none of  the
          hazards posed by waste handled at  the facility could require a
          particular kind of equipment specified below:
                (a)  An  internal communications or alarm  system capable of
          providing  immediate emergency  instruction  (voice or signal) to
          facility  personnel",
                (b)  A device, such as a telephone  (immediately available  at  the
          scene of  operations) or a hand-held two-way radio, capable of
          summoning emergency assistance  from local police departments,  fire
          departments,  or State  or  local emergency response teams;
                (c)  Portable  fire extinguishers, fire control equipment
          (including special extinguishing equipment, such as that using  foam,
          inert gas, or dry  chemicals),  spill control equipment, and
          decontamination equipment; and
                (d)  Water  at  adequate volume  and pressure to supply water  hose
          streams,  or  foam producing equipment, or automatic sprinklers,  or
          water  spray  systems.

          §264.33   Testing and maintenance of equipment.
               All  facility  communications  or alarm systems, fire  protection
          equipment, spill control  equipment, and decontamination equipment,
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         where required, must be tested and maintained as necessary to assure
         its proper operation in time of emergency.

         §264.34  Access to communications or alarm system.
               (a) Whenever hazardous waste is being poured, mixed,  spread,  or
         otherwise handled, all personnel involved in the operation must have
         immediate access to an internal alarm or emergency communication
         device, either directly or through visual or voice contact with
         another employee, unless the Regional Administrator has ruled that
         such  a device  is not required under §264.32.
               (b) If there is ever just one employee on the premises while
         the facility is operating, he must have immediate access to a
         device, such as a telephone (immediately available at the scene of
         operation) or  a hand-held two-way radio, capable of summoning
         external emergency assistance, unless the Regional Administrator has
         ruled that such a device is not required under §264.32.

         §264.35  Required aisle space.
               The owner or operator must maintain aisle space to allow the
         unobstructed movement of personnel, fire protection equipment, spill
         control equipment, and decontamination equipment  to any area of
         facility operation in an emergency, unless it can be demonstrated to
         the Regional Administrator that aisle space is not needed for any of
         these purposes.

         §264.36  Special handling  for  ignitable or reactive waste.*

         §264.37  Arrangements with local authorities.
               (a) The owner or operator must attempt to make the following
         arrangements,  as appropriate  for the type of waste handled at his
         facility and the potential need  for the services  of these
         organizations:
               (1) Arrangements to  familiarize police, fire departments, and
         emergency response teams with  the  layout of the  facility, properties
         of hazardous waste handled at  the  facility and associated hazards,
         places where facility personnel would normally be working, entrances
         to and roads inside  the  facility,  and possible evacuation routes;
               (2) Where more  than one  police and fire department might
         respond  to  an  emergency,  agreements designating  primary emergency
         authority to a specific police and  a specific fire department and
         agreements with  any  others  to  provide support to  the primary
         emergency authority;
               (3) Agreements  with  State emergency  response teams,  emergency
         response contractors, and  equipment suppliers; and
*This section was revoked and reserved by a  Federal  Register  notice  on  January
 12, 1981 at 46 FR 2847.  Applicants  should  call  the RCRA Hotline  (see
 Appendix A) to see if these requirements have been  added.

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               (4)  Arrangements  to  familiarize  local hospitals with the
          properties of hazardous waste  handled at  the  facility  and the  types
          of injuries or illnesses  which could  result  from  fires, explosions,
          or releases at the facility.
               (b)  Where State or  local  authorities decline to enter  into  such
          arrangements, the owner  or operator must  document the  refusal  in  the
          operating record."

     Requests and justifications for waivers of any of  the  Part  264 -
Subpart C requirements must be made in  Part  B of the permit application.   The
inherent hazards associated with the treatment, storage,  and disposal of
hazardous waste reduce the possible scenarios where valid justification  for
waivers could be demonstrated.  Thus,  the guidance  provided will be for  owners
or operators of hazardous waste facilities attempting  to  achieve compliance
with the Part 264 standards.

5.6.2  Guidance to  Achieve the Part 264  Standards

5.6.2.1  General—
     The intent of  Subpart C of Part 264 is  to  insure  that  each  permit
applicant provides  a complete description of the preparedness and prevention
measures which have been or will be implemented at  the  HWM  facility to
minimize the possibility of a fire, explosion,  or any  unplanned  sudden or
non-sudden release  of hazardous waste or hazardous  waste  constituents to air,
soil, or surface water which could  threaten  human health  or the  environment.

     Subpart C sets requirements on:

     •    Facility  design and operation  in §264.31,

     •    Equipment available in §264.32,

     •    Equipment testing and maintenance  in  §264.33,

     •    Communications or alarm systems in §264.34,

     •    Aisle space in §264.35,  and

     •    Arrangements with local authorities in §264.37.

Much of the information necessary to demonstrate compliance with the
requirements of Subpart C will be developed and contained in detail  in other
portions of Part B of the permit application.   In these cases,  a brief
description should be incorporated  in the discussion of Preparedness  and
Prevention and  the location of the specific  details should  be referenced.

     Additionally,  the Subpart C requirements are closely tied to the
Contingency Plan required by Subpart D of Part  264.  The  Contingency  Plan  is
described in the next section of this manual.   Whereas Subpart C requires  a
description and documentation that efforts have been taken  to prevent and  be
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prepared for an emergency or unplanned occurrence,  the  Contingency  Plan
required in Subpart D is a document  that  facility personnel  will use  if  an
unplanned or emergency event occurs.

5.6.2.2  Preparedness and Prevention [40  CFR 270.14(b)(6)  and  §264.30-264.37]—
     Applicability [§264.30].   All owners and operators of hazardous  waste
facilities must comply with the requirements of Subpart C  unless  the  applicant
is exempt as specified in §264.1.

     Design and Operation of Facility [§264.31]. The applicant must  insure
that his HWM facilty has been designed, constructed,  maintained,  and  operated
to minimize the hazards associated with the hazardous waste  operations
employed at the facility.  Drawings  sketches, or plans  of  the  facility and
construction specifications should be included to demonstrate  that  the design
and construction of the facility comply with the Part 264  standards.  Facility
operation manuals or procedures should be included  to describe the  methods
used to maintain and operate the facility.

     In this case, much of the information required to demonstrate
"preparedness and prevention" will be incorporated  elsewhere in Part  B of the
application for other reasons.  Thus, in order to demonstrate compliance, the
discussion in this part of the application could emphasize how the  design,
construction, maintenance, and operation of the facility "minimize" danger and
contribute to preparedness and prevention.  The discussion should direct the
permit  reviewer to those other locations  in the application where the detailed
plans and procedures are presented.

     Required Equipment  [§264.32].  The regulation specifically identifies
four (4)categories of emergency equipment which must be identified and
discussed in the permit application.  You should also be aware that the
requirements of §264.54(e) also address emergency equipment and require  that
specific details of that equipment be included  in the Contingency Plan.   The
equipment categories identified in §264.32 are  items whose inclusion in  the
facility design demonstrate that  you  are  "prepared"  for an emergency or
unplanned occurrence.  Thus,  a somewhat general discussion here,  which
identifies  the type, number,  and  location of  the communication and alarm
systems, would be  acceptable  if the detailed  descriptions in the Contingency
Plan are properly  referenced.

     Internal Communication or Alarm  System  [§ 264.32(a)].  The facility must
have a  communication or alarm system  capable  of providing emergency
instruction.  The  primary  purpose of  the  alarm system  is  to provide emergency
instruction to enable rapid evacuation of the affected  areas.  A. secondary,
but equally important purpose is  to  initiate  the emergency response plan which
is part of  the Contingency Plan.  Intercoms,  internal  telephones or two-way
radios  can  serve as  communication devices.   The alarm  system should be a bell,
siren,  buzzer or similar device audible  from  all areas  of the  facility.   The
alarms  can  be either manually or  automatically activated, but  automatic
systems should also  provide  for manual activation.   Switches should be readily
accessible  to  all  personnel involved in  waste handling operations.
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Example:

     "The operations building is equipped  with 15  wall-mounted  switches
tied into an electric bell alarm system.   Ten switches  are  located  in
production areas, adjacent to each of 10 work stations,  and five  are
located in storage areas.   The switches are clearly marked  for  rapid
identification.  Workmen are instructed  to keep the surrounding areas
free of obstructions.  In addition,  remote sensors which detect
combustible gas, low oxygen levels and sprinkler system flow are  tied
into the alarm.  Activation of any individual switch or remote  sensor
will sound all bell alarms and lights in  the system.

     Two work crews, consisting of four men each,  are involved  in outside
landfilling and treatment operations. Each crew foreman carries  a
hand-held two-way radio which can be used  to contact the operations room
in the event of an emergency.  Members of  the crews maintain visual and
voice contact with each other at all times.

     There is an internal phone system which connects the operations room
to all areas of the operations building.   There is a phone  (part  of this
system) located at the landfill and at the treatment area.

     A complete description of the alarm system showing switch, sensor,
and alarm bell locations and system specifications can be found on  page _
of the Contingency Plan (Attachment _ of  this application).  An equally
detailed description of the phone system begins on page _ of the
Contingency Plan."

     External Communication System [264.32(b)].  Should an  emergency
situation arise, the HWM facility will need some means of summoning
assistance from  local police departments,   fire departments, and State  and
local emergency response teams.  Both a  telephone and a hand-held two-way
radio are acceptable communication devices.  Such devices must  be
immediately available at the scene of operations.

Example:

     "The facility  is equipped with an intercom system to provide
internal emergency communications.  Any emergency will be brought to  the
attention of  the chief engineer stationed  at the operations control
room.  He will quickly evaluates the situation and places any necessary
calls  to police  departments,  fire departments and/or emergency response
teams  from one of the outside phones located in the control room.  If  the
control room  is  affected by the emergency  situation, a telephone at the
front gate will be used to summon assistance.

     Details  on  the  specifications,  locations, and operation of the
intercom system are  located on page _ of the Contingency Plan.   The
locations of  all outside phones are  shown  on the emergency equipment
location plan which  follows page _ in the  Contingency Plan."
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     Emergency Equipment [§264.32(c)].   Provide a  description  of  any  equipment
to be used in the event of  an emergency situation.   Emergency  equipment must
include portable fire extinguishers,  fire  control  equipment  (including any
special extinquishing equipment  such  as foams,  inert  gas,  or dry  chemicals),
spill control equipment (e.g. pumps,  absorbants, vacuum cleaners,  etc.) and
decontamination equipment (e.g.  pumping or vacuum  equipment).   You should
provide a description of the number and type of each  piece of  emergency
equipment and its location  and function relative to  process  operations.

     Example for Fire Control Equipment:   (Considering a facility which
     employs several physical/chemical  processes for  treating  liquid  hazardous
     wastes. )

          "Several treatment processes  are carried out in a large single  floor
     building.  To provide  rapid response  to fires,  wall-mounted,  hand-held
     fire extinguishers are centrally located at each of six operations.
     Three additional extinguishers are provided in  a storage  area.  Because
     the primary danger of fire is from flammable  liquids, carbon dioxide
     extinguishers are used.  An automatic sprinkler system runs  throughout
     the building.  The sprinkler system is of the foam-water  type; providing
     an initial discharge of water.  The sprinkler heads are designed to  open
     at between 250 and 286°F and are spaced 10 feet apart,  each  head covering
     an area of 100 square  feet.

          The outside yard  storage area contains four fire hydrants,  spaced
     100 feet apart and 125 feet of 2 1/2  inch fire  hose are stored on racks
     next to each hydrant."

     Example for Spill Control:

          "The  facility has several above  ground tanks used to store and/or
     treat hazardous wastes.  To control spills, each tank is  completely
     surrounded by a dike constructed of compacted clay soil.   The dikes  are
     of sufficient height to contain the entire contents of the tanks.   The
     facility has three identical trailor-mounted  portable pumps  powered  by
     10-HP gasoline engines.  Each pump can transfer 	 GPM at 20 ft. TDH.
     The facility maintains sufficient empty tank  capacity to  transfer the
     contents of the largest tank onsite."

     Example for Decontamination Equipment:

          "The  facility owns a 10,000 gallon tank  truck which has been fitted
     with a vacuum unit that is capable of cleaning up solid or liquid
     materials.  The tank truck also has fittings  compatible with the hoses
     used on the trailer-mounted emergency pumps.   A separate vacuum unit,
     mounted on a special fork-lift compatible skid, is stored in the same
     shed as the emergency  fire equipment.  By agreement, an additional  10,000
     gallon  tank truck is available from the County Fire Department."
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     Water Supply for Fire Fighting Equipment  [264.32(d)].   The  owner  or
operator must show that  sufficient  water  will  be  available  for emergency use.
In addition to providing water for  sprinklers,  the  supply  should be  adequate
for hydrants and hose streams.  Identify  any secondary  water supplies  such  as
gravity tanks, suction tanks,  private reservoirs, rivers,  ponds,  etc., which
can be used in case of emergency.

     Example:

          "A public water supply serves  as  the primary  source of emergency
     water.  The system has a  rated delivery capacity of  1,500 gpm at
     40 psig.  This supply is  supplemented  by  two 100,000  gallon gravity water
     tanks capable of delivering 1,500 gpm  at  60  psig.   The  maximum  water
     requirement under worst case conditions  is estimated  to be  2,000  gpm."

          You are reminded that the required equipment  identified in §264.32
     must be described in more detail in  the Contingency  Plan which  is
     presented in the next section  of this  manual.   The intent of the
     regulations is to insure  that  you have given serious  thought to the
     unplanned or emergency situations that might occur at  your  facility and
     have made plans to handle these situations  in  ways which minimize threats
     to human health and the environment.

     Testing and Maintenance of Equipment [§264.33].  Your  facility's
communication and/or alarm systems, fire  protection equipment, spill control
equipment, and decontamination equipment  must  be  periodically inspected and
tested to insure proper operation during  an emergency.   The  inspection
procedure must conform to guidelines provided  in  Section  264.15.  The
applicant should prepare an inspection schedule detailing  testing and
maintenance procedures.   The frequency of scheduled testing and  maintenance
will vary depending on the role and reliability of  the  individual pieces of
equipment.  Most emergency equipment requires  a relatively  frequent  and
thorough inspection to insure  that  it will  adequately perform its contingency
function so as to prevent dangerous conditions.   See  Section 	,  Inspections,
for a detailed discussion of inspection  testing and maintenance  requirements.

     The intent of §264.33 is  to insure  that you  have included a 11 your
emergency equipment in the Inspection Plan  and Schedule that you are required,
by §264.15, to prepare and submit with Part B  of  the  permit  application.
Satisfactory compliance with §264.33 can  be achieved by thoroughly referencing
where the emergency equipment  inspection  and maintenance  procedures  can be
found in the Inspection Plan and Schedule.

     Example:

          "All the equipment required by  §264.32  will be  inspected,  tested,
     and maintained as required by  §264.33. A complete list of  the  emergency
     equipment can be found beginning on  page  _ of  the  Contingency Plan
     (Attachment to this application).  Inspections,  tests,  and  maintenance
     are contained in the Inspection Plan and  Schedule  that  is Attachment    to
     this application.  The following table identifies  the  equipment and the
     pages in the Inspection Plan where  testing and maintenance  are  described.

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                    Equipment                     Location  in  Inspection  Plan
Internal Communications
Alarm Systems
Fire Control Equipment
Spill Control Equipment
Decontamination Equipment
Emergency Water Supply System
Access to Communications or Alarm System
pp.
pp.
pp.
pp.
pp.
pp.
[§264.34(a);
14
24
15
29
35
12
1.
and 42
through 28
through 23
through 35
through 41
and 13
The applic
must demonstrate that immediate access  to a communications  or  alarm system is
available to all personnel involved in  hazardous  waste handling  operations.
Access can either be direct or through  visual or  voice contact with another
employee.

     Example:

          "Fifteen wall-mounted switches, wired into an alarm  system,  are
     located throughout building A which houses several hazardous  waste
     processing operations.  The switches are centrally located  to the various
     work stations providing immediate  access to  all employees inside  the
     building.  Personnel involved in outside treatment and landfill
     operations work in two crews of four workmen.   The foreman  of each  crew
     carries a hand-held two-way radio  which can be used to contact the
     control room should an emergency arise."

     Access  to Emergency Services [§264.34(b)].  If there is ever  a situation
where only one employee is on the premises while  the facility  is in operation,
that person  must have immediate access  to an outside communications device
such as a telephone or a hand-held two-way radio with which emergency  help can
be summoned.  When the facility is not  operating, but attended by  a single
individual,  you should still consider the issue of access to outside
communications.

     Required Aisle Space  [§264.35].  The applicant must show that sufficient
aisle space  will be maintained to provide unobstructed movement  of emergency
equipment.   In providing information on aisle space, it would be helpful to
include floor plans indicating the spacial distribution of aisles  relative to
process operations and building entries.

     Example:

          "Aisles within the operations building provide access  to storage
     areas and each process operation.   The aisle width is maintained  at _
      inches to allow passage of two fork trucks.  Aisle boundaries are
     clearly marked with four inch wide orange lines.  Workmen are instructed
     to keep aisles clear  of obstructions at all times."

     Arrangements with Local Authorities  [§264.37(a)].  The permit applicant
is required  to attempt to  make arrangements with appropriate  local agencies in
an effort to coordinate responses to emergency situations.  Any  arrangements
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that are made must be described in detail in the Contingency Plan.   If  you  are
applying for a permit for either an existing or  new facility you must make
these arrangements and submit them in your Contingency Plan with your permit
application.  As part of the "arrangements to familiarize"  that are  required
by §264.37(a)(1),  you should consider touring the local authorities  through
your facility.  This, of course, may not be possible for you to do prior  to
submitting a permit application for a new facility.  However,  an application
for a new facility must, at a minimum,  indicate  that agreements have been
reached and that you have supplied the authorities with some information.   It
may also be to your advantage to indicate in your permit application that you
will supplement that information and provide the opportunity for onsite visits
after the facility is constructed.

     Arrangements with Emergency Services [§264.37(a)(1)] .   Provide  police,
fire and emergency response teams with a layout  of the facility.   Identify
types of hazardous wastes handled, places where  workers are normally working,
facility entrances, roads inside the facility and possible  evacuation routes.
Detailed site maps and floor plans showing water supplies,  process operations,
access routes, etc. would be helpful.  Indicate  any special hazardous
situations which might be encountered (e.g. explosions, toxic fumes, reactive
chemicals) and discuss any special equipment needed to protect personnel  (e.g.
protective clothing, respirators).  It would also be a good idea to  have  fire
department officials visit the plant to inspect  fire protection capabilities
onsite.  If a fire department inspection is required as part of your local
building permit, you should mention that fact in your  application.

     Example:

          "Meetings were held between management, personnel and local fire,
     police and emergency response officials.  Detailed site maps  and building
     floor plans were provided for each agency.   They  have  been given lists of
     wastes being treated, and information detailing hazardous characteristics
     of the wastes involved.  Fire department officials have visited the  site
     and have observed site access routes, the locations of highrisk areas,
     and have inspected fire protection capabilities including sprinkler
     systems and primary and secondary water supplies.  In  addition, the  fire
     department has conducted training exercises using an ignitable  oily
     sludge waste.  The fire department has also provided training for  an
     emergency squad comprised of five plant personnel.  Their role  will  be to
     begin emergency operations immediately, preparing for  the arrival  of the
     local fire department and to guide the fire fighting effort because  of
     their intimate knowledge of plant operations.  They are also  responsible
     for rescue operations and evacuation of injured or threatened personnel."

     Agreements Designating Primary Emergency Authority [§267 .37(a)(1)] .
Local police and fire departments often have reciprocating  emergency response
agreements with departments within the same region.  Where  such agreements
exist, the site owner or operator must attempt to designate specific fire and
police departments as primary emergency authorities.  Site  owners  or operators
must attempt to obtain agreements with other departments to provide  support to
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the primary emergency authority.   Such  agreements  should be obtained in
writing and photocopies should be  included  in the  Contingency Plan  submitted
with the permit application.

     Example:

          "Five towns around  the  facility have fire  departments  operating
     under cooperative assistance  agreements.  The are:  Grey, Acton, Athol,
     Paris, and Middleton.   Only  the Grey and Paris  departments  have agreed to
     assist our fire department (Middleton) in an  emergency response to our
     facility.  We have met with  the Chiefs of those three departments and it
     has been agreed that the Middleton Chief will be responsible for calling
     out the Paris and Grey departments,  in that order,  as needed.  The
     Middleton Chief has been designated  the primary fire equipment
     authority.  He will be with  the Emergency Coordinator in the Emergemcy
     Response Center and will direct his  equipment,  through his  Lieutenant,
     and the other equipment, through their respective Chiefs onsite, from
     that point."

     Agreements with Emergency Response Teams [§264.37(a)(3)1.   The owner or
operator should attempt to make arrangements to the  appropriate  state
emergency response team, emergency response contractor and/or equipment
suppliers.  These arrangements must also be included in the  Contingency Plan
but should be described in the same detail  as the  above example  in  the
application.

     Arrangements with Local  Hospitals [§264.37(a)(4)].  The  owner  or operator
should furnish local hospital officials with information on  the  properties and
types of hazardous waste handled at the facility  In addition,  the  types of
injuries or illnesses that could  result from fires,  explosions or releases of
those hazardous materials should be thoroughly presented to  the  hospital.
With this information, the hospital can develop a  procedure  for  addressing any
special type of injuries which may occur during an emergency.   Include a
detailed discussion of hospital arrangements in the  Contingency  Plan.

     Example:

          "Pesticide residues stored at the facility would produce  harmful
     emissions in the event of a fire.  The hospital has been informed that
     inhalation of these emissions could result in poisoning symptoms.  The
     hospital has a contingency plan calling for decontamination and  treatment
     of potential victims.  The decontamination procedure consists  of removing
     the victims clothing and sealing it in plastic  bags.  The  individuals are
     then bathed and issued clean hospital gowns.   Blood tests  and  chest
     x-rays are then administered to detect any signs of poisoning."

     Failure  to Reach Agreements [§264.37],  If state or local  authorities
decline to enter into arrangements, the owner or operator must  document  the
refusal in the operating record.   You should identify all agencies  with which
agreements could not be reached and identify their reasons  for  declining  to
enter into agreements.
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5.6.3  List of Major Points

     1.   Have the facets of facility design,  construction, maintenance,  and
          operation which contribute  to  preparedness  and  prevention been
          highlighted and discussed?   Have  the places in  the  permit
          application where  details can  be  found  been adequately  referenced?

     2.   Have each of the four required equipment  groups been  discussed  and
          references made to the locations  of  more  detailed information in  the
          Contingency Plan?

     3.   Has a statement been made regarding  emergency equipment testing and
          maintenance?  Has  the Inspection  Plan and Schedule  been referenced?

     4.   Has it been shown  that all  employees have immediate access  to
          communications and alarms?   Has access  to emergency services during
          single employee occupancy been addressed?

     5.   Is there a discussion of aisle space adequacy,  documented by plot
          plans or other drawings?

     6.   Have attempts at arrangements  with  local  authorities  been
          documented?  Are successful agreements  described and  their  location
          in the Contingency Plan referenced?   Have failed agreement  attempts
          been noted?  Have  fire,  police, emergency response, and hospitals
          all been addressed?
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5.7  CONTINGENCY PLAN AND EMERGENCY PROCEDURES

5.7.1  Regulatory Citations

     Information on the Contingency Plan  and Emergency Procedures  must  be
included in Part B of the permit  application,  as  specified  in:

               "§270.14(b)(7)   A  copy of  the contingency plan required  by
          Part 264, Subpart  D.  Note:  Include where  applicable, as  part of
          the contingency plan, specific  requirements in §264.227  and 264.255."

     The regulatory requirements  regarding  the Contingency  Plan are  contained
in Subpart D of Part 264.  They are:

          "Subpart D—Contingency Plan and  Emergency  Procedures

          §264.50  Applicability.
               The regulations  in this Subpart apply  to owners and operators
          of all hazardous waste  facilities,  except as §264.1 provides
          otherwise.

          §264.51  Purpose and  implementation of  contingency plan.
               (a) Each owner or  operator must have a contingency  plan  for his
          facility.  The contingency plan must be designed  to minimize  hazards
          to human health or the  environment from fires, explosions, or any
          unplanned sudden or non-sudden  release  of hazardous waste  or
          hazardous waste constituents to air, soil,  or surface water,
               (b) The provisions of the  plan must be carried out  immediately
          whenever there is  a  fire, explosion, or release of hazardous  waste
          or hazardous waste constituents which could threaten human health  or
          the environment.

          §264.52  Content of  contingency plan.
               (a) The contingency plan must describe the actions  facility
          personnel must take  to  comply with §264.51  and 264.56  in response  to
          fires, explosions, or any unplanned sudden  or non-sudden release of
          hazardous waste constituents to air, soil,  or surface water at  the
          facility.
               (b) If the owner or operator has already prepared  a Spill
          Prevention, Control,  and Countermeasures (SPCC) Plan in  accordance
          with Part 112 of this Chapter,  or Part  1510 of Chapter V,  or  some
          other emergency or contingency  plan, he need only amend  that  plan  to
          incorporate hazardous waste management  provisions that  are
          sufficient to comply  with the requirements  of this Part.
               (c) The plan must  describe arrangements agreed to  by local
          police departments,  fire departments, hospitals,  contractors, and
          State and local emergency response teams to coordinate  emergency
          services, pursuant to §264.37.
               (d) The plan must  list names, addresses, and phone  numbers
          (office and home)  of  all persons  qualified  to act as emergency
          coordinator (see §264.55), and  this list must be  kept up to date.
          Where more than one  person is listed, one must be named  as primary

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emergency coordinator and others must be listed in the order in
which they will assume responsibility as alternates.  For new
facilities, this information must be supplied to the Regional
Administrator at the time of certification, rather than at the time
of permit application.
     (e) The plan must include a list of all emergency equipment
at the facility (such as fire extinguishing systems, spill control
equipment, communications and alarm systems (internal and external),
and decontamination equipment), where this equipment is required.
This list must be kept up to date.  In addition, the plan must
include the location and a physical description of each item on the
list, and a brief outline of its capabilities.
     (f) The plan must include an evacuation plan for facility
personnel where there is a possibility that evacuation could be
necessary.  This plan must describe signal(s) to be used to begin
evacuation, evacuation routes, and alternate evacuation routes (in
cases where the primary routes could be blocked by releases of
hazardous waste or fires).

§264.53  Copies of contingency plan.
     A copy of the contingency plan and all revisions to the plan
must be:
     (a) Maintained at the facility; and
     (b) Submitted to all local police departments; fire departments,
hospitals, and State and local emergency response teams that may be
called upon to provide emergency services.

§264.54  Amendment of contingency plan.
     The contingency plan must be reviewed, and immediately amended,
if necessary, whenever;
     (a) The facility permit is revised;
     (b) The plan fails in an emergency;
     (c) The facility changes—in its design, construction,
operation, maintenance, or other circumstances—in a way that
materially increases the potential for fires, explosions, or
releases of hazardous waste or hazardous waste constituents, or
changes the response necessary in an emergency;
     (d) The list of emergency coordinators changes; or
     (e) The list of emergency equipment changes.

§264.55  Emergency coordinator.
     At all times, there must be at least once employee either on
the facility premises or on call (i.e., available to respond to an
emergency by reaching the facility within a short period of time)
with the responsibility for coordinating all emergency response
measures.  This emergency coordinator must be thoroughly familiar
with all aspects of the facility's contingency plan, all operations
and activities at the facility, the location and characteristics  of
waste handled, the location of all records within the facility, and
the facility layout.   In addition, this person must have the
authority to commit the resources needed to carry out the
contingency plan.

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§264.56  Emergency procedures.
     (a) Whenever there is an imminent or actual emergency situation,
the emergency coordinator (or his designee when the emergency
coordinator is on call) must immediately:
     (1) Activate internal facility alarms or communication systems,
where applicable, to notify all facility personnel; and
     (2) Notify appropriate State or local agencies with designated
response roles if their help is needed.
     (b) Whenever there is a release, fire, or explosion, the
emergency coordinator must immediately identify the character,  exact
source, amount, and areal extent of any released materials.  He may
do this by observation or review of facility records or manifests,
and, if necessary, by chemical analysis.
     (c) Concurrently, the emergency coordinator must assess possible
hazards to human health or the environment that may result from the
release, fire, or explosion.  This assessment must consider both
direct and indirect effects of the release, fire, or explosion
(e.g., the effects of any toxic, irritating, or asphyxiating gases
that are generated, or the effects of any hazardous surface water
run-off from water or chemical agents used to control fire and
heat-induced explosions).
     (d) If the emergency coordinator determines that the facility
has had a release, fire, or explosion which could threaten human
health, or the environment, outside the  facility, he must report his
findings as follows:
     (1) If his assessment indicates that evacuation of local areas
may be advisable, he must immediately notify appropriate local
authorities.  He must be available to help appropriate officials
decide whether local areas should be evacuated; and
     (2) He must immediately notify either the government official
designated as the on-scene coordinator for that geographical area,
(in the applicable regional contingency  plan under Part 1510 of this
Title) or the National Response Center (using their 24-hour toll
free number 800/424-8802).  The report must include:
     (i) Name and telephone number of reporter;
     (ii) Name and address of  facility;
     (iii) Time and type of incident (e.g., release, fire);
     (iv) Name and quantity of material(s) involved, to the extent
known;
     (v) The extent of injuries, if any;  and
     (vi) The possible hazards to human  health; or the environment,
outside the facility.
     (e) During an emergency,  the emergency coordinator must take
all reasonable measures necessary to ensure that fires, explosions,
and releases do not occur, recur, or spread to other hazardous waste
at  the  facility.  These measures must  include, where applicable,
stopping processes and operations, collecting and  containing
released waste, and removing or  isolating containers.
     (f) If the  facility  stops operations  in response  to a fire,
explosion, or release, the emergency coordinator must monitor for
leaks,  pressure buildup,  gas generation,  or ruptures in valves,
pipes,  or other equipment, whenever this  is appropriate.

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               (g) Immediately after an emergency,  the emergency coordinator
          must provide for treating, storing,  or disposing of recovered waste,
          contaminated soil or surface water,  or any other material that
          results from a release,  fire, or explosion at the facility.
               (h) The emergency coordinator must ensure that, in the  affected
          area(s) of the facility;
               (1) No waste that may be incompatible with the released
          material is treated, stored, or disposed  of until cleanup procedures
          are completed; and
               (2) All emergency equipment listed in the contingency plan is
          cleaned and fit for its  intended use before operations are resumed.
               (i) The owner or operator must notify the Regional
          Administrator, and appropriate State and  local authorities,  that the
          facility is in compliance with paragraph  (h) of this Section before
          operations are resumed in the affected area(s) of the facility.
               (j) The owner or operator must note  in the operating record the
          time,  date, and details  of any incident that requires implementing
          the contingency plan.  Within 15 days after the incident, he must
          submit a written report  on the incident to the Regional
          Administrator.  The report must include:
               (1) Name, addressj  and telephone number of the owner or
          operator;
               (2) Name, address,  and telephone number of the facility;
               -(3) Date, time and  type of incident  (e.g., fire, explosion);
               (4) Name and quantity of material(s) involved;
               (5) The extent of injuries, if any;
               (6) An assessment of actual or potential hazards to human
          health or the environment, where this is  applicable; and
               (7) Estimated quantity and disposition of recovered material
          that resulted from the incident."

5.7.2  Guidance to Achieve the Part 264 Standards

5.7.2.1  General—
     The intent of Subpart D of Part 264 is to insure that all permit
applicants have developed and formalized a Contingency Plan for their
facilities that will be immediately implemented in  the event of a fire,
explosion, or other unplanned occurrence that has or could present a hazard to
human health or release hazardous  waste to the environment.

     Subpart D sets requirements on:

     •    The purpose and implementation of the contingency plan in §264.51,

     •    Content of the contingency plan in §264.52,

     •    Copies of the contingency plan in §264.53,

     •    Amendments of the contingency plan in §264.54,

     •    Emergency coordinator in  §264.55, and

     •    Emergency procedures in  §264.56.

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The most effective method for an applicant to demonstrate compliance with the
requirements o£ Subpart D is to develop a formal Contingency Plan and submit
that plan as part of Part B of the permit application.   The Contingency Plan
should be a document written for use by facility personnel in the event of the
occurrence of an emergency or unplanned event.  In addition to submitting your
actual Contingency Plan document, your permit application should include a
discussion which identifies where, in the Contingency Plan, the requirements
of Subpart D are addressed.  This discussion will allow agency personnel who
review your application to quickly confirm that your Contingency Plan is
adequate.

     There are no provisions for a waiver or exemption from the requirement
for a Contingency Plan.  All owners and operators must develop a Contingency
Plan and submit it with Part B of their permit applications.  However, the
preparedness and prevention requirements set forth in Subpart C of Part 264
are closely tied to the Contingency Plan requirements.   Subpart C requirements
were discussed in the preceding section of this manual.  Thus, although a
specific facility may be exempted from certain preparedness and prevention
requirements in SubparC C, all facilities must have a Contingency Plan that
addresses applicable requirements of Subpart C and all requirements of
Subpart D of Part 264.  After review and modification or approval, your
Contingency Plan will become a condition of your permit.

     Owners and operators of surface impoundments must also provide, in their
Contingency Plan, procedures that address how compliance with the requirements
of §264.227(b) will be achieved.  At this time (May 1983), there are no other
facility-type specific Contingency Plan requirements.  However, the EPA may
well add these requirements to Subparts I through 0 of Part 264 in the
future.  Owners and operators of facilities should contact the government
agency to which they will submit their permit application to determine if
there are any facility specific Contingency Plan requirements in effect at the
time they are preparing Part B of their application.

5.7.2.2  Contingency Plan and Emergency Procedures [40 CFR 270.14(b)(7) and
§264.50-264.56] —
     Applicability  [§264.50].  All permit applicants must provide a copy of
their Contingency Plan unless they have been exempted as specified in §264.1

     Purpose and Implementation of Contingency Plan  [§264.51].  The
contingency plan for your facility must be designed to minimize hazards to
human health or the environment  from  fires, explosions, or any unplanned
sudden or nonsudden release of hazardous waste or hazardous waste constituents
to air,  soil, or surface water.  Your Contingency Plan must demonstrate that
specified emergency procedures will be implemented immediately whenever a
hazard at the facility occurs.

     Content of Contingency Plan  [§264.32].  Your contingency  plan must
describe the actions that facility personnel will take to comply with and
implement the plan  (§264.51) including emergency  procedures  (§264.56).  If you
have already prepared a Spill Prevention, Control, and Countermeasures  (SPCC)
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Plan or other emergency or Contingency Plan for your facility, amendments to
that plan may fulfill the requirements of Subpart D.  If so, the amended plan
should be submitted with Part B of your permit application.  A sample table of
contents for a Contingency Plan is shown in Table 5-20.

     The following four components are specifically identified in §264.52,
paragraphs (c) through (f), as necessary for inclusion in an adequate
Contingency Plan.

     Coordinated Emergency Services (§264.52(c))—A coordinated emergency
services plan must be arranged and agreed to by local police departments, fire
departments, hospitals, contractors, State and local emergency response teams,
and the HWM facility's owner or operator, pursuant to §264.37.  You should
obtain written agreements whenever possible.  See the discussion in the
preceding section of this manual on Subpart C—Preparedness and Prevention
(§264.37) for additional information on coordinated emergency services.

     Copies of written agreements must be included in the Contingency Plan
document.  Remember, the Contingency Plan is written for use by your
personnel.  Therefore, in addition to copies of the written agreements,
detailed instructions should be included in the Contingency Plan of how
coordinated emergency services are obtained, what will be provided, and how
they will be managed.  The part of your permit application where you are
describing these arrangements to the regulatory agency can be general and
brief provided that you reference the specific part of the Contingency Plan
where details are provided.

     In Table 5-20, the example table of contents indicates that Part 5 of the
Contingency Plan contains information on Coordinated Emergency Services.  In
the part of your permit application where you are describing these services to
the regulatory agency, you could make a statement similar to;

               "Coordinated Emergency services agreements have been
          established in writing with:  the fire departments of Middleton,
          Grey,  and Paris;  the Middleton Police and the  State Police; the
          Bellevue Hospital in Middleton and the Acton State Hospital in
          Acton;  and HazCon Services, Inc. in Athol.  No written agreement has
          been established with the State emergency response team.   That team
          has indicated that they are required by State  Law to cooperate in
          the event of an emergency.  All the above identified groups have
          toured our facility, participated in development of the Coordinated
          Emergency Services section of our Contingency  Plan, and have been
          supplied with copies of that Plan.  The Coordinated Emergency
          Services section begins on page 	 of the Contingency Plan
          (attachment 	 to this application) and contains copies of the
          written agreements as well as complete procedures for activating and
          coordinating the indicated emergency services."
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 TABLE 5-20.   SAMPLE TABLE OF CONTENTS FOR A CONTINGENCY PLAN


1.   Purpose

2.   Scope

3.   Responsibilities

4.   Organization and Duties

5.   Coordinated Emergency Services

6.   Training

7.   Routine Surveillance to Detect Potential Hazards

8.   Emergency Procedures

    A.  Fire

    B.  Explosion

    C.  Hazardous Waste Release

9.   Evacuation Plans

10. Recordkeeping and Incident Reports

Appendix A—List of Emergency Coordinators, names, addresses
            and phone numbers

Appendix B—List of Emergency Equipment

Appendix B—Incident Reports
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     In your Contingency Plan,  the Coordinated  Emergency Services  section
should be written to instruct facility personnel on "how to" obtain and
coordinate those services.   An  example of how that section of your plan might
be presented is given below:

     "This section of the Contingency Plan identifies available off-plant
Emergency Services.  Written agreements with these off-plant groups are at the
end of this section.  These services are to be  requested only by the In-Plant
Emergency Coordinator.

     •    Call the Middleton Fire Department, Telephone No. 774-9191

     •    Notify the Plant  Fire Coordinator to  meet fire equipment at the  West
          Gate with mobile  radio.

     •    Plant Fire Coordinator will send ranking responding officer to
          Emergency Control Center.

     •    Plant Fire Coordinator will stay with fire equipment.

     •    The ranking responding fire department officer will direct equipment
          from Control Center until replaced by the Middleton Fire Chief on
          his arrival.

     •    All Plant Fire Team Leaders will report to ranking fire  department
          officer at fire site  on his arrival.

     •    Fire department personnel will not enter process buildings or tank
          pits.  They will  provide equipment, support, and rescue  services to
          Plant Fire Teams."

     Your plant-specific Contingency Plan will, of course, be organized and
worded as is best suited to your facility.  However, the point of  the above
example is that the Coordinated Emergency Services part of the Plan, and all
other parts, should be presented as instructions to your personnel.  The
Contingency Plan should be  specific regarding what to do, who to notify, and
in the case of off-plant assistance, what those groups will and will not do
during the emergency.

     List of Emergency Coordinators (§264.52(d))—A list of names, addresses,
and phone numbers (office and home) of all persons qualified to act as
emergency coordinators (see §264.55) in the order in which they will assume
responsibility must be included.  The choice of emergency coordinator and
alternates is extremely important.  Since §264.55 requires that the emergency
coordinator "must have the  authority to commit  the resources needed to carry
out "the contingency plan,"  it is strongly suggested that you consider
personnel from facility management positions for the required list.
Additional guidance on choosing emergency coordinators is provided in this
section of the manual in the discussion of §264.55.
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     The provisions of §264.52(d)  require only that the list of emergency
coordinators be included in the Contingency Plan.   However,  from an
operational standpoint, copies of this list should probably be posted in
various parts of the facility such as control rooms and guardhouses.

     Note that this list of emergency coordinators does not have to  be
submitted with your application for new facilities.  In these cases,  the list
can be submitted at any time before you begin operations at the completed
facility.  Although you may not be able to supply  names and associated details
on emergency coordinators for a new facility at the time of application
submittal, you should consider identifying the personnel by position  title
when you submit your application.

     Table 5-21 is an example of a format that could be used for the  emergency
coordinators list.  Ideally, there would be one person from the list  at the
facility (onsite)  at any given time.   Alternatively,  the primary coordinator
should be the most senior member of the staff closest to the facility.   In
addition to a list such as this,  it is recommended that you identify  the
onsite emergency coordinator for those periods (nights, weekends,  vacations)
when the primary emergency coordinator is not onsite.

     List of Emergency Equipment (§264.52(e))—You must list all emergency
equipment at the facility that is  applicable to facility operations.   Include
the location, a physical description, and the capabilities of each item
listed.  As specified in §264.32,  the list must include the following:

     •    Internal communication or alarm system

     •    External communication system

     •    Fire extinguishing systems (including primary and secondary water
          supplies)

     •    Spill control equipment

In addition to listing the emergency equipment, the Contingency Plan  must
include a physical description of  each item on the list, provide its  location,
and give a brief outline of its capabilities.  Remember that this list will be
used by your personnel during an emergency.  The format chosen for the list
should, therefore, allow identification of any needed equipment and its
location in the easiest possible manner.  It is suggested that a plot plan
showing the locations of the equipment also be included in the Contingency
Plan.

     Evacuation Plan (§264.52(f))—An evacuation plan for the safe egress of
facility personnel must be developed.  Recognizable signals to commence an
evacuation, routes, alternate evacuation routes (in case primary exit routes
are blocked by releases of hazardous waste or fires), and safe assembly areas
to account  for all evacuated personnel should be noted in the plan.   Maps
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                                 TABLE 5-21.   EMERGENCY COORDINATORS LIST
                                                                                           Date:
NOTE ; CONTACT IN ORDER LISTED


(SEE NOTE 1) Supersedes all lists dated:
and earlier.
Telephones
Name & home address Work Home Availability cm-site Comments
PRIMARY
ALTERNATES

NOTE 1: On
John Gregson
15 Park Dr.
Acton
Bill Johnson
180 Boston St.
Middle ton
Sam Houston
17 Sycamore St.
Grey
Steve Sforza
1919 Columbia Ave
Athol
Dave McNulty
63 Bourne Dr.
Middleton
nights (2nd and 3rd
X 500 (555)690-4673 Mon.-Fri, 08:00 a.m. -05:00 p.m. * J. G. must be notified
Sat. 09:00 a.m. -Noon of all emergency
situations.
* See Note 2.
X 503 {555)919-5623 Mon.-Fri. 08:00 a.m. -05:00 p.m. * B. J. must be called
Page: 766 Sun. Noon-05:00 p.m. in for all emergency
situations.
» See Note 1.
X 520 (555)523-5772 Mon.-Fri. 04:30 p.m. -01:00 a.m.
Page: 768
X 534 (555)734-7872 Tues.-Sat. 12:30 a.m. -08:30 a.m.
Page: 773
X 557 (555)774-6051 Rotating « Guardhouse will know
Page: 771 if McNulty is on-site.
shifts) and weekends contact Coordinator on-site first - then contact B.
Johnson.
NOTE 2:  Alternative home phone for Gregson is (617)224-9139  on weekends.

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clearly delineating evacuation  routes,  fire  fighting  equipment,  alarms  and
assembly areas should be prepared.   In  addition,  the  applicant should note  the
presence of employee training sessions, fire drills,  and  the  placement  of
evacuation maps posted at the facility.

     Table 5-22 is an example of an  Evacuation Plan  format  and content.  The
Evacuation Plan is extremely important  to insure  that employees are safely
removed from danger and are not inhibiting plant  and  outside  emergency
personnel from effectively dealing with the emergency.  The plan in Table  5-22
is only an example.  You will have to develop an  Evacuation Plan specific  to
the needs of your facility and it must  be included in your  Contingency  Plan
document.

     Copies of Contingency Plan [§264.53].  The applicant must submit a copy
of the Contingency Plan to the EPA Regional  Administrator with Part B of the
permit application.  In addition, copies of your  Contingency  Plan and all
revisions to the plan must be:

     (a)  maintained at the facility; and

     (b)  submitted to all local police departments,  fire departments,
          hospitals, and State and local emergency response teams that  may
          provide emergency services to the facility.

It is suggested that numbering the individual copies of the Contingency Plan
and keeping a log of where each copy is located will assist in updating the
Plan when necessary.  Regardless, your permit application should state  how
many copies of your Contingency Plan exist and to whom the  copies were  given.
Your application should also state how many copies are retained at your
facility and, as specifically as possible, where  they are located.

     Amendment of Contingency Plan. [§264.54].  The Contingency Plan, must be
reviewed and immediately amended, if necessary, whenever:

     (a)  The facility permit is revised;

     (b)  The plan fails in an emergency;

     (c)  The facility design, construction, operation, maintenance, or other
          circumstances change to increase the potential for fires,
          explosions, or releases of hazardous waste or hazardous waste
          constituents, or changes the response necessary in an emergency;

     (d)  The list of emergency coordinators changes; or

     (e)  The list of emergency equipment changes.
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                  TABLE 5-22.  EMERGENCY EVACUATION PROCEDURES
PURPOSE:  Plan for safe evacuation in the event of an emergency.

RESPONSIBILITIES:

1.   The Emergency Coordinator is responsible for implementing the evacuation
     procedure.

2.   Each Area Monitor is responsible for directing employees and visitors  in
     his/her section to the proper exit and their assigned safe area outside
     (see assignments).

PROCEDURE:

1.   The Emergency Coordinator will notify supervisors and Area Monitors  if an
     evacuation may be necessary.

2.   The Emergency Coordinator will assess the conditions and order an
     evacuation or other actions required.

3.   When an evacuation is announced stop work.  The Area Monitors will direct
     employees in their areas to the closest available exit.

4.   All employees must leave the facility and report to the designated
     assembly area.  Do not run.  Do not linger in entrance ways or driveways,
     stay together in your assigned safe area.

5.   Each employee must report to his/her Area Monitor once outside the
     building.

6.   Each Area Monitor must report to the Emergency Coordinator when his/her
     employees have cleared the facility.

7.   The Emergency Coordinator will notify the Area Monitors when it is safe
     to re-enter the facility.

8.   Stay outside the facility until notified by the Area Monitors to
     re-enter.

EVACUATION ROUTES, EXIT ASSIGNMENTS:

1.   The attached floor diagrams (see Figure 7A) of Company X show each
     section of the office area and facility and the best route for each
     section to use when evacuating the building.  Fire alarms and fire
     extinguishers are also noted on the diagrams.

2.   The designated assembly areas for each section of the facility are shown
     in Figure 7A.
                                   (continued)
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                             TABLE 5-22 (continued)
EMERGENCY PRECAUTIONS:

1.   Keep calm, think, avoid panic and confusion.

2.   Know all exit locations:  Be sure you know the safest and quickest way
     out of all buildings.

3.   Do not lock office doors when vacating the facility.  The Emergency
     Coordinator and emergency support personnel must have visual access to
     all areas to ensure that the facility is clear of personnel.

4.   Do not delay evacuation of the facility for any reason.

5.   Do not assist in fire  control unless properly trained and qualified.

6.   Do not use voice paging system.  The paging system must be left open for
     issuing plantwide instructions.

7.   When evacuating the facility WALK to the nearest safe exit.  Report to
     the safe areas away from the buildings and wait for instructions.

8.   Keep out of the way, stay clear of the facility, and DO NOT interfere
     with emergency operations.

9.   DO NOT reenter the facility until instructed to do so.
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The requirements of this section (§264.54) are intended for owners or
operators of facilities that have previously prepared and submitted a
Contingency Plan with Part B of their permit application.  Amendments would be
required only after EPA approval of the initial Contingency Plan and if one or
more of the aforementioned conditions exist at the applicant's facility.
Because the Contingency Plan will be a condition to your facility permit,  any
amendments to it will be judged a modification to the facility permit.
However, changes to the lists of emergency coordinators or emergency equipment
constitute minor modifications to the permit.

     Because of the importance of this document during emergency situations,
you should consider identifying a specific person, by name or title, who would
be responsible for all revisions to all copies, on a periodic basis and on an
"as needed" basis.  Your permit application should clearly indicate how the
copies of your Contingency Plan will be amended when the need arises.   You
should place special emphasis on how offsite copies of the plan will be
amended and, especially, how you will be assured that amendments are
incorporated into those copies.

     Emergency Coordinator [§264.55].  The applicant should select at least
one employee who is either on the facility premises during peak operational
periods (preferred) or available to respond to an emergency by reaching the
facility within a short period of time.  This employee should be designated
the primary emergency coordinator.  The emergency coordinator is responsible
for coordinating all emergency response measures, and being thoroughly
familiar with:

     (a)  the facility's contingency plan,

     (b)  all operations and activities at the facility,

     (c)  the location and characteristics of waste handled,

     (d)  the location of all records within the facility, and

     (e)  the physical layout of the facility.

     The selected emergency coordinator should have the authority to expend
funds and recruit employees to implement the Contingency Plan.  The
owner/operator should also select alternative employees to act as emergency
coordinators if for some reason the designated emergency coordinator is
unavailable.

     Your selection of the proper primary emergency coordinator and
alternatives is extremely important to successful implementation of your
Contingency Plan, when and if it needs to be implemented in an emergency.   The
agency reviewing your application will pay particular attention to the
qualifications of the persons named in your Contingency Plan.   You should
therefore include in your application a brief biographical sketch of the
background and experience of the named personnel with your justification for
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appointing them as emergency coordinators.   Your application should also
describe how the coordinators will be contacted in an emergency and who is
responsible for insuring that notification.

     Because §264.55 requires that your emergency coordinator have the
authority to commit company resoures in an emergency situation, you should
consider naming only the highest-ranking personnel to positions as
coordinators.  If a named coordinator must continually contact an offsite
senior executive for approval of his actions,  it is unlikely that the
reviewing agency will approve his designation  as a coordinator.  However, it
may be acceptable in certain cases to identify less senior personnel as
emergency coordinators for second and third shifts and weekends provided that
the person identified will act in that capacity only for the period required
for a senior executive to arrive from offsite  and assume primary emergency
coordinator responsibilities.

     The following two examples are offered to indicate the detail which your
discussion of emergency coordinators should achieve in your permit
application.  The first example addresses the  biographical and experience
qualifications that would justify the choice of a coordinator.  The second
example addresses the type of discussion on notification of coordinators that
should be in your application.  Both examples  are based on the example list of
emergency coordinators presented previously in Table 5-21.

     Example 1:  "Mr. John Gregson has been selected as primary emergency
     coordinator for this company.  Mr. Gregson is a civil engineer and Vias
     been employed at this company for 12 years.  He is presently Plant
     Manager at the facility.  During his employ he has participated in the
     planning and operation of all facility activities.  He is well suited  for
     this position because he assisted in the  preparation and review of the
     Contingency Plan and is thoroughly familiar with the facility, operations
     and activities, and location of records.   As Plant Manager, Mr. Gregson
     has the necessary authority to commit resources to implement the
     Contingency Plan."

     Example 2:  "The list of emergency coordinators is contained in all
     copies of the Contingency Plan.  In addition, it is posted next to the
     outside phones in all three control rooms and in the two Guardhouses.
     The Shift Supervisor in the area where the emergency occurs is
     responsible for notifying the emergency coordinator.  If the Shift
     Supervisor is not in the control room at the time the emergency occurs, a
     senior operator in each control room has  been identified and instructed
     to notify the emergency coordinator.

     During second and third shifts and on weekends the onsite emergency
     coordinator  (Mr. Houston, Mr. Sforza, or Mr. McNulty) will immediately
     call in Mr. Bill Johnson, who is the Chief Plant Engineer, and resides
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     4 miles from the  plant.   The  onsite  coordinator  will  implement  his  duties
     and transfer them to Mr.  Johnson on  his  arrival.   When Mr.  Johnson  cannot
     be called in,  Mr.  Gregson will  be called in."

     Emergency Procedures [§264.56].  The applicant must discuss emergency
procedures in the Contingency  Plan in his application.   The emergency
procedures required to comply  with §264.56 are explicitly outlined in the
standard.  The responsibility  for  implementing the  procedures are divided
between the emergency  coordinator  and the owner or  operator  of the facility.
The eight (8) emergency procedures implemented by the emergency coordinator
when a fire, explosion or hazardous  waste release occurs are:

    Xa)  Active facility alarms and notify appropriate State or local
          agencies;

    ,^(b)  Identify the character,  exact source, amount, and areal extent of
          any released material;

     (c)  Assess possible direct and indirect hazards to human health or the
          environment  that may result from the release, fire, or explosion;

          Determine if evacuation  of local areas is required, and immediately
          notify either the government official designated as on-scene
          coordinator  or the National Response Center;

          Insure that  fires, explosions,  and  releases do not  occur,  recur, or
          spread to other hazardous  waste at  the facility;

          Monitor for  leaks, pressure buildup, gas  generation, or ruptures in
          valves, pipes, or other  equipment if facility operations cease;

          Provide treatment, storage, and disposal  of any material that
          results from a release,  fire, or explosion  immediately after an
          emergency; and

     (h)  Insure that  no waste incompatible with the  released material is
          processed until cleanup  procedures  are completed and all emergency
          equipment listed in  the  Contingency Plan  is cleaned and fit for its
          intended use.

     The two (2) emergency procedures implemented by  the owner or operator of
     the facility are:

     (a)  Notify the EPA Regional  Administrator and State and local
          authorities  that the facility is in compliance with §264.56(h)
          before operations commence; and

     (b)  Record the time, date, and details  of any incident  that requires
          implementing the Contingency Plan and submit a written report  on the
          incident to  the EPA  Regional Administrator  within  15 days  of the
          incident.
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     Your Contingency Plan must contain specific instructions for the
emergency coordinator to follow and implement.  The contents of §264.56
indicate what the emergency coordinator must do and your Contingency Plan
should be specific as to how those items will be accomplished by listing
specific steps that the coordinator will take.  You should include a
discussion of these steps in your permit application that will identify what
instructions in the Contingency Plan emergency procedures are intended to
address the eight specific items in §264.56(a) through (h).  However, because
Contingency Plan must be facility specific, it is likely that additional
procedures will be necessary.

     The steps which the owner or operator must take after the emergency is
over are presented in §264.56(i) and (j).  The Contingency Plan should
indicate how the owners or operators will confirm that the facility  is in
compliance with §264.56(h).

     The Contingency Plan should also  include specific instruction on how  to
prepare the report required by §264.56(j).  Your discussion of the owner's and
operator's responsibility in your permit application should identify the
specific places in the Contingency Plan where procedures designed to comply
with §264.56(i) and  (j) are located.

     Contingency Plan Requirements for Surface Impoundments (§264.227).
Subpart K of Part 264 contains requirements for surface impoundments.  In
particular, §264.227 presents  criteria for when a surface  impoundment must be
removed from service in §264.227(a) and what must be done  to remove  it from
service in §264.227(b).  Section 264.227(c) then requires  that procedures  for
complying with the requirements of §264.227(b) must be specified in  the
Contingency Plan.

5.7.3  List of Ma j or Po in t s

     1.   Does your  company have a Contingency Plan?  Can  another plan be
          amended to comply with Subpart D?

     2.   Describe in detail the emergency procedures and  evacuation plan  of
          your facility.

     3.   Identify all key  personnel and equipment  required to  implement  the
          plan.

     Additional background  discussion  on the  Contingency Plan  can be found in
the preamble on Subpart D in the May  L9, 1980 Federal Register at page 33183.
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5.8  GENERAL HAZARD PREVENTION

5.8.1  Regulatory Citations

     Information on hazard prevention must be submitted with Part B of the
permit application, as required by:

               "270.14(b)(8) A description of procedures, structures, or
          equipment used at the facility to:
               (i) Prevent hazards in unloading operations (for example,
          ramps, special forklifts);
               (ii) Prevent run-off from hazardous waste handling areas to
          other areas of the facility or environment, or to prevent flooding
          (for example, berms, dikes, trenches);
               (iii)  Prevent contamination of water supplies;
               (iv) Mitigate effects of equipment failure and power outages;
          and
               (v) Prevent undue exposure of personnel to hazardous waste (for
          example, protective clothing)/'

     The §270.14(b)(8) regulatory requirements do not identify specific
Part 264 standards with which the application information must prove
compliance.  However, the five informational items identified in §270.14(b)(8)
are clearly stated and are likely to be addressed by information developed for
and included in the Part B application for other purposes.

5.8.2  Guidance to Achieve the Part 264 Standards

     The requirements of §270.14(b)(8) do not identify any specific Part 264
standards.  However,  the intent of requiring a description of procedures,
structures, or equipment used in hazard prevention is to draw the applicant's
attention to the five potential sources of hazards which are listed in
§270.14(b)(8).

     It is likely that another part of your application may already identify
procedures, structures, or equipment applicable to the five items in
§270.14(b)(8).  In those cases, you can either repeat or reference those
discussions to demonstrate compliance with §270.14(b)(8).  Specifically, the
requirements of §270.14(b)(8)(i)(iv), and (v) may well be addressed in your
discussion of preparedness and prevention or your Contingency Plan (see
Sections 5.6 and 5.7 of this manual).  Likewise, the run-off requirement of
§ 270.14(b)(8)(ii) will be addressed in your response to your facility's
specific design standards in Part 264 and flooding will be addressed in your
analysis of facility location required by §270.14(b)(11) (see Section 5.11 of
this manual).  The requirements of §270.14(b)(8)(ii) will be addressed in your
discussion of compliance with Subpart F of Part 264,  The specific request for
information identified by §270.14(b)(8) should also serve as a check that you
have addressed these issues adequately in other portions of your Part B permit
application.
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     When identifying and discussing procedures,  structures,  or equipment used
at your facility to prevent hazards in unloading  operations,  you should also
present information regarding loading operations  if applicable.  In order to
be thoroughly responsive to §270.14(b)(8)(i) ,  your discussion should indicate
that you have identified the potential hazards that exist or could result
during loading and unloading and have taken positive steps to minimize or
eliminate the likelihood of their occurrence.

     Your facility's run-off controls, flooding potential, and flood control
measures are likely to have been presented  in your permit application under
the discussions to demonstrate compliance with facility design and location
standards.  However, in your response to §270.14(b)(8)(ii),  you should also
consider demonstrating that drainage in and around your facility is sufficient
to handle short duration, high intensity storm events.   Even if your facility
is not in a 100-year floodplain, surface drainage during short duration,  high
intensity storms could result in flooding because of the topography around
your facility.  You should consider addressing this issue in your permit
application.  At a minimum, your discussion to address  §270.14(b)(8)(ii)
should reference the locations in your application where the  details of your
run-off and flood prevention procedures, structures, or equipment are
presented.

     The overall intent of the Part 264 standards, and  especially Subpart F of
Part 264, is the protection of ground water and surface water.  Your response
to §270.14(b)(8)(iii) should be used to summarize the key features of your
facility's procedures, structures, or equipment that are intended to prevent
contamination of water supplies.  Your discussion should direct an application
reviewer to the parts of your application  where details are presented.

     Any procedures, structures, or equipment that are  used to mitigate the
effects of a power outage or equipment failure should be addressed in detail
in your Contingency Plan (see Section 5.7  of this manual).  Thus, your
response to §270.14(b)(8)(iv) could be a summary which  also references the
portions of your application and Contingency Plan where details are
presented.  You need only address equipment failures and power outages to the
extent that their occurrence has the potential to cause a violation of your
permit or a release of hazardous waste.  However, you should address equipment
failures over which you have no control, either because they result from acts
of nature or because the equipment is maintained by a supplier.

     When you prepare a response to §270.14(b)(8)(v), you should address both
routine and emergency procedures, structures,  or equipment that will be
employed to protect personnel from undue exposure to hazardous waste.  Your
Contingency Plan should address emergencies and can be referenced for
compliance with the §270.14(b)(8)(v)  requirement.  However, routine personnel
protection must also be discussed.  Subpart I—Personal Protective Equipment
of the Occupational Safety and Health Standards in 29 CFR 1910 should be used
as guidance when addressing  §270.14(b)(8)(v).  The amount of training that
personnel will  receive  in  protection  procedures,  structures, or equipment
should be indicated in your  application.  Passive personnel protection items
should also be  identified.
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5.8.3  Listof Major Points

     1,   Have each of the five hazard prevention, areas been discussed in the
          application?

     2.   Have other locations in the application where details can be found
          been properly referenced?
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5.9  PREVENTION OF IGNITION OR REACTION OF WASTES

5.9.1  Regulatory Citation

     Information on precautions employed to prevent accidental  waste ignition
or reaction must be submitted with Part B of the permit  application, as
specified in:

               "§270.14(b)(9)  A description of precautions to  prevent
          accidental ignition or reaction of ignitable,  reactive,  or
          incompatible wastes as required to demonstrate compliance with
          §264.17 including documentation demonstrating  compliance with
          §264.17(c)."

     The regulatory requirements regarding the precautions required are
contained in §264.17.   They are:

          "§264.17  General requirements for ignitable,  reactive,  or
          incompatible wastes.
               (a)  The owner or operator must take precautions to prevent
          accidental ignition or reaction of ignitable or reactive waste.
          This waste must be separated and protected from sources  of ignition
          or reaction  including but not limited to:  open flames,  smoking,
          cutting and  welding, hot surfaces, frictional  heat, sparks (static,
          electrical,  or mechanical), spontaneous ignition (e.g.,  from
          heat-producing chemical reactions), and radiant heat. While
          ignitable or reactive waste is being handled,  the owner  or operator
          must confine smoking and open flame to specially designated
          locations.  "No Smoking" signs must be conspicuously  placed wherever
          there is a hazard from ignitable or reactive waste.
               (b)  Where specifically required by other Sections  of this  Part,
          the owner or operator of a facility that treats, stores, or disposes
          ignitable or reactive waste, or mixes incompatible waste or
          incompatible wastes and other materials, must take precautions to
          prevent reactions which:
               (1)  Generate extreme heat or pressure fire or explosions,  or
          violent reactions;
               (2)  Produce uncontrolled toxic mists, fumes, dusts, or gases in
          sufficient quantites to threaten human health or the  environment;
               (3)  Produce uncontrolled flammable fumes or gases  in sufficient
          quantities to pose a risk of fire or explosions;
               (4)  Damage the structural integrity of the device  or facility;
               (5)  Through other like means threaten human health or the
          environment.
               (c)  When required to comply with paragraphs (a) or  (b) of this
          Section, the owner or operator must document that compliance.   This
          documentation may be based on references to published scientific or
          engineering literature, data from trial tests (e.,g.,  bench scale or
          pilot scale tests), waste analyses  (as specified in  §264.13),  or the
          results of the treatment of similar wastes by similar treatment
          processes and under similar operating conditions.
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     In addition to the "general" requirements contained in §264.17, there are
facility-type specific information requirements in Part 270 and associated
specific standards in Part 264.  The following list identifies where these
specific requirements can be located.
        Facility Type

     Containers

     Tanks

     Surface Impoundments

     Waste Piles

     Land Treatment

     Landfills
    Specific
   information
   requirements

§270.15(c) and (d)

§270.16(f)

§270.17(h) and (i)

§270.18(g) and (h)

§270.20(g) and (h)

§270.21(f) and (g)
Specific standards

§264.176,  §264.177

§264.198,  §264.199

§264.299,  §264.230

§264.256,  §264.257

§264.281,  §264.282

§264.312,  §264.313
5.9.2  Guidance to Achieve the Part 264 Standards
5.9.2.1  General--
     The intent of the precautionary requirements is to reduce the potential
for accidental ignition or reaction of ignitable and/or reactive wastes, or
the mixing of incompatible wastes by insuring that facility personnel are
thoroughly familiar with the prevailing dangers, and more significantly that
the design of the facility and the devices utilized for treating, storing, and
transporting wastes account for these dangers.

     Ignitability is exhibited by a solid waste if it has any of the four
properties listed in §261.21(a).  More specifically, §261.21(a) (1) addresses
liquids, §261.21(a)(2) addresses nonliquids, §261.21(a)(3)  addresses
compressed gases, and §261.21(a)(4) addresses oxidizers.   The provisions of
§261.21(a)(1) identify three ASTM standard methods that can be used to
determine ignitability.  They are:

     •    ASTM Standard D-93-79

     •    ASTM Standard D-93-80

     •    ASTM Standard D-3278-781

These methods are also described along with test methods  for gases and
oxidizers in Section 2.1.1 of "Test Methods for Evaluating  of Solid Waste,
Physical/Chemical Methods" (July 1982) Second Edition (SW-846).2  (Addresses
of Government Printing Office Book Stores and EPA Regional  Libraries are
provided in Appendix A.)
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     Reactivity is exhibited by a solid waste if it has any of the eight
properties listed in §261.23(a).  These properties are based largely upon the
definitions employed by the National Fire Prevention Association.  Detailed
information on identification and testing of reactive wastes is presented in
Section 2.1.3 of SW-846 and in Section 5.3 of this manual.

     The owner or operator of a facility which handles ignitable or reactive
wastes, or which mixes incompatible wastes, or wastes and materials which are
incompatible must take precautions against reactions which:

     (1)  Generate extreme heat or pressure, fire or explosions, or violent
          reactions;

     (2)  Produce uncontrolled toxic mists, fumes, dusts, gases  in sufficient
          quantities to threaten human health or the environment;

     (3)  Produce uncontrolled flammable fumes or gases which, in sufficient
          quantities, pose a risk of fire or explosion;

     (4)  Damage the structural integrity of the device or facility;

     (5)  Through other means threaten human health or the environment.

     The precautions taken to prevent these reactions would generally
en c omp ass:

     •    Identification of ignitable, reactive, and incompatible wastes

     •    Identification of the ways that incompatible wastes are combined

     •    Identification of the sources of ignition and reaction  (as indicated
          in §264.17(a))

     •    Analysis  of the  storage devices used, and their placement in  the
          facility,  should the wastes be stored as they are

     •    Analysis  of methods of treatment which would render wastes
          unreactive or nonignitable, and subsequent testing to  insure  that
          the wastes are no longer  ignitable or reactive.

 5.9.2.2   Precautions (§264.17 and 270.14(b) (9) ) —
      Identification of Ignitable, Reactive, and Incompatible Wastes—In
 Part  261, Subpart D, hazardous wastes are listed.  Ignitable wastes are
 identified  by  an "(l)" and reactive  wastes are  identified by an  "(R)".
 However,  these  listings will not provide all the  information you will need  to
 identify  ignitable,  reactive, or otherwise incompatible wastes.   It is
 recommended  that you review Section  5.3, Waste Analysis Plans, to determine
 applicable  procedures  for  characterizing these wastes.
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     Because many types *f hazardous waste are extremely reactive,  the
compatibility of hazardous wastes to be combined must be thoroughly evaluated
in order that the aforementioned reactions be prevented.  The applicant must
identify the methods which he will employ for estimating the potential
consequences of mixing different classes of waste.

     Identification of the Ways Incompatible Wastes are Combined—The primary
cause of combining incompatible wastes is insufficient or inaccurate
information about a waste or wastes.  Regardless of the efforts to  adequately
characterize wastes via the waste analysis plan, properties of some wastes may
change with time and temperature, thereby producing more or different
hazardous components.

     A second cause of accidents is the indiscriminate handling of  waste,
which might encompass the following:

     •    Containers which are supposedly empty, but may contain incompatible
          residual wastes.

     •    Haulers may "top off" their load on the way to the disposal site.

     •    Rough handling could cause container rupture or leakage that might
          result in comingling of otherwise segregated incompatible wastes.

     •    Indiscriminate disposal of containerized incompatible wastes in  the
          same cell could result in incompatible waste mixing, once the
          containers corrode and leak.

5.9.2.3  Sources of Ignition or Reaction (§264.17(a))—
     The regulations list several sources of ignition or reaction from which
the ignitable or reactive wastes must be separated and protected including but
not limited to:

     •    Open flames,

     •    Smoking,

     •    Cutting and welding,

     •    Hot surfaces,

     •    Frictional heat,

     •    Sparks (static, electrical, or mechanical),

     •    Spontaneous ignition (e.g., from heat-producing chemical  reactions),
          and

     •    Radiant heat.

While many of these are self-explanatory, there are three sources which bear
further comment.


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     Special precautions must be taken against smoking by personnel  in
facilities handling ignitable or reactive wastes.   While the wastes  are  being
handled, smoking must be confined to specially designated areas.   Warnings
against smoking should be clearly displayed to all occupants of the  facility.
"No Smoking" signs should be placed conspicuously  in areas where  hazards exist
from smoking or open flames.

     The facility owner and operator must take care as well in the equipment
used in the handling of these wastes.  Tools and machinery which  are used in
handling ignitable or reactive wastes should be constructed of nonsparking
raaterials.  For example, when placing containers of waste in a landfill, it is
recommended that a tractor barrel grappler be employed.  Such equipment  allows
the operator to accurately place the containers in a landfill, while greatly
minimizing the risks of damage to the container or ignition or reaction  due to
spark-producing equipment.

     The ignitable or reactive wastes, particularly the ignitable wastes,
should be segregated from other wastes which may generate radiant heat  or
cause spontaneous ignition.  For example, ignitable wastes will have to  be
segregated from other wastes which may be subject  to microbial degradation or
wastes which may be subject to exothermic reaction with water.

     Storage Devices—Containers, Tanks, Waste Piles—If the owner or operator
of the hazardous waste management facility chooses to store or dispose of
wastes which are ignitable or reactive, special precautions must  be  taken in
the selection of the devices employed.  Wastes which are reactive or ignitable
may not be placed in a landfill untreated.  Ignitable or reactive wastes
stored  in containers should not be placed near a waste pile, container,  tank,
or surface impoundment which contains a waste or wastes which are
incompatible, unless separated and protected by means of a dike,  berm,  wall,
or other structure.  The container must be in good condition (e.g.,  no
apparent rusting or structural defects).  The permit reviewer may require that
all containers meet the container requirements of  the Department of
Transportation Regulations.

     For storage of ignitable, reactive, or incompatible waste in tanks, it is
necessary that the buffer zone requirements in the National Fire Prevention
Association's publication "Flammable and Combustible Code—1977" in Tables 2-1
and 2-&3 be complied with.  Wastes must not be placed in unwashed tanks
which previously held incompatible wastes or materials.

     An ignitable or reactive waste may only be placed in a waste pile if the
addition of that waste to an existing pile results in the waste or mixture no
longer  meeting the definition of ignitable or reactive waste as specified in
§261.21 and §261.23, respectively.

     Treatment Methods—A number of methods are available to treat,  render, or
mix wastes so that they are no longer ignitable or reactive.  Several
treatment processes which previously were only used in the organic or
inorganic chemical industry are being considered  for broader applications in
the treatment of hazardous  wastes.
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     The rendering of ignitable or reactive compounds nonignitable or
unreactive may be accomplished by diluting the waste with other compatible
material.  There are several disadvantages to doing this, however.  Hazardous
reactions may result if the materials being mixed are incompatible.  Dilution
of liquids is also undesirable because of added liquids involved.  For
example, disposal of diluted wastes in a landfill would result in greater
leachate generation.  If the quantities of wastes are relatively small,
dilution may be the most economical precautionary measure.

     Incineration may be considered as a method to render reactive or
ignitable wastes nonreactive or nonignitable.  Ignitable hazardous wastes,
containing solvents and other organic materials are easily incinerated.
Incineration reduces waste volume and may also reduce the potential for  ground
water contamination from the ash compared to that associated with disposing of
the parent waste.  On the other hand, compliance with air emissions standards
requires emissions evaluation.

     After treatment processes are complete, the owner/operator must conduct
testing, or document by some other means, that the waste is no longer
ignitable or reactive.  If testing is employed, specification of the testing
procedure must be provided.  Available methods to test for ignitability  are
set forth in §261.21.   Two test methods are acceptable for determining the
flashpoint:  Pensky-Martens Closed Cup Tester using the test method specified
in ASTM Standard D-93-79 or D-93-80,  or a Steaflash Closed Cup Tester, using
the test method specified in ASTM Standard D-3278-78.  To test for reactivity,
the applicant should base the demonstration on tests for:  water reactivity,
flashpoint/flammability, oxidation/reduction potential, pH, and the presence
of cyanide or sulfide.  The testing procedures should conform with the ASTM
Standards and test methods incorporated in SW-846.  As stated in §264.17(c),
documentation of compliance may be based upon references to published
scientific or engineering literature, data from trial tests, waste analyses,
or the results of the treatment of similar wastes by similar treatment
processes and under similar operating conditions.

5.9.2.4  Documentation (§264.17(c)) —
     Documentation of the precautions taken by the owner or operator of  a
hazardous waste management facility handling ignitable or reactive wastes to
prevent accidental ignition or reaction is required in the permit
application.  The documentation will  involve a complete description of the
precautions taken, and how they serve to comply with the §264.17 regulations.
The permit application may be judged  to be deficient if the required
documentation is not submitted or is  judged to be inadequate.

     Specifically, you should list the ignitable and/or reactive or the
incompatible wastes to be handled, stored, or disposed of at the facility.  If
methods other than those referenced in the regulations have been employed to
determine ignitability or reactivity  (which have been approved by the
Administrator), they must be detailed.  The methods employed for estimating
the potential consequences of mixing  different wastes should be documented.
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     The sources of ignition and reaction  present in  the  facility should be
identified and described.  The precautions for prevention of sparking should
be described, as well as the other measures  employed  to separate and  protect
the wastes from open flames, smoking,  cutting and welding, hot surfaces,
frictional heat, and spontaneous ignition  (e.g.,  from heat-producing  chemical
reactions and radiant heat).  Describe how smoking and open flames are
confined to specifically designated locations when ignitable and/or reactive
wastes are being handled, and how "No  Smoking" signs  are  conspicuously placed
wherever there is a hazard from such wastes.

     Sketches, drawings, or data should be provided to demonstrate how
containers of ignitable or reactive waste  are to  be located.  Description of
the container systems employed should  be included, especially noting
compliance with relevant standards (e.g.,  the National Fire Prevention
Association's buffer zone requirements for tanks).  If no treatment methods
are employed, describe how the ignitable,  reactive, or incompatible wastes are
to be separated and protected.  State  which  containment systems are to be
employed for emergency usage.

     If the wastes are to be treated,  the  treatment procedure used must be
fully documented.  Fundamentally, one  must show how the method will ensure
that the wastes no longer fulfill the  requirements for classification as
ignitable or reactive hazardous wastes.  The testing methods employed should
also be fully documented.

     As you will note from the above description of the documentation
necesary, much of the information or data  necessary to document that  the
proper precautions have been taken will be  included in your application for
other reasons.  In these cases, you should reference the location of  these
materials in your application under your discussion to demonstrate compliance
with the requirements of §270.14(b)(9).  When you reference material  rn this
manner, make certain that the referenced material does, in fact, describe the
precautions taken to show compliance with  §264.17 or include a brief
discussion to "tie together" the referenced materials.

5.9.3  Listof Major Points

     1.   Have you listed the ignitable, reactive, and incompatible wastes  to
          be handled at your facility?

     2.   Have you documented the potential consequences of mixing of wastes?

     3.   Have you taken precautions to separate and protect ignitable  or
          reactive wastes from  sources of ignition or reaction  located  in your
          facility?

     4.   Have  you designated special  areas at your facility to which smoking
          and open  flames must  be confined, and  placed "No  Smoking"  signs  in
          all other  locations?
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5.   Have you taken all necessary precautions in the selection and
     placement of containers and other storage devices?

6.   Have you documented the methods employed to treat the ignitable or
     reactive wastes, and the methods employed to test the wastes
     following treatment?

7.   Have you fully documented compliance with all pertinent  sections of
     the regulations?
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5.10  TRAFFIC

5.10.1  Regulatory Citations

     Information related to traffic movement  must  be  submitted with Part  B of
the permit application,  as  specified in:

               "§270.14(b) (10)   Traffic pattern, estimated  volume  (number,
          types of vehicles) and control  (for example,  show turns  across
          traffic lanes, and stacking lanes (if appropriate); describe  access
          road surfacing and load bearing capacity; show  traffic control
          s ignals) ,

     Part 264 of the regulations does not specify  any regulatory standards
with which traffic movement must comply.

5.10.2  Guidance to Achieve the
5.10.2.1  General —
     The intent of requiring subtnittal of the traffic related information
delineated in §270. 14(b) (10) with the permit application is  to insure  that
movement of hazardous waste, and simply traffic movement,  will be conducted
safely to minimize the risk of accidents.  The traffic related information
required is only for that area inside and immediately surrounding the
hazardous waste management facility.

     As noted above;, there are no "standards" in Part 264 with which traffic
related items must comply.  However,  the overriding concern  is safety.   As an
applicant, you should be concerned that the movement of hazardous waste into,
out of, and within your facility will be conducted in a manner that  minimizes
accident potential.  Additionally, general traffic movement  should not be such
that hazardous waste stored or disposed of at your facility  will be
disturbed.  In order to present traffic related items most effectively in your
permit application, it is suggested that both a discussion and a drawing be
provided.

5.10.2.2  Traffic Patterns and Estimated Volumes--
     You should provide a thorough description of both the pattern of  general
traffic and the pattern of traffic moving hazardous waste within your
facility.  A description of traffic on roadways traveled by  the public which
intersect, with access roadways to your facility should also  be provided.  The
following items should be considered for inclusion in your discussion of
traffic patterns and volumes;

     »    routes traveled

     e    distances traveled

     •    number of vehicles
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     •    types of vehicles

     •    waste movement sampling and unloading  locations

     •    amount of pedestrian traffic

If traffic volumes vary with the time of  day,  or if  routes will be varied,
these variations should be  identified. The  following  examples are intended to
provide insight into how information on traffic  patterns and volumes  should be
presented in your permit application.   The first is  an example presentation
for an offsite landfill.   The  second is an example for an industrial  facility
which operates an onsite surface impoundment and a landfill.

     Example 1:

          "Plot plan xyz shows the roadways  in and around our  facility.
     Access gates are off Pine St. on the south  side and off Lowell St. on the
     north side.  At both gates, their is a  150-foot distance  from the  street
     to the gatehouse where all entering  vehicles must stop.   That area, plus
     the adjacent aprons shown, provide enough room  for up  to  four
     tractor-trailer rigs to pull completely off the public roadway at  each
     gate while waiting to be processed through  the  gates.

          Pine St. is a two-lane road with a posted  40 MPH  speed  limit.
     It is moderately busy with passenger vehicles during the  morning and
     evening rush hours but is only lightly  traveled in off-peak  hours.  It is
     not a major connector, a short-cut,  nor a school  bus route.

          Lowell St, is a four lane, divided surface artery with  a posted speed
     limit of 45 MPH.  It is heavily traveled during the morning  and  evening
     rush hours by passenger vehicles and trucks and moderately traveled
     during all the other daylight hours  during  which  our facility operates.
     Lowell St. is not a school bus route.

          Both entrances to our facility  are equally used.  Over  the  past year,
     an average of 45 trucks entered our  facility per  day.  The majority of
     these (40) are ten-wheel flat-bed or open dump  trucks.  The  remainder are
     20 and 40 foot trailers.   Occasionally, waste is  brought  to  our  site in
     pick-up trucks.  During the period from March to  May,  an  additional seven
     trucks per day (4 dump and 3 flat-bed)  above average entered our facility
     during cleanup of the  Reeseville Farm site.

          As shown on plot  plan xyz, vehicles entering our  site travel  the
     perimeter roads to the active portion of the landfill.  Empty vehicles
     all use roadway A and  turn left or right at intersection  B toward  their
     desired exit gate.  Both the perimeter  and  exit roadways  are clearly
     marked as one-way."

     Example 2:

          "Plot plan xyz shows the roadways  within our facility.  The landfill
     is labeled A and the surface impoundment is labeled B.

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          Hazardous wastes  destined  for  the landfill are collected from the
     loading docks labeled  1  through  6.  As shown in the plot plan, the
     collection truck (a  ten-wheel flat-bed) uses one of the indicated routes
     from the loading docks to  the west  perimeter road and then to the
     landfill.   Collections are scheduled  for once per week on Wednesday and
     it typically  requires  three  trips to  complete the collections.

          Hazardous wastes  entering  the  surface  impoundment are delivered
     directly by pipelines  as described  on page 	 of this application.  As
     shown on the  plot plan,  there is a  plant roadway along the east side of
     the impoundment.  A  guardrail has been installed along that roadway at
     the impoundment.

          Roadways in the plant are  traveled by various company trucks,
     forklifts, and electric  carts.   All noncompany vehicles are restricted to
     the roadways  marked  on the plot plan.  The hazardous waste collection
     truck routes  do  not  follow or intersect the noncompany vehicle routes.

          The plant speed limit is posted  at 10 MPH.  The hazardous waste
     collection truck is  painted yellow  and is equipped with a revolving amber
     light on the  cab roof.  All plant employees have been informed of the
     description and  purpose  of this truck.  Plant traffic safety rules have
     established that this  truck has the right-of-way at all times."

     The plot plan and description of traffic in your application should also
indicate traffic control  signs  and signals.  If  you have established special
procedures for controlling  vehicles  containing hazardous wastes you should
describe those procedures in  your application.

     You are also  required  to provide a  description of roadway surfaces and
load bearing capacity.,  The intent here  is to insure that the roadways are
appropriate for the type  and  number  of vehicles which will be using them.
Further, if the road  surface  is such that  it will require periodic
maintenance, you should consider describing the  frequency and type of
maintenance that will be undertaken  to  insure  that  the  roadway will remain
safe for vehicular traffic.  The reviewing agency may also be concerned with
the amount of dust that will  be generated  by vehicular  traffic  in  and  around
your facility.

5.10.3  List of Major Points

     1.   Have vehicle routes been clearly indicated?

     2.   Has a description of the number  and  types of vehicles been provided?

     3.   Have  traffic control signs, signals,  and  procedures been  identified?

     4.   Has the adequacy  of roadway surfaces  and  load bearing capacity  for
          expected traffic  been clearly  demonstrated?
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5.11  LOCATION INFORMATION

5.11.1  Regulatory Citations

     Information on the location of the facility must  be  submitted  with  Part  B
of the permit application, as  specified in:

          "§270.14(b)(11)   Facility location  information.
               (i)  In order to determine the applicability  of  the  seismic
          standard [§264.18(a)J the owner or  operator  of  a new  facility  must
          identify the political jurisdiction (e.g., county,  township, or
          election district) in which the facility is  proposed  to be  located.
               (ii)  If the facility is proposed to be located  in an  area
          listed in Appendix VI of Part 264,  the owner or operator  shall
          demonstrate  compliance with the seismic standard.   This
          demonstration may be made using either published geologic data or
          data obtained from field investigations carried out by the
          applicant.  The  information provided must be of such  quality to be
          acceptable to geologists experienced in identifying and evaluating
          seismic activity.  The information  submitted must show that either:
               (A)  No faults  which have had  displacement in Holocene time  are
          present, or  no lineations which suggest the  presence  of a fault
          (which have  displacement in Holocene time) within 3,000 feet of a
          facility are present, based on data from:
               (1)  Published  geologic studies,
               (2)  Aerial reconnaissance of  the area  within a  five-mile radius
          from the facility.
               (3)  An analysis of aerial photographs  covering  a 3,000 foot
          radius of the facility, and
               (4)  If needed to clarify the  above data,  a reconnaissance based
          on walking portions  of the area within 3,000 feet of  the  facility,  or
               (B)  If faults  (to include lineations)  which have had
          displacement in  Holocene time are  present within 3,000 feet of a
          facility, no faults  pass with 200  feet of the portions of the
          facility where treatment, storage,  or  disposal  of hazardous waste
          will be conducted, based on data from a comprehensive geologic
          analysis of  the  site.  Unless a site analysis is otherwise
          conclusive concerning the absence  of faults  within 200 feet of such
          portions of  the  facility data shall be obtained from  a subsurface
          exploration (trenching) of the area within a distance no  less  than
          200 feet from portions of the facility where treatment, storage,  or
          disposal of  hazardous waste will be conducted.   Such  trenching shall
          be performed in  a direction that is perpendicular  to  known  faults
          (which have  had  displacement in Holocene time)  passing within
          3,000 feet of the portions of the  facility where treatment, storage,
          or disposal  of hazardous waste will be conducted.   Such
          investigation snail  document with  support ing maps  and other
          analyses, the location of laults found.
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               (iii)  Owners and operators of all facilities shall provide an
          identification of whether  the facility  is located within a 100-year
          floodplain.  This identification must indicate the source of data
          for  such determination and  include a copy of  the relevant Federal
          Insurance Administration (FIA) flood map, if  used, or the
          calculations and maps used  where an FIA map is not available.
          Information shall also be  provided identifying the 100-year flood
          level  and any other special  flooding factors  (e.g., wave action)
          which  must be considered in designing, constructing, operating, or
          maintaining the facility to withstand washout from a 100-year  flood.
               (iv)  Owners and operators of facilities located in the 100-year
          floodplain must provide the  following information:
               (A)  Engineering analysis to indicate the various hydrodynamic
          and  hydrostatic forces expected to result at  the site as consequence
          of a 100-year flood.
               (B)  Structural or other engineering studies showing the  design
          of operational units (e.g.,  tanks, incinerators) and flood
          protection devices (e.g.,  floodwalls, dikes)  at the facility and how
          these  will prevent washout.
               (C)  If applicable, and  in lieu of paragraphs (b)(11)(iv)(A)
          and  (B) above, a detailed  description of procedures to be followed
          to remove hazardous waste  to  safety before the facility  is flooded,
          including:
               (1)  Timing of such movement relative to flood levels,
          including estimated time to move the waste, to show that such
          movement can be completed  before floodwaters  reach the facility.
               (2)  A description of the location(s) to which the waste  will
          be moved and demonstration that those facilities will be eligible  to
          receive hazardous waste in accordance with the regulations under
          Parts  270, 271, 124, and 264  through 266 of this Chapter.
               (3)  The planned procedures, equipment,  and personnel to  be
          used and the means to ensure  that such  resources will be available
          in time  for use.
               (4)  The potential for accidental  discharges of the waste
          during movement.
               (v)  Existing facilities NOT in compliance with §264.l8(b)
          shall  provide a plan showing how the facility will be brought  into
          compliance and a schedule  for compliance."

     The regulatory requirements  for facility location  are contained in
§264.18.  They are:

          "§264.18  Location  standards.
               (a)  Seismic considerations.   (1)  Portions of new facilities
          where  treatment, storage,  or disposal of hazardous waste will  be
          conducted must not be  located within 61 meters  (200 feet) of a fault
          which has had displacement in Holocene  time.
               (2)  As used in paragraph  (a)(l) of  this Section:
               (i)  "Fault" means a  fracture along which rocks on  one side have
          been displaced with respect to  those on the other  side.
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               (ii)   "Displacement"  means  the  relative movement  of  any  two
          sides of a fault measured  in any direction.
               (iii)  "Holocene" means the most  recent epoch  of  the Quarternary
          period,  extending from the end of the  Pleistocene  to the  present.
               (b)  Floodplains.  (1)  A facility located  in  a 100-year
          floodplain must be designed, constructed,  operated, and maintained
          to prevent washout of any  hazardous  waste  by a  100-year flood,
          unless the owner or operator can demonstrate  to the Regional
          Administrator's satisfaction that:
               (i)  Procedures are in effect  which will  cause the waste to  be
          removed  safely, before flood waters  can reach  the  facility,  to  a
          location where the wastes  will not  be  vulnerable to flood waters;  or
               (ii)   For existing surface  impoundments, waste piles,  land
          treatment units, and landfills,  no  adverse effects  on  human health
          or the environment will result if washout  occurs,  considering:
               (A)  The volume and physical and  chemical  characteristics  of
          the waste  in the facility;
               (B)  The concentration of hazardous constituents  that would
          potentially affect surface waters as a result  of washout;
               (C)  The impact of such concentrations on  the  current or
          potential  uses of and water quality  standards established for the
          affected surface waters; and
               (D)  The impact of hazardous constituents  on the  sediments of
          affected surface waters or the soils of the 100-year  floodplain that
          could result from washout.
               (2)  As used in paragraph (b)(l)  of this  Section:
               (i)  "100-year fioodplain"  means  any  land  area which is  subject
          to a one percent or greater chance  of  flooding  in  any  given year
          from any source.
               (ii)   "Washout" means the movement of hazardous waste from the
          active portion of the facility as a  result of  flooding.
               (iii)  "100-year flood" means  a flood that has a  one percent
          chance of  being equalled or exceeded in any given  year."

     The regulations address two issues relative to  a facility's location;
seismic considerations and floodplains.  The  guidance provided  in the
following part of  this section of the manual  is  organized under  these  two
topical headings.

5.11.2  Guidance to Achieve the Part 264 Standards

5.11.2.1  Seismic  Considerations--
     Purpose—The  intent of the regulation requiring consideration  of  seismic
activity when locating a facility is to protect  these facilities from the
deformation and displacement of the  earth's surface  when  an  earthquake  occurs
and to prevent the release of hazardous waste  that could  result  from damage  to
the facilities.  At  present (May 1983), the seismic  standard  applies  only to
the location of new hazardous waste  facilities.   Existing facilities  do not
have to comply with the seismic standard in §264.18(a).   However, applicants
seeking a permit for an existing facility  are  advised to  contact the
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permitting authority (see Appendix A) to determine if any seismic standards
are applicable at the time they are preparing Part B of their permit
application.  A flow diagram (Figure 5-3) is provided to summarize the
location information requirements to meet the seismic standard of §264.18(a).
For new facilities the political jurisdiction (e.g., county,  township, or
election district) in which the facility is proposed to be located must be
identified and compared to the list of such jurisdictions provided in
Appendix VI to Part 264 (Table 5-23).  If the location is NOT listed  in
Appendix VI, no further information is required to demonstrate compliance with
§264.18(a) (all other locations are assumed to be in compliance).  If the
location IS listed in Appendix VI, the applicant must demonstrate compliance
with the seismic standard specified in §264.18(a).

     Examples:

          "The proposed facility is to be located in Tacoma,  Washington, which
     lies in Pierce County.  Appendix VI lists Pierce County and, therefore,
     we have demonstrated compliance with §264.18(a) in Section _ of  this
     application."

          "The proposed facility is to be located in Massachusetts.
      Appendix VI does not list Massachusetts and, therefore, we have provided
     no further information to demonstrate compliance with §264.18(a)."

     The information which must be submitted by facilities that will  locate in
areas listed in Appendix VI of Part 264 to demonstrate compliance with
§264.18(a) is identified in §270.14(b)(11)(ii).  One of two compliance
showings must be made, §270.14(b)(11)(ii)(A) addresses facilities which can be
shown NOT to be located within 3,000 feet of a fault displaced in Holocene
time and §270.14(b)(11)(ii)(B) covers facilities where such a fault is found
within 3,000 feet of the facility.

     In either case, the applicant must demonstrate compliance with the
Seismic standard by using either:

     »    published geologic data, or

     •    data obcained from field investigations conducted or sponsored by
          the applicant.

     Published geologic data includes any existing data which may be  available
to the applicant.  Field investigations would entail original work performed
by the applicant or representatives.  Holocene time is the geologic epoch
which represents approximately the last 11,000 years, although in some parts
of the U.S., the limits of the Holocene may range from 10,000 to 15,000 years
ago.  Where deposits or landforms of known Holocene age are offset or
displaced by faults, movement along  the fault is established to have  occurred
within Holocene time.l
                                    5-142

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Figure 5-3.  Seismic standard requirements.

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       TABLE  5-23.   APPENDIX VI POLITICAL  JURISDICTIONS
                  Political Jurisdictions  in  Which  Compliance
                     With  §264.18(a) Must Be Demonstrated
                                    Alaska
Aleutian Islands
Anchorage
Bethel
Bristol Bay
Cordova-Valdez
Fairbanks-Fort  Yukon
Juneau
Kenai-Cook Inlet
Ketchikan Prince  of Wales
Kodiak
Lynn Canal-Icy Straits
Palmer-Wasilla-Talkeena
Seward
Sitka
Wade Hampton
Wrangeli Petersburg
Vukon-Kuskokwim
Cochise
Graham
Archuleta
Conejos
Hinsdale
Hawaii
                                    Arizona
Greenlee
Yuma
                                  California

                                  All

                                   Colorado
                                    Hawaii
Mineral
Rio Grande
Saguache
                                     Idaho
Bannock
Bear Lake
Bingham
Bonnevilie
Caribou
Cassia
Clark
Franklin
Fremont
Jefferson
Mad i son
Oneida
Power
Teton
                                    Montana
Beaverhead
Broadwater
Flathead
Gallatin
Granite
Jefferson
Lake
Lewis and Clark
Madison
Meagher
Missoula
Cascade
Deer Lodge
Park
Powell
Sanders
Silver Bow
Stillwater
Sweet Grass
Teton
Wheat land
                                  (continued)
                                     5-144

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                         TABLE 5-23  (continued)
                                     Nevada
                                     Ail
                                   New Mexico
Bernalillo
CaCron
Grant
Hidalgo
Lo s Alamo s
Rio Arriba
Sandoval
Santa Fe
S i e r ra
Socorro
Taos
Torrance
Valenc la
                                      Utah
Beaver
Box Elder
Cache
Carbon
Davis
Duchesne
Emery
Garfield
Iron
Juab
Mi Hard
Horgan
Chelan
Clallatn
Clark
Cowlitz
Douglas
Ferry
Grant
Grays Harbor
Jefferson
King
Kipsap
Kittitas
Lewis
Piute
Rich
Salt Lake
Sanpete
Sevier
Summit
Tooele
Utah
Wasatch
Washington
Wayne
Weber
                                   Washington
Mason
Okanogan
Pacific
Pierce
San Juan Islands
Skaglt
Skamania
Snohomish
Thurston
Wahkiakum
Whatcom
Yakima
Fremont
Lincoln
Park
Sublette
Teton
Uinta
Yellowstone National. Park
                                  5-145

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     Although specific procedures for conducting appropriate field
investigations are riot provided in the regulations,  all  permitting decisions
(waivers, monitoring programs)  are based on such data.   The applicant's
objective in such an investigation is to obtain the  information necessary to
allow the permit writer to evaluate with confidence  that the site is  not
within 3,000 feet of a fault.   Information presented by  the applicant must be
of a quality acceptable to geologists experienced in identifying and
evaluating seismic activity.

     In the case of §270.14(b)(11)(ii)(A), an applicant  must show that no
faults (or lineations suggesting faults) which have  had  displacement  in
Holocene time are present within 3,000 feet of the facility.  The applicant
should base this decision on some or all of the following data sources:

     •    published geologic studies

     •    walking reconnaissance of the area (3,000  feet)

     •    aerial reconnaissance of the area (5-mile  radius)

     •    analysis of aerial photos (3,000 foot radius).

     Published geologic studies are available through both federal and state
agencies (the U.S. Geological  Society, State Geological  Survey Offices,  the
U.S. Soil Conservation Service, etc.).  A listing of the addresses of some of
these agencies is included in Appendix C of this manual.  In addition, the
Nuclear Regulatory Commission thoroughly researches  the  geology around
proposed nuclear sites, thus they might be a source  of information.  Since a
variety of site related data are required to fulfill permit application
requirements  (topography, soils, bedrock and surficial geology, ground water,
surface water, etc.)  it is recommended that all available information be
thoroughly researched.  Publications, maps, and computerized data bases are
all useful.   In some  cases, additional information such  as ground-penetrating
radar or seismic refraction surveys may also be available.  Local agencies and
professional  literature should also be consulted.  Any deficiencies in data
should be noted.  The data should be reviewed and summarized by a qualified
geologist who is familiar with local conditions.

     If  local conditions are relatively unknown, a walking reconnaissance is
recommended.  This walking tour would ideally be designed to tie  in other
parameters necessary  to complete the application.  For example, snapshots
could be obtained, sketches of the area could be drawn  for use in compiling
the site map, seismic study areas and flood control  measures could be
considered,  soil samples could be procured, etc.  The people participating in
the site tour should  include those whose expert opinions will be used in
evaluating the site;  i.e., a geologist, engineer, aerial photograph
interpreter,  etc.

     If  existing aerial photographs are available, they may be used as an
additional source of  information.  Virtually, all of the U.S. has been
                                    5-146

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photographed in recent years for various federal agencies  and a  map  has  been
compiled indicating areas photographed.2  This  map is available  free of
charge from the:

                              U.S.  Geologic Survey
                            Washington, D.C.  20242

The map shows all areas of the U.S.,  by county,  which have been  photographed
by Federal agencies.  Names and addresses  of the agencies  holding  the
negatives for photographs are printed on the back of the map.  Stereographic
coverage should be requested.   Other  potential  sources of  aerial photos  are
listed in Appendix D of this manual.   Aerial photos will vary in quality with
season of flight, film type, photo  scale,  cloud cover, and other factors. You
should determine what photos are available for  the site area and procure them
if they would aid in determining the  presence of faults.

     Air photo interpretation requires experience.  Diagnostic features
include terrain position, color tones, topography, drainage and  erosional
features, and vegetative cover.  Scale should be 1:20,000  for geologic
interpretation of surface materials,  in some instances deep, underground
conditions can also be predicted given sharp photography.   Onsight follow-up
to aerial interpretations (walking  reconnaissance) is recommended  to validate
results.  Features such as sink holes, which must be investigated  as part of
foundation analysis, can also be noted using aerials.

     If available photos, having been reviewed  by one experienced  in aerial
photo interpretation techniques, show conclusively that no faults  are present,
the applicant should submit those photos to meet the requirements  of
§270.14(b)(11)(ii)(A).  If instead, there  is doubt as to their clarity in
indicating lineations or faults for some reason (quality of photo, time  of
year, etc.) or if they do not adequately cover  the area in question  (within  a
5-mile radius and covering  a 3,000 foot radius about the  facility)  the
applicant might consider an aerial  reconnaissance flight.   Information for
planning such a flight is presented as Appendix E to this  manual.

     Example:

          "No faults having had displacement in Holocene time are  present at
     our site which is located in Long Beach, California.   We consulted  the
     regional USGS Office for ground-penetrating radar or  seismic  refraction
     surveys in the area and procured a ground-penetrating radar survey  which
     ran inside the site boundary.   Topographic and geologic (surficial  and
     bedrock) maps were obtained.  Holocene fault maps of  the area were  also
     procured, as they have been compiled  under the California Geologic
     Hazards Act.  The maps were searched  for faults, including  fault traces,
     fault planes, faults which did not have surface expression, main faults,
     branch faults, and secondary faults.   Aerial photographs were obtained
     from the Soil Conservation Service which covered a 5-mile radius of the
     area, and the area within a 3,000 foot radius was analyzed  by our
     geologist, who is also skilled in interpretation of aerial  photographs.
                                    5-147

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          In reviewing the aerial photos,  the  interpreter searched  for
     indicators of faults, such  as alignments  of  stream segments  and  small
     drainage courses.  As most  high-angle faults are expressed  on  photographs
     as straight or gently curving lines  (this characteristic  is  probably  the
     most important clue that a  fault may  exist), all linear features were
     examined carefully.3  jn One area,  a  shadow  had  been cast on the
     photos.  This area was walked by our  experienced geologist,  our
     engineers, and others who had a part  in  site evaluation.  No evidence  of
     lineations or faults having displacement  during  Holocene  time  was found."

     If your analysis of the four data sources indicates that  there are no
faults within 3,000 feet of the  proposed  facility,  then you must  document  that
fact in your permit application  and you will  have shown compliance  with the
seismic standard in §264.18(a).   It may not be necessary to submit  copies  of
all the supporting data.  The agency may simply accept the signed statements
of the geologist, photo interpreter, etc.   In  any case, you should  include  a
detailed list of all the materials you reviewed and investigated to support
your statement on the absence of faults.

     In the event that your investigation  does identify a fault  within
3,000 feet of your facility, the information  you  submit must make the showing
indicated in §270.14(b)(11)(ii)(B).

     The objective is to provide EPA with  suitable information to show that no
faults (or lineations) pass within 200 feet of the portions of the  facility
where treatment, storage, or disposal of hazardous waste will  be conducted.
This should be based on data from a comprehensive geologic analysis of the
site.  This analysis can serve many purposes  in that  other sections of the
application require similiar data.  A comprehensive geologic analysis would
use any or all of the following  tools:

     •    surface geophysical surveying

     •    drilling and logging of boreholes

     •    other methods

     Seismic Surveys can be used to show where faults or lineations run and to
estimate elevations and thickness of hydrogeologic units.  For the  analysis
required, ground-penetrating radar and possibly seismic refraction methods
could be utilized.  Less definitive seismic tools for fault-detection include
microgravimetry and magnetic surveys.  Reflection seismograph  surveys may  show
faults by a zone of no reflection but provide no  definite basis  for
determining direction of  fault placement;  a gravity survey complementary to
this can locate the corresponding fault indications and show direction of
displacement.  Drilling and borehole logging  can  improve estimates of contact
elevations.  To verify seismic data, some sort of digging is often required,
such as logging or trenching (subsurface exploration).
                                    5-148

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     Aspects of seismic surveys are explained in the following references:^

     •    For general field investigations  including geologic mapping,  and
          evaluations of borings and trenches - Earth Manual, U.S.  Dept.  of
          Interior,  U.S. Government Printing Office, Washington,  D.C.   1974;

     •    For surface geophysical methods - Zohdy et al.,  "Application  of
          Surface Geophysics to Groundwater Investigations," U.S.  Geological
          Survey Techniques of Water Resources Investigations Book 2,
          Chapter D.I, 1974; Roux "Electrical Resistivity  Evaluations at  Solid
          Waste Disposal Facilities" U.S. EPA SW-729, 1978;  Telford et  al.,
          Applied Geophysics,  Cambridge University Press,  Cambridge,  1977;
          Dobrin, Introduction to Geophysical Prospecting, McGraw-Hill,  Inc.,
          New York,  1976; L. L. Nettleton,  Monograph Series  No.  1,  Elementary
          Gravity and Magnetics for Geologists and Seismologists,  1971;
          Paul M. Tucker and Howard J.  Yorston, Monograph  Series  No.  2,
          Pitfalls in Seismic Interpreation, 1973;

     •    For borehole geophysical methods  - Keys and MacCary, "Application of
          Borehole Geophysics to Water  Resources Investigations;  U.S.
          Geological Survey Techniques  of Water Resources  Investigations,
          Book 2, Chapter El,  1971.

The Earth Manual, Zohdy et al. (1974),  and  Keys and MacCary  (1971)  are
available through the U.S. Government Printing Office (see Appendix A).

     If the comprehensive geologic analysis does not provide conclusive
evidence that faults are absent within  200  feet of the portions  of the
facility, where treatment, storage, or  disposal of hazardous waste will  be
conducted, the regulations require the  applicant to perform subsurface
exploration (trenching) of the area within  a distance no  less than 200  feet
from such portions of the facility.  This trenching must be  performed in  a
direction that is perpendicular to known faults (which have  had  displacement
in Holocene time) passing within 3,000  feet of such portions of  the facility.
Supporting maps and other analyses must document the location of any faults
found and these must be submitted as part of the permit application.
Excavations such as this, to more accurately define shallow subsurface
conditions, may also be tied in to permit requirements such  as a liner
foundation analysis (if a liner is to be used) or other test pits and trenches.

     Example 1:

          "We conducted a geologic analysis to augment information from aerial
     photographs which had indicated a  lineation approximately 1,000 feet from
     the proposed facility location. This  was followed by an onsite
     reconnaissance of the area for clarification.  The walking  tour indicated
     that, in fact,  more information would  be necessary to determine if  the
     fault intersected the proposed facility area.  Using  ground  penetrating
     radar, the fault was shown to lie  outside of a 200 foot radius of  the
     facility.  Maps and data from the  survey along with our geologist's
     interpretation are included with this  submittal."


                                     5-U9

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     Example 2:

          "In carrying out  the  geologic  analysis  of  this  site,  two  faults were
     investigated.   One,  termed the main fault as  it showed greatest
     displacement,  length and continuity, was  located  approximately 1,500 feet
     from the site.   Diverging  from this fault and extending well beyond the
     main fault  was  a branch  fault which ran  to a point only 180  feet  from one
     portion of  the  facility  as designed.   It was  decided  that  a  trenching
     operation was  necessary  to further  define the extent  of the  branch  fault,
     and a back  hoe  was used  to trench perpendicular to the fault in this
     area.  Based on the results of this trenching, we re-designed  the
     facility to locate storage tank  F at a distance of 400 feet  from  the
     branch fault.   We are  submitting the following with  this application:
     detailed engineering drawings of the trenches;  surficial and bedrock
     geology maps of the site compiled by a local geologist; and  a  seismic
     analysis of the site using ground-penetrating radar."

List of Major Points

     1.   Under  what political  jurisdiction does  the proposed location fall?

     2.   Is this county, township, etc. listed in Appendix VI?

     3.   Is published geologic data  available  for this site?   What other data
          can be obtained from  the sources  used?

     4.   If published data is  not available  or inadequate, what  type  of field
          investigations are  needed to secure  adequate information? Can these
          be tied into the  other requirements  within this  application?

     5.   Is a site walking reconnaissance  of  the site necessary  to clarify
          the seismic data?  Who should  participate  in such a tour? What
          other  data can be collected during  the  tour?

     6.   Do aerial photographs exist for the  area,  and if so,  were they taken
          (at the correct season of  the  year,  on  a useful  type  of film,  from  a
          low enough altitude,  such  that they show the entire site  area etc.)
          such that they are  useful  in  interpretation  of  faults (lineations)?
          If not, is an aerial  reconnaissance  flight a viable option?

     7.   Who will interpret  the photos, once  obtained?

     8.   If the aerials show faults  to  be  present within 3,000 feet of the
          site,  can a comprehensive geologic  analysis  of  the  site provide
          ample evidence to indicate  that no  fault or  lineation displaced in
          Holocene time runs  within  a 200 foot radius  of  the portions  of the
          site where hazardous  waste  will be  treated,  stored, or  disposed of?

     9.   What data will be submitted to support  this  application?
                                     5-150

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     10.  If this information cannot show conclusively that no fault is
          present within this 200 foot radius  and therefore trenching is
          necessary to provide more evidence,  what trenching data (maps,
          analyses, etc.) can be used to show  that faults  are not present in
          the 200 foot range?

     11.  Has a geologist familiar with the local situation been involved in
          this investigation?  Would the data  be acceptable to geologists
          experienced in identifying and evaluating seismic activity?

     Additional discussion on the seismic considerations can be found in the
preamble to the regulations located at 46 FR 2810 in the January 12, 1981
issue of the Federal Register.  Applicants should also consult the EPA
Background Document "Standards Applicable to Owners and Operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities under RCRA, Subtitle C,
Section 3004.  General Facility Standards for  Location of Facilities
(40 CFR 264, Subpart B, Section 264.18)."  U.S.  EPA, December 30, 1980.

5.11.2.2  Floodplains—
     Purpose—The intent of the regulation is  to prevent the release of
hazardous wastes from a facility during a flood.  In general, the EPA feels
that waste management facilities should not be located where a flood may
occur.  However, in some circumstances, it may be necessary to locate a new
waste management facility in a floodplain and, in fact, some existing
facilities are so located.  Thus, the informational and regulatory
requirements of §270.14(b)(11)(ii) , (iv),(v) and §264.18(b) have been
established to minimize the potential for hazardous waste release in the event
of a flood; they apply to both new and existing facilities.  Existing
facilities not in compliance with the floodplain standard must provide a plan
showing how they will be brought into compliance and a compliance schedule.
Figure  5-4 is a flow diagram which summarizes  the floodplain information
required to meet the standard in §264.18(b).

     The standards in §264.18(b)(1) specify the design, construction,
and operating requirements for facilities located in a 100-year floodplain.
Definitions are provided in §264.18(b)(2) that should be noted including:

     »    100 year floodplain:  any land area  which is subject to a 1 percent
          or greater chance of flooding in any given year from any source.

     •    100 year flood:  a flood that has a  1 percent chance of being
          equaled or exceeded in any given year.

     *    Flood prone is defined here as any land area susceptible to being
          inundated by water from any source. ^

     The first step in showing compliance is documentation of whether the
facility is located within a 100-year floodplain.  Relevant information that
must be provided in the application should include:

     •    the source of data used for this determination.
                                    5-151

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OWNER/OPERATORS  OF  A..L  fAClLltlES
WILL PROVIDE  AN  IDENTIFICATION OF
WHETHER THE FACILITY  IS LOCATED
WITHIN A 100-YEAR FLQOOPLAIN
 I
h-1
Ul
     INDICATE  SOURCE OF DATA FOR  SUCH
     DETERMINATION

     INCLUDE A COPY OF THE RELEVANT  FEDERAL
     INSURANCE ADMINISTRATION (FIA)  FLOOD
     MAP,  IF USED OR THE CALCULATIONS AND
     MAPS  USED WHERE A FIA MAP IS NOT
     AVAILA6LE l

     INCLUDE. INFORMATION IDENTIFYING THE
     100-YEAR  FLOOD L'EVEL AND ANY OTHER
     SPECIAL FLOODING FACTORS (e.g , WAVE
     ACTION) WHICH MUST BE CONSIDERED IN
     DESIGNING, CONSTRUCTING, OPERATING,
     OR  MAINTAINING THE FACILITY  TO WITH-
     STAND WASHOUT FROM A 100-YEAR FLOOD
  OWNER/OPERATORS  OF FACILITIES LOCATED
  WITHIN THE 100-YEAR  FLOODPLAIN MUST
  PROVIDE ADDITIONAL INFORMATION
SUBMIT AN ENGINEERING ANALYSIS TO INDICATE
THE VARIOUS  HYDRODYNAMIC AND HYDROSTATIC
FORCES EXPECTED  TO  RESULT AT THE SITE AS  A
CONSEQUENCE  OF A 100-YEAR FLOOD

PROVIDE STRUCTURAL  OR OThEP ENGINEERING
STUDIES SHOWING  THE  DESIGN OF OPERATIONAL
UNITS (e g ,  TANKS,  WASTE PILES) AND
FLOOD PROTECTION DEVICES [e.g ,  FLOODWALLS
DIKES) AT THE FACILITY AND HOW THESE WILL
PREVENT WASHOUT
                                                                                                                                            EXISTING  FACI_L_m^ES_ NOT IN COMPLIANCE  WITH
                                                                                                                                            T^^TTTSTbTTFLOODPLAI NS ]  MUST PROi/IDt  A  PLAN
                                                                                                                                            SHOWINf, HO* THE  FACILITY "ILL BE QHGuijHl  INTO
                                                                                                                                            COMPLIANCE AND A SCHEDULE FOR COMPLIANCE
                                                                                                                                      OR
                                                                                                                                 IF APPLICABLE
                                                                                                                                                     IN LIEU OF a)  and  b) . PROVIDE A DETAILED
                                                                                                                                                     DESCRIPTION OF PROCEDURES TO BE FOLLOWED
                                                                                                                                                     TO REMOVE HAZARDOUS WASTE TQ SAFETY BEFORE
                                                                                                                                                     THE FACILITY IS  FLOODED  INCLUDING
                                                 TIM NG  OF  SUCH MOVEMENT RELATIVE    (i
                                                 TO 
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     •    an original or clear copy of the relevant Federal Insurance
          Administration (FIA) flood map or calculations and maps used where
          an FIA map is not available.

     •    clear identxfication of the 100-year flood level and any other
          special flooding factors (e.g. wave action) which must be considered
          in designing, constructing, operating or maintaining the facility to
          withstand washout from a 100-year flood.

     As a part of the National Flood Insurance Program (NFIP), Flood Hazard
Boundary Maps (FHBM) have been prepared for virtually all 20,238 communities
that have been identified as "flood prone".1  The FHMB delineates the
boundaries of the 100-year floodplain, but elevations are not provided.
Nearly 90 percent of the Federal Emergency Management Agency (FEMA) maps are
FHBMs.  In addition, some of the communities that have been accepted into the
NFIP have Flood Insurance Rate Maps (FIRM) which delineate the 100-year
floodplain and also provide flood elevations.-'-  Where these maps are
available, the determination as to location on a 100-year floodplain is
straight-forward.  Such maps are most often included as part of a brief Flood
Insurance Study for a particular political jurisdiction along a waterway.  The
U.S. Department of Housing and Urban Development, Federal Insurance
Administration which publishes such studies, includes a fold-out map
delineating 100-year flood boundaries for various river reaches in the area
covered.  Examples provided in this section refer to such a map and a
representative drawing of one may be found in Figure 5-5 which appears later.
In addition, parameters such as hydraulic analyses used to determine the flood
level, community description, and principal flood problems and flood
protection measures are provided in such flood insurance studies.

     If a 100-year flood level is not available from another source, it can be
determined using a FHBM.  A qualified hydrologist will be able to make such a
determination in less than a day's work or FIA may be contacted to assist in
determining the 100-year flood elevation at a particular location.1  FIA,
however, does not usually map floodplains that are less than 200 feet wide;
therefore, it is unlikely that mapped information exists for such areas.
Where FIA omits an area due to this 200 foot exclusion, the owner or operator
will have to make a determination as to the extent of the 100-year floodplain.
FIA mapping procedures or equivalent mapping techniques should be used to make
this determination, and to determine what the 100-year flood elevation would
be.l-  You should note that floodplains less than 200 feet wide are
frequently subject to local zoning ordinances and easements.

     Other sources of floodplain maps and additional information may also be
consulted, such as the U.S. Geological Survey, the U.S. Army Corps of
Engineers, the U.S. Soil Conservation Service, and the Office of Coastal Zone
Management.  The Army Corps of Engineers has issued technical manuals on
design and construction techniques and methods for ascertaining the proper
levels of structural integrity for flood protection devices such as dikes,
covers, and flood walls.  For example, the general manual entitled "Flood-
Proofing Regulations" will be of use to the applicant (EP 1165-2-314,
June 1972).  There is also an Engineering Manual by the Army Corps of
                                    5-153

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Engineers (EM 1110-2-1913) for design and construction of levees (1978).   The
Department of the Army also published "Wall Design:  Floodwalls" in 1948 which
was due to be revised by 1981.  The U.S. Bureau of Reclamation published a
manual for design of small dams in 1973.  In addition, the Nuclear Regulatory
Commission has thoroughly researched the manner in which one protects elements
of a nuclear facility from the hazards of flooding.  Those techniques could
also be applied in hazardous waste facility protection.1

     Example 1:  Flood Insurance Study Available

          "The facility is proposed to be located in the Borough of Trainer,
     Pennsylvania, near Marcus Hook Creek, which is a tributary to the
     Delaware River.  Facility plans call for use of land near the Smith
     Street area, as shown in Figure 5-5.  The Flood Insurance Study for
     Trainer Borough has been obtained through the Federal Emergency
     Management Agency (FEMA), Region III, Philadelphia, PA, and is submitted
     as part of this application.  The location of the facility is within the
     100-year floodplain as indicated on the map provided by FEMA (see
     Figure 5-5).  That map is included  in this application.  The flood
     elevation is approximately 12.25 feet msl (provided on map).  Special
     flooding factors applicable in this area were researched; wave action  is
     not deemed to be a significant problem on the creek.  Potential sources
     which could influence flooding, located upstream of the site, are
     enumerated and plans for dealing with flooding are included in this
     application."

     Example 2:  Site Near Water Body—No Flood Insurance StudyAvailable Use
                 Hydrologist and Computer Modeling

          "The proposed facility will be built near a water body for which  no
     Federal Flood Insurance Study has been carried out,  A map of the area is
     included in this submittal showing  the potential 100-year  flood elevation
     as determined by a hydrologist.  Water surface elevation for the 100-year
     flood was computed using the U.S. Army Corps of Engineers HEC-2 <;tep-back
     water computer program (U.S. Army Corps of Engineers, Hydrologic
     Engineering Center, October 1973, HEC-2 Water Surface Profile Users
     Manual 723-02A, Davis, CA).6  xhe map included in this submittal
     delineates the 100-year flood elevation predicted by the model as well as
     the proposed  facility location and  indicates  that the facility will not
     be located in this floodplain."

     Example 3:  Site Near Small Creek—No FIA Study Available—Request Aid

          "The site location is near a small creek which is excluded from FIA
     maps due  to the fact that the  floodplain is  less  than 200  feet in width.
     We requested  aid from the FIA to help designate the 100-year floodplain
     and associated elevation for this area*  The  resultant map  is part of
     this application and indicates that  the site  is not within  the 100-year
     floodplain boundary."
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            FLOOOWAY
  PROPOSED
     SITE
D
 100 YR.
'FLOOD BOUNDARY
 500 YR.
 FLOOD BOUNDARY
 0    ZOO   400 feet

     SCALE        /
    Figure 5-5.
             Site located on 100-year floodplain,
             Source:  Reference 6.
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     Example 4:   Site Near Water Body—No  FIA Study Available—Obtain
                 Gaging Records

          "Records from a nearby gaging station were obtained  from the  USGS
     covering the past 50 years.  Combining these  flood  records  with
     climatological data from the National Weather Service  an  elevation for  a
     100-year flood was determined.   Drum  storage  onsite was designed such
     that it was located at the  highest point onsite, 25 feet  above the
     estimated 100-year flood evaluation."

     If the preceding investigation reveals that your facility is  not in the
100-year floodplain, submittal of the documentation is compliance.   If,
however, your facility is located in the 100-year  floodplain,  then the
regulations require that a facility in a 100-year  floodplain be  designed,
constructed, operated and maintained to prevent washout, unless  you can
demonstrate that if washout occurs,  no adverse effects on human  health  or  the
environment will result.  To demonstrate this, regulations  stipulate  that  you
must either:

     •    Provide for the safe removal of  waste (to a non-vulnerable  location,
          as specified) before the flood waters reach the site,  OR,

     •    Owners of existing surface impoundments, waste piles,  land  treatment
          units, and landfills may choose  to demonstrate that  no adverse human
          health effects or environmental  effects  will result  if washout
          occurs based on:

          -    the volume and physical and chemical characteristics of  the
               waste in the facility;

          -    the concentration of hazardous constituents  that  would
               potentially affect surface  waters as a result of  washout;

               the impact of such concentrations on the current  or potential
               uses of the affected surface waters, including  demonstration  of
               compliance with established water quality standards; and

          -    the impact of hazardous constituents on the  sediment of
               affected surface waters or the soils of the  100-year floodplain
               that could result from washout.

     All applicants who do not make a "no adverse affects"  showing must
provide information regarding either the procedures that will  be relied upon
to  insure flood protection or the methods that will be used to remove wastes
to  safety in the event: of flooding.  Flood protection refers  to any method
which prevents  flood waters from reaching the facility or active portions
thereof, such as building a sufficiently high berm around a waste pile  or a
landfill, or designing; a  levee  such  that it is built at the height of the
100-year flood plus a 3-foot safety  factor.  Flood proofing measures,  on the
other hand, allow  flood waters  to come into contact with structures as  long as
structural damage  is prevented.   For example, elevating a tank such that flood


                                     5-156

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waters in a 100-year flood would be likely to make contact with the tank's
support structure, but not overtop the tank itself,  or use of impermeable
walls for structures, or proper anchoring of containers.   Flood protection
measures may also be needed at a flood proofed facility if waste will  be
exposed at the 100-year flood level (i.e., an uncovered tank).!  Any permit
applicant who decides to demonstrate that a facility is protected against
hazardous waste release if flooded must provide both an engineering analysis
that indicates the various hydrodynamic and hydrostatic forces expected at  the
site as a consequence of a 100-year flood, and structural or other engineering
studies showing the design of operational units (e.g., tanks) and flood
protection devices (e.g., floodwalls,  dikes) at the facility and how these
will prevent washout.

     Alternatively, any applicant seeking a permit for a facility that is
located in a 100-year floodplain has the option of removing waste from a  flood
prone area in the event of flooding.  In these cases, the applicants should
describe a justifiable plan which details the procedures to be followed to
remove hazardous waste to safety before the facility is flooded.  The
information which is required is presented in §270.14(b)(11)(C) and includes:

     •    An indication of the timing of waste movement relative to flood
          levels, including estimated time to move all the waste.  You must
          show that such movement can be completed before floodwaters  reach
          the facility.

     •    A description of the location(s) to which the waste will be  moved.
          You must demonstrate that this facility is either permitted  by  EPA
          under 40 CFR Part 264, authorized to manage hazardous waste  by  a
          state with a hazardous waste management program authorized under
          Part 123 of 40 CFR or in interim status under Part 265 of 40 CFR.

     •    An explanation of the planned procedures,  equipment, and personnel
          to be used and the means you will employ to ensure that such
          resources will be available in time for use.

     •    A determination and description of the potential for accidental
          discharges of the waste during movement.

     Requirements pertaining to other Federal laws (the Wild and Scenic Rivers
Act, the National Historic Preservation Act, the Endangered Species Act,  the
Coastal Zone Management Act, the Fish and Wildlife Coordination Act, and  other
Executive Orders) which affect the location and permitting of facilities may
be found in §122.12.  EPA also has a manual for Special Environmental  Area
(SEA) requirements for hazardous waste facility permits that provides  details
relative to these laws.  Applicants are encouraged to consider the
requirements of these other laws when planning a facility location to  prevent
possible permit delays.
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Example 1:  Proposed Land Treatment Facility—Flood Protection

     "The land treatment facility is proposed to be located on the
100-year floodplain.  As the facility is to be used for land treatment,
the appropriate methodology for prevention of washout of wastes requires
flood protection,  i.e.,  not allowing flood waters to reach the facility
or active portions thereof.  Design plans include construction of a levee
around the facility which is sufficiently high to protect against washout
of wastes.  This was determined by designing the levee to be the
elevation of the 100-year flood plus a safety factor of 3 feet.  Prior to
placement of the levee,  the ground surface will be cleared and grubbed
such that the formation of voids where humus has decomposed (and hence
form internal drainage networks which might undetermine the structural
integrity of the levee)  will be unlikely.1  The Army Corps of Engineers
"Engineering Manual for  Design and Construction of Levees" was followed.
In addition, the entire building that stores wastes before application to
the land will conform to FIA minimum requirements in that the lowest
floor will be built at an elevation equal to the level of the 100-year
flood elevation,.  An engineering analysis which indicates the various
hydrodynamic and hydrostatic forces expected to result from the 100-year
flood and measures taken to design the facility accordingly is also
included."

Example 2:  Proposed Drum Storage—Flood-Proofing

     "The facility is located on the 100-year floodplain.  Flood-proofing
measures are described in detail; they allow flood waters to come into
contact with the building structures while preventing damage thereof.
The Army Corps of Engineers manual "Flood-Proofing Regulations" was
rigorously followed.  The floodproofing follows FlA's minimum
requirements.  The building housing the drums will be floodproofed such
that below the 100-year flood level the structure is water tight with
walls substantially impermeable to the passage of water.  In addition,
structural components will be capable of resisting hydrostatic and
hydrodynamic loads and etfects oi buoyancy. "

Kxample 3:  Proposed Drum Storage--Manageria1 Solutions

     The site  is  located on a 100-year floodplain.  Managerial
procedures, as described, demonstrate that the drams are adequately
safeguarded against washout without utilizing specific flood-proofing
methods.  The  proposed site is designed to store up to 400 barrels of
hazardous wastes we produce.  Under normal circumstances, the barrels
will be stored on pallets  (four to a pallet) in Building D located at the
most convenient access point to the site.  However, as this point is also
within the 100-yt-ar floodplain of a small stream, an attachment is
provided  to show  plans which would guarantee sate storage of the drums in
the event of the  100-year  flood.
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     Forklift trucks will  be used to transport  the barrels  from their present
location to a concrete platform,* built 6 feet  above  the  100-year  flood  level
on a hill onsite (approximately 500 feet away from Building D) .   Drums will  be
placed, at a maximum,  two  drums high,  using the pallets  for support.   In most
circumstances, however, we will be storing significantly  fewer  than 400  drums
and stacking will not be necessary.  Waste removal procedures are  keyed  to the
river stages, such that, when the river approaches the 100-year flood stage,
the contingency plan for drum relocation is initiated. Using four forklifts
and a flat-bed truck we estimate that 400 drums can be moved in 3  hours  and
assure completion before floodwaters reach the  facility.

     The potential for accidental discharge of  the waste  during movement has
been evaluated (damaging drums with the forklift,  spilling  drums,  etc.)  and
necessary precautions are  included as an attachment.   Personnel  who will be
involved are trained and available at all times onsite.   Methods to prevent.
any discharge are included in the application,  including:   health  and safety
precautions, drum removal  stipulations, a mock  demonstration of  removal,
personnel qualifications,  and flat-bed truck and forklift maintenance."

     Example 4:  Existing  Waste Pile

          "Almost half of  the facility property is located  within  the 100-year
     floodplain and is subject to floods 1-5 feet  in  depth.  The long-term
     solution offered is to move the waste pile to higher ground;  plans  for
     such are attached. However, if a flood occurs prior to this, the
     following steps will  be followed:

     1.   We will consult  with the nearest National Weather Service station  or
          the Army Corps of Engineers  for a projected time  and  elevation of
          flood crest.

     2.   If this crest will result in less than 1 foot of  water in the  waste
          pile area, sandbags will be used to dike the area to  a level of
          1 foot over the  projected level of water.

     3.   If the crest will be greater than 1 foot, the waste will be removed
          in a sitniliar manner to that described in "Managerial  Solutions" of
          this section. The waste pile will take  approximately  6  hours  to
          remove; a sandbag dike will protect the  site during this time."
*Note:   The applicant .should recognize that  the  location to which  the  wastes
 will be moved must be a RCRA Interim Status  Facility  or a  RCKA Permitted
 Faci11 ty.
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     Example 5:   New  Landfill

          "A permanent  flood water  protection dike will be constructed around
     three sides  of the  active  landfill cells.  A temporary flood water
     protection  dike  is  to  be constructed  along the  fourth side of the active
     landfill cells,  to  be  moved  as  the landfill cells are expanded.  When the
     maximum landfill cell  size is  reached,  a permanent flood water protection
     dike will be constructed.   The  flood  water protection dike will be
     constructed to a minimum elevation of thirteen  feet above mean sea  level,
     thus providing a factor of safety of  2  feet above the 100-year flood
     elevation.   Additionally,  side  slopes will not  exceed three horizontal  to
     one vertical and will  be protected from erosion due to incident rainfall,
     rainfall runoff, or flooding.   Attachments showing all engineering  plans
     are included."

     Example 6:   Existing Landfill

          "The landfill  site is located on a 100-year  floodplain.  The volume
     and physical and chemical  characteristics of the waste in the facility
     are reported as  attachments  to this application,  as well as
     concentrations of hazardous  constituents that could affect surface  waters
     in a washout.  Impacts of  these constituents on users, water quality
     standards and sediments was  evaluated by a toxicologist and are reported
     in the application. The  facility  is  shown to be  in compliance with
     existing standards."

     Existing facilities that are located  on a 100-year floodplain but do not
have a flood plan or  are not designed to withstand washout are not in
compliance with the  floodplain  regulations in §264.18(b).  These applicants
are required by §270.L4(b)(l1)(v) to provide a plan  indicating how and when
the facility will be  brought  into compliance.  A  schedule  supporting these
assertions must be included.

     Example:

          "The facility was built in 1976.  It is located  on  the 100-year
     floodplain and no  flood protection or flood  proofing measures exist;
     therefore,  it is currently NOT in  compliance with the regulations  in
     §264.18(b).  Under  the interim RCRA permit for  this facility, a
     compliance schedule was  adopted which allows a  one year  time period
     during which levees will be built  to  bring the  facility  into compliance.
     Engineering plans  of levee development are  included in  this application;
     they show the design of the operational units of  the  facility.  Various
     hydrodynamic and hydrostatic forces  expected during a 100-year  flood are
     reported and features  to  protect the  facility  from damage due to  such are
     enumerated."
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List of Major Points

     1.   Is the area in question adjacent to any streams or rivers?

     2.   Are FIA flood hazard boundary maps/insurance  studies  available  for
          the area in question?  Are Flood Insurance Rate Maps  available?

     3.   If not, are floodplain maps available from USGS or the  Army  Corps  of
          Engineers or local planning agencies?

     4.   If the site is on a small floodplain area ( 200 feet  wide),  will  the
          FIA help determine the 100-year flood elevation and areas  affected?
          Can FIA techniques be used to calculate the elevation in-house?

     5.   What other tools can be used to indicate that the site  is  or is not
          located on a 100-year floodplain?

     6.   What special flooding factors should be considered in designing,
          constructing, operating, and maintaining the  facility to withstand
          washout from a 100-year flood?

     7.   What hydrostatic and hydrodynamic forces are  expected to result at
          the site as a consequence of a 100-year flood?

     8.   What type of control measure is warranted at  the site:  flood
          protection or flood proofing?

     9.   How are such units designed to show that washout will be prevented?

     10.  Is it practical to remove the waste to a safe location  at  the onset
          of flood conditions?  How will such notification be assured? How
          will the removal take place?  What equipment  will be  used?   How is
          availability documented?  How quickly can removal occur?  What will
          be involved in the procedure, who will be responsible for  what
          action, etc.?  Where will the waste be moved  to?  Is  this  place
          eligible to receive hazardous waste in accordance with  the
          regulations?  What means are available to insure that the  resources
          for such removal will be available in time for  use?  What  is the
          potential for accidental discharge of waste to  the environment
          during movement?

     11.  What are the volumes and physical and chemical  characteristics  of
          the waste?

     12.  What is the concentration of hazardous constituents that could
          affect surface waters during washout and what impact  does  this have
          on potential users of these waters and applicable water quality
          standards?

     13.  What is the impact on the sediments of these  potentially affected
          surface waters or soils of the 100-year floodplain if there  is a
          washout?

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     14.   Is  the  facility  in  compliance  with  §264.18(b)  (The  Floodplain
          standards)  i.e.,  is it  designed,  constructed,  operated,  and
          maintained  to prevent washout  of  any hazardous waste  during  a
          100-year  flood?

     15.   If  not,  can it be demonstrated instead  that  the waste will be  safely
          removed  to  a non-vulnerable  location in  case of flood?

     16.   If  none  of  the above, can  it be demonstrated that no  adverse effects
          on  human  health  or  the  environment  will  ensue  due to  washout (from a
          100-year  fLood)  from the facility?   Consider volume and  physical  and
          chemical  characteristics of  the waste;  concentration  of  wastes which
          could affect surface waters  in a  washout;  impact on users, water
          quality  standards,  impact  on soils, etc.

     Additional discussion on the floodplain  requirements can be found in the
preambles to  the  regulations  at 46 FR  2813  and 47  FR 32290 in the
January 12,  1981  and  July  26, 1982 Federal  Registers,  respectively.  Also,
applicants should  review the  EPA  Standard for Location of Facilities described
at the end of the  seismic  analysis Section, 5.11.2.1.

5.11.3  References

      1.   General  Facility Standard  for  Location  of Facilities  (40 CFR 264,
          Subpart  B,  Section  264.18).   Background  Document.   U.S.  Environmental
          Protection  Agency.   December 30,  1980.

      2.   Avery,  T. Eugene.  Interpretation of Aerial  Photographs.  2nd
          Edition.   Burgess Publishing Company, Minneapolis,  MN, 1968.

      3.   Ray, Richard G.   Aerial Photographs in  Geologic Interpretation and
          Mapping.   Geological Survey  Professional Paper 373; U.S. Government
          Printing Office, Washington, DC., 1960,  p. 21.

      4.   Draft Permit: Writers Manual  for Subpart F.

      5.   U.S. Federal Emergency  Agency, Federal  Insurance Administration.
          "National Flood  Insurance  Program."  §1909.1 Definitions.   Federal
          Register.  Vol.  41, No. 207.  Tuesday,  October 26,  1976.

      6.   U.S. Department  of Housing and Urban Development,  Federal Insurance
          Administration.   Flood  Insurance  Study.   Borough of Trainer, PA,
          Delaware County, September 1977.
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5.12  PERSONNEL TRAINING

5.12.1  Regulatory Citations

     Information on employee training must be submitted with Part  B of the
permit application, as specified in:

               "§270.14(b)(12)  An outline of both the introductory and
          continuing training programs by owners or operators to prepare
          persons to operate or maintain the HWM facility in a safe manner as
          required to demonstrate compliance with §264.16.   A brief
          demonstration of how training will be designed to meet actual job
          tasks in accordance with requirements in §264.16(a)(13)."

     The regulatory requirements regarding employee training are contained in
§264.16.  They are:

          "§264.16 Personnel Training
               (a)(l) Facility personnel must successfully complete a program
          of classroom instruction or on-the-job training that teaches them to
          perform their duties in a way that ensures the facility's compliance
          with the requirements of this Part.  The owner or operator must
          ensure that this program includes all the elements described in the
          document required under paragraph (d)(3) of this Section.
               (2) This program must be directed by a person trained in
          hazardous waste management procedures and must include instruction
          which teaches facility personnel hazardous waste management
          procedures (including contingency plan implementation) relevant to
          the positions in which they are employed.
               (3) At a minimum, the training program must be designed to
          ensure that facility personnel are able to respond effectively to
          emergencies by familiarizing them with emergency procedures,
          emergency equipment,  and emergency systems, including, where
          applicable:
               (i) Procedures for using, inspecting, repairing,  and replacing
          facility emergency and monitoring equipment;
               (ii) Key parameters for automatic waste feed cut-off systems;
               (iii) Communications or alarm systems;
               (iv) Response to fires or explosions;
               (v) Response to ground water contamination incidents; and
               (vi) Shutdown of operations.
               (b) Facility personnel must successfully complete the program
          required in paragraph (a) of this Section within six months after
          the effective date of these regulations or six months after the date
          of their employment or assignment to a facility or to a new position
          at a facility, whichever is later.  Employees hired after the
          effective date of these regulations must not work in unsupervised
          positions until they have completed the training requirements of
          paragraph (a) of this Section.
               (c) Facility personnel must take part in an annual review of
          the initial training required in paragraph (a) of this Section.
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               (d)  The owner or operator must maintain the following documents
          and records at the facility;
               (1)  The job title for each position at the facility related to
          hazardous waste management,  and the name of the employee filing each
          job;
               (2)  A written job description for each position listed under
          paragraph (d)(l) of this Section.   This description may be
          consistent in its degree of  specificity with descriptions of other
          similar positions in the same company location or bargaining unit,
          but must  include the requisite skill, education, or other
          qualifications, and duties of employees assigned to each position;
               (3)  A written description of  the type and amount of both
          introductory and continuing  training that will be given to each
          person filling a position listed under paragraph (d)(l) of this
          Section;
               (4)  Records that document that the training or job experience
          required  under paragraphs (a), (b), and (c) of this Section has been
          given to, and completed by,  facility personnel.
               (e)  Training records on current personnel must be kept until
          closure of the facility; training  records on former employees must
          be kept for at least three years from the date the employee last
          worked at the facility.  Personnel training records may accompany
          personnel transferred within the same company."

5.12.2  Guidance to Achieve the Part 264 Standards

5.12.2.1  General—
     The intent of  the personnel training requirements is to reduce the
potential for mistakes which might threaten human health or the environment by
insuring that facility personnel working in jobs where they handle hazardous
waste will be thoroughly familiar with their duties and responsibilities.
Further, the intent of the training requirements is not only to train
personnel in the mechanics of their job function.  Rather, and especially in
the areas of safety and emergency response,  employees should be made cognizant
of why they must perform certain tasks in a prescribed manner.  Providing
employees with a thorough explanation of why certain operations are performed
as they are, and not in a seemingly easier fashion, should reduce the use of
"short-cut" procedures that may be dangerous to plant personnel or the
surrounding population.

     An outline of  the training program for each of the job positions at your
facility must be submitted with your Part B application.  It should list the
areas of concern which will be covered in both the initial training program
and in the annual  review program.

     The point that you should make in your outline is that your programs will
prepare your employees to operate and maintain the hazardous waste facility in
a safe manner (as  required to demonstrate compliance with §264.16).
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     You must also include a brief description of how your training programs
will be designed to relate specifically to individual job tasks in
familiarizing your employees with emergency procedures,  emergency equipment,
and emergency systems at your facility.

     The requirements of §264.16 are that:

     •    Facility personnel must successfully complete  a training program
          which ensures the facility's compliance with the requirements of
          this Part (§264.16(a)(1)).

     •    The training program must be directed by a person trained in
          hazardous waste management procedures (§264.16(a)(2)).

     •    The training program must be designed to ensure at a minimum that
          facility personnel are able to respond with familiarity during an
          emergency situation (§264.16(a)(3)) .

     •    Facility personnel must successfully complete  the program within six
          months of their assignment to a facility (§264.16(b)).

     •    Facility personnel must take part in an annual review of the
          training program (§264.16(c)).

     •    The owner/operator must maintain documentation at the facility
          (§264.16(d)).

     •    Training records on current personnel must be  kept until closure of
          the facility (§264.16(e)).

     "Facility Personnel," is defined in §260.10, as:  "All persons who work
at, or oversee the operations of a hazardous waste facility, and whose actions
or  failure to act may result in noncompliance with the requirements of
Parts 264 or 265 of this Chapter."  In other words, all  personnel (supervisors
and nonsupervisory personnel) who are actively engaged in the operation of the
facility require the type of training which is described in this section of
the manual.

5.12.2.2  Responsibility of Facility Personnel § 264.16(a)(1) —
     Under the guidelines of the regulation, all personnel associated with the
handling of hazardous wastes are required to "successfully" complete a program
of  classroom instruction or on-the-job training that teaches them to perform
their duties in a way that ensures the facility's compliance with the
requirements of this part.

     Training records for each employee must be maintained at your facility.
However, these records and other paperwork required by §264.16 are not
required to be submitted with Part B of your application.  The only items in
regard to personnel training that must accompany your application are an
outline of introductory and continuing training programs and a brief
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description of how job tasks relate to the training.   However,  these items
should be specific enough to demonstrate that your training program complies
with the requirements of §264.16.  Also note that §264.16 requires  that
detailed information and records regarding your training program must be made
available at your facility.

     It is required that the training programs be specific to the various
positions performed at your facility.  Training should be structured so that
it parallels as realistically as possible the actual  job in order that the
"real world" activities are approximated as much as possible.  Any  training
program must also take into account the educational level of the class.  .

     Training may be acquired in any one of three ways:  a formal training
program (which refers to a training program offered outside of the  facility
such as the National Hazardous Materials Training Course offered by the Toxic
Substances Control Laboratory of Vanderbilt University), in-house training
programs, or on-the-job training programs.  A combination of these  three is
also feasible.  The decision lies with the owners and operators of  the
facility to determine which option is the most beneficial to operation of
their facility.

     It is not necessary for all facility personnel to be trained by attending
a formal program.  One approach would be to send only your supervisory
personnel to formal, off-site training programs.  In  this way,  they can
acquire the appropriate training skills and then relay those skills to the
remaining facility personnel by conducting more focused, on-the-job training
sessions.

     Choosing on-the-job or in-house training program options,  as opposed to a
formal training program, allows for more flexibility  in your training
programs.  They can be designed to closely fit the individual needs of the
employees' job requirements.  A formal training program will be more general
than a set of training programs designed for each of  the positions  at your
facility, and thus may not cover all of the various job positions in the level
of detail which is required by the regulation.

     All facility personnel, regardless of their position, must be
familiarized with your facility's contingency plan so they will all be able to
respond effectively in an emergency situation (i.e.,  an evacuation due to the
volatilization of spilled toxic wastes).  In this case, the majority of
employees will be responsible for vacating the premises in a predetermined
manner, while other facility personnel  (those who have been properly trained)
will have higher levels of responsibility.  Some may be responsible for
containing the spill, informing  local officials (i.e., police and firemen), or
bringing out fire-fighting equipment.

5.12.2.3  Program Instructors §264.L6(a)(2)—
     The training program must be instructed by persons who are trained  in
hazardous waste management procedures and can familiarize facility personnel
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with those same management procedures.   Facility personnel are only
responsible for learning those procedures which are relevant to the positions
in which they are employed.

     Program instructors,  especially those conducting formal programs, should
preferably be experts in the field of hazardous waste management, since
answers to questions that could arise during the class may require a
background of considerable experience and expertise.  For performance type
training programs (on-the-job training), the instructor should be a supervisor
who is skilled in the current methods of facility operation.  Supervisors are
recommended since they are the ones who must ultimately make the determination
of whether or not the trainees have mastered the skills necessary to perform
the tasks called for in their job descriptions.

5.12.2.4  Response to Emergencies §264.16(a)(3) —
     At a minimum, your training program must familiarize facility personnel
with emergency procedures, emergency equipment, and emergency systems which
are applicable to their positions.  Emergency response procedures which should
be taught to selected facility personnel, as required by the regulations, are:

     •    Procedures for using, inspecting, repairing, and replacing facility
          emergency and monitoring equipment,

     •    key parameters for automatic waste feed cut-off systems,

     •    communications or alarm systems,

     •    response to fires or explosions,

     •    response to ground water contamination incidents, and

     •    shutdown of operations.

     Additionally, employees who are in charge of managing wastes must have
certain knowledge which will help them perform their jobs adequately.  For
example, their training program might include the following instructions;

     •    the chemical characteristics of the wastes which they are assigned
          to manage (i.e., reactivity and incompatibility with other types of
          wastes),

     «    knowledge of what to do in the event of a spill or leak,

     •    the types of protective equipment (such as respirators or self
          contained breathing equipment) or clothing to be worn,

     •    proper operation of trucks, forklifts, or any other machinery to be
          used in waste disposal,

     e    knowledge of basic first aid, and

     »    who to inform in the event of an emergency (such as the foreman).


                                  5-167

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     It is your responsibility to define the scope of the training programs.
The training programs should assure the Agency that your employees have or
will have acquired the necessary training and management skills needed to
perform their jobs in a competent manner that will protect human health and
the environment.  Thus, the more detailed the training program documentation,
the more apparent it will be to the Agency that your facility is providing  its
personnel with proper training.

5.12.2.5  Time Requirements §264.16(b)—
     To comply with the §264.16 regulations, the training program must be
successfully completed by facility personnel at existing facilities within
6 months after the effective date of the regulations.  Thus, you have
12 months from the promulgation date of the regulations (July 26, 1983) to
make sure that your personnel have received their proper training.

     New employees who are hired after the effective date of the regulations
must not work in unsupervised positions requiring them to handle hazardous
wastes until they have completed their training programs.  New employees may
handle hazardous wastes but only under the supervision of trained employees.
It is beneficial to your facility to meet this requirement, as it will help
avoid accidents and may help to keep insurance premiums at a minimum.

5.12.2.6  Annual Review §264.16(c)~
     The emergency procedures taught in the original training program must  be
reviewed on an annual basis to keep personnel up to date with any changes,
such as the characteristics of new wastes managed at your facility.  With new
and more sophisticated technologies being developed for hazardous waste,
management facilities may have to periodically change certain procedures to
remain current with these new technologies.

     Also, due to changes in facility processes or emergency equipment, or
with the types of wastes being accepted at your facility, your facility's
contingency plan may need to be modified.  Therefore, the contingency plan
should also be included in the annual review process.

5.12.2.7  Recordkeeping §264.16(d)&(e)—
     Records must be kept at your facility  for examination by the Regional
Administrator upon request.  Maintenance of facility personnel training
records acts as a certification program.  The following must be  included on
your records:

     (1)  A job title  for each position at your facility that is related to
          hazardous waste management (i.e., excluding clerical or janitorial
          positions) and the names of the employees  filling those positions,
      (2)  a job description for each of  those positions,
and
      (3)   a description of the  type and amount of  introductory and  continuing
           training  that will be given to each employee.
                                  5-168

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     The job description (for each position) must include:

     •    skill, education, or other qualifications needed by employees to
          fill each position at your facility,

     •    duties of employees assigned to each position.

     It should not be too difficult to comply with the first or second
recordkeeping requirements, since many facilities may have this information
already in a written format.  If not, job titles and job descriptions must be
defined for each position.

     The third recordkeeping requirement relates directly to the training
program.  For each job description, you must include the type of training to
be given and the length of the program.  For instance, if you are sending
employees to a formal training program you must keep a written document
stating the types of hazardous waste management practices being taught and the
length of time involved.

     Similarly, if you have designed your own training programs to be
conducted in-house or on-the-job, you must keep a detailed written account of
the material to be presented for each position.  You must also include the
techniques to be used and a schedule to be followed by the instructors.  The
training records must also contain the type and amount of training that will
be given to fulfill the annual review requirement.

     The records must be documented to prove that the proper training has been
given to, and completed by facility personnel.  Therefore, you must keep a
record of the dates on which employees received their initial training and
schedule the annual review.

     The training records for current personnel must be kept on file at your
facility until your facility closes.  The training records of former employees
must be kept for at least 3 years from their last date of employment at your
facility.  If a person is transferred within the same company, their training
records remain the same.

     The training records are needed by the Agency in order to judge whether
facility personnel have to appropriate skills called for by their job
descriptions and their specific duties in handling hazardous wastes.  Thus,
the more detail used in your training records, the more apparent it will be
that your personnel are receiving the appropriate training.

5.12.3  List of Major Points

     1.   Has an outline of the training programs been included in the
          application?

     2.   Have both the original and annual training programs been addressed
          in the outline?
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3.    Has a description of how the training programs specific to the
     various job tasks performed at the facility been included with the
     outline?

A.    Do the outline and descriptions of the training programs demonstrate
     that the facility personnel will acquire the ability to respond
     effectively to emergency situations which are related to their tasks
     and that they will be familiarized with the contingency plan?

5.    Has documentation that the instructor is a person trained in
     hazardous waste management been included?

6.    Has it been demonstrated that all employees will be trained within si
     6-month time period from the date of their employment or transfer?

7.    Have the training records for all facility personnel that will be
     maintained at the facility been described?
                             5-170

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5.13  TOPOGRAPHIC MAP REQUIREMENTS

     In fulfilling requirements set forth for Part B of the RCRA application,
one of the first steps is to make or obtain a topographic map covering the
area in question.  Not only can this map serve as a base upon which
information detailed in this section should be placed (legal boundaries,
etc.); it also provides some of the required parameters intrinsically, for
instance, USGS maps show contours, scale, date,  etc.  The requirements of
§270.14(b)(19) are delineated here in conjunction with recommended methods for
meeting these requirements.  An example of a topographic map for a site is
included to assist in the presentation.

5.13.1  Regulatory Citations

     Part B of the permit application must incorporate a topographic map and
associated information to meet the requirements  of §260.14(b)(19), which are:

               "270 .14(b ) (19)  A topographic map showing a distance of
          1000 feet around the facility at a scale of 2.5 centimeters (1 inch)
          equal  to not more than 61.0 meters (200 feet).  Contours must be
          shown  on the map.  The contour interval must be sufficient to
          clearly show the pattern of surface water  flow in  the vicinity of
          and from each operational unit of the facility.  For example,
          contours with an interval of 1.5 meters (5 feet),  if relief is
          greater than 6,1 meters (20 feet), or an interval of 0.6 meters
          (2 feet), if relief  is less than 6.1 meters (20 feet).  Owners and
          operators of HWM facilities located in mountainous areas should use
          large  contour intervals to adequately show topographic profiles of
          facilities.  The map shall clearly show the following:
               (i)  Map scale  and date.
               (ii) 100-year floodplain area.
               (iii)  Surface  waters including intermittant  streams.
               (iv) Surrounding land uses (residential, commercial,
          agricultural, recreational).
               (v)  A wind rose (i.e., prevailing wind-speed and direction).
               (vi) Orientation of the map (north arrow).
               (vii)  Legal boundaries of the HWM facility site.
               (viii)  Access  control (fences, gates).
               (ix) Injection  and withdrawal wells both onsite and offsite.
               (x)  Buildings; treatment; storage, or disposal operations; or
          other  structures (recreation areas, runoff control systems, access
          and internal roads,  storm, sanitary, and process sewerage systems,
          loading and unloading areas, fire control  facilities, etc.).
               (xi) Barriers for drainage or flood control.
               (xii)  Location of operational units within the HWM facility
          site,  where hazardous waste is (or will be) treated, stored, or
          disposed (include equipment cleanup areas).
                                    5-171

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     Additional information which must be noted on the topographic map is
specified in the requirements of § 270.14(c)(3) , as follows:

               "On the topographic map required under paragraph (b)(19) of this
          section, a delineation of the waste management area, the property
          boundary, the proposed "point of compliance" as defined under
          §264.95, the proposed location of ground water monitoring wells as
          required under §264.97, and, to the extent possible, the information
          required in paragraph (c)(2) of this section.", that being  ...
          "(2)  Identification of the uppermost aquifer and aquifers
          hydraulically interconnected beneath the facility property,
          including ground water flow direction and rate, and the basis for
          such identification (i.e., che information obtained from
          hydrogeologic investigations of the facility area)."

5.13.2  Obtaining Topographic Maps

     The regulations require that the topographic map submitted in Part B of
the application include:  2 feet or 5 feet contour intervals.  USGS maps
(7.5 minute quadrangles) generally incorporate 10 feet contour intervals so
that the applicant may generally have to produce a map for his site.  Some
USGS maps for flat regions are at 5 feet intervals but will still likely be
insufficient due to the range of elevation (little) incurred in such an area
(with flat areas, the intent is to provide 2 feet contour intervals; with
steep, 5 feet).  For this reason, several methods which are applicable in
producing or obtaining the necessary topo maps are discussed here.  They
include:

     •    obtaining a map from local town offices,

     •    onsite surveying to gather exact elevation information and present
          it in map form,

     •    the use of a photogrammetric company to fly the site and develop a
          map with a specified contour interval,

     •    the use of a USGS map, where it will allow the permit applicant to
          meet the qualifications required.

     Often, local  town offices, such as the Building Department or Board of
Assessors, have compiled large scale maps which might be helpful in meeting
the topographic map requirements.  Such a map could be used as a base map if
the contour intervals are 2 or 5 feet.

     If no suitable topographic mapping of the proposed  site location exists,
it may be necessary to measure and plot land elevations by conducting a stadia
survey.  This  technique will provide  the  information necessary for  plotting
any desired contour interval.

     Another method which the applicant might choose to  meet the topographic
map requirements entails the use of a photogrammetric survey company  to fly
the site and produce  the map required.  Such companies are available
                                     5-172

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throughout the U.S.   Their abilities include  planning  and  scheduling  the
flight to collect data for the map,  performing the flight, analyzing  the
results, and compiling a final topographic map.   In addition,  the  applicant
could request that this company take the aerial  photos needed  for  fault
location or other geologic information,  thus  fulfilling several  requirements
at once.

     USGS topographic maps are referred  to as quadrangle maps.   They  cover
four-sided areas indexed by geographical latitude and  longitude.   Quadrangle
size is given in minutes or degrees; most often a 7.5  minute quadrangle  will
be desired for RCRA permitting.

     The first step in obtaining a topographic map of  the  site  area is to
determine which map(s) are appropriate,  i.e.  what are  the  names  of the
specific quadrangles covering this area.  This may be  accomplished in any of
several ways.

     1.   The USGS may be contacted in Arlington, VA for areas  east of the
          Mississippi River; Denver, Co. for  areas west of the
          Mississippi River.  They would provide the name  over  the phone or
          send out an index map for the  state in question.  The  permit
          applicant could then locate the area on the  index map  and obtain the
          name(s) of needed quandrangle(s) in this manner.

     2.   Index map sets may be available from a local college  or  University.
          These could be consulted to determine  which  quadrangle  is desired.

     3.   Local town offices may be aware of  which quadrangle  covers  their
          area (town engineer, planners, etc.).

     4.   Other nearby institutions or firms  that deal with land  holdings or
          have extensive properties in the area  are likely to  have USGS
          quadrangles for the area.

     5.   If a geologist is used in any  seismic  interpretations,  this person
          could easily obtain the quadrangle  in  question.

     6.   Maps may be purchased over-the-counter from  local USGS  offices,  map
          distributers, and other suppliers.

A sample order form is included here as  Figure 5-6. RCRA  requires a
topographic map showing a distance of 1000 feet  around the facility.   This
requirement will determine how many quadrangles  are necessary  to  include  and
order.

5.13.3  Topographic Map Features

     The USGS will provide, free on request,  a one-page sheet which shows  the
topographic map symbols normally found on their  maps.   These features should
also be noted on maps formed through photogrammetry, compiled by  surveying, or
obtained through town offices.  Several  of these symbols are described below.
                                      5-173

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               Mail this order to:

                    EASTERN DISTRIBUTION BRANCH
                        U.S. GEOLOGICAL SURVEY
                          1200 SOUTH EADS STREET
                         ARLINGTON, VIRGINIA 22202
       MAP ORDER BLANK
       DATE:

       FROM:  X.

       Street Addrew

       CitT 	
                                            State
                                                                           Zip Code
                           LIST MAPS ALPHABETICALLY BY MAP NAMES IN STATE CROUPS
                                Indexei and alphabetized order forms available for all Stale*
         Quantity   Map Name and State  OR  Map Series and Number
                                                                Scale
Unit Price
            Total Prite
                      	                                         ["" 5«« mwt* ||4« l«r "1
PREPAYMENT REQUIRED Remittance parable to U.S. C«olo«ieal Sur»er   \_ «~~V -/-~-~ J  Total
                  for PROMPT, ACCURATE SHIPMENT PLEASE FILL IN THE FOLLOWING LABEL
                                      PIe«e PRINT or TYPEWRITE
FROM:
  EASTERN DISTRIBUTION BR

   U.S. GEOLOGICAL SURVEY
   1200 SOUTH EADS STREET
  ARLINGTON. VIRGINIA 22202
                              TO:
                              Name
                              Street Addrwa
                             Citr.
                                                            State
                                                                                 Zip Code .
                        Figure 5-6.   Sample  USGS  map order  form.
                                              5-174

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5.13.3.1  Contours—
     Contours are imaginary lines following the ground surface at a constant
elevation above or below sea level.   Contour lines  are normally shown in brown
on USGS topographic maps.  USGS maps vary in contour interval; they are either
5 feet, 10 feet, or 20 feet, depending on the relief involved.  The contour
interval is reported beneath the scale at the bottom of the map or may be
determined by simple inspection of the map.  Contour intervals depend on
ground slope and map scale.  Small contour intervals are used for flat areas;
larger contour intervals for mountainous terrain.

     The Part 270 regulations require contour intervals of 5 feet with relief
of more than 20 feet; and intervals  of 2 feet with  relief less than 20 feet.
Relief is the total change in elevation over the area of concern.  The site in
question could be mapped using a USGS 5 feet contour map if relief is more
than 20 feet within the site area.  Otherwise, USGS maps would not provide
sufficient detail.  Regardless of the mapping system used, major contour
intervals should be clearly noted with the applicable land elevation.

5.13.3.2  Scale—
     The scale shows the relationship between distance on a map and the
corresponding distance on the ground.  The scale of USGS topo maps is provided
at the bottom of the map in the form of a numerical ratio and graphically
using bar scales marked in feet, miles, and kilometers.  For example, the
numerical ratio 1:24,000 indicates 1 inch on the map equals 24,000 inches on
the earth; or 1 cm on the map equals 24,000 cm on the earth, etc.  Any map
used should clearly indicate scale.   The scale must be no smaller than
1 inch = 200 feet (1:2400) to meet RCRA topographic map requirements.
However, for larger HWM facilities,  the EPA will allow the use of other scales
on a case-by-case basis.

5.13.3.3  Date--
    .The date on which the map was compiled (year of photos used, etc.) should
be inserted on the map where new maps or town maps  are used.  USGS quadrangles
provide a date (year) in which aerial photographs were taken (from which the
map was compiled) on the bottom left hand corner of the map.  In addition, the
date of any field check is provided.  The most recent revisions to the map are
normally added in purple, along with the year of any aerial photographs.
Dates are also included in the bottom right hand corner of the map, under the
quadrangle name.  USGS attempts to update their maps every five years.

5.13.3.4  Surface Waters-—
     Surface waters, including intermittent streams, must be shown on the
topographic map supplied in the application.  For USGS topographic maps, USGS
symbols should be consulted in determining the various types of surface waters
shown.  Perennial streams are normally shown as solid blue lines whose
thickness relates to stream flow (size).  Intermittent streams are usually
shown as solid blue lines interrupted by dots at frequent intervals and no
exaggeration of width.  These surface water types may be contrasted with
ephemeral streams which consist of a dry channel throughout most of the year,
bearing water only during and after rainfall.  Ephemeral streams need not be
shown on the topo site map.
                                       5-175

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     All topographic maps should also depict ponds and lakes.   The USGS maps
show lakes (usually blue),  dams, large rapids,  marshes,  waterfalls,  etc.

5.13.3.5  Land Forms/Land Use—
     RCRA requires that the site topographic map depict  surrounding land uses
such as residential, commercial, agricultural,  or recreational.  This
information may be ascertained from sources in  local town offices, by
first-hand observations, or by using the USGS quadrangle.

     The USGS quadrangle indicates buildings (dwellings, places of employment,
etc.) usually as solid hatch-marked squares.  Schools, churches, and
cemetaries are also indicated, as are barns or  warehouses.  Golf courses are
often indicated, as are railroad tracks.  Various boundary line types are used
to delineate city limits, national or state reservations, small parks, land
grants, etc.  The breakdown of
residential/commercial;'agricultural/recreational uses may thus be seen to a
great degree from observing a USGS quadrangle map.  Applicants not using USGS
quads should seek land use information from the local planning board, regional
planning commissions, state agencies, etc.  In  addition, the Geological Survey
has special land use maps available for some areas.  The applicant can inquire
about the area in question at:

                                Geography  Program
                      Land Information and Analysis Office
                                  USGS - MS 710
                                Reston,  VA  22092

5.13.3.6  Map Orientation—
     Part 270 requires  that the orientation of the topographic map be
displayed using a north arrow.  USGS  topographic maps include north arrows
(showing magnetic north) to the left  of the scale at  the bottom of each map.
Most other maps (land use, town planners, etc.) have such direction indicators,

5.13.4  Obtaining Climatological Information (Wind Rose)

     Wind rose information is available through:

                            National  Climatic  Center
                              Department of Commerce
                                Federal Building
                         Ashville,  North Carolina  28801
                                  (704)  258-2850

Often,  the climatic  center will refer the  caller  to a data-collecting office
which  is  local to the area of concern.  A wind rose can be inserted on the
topographic map with additional wind  data noted  in accompanying discussion.
                                      5-176

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 5.13.5  Flood Plain Area Maps

     An indication of the 100-year floodplain area must be included on the
 topographic map submitted with your application, as required in
 §270.14(b)(19)(ii).  Additional information which you must submit on  flooding
 is presented in Section 5.11 of this manual.

     As a part of the National Flood Insurance Program (NF1P), Flood  Hazard
 Boundary Maps (FHBM) have been prepared for virtually all (20,238) communities
 that have been identified as "flood prone".  The FHMB delineates the  boundaries
of the 100-year flood plain, although they do not provide elevations.  Nearly
 90 percent of the Federal Emergency Management Agency (FEMA) maps are of  this
type.  In addition, some of the communities that have been accepted into  the
NFIP have Flood Insurance Rate Maps (FIRM) which delineate the 100-year flood
plain and also provide flood elevations.  Where these maps are available,
determination of the 100 year flood plain is straight-forward.  Such  maps are
most often included as part of a brief Flood Insurance Study for a particular
political jurisdiction along a waterway.  The U.S. Department of Housing  and
Urban Development, Federal  Insurance Administration which publishes such
studies,  includes a fold-out map delineating 100-year flood boundaries for
various river reaches in the area covered.  An original or clear copy of  this
map (or another suitable map) should be included in the permit for all cases
in which sites are located  near a river.  Hydraulic analyses used to  determine
the flood level,  community  description,  and principal flood problems  and  flood
protection measures are also provided in the flood insurance studies  and
 should be included in the application.

     If a 100-year flood level is not available from another source,  the
applicant may have to determine the level using a Flood Hazard Boundary Map.
The applicant should use a  qualified hydrologist for such determinations  or
may contact the FIA to assist in determining the 100-year flood elevation at
 the location in question.

     FIA does not usually map flood plains that are less than 200 feet wide.
 In such situations, the applicant will have to make a determination of the
extent of the 100-year floodplain.  FIA mapping procedures should be  used to
make this determination, or the applicant can assume it is 200 feet to be
conservative  The applicant might also consult the U.S. Geological Survey (may
have detailed flood-hazard maps of area) the U.S. Army Corps of Engineers, the
U.S. Soil Conservation Service, the Office of Coastal Zone Management, or
others for floodplain information.  All data sources should be noted  in the
application.  In addition,   any special flooding factors (e.g. wave action)
which might be considered in designing,  constructing, operating, or
maintaining a facility to withstand washout from a 100-year flood should  be
included on the map.

5.13.5.1  Site Boundary Maps—
     The applicant should include the boundaries of the site land.  An
official plot plan from town offices should be obtained and included  as part
of this information.
                                       5-177

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5.13.6  Other Required Information

     Information which should be delineated on the topographic map includes:

     •    Access control (fences, gates),

     •    Buildings, treatment,  storage,  or disposal operation areas and other
          structures nearby or onsite,

     •    Barriers for drainage or flood  control,

     •    Operational HWM facility unit locations.

5.13.6.1  Well Locations--
     The applicant should designate existing and proposed onsite and offsite
wells on the submitted topographic map.  Well depth and elevation should be
reported for comparison with the submitted cross-section and/or well logs.
Cross-section locations should be clearly delineated on the map.

5.13.6.2  Access Control—
     Fences and gates are required for  security purposes (see Section 5.4) at
all hazardous waste management sites.   These structures should be indicated on
the topographic map submitted.

5.13.6.3  Buildings and Other Structures  Nearby or Onsite—
     Each existing or proposed building located in the site area should be
depicted on the topo map.  This  will enable the applicant to provide the
reviewer with an idea of site operations,  transportation routes onsite and
offsite, proximity of units to surface  waters, relationship to elevation and
geology, etc.

5.13.6.4  Barriers for Drainage or Flood  Control—
     The applicant should show drainage or flood control measures on the
topographic map where appropriate.

5.13.6.5  Operational Unit Locations—
     The topographic map submitted by the applicant should also include the
location of all existing and proposed operational  units.  Other facility
design features such as run-on/run-off  control systems and wind dispersal
control systems should be shown.

5.13.7  List of Major Points

     1.   Has a topographic map been provided in the application?

     2.   Does the map have the required scale and contour intervals?

     3.   Does the map show the area within 1000 feet of the facility?

     4.   Does the map clearly show the items identified in §270.14(b)(19)(i)
          through (xii)?
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5.14  MANIFEST SYSTEM, RECORDKEEPING, AND REPORTING

5.14.1  Regulatory Citations

     Subpart E—Manifest System, Recordkeeping,  and Reporting, of Part 264, is
not specifically identified in the Part 270 permit information requirements.
Although permit applicants are not required to submit material to demonstrate
compliance with Subpart E with their permit applications, failure to comply
with the Subpart E requirements is a violation of any permit that may be
issued.

     The owners and operators of existing and interim status facilities should
be especially cognizant of the Subpart E requirements for two reasons.  First,
they should already be complying with these requirements as required by
Subpart E of the interim status regulations in Part 265.  Second, the review
of a Part B permit application by the permitting authority is very likely to
include a thorough site inspection of the applicant's facility.  During that
inspection,  the applicant can expect to be asked to show that his manifesting,
recordkeeping, and reporting procedures do comply with the Part 264, Subpart E
requirements.   Applicants who cannot demonstrate a thorough knowledge of those
requirements,  or whose procedures are identified as not complying with the
requirements during the inspection, could delay or jeopardize the approval of
their permit application.

     Subpart E of Part 264 is reproduced below.

          "Subpart E—Manifest System, Recordkeeping, and Reporting

          §264.70  Applicability.
               The regulations in this Subpart apply to owners and operators
          of both on-site and off-site facilities, except as §264.1 provides
          otherwise.  Sections 264.71, 264.72, and 264.76 do not apply to
          owners and operators of on-site facilities that do not receive any
          hazardous waste from off-site sources.

          §264.71  Use of manifest system.
               (a)  If a facility receives hazardous waste accompanied by a
          manifest, the owner or operator or his agent, must:
               (1)  Sign and date each copy of the manifest to certify that
          the hazardous waste covered by the manifest was received;
               (2)  Note any significant discrepancies in the manifest (as
          defined in §264.72(a)) on each copy of the manifest;
               (3)  Immediately give the transporter at least one copy of the
          signed manifest;
               (4)  Within 30 days after the delivery, send a copy of the
          manifest to the generator; and
               (5)  Retain at the facility a copy of each manifest for at
          least three years from the date of delivery.
               (b)  If the facility receives,  from a rail or water (bulk
          shipment) transporter, hazardous waste which is accompanied by a
          shipping paper containing all the information required on the


                                 5-179

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manifest (excluding the EPA identification numbers,  generator's
certification, and signatures),  the owner or operator, or his agent
must:
     (1)  Sign and date each copy of the manifest or shipping paper
(if the manifest has not been received) to certify that the
hazardous waste covered by the manifest or shipping  paper was
received;
     (2)  Note any significant discrepancies (as defined in
§264.72(a)) in the manifest or shipping paper (if the manifest has
not been received) on each copy of the manifest or shipping paper.
     (3)  Immediately give the rail or water (bulk shipment)
transporter at least one copy of the manifest or shipping paper (if
the manifest has not been received);
     (4)  Within 30 days after the delivery, send a copy of the
signed and dated manifest to the generator; however, if the manifest
has not been received within 30 days after delivery, the owner or
operator, or his agent, must send a copy of the shipping paper
signed and dated to the generator; and
     (5)  Retain at the facility a copy of the manifest and shipping
paper (if signed in lieu of the manifest at the time of delivery)
for at least three years from the date of delivery.
     (c)  Whenever a shipment of hazardous waste is initiated from a
facility, the owner or operator of that facility must comply with
the requirements of Part 262 of this chapter.

§264.72  Manifest discrepancies.
     (a)  Manifest discrepancies are differences between the
quantity or type of hazardous waste designated on the manifest or
shipping paper, and the quantity or type of hazardous waste a
facility actually receives.  Significant discrepancies in quantity
are:  (1) For bulk waste, variations greater than 10 percent in
weight, and (2) for batch waste, any variation in piece count, such
as a discrepancy of one drum in a truckload.  Significant
discrepancies in type are obvious differences which can be
discovered by inspection or waste analysis, such as waste solvent
substituted for waste acid, or toxic constituents not reported on
the manifest or shipping paper.
     (b)  Upon discovering a significant discrepancy, the owner or
operator must attempt to reconcile the discrepancy with the waste
generator or transporter (e.g., with telephone conversations).  If
the discrepancy is not resolved within 15 days after receiving the
waste, the owner or operator must immediately submit to the Regional
Administrator a letter describing the discrepancy and attempts to
reconcile it, and a copy of the manifest or shipping paper at issue.

§264.73  Operating record.
     (a)  The owner or operator must keep a written operating record
at his facility.
     (b)  The following information must be recorded as it becomes
available, and maintained in the operating record until closure of
the facility:
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     (1)  A description and the quantity of each hazardous waste
received, and the method(s) and date(s) of its treatment, storage,
or disposal at the facility as required by Appendix I;
     (2)  The location of each hazardous waste within the facility
and the quantity at each location.  For disposal facilities, the
location and quantity of each hazardous waste must be recorded on a
map or diagram of each cell or disposal area.  For all facilities,
this information must include cross-references to specific manifest
document numbers, if the waste was accompanied by a manifest;
     (3)  Records and results of waste analyses performed as
specified in §§264.13, 264.17, and 264.341;
     (4)  Summary reports and details of all incidents that require
implementing the contingency plan as specified in §264.56(j);
     (5)  Records and results of inspections as required by
§264.15(d) (except these data need be kept only three years);
     (6)  Monitoring, testing, or analytical data where required by
Subpart F and §§264.226, 264.253, 264.254, 264.276, 264.278,
264.280, 264.303, 264.309,  and 264.347;
     (7)  For off-site facilities, notices to generators as
specified in §264.12(b); and
     (8)  All closure cost estimates under §264.142, and, for
disposal facilities, all post-closure cost estimates under  §264.144.

§264.74  Availability, retention, and disposition of records.
     (a)  All records, including plans, required under this Part
must be furnished upon request, and made available at all reasonable
times for inspection, by any officer, employee, or represenative of
EPA who is duly designated by the Administrator.
     (b)  The retention period for all records required under .this
Part is extended automatically during the course of any unresolved
enforcement action regarding the facility or as requested by the
Administrator.
     (c)  A copy of records of waste disposal locations and
quantities under §264.73(b)(2) must be submitted to the Regional
Administrator and local land authority upon closure of the facility.

§264.75  Biennial report.
     The owner or operator must prepare and submit a single copy of
a biennial report to the Regional Administrator by March 1 of each
even numbered year.  The biennial report must be submitted on EPA
form 8700-13B.   The report must cover facility activities during the
previous calendar year and must include:
     (a)  The EPA identification number, name, and address of the
facility ;
     (b)  The calendar year covered by the report;
     (c)  For off-site facilities, the EPA identification number of
each hazardous waste generator from which the facility received a
hazardous waste during the year; for imported shipments, the report
must give the name and address of the foreign generator;
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     (d,)  A description and the quantity of each hazardous waste the
facility received during the year.  For off-site facilities, this
information must be listed by EPA identification number of each
generator;
     (e)  The method of treatment, storage, or disposal for each
hazardous waste;
     (f)  [Reserved]
     (g)  The most recent closure cost estimate under §264.142, and,
for disposal facilities, the most recent post-closure cost estimate
under §264.144; and
     (h)  The certification signed by the owner or operator of the
facility or his authorized representative.

§264.76  Unmanifested waste report.
     If a facility accepts for treatment, storage, or disposal any
hazardous waste from an off-site source without an accompanying
manifest, or without an accompanying shipping paper as described in
§263.20(e)(2) of this Chapter, and if the waste is not excluded from
the manifest requirement by §261.5 of this Chapter, then the owner
or operator must prepare and submit a single copy of a report to the
Regional Administrator within fifteen days after receiving the
waste.  The unmanifested waste report must be submitted on EPA form
8700-13B.  Such report must be designated  'Unmanifested Waste
Report1 and include the following information:
     (a)  The EPA identification number, name, and address of the
facility;
     (b)  The date the facility received the waste;
     (c)  The EPA identification number, name, and address of the
generator and the transporter, if available;
     (d)  A description and the quantity of each unmanifested
hazardous waste the facility received;
     (e)  The method of treatment, storage, or disposal for each
hazardous waste;
     (f)  The certification signed by the owner or operator of the
facility or his authorized representative; and
     (g)  A brief explanation of why the waste was unmanifested, if
known.

§264.77  Additional reports.
     In addition to submitting the biennial reports and unmanifested
waste reports described in §§264.75 and  264.76, the owner or
operator must also report to the Regional Administrator:
     (a)  Releases, fires, and explosions as  specified in §264.56(j);
     (b)  Facility closures specified in §264.115; and
     (c)  As otherwise  required by Subparts F and  K-N.

§264.78-264.89  [Reserved]
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5.14.2  Guidance to Achieve the Part 264 Standards

     The purpose of Subpart E of Part 264 is to establish specific handling
procedures for records of waste movement.  The requirements in Subpart E are
the heart of the "cradle-to-grave" tracking system that the EPA has
established for movements of hazardous wastes.

     The applicability statement in §264.70 indicates that the regulations
apply to all owners and operators of hazardous waste treatment, storage, and
disposal facilities.  However, the regulations make a distinction between
facilities used to treat, store, or dispose of wastes generated on the same
property (onsite facilities) and facilities used to treat, store, or dispose
of wastes that were not generated on the facility property (offsite
facilities).  Specifically, owners and operators of onsite facilities are not
required to utilize a manifest system if they do not receive any hazardous
waste from offsite sources.  However, they are still required to comply with
the manifest system standards contained in Subpart B of Part 262 if they ship
hazardous waste off of their property.  The owners and operators of all^
facilities, regardless of whether they are onsite or offsite facilities, must
comply with the requirements of §§264.73, 264.74, 264.75, and 264.77.

     The requirements for manifest handling with which owners or operators of
hazardous waste treatment, storage, or disposal facilities must comply are
contained in §264.71.  Two handling procedures are identified, one for
manifests which accompany hazardous wastes received, and one for shipping
papers accompanying hazardous wastes received from rail or water (bulk
shipment) transporters.  The procedures for handling either manifests or
shipping papers are identical.  They are:

     1.   Sign to certify receipt of the waste,

     2.   Note, on the document, discrepancies between the document and the
          wastes received,

     3,   Immediately give a signed copy to the person delivering the waste,

     4.   Send a signed copy to the generator within 30 days, and

     5.   Keep a signed copy on file for 3 years from date of receipt.

     Waste analyses do not have to be performed immediately upon receipt to
identify discrepancies.  The discrepancies that should be noted on the
manifest or shipping papers are obvious ones  that can be immediately
determined by counting or measuring the waste received and comparing the
manifest or shipping papers with labels on the waste.

     A description of what a discrepancy is and the actions that must be taken
when a discrepancy is identified either on receipt or during later waste
analyses are presented in §264,72.  The description of discrepancies in
quantity presented in §264.72(a) identifies any difference in piece count for
batch waste and greater than a 10 percent difference in quantity for bulk
                                    5-183

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wastes as significant discrepancies.  However, the receiver of bulk wastes
should use judgment regarding whether or not to adhere to  the  10 percent
requirement based on the size of the bulk shipment received.   Any difference
between the amount of the bulk shipment stated on the' manifest or shipping
papers and the amount actually received should be noted on the documents  at
the time of receipt.  The receiver should then decide whether  or not  to take
the actions identified in §264.72(b) based on the quantity of  difference  and
not the percent of difference for bulk shipments.

     In §264.72(b), receivers of hazardous waste are required  to attempt  to
reconcile significant discrepancies with the generator or  transporter within
15 days of receiving a waste.  If your permit requires you to  analyze incoming
waste, you must stiil attempt to reconcile differences within  the "15 days
from receipt" limit,  It is therefore to your advantage to perform any
required analyses as soon as possible after receipt to avoid the reporting
requirement if analysis identifies a discrepancy.

     If identified discrepancies in type or quantities of waste received
cannot be reconciled within 15 days of receipt, the receiver must immediately
notify the Regional Administrator.  The notification must  include a letter
describing the discrepancy and attempts to reconcile it, and include  copies of
the subject manifests or shipping papers.

     Owners and operators of hazardous waste treatment, storage, or disposal
facilities are required by §264.73(a) to keep a written operating record.
Eight items of information which must be recorded in the operating record are
identified in §264.73(5).  They are:

     1.   Records on wastes received and treated, stored,  or disposed;

     2.   Records on locations of wastes within the facility,

     3.   Waste analyses results,

     4.   Records of contingency plan implementation,

     5.   Inspection records,

     6.   Ground water monitoring, testing, or analytical  data,

     7.   Notices of permit acquisition and waste acceptance to generators,

     8.   Closure anal post-closure estimates.

     All of the information  that is required to be entered into the operating
record must be retained until the facility is closed, except for inspection
records which need be kept for only 3 years from  the date  of inspection.

     Appendix I of Part 264, referenced in §264.73(b)(1),  contains
recordkeeping instructions for a portion of the operating  record.
Specifically, it identifies  how to record the information  required by
§264.73(b)(l).

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     The requirements of §264.74 place stipulations  on  handling  of  all  records
relative to Part 264.  Specifically,  they  require  that  you must  allow
authorized Agency personnel to inspect the  records,  that  you must  retain
records for longer than required by  the regulations  if  you are  involved in
enforcement actions or are requested  to retain  them  by  the Agency,  and  that
you must submit copies of  the records required  by  §264.73(b)(2)  to  the  local
land authority and EPA when you close the  facility.

     Section 264.75 requires that you submit a  biennial  report  of your
activities on a form prescribed by the EPA.  The form is  identified as  EPA
form 8700-13B and copies are available from  the EPA  offices  identified  in
Appendix A of this manual.   The information which must  be supplied  in a
biennial report is identified in §264.75(a)  through  (h).  The EPA established
the biennial reporting requirement on January 28,  1983.   The first  biennial
report is due on March 1,  1984.  Note that  submission of  the first  biennial
report is due on that date even if you have not received  a permit by that
time.  Owners and operators of facilities  who have not  received  permits should
refer to the biennial reporting requirements in Subpart  E, §265.75  of
Part 265.  Additional information on  the biennial  report  can be  found in the
January 28, 1983, Federal Register at page  3977.

     The requirements of §264.76 establish  procedures which must be followed
if hazardous wastes are received without an accompanying  manifest or shipping
paper.  Those requirements indicate  that an "Unmanifested Waste  Report" must
be submitted to the EPA within 15 days of  receiving  the  waste.   The EPA has
identified the same form (EPA form 8700-13B) as used for  the biennial report
as the form to be used for an Unmanifested Waste Report.  The informational
items which must be included on that report  form are identified  in  §264.76(a)
through (g).  Additional information on this type of report can  be  found in
the January 28, 1983, Federal Register at  page  3981.

     The last section of Subpart E in Part  264, §264.77,  identifies additional
reports that must be made to the EPA.  They include  reports of  hazardous waste
releases, fires, explosions,  closures, or  any other  reports  that may be
required in Subparts F and K through N of  Part  264.  Owners and  operators  of
hazardous waste treatment,  storage, or disposal facilities should review those
Subparts to determine if they contain any  reporting  requirements applicable to
their operations.

5.14.3  List of Major Points

     Subpart E of Part 264 does not require the submission of any information
with the Part B permit application.  However, the  following are  questions  that
each applicant should bear in mind during  preparation and submission of the
Part B:

     1.   Are you familiar with and do you understand the requirements  set
          forth in §§264.70 through 264.77?
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2.    Have you compared your existing procedures for manifest handling,
     recordkeeping,  and reporting to the Subpart E requirements and
     corrected or instituted procedures that comply with Subpart E
     requirements when those procedures were lacking?

3.    Are your personnel who are handling manifests or performing
     recordkeeping or reporting familiar with the Subpart E
     requirements?  Have they been trained in the procedures you have
     instituted to comply with Subpart E?

4.    Have you checked Subparts F and K through N of Part 2.64 to make  sure
     that any recordkeeping or reporting necessary in addition to
     Subpart  E is being conducted?

5.    Have you checked Subparts E, F, and K through N of Part 265 to
     insure that past activities have complied with any manifest system,
     recordkeeping,  or reporting requirements contained in those Subpartss?

6.    If your facility is inspected during the permit application review
     process, do you know where the various records are kept so that  they
     can be promptly located for the inspector's review?
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                           6.0   COMPLETENESS  CHECKLIST
     This section contains a checklist of items which must be included in a
RCRA permit application.  The checklist separately covers Part A and B for a
land storage,  treatment, and disposal permit application.

     The checklist is forty-one (41) pages long and addresses more permit
application requirements than are discussed in this manual.  However, items
related to the topics presented in this manual (the general information
requirements of §270.14(b)) can be found on pages 3 through 14 and 21 of the
checklist.

     Use of this checklist is not a regulatory requirement.  However, its use,
or use of any  similar type document, is strongly recommended.  By completing
and submitting this type of document, you will have developed both a summary
and a table of contents for your permit application.  It will also assist the
reviewing agency and enable a more expeditious review of your application.
Its use will assist you in confirming that you are submitting a complete
applicat ion.

     Each required information item is briefly stated.  Regulatory citations
are provided which enable quick location of the full text of the regulation
that contains  each required item (if no citation is indicated next to a
specific item, the last citation indicated above the item contains the
requirement) .

     Space is  provided so that you can indicate whether the item is  included
in your application or did not apply.  Space is also provided so that you can
record the page number or other indication of where the item can be  found in
your application.

     The required items are generally listed in the sequence that they are
presented in §§270.13, 270.14, 270.17, 270.18, 270.20, and 270.21 of the
regulations except where presentation of information from a later section is
specifically requested.  The one exception is that the additional information
requested in §270.14(c) is listed at the end of the checklist beginning on
page 35.
                                    6-1

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Part 270 Part 264
270.10(d)
and 270.13
270.13(g)
270.13(g)
270.13(m)
270.13(c)
270.13(a)
270.13(b)
270.13(b)
270.13(b)
270.13(b)
270.13(h)(l)
270.13d)
270.13(1)
270.13(h)(2)
270.13(e)
270.13(d;
Page L of 41
LPA I.U. No.

Loca t ion
Not in
Subject Requirement Provided Applicable Application Comments
Part A Requirements
Statement that facility is new or existing
- Statement that application is first or revised


SIC Codes
Description of activities requiring permit
Faci lity : Name
Mailing Address
Location
Latitude and Longitude
Scale drawing (existing facility only)
Sufficient detail
~ Topographic Map
Sufficient detail
Other map
Sufficient detail
Photographs (existing facilities only)
Sufficient detail
- Owner : Name
Address
Telephone
Operator: Name


Telephone

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                                                                                                                        Page  2  of  41
                                                                                                                        EPA  1,0, No.
                                                                                                              Location
                                                                                                   Not            in
 Part 270      Part  264      Subject Requirement                                      Provided   Applicable
2?0.13(d)                   -     Ident:ideation of  facility  ownership  status
                                  and status as federal.  State,  private,
                                  public, or other entity
270.13(fJ                    -    Statement that facility  is  or  is  not  on
                                 Indlan lands

270.13(k)                    -    Listing of all pens its and  construction
                                 approvals received/applied  for

270.13(j)                    -    List of 40 CFR 261 wastes and  annual  amount s
                                 to be hand led

270.13(i)                    -    Descriptionof all processes to be  used  to
                                 handle wastes and design capacity of  each
                                 process

                             Part A Certification and  Signatories

270.11(d)                    -    Certification paragraph

270.1l(a)                    -    Appropriate signatory

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                                                                                                                       Pa8c 3 of 41
                                                                                                                       EPA L.D.  No.
                                                                                                              Location
                                                                                                   Not            m
 Part 270      Part 264     Subject Requirement                                      Provided    Applicable    Application          Comments


270.14                      Part B General Information Requ trements

270.14(b)(l)                -    Generaldescriptionof the facility                 	    	  _    	|	    	

270.14(b)(2)  264.13(a)     -    Chemical and physical analysis of hazardous         	    	    	    	
                                 wastes to be hand led

270.14(b)(3)                -    Waste analysis plan                                 	    	    	    	

              264.L3(b)          -    Analysis parameters with rationale	    	_____	
              (l)-(5)
                                      Test methods for analyzing parameters          		    	    	

                                      Procedure for collecting representative	__    	    	
                                      samples

                                      Frequency of analyses                          	    	    	    	

                                      List and description of waste analyses  to		
                                      be generator supplied

              264.13(b)(6)       -    Waste analysis procedures for ignitable,       		    	    	
              and                     reactive, incompatible wastes
              264.17(c)

              264.13(c)               -    Procedures to determine identity  of       	    	   	    	
                                           each waste movement

                                           Procedures £or collecting  rep re sen-       		     	    	
                                           tative samples

270.14(b)(4)                -    Security description for active portion  of          		    	    	
                                 faci1 ity

              264.14(aJ          -    Security procedures waiver justification	   ___		

                                           Unknowing/unauthorized contact with	   		
                                           waste not hannfu 1

                                           Unknowing/unauthorized disturbance of     	    	______	
                                           waste or equipment cannot  cause
                                           violation of Part 264

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                                                                                                                        Page 4 of 41
                                                                                                                        EPA I.D,  No.
                                                                                                               LOGat ion
                                                                                                   Not           in
  Part  270      Part  264     Subject  Requirement                                      Provided   Applicable    Application          Comments
2?0.14(b)(4)   264,14(b)          '-    Be script ion  of  24-*hour survei 1 la nee sys tern

                                       Description  of  artificial or natural
                                       barriers

                                       Description  of  controlled entry/egre ss
                                       procedures

               2b4,iA(c)           -    Description  oi  warning signs

                                            List of  languages on signs

                                            Statement  of  25-toot legibility

                                            De script ion of  sign locafcions and
                                            numbers  of signs

27Q.l&(b)(5)                 -     General  Inspec tion Schedule and Procedures
                                  De script ion

               264.15{b)(l)        -    Written  schedule

               264,15(b)(2)        -    Statement as  to where,  at facility,
               and                      inspect ion schedule  and inspect ion
               265.15(d5                records vill  be kept

               264.15(b)(l)        -    Identification of  ecjuipnient/processes to
                                       be  inspected

               264. i5Cb) (3)        -    Identification of  types ot probletas  eacti
                                       equipment/process  to be checked  for

               264,13(b)(4)        -    Frequency of  inspect ions  by  equipment/
                                       process

               264.15(c)           -    Schedule of  remedial action

270.14(b)(5)   264.l5(a)      -     Specific  Inspection Requirements  for  Surface
and            and                 Impoundments
2?0.1?
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                                                                                                                      Page 5 of 41
                                                                                                                      hPA l.U. No.
                                                                                                             Location
                                                                                                  Not           in
 Part 270      Part 264     Subject Requirement                                     Provided   Applicable   Application


270.14(b)(5)  264.15(aJ               -    Inspections weekly and after storms      	   	   	
and           and                          for
270.17(d)     264.226
                                                Operation of overtopping controls   	   	   	
                                                Sudden drop in impoundment 1iquid
                                                leve 1

                                                Presence of liquid in leak detec-
                                                tion system

                                                Integrity of dikes/containment
                                                devices

                                                Statement from qualified engineer
                                                that structural integrity of
                                                dikes will be certified upon
                                                construction completion

                                                Qualified engineer's certifi-
                                                cation of dike integrity for

                                                     Stress

                                                     Piping/scouring

270.14(b)(5)  264.15(a)     -    Specific Inspect!on Requirements for Waste
and           and                Piles
270.18(e)     264.254
                                      Description  of procedures for

                                           Inspection of liners/covers during
                                           and immediately after installation

                                           Inspect ions weekly and after storms
                                           for

                                                Operation of run-on/run-off
                                                cont rols

                                                Liquids in leak detection system

                                                Proper functioning of wind
                                                dispersal controls

                                                Leachate in and proper operation
                                                of leachate collect ion/removal
                                                system

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                                                                                                                       Page 6 of 41
                                                                                                                       EPA l.D, No.
 Part 270      Part 264     Subject Requirement
                                                                             Location
                                                                  Hot            in
                                                    Provided    Applicable   Application
                                                                                                                                  Comments
270.14(b)(5)  2&4,15(a)
and           and
270.20(c)(5)  264.273(g)
270.14(b)(5)  264.15(a)
and           a ndl
270.21(d)     264.303
27G.14(b)<65  Part 264
              Subpart C


              264,32(a)


              264.34(a)


              264,32(b)


              264.
Specific Inspection Requirements for Land
Treatment Units

-    Description of procedures for units inspec-
     tions weekly and after stores for

          Operation of run-on/run-off cantroIs

          Function of wind dispersal controls

Specific Inspect ion Requirements for Landfills

     Description of procedures for

          Inspection of liners/covers during
          ar\d lassedlately after installation

          Inspect ions weekly and after storms
          for

               Operation of rxm-an/run-off
               controls

               Liquids in leak detection system

               Proper functioning o£ wind
               dispersal controls

               Leachate in and proper operation
               of leachate collection/removal
               system

Preparedness and Prevent ion Documentation

     Waiver(s) request and justification

     Description of internal cotnmxinications/
     alarm system(s)

     Documentation of personnel access to
     internal coaanunicatiorv/alarra system(s)

-    Descript ion of external cooaiunicaC ions/
     a lam system(s)

~-    Docume n t a 11 on of pe r s onne 1 access to
     external communications/alarm system(s)

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                                                                                                                       Page  7  of  41
                                                                                                                       EPA  I.D.  No.
 Part 270
               Part 264     Subject Requirement
                                                                                    Provided
                                                                 Not
                                                              Applicable
 Locat ion
    in
Application
                                                                                                                                  Comments
270.14(b)(6)  264.32(c)
              264.32(d)
              264.33
              264.35

              264.37 (alsc
              264.52U))
              264.37(a)(2)
270.14(b)(7)  Part 264
              Subpart D

              264.51 and
              264.52U)

              264.52(d)
—    Description of fire control/
     extinguishing, spill control, and
     decontamination equipment

-    Documentat ion of adequate water volurae and
     pressure for above equipment

-    Documentation of equipment testing/
     maintenance schedule and procedures

-    Document at ion of adequate isle space

     Documentation and descriptions of
     arrangements or attempts at  arrangements
     with;

     -    Police department(s)

     -    Fire department(s)

          Hospitals

     -    Local emergency response teams

          State emergency response teams

     -    Emergency response contractors

          Equipment suppl i.ers

-    Documentation of agreements  designating
     primary emergency authority

Contingency Plan Documentat ion


     Criteria for implement at ion  of
     contingency plan

     Emergency Coord mators Identification

          Names

          Addresses

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                                                                                                                       Page  8 of  41
                                                                                                                       EPA  l.D, No.
                                                                                                             Lo cat to n
                                                                                                  Not            in
 Part 270      Part 264     Subject Requirement                                     Provided   Applicable   Application           Comments
2?O.Hib)(7)                          -    Home/Work Phones

              264.55                  ~    Documentation of  Qualifications

                                           Documentat ion of  Authority

                                           Description of notification
                                           procedure

              264,52(e)          -    Emergency equipment list

                                           Documentation of  equipment location

                                           Physical descript ion of equipment

                                           Statement of  equipment capabilities

              264.52(f)          -    Evacuation Plan

                                      -    Criteria for  implementat ion

                                      -    Description of signal(s) to implement

                                      —    Description of prioiary and alternate
                                           routes

              264,53             -    ContingencyPlan Copy  Location

                                           Description of location of facility * s
                                           copy of  plan

                                           Nuraber of duplicate copies distributed
                                           and  their location

              264.54             -    Contingency Plan Amendment

                                           Identification of person responsible
                                           and  authori zied to change /amend plan

                                      -    Description of procedure to change/
                                           amend  facility copy of plan

                                           Description of procedure to insure
                                           update of all  copies of plan

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                                                                                                                      Page  9 of 41
                                                                                                                      EPA  l.D. No.
 Part 270
               Part 264
                            Subject Requirement
                                                                             Location
                                                                 Not            in
                                                   Provided   Applicable   Application
27G.14(b)(7)  264.56
270.l4(b)(7)  264.227
and
270.17(f)
     Detailed Ernergency Procedures

          Procedure for facility personnel
          notification

          Procedure for state/local agency
          notification

          procedure for identification of
          character source, amount, and
          areal extent of released  materials

          Procedure for assessment  of
          environment/human hea 1th  hazards

          Identification of On-Scene Coord mator
          for geographic area

          Description of specific responses and
          control procedures for

               Fire

               Explosion

               Spill

          Description of process shutdown and
          monitoring procedures

          Description of cleanup procedures and
          associated material treating, storing,
          disposa1 procedures

          Descript ion of emergency  equipment
          cleaning and refitting procedures

          Description of procedures to insure
          incompatible waste segregation during
          c leanup

Specific Contingency Plan Requirements for
Surface Impoundments

     Procedure for stopping waste addition to
     impoundment

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                                                                                                                         Page  10  of  
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                                                                                                                       Page  11  of  i*L
                                                                                                                       EPA I.D.  No.
 Part 270
               Part 264     Subject Requirement
                                                                                    Provided
                                                                  Not
                                                               Applicable
                                                                                                              Location
Application
                                                                                                                                  Comments
270.14(b)(9)   264.17(b)
and 270.17(h)
and' 270.17(i)
               264.229
              264.230
270.14(b)(9)  264.17(b)
and 270.l8(g)
and 270.l8(h)
              264.256
              264.257
270.14(b)(9)  264.17(b)
and 270.20(g)
and 270.20(h)
              264.281
     Documentation that procedures are adequate
     to prevent accidental ignitions or react ions

     Description of number, location, and type
     of warning/prohibit ion signs

     Documentation that procedures are adequate
     to prevent accidental ignitions or reactions

Specific Ignitable/Reactive Waste Requirements
for Surface Impoundments

     Procedure s that render waste nonreactive
     or nonignitable

     Procedures for preventing  reactions

     Procedures for protecting  wastes

     "Emergency use only" documentat ion

     Incompatible waste segregation or
     protect ion procedure s

Specific Ignitable/Reactive Waste Requirements
for Waste Piles

     Procedure s that render waste nonre active
     or nonignitable

     Procedures for preventing  reactions

     Procedures for protecting  wastes

     Incompatible waste segregation or protection
     procedures

Specific Ignitable/Reactive Waste Requirements
for Land Treatment Facilities

     Document at ion that application to soil
     renders waste nonreact ive/nonignitable
     and prevents react ions
                                      Procedures for protecting wastes

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                                                                                                                         Page  12 of 41
                                                                                                                         EPA l.D.  No.
                                                                                                               Location
                                                                                                    Not            in
 Part 270      Part 264     Subject Requirement                                       Provided   Applicable   Application           Comments
              264.282             ~     Procedures  which insure that iacompatib Le
                                       wastes  are  not  applied to same tre atment
                                       zone

270.14(b)t9)  2b4.17(b)      -     Specific  Ign itable/He act ive Waste Requirements.
and 270. 2Hf)                     for  Landfills
and 270.2Ug)
              2b4.312             -     Procedures  that re nder wastes nonreac tive
                                       and nonigniidble

                                  ~     Procedures  for  preventing reactions

                                       Procedures  lor  protecting wastes

              2b4.jl3             -     Procedures  for  insuring that incompatible
                                       wastes  vill  not be  disposed of in same
                                       landfill cell

              2 64.jib             -     Procedures  for  identilying contents and
              (c)-(e)                  insuring proper landfilling of incoming
                                       labpack s

27U.14(b)(10)                -     Traffic Documentation*

                                       Ideatit icat ioa  of,

                                           Waste movement routes

                                           Number  o£  movements  by type vehicle

                                           Quantity of waste moved per movement
                                           per vehicle

                                           Traffic control sign        personnel

                                           Route  surface  composition and load
                                           bearing capacity

270.14(b)(ll)                -     FacilityLocation Document at ion

270.14(b)(11)                     -     Political jurisdiction identified (new
(i) and (11)                           facilitiesonly)

                                       Comparison  to Appendix VI of Part 264
*There are no standards in Part 264 for traffic movement t  The  inf ormat ion that must be submitted with  the  Part  B  permit  application, as
 required by §2/0.14C b) (10), will be used by the Agency  to evaluate  safety at the facility.

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                                                                                                                      Page  13 of 41
                                                                                                                      LPA JL.i).  No.
 Part 270
               Part 264
                            Subject  Requirement
                                                                                    Provided
                                                                       Location
                                                            Not           in
                                                         Applicable   Application
                                                                                                                                 Comment s
              264.18(a)
270.l4(b)Ul) 264.18(b)
(in)-(iv)
Demonstration that faults with
displacement in Holocene time are more
than 3000 feet from facility

Demonstration that no faults pass within 200
feet of sites where T/S/D to be conducted

Documentation of facility location
relative to L00~year flood plain level
or wave action flooding

Document at ion that facility can withstand
the 100-year flood without washout of
hazardous waste by:

Analysis of hydrodynamic/hydrostatic
forces resulting at site from 100-year
flood, and

Presentation of operating units and flood
protection devices design and how they
will prevent washout, or

Plan for removal of waste before washout
includ ing,

-    Timing of removal relative to flood
     leveIs
                                           Estimated  time to remove  all waste

                                           Location to which waste will be moved
                                           and  proof  of compliance with Parts 122
                                           through  124 and 264 through 267 of
                                           this Chapter

                                           Detailed description of personnel,
                                           equipment,  and procedures for waste
                                           reraova1  sufficient to insure
                                           availability in time for  use

                                           Analysis of potential for discharge
                                           during waste movement

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                                                                                                                        Page 14 of 4
                                                                                                                        EPA I.D. No.
 Part 270
               Part 264
                            Subjec t Requirement
                                                                                     Provided
                                                                                                    Not
                                                                                                Applicable
                                                                                                               Location
                                                                                                              Ap plication
                                                                                                  Comroe nts
270. l<*(b
(H)U)
270.14lb)U2)
270.14(b)(13) 264.112
               264.11J
          A plan documenting how and on what  time
          schedule the facility will comply vith
          §264.18(b)  if riojt_ in compliance
          (existing facilities only).

Personne1 Training Program Document at ion

     Outlineof i n t rod 11 c t o ry and c a nt I ~m i. rig
     personne1 training programs*

     Identification and qualifications of  program
     instructor

     Brief description of how training program
     meets actual job tasks*

     Description ot procedures to insure  all
     appropriate personne1 receive appropriate
     training  and receive annual training
     review

     Description of records to be kept, their
     location, and procedures to insure they
     are retained for proper length of time

Closure Plan Doc ument at ion
     Description of partial and tinal closure
     procedures

     Description of maximum unclosed port ion
     during facility life

     Estimate  of maximum waste inventory  in
     storage/treatment during facility life

     Equipment decontamination procedure

     Estimated year of closure

     Description of closure schedule including

     ~    Tota 1 time to close
*This documentat ion on  Personne1 Training muj^ be  included  in  the  application.   The remaining three items may  be  mcluded  at  the applicant's
 discre tion.

-------
                                                                                                                       Pag.>  n  of  H!
                                                                                                                       EPA l.D,  No,
                                                                                                              Location
                                                                                                  Not            in
 Part 270      Part 264     Subject Requirement                                     Provided   Applicable   Application
270.14
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                                                                                                                          Page  16 of 41
                                                                                                                          EPA l.D.  No,
                                                                                                                Location
                                                                                                     Not           in
 Pa re  270       Part 264     Subject Requirement                                      Provided    Applicable   &pplicatian


270.l4(b)      264.112       -    Specific Closure Plan Requirements for Waste			
(13) and                          Piles
270.1SU)
               264.258(a)         -    Procedure for  removal  and/or decontamination  	____	   -
                                       of all wastes  and materials/equipment
                                       associated with the waste pile

               264.258(b)         -    Procedure for  closing  in conform ante with          ______	    _ _	_____   —_ „_„„„„„„,		,„
                                       landfill closing requirements

27Q.14
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                                                                                                                      Page 17 of ^1
                                                                                                                      EPA I.D. No.
                                                                                                             Location
                                                                                                  Not           in
 Part 270      Part 264     Subject  Requirement                                      Provided   Applicable   Application          Comments


                                           Function with minimum maintenance
                                           Promote drainage and minimize
                                           erosion/abrasion

                                           Settle/subside without losing
                                           integrity

                                           Be  less permeable than bottom liners
                                           or  subsoils

270.14(b)     264.117 and   -    Post-Closure  Plan Documentation
(13)          264.118
                                      Descript ion of ground water monitoring
                                      activities  and frequencies

                                      Description of maintenance activities and
                                      frequencies for;

                                           Final  containment structures

                                      -    Fac111ty monitoring equipment

                                      Location(s) and number of copies of post-
                                      closur£  plan

                                      Identification and location (address and
                                      phone number) of person responsible for
                                      storage  and updating of facility copy of
                                      post-closure plan prior to closure

                                      Identification and location (address and
                                      phone number) of person responsible for
                                      storage  and updating facility copy of
                                      post-closure plan during post-closure
                                      period

                                      Procedure for updating all other copies of
                                      post-closure plan

270.14(b)     264.118 and   -    Specific Post-Closure Plan Requirements for
(13) and      264.228(b)          Surface Impoundments
270,17(g)
                                 -    Procedures  for maintenance and repair of
                                      final cover

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                                                                                                                         Page 18 of 41
                                                                                                                         EPA I.D, No.
                                                                                                                Location
                                                                                                    Hot            in
 Part 270       Part  264     Subject  Requirement                                      Provided   Applicable    Application


                                       Procedures for maintenance  and  monitoring		
                                       of leak detection system

                                  ~    Procedures for maintenance  and  monitoring     _____	   --—..—,	
                                       of ground water monitoring  system

                                       Procedures for camp Iiance with  Subpart  F			

                                       Procedures fof preventing run-on/run-off		         _
                                       final cover damage

270.14(b)     264.118  and    -    Specific Post-Closure Plan Requirements  for	   _             _
(13) and      264.258(b)          Waste Piles
Z70.18(i)
                                       Procedure s for post-closure  care  chat meet	      		,...,__    ..._.,.,.„,.,.
                                       the requirements for landfills

27Q.14(b)     264,118  and    -    Specific Post-Closure Plan Requirements  for	   _____^____    »_____^____-
(13) and      264.2SO(e)          Land  Treatment Facilities
2?0.20(f)
                                       Procedures to enhance degradation! of wastes		        ,--........,...._
                                       in treatment gone

                                       Procedure for maintaining vegetative cover    _	   _____________    ___™____	

                                  -    Procedure fo^ T^amtainin^ run—on controls                 	  	       ^	^^ ^

                                  -*•    Procedure for maintaining run-off controls     	        	

                                       Procedures for wind dispersal control	    	        „„__„.,

                                       Procedure s to insure compliance with food-     	                   	^
                                       chain crop prohibitions

                                       Procedures for unsaturated  eoae monitoring		    	  __ ______

270.1^Vbi     264.118  and    -    Specific Post-Closure Plan Requirements  for         		          ___
(13) and      264.310(b)          Landfills
270.2t(e)
                                       Procedures for maintenance  and  re pa ir of       	          	    _________™____.
                                       final cover

                                       Monitoring $nd maintenance  procedures for        		
                                       leak detection system

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                                                                                                                       Page  i.y uf 41
                                                                                                                       EPA  I.D.  No.
 Part 270
               Part 264     Subject Requirement
                                                                                    Not
                                                                      Provided   Applicable
                                                                             Location
                                                                                in
                                                                            AppIication
                                                                                                                                  Comments
27Q.14(b)
(14)
270.l4tb)
(15)
              264. 310(c)
              264.120
264.119



264.142

264,143 and
264.146

264,151
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                                                                                                                       Page 20 of 41
                                                                                                                       EPA I.D. No.
  Part  270
270.14(b)
(16)
2?G.14(t>)
(17)
                Pare  264      Subject  Requirement
                                                                                     Provided
                                                                                     Not
                                                                                  Applixa
                                                                             location
                                                                                in
                                                                            Application
                                                                                                                                  Co mine ti t s
264.144

264.145 and
264.146

264.151U)

264.15Hb>

264.15L(c)

264.151
-------
                                                                                                                       EPA  I.D.  No.
                                                                                                              Locat ion
                                                                                                  Not            in
 Part 270      Part 264     Subject  Requirement                                     Provided   Applicable   Application
270.14(b)     264.149       -    Documentat ion of a State Required Financial
(18)                             Mechanism for Closure,  Post-Closure, or
                                 Liability including

                                      EPA I.D. number

                                      Facility name

                                      Facility address

                                      Amounts of liability coverage or funds
                                      a s s u re d

              264.150       -    Documentation of State Assumed Responsibility
                                 for Closure  Post-Closure or Liability including

                                      Letter  from State describing State's
                                      re sponsibilities

                                      Facility EPA I.D.  number

                                      Facility name

                                      Facility address

                                      Amounts of liability coverage or funds
                                      as sured

270.14(b)                   -    Topographic  map showing a distance of 1000
(19)                             feetaroundfacilityatascaleofnotmore
                                 than 1 inch  equals 200 feet that clearly shows

                                      Contours

                                      Proper  contour intervals

                                      Map scale and date

                                      100-year flood plain area

                                 -    Surface waters and intermittent streams

                                      Surround ing land uses

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                                                                                                                        Page  22  of  41
                                                                                                                        EPA  l.D.  No,
                                                                                                              Local ion
                                                                                                   Not            in
 Part 2?0       Part  2 64      Subject  Requ irement                                      Provided   Applicable   Application
270.14(b)                        -    Wind rase
(19)
                                      North orientation

                                      Legal boundaries of  facility  site

                                      Access contra 1

                                      Inject ion and withdrawal  wells  onsite  and
                                      of fsite

                                      Buildings and recreation  areas

                                 -    Runof t control systems

                                      Access and internal  roads

                                 ~    Storm, sanitary, acid process  sewerage
                                      systems

                                      Loading and unloading areas

                                      Fire control  facilities

                                 -    Barriers for drainage or  flood  contra i

                                 -    Location of past or  present operational
                                      units and equipment  cleanup ar«;as

270.17                      Specific Part B Inlonnation Requirements  for  Surface
                            Impoundments

27£>.i?(a)                        -    iistofhaaardouswastesplacedor
                                      to be placed  in impoundment

270.17(b)     264-221            -    Detailed plans and an engineering report
                                      desc ribing

270.1?(b)(i)  264-,22l(a)              -    Liner system construction  (new only)

              26***22l(a)(l)                -    Material of const ruction

                                                Chemical propert ies

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                                                                                                                           L.u.  No.
 Part 270
               Part 264     Subject Requirement
                                                                   Location
                                                        Not            in
                                          Provided    Applicable    Application
                                                                                                                                  Coinment s
270.17(b)(l)
              264.22l(a)(2)

              264.22l(a)(3)

              264.221(a)(i)
              264.22Kb)
270.17(b)(2)  264.22l(c)
     Physical strength

~    Thickness

     Foundat ion design/integrity

     Area covered

Liner system integrity against  (new
only)

     Internal and external pressure
     gradients

     Contact with waste/leachate

     Climatic conditions

     Installation stresses

     Daily operational stresses

Liner system exemption including

     Nature and quantity of wastes

     Alternative design and operation

     Impoundment location description

          Hydrogeologic setting

          Attenuative capacity  of
          materials between impoundment
          and groundwater and surface
          water

-    Documentat Lon of no migration to
     ground/surface waters at any
     future time

Procedure s/equipment to prevent
overtopping from
                                                Normal operation

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                                                                                                                Loc.i t ion
                                                                                                    No t            i n
                Fart 2bA     Subject Requ iroment                                      Provided   Applicaole    App £icdtion
               2b<*.22Hc)                    -    Abnormal operation

                                            ™"    Ove rf 111 ing

                                                 Wind/wave act ion

                                                 RainlJll

                                                 Run-on

                                            ~    E q ii i pine n L m.i 11" u nc 11 on s

                                            —    HxtTnais er ror

2?0,l?ib)(3)   264.221(d)               -    Scroctural integrity ot dikes

270,L7tc)      264.222(^J          -    Documentation for Part  26A, Subpart  F
                                       exempt ion inc luct ing ,

                                       -    Impouridi^ent and 1 iner loeat ion  above
                                            seasonal highwater table

                                            Two liners meeting §264.221(a)
                                            requ iremeot s

                                            Leak detection system between  liners

270.18                       -     SpecificPartB Information  R«c|u iremeats  for
                                  Waste Pxles

270.IB(a)                         -    Lxstofhazardouswastespiacedortobe
                                       placed in each waste pile

2?0.lS(b)      2t>4.250tc)          -    Documentation of  genera 1 exempt ion from
                                       §264.251  and P^rt  264,   Sabpart F, including,

                                            Waste pile protection from precipitation

                                            Procedures for insuring liquids  are
                                            not  placed in pile

                                            Description  of run-on controls

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                                                                                                                      Page 25 of 41
                                                                                                                      L PA  I. D. N'u.
                                                                                                             Location
                                                                                                  Not           in
 Part 270      Part 264     SubjectRequirement                                      Provided   Applicable   Application          Comments


                                           Description of wind dispersal controls	    	
                                           other than wetting
                                           Decomposition/reactions do not cause
                                           leachate general ion

270.18(c)     2 64.251(a)         -    Detailed plans and an engineering report
                                      desc ribing,

270.18(cJ(l)  264.251(a)(l)            -    Liner  system construction (new only)

              264.221(aJ                   -    Material of construct ion

                                                Chemical propertles

                                                Physical strength

                                                Thickness

                                                Foundat ion design/integrity

                                                Area covered

                                           Liner  system integrity against (new
                                           only)

                                                Internal and external pressure
                                                gradients

                                                Contact with waste/leachate

                                                Cliraatic conditions

                                                Installation stresses

                                                Daily operational stresses

              264.25l(a){2)            -    Leachate collection and remova I sy steir
                                           to maintain. Less than one foot of
                                           leachate on liner including,

                                                Materials of construction

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                                                                                                                       Page 26 of 41
                                                                                                                       EPA I.D. No,
                                                                                                              Location
                                                                                                   Not           in
 Part  270       Part  264      Subject  Requirement                                      Provided   Applicable   Application
270.l8(c)(l)                               -    Chemical  resistance  to  waste/
                                                leaehate

                                                Strength  sufficient  to  prevent
                                                collapse

                                                ProVJLsions to  prevcat c.lo&ging

               264.25l(b)              "    Liner  system/leactiate  system exemption
                                           including,

                                                Nature and quantity  &t  wastes

                                                Alternative design and  operation

                                                Pile location  description

                                                •*•*    Hydrogeologic set ting

                                                     Attenuative  capaci ty of
                                                     materials between  pile,
                                                     ground and surfac e  waters

                                                Documentation  of  no migration to
                                                ground/surface waters at any
                                                future time

2?0.1S{c)(2)  264.251(c)              -    System for control  of  run-on  from
                                           peak discharge of a 25~~year  storm

270.1S(c)(3)  264.251(d)              -    System for control  of  run-off water
                                           volume  ot a 24-hour, 25-year  storm

27G.ia(c)<4)  264-251(e)              -    Procedures to manage collection and
                                           holding, facilities  associated with
                                           run~"ou and run—of f  contro 1 systems

270.18(c)(5)  264.251(f)              -    Wind dispersal control procedures

270.ia(d)     264.252U)         -    Documentation for Part 264, Subpart F
                                      exempt ion including,

                                      -    Pile and liners above  seasonal high
                                           water table

-------
                                                                                                              Lo cation
                                                                                                   Mot            in
  Part  270       Part  264     Subject Requirement                                      provided    Applicable    Application
2?0,18(d)                             -    Two liners meet ing  requirements of
                                           i264.251(a)(l)

                                           Leak detection system between  liners

                                           Leachate system meeting  §2t>4,251(a)(2)
                                           requ iretnents

              264,253(b)         -    Documentation for Part 264, Subpart F
                                      exemption including,

                                           Pi te and liners above seasonal high
                                           water table

                                           Liner meets |2fe£*.25i(a)(l)  requirements

                                      -    Soi1 characteristics/depths

                                           Leachate system meets §2fe4.2Sd(a}(2)
                                           requirements

                                      -    Schedule/procedures  for  liner
                                           inspection by waste  removal

                                           Sufficient liner strength/thickness
                                           to ailow periodic rewovaI/replacement
                                           of wastes

2?O.I8(f)                        ~    Descriptionof treatment carried out in
                                      or on the pile including,

                                           Details of treatment process

                                           Equipment used

                                           Nature and quality of residuals

270.20                      -    Specific PartB Inforraation Requirements for
                                 Land Treatment Facilities

2 70.20(a)                        -    Descript ion of treatment demonstration
                                      plans by

              264,272(b)              -    Field test

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                                                                                                                        Page  28 of 4L
                                                                                                                        EPA 1.0.  No-
                                                                                                               Loeat ion
                                                                                                   Not            in
 Part 270      Part 264     Subject Requirement                                      Provided   Applicable   Application           Comments
2?Q.20(a)                             -    Laboratoryanalysis

                                           Avaliable data

                                           Operating data  (existing  units  only)

                                      Submittnl for laboratory  analyses  or 1 le Id
                                      test d onions t rat ion permit  i rvc lud i ng ,

              264»272(c)              -    Doc omen tat ion oi accurate  $ irrm laf ion

                                           -    Wastes and hazardous  constitucnts
                                                descriptions  (Part  261,  Appendix
                                                VHI)

                                                C1 ima t o 1 og i c  I n f o rrn a 11 o n

                                                Topographical data

                                                Operating  practices

                                           ™    Typc of test  to  be  conducted

                                                Test materials  and  methods

                                           ™"    fcxp^c ted complet ion  t ime

                                      -    Statement on appropriateness  oi
                                           deinonstrat ion

                                      ~    St atenient on human he a 1 th  and environ"
                                           tne n t  protection considering,

                                                Character!sties  of wastes  to  b^
                                                tested

                                                Operating  and monitoring during
                                                tests

                                                Duration of test

                                                Volume ot waste  used  in  test

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                                                                                                                       Page 29 of 41
                                                                                                                       EPA I.D. No.
 Part 270
               Part 264
                            Subject Requ irement
                                                                                                              Location
                                                                                                   Not
                                               Provided    Applicable   Application
270.20(b)
              264.271(a)
270.20(bK2)  264.273(a)
(i)
270.20(b)(3)  264.278
              (aJ-(f)
          Potential tor hazardous waste
          migration to ground/surface waters
          (field tests only)

De script ion of land treatment  program

     Wastes to be land treated

     Design measures to maximize treatment
     including,

          Rate and method of waste
          applLcation

          Soil pH control measures

          Microbial/chemical reaction
          enhancements

     ~~    Treatment zone moisture control
          measures

     Qnsaturated zone monitoring proce-
     dures including,

          List ot and rational  for  selecting
          compounds to be monit ored

          Monitoring equipment, procedures,
          frequency

          Procedures for selecting  sampling
          locations

     ~    Sample collection procedures

          Sample preservation/shipment
          procedure s

          Sample chain of custody control

     -    Sample analysis procedures

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                                                                                                                       Page 30 of 41
                                                                                                                       EPA I,D» No.
 Part 270
Part 264     Subject Requirement
                                                                                     Provided    Applieaole   Application
27Q.20(b)U)
270.20     264.273
                            -     More  cha«i 3 feet above the
                                 seasonal  high water taDle

                       Descript ion of  land treatment unit
                       design

                       -    Procedures/equipment  to prevent
                            run-on from  peak discharge of 25-year
                            storm
                                           Procedures/equipment to collect arid
                                           cont ro1 the run~o ff water vo iume  from
                                           a 24-hour, 25~year storm

                                           Procedure s/equipment to minimize
                                           run-off Lrom treatment Rone during
                                           active lite
270.20(d)     264.276(a)
                       ~    Run-on  sr.d  r^n-ofi  Loiieccion and
                           controI  systems  management  plan

                           Procedures/equipment  for  wind disper-
                           sal control

                       Documentation of  request  for growth of
                       food-chain crops  on  treatment  zone not
                       receiving cadmium in  wastes

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                                                                                                                      Pa^r- Jl oi 41
                                                                                                                      EPA l.fJ. No.
                                                                                                             Location
                                                                                                  Not           in
 Part 270      Part 264     Subject  Requj,remen£                                      Provided   Applicable   Application          Comments
270.20(d)     264.2?6(a)          -     Statement  that  demonstration of  no risk to
                                      human  health  will  be  conducted  by,
                                           Field  tests

                                      ~     Greenhouse  studies

                                      """     Ava 11 a b 1 e data

                                           Operating data (existing  only)

                                      Demonstration program description,
                                      me luding;

                                           Soil pH

                                      ~     Cation exchange  capacxty  of  soil

                                           Specific wastes  to  be  applied

                                           Waste  application rates

                                           Waste  application methods

                                      ~     Identification of demonsCration  crops

                                               Planting  arid growth  procedures

                                               Characteristics of crop

                                           -    Sample  selection  criteria

                                           -    Sample  collection procedure

                                           **    Sample  size

                                           -    Analyses  methods

                                               Statistical  data  evaluation
                                               procedure s

                                     ~     Identification of comparison crops

                                          -    Characteristics of crop

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                                                                                                                       Page  32 of 4i
                                                                                                                       EPA l.D.  No.
                                                                                                              Location
                                                                                                   Not            La
 Part 270       Part  264      " hject Requirement                                      Provided    Applicable    Application          Comments
270*2G(d)     264.276(a)                   -    Plant ing and growth procedures

                                           -    Condit ions of growth

                                           -    Sample select!on criteria

                                                Sample collection procedures

                                                Sample size

                                           -    Analyses methods

                                                Statistical data evaluation
                                                procedures

                                           Request for a permit to conduct demon™
                                           strat ion program

2?0.20(e)     264.2?6(b)         -    Documentation of request for growth of
                                      food-chain crops on treatment zone if
                                      wastes contain cadmium

                                           Cadmium concentration in waste

                                           Soil pH

                                           Annua 1 appl ication of cadtn>ntn in
                                           kilograms per hectane

                                           Soil cation exchange capac i ty

                                           Identification of animal feeds to be
                                           grown

                                           Plan Co prevent animal feed ingest ion
                                           by huraatis

                                           Documentation of notice on deed

270*21                      ~    SpecifiePartB Information Requirements for
                                 Landfills

27Q»21(a)                        -    List of hazardous  wastes to be placed in
                                      each land fill cell

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                                                                                                                      Page 33 ,ii ^.
                                                                                                                      EPA I.D. No.
 Part 270
               Part 264     Subject  Requirement
270.2Ub)(l)
              264,JUl(a)


              264.3Q1UM1)
                                                            Not
                                              Provided   Applicable
 Location
    in
Appiication
Detai Led plans and an engineering report
describing

-    Liner systen construction (new only)

          Material of construct ion

          Chemical properties

          Physical strength

          Thickness

     —    Found at ion des ign/i ntegnty

          Area covered

     Liner system integrity against (new
     on ly)

     -    Internal and externa 1 pressure
          gradients

          Contact with waste/leachate

          Climatic condit ions

          Installation stresses

     -    Daily operational stresses

     Leachate collection and removal system
     to maintain less than one toot of
     leachate on liner including,

          Materials of construction

          Chemical resistance to waste/
          lt;achate

     ~    Sufficient strength to prevent
          collapse

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                                                                                                                       Page 34 of 41
                                                                                                                       EPA I.D. No.
 Pare 270
               Part 264
                            Subject Requirement
                                                                        JUoca t ton
                                                             Not            in
                                               Provided    Applicable   Application
270.21(b)U)
270.21(b)(2)  274.30l(c)


2?0.2l(b)(3)  2?4.3QHd)


27G.2l(b)(4)  2?4.30L(e)



2?0.2l(b)(5)  274.301(1)

270.2l(c)     264.302U)
     -    Provisions to prevent c logging

-    Liner systeWleachate system exempt ion
     including ,

          Nature and quantity of wastes

     -    Alter native design and operation

     -    Land fill location description

               Hydrogeologic setting

               At tenuat ive capac i ty of
               materials between landf i 1 1
               and ground and surface waters

          Documentation o£ no migration to
          ground /surf ace waters at any
          future time

~    System for control of run -on f rorn
     peak discharge of a 2 5-year storm

     System for control of run-off water
     vo lume froEis a 24-hour, 2 5~year st onn

     Procedures to manage collection and
     holding Caci lities associated with
     tun~"on arid run—of f coat rol systems

-    Wxnd dispersal control procedures

Documentation for Part 264, Subpart F
exempt ion inc 1 ud ing ,

     Land f 1 1 1 and liners above seasonal
     high water table
                                           Two 1 iners tnee t ing requ ireraent s of

-------
                                                                                                              Location
                                                                                                   No t            in
 Part  270       Part 264     Subject Requirement                                      Provided    Applicable   Applicati
                                                                                                                      on
                                      ™*    Leak, detection system between  1 xnefs

                                           Leachate system meeting  1264.3Gl(a)(2)
                                           requirements

270.21th)      2b4.314            -    Document at ion of procedure s/equipment  for
                                      landfilling  liquid wastes

27Q,21(i)      264.315            -    Documentation of procedures/equipment  for
                                      landfi11ing containers

270,14(c)      Fart 264      Part B Protection of Ground Water  Information Require-
               Subpart F     ments for Surface Impoundments» Waste Pi les,  Land
                            Treatment Units,  and LandfilIs

2?0.\4(c)(l)                -    Interim status period ground-water monitoring
                                 data summary

27G.14(c)(2)                -    Ldentification of uppermost and hydraulically
                                 interconnected aquifers under facility including,

                                 -    Wa ter f1ow rate and direct ion

                                      Bases for identification

2?G.l4(c)(3)                -    Topographic map
and
2?0.14(b)(19}                    -    Delineation of property boundary

               264.95(b)          -    Delineationofwaste management area

               264.95(a)          **    Delineat ion of proposed point of
                                      compliance

                                      Ground-water monitoring wel1  locations

                                      Location of aquifers

270.!4
-------
                                                                                                                       rage 36 of 41
                                                                                                                       EPA l.D. No.
 Part  2?0
                Part  26&      Subject Requirement
270.14(0(5)  264.9?
               264.9?(a)
              264.9?(c)
              2d4.9?(e)
              264.97(f)
270.14(0(6)  264.91UX4)
              and 264.98
     Appendix VIII constitutenCs concentrations

     -    Concetitrations throughout  plume

          Maximum concentrations  in  plume

Detailed plans and an engineering report of
Ground Water Monitoring Program

-    Descriptor! of veils

     -    Number of we Us

          Locat tons

          Depths

          Assurance of unaffected background
          water measurewent

          Assurance of compllariee point ground
          water measurement

     -    Casing description

     Description of sampling/analysis procedures

          Sample collection methods

     -    Sample preservation/shipment

          Analytical procedures

          Chain of custody control

     Documentation of proper/adequate analytical
     procedures

     Procedure for determination of ground
     water elevation with each sample

Description of Detection Monitoring Program
including,
                                                                                                              LOG at i
                                                                                                   Not
                                                                                     Provided   Applicable   Applicat ion
                                                                                                                                  Comments

-------
                                                                                                                      Page 37 of 4
                                                                                                                      hPA 1.0. No.
 Part 270
               Part 264     Subject  Requirement
                                                                        Locat ion
                                                            Not           in
                                              Provided   Applicable    Application
                                                                                                                                 Comments
270.14(c)(6)  264.93 and
d)           264.98(a)
270.14(c)(6)  264.98(a)(4)
(ill)         and
              264.98(c)(l)

              264.98(c)(3)
              264.97(g)(l)


              264.97(g)(3)


              264.97(g)(4)
270.14
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                                                                                                                      Fage 38 of 41
                                                                                                                      EPA. I.D, No*
 Part 270
               Part 264
                            Subject Requirement
                                                                                    Provided
                                                        Not
                                                    AppL icable
 Loeat ion
    in
Application
              264.98(e)
              264,98(f) &
              264.97(dH(e)

              264.98(g)
27Q.14(c)(6)  264.98(h)





              264.98(h)(l)


              2&4.98(h)<2)
     Pos t -closure period

Procedure for annual determination of
uppermost aquifer flow  rate and
direction

Documentation of sample collection
and analysis procedures

Procedure for dete naming a statisti-
cally significant increase for any
monitored parameter or constituent by

     Comparing compl lance point data
     to background value data using
     the procedures in  §264.97(hMD
     or (2), and

-    Providing an estimate of the time
     period after sampling completion
     necessary to obtain results

Procedure to be implemented if a
statistically significant increase in
any constituent or parameter i s
identified at any compl iance point
monitoring wel 1, including

     Written notification to Regional
     Adminis trator

-    Sarapl e collect ion and analysis
     methods for all Appendix VIII
     constituents at all monitoring
              264.98(h)(3)
                                               Method  for  establishing  Appendix
                                               VIII  constituent  background values

                                               Preparation of  an application for
                                               pe rai t  mod ificaticm  to establish
                                               compliance  monitoring

-------
                                                                                                                            Page  39 of 41
                                                                                                                            EPA  l.D.  No.
                                                                                                                  Location
                                                                                                      Not            i-n
 Part 2?0       Part  264     Subject Requirement                                        Provided   Applicable   Appi teat ion           Comments


2?0.14(c)(?)   264.9l(a)(l)  -    Description  of  Compliance Monitoring Program,       			          _„„„	
               and  264.99         inclading

                                       List  of  wastes previously  handled at             _	   ,_..,.,.,.,.,.. „..^.....^....J~_     _....-,	, „........_ _	_	„.
                                       facility

                                  -    Characterization of contaminated ground-	   	     _.%^_____mm____^^
                                       water

                                       —     Hazardous const ituents  ident if led	    _   ___™__M	   	„__	       „	_

                                       -     Hazardous constituents  concentrations     	   		;______^_             miiii_	^	^^

               264.99(b)          -    Descriptionof compl lance  monitor i ng           	   __mrawm-____.   _    		,,,,,^_,,^_.,.,.,.^,.,.,.,.
                                       system  at  the compliance point

                                       List  of  hazardous constituents to be                 _     	____.	     ._________.,-	
                                       compliance monitored

               264.96             -    Proposed compliance period                      ...„....,„.	.        	„,.,.,.,_,„..	     _.	

               264.99(d)          -    Procedure  for col lee ting quarterly samples		   	     	__„____,
                                       at compliance point during  compliance
                                       period

               264.99(c) (3)       -    Procedures for establishing  background         	   _	  .        _
                                       concentrat ion values for constituents that
                                       are based  on

                                       ~     Use of  an appropriate  ground-vater          	   	  .,,.,.,„,.,„„,,_	        _^	
                                             momtoring system, and

               264.9?(g)               -     Data  that is available  prior to permit     _          _	 .        _         	
                                             issuance

                                       ""     Data  that accounts for  measuretnent        	   		     	
                                             errors  in sampling and  ana lye is

                                             Data  that accounts for  seasonal ground-		   		   	
                                             water 
-------
                                                                                                                       Page  40  of  41
                                                                                                                       EPA I.D.  No,
Part 270      Pare 264     Subject Requirement
                                                                                    Provided
                                                             Not
                                                          Applicable
                                                                                                              Locat io
                                                                                                            Application
                                                                                                                                  Comments
27G.14(c)(?)  264.92 and

Proposed concentration  limits  for  const i-
tuents with justification based  on

     S2&4.94UX1) and  §2&4.97
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                                                                                                                      Page 41 of 41
                                                                                                                      EPA I.D. No.
                                                                                                             Location
                                                                                                  Not
 Part 270
               Part 264
                            Subject Requirement
                                                                      Provided   Applicable   Application
270.14CcH7)
(v)
270.14(c)(8)
270.14(c)(8)
(i)
270.14(c)(8)
(ii)

270.14(c)(8>
dii)
270.14(c)(8)
(iv)
264.99(i.)(2)
264.91(a)(2)
and 264.100
264,100(a)(l)



264.100(a)(2)


264.100(b)



264,100(c)


264.100{d)
              264.91UM3)
              and
              264.lOOCe)
              264,lOO(g)
2?O.U(d>

270.11(a)
               ~*    Details of program to comply
                    with g round—watef protect ion
                    standard

                    Details of ground-water
                    monitoring Co demonstrate
                    effeetiveness of program

     Description of Corrective Action Program,
     including

          Characterization of contaminated
          ground—water

               Identified hazardous constituents

               Concentrations of hazardous
               constituents

          Concentration limit for each hazardous
          constituent

          Detaxled plan and an engineering report
          describing the corrective actions to be
          taken at the compllance point

     —    Time period necessary to implement correc—
          t ive action program

     -    Description of ground—water monitoring
          program that will be sufficient to assess
          the adequacy of cor re ct ive ac tion

          Description of the corrective action to
          be taken for constituents in ground-water
          between compliance point and downgradient
          facility boundary

     -    Procedure and content for semi-annually
          submitting written reports to the Regional
          Administrator on program effectiveness

Part B Certification and Signatories

     Certification paragraph

-    Appropriate signatory

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                              APPENDIX A

                       FEDERAL AND STATE AGENCY
                   ADDRESSES AND  TELEPHONE NUMBERS
A.I  RCRA HOTLINE

A.2  GOVERNMENT PRINTING OFFICE (GPO)

A.3  EPA REGIONAL OFFICES

A.4  STATE AGENCIES

A. 5  GPO BOOKSTORE LOCATIONS
                                   A-l

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A.I  RCRA HOTLINE:   (800) 424-9346

            Hours:   Monday - Friday
                    8:00 a.m. - 4:30 p.m.  EST or EDT

A.2  MAILING ADDRESS:   Superintendant of Documents
                       Governmental Printing Office
                       Washington, D.C.   20402

           Telephone:   (202) 783-3238

     Ordering Procedure:

     •    Payment in advance is required for shipment of regulations.   Do not
          send currency (bills and coins)  or postage stamps.

     •    Make checks or money orders payable to the Superintendant of
          Documents.

     •    If first-class mailing is desired, contact GPO at the above
          telephone number - it costs more.

     •    To order any document, obtain a Governmental Printing Office order
          form #1981-0-346-379/1307.  These are available through any  GPO
          bookstore or by contacting the Superintendant"s office.

     •    Type or print:  Office/Home Telephone Number
                          Visa or MasterCard Number (if applicable)
                          Deposit Account Number (if applicable)
                          Date of Order
                          Order Number  (if any)
                          Complete Name and Address
                          Stock Number
                          Quant ity
                          Unit of Issue
                          Title
                          Price
                          Payment Enclosed
                          Shipping Address  (if different from other)

     •    For information on publications, or for placing a Deposit Account or
          Visa or MasterCard order,  call the above  telephone number.

     •    Mail completed  form  to  the above address.
                                        A-2

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A.3  REGIONAL EPA OFFICE BRANCHES WHO ADMINISTER THE RCRA
     Region I:
     Region II:
     Region III:
     Region IV:
     Region V:
     Region VI:
     Region VII:
     Region VIII:
State Waste Programs Branch
Waste Management Division
John F. Kennedy Federal Building
Boston, MA  02203
(617) 223-6883

Solid Waste Branch
Air and Waste Management Division
26 Federal Plaza
New York, NY  10007
(212) 264-0505

Waste Management Branch/RCRA Permit Section
Air and Waste Management Division
Curtis Building, 6th and Walnut Streets
Philadelphia, PA  19106
(215) 597-9118

Residuals Management Branch
Air and Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA  30308
(404) 881-3443

Waste Management Branch
Waste Management Division
Federal Building, 230 South Dearborn
Chicago, IL  60604
(312) 886-7579

Hazardous Materials Branch
Air and Waste Management Division
First International Building, 1201 Elm Street
Dallas, TX  73270
(214) 729-2645

Waste Management Branch
Air and Waste Management Division
324 East llth Street
Kansas City, MO  64106
(816) 374-6531

Waste Management Branch
Air and Waste Management Division
Suite 900, 1860 Lincoln Street
Denver, CO  80203
(303) 837-6238
                                       A-3

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     Region IX:     Programs Branch
                    Toxics and Waste Management Division
                    215 Fremont Street
                    San Francisco,  CA
                    (415) 974-7411/974-8391

     Region X:      RCRA Branch
                    Air and Waste Management Division
                    1200 6th Avenue
                    Seattle, WA  98101
                    (206) 399-2782

A.4  STATE AGENCIES DEALING WITH HAZARDOUS WASTES
     Alab ama
     Alaska
     Arizona
     Arkansas
     California
     Colorado
Environmental Health Administration
Solid and Hazardous Waste Division
328 State Office Building
Montgomery, AL  36130
(205) 834-1303

Department of Environmental Conservation
Environmental Quality Management Section
Solid Waste Management Section
Pouch 0
Juneau, Alaska  99811
(907) 465-2667

Department of Health Services
Division of Environmental Health Services
Bureau of Waste Management
1740 West Adams
Phoenix, AZ  85007
(602) 255-1170

Department of Pollution Control and Ecology
Solid Waste Division
P.O. Box 9583
Little Rock, Arkansas  72219
(916) 562-7444

Solid Waste Management Board
1020 9th Street, Suite 300
Sacramento, CA  95841
(916) 322-3330

Department of Health
Office of Health and Environmental Protection
4210 East llth Avenue
Denver, CO  80220
(303) 320-8333
                                        A-4

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Connecticut
Delaware
District of
Columbia
Florida
Georgia
Hawa i i
Idaho
Department of Environmental Protection
Division of Environmental Quality
Solid Waste Management Unit
State Office Building
165 Capitol Avenue
Harford, CN  06115
(203) 566-5847

Department of Natural Resources and Environmental Control
Division of Environmental Control
Solid Waste/Hazardous Waste Section
Edward Tatnall Building
P.O. Box 1401
Dover, Delaware  19901
(302) 736-4781

Department of Environmental Services
Solid Waste Management Administration/
Hazardous Waste Division
500 Overlook Avenue, S.W.
Washington, D.C.  20032
(202) 767-8176/767-8422

Department of Environmental Regulation
Division of Environmental Programs
2600 Blairstone Road
Tallahassee, FL  32301
(904) 487-1855

Department of Natural Resources
Environmental Protection Division
Land Protection Branch
270 Washington Street, S.W.
Atlanta, GA  30334
(404) 650-2833

Department of Health
Environmental Protection and Health Services Division
P.O. Box 3378
1250 Punchbowl Street
Honolulu, HI  96801
(808) 548-4139

Department of Health and Welfare
Division of Environment
Statehouse
Boise, Idaho  83720
(208) 334-4059
                                   A-5

-------
Illinois       Environmental Protection Agency
               Land Pollution Control Division
               2200 Churchill Road
               Springfield, IL  62706
               (217) 782-6760

Indiana        Environmental Management Board
               P.O. Box 1964
               1330 Michigan Street
               Indianapolis, IN  46206
               (317) 633-0170

Iowa           Department of Environmental Quality
               Air and Land Quality Division
               Henry A. Wallace Building
               900 East Grand Avenue
               Des Moines, Iowa  50319
               (515) 281-5851

Kansas         Department of Health and Environment
               Solid Waste Management Division
               740 Forbes Building
               Topeka, KS  66620
               (913) 862-9360

Kentucky       Bureau of Environmental Protection
               Waste Management Division
               Fort Boone Plaza
               18 Reilly Road
               Frankfort, Kentucky  40601
               (502) 564-6716

Louisiana      Department of Natural Resources
               Solid Waste/Hazardous Waste Division
               P.O. Box 44066
               Baton Rouge, Louisiana  70804
               (504) 342-1216/342-1227

Maine          Department of Environmental Protection
               Solid Waste/Hazardous Materials Division
               State House, Station 17
               Augusta, ME  04333
               (207) 289-2111/289-2251

Maryland       Department of Health and Mental Hygiene
               Waste Management Division
               201 West Preston Street
               Baltimore, Maryland  21201
               (301) 383-3123
                                   A-6

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Massachusetts
Michigan
Executive Office of Environmental Affairs
Department of Environmental Quality Engineering
Solid and Hazardous Waste Division
One Winter Street
Boston,  MA  02108
(617) 292-5589

Bureau of Environmental Protection
Hazardous Waste Management Office
P.O. Box 30038
Lansing, Michigan  48909
(517) 373-8114
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
Health Department
Environmental Health Division
717 Delaware Street SE
Minneapolis, Minnesota  55440
(612) 296-5320

Department of Natural Resources
Bureau of Pollution Control
P.O. Box 10385
Jackson, MS  39209
(601) 961-5202

Department of Natural Resources
Division Of Environmental Quality
Solid Waste Management Program
P.O. Box 1368
Missouri Boulevard
Jefferson City, Missouri  65102
(314) 751-3241

Department of Health and Environmental Sciences
Environmental Sciences Division
Solid Waste Management Bureau
Cogswell Building
Helena, Montana  59620
(406) 449-2821

Department of Environmental Control
P.O. Box 94877
State Office Building
Lincoln, Nebraska  68509
(402) 471-2186

Department of Conservation and National Resources
Division of Environmental Protection
201 South Fall Street, Capitol Complex
Carson City, Nevada  89710
(702) 885-4670
                                    A-7

-------
New Hampshire
New Jersey
New Mexico
Department of Health and Welfare
Bureau of Solid Waste Management/
Hazardous Waste Management
Hazen Drive
Concord, NH  03301
(603) 271-4586/271-4608

Department of Environmental Protection
Solid Waste Division/Hazardous Waste Bureau
CN 402
Trenton, NJ  08625
(609) 292-9120/292-9877

Health and Environmental Department
Environmental Improvement Division
P.O. Box 968
Santa Fe, NM  87503
(505) 827-5271

Department of Environmental Conservation
Solid Waste Management Division/
Bureau of Hazardous Waste
50 Wolf Road
Albany, NY  12233
(518) 457-5861/457-3254
North Carolina Department of Human Resources
               Division of Health Services
               Solid and Hazardous Waste Management Branch
               P.O. Box 2091
               225 North McDowell Street
               Raleigh, North Carolina  27602
               (919) 733-2178
New York
North Dakota
Ohio
Oklahoma
Health Department
Environmental and Waste Management Research Division
1200 Missouri Avenue
Bismarck, North Dakota  58505
(701) 224-2382

Environmental Protection Agency
Office of Land Pollution Control
P.O. Box 1049
361 East Broad Street
Columbus, Ohio  43216
(614) 466-8934

Health Department
Environmental Health Services
Industrial and Solid Waste Service
1000 NE  10th Street
Oklahoma City, OK  75152
(405) 271-5338
                                    A-8

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Oregon
Pennsylvania
Department of Environmental Quality
Solid Waste Division
522 SW 5th Street
Portland, OR  97204
(503) 229-5336

Department of Environmental Resources
Office of Environmental Protection
Bureau of Solid Waste Management
Fulton Building, P.O. Box 2063
Harrisburg, PA  17120
(717) 787-9870

Department of Environmental Management
Division of Land Resources
75 Davis Street
Providence, RI  02908
(401) 277-6820
South Carolina Board of Health and Environmental Control
               Bureau of Solid and Hazardous Waste
               2600 Bull Street
               Columbia, SC  29201
               (803) 758-5544
Rhode Island
South Dakota
Tennessee
Texas
Utah
Department of Water and Natural Resources
Environmental Health Division
Joe Foss Building
Pierre, SD  57501
(605) 773-3329

Department of Public Health
Bureau of Environmental Health Services
Solid Waste Management Division
Cordell Hull Building
Nashville, TN  37129
(615) 741-3424

Department of Health
Bureau of Solid Waste
(512) 458-7271

Department of Health
Division of Environmental Health
Bureau of Solid Waste Management
150 North Temple Street
P.O. Box 2500
Salt Lake City, UT  84110
(801) 533-4145
                                   A-9

-------
     Vermont
     Virginia
     Washington
     West Virginia
     Wisconsin
Environmental Conservation Agency
Air and Solid Waste Division
State Office Building
Montpelier, VT  05602
(802) 828-3395

Department of Health
Division of Solid and Hazardous Waste Management
109 Governor Street
Richmond, VA  23219
(804) 786-5271

Department of Ecology
Solid Waste Management Division/Hazardous Waste Section
P.O. Box 829
Olympia, WA  98501
(206) 459-6273/459-6301

Department of Health
Office of Environmental Health
1800 Washington Street East
Charleston, WV  26505
(304) 348-2987

Department of Natural Resources
Bureau of Solid Waste Management
101 South Webster Street
Madison, Wisconsin  53707
(609) 266-1327
     Wyoming        Environmental Quality
                    Solid Waste Management Program
                    401 West 19th Street
                    Cheyenne,  Wyoming  82002
                    (307) 777-7753

A.5  GOVERNMENT PRINTING OFFICE BOOKSTORE LOCATIONS

     Region I       Boston,  MA
                    John F.  Kennedy Federal Building
                    Sudbury Street
                    (617) 223-6071

     Region II      New York,  NY
                    20 Federal Plaza
                    (212) 264-3825

     Region III     Philadelphia, PA
                    Federal Office Building
                    600 Arch Street
                    (215) 597-0677
                                       A-10

-------
               Pittsburgh,  PA
               Federal Building
               1000 Liberty Avenue
               (412) 644-2721

               Washington,  DC area:
               Main Bookstore
               710 N Capital St.
               (202) 275-2091
               Commercial Department
               14th and E Streets NW
               (202) 377-3527
               HHS
               330 Independance Ave. SW
               (202) 472-7478
               ICA
               1776 Pennsylvania Ave.  NW
               (202) 724-9928
               Laurel Bookstore
               8660 Cherry Lane
               Laurel, MD
               (301) 953-7974
               Pentagon Building
               Main Concourse
               (703) 557-1821
               State Department
               21st and C Streets NW
               (202) 632-1437

   ion IV      Atlanta, GA
               Federal Building
               275 Peachtree Street  NE
               (404) 221-6947

               Birmingham,  AB
               9220-B Parkway East
               Roebuck Shopping City
               (205) 254-1056

               Jacksonville, FL
               Federal Building
               400 W. Bay Street
               (904) 791-3801

Region V       Chicago, IL
               Everett McKinley Dirksen Building
               219 S. Dearborn Street
               (312) 353-5133
                                   A-ll

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               Cleveland,  OH
               Federal Office Building
               1240 E. 9th Street
               (216) 522-4922
Region VI
Region VII
Columbus,  OH
Federal Office Building
200 N. High Street
(614) 469-6956

Detroit, MI
Patrick. V. McNamara Federal Building
477 Michigan Avenue
(313) 226-7816

Milwaukee, WI
Federal Building
519 E. Wisconsin Avenue
(414) 291-1304

Dallas, TX
Federal Building—U.S. Courthouse
1100 Commerce Street
(214) 729-0076

Houston, TX
45 College Center
9319 Gulf Freeway
(713) 226-5453

Kansas City, MO
Federal Office Building
601 E. 12th Street
(816) 374-2160
Region VIII
Region IX
Denver, CO
Federal Building
1961 Stout Street
(303) 837-3904

Pueblo, CO
720 N. Main Majestic Building
(303) 544-3142

San Francisco, CA
Federal Office Building
450 Golden Gate Avenue
(415) 556-0643
                                    A-12

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               Los Angeles,  CA
               ARCO Plaza
               505 S.  Flower Street
               (213) 688-5841

Region X       Seattle,  WA
               Federal Office Building
               915 Second Avenue
               (206) 442-4270
                                  A-13

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                              APPENDIX B




                    SYNOPSIS OF TECHNICAL REPORTS







B.I  SYNOPSIS OF TECHNICAL GUIDANCE DOCUMENTS




B.2  SYNOPSIS OF TECHNICAL RESOURCE DOCUMENTS




B.3  SYNOPSIS OF OTHER GUIDANCE MANUALS
                                   B-l

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B.I  SYNOPSIS OF TECHNICAL GUIDANCE DOCUMENTS

     (1)  Surface Impoundments  Liner Systems,  Final  Cover,  and  Freeboard
          Control discusses design specifications  for the principal  components
          of surface impoundments  (i.e.,  liner systems,  monitoring methods,
          overtopping controls,  and closure caps).   Appendices  are  included
          that provide laboratory  and field testing  protocols  for obtaining
          necessary data elements.

     (2)  Waste Pile Design - Liner Systems describes liner designs  that
          provide an essentially impermeable waste  pile  base of sufficient
          strength to allow periodic removal of all  wastes in  order  to
          physically inspect the base liner.  Details such as  suitable liner
          materials, liner thickness, and leachate  processing  are discussed.
          Appendices with useful test procedures are included.

     (3)  Land Treatment Units identifies specific  designs and  various
          operating procedures to:  maximize waste  treatment; control water
          run-on/run-off and wind  dispersal; monitor for waste  constituent
          escape; close facility;  and maintain the  site  after  closure.
          Methods to demonstrate waste treatability in soil are provided along
          with appendices containing testing protocols.

     (4)  Landfill Design - Liner  Systems atid_ Final Cover presents  various
          liner specifications,  leachate processing methods, and final cover
          designs that would give  satisfactory performance in  a given
          environmental setting.  Appendices containing  relevant testing
          procedures are included.

B.2  SYNOPSIS OF TECHNICAL RESOURCE DOCUMENTS

     (1)  Evaluating Cover Systems for Solid and Hazardous Waste (SW-867)
          presents a procedure for evaluating  final cover engineering plans
          proposed for solid and hazardous waste land disposal facilities.
          All aspects of cover design are addressed in sufficient  detail to
          allow a complete evaluation of the entire cover system.

     (2)  Hydrologic.Simulation on Solid Waste Disposal  Sites  (SW-868)
          describes the use of a computer-based model for simulating the
          percolation of water through cover material at a solid waste
          disposal site.  This model is a tool for evaluating  present cover
          materials, and the design of new landfill covers.  Previous computer
          experience by the program user is not necessary.

     (3)  Landfill and Surface Impoundment Performance Evaluation (SW-869)
          provides techniques for determining  the adequacy of  design features
          such as liners, drain layers, slope, and position of drains in
          controlling liquid waste escape from surface impoundments and
          landfills into the environment.
                                         fl-2

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     (4)  Lining of Waste Impoundment and Disposal  Facilities  (SW-870)
          discusses performance evaluation,  selection,  installation,  and
          maintenance of specific liner and  cover materials  for certain
          containment situations based upon  the  latest  technology.   It
          includes a description of several  industrial  waste streams,  and
          indicates several testing procedures  for  evaluating  the waste/liner
          interaction.

     (5)  Management of Hazardous Waste Leachate (SW-871)  presents  options  for
          controlling,  treating, and disposing  of hazardous  waste leachates
          generated by surface impoundments  and  landfills.   Discussion
          includes factors that influence leachate  generation,  data on
          leachate characteristics, alternative  technologies for processing
          leachates, and data on treatment costs and byproducts.  A systematic
          approach is provided for selecting an appropriate  leachate
          management method.

     (6)  Guide to the Disposal of Chemically Stabilized and Solidified Waste
          (SW-872) describes  current treatment  technology, and  design of
          long-term storage and disposal systems using
          stabilization/solidification of wastes.  In includes  data on the
          properties of treated wastes, and  a listing of major  technology
          suppliers with a summary of each process.   Sufficient information  is
          provided to determine relative cost/effectiveness  of
          stabilization/solidification for a particular waste  and disposal
          system.

     (7)  Closure of Hazardous Waste Surface Impoundments (SW-873)  discusses
          the important details to consider  in  evaluating closure and
          post-closure plans  for hazardous waste surface impoundments.
          Methodologies are presented for site  specific assessments.

     (8)  Hazardous Waste Land Treatment (SW-874) describes  current technology
          and provides methods for evaluating the design and performance  of
          hazardous waste land treatment facilities.  All  aspects of land
          treatment are discussed from initial  site  selection  through final
          closure.

FUTURE TECHNICAL RESOURCE DOCUMENTS

     (9)  Evaluation o£ Closure and Post-Closure Care Plans  for Hazardous
          Waste Landfills presents an overview  of the current  state-of-the-art
          technologies for closing landfill  facilities.  (Due  in early 1984.)

     (10) Soil Properties, Classification, and  Hydraulic Conductivity Testing
          is a compilation of available laboratory  and  field testing methods
          for the measurement of hydraulic conductivity of soils  along with
          background information on relevant soil properties and
          classification systems.  (Due in early 1984.)  However, the RCRA
          Technical Guidance  Documents present  the  official  EPA test methods
          for hydraulic conductivity determinations.

     (11) Solid Waste Leaching Procedure Manual  provides laboratory batch
          procedures for extracting a leachate  sample from solid  waste that  is
          similar to the composition of leachate from the waste under field
          conditions.  (Due in early 1984.)
                                       B-3

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B.3  SYNOPSIS OF OTHER GUIDANCE MANUALS

     (1)  Test Methods for Evaluating Solid Wastes  (SW-846)  provides
          standardized laboratory procedures for determining whether a waste
          is hazardous as defined in Section 3001 of the Resource  Conservation
          and Reocvery Act (PL94-580),  and for obtaining data to satisfy the
          requirement of 40 CFR Part 261,  Identification and Listing of
          Hazardous Waste.  These methods  will generate data of acceptable
          quality to support waste evaluation and listing/delisting
          petitions.  Included are protocols for collecting  representative
          waste samples, determining pH,  flash point, leachability,
          reactivity, corrosivity, ignitability, mobility of toxic
          constituents, and general composition of the waste.  These
          procedures are current state-of-the-art techniques and will be
          periodically updated and expanded as new information is  developed.

     (2)  A Method for Determining the Compatibility of Hazardous  Wastes
          (EPA-600/2-80-076) presents a procedure for determining  the
          compatibility of combinations of two wastes or waste streams.  The
          manual includes a chart of 41 reactivity groups.  Wastes to be
          combined are first subjected to the analysis procedure for
          identification and classification into a reactive  group.  The chart
          is used to predict the compatibility of the classified wastes on
          mixing.

     (3)  Handbook for Remedial Action at Waste Disposal Sites
          (EPA-625/6-82-006) describes available remedial action technologies
          and how they may be applied for the clean-up of hazardous waste
          disposal sites.  A general approach to selecting an appropriate
          clean-up technique for a specific site is provided.

     (4)  Permit Writer's Guidance Manual for Subpart F(being drafted)
          provides a comprehensive examination of items covering ground-water
          protection requirements for permit writers to examine when reviewing
          Part B applications.

     (5)  Ground-Water Monitoring Guidance for Owners and Operators of Interim
          Status Facilities (SW-963) provides guidance for facilities in
          compliance with the Interim Status requirements.

     (6)  Financial Assurance for Closure and Post-Closure Care:  Requirements
          for Owners and Operators of Hazardous Waste Treatment, Storage, and
          Disposal Facilities - A Guidance Manual (SW-955) describes the
          responsibilities of the regulated community in fulfilling the
          financial assurance requirements of the regulations.  Tasks that
          must be performed by the Regional Office, and possible contingencies
          that may arise are discussed.  A checklist of required information
          and sample application forms are provided.

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     (7)  Liability Coverage:   Requirements  for  Owners  or  Operators  of
          Hazardous Waste Treatment,  Storage,  and  Disposal Facilities -  A
          Guidance Manual (SW-961)  describes the responsibilities  of the
          regulated community  in  providing liability  coverage  for  facilities,
          and discusses the role  of the Regional Office.   Included are a
          checklist of required information  and  sample  application forms.

FUTURE RESOURCE MANUALS

     Work is in progress on technical resource manuals  in  the  following
subject areas:

     •    numerical simulation techniques for design  of soil  liners  for
          storage impoundments and  waste piles

     •    further information  on  the compatibility of soil liners  and
          hazardous wastes

     •    characteristics of hazardous waste streams

     The availability of these manuals will  be announced  in the Federal
Register, and in future editions  of this Manual.
                                        B-5

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                                   APPENDIX C

                        ADDRESSES OF GEOLOGICAL  AGENCIES
     Geological agencies are located throughout  the  United  States,  in  the  form
of Federal agencies (U.S.  Geological Survey),  state  geological  surveys,  and
district branches of USGS.  The Federal USGS  offices fall within the U.S.
Department of the Interior.   This  Appendix provides  direction  to the reader  on
the Federal level only.   This is due to several  factors,  the most important
being that the Federal USGS  can provide up-to-date state  and district  office
addresses and telephone numbers.  Thus, the two  distribution offices of  the
USGS (east and west) are listed here along with  the  10 Public  Inquiries
Offices (PIO's) spread throughout  the country.   Both can  provide services  and
maps; specific functions are noted in this Appendix.

     The two distribution offices  of the Federal U.S. Geological Survey  are
for areas east of the Mississippi  River, including Minnesota,  Puerto Rico, and
the Virgin Islands:

     •    Eastern Distribution Branch
          U.S. Geological Survey
          1200 South Eads Street
          Arlington, Virginia  22202

and for areas west of the Mississippi River,  including Alaska,  Hawaii,
Louisiana, Guam, and American Samoa:

     •    Western Distribution Branch
          U.S. Geological Survey
          Box 25286 Denver Federal Center
          Denver, Colorado  80225

These offices can provide indexes  which list  all published  maps and include
order blanks, prices, and detailed ordering instructions.   They also list
addresses of local map reference libraries, local map dealers,  and Federal map
distribution centers.  You should  use these addresses for obtaining
topographic and other maps through the mail.

     Public inquiries offices of the USGS are  provided in Table C-l.   These
offices can also provide index maps and sell  topographic  maps  over the
counter.  They can ship geologic maps through  the mail for  nearby states.
                                        C-l

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TABLE C-l.   PUBLIC INQUIRIES OFFICES  OF THE U.S.  GEOLOGICAL SURVEY'
 Anchorage,  Alaska
 Los Angeles,  California'1
 Menlo Park,  California
 San Francisco,  Californiac
Rm. 108 Skyline Bldg.
508 2nd Avenue
Anchorage, AK  99501

Rm. 7638 Federal Bldg.
JOO No. Los Angeles St.
Los Angeles, CA  90012

Bldg. 3, MS 33
345 Middlefield Rd.
Menlo Park, CA  94025

8m. 504 Custom House
555 Battery Street
San Francisco, CA  94111
(907) 277-0577
(213) 688-2850
                                                               (415) 323-8111
(415) -556-5627
 Denver,  Colorado
 Washington,  District  of
   Columbia
 Dallas,  Texas
 Salt Lake City,  Utah
 Reston,  Virginia
 Spokane,  Washington
Km. 169 Federal Bldg.
1961 Stout Street
Denver, CO  80294

Km. 1028 GSA Bldg.
19th & F Sts. NW
Washington, DC  20244

Rm. l-C-45 Federal Bldg.
1100 Commerce Street
Dallas, TX  75242

Riii. 8105 Federal Bldg.
125 S. State St.
Salt Lake City, UT  84138

Rm. 1-C-4U2 National Center
  STOP 503
12201 Sunrise Valley Dr.
fteston, VA  22092

Km. 678 U.C. Courthouse
W. 920 Riverside Avenue
Spokane, WA  99201
(303) 837-4169
(202) 343-8073
(214) 767-0198
(801) 524-5652
(702)  860-6167
(509)  456-2524
 aAny  of  these  offices  handle roost  states; you should generally contact the
  one  nearest you,  especially in  the case of geologic maps.  These offices
  center  on  bibliographic  research  projects.  They will provide indexes of OSGS
  quadrangles,  by state,  free of  charge.  They can also mail geologic maps and
  brochures, although  in  some cases they cannot ship topographic maps (this
  requires mailing  tubes).  They  all sell topographic maps over-the-counter.
  For  shipment  of topographic maps, the reader should consult the two addresses
  provided at the beginning of  this Appendix.

 ^Handles geologic  maps of California, Alaska, Hawaii, Arizona, Nevada,
  Washington, and Oregon.

 cFocus on Idaho Geologic  maps  as well

 Source:  Geologic  Survey  Professional Paper 950, "Nature  to be Commanded,"
  1978, p. 92.
                                        C-2

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     The geological surveys can provide a variety  of  maps  (topographic,
geologic, seismic,  etc.)  depending on  the location.   They  can  also  provide
other data which may be useful such as books  and reports  or  information  such
as seismic-refraction data.  An excerpt of several  reports listed in  a recent
USGS "New Publications of the Geological Survey" (October  1982)  is  included as
Table C-2.  These publications are issued monthly.

     In addition, geologic data may be available through  private sources  for
some locations.  For example, the geology or  earth  science departments of
universities may have geologic data for the area.

     You might also consult the local  telephone  director  to  check for other
branch offices of the USGS which might be located  near your  site or changes in
telephone number or location from those listed here.
                                        C-3

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                TABLE  C-2.   EXAMPLES  OF  AVAILABLE USGS  DOCUMENTS^
OF 81-0459.  Seismic-refraction data taken in southwest NEW MEXICO and
     southeast ARIZONA, by L. H. Jaksha, A. Garcia, and E. E. Tilgner.   19  p.
     (NC, Da, M, T, SF, LA, U; USGS, Seventh Floor, 505 Marquette, NW.   (P.O.
     Box 26659), Albuquerque, Ml  87125; New Mexico Bur. Mines and Mineral
     Resources, Campus Station, Socorro, NM  87801; Arizona Bur. Geol.  and
     Mineral Tech., 845 North Park Ave., Tuscon, AZ  85719).  Microfiche
     $3.50; paper copy $2.25.

OF 82-0837.  Map showing geophysical tracklines, south-central Monterey Bay,
     CALIFORNIA (summer 1981), by G. W. Hill and J. L. Chin.  1 over-size
     sheet, scale 1:24,000 (1 inch = 2,000 feet).  (NC, Da, M.)  Microfiche
     $1; paper copy $2.50.

OF 82-0832.  Interpretation of an aeromagnetic  survey of parts of Shannon,
     Carter, Oregon, and Ripley Counties in southeastern MISSOURI, by Allan
     Spector, with  introduction by Gerda Abrams.   20 p., 1 over-size sheet,
     scale  1:62,500 (1 inch = 1 mile).  (NC, Da, M; Missouri  Dept. Natural
     Resources, Div. Geol. and Land Survey (P.O. Box 250), Rolla, MO  65401.)
     Microfiche $4; paper copy $5.25.

OF 82-0655.  Geological map of the Alenaio-Waipahoehoe Stream area, South Hilo
     District, HAWAII, by J. M. Buchanan-Banks  and J. P. Lockwood.  1
     over-size sheet,  scale 1:24,000 (1 inch =  2,000 feet).   (NC, Da, M, SF,
     LA.)   Microfiche  $1; paper copy $1.75.

OF 82-0195.  Bibliography of Alaskan geologic maps by 1:250,000 quadrangle,
     compiled by J. F. Morrone. 70 p.  (NC, Da,  M,  A, S, SF, LA; USGS,
     Room  207, O'Neill Bldg., Univ. Alaska (P.O. Box 80586),  Fairbanks,  AK
     99708; Alaska  Div. Geol. and Geophys. Surveys, 3001 Porcupine Dr.,
     Anchorage, AK  99501; and University Ave.  (P.O. Box 80007), Fairbanks,
     AK  99708.)  Microfiche $3.50; paper copy  $9.

OF 82-0462.  Geochemical and geostatistical evaluation, Arkansas Canyon
     planning unit.  Fremont and Custer Counties,  COLORADO, by E. F. Weiland.
     115 p., 31 over-size sheets.   (NC, Da, M,  Db, U.)  Microfiche $19;  paper
     copy  $127.25.

OF 82-0488.  Catalog of earthquakes in southern ALASKA, April-June 1978, by
     C.  D.  Stephens, M. C. Astrue,  J.  R. Pelton, K. A. Fogleraan, R. A.  Page,
     J.  C.  Lahr, M. A. Allan, and S. M. Helton.  37 p.  (NC, Da, M, A, S, SF,
     LA; USGS, Room 207, O'Neill Bldg., Univ. Alaska  (P.O.  Box 80586),
     Fairbanks, AK  99708; Alaska Div.  Geol, and Geophys.  Surveys, 3001
     Porcupine Dr., Anchorage, AK   99501; and University Ave. (P.O. Box
     80007), Fairbanks, AK 99708.)  Microfiche  $3.50; paper copy $4.75.


                                   (continued)
                                        C-4

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                              TABLE  C-2  (continued)
OF 82-0579.  Quaternary fault map of the Basin and Range and Rio Grande rift
     provinces,  Western United States,  by J. K. Nakata, C. M. Wentworth, and
     M. N. Machette.  2 over-size sheets, scale 1:2,500,000  (1 inch = about
     40 miles).   (NC, Da,  M, Db, U,  SF,  LA, T, S; USGS, Seventh Floor,
     505 Marquette, NW.  (P.O. Box 26659), Albuquerque, NM   87125; Montana
     Bur. Mines  and Geol.,  Montana Coll. Mineral Sci. and Tech., Butte, MT
     59701; Nevada Bur. Mines and Geol., Univ. Nevada, Reno, NV  89557;
     Oregon Dept. Geol. and Mineral Industries, Room  1069, State Office Bldg.,
     1400 SW. Fifth Ave.,  Portland,  OR  97201; Wyoming Geol. Survey, Univ.
     Wyoming (P.O. Box 3008, Univ. Station), Laramie, WY  82071).  Microfiche
     $1; paper copy $7.

OF 82-0644.  Subsurface information from eight wells  drilled at the IDAHO
     National Engineering  Laboratory, by F. J. Goldstein and W. D. Weight.
     34 p.  (NC; USGS WRD,  Idaho National Engineering Laboratory, CF-690,
     Room 164, Idaho Falls, ID  83401; Public Document Room, DOE's Idaho
     Operations  Office, 550 Second St.,  Idaho Falls,  ID  83401.)  Microfiche
     $3.50; paper copy $4.25.

OF 82-0689.  Data on subsurface storage of liquid waste near Pensacola,
     FLORIDA, 1963-1980, by R. W. Hull and J. B. Martin.  186 p.  (NC, Wb;
     USGS, WRD,  325 John Knox Rd., Suite F-240, Tallahassee, FL  32303; USGS,
     WRD, 325 John Knox Rd., Suite L-103, Tallahassee, FL  32303.)  Microfiche
     $3.50; paper copy $24.

OF 82-0876.  Inventory of  drilling activities of the  U.S. Geological Survey
     in the United States  during fiscal year 1980, compiled  by M. J. Reed,
     Robert Mallis, and J.  D. Bliss.  19 p.  (NC, Da, M.)  Microfiche $3.50,
     paper copy  $2.25.

OF 82-0877.  A description of colored gravity and terrain maps for the United
     States and  adjacent Canada east of 104°, by R. W. Simpson,
     T. G. Hildenbrand, R.  H. Godson, and M. F. Kane.  18 p.  (NC, Da, M.)
     Microfiche  $3.50; paper copy $2.25.  Standard 2" by 2"  color slides of
     these maps  are available through the U.S. Geologic Survey Photo Library,
     Mail Stop 914, Box 25046, Denver Federal Ctr. , Denver,  CO  80225.
     Telephone (303) 234-4004.


aSource:  "New Publications of the Geological Survey," U.S.  Dept. of
 Interior, List  891—Oct.  1982.  p.  10 and 11.
                                      C-5

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                                   APPENDIX D

                               AERIAL PHOTOGRAPHS
SOURCES OF AERIAL PHOTOGRAPHS

Federal Level

     There are several Federal agencies which handle aerial photographs.   The
first source that you may want to contact is:

     •    NCIC Headquarters
          U.S. Geological Survey
          507 National Center
          Reston, VA  22092
          (703) 860-6045

The NCIC will send out a printout of all the agencies (Federal,  state,
commercial) which have photographs available for the area in question.

     Thereafter,  individual agencies such as the following five  can  be
contacted:

     •    Aerial Photography Field Office
          ASCS-USDA
          P.O. Box 30010
          Salt Lake City, Utah  84130
          801-524-5856

This agency has all ASCS photos, all Forest Service photos, and  many others
(some USGS, National High Altitude Photos (Nhap),  etc.).   Besides  providing
photos through the mail, the ASCS serves as a public reference facility.   Any
maps they have can be used by the public by visiting their facility. Aerial
photos available through ASCS go back historically to 1944; their  archives go
into the 1930's.

     •    EROS Data Center
          U.S. Geological Survey
          Sioux Falls, South Dakota  57198
          (605) 594-6511 X151 for cartographic unit

EROS has Landsat and U-2 photos, mainly black and  white at 1:80,000  scale,
flown at the same time as the color photos for Landsat.  They do computer
searches to retrieve listings of all available photos.
                                        D-l

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     •    Soil Conservation Service
          USDA-SCS
          P.O. Box 6567
          Fort Worth, TX  76115
          (817) 334-5292

The SCS has consolidated its branches into this one office.   SCS  supplies
mostly low-altitude photos.

     •    National Archives
          841 South Pickett Street
          Alexandria, VA  22304
          (703) 756-6700

The National Archives should be contacted for archival photographs.   All of
these agencies will require some identification of site location  by  the
applicant.  This may be in the form of a copy of a town engineer's map;  a
Department of Transportation (DOT) map;  a description  of the township, range
and section; a hand-drawn map of the site and its location in regard to  a
nearby town; a copy of the portion of a  USGS quadrangle that shows  the site;
the latitude/longitude coordinates of the site area, etc.  In all cases,  the
exact site location should be marked out and the topographic quadrangle  used
noted.  Any details that will help the agency provide aerial coverage of  the
area in question should be included.  Each agency also has forms  available for
requesting photographs.

     If the site is near the U.S.-Canada border, it may also be useful  to
contact:

     •    The National Air Photo Library
          Surveys and Mapping Branch
          Department of Energy, Mines, and Resources
          615 Booth Street
          Ottawa, Ontario KlA OE9

Interstate Level

     Table D-l provides a listing of interstate agencies which are likely  to
have aerial coverage for their representative areas.

State Level

     Numerous state agencies are likely to maintain aerial photographs on
file.  If the sources previously outlined are too remote or do not have  the
information you are looking for, you may be able to obtain photos from state
pollution control agencies, health departments, water resources departments,
and state highway departments as well.

Private Companies

     A wide selection of photographic negatives are held by private aerial
survey companies and most often can be ordered directly from these sources.
                                         D-2

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TABLE D-l.  INTERSTATE AGENCIES WHICH ARE LIKELY TO HAVE
            AERIAL PHOTOGRAPHY COVERAGE
Bi-State Agency

Bi-State Development Agency
915 Olive Street
St. Louis,  MO

Delaware River

Interstate Commission on the Delaware River Basin
Suburban State Building
Philadelphia, PA

New England

New England Interstate Water Pollution Control Commission
73 Tremont Street
Boston, MA

Klamath River Compact Commission

Klamath River Compact Commission
P.O. Box 388
Sacramento, CA

New York/New Jersey/Connecticut

Interstate Sanitation Commission
10 Columbus Circle
New York, NY

Ohio River

Ohio River Valley Water Sanitation Commission (ORSANCO)
414 Walnut Street
Cincinnati, OH

Interstate Commission on the Potomac River Basin

203 Tranportation Building
Washington, D.C.
                           D-3

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Names and addresses of leading photogrammetrie  companies  may be  found  in
current issues of "Photogrammetric  Engineering",  the  Journal of  the American
Society of Photogrammetry,  or through  local  telephone listings.   Photo  indexes
and costs can usually be obtained by direct  inquiry to  the  appropriate  agency.

TYPES OF AERIAL PHOTOGRAPHS NEEDED  FOR ANALYSIS

     Air photo analysis is  best done using a multistage approach;  i.e., one
looks first at high-altitude photography  and works down to  a lower level.  For
this reason, Landsat imagry (EROS)  is  important as it provides a large  scale
and an analyst can identify lineaments.   One could then use smaller scale  U-2
photographs for the same area (1:125,000  scale) at which  point the analyst can
eliminate the man-made features such as  power-lines,  old  tree cuts, etc.
Finally, low-altitude photos such as those produced by  the  Soil  Conservation
Service at 1:20,000 scale could be  used.

     It is desirable to use photos  which  are multiseasonal; winter is  usually
best as this provides a low sun angle  and minimal leaf  color.  To increase the
sensitivity of analysis, many variations  can be considered, such as side  lap,
seasonal difference, use of stereoscopy,  etc.
                                        D-4

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                                   APPENDIX E

                     AERIAL RECONNAISSANCE FLIGHT PLANNING
     To prepare for an aerial reconnaissance flight,  the aid of a person
experienced in aerial photography will be required.   Some guidelines on  flight
planning are presented in Table E-l.   Aerial reconnaissance of an area entails
planning the flight (height,  season,  number of flight lines, etc.) and
checking to be sure these specifications are followed.   When photos are
delivered for a project, one  reviews  properties such  as excessive crab,  tilt,
scale differential and photo  quality.  The applicant  should refer to the U.S.
Forest Service (USFS) Lake States Station Paper 96 which details procedures
and reasons for making such checks.   After the flight,  post-flight
interpretation of photos is performed.
                                        E-l

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      TABLE E-l.   CONSIDERATIONS IN AERIAL RECONNAISSANCE FLIGHT PLANNING


     Specifications  and Equipment Considerations

          •    Average forward  overlap3

          •    Desired photo scale

          •    Focal length

          •    Flight ground speed

          •    Intervalometerb

          •    Film format


     Computations

          •    Flying height above terrain and height above mean sea level

          •    Direction and number of flight lines

          •    Adjusted distance between flight lines

          •    Adjusted percent of side lap or end lapc

          •    Map distance between flight lines

          •    Unadjusted distance between exposures on each line

          •    Time between exposures

          •    Map distance between exposures on each line

          •    Number of exposures on each line

          •    The amount of film required (feet and number of rolls)


aOverlap is the amount that one photograph overlaps the area covered by the
 other, customarily expressed as a percentage. '

t>A timing device for automatically operating the shutter of a camera at any
 predetermined interval.

cSide lap is the overlap between photographs in adjacent parallel flights;
 end lap is the overlap between photos in the same flight.

Source:  Eugene  T. Avery.   Interpretation of Aerial Photographs.  2nd  Edition,
         Burgess Publishing  Company, Minneapolis,  MN,  1968.


                                      E-2

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                                     APPENDIX F

                          QUALITY ASSURANCE/QUALITY CONTROL
                            (Reprinted from  Section Ten of
                      Test  Methods for Evaluating Solid Waste,
                              SW-846.  U.S. EPA, 1982)

     "Section 10.1 defines Quality Control (QC) and Quality Assurance (QA).
Section 10.2 discusses how  QC/QA procedures can be used to ensure achievement
of program goals.  The various QC/QA aspects of sampling are discussed in
Section 10.1.3 while Section 10.1.4 discusses and lists appropriate laboratory
QC/QA activities.  Section  10.1.5 discusses the criteria with which acceptable
data must comply and methods of data evaluation.


10.1  Introduction

     Quality assurance (QA) is a system for ensuring that all information,
data, and resulting decisions compiled under a specific task are technically
sound, statistically valid, and properly documented.  Quality control  is the
mechanism through which quality assurance achieves its goals.Qua!ity
control  programs define the frequency and methods of checks, audits, and
reviews necessary to identify problems and  dictate corrective action,  thus
verifying product quality.

     The soundness of an organization's QC/QA program has a direct bearing on
the  integrity of its sampling and laboratory work.   Results of sampling or
analysis conducted without  adequate quality control and assurance may  be
deemed unacceptable for RCRA evaluation purposes.  The following section
discusses some minimum standards for QC/QA  programs.  Generators who are
choosing contractors to perform sampling or analytical work should make their
choice only after evaluating the contractor's QC/QA program against the
procedures presented in these sections.  Likewise,  contractors that currently
sample and/or analyze solid wastes should similarly evaluate their QC/QA
programs.


10.2  Program Design

     The initial  step for any sampling or analytical work should be to
strictly define the program goals.  Once the goals  have been defined,  a
program must be designed that will meet these program goals.  QC and QA
measures will be the mechanisms used to monitor the program and to ensure
that all data generated are suitable for their intended use.  A knowledgeable
person who is not directly  involved in the  sampling or analysis must be
assigned the responsibility of ensuring that the QC/QA measures are properly
employed.

     As  a minimum, a proper QC/QA program would include the following:

      1.  The intended use(s) for the data,  and the necessary level of
          precision and accuracy of the data for these intended uses.

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     "2.   A representative  sampling  plan that  includes provisions for:

          - selecting  appropriate  sampling  locations, depths, etc.

          - providing  a  statistically  sufficient number of  sampling sites.

          - measuring  all necessary  ancillary  data.

          - determining  climatic flow  or other conditions under which
            sampling should  be  conducted.

          - determining  which media  are to  be  sampled (e.g., wastewater,
            sediment,  effluent, soil).

          - determining  which parameters are to be measured  (and where).

          - selecting  appropriate  sample containers.

          - selecting  the frequency  of sampling and  length  of sampling
            period.

          - selecting  the types of sample  (e.g., composites  vs. grabs) to  be
            collected.

          - sample  preservation.

          - chain-of-custody.

     3.   An analytical  plan  that includes:

          - chain-of-custody procedures.

          - appropriate  sample  preparation  methods.

          - appropriate  analytical methods.

          - appropriate  calibration  and analytical procedures.

          - data handling,  review  and  reporting.

     4.   Planning for  the inclusion  of proper  and  sufficient QC/QA  activities,
         including  the use  of QC samples throughout  all phases of the  study
         to ensure  that  the  level  of quality of the  data will meet  the
         requirements  of the intended  use(s) of the  data.

     All  program details should be put in  writing  and assignments made to
appropriate personnel.

     If the above procedures are followed  (i.e., an  appropriate program  is
designed, tasks are assigned to knowledgeable  personnel, and sufficient  QC/QA
                                       F-2

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"steps are employed),  the  program  should meet and possibly  surpass  its  goals
 in most cases;  at  worst the  failure  to meet the program  goals will  be  detected
 and the usefulness of any data will  be quantified.


 10.3  Sampling

      The quality of a sampling program has a direct bearing  on the  legal,
 physical, and chemical  integrity  of  the samples.   If the representativeness
 of the samples  cannot be  verified  due to  inadequate attention to sampling
 procedures,  then the  usefulness of the analytical  data will  be limited,
 regardless  of the  refinement of the  analytical program.  It  is imperative,
 therefore,  that no analytical program be  conducted without an adequate
 sampling plan which does  or  will  document the degree of  representativeness
 of the parameters  of  interest.

      10.3.1   Design of  a  Sampling  Plan

      Section One of this  manual discusses the considerations involved  in
 designing a  representative sampling  plan.  For each specific project,  a
 sampling plan should  be designed  prior to commencement of  sampling.   If the
 plan addresses  the considerations  discussed in Section One,  then the  resulting
 samples  should  be  representative  of  the waste of interest  and therefore
 suitable for evaluation of the waste according to  RCRA criteria.


      10.3.2   Sample Collection

      A variety  of  different  sampling devices are used in sampling depending
 on the type  of  sample (solid, liquid, multiphased), the type of sample
 container, and the sampling  location.  Section One and portions of  Section
 Three of this manual  describe different devices that are available.   The
 appropriate  sampling  device must  be  selected and its use supervised by a
 person thoroughly  familiar with both the sampling and analytical requirements.
 This  familiarity is essential since  (1) certain sampling devices are made of
 materials that may contaminate samples, (2) cross contamination of  samples
 can  occur if the sampling device  is  not cleaned properly,  (3) routine  sampling
 methods  may  not.be applicable when the waste is to be analyzed for  a  different
 parameter (e.g., volatile organic  compounds), and  (3) the method of employing
 the  sampling devices  may  affect the  integrity of the sample.


      10.3.3   Sample Preservation

      Some form of  preservation is  usually required for all  samples.   The type of
 sample preservation required will  vary depending on the sample type and the
 parameter to be measured.  .Therefore, more than one container of the  same
 waste may be  necessary if the waste  is to be analyzed for more than one
 parameter type.
                                      F-3

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    "The analytical methods included in this manual refer to the optimum
means of preservation.  Since the chemical make-up of certain samples can
alter the effectiveness of preservation measures, all sample analyses should
be performed as soon as possible after sampling and before any recommended
holding time has expired.


     10.3.4  Chain of Custody

     Although chain-of-custody procedures may not be required in all cases,
they often are an essential part of sampling/analytical schemes-since these
procedures can document the history of samples.  Chain-of custody establishes
the documentation arid control necessary to identify and trace a sample from
sample collection to final analysis.  Such documentation includes labeling to
prevent mix-up, container seals to detect unauthorized tampering with
contents of the sample containers, secure custody, and the necessary records
to support potential litigation.

     A sample is considered to be under a person's custody if (1) it is in the
person's physical possession, (2) in view of the person, (3) secured by
that person so that no one can tamper with the sample, or (4) secured by that
person in an area that is restricted to authorized personnel.

     Refer to Section One for details of how to implement chain-of-custody
procedures.


10.4  Analysis

     An analytical program defines standard operating procedures to be used
in waste analysis, appropriate QC/QA procedures, means for detecting out-of-
control situations, and remedial actions.  A separate analytical  program
should be developed for each different waste to be analyzed.  The program
should be thoroughly specified before sampling is begun, since the analytical
procedures to be used may affect the choice of sampling devices and procedures.

     The program should select methods that will provide data at the level of
accuracy and precision that will be required by users of the data for decision-
making purposes under RCRA.  Once the appropriate method(s) have been selected
it is imperative that the accuracy and precision of all analytical data be
thoroughly documented by means of a wel1-designed QC/QA program.

     Laboratory QC/QA activities normally include:

      1.  Use of EPA-acceptable sample preparation and analytical methods.

      2.  Calibration of laboratory instruments to within acceptable limits
          according to EPA or manufacturer's specifications before, after,
          and during (as acceptable) use.  Reference standards must be used
          when necessary.
                                      F-4

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     "3.  Periodic inspection, maintenance,  and servicing (as necessary) of
          all laboratory instruments and equipment.

      4.  The use of reference standards and QC samples (e.g., checks,
          spikes, laboratory blanks, duplicates, splits)  as necessary to
          determine the accuracy and precision of procedures, instruments,
          and operators.

      5.  The use of adequate statistical  procedures (e.g., QC charts) to
          monitor the precision and accuracy of the  data  and to establish
          acceptable limits.

      6.  A continuous review of results to  identify and  correct problems
          within'the measurement system (e.g., instrumentation problems,
          inadequate operator training, inaccurate measurement methodologies).

      7.  Documenting the performance of systems and operators.

      8.  Regular participation in external  laboratory  evaluations (including
          the EPA Performance Audit Program) to determine the accuracy and
          overall performance of the laboratory.  This  should include performance
          evaluation and interlaboratory comparison  studies, and formal
          field unit/laboratory evaluations  and inspections.

      9.  Use of acceptable sample identification and,  as necessary,  formal
          chain-of-custody procedures in the laboratory.

     10.  Maintenance and storage of complete records,  charts, and logs  of
          all pertinent laboratory calibration, analytical, and QC activities
          and data.

     11.  Ensuring all  data outputs are presented in their prescribed format.

     Specific Quality Control  measures for each method  can be found by
referring to the individual analytical methods included in this manual.


10.5  Data Handling

     The quality of  all data must be assessed before the  data are used.
Assessment should focus on five basic points.

      1.  Accuracy - Can the data's accuracy be determined, and is it
          acceptable for the planned use?  QC/QA procedures will  be designed
          to measure the accuracy of all  analytical  data.

      2.  Precision  - Can the data's precision be determined, and is  it
          acceptable for the planned use?  QC/QA should demonstrate the
          reproducibility of the measurement process.
                                       F-5

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     "3.   Completeness - Are a sufficient amount of data  available  for the
          planned use?  QC/QA shall  identify the quantity of  data needed to
          meet the program goals,

      4.   Representati veness - How well  do the data represent actual
          conditions at the sampling location, considering the original
          study design, sampling methods, analytical  methods, etc.,  which
          were used?

      5.   Comparability - How comparable are data with  respect to several
          factors, including:

          - consistency of reporting units?
          - standardized siting, sampling, and methods  of analysis?
          - standardized data format?

     All  these factors must be considered when designing  a study, and QC/QA
procedures must specify a reviewing process for all data.

     Statistical  procedures applicable to data evaluation include:

     1.  Central  tendency and dispersion

         - Arithmetic mean
         - Range
         - Standard deviation
         - Relative standard deviation
         - Pooled standard deviation
         - Geometric mean

     2.  Measures of variability

         - Accuracy
         - Bias
         - Precision; within laboratory and between laboratories

     3.  Significance test

         - u-test
         - t-test
         - F-test
         - Chi-square test

     Specific data handling precautions are noted in the individual  methods
described in this manual."
                                         F-6

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     UwIronrtintaT
       5, Library •'
rv»'' ;;, Dearborn St
Chicago, Zli   .60604

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