EPA    530SW88001
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               United States           Office of Solid Waste      September 1988
               Environmental Protection     and Emergency Response
               Agency             Washington, DC 20460
               Office Of Solid Waste
               Model RCRA Permit
               for Hazardous Waste
               Management Facilities
               (Draft)

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            WASHINGTON, D.C.  20460
                           SEP -8 1988
                                                             OFF:CE OF
MEMORANDUM                                           SUD WASTE AN EMfcML>ENl-

SUBJECT: Model Permit and Permit Quality Protocol

FROM:    Bruce R. Weddle, D	
         Permits and State Programs Division

TO:      Addressees
     Attached for your review and use are two draft revised
guidances: Model RCRA Permit for Hazardous Waste Management
Facilities and RCRA Permit Quality Protocol.  These documents  have
been updated to include more recent rules, policies, and guidances.
The Model Permit will replace models that were sent out years  ago
(pre-HSWA).   The Protocol will replace the RCRA Permit Quality
Protocol, August 1986.  Comments on the incineration sections  are
requested by October 28, 1988.  Comments on the other sections are
requested by December 16, 1988.


     The primary purpose of the Model Permit and Protocol  is to
assist Permit Writers in drafting or reviewing hazardous waste
facility permits.  They cover process-specific conditions  for
container storage areas, tanks, incinerators, waste piles, surface
impoundments, land treatment areas, and landfills, as well as
ground-water monitoring, corrective action, closure and post-closure,
and other general permit and facility conditions.  The introduction
to the Model Permit discusses an approach (with examples)  to
developing permits.  The Protocol is to be used in conjunction with
the Model Permit to evaluate the technical completeness and adequacy
of permits.   The Protocol provides a checklist of permit conditions,
which mirrors the Model Permit conditions, for use in evaluating the
completeness of the permit, and for a select number of permit
conditions,  the Protocol provides technical and enforceability
evaluation criteria and guidance.  In addition, the Protocol is to be
used to help evaluate the completeness and adequacy of the
Administrative Record in supporting the permit conditions.  The
Protocol is used by Headquarters when conducting Regional  reviews,
and Regions should use it when evaluating the States.

     These draft revised guidances reflect the Federal rules as of
July 1, 1987, including the latest tank rules, as well as  some more

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recent rules, policies, and guidances such as carbon monoxide and
heavy metals conditions for incinerators.  The Model Permit module
containing conditions for corrective action for solid waste
management units under RCRA Section 3004(u) is not quite finished, so
it will be mailed separately in the near future when available.   The
Model Permit does not include a model for: Mobile Treatment Units
(MTUs); Research, Development,  and Demonstration (RD&D)  Permits; or
miscellaneous units (Subpart X).  The Protocol however does contain a
checklist for RD&D Permits.

     Some Regional Permit Writers suggested that it would be helpful
if the Model Permit would identify which conditions are HSWA
conditions.  This draft takes a cut at identifying these.  In some
cases, however, conditions are both HSWA and pre-HSWA, and the
distinction is less clear  (e.g., tank conditions).

     This draft Model Permit may be used in developing or finalizing
land disposal permits, but its use is not to delay issuance of these
permits.  That is, use of this Model is not required and may not be
possible for current land disposal permits.  If Permit Writers wish
to use the draft Model Permit,  they should keep in mind that this is
a draft undergoing Regional as well as additional Headquarters review
and should use it with caution.

     To assist Permit Writers who may want to use the Model Permit as
a starting point for drafting permits, we are making diskettes of the
Model Permit available to the Regions and States.  When using these
diskettes, Permit Writers should keep in mind that this is a draft
model, that it contains many notes and other instructional material
that need to be followed, and that many site-specific conditions need
to be added or tailored to the specific site.  Diskettes may be
obtained by directly contacting Ms. D.D. Rhodes of A.T.  Kearney, Inc.
at 703-683-7932.

     The initial printing of these guidances was limited to 175
copies.  Additional copies are currently being ordered.   If you would
like additional copies for your staff or to send to your States,
please contact Naum Bers at FTS 475-7239.

     Based on review comments on these drafts we may send out revised
pages, modules, or whole new documents based on the extent of the
revisions and on whether the revisions are done in stages rather than
one complete new revision.  For example, because of the importance of
the incinerator modules in FY 89, if appropriate, we will revise
those modules first.  Even in the longer term, these are considered
to be dynamic documents; that is, improvements and revisions are
expected as additional rules, policies, and guidances are developed
or revised, and better language is developed.  Therefore, the longer
range plan is to periodically send out revised pages, modules, or
whole documents as needed.

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                                  -3-
     Comments or questions on the attached guidances should be
addressed to Kenneth Shuster,  Permits and State Programs Division
(OS-340), Office of Solid Waste, U.S. Environmental Protection
Agency, Washington, B.C.  20460, or FTS 382-2214.

Attachments
Addressees:

Gerald Levy, Region I
Linda Murphy, Region I
Mary Jane O'Donnell, Region I
Stanley Siegel, Region II
Andy Bellina, Region II
Frank Langone,  Region II
Barry Tornick,  Region II
Angel Chang, Region II
Robert Greaves, Region III
John Humphries, Region III
Patrick Anderson, Region III
Sheila Briggs,  Region III
James Webb, Region III
James Scarbrough, Region IV
Doug McCurry, Region IV
Betty Willis, Region IV
Craig Brown, Region IV
Beverly Foster, Region IV
Mickey Hartnet, Region IV
Wayne Garfinkel, Region IV
John Dickinson, Region IV
Karl Bremer, Region V
Y. J. Kim, Region V
Rich Traub, Region V
Jim Mayka, Region V
Charles Slaustas, Region V
George Hamper,  Region V
Hak Cho,  Region V
Randy Brown, Region VI
Sam Becker, Region VI
Bill Honker, Region VI
Henry Onsgard, Region VI
Rob Franke, Region VI
Larry Brnicky, Region VI
Laurie Burch, Region VI
Dan Johansen, Region VI
Mark Sides, Region VI
Mike Sanderson, Region VII
Lyndell Harrington, Region VII
Luetta Flournoy, Region VII
Louis Johnson, Region VIII
Terry Anderson, Region VIII
Larry Wapensky, Region VIII
Judith Wong, Region VIII
Rich Vaille, Region IX
Jim Breitlow, Region IX
Chuck Flippo, Region IX
Larry Bowerman, Region IX
Mike Gearheard, Region X
George Hofer, Region X
Catherine Massimino, Region X
Wallace Reid, Region X
cc: Tina Kaneen, OGC
    Fred Chanania, OGC
    Elaine Stanley, OWPE
    Susan Bromm, OWPE
    Steve Heare, OWPE
    Susan Hodges,  OWPE
    Jackie Tenusak, OWPE
    Matt Hale, PSPD
    Elizabeth Cotsworth, PSPD
    George Garland, PSPD
    Suzanne Rudzinski, PSPD
Dave Fagan, PSPD
Frank McAlister, PSPD
Margaret Schneider,  PSPD
Susan Absher,  PSPD
Alex Wolfe, PSPD
Jim Michael, PSPD
Sonya Stelmack, PSPD
RCRA HOTLINE
ASTSWMO

Regional DDs w/o attachments

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         MODEL RCRA  PERMIT

         FOR HAZARDOUS WASTE

       MANAGEMENT  FACILITIES



               [DRAFT]
U.S. ENVIRONMENTAL PROTECTION AGENCY
           SEPTEMBER 1988

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                                    FOREWORD
This "Model Permit" is a guide to help Permit Writers draft and review RCRA
permit conditions.  By using language that has, in most cases, already been
well thought out and refined, this model will help: shorten the time needed to
draft and review permits; promote national consistency; and result in clearer
and more readily implementable and enforceable permit conditions.

This guidance is considered to be a dynamic working document.  It has been said
that the last permit in each Region (or State) typically serves as the latest
"Model Permit" for the next permit, since it has the latest cogitated and
refined language.  This "Model Permit" guidance contains conditions from recent
permits from various Regions.  It is anticipated that this model will be
updated periodically,  as needed, in order to incorporate:  (1) new rules,
policies, and guidances; (2) results of judicial decisions; and (3) Regional
Permit Writer and other comments, and otherwise improved permit condition
language.

Any comments or questions on this version should be addressed to:  Kenneth
Shuster, Permits and State Programs Division (OS-340);  Office of Solid Waste,
U.S. Environmental Protection Agency,  401 M Street, S.W.,  Washington, D.C.
20460 (FTS: 382-2214)

Diskettes of the Model Permit are available to Permit Writers only by directly
contacting Ms. DeDe Rhodes, A.T. Kearney, Inc., at (703) 683-7932.

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                               ACKNOWLEDGEMENTS
This Model Permit was compiled by A.T.  Kearney,  Inc.  under contract to EPA.
The EPA Project Officer was Kenneth Shuster.

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                               RCRA MODEL PERMIT

                               TABLE OF CONTENTS



  I.   INTRODUCTION	        1

 II.   APPROACH TO WRITING PERMITS	        3

III.   INSTRUCTIONS FOR USE OF MODEL PERMIT	       11

MODEL PERMIT COVER SHEET	       12

MODULE I	GENERAL PERMIT CONDITIONS	      I -1

MODULE II	GENERAL FACILITY CONDITIONS	     II-1

MODULE III	CONTAINERS	    III-l

MODULE IV	TANKS	     IV-1

MODULE V	SURFACE IMPOUNDMENTS	     V-l

MODULE VI	WASTE PILES	     VI-1

MODULE VII (A) -LAND TREATMENT OPERATIONS	 VII (A) -1

MODULE VII(B) -LAND TREATMENT DEMONSTRATIONS	 VII(B) -1

MODULE VIII---LANDFILLS	   VIII-1

MODULE IX( A)--INCINERATION	  IX(A)-1

MODULE IX(B)--SHORT-TERM TEST INCINERATION	  IX(B)-1

MODULE X	GROUND-WATER DETECTION MONITORING	      X-1

MODULE XI	GROUND-WATER COMPLIANCE MONITORING	     XI-1

MODULE XII (A) -CORRECTION ACTION FOR REGULATED UNITS	 XII (A) -1

MODULE XII(B)-CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS	 XII(B)-1
              Sa  SuV^r^ $
MODULE XIII---POST-CLOSURE CARE	   XIII-1

MODEL RCRA PERMIT SUPPORTING DOCUMENTATION

     A.   SUMMARY LIST OF PERMIT ATTACHMENTS FROM PERMIT
         MODULES I THROUGH XIII	      A-l

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                             I.   INTRODUCTION
PURPOSE OF GUIDANCE.  The purpose of this guidance is to help Permit
Writers in drafting or reviewing hazardous waste management facility
permits under Subtitle C of the Resource Conservation and Recovery Act of
1976 (RCRA),  as amended.  The guidance provides an updated model of
recommended language and format for permit conditions.

SCOPE OF GUIDANCE.  The Model Permit consists of a permit cover sheet and
16 modules.  The first two modules are applicable to all permits and
cover:  general permit conditions (e.g., duration of permit) and general
facility conditions (e.g., waste analysis plan, site security, and
personnel training plan).   The next nine modules contain conditions for
each type of unit (e.g., tanks, incinerators, landfills) for which there
are unit-specific standards in 40 CFR Part 264.  The next four modules
address ground-water monitoring and corrective action conditions.  The
last module addresses post-closure care.  The Permit Writer needs to
select which of the last 14 modules are pertinent to the particular
facility under review, and then within all pertinent modules, which
conditions are pertinent.

This version of the Model Permit is based on the EPA regulations in 40
CFR Parts 264, 268, and 270, as of July 1, 1987, and related policies and
guidances.  It supersedes all earlier versions.  In addition, included in
this guidance are permit conditions contemplated for corrective actions
for solid waste managements units (SWMUs) under HSWA1 [presented in
Module XII(B)].  The guidance does not include a model permit for mobile
treatment units (MTUs), which will appear in a separate guidance
document, nor does it include a model permit for Research, Development,
and Demonstration (RD&D) permits nor for miscellaneous units (Subpart X).
(The "Model RCRA Research, Development and Demonstration, Fact Sheet and
Public Notice," (EPA/530-SW-87-003),  dated January 1987 does provide a
model for RD&D permits.)
     The Hazardous and Solid Waste Amendments of 1984 (HSWA) amended RCRA
     to include Section 3004(u) to require corrective action for all
     releases of hazardous waste or constituents from any SWMU at a
     facility seeking a RCRA permit.  These permits may include schedules
     of compliance for such corrective action where the corrective action
     cannot be completed prior to permitting.  A new Subpart S to 40 CFR
     264, with associated amendments to 40 CFR 270, is being developed to
     implement this provision.  Nevertheless, all permits issued before
     these rules are finalized must include permit conditions to address
     corrective action for SWMUs.  Because of this statutory requirement,
     the Model Permit includes Module XII(B), addressing corrective
     action for SWMUs, even though the detailed rules have not yet been
     issued.
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The Model Permit identifies:  (1) conditions that are exclusive to            I
existing facilities and conditions that are exclusive to new facilities,       ^
as well as conditions that apply to both existing and new facilities;  (2)
optional methods of meeting the regulatory requirements, where allowed;
and (3) conditions which may be waived or varied under the regulations.

The Model Permit may be used for drafting or reviewing post-closure
permits, as well as for operating permits, by eliminating the conditions
for operating requirements that no longer apply.

RELATIONSHIP OF MODEL PERMIT TO PERMIT QUALITY PROTOCOL.  The Model
Permit guidance is meant to be used in conjunction with the RCRA Permit
Quality Protocol .   The Protocol provides:  (1) a checklist of permit
conditions, which mirrors the Model Permit conditions, to be used to
review the completeness of the permit, (2) a "Permit Condition Evaluation
Guidance," (3) a discussion of the purpose and content of the
Administrative Record to support the permit and a checklist for
procedural requirements, and (4) a checklist for RCRA RD&D permit
conditions.  The "Permit Condition Evaluation Guidance" gives information
on how to evaluate a select number of permit conditions in terms of: a)
thoroughness and technical soundness, by providing a description of the
scope and content of the condition and pertinent information that should
be in Part B of the permit application to support the condition, and by
listing references to help with technical evaluations and b)
enforceability of permit conditions.
     The RCRA Permit Quality Protocol. EPA, September 1988, is an updated
     version of the RCRA Permit Quality Protocol. EPA, August 1986.
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                     II.   APPROACH TO WRITING PERMITS

Permits establish the requirements that facilities must comply with
(since, in general, compliance with a RCRA permit constitutes compliance,
for enforcement purposes, with Subtitle C of RCRA).  Therefore, it is
necessary for the permit  to be:
     (1)  Protective of human health and the environment,
     (2)  Comprehensive (i.e., reflect all the pertinent requirements in
          the regulations, 40 CFR Parts 264, 268, and 270, and HSWA--
          requirements not in the regulations that are implemented via
          statute,
     (3)  Technically sound,  and
     (4)  Enforceable (i.e.,  clear, unambiguous, and specific).
Clearly, these are inter-related.  For example, if a permit condition is
not technically sound, it may not be protective, meet the regulations, or
be enforceable.  The Permit Writer is responsible for making sure the
permit meets these criteria.   Tools available to the Permit Writer
include: (1) the regulations (and related Federal Register preambles),
primarily 40 CFR Parts 264, 268, and 270, (2) RCRA, as amended by HSWA,
(3) the permit (Part B) application, (4) enforcement inspection and other
site-specific reports, (5) Agency guidances and regulatory
interpretations, as contained in the OSWER directives system and "Permit
Policy Compendium" (including this Model Permit and the Permit Quality
Protocol), and (6) technical documents/texts.  The Model Permit and
Protocol give references to (1), (2), (3), (5), and some (6).

Permit development begins with submission of the permit (Part B)
application.  Permit applications are required to address all the
hazardous waste facility requirements, contained primarily in 40 CFR
Parts 264, 268, and 270, and HSWA.  These applications include location,
design, construction, operation, monitoring, closure, and post-closure
information, which require various technical expertise to review (e.g.,
hydrogeology, chemistry, civil engineering,  and statistics).  During the
permit application review process, technical soundness, comprehen-
siveness,  and protectiveness aspects listed above are thoroughly
evaluated.  Once the permit application is determined to be complete,
technically sound, and protective, permit conditions incorporating this
Part B information will likewise tend to be complete, technically sound
and protective and easier to review for these attributes.

To determine what conditions to include in the permit, the Permit Writer
needs to:  (1) address all pertinent requirements in the regulations
(Parts 264,  268, and 270) and HSWA and (2) include items proposed by the
Permittee in Part B of the permit application to meet the regulations or
to protect human health and the environment.

Since both the permit application and the permit must address all
applicable requirements in the regulations and HSWA, the completeness
checks are similar and mirror the regulations and HSWA, but the permit
application checklist needs to be more detailed and technically oriented,
since it also includes the requisite ana'lyses to determine whether the
design, etc. meets the performance standards.
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DEVELOPING PERMIT CONDITIONS.  At the end of this chapter are two
examples that illustrate how to develop permit conditions from regulatory
requirements and the Part B, including the necessary technical reviews
and supporting information needed in the Administrative Record.

ENFORCEABILITY.   In general, to enhance clarity and enforceability,  it
helps to ask and answer, for each permit condition, the following
questions:  WHAT?, WHERE?, HOW?, WHEN?, BY WHOM?, and TO WHOM?  If a
permit condition does not clearly answer these questions, then the permit
condition may need to be modified to do so.  These questions should be
asked of all permit attachments (Part B items incorporated by reference),
as well as the permit conditions.  [See also the discussion on
specificity versus flexibility in the next section on INCORPORATION OF
PART B ITEMS INTO PERMIT.]

INCORPORATION OF PART B ITEMS INTO PERMIT.  As discussed above, the Model
Permit incorporates, by reference, a number of items that should be in
Part B of the permit applications.  Some of these items are specifically
required by the 40 CFR Part 264 rules, as well as the Part 270 rules
(e.g., Facility Inspection Schedule; Contingency Plan; Closure Plan;
Post-Closure Plan).   It is entirely appropriate  (if well written,
comprehensive, technically sound, and enforceable) to incorporate these
items by specific reference.

In some cases, the Permit Writer may want to incorporate other items that
are in the Part B, such as run-on/run-off control system designs and
liner and leachate collection and removal system designs, that are
required by 40 CFR Part 270 to demonstrate compliance with Part 264
performance standards.  These items can be incorporated by either placing
the specific information in the permit (as permit conditions) or by
referencing these items, and either attaching them to the permit, or in
some cases, including a specific reference to the item, in the Part B or
Administrative Record (e.g., for engineering drawings).

Three cautions are warranted here:  (1) the Permit Writer must be very
careful to make sure that only what is desired as a permit condition is
incorporated by reference,  (2) that the incorporated material says what
the Permit Writer wants it to say (e.g., it is enforceable as discussed
above), and (3) that the permit provide flexibility for modifications.
These are discussed below.

When incorporating,  by reference, items that are in Part B of the permit
application, the Permit Writer needs to make sure that the reference
includes a concise description of each item, including, as appropriate,
the document title,  number, and date, and any updates or amendments to
the item.  This is particularly true of Part B items that have undergone
substantial revisions, including replacements, addenda, and errata.  In
general, it is best to have a consolidated, updated document to
reference, rather than an original document that has a number of
replacements, addenda, or errata.  Where practical, it is also best to
attach to the permit all items incorporated by reference.
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If the Part B material the Permit Writer wants to incorporate does not
contain the information the Permit Writer wants it to, then, as discussed
above, the Permit Writer needs to get the owner/operator to revise it.
Otherwise, the Permit Writer will have to draft the appropriate permit
condition to overcome the deficiency.

It is desirable, for enforcement purposes, for a permit to be very
detailed (e.g., to include design specifications from the Part B).
However, the more detailed a permit is, the more restrictive it becomes.
In some cases, such restrictiveness can be counterproductive.  For
example, it could unnecessarily delay implementation of environmentally
desirable changes, such as installation of monitoring wells, level
controls, or leachate sump pumps.  Such actions may be technically
necessary or desirable but for procedural and legal reasons must be
foregone or postponed since, in order to stay in compliance with the
permit, the Permittee must seek and get approval of a permit modification
before making any desirable or necessary changes.

Such changes may be precipitated by:  (1) obsolescence (e.g., the
manufacturer goes out of business or discontinues the specified model),
(2) a desire to upgrade (e.g., a thicker liner, a greater capacity pump),
(3) cost (e.g., the availability of a comparable or better model that is
cheaper), (4) new performance information (e.g., that shows another model
to be superior), (5) a new technically improved model (e.g., a new
material), or (6) a change in personnel or procedure (e.g., a change in
person identified in the contingency plan as responsible for responding
to emergencies).  For example, it may be desirable or necessary to
replace the "XYZ Company Model 15" 50 gpm cast iron, manually activated
leachate sump pump with an activated leachate sump pump (an available
pump that the manufacturer still services, of greater capacity, of better
material, with better controls,  and more reliable).  A good solution to
this dilemma is to include the detailed specifications in the permit
conditions,  but also to provide flexibility by permit language that
allows changes.  Such language could state that for changes to items in
the permit,  the owner/operator must notify EPA (usually in advance) and
follow the permit modification rules, which are currently being revised
(i.e., some changes can be made by notice without EPA approval, or
proposed changes can be made upon notification and approval, or after no
word from EPA by a certain date,  and some changes can only be made by
notice to EPA and formal permit modification, including public notice and
comment, at the other extreme).

The substitution of an equivalent or better device or of a different
contact person for emergencies could be examples of the first extreme.
Model Permit conditions I.E.10.  and I.E.11.  address Permittee reporting
requirements for facility changes and condition I.B.I, addresses causes
for permit modifications.

At the back of each module is a list of the Part B items referenced in
that module.  In general,  these items should be attached to the permit.
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USE OF COMPLIANCE SCHEDULES IN THE PERMIT.   Under Section 270.33, the
permit may specify a schedule of compliance leading to compliance with
the Act and regulations.  Any schedule of compliance must require the
facility to come into compliance as soon as possible, and specify the
compliance date.  If the compliance schedule is for more that one year,
it must include interim requirements and dates.  The time between interim
dates shall not exceed one year, except if a task is not readily
divisible into stages of less than one year to complete, then submission
of progress reports by interim dates shall be required.

Compliance schedules are appropriate to allow facilities to come into
compliance with HSWA requirements and Part 264 standards, if they are not
already required under Parts 265 or 270 (e.g., for installation of liners
and LCRSs).  In general, compliance schedules should not be used in
permits to secure compliance with Parts 265 or 270, to the extent such
requirements are relevant to the permit issuance.  This is especially
true of requirements upon which other conditions are based, such as a
lack of adequate hydrogeologic assessment to determine ground-water
monitoring system design.  NODs, compliance orders, and permit denials
are generally more appropriate for these deficiencies.

USE OF "OMNIBUS" PROVISION.  The conditions listed within each module of
this Model Permit should cover most situations.  However, under authority
of Section 3005(c)(3) of RCRA [which was added by Section 212 of HSWA and
codified as 40 CFR 270.32(b)(2)], Permit Writers can add terms and
conditions that are not final regulations in Part 264 or Part 270, if
they determine that such conditions are necessary to protect human health
and the environment for that facility.  This is referred to as the
"omnibus" provision.  For example, Permit Writers might want to add
provisions in the ground-water monitoring modules for:  (1) unsaturated
zone monitoring (where depth or flow time to the water table is
relatively great and the hydrogeologic setting is quite complex); (2)
saturated zone monitoring in a low permeability (confining) zone above an
aquifer; (3) air monitoring for certain volatile organics; or (4) well
abandonment.  The statement of basis or Fact Sheet accompanying the
permit must explain the basis or rationale for these conditions, and the
Administrative Record must document the basis.

The legislative history pertaining to the "omnibus" provision suggests
that an appropriate use of this provision is to add conditions to a
permit that reflect proposed or pending rules.  That way, the permit will
not have to be modified when the rule is finalized.  Again, the omnibus
provision should be used only where it is deemed necessary to protect
human health and the environment.  In deciding on whether to include such
a provision and in crafting the language for the provision, the Permit
Writer should assess the probability that the rule will be finalized as
written and that the condition is needed, in the short term, in the
permit to protect human health and the environment.

AUTOMATIC INCORPORATION OF HSWA ITEMS INTO PERMIT.  In several instances,
HSWA imposes self-implementing requirements that apply to certain
facilities, regardless of what their current permit conditions say.  40
CFR 270.4 has been amended (52 FR 45788, December 1, 1987) to clarify
                               - 6 -

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that compliance with a RCRA permit constitutes compliance with Subtitle C
of RCRA, except for HSWA self-implementing requirements.  That is, the
permit does not shield the facility from these requirements.   There is no
need to reopen or modify the existing permits to incorporate these
provisions, unless a variance is sought (where the statute provides for a
variance).   The reason is that these requirements go into effect by
statute (e.g., the ban on bulk liquids in landfills and regulations
promulgated under 40 CFR Part 268 restricting the placement of hazardous
wastes in or on the land).  Thus, the land disposal restrictions are
fully enforceable, notwithstanding contrary or absent permit provisions
concerning land disposal.

For land disposal permits that are now being drafted, it is not necessary
(but is recommended) to provide permit conditions regarding the
applicability of the land disposal restrictions, since they apply
automatically.  For the land disposal restriction rules already issued
and permits issued after additional rules are finalized, it is
recommended that the applicable conditions be incorporated into the
permit.  However, whether or not such conditions are included, the Fact
Sheet should briefly describe the effect of new land disposal restriction
requirements for the benefit of the public and the facility
owner/operator.

ADMINISTRATIVE RECORD.  Because the Administrative Record is the official
documentation explaining the basis of permit conditions and the only
supporting evidence that EPA can use during appeals of permit decisions,
the RCRA Permit Quality Protocol includes a chapter on Administrative
Records.  The chapter includes a checklist for Administrative Record
content.

Example #1:  Regarding run-on and run-off, the regulations require:

   " (f) The owner or operator must design, construct,  operate, and
     maintain a run-on control system capable of preventing flow onto the
     active portion of the landfill during peak discharge from at least a
     25-year storm.
     (g) The owner or operator must design, construct,  operate, and
     maintain a run-off management system to collect and control at least
     the water volume resulting from a 24-hour, 25-year storm.
     (h) Collection and holding facilities (e.g., tanks or basins)
     associated with run-on and run-off control systems must be emptied
     or otherwise managed expeditiously after storms to maintain design
     capacity of the system." [40 CFR 264.301]

This is a design and operation performance standard, as are many of the
Part 264 requirements, which provides flexibility to the permit applicant
but also requires a substantial amount of information to be supplied and
evaluated.   For this run-on/run-off example,  the applicant must provide:
design specifications (e.g.,  dimensions and locations of dikes, berms,
culverts,  basins, and tanks,  etc., for both the run-on and run-off
systems);  operating plans (e.g.,  how run-off will be treated and
discharged; how tank or basin levels will be controlled);  and any test
and analysis information to support the design or operating procedures
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and to show they meet the performance standards (e.g.,  peak
flow/discharge and maximum volume calculations, based on watershed size,       
shape, slope, and surface, etc., to show that the size  of the culverts,       ^
tanks, pumps, etc. are large enough to handle the 25-year storm).  During
the permit application review process, the Permit Writer makes sure the
application is complete,  and that the design and operating plans are
technically sound and meet the performance standards.   This evaluation
may include independent analyses and/or a check on the  calculations
presented by the applicant.  The "Permit Condition Evaluation Guidance"
in the Protocol includes a discussion of evaluation criteria for the
design, construction, and operating plans for run-off controls, including
supporting calculations and references for further information on how to
evaluate these.  Three EPA-developed references are given:  the "Permit
Applicants' Guidance Manual" (1984), the "Permit Writers' Guidance
Manual" (1983), and the "Construction Quality Assurance Manual" (1985),
each of which has detailed technical discussions and provides further
references.  The Permittee and Permit Writer analyses to support the
determination of regulatory compliance need to be placed in the
Administrative Record [see discussion of Administrative Record in the
Protocol].

Once the permit application is complete, is judged technically sound and
protective, and meets the performance standards, the task of writing the
permit is greatly simplified.  Continuing with the run-on/run-off
example, the respective Model Permit conditions specify:

   " The permittee shall design, construct, operate, and maintain a run-
     on control system...[and] run-off management system... in accordance
     with the design plans, specifications, and operating practices
     contained in Permit Attachment[s]...[from Part B of the permit
     application]."

   " The Permittee shall empty or otherwise manage run-on and run-off
     collection and holding facilities to maintain the design capacity of
     the systems(s), in accordance with the design plans and operating
     practices specified  in Permit Attachment[s]...[from Part B of the
     permit application]."

Clearly, if this approach is used (i.e., including, by reference,
portions of the permit (Part B) application), it simplifies the permit
and writing the permit, but requires that the Part B be complete, clear,
unambiguous, and correct.  It also helps if the Part B doesn't contain
superfluous information.  Since the Part B is written by the Permittee,
and often by a consultant or number of specialized consultants hired by
the Permittee, the Part B may not meet these criteria.   One way to
correct this is to have the Permittee revise the Part B, which typically
means a detailed review and perhaps even a rewrite of portions by the
Permit Writer.  (Generally, the Permit Writer should not write portions
of the permit application, but on occasion some drafted or suggested
language in review comments by the Permit Writer is more expeditious and
helpful than a critical statement.)  Or the Permit Writer may need to
incorporate only relevant portions of the Part B, and/or provide the
needed language directly  in the permit.

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Example #2:  Regarding leachate collection and removal systems (LCRSs),
the regulations require:

   " A leachate collection -and removal system immediately above the liner
     that is designed, constructed, maintained, and operated to collect
     and remove leachate from the landfill.  The Regional Administrator
     will specify design and operating conditions in the permit to ensure
     that the leachate depth over the liner does not exceed 30 cm (one
     foot).  The leachate collection and removal system must be:
          (i) Constructed of materials that are:
               (A)  Chemically resistant to the waste managed in the
                    landfill and the leachate expected to be generated;
                    and
               (B)  Of sufficient strength and thickness to prevent
                    collapse under the pressures exerted by overlying
                    wastes, waste cover materials, and by any equipment
                    used at the landfill; and
          (ii) Designed and operated to function without clogging through
               the scheduled closure of the landfill." [40 CFR
               264.301(a)(2)]

Regarding the LCRS,  the codified HSWA rules state:

   " (c) The owner or operator...must install...a leachate collection
     system above and between the liners...[that] protects[s] human
     health and the environment." [40 CFR 264.301(c)]

As in the run-on/run-off example, both of these are design and operation
performance standards, which provide flexibility to the permit applicant
but also require a substantial amount of information to be supplied and
evaluated.  Although the above HSWA language essentially replaced
264.301(a)(2), and the HSWA language is more vague, in practice, the
264.301(a)(2) language is being applied to meet the HSWA performance
standard, except that the one-foot head requirement is viewed as a
longer-duration maximum that may be exceeded temporarily upon major storm
events.  At any rate, the information and evaluation needs are the same.
That is, the applicant must provide:  design specifications (e.g., to
determine the head or to show compliance with the one-foot head
requirement, the design must specify:  thickness of drainage layer,
permeability of drainage layer, slope of drainage layer bottom,  length of
run or distance between drainage sumps, permeability of bottom layer, and
sump removal rate);  operating plans (e.g., will the sumps be
automatically activated and how,  or will they be manually inspected and
activated and at what frequency,  etc.); and any test and analysis
information (e.g., leachate/drainage layer compatibility test results;
weight/compressibility analyses;  leachate generation and impingement rate
analyses, in conjunction with the design, to show compliance with the
one-foot head).  As in the previous example,  during the permit
application review process, the Permit Writer makes sure the application
is complete, and that the design and operating plans are technically
sound and meet the performance standards.  This evaluation may include
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independent analyses and/or a check on the calculations presented by the
applicant.  Again, these supporting calculations need to be placed in the
Administrative Record.

Once the permit application is complete and is judged technically sound
and protective, the task of writing the permit is greatly simplified.
Continuing with the LCRS example, the Model Permit condition simply
states:

   " The Permittee shall install... two leachate collection and removal
     systems... in accordance with the design plans and reports contained
     in Permit Attachment VIII-1."

The Model Permit then contains the following two notes to the Permit
Writer:

   o "Detailed design drawings of...the leachate collection and removal
     system and engineering reports contained in Permit Attachment VIII-
     .1,  must demonstrate how the Permittee will meet all of the
     requirements of 40 CFR 264.301(c)."
   o "The Permit Writer should provide a brief description of
     the...leachate collection and removal system (e.g., construction
     materials, thickness and permeability of drainage layer).  Example
     language is as follows: ...The leachate collection and removal
     system shall consist of a drainage tile system, embedded in a course
     sand media of 1x10"^ cm/sec or greater permeability, discharging to
     a sump with a level-controlled positive displacement pump,
     discharging to Tank 002 for subsequent testing and discharge to
     NPDES-regulated Outfall 002 or to the leachate treatment system."

Clearly,  it is very important that the referenced LCRS design and
operating plans be complete, clear, and technically sound.
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                  III.   INSTRUCTIONS  FOR USE OF GUIDANCE

In developing a permit for a specific facility,  Permit Writers should
include the permit cover or authorization sheet and Modules I (General
Permit Conditions) and II (General Facility Conditions).   In addition,
any other modules (e.g., tank systems, landfills) that pertain to the
facility should be included.  Omit the others and renumber the remaining
modules accordingly.

The modules contain bracketed items.   These are either:  (1) citations
from the Act (RCRA/HSWA) or RCRA regulations (i.e.,  from 40 CFR Parts
260-264, 266, 268, 270, and 124) and should be included in the permit
(States should substitute or add their own citations); (2) optional
language or alternatives that require the Permit Writer to select the
appropriate words; or (3) explanatory notes (in bold type) that give
guidance but should not be included as part of the actual permit.

The major HSWA provisions are also identified in each module to help
Permit Writers decide which provision should be addressed by EPA or State
Permit Writers where a State is only partially authorized.

APPLICABILITY TO STATE PERMITS.  The Model Permit can be used by State
Permit Writers as well as EPA Permit Writers.   It will be particularly
useful in those States whose regulations closely mirror EPA's.
Appropriate State-specific terms will need to be substituted for EPA-
specific terms such as "Regional Administrator."  State Permit Writers
will also need to add or revise permit conditions for any State
regulatory requirements that are broader in scope, more stringent, or
otherwise different than the Federal requirements.
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              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                 PERMIT
                FOR A HAZARDOUS WASTE MANAGEMENT FACILITY
Permittee	   Facility Identification
         	     Number	 	
                                   Permit Number
Pursuant to the Solid Waste Disposal Act,  as amended by the Resource
Conservation and Recovery Act of 1976, as amended (42 USC 6901 et seq..
commonly known as RCRA) and regulations promulgated thereunder by the
U.S. Environmental Protection Agency (EPA) (codified and to be codified
in Title 40 of the Code of Federal Regulations), a Permit is issued to
[insert name of the Permittee] 	 (hereafter called
the Permittee), to operate a hazardous waste [choose applicable
management method:  treatment, storage, and/or disposal] facility located
in  [insert name of city and state] 	,  on [insert street
address] 	,  at latitude 	 and longitude 	,
summarily described as follows:

[Note:  The Permit Writer should insert a brief description of the
facility here.  This description should contain the following
information:  a summary of the types of waste management units (e.g.,
tanks, landfills) permitted; whether or not the facility is required to
conduct ground-water monitoring; how closure will be accomplished (e.g.,
clean closure or closure in place); the types of waste management units
(tanks, waste pile, surface impoundment, landfill, or land treatment
units) that may require post-closure; whether the facility is or will be
taking corrective action; and whether the Permit includes any compliance
schedules.  Note also any special features associated with the operation
and associated permit conditions.]
The Permittee must comply with all terms and conditions of this Permit.
This Permit consists of the conditions contained herein (including those
in any attachments) and the applicable regulations contained in 40 CFR
Parts 260 through 266, 270, and 124, as specified in the Permit.
Applicable regulations are those which are in effect on the date of
issuance of the Permit, in accordance with 40 CFR 270.32(c).

This Permit is based on the assumption that the information submitted in
the Part B Permit Application attached to the Permittee's letter dated
	, as modified by subsequent amendments [dated 	 and
	], (hereafter referred to as the Application) is accurate and that
the facility will be  [constructed and] operated as specified in the
Application.

Any inaccuracies found in the submitted information may be grounds for
the termination, revocation and reissuance, or modification of this
Permit in accordance with 40 CFR 270.41, 270.42,  and 270.43 and for
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enforcement action.  The Permittee must inform EPA of any deviation from
or changes in the information in the application which would affect the
Permittee's ability to comply with the applicable regulations or permit
conditions.

This Permit is effective as of 	,  19	 and shall remain in effect
until 	,  19	 unless revoked and reissued under 40 CFR 270.41,
terminated under 40 CFR 270.43,  or continued in accordance with
270.51(a).

[Note:  For land disposal facilities, add the following condition.]

This Permit shall be reviewed by the Regional Administrator five years
after the date of Permit issuance or reissuance and shall be modified as
necessary, as provided in 40 CFR 270.41.  [40 CFR 270.50(d)]

	            	[Signature]	
       Date                        [Insert name and title of person
                                   authorized to issue the Permit]
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                                                           September 1988
                  MODULE  I  -  GENERAL  PERMIT  CONDITIONS

[Note:  This permit module contains the general conditions required for
all RCRA permits by 40 CFR Part 270.  This module must be included in all
RCRA Permits, except the following optional permit conditions:  I.E.12,
I.E.14, and I.I.]

[Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]

I.A. EFFECT OF PERMIT

The Permittee is allowed to [insert appropriate method:   treat, store,
and/or dispose on-site] hazardous waste in accordance with the  conditions
of this Permit.   Any [storage, treatment, and/or disposal] of hazardous
waste not authorized in this Permit is prohibited.  Subject to  40  CFR
270.4, compliance with this Permit generally constitutes compliance,  for
&2purposes of enforcement, with Subtitle C of RCRA.  Issuance of this
Permit does not convey any property rights of any sort or any exclusive
privilege; nor does it authorize any injury to persons or property,  any
invasion of other private rights, or any infringement of state  or  local
law or regulations.   Compliance with the terms of this Permit does not
constitute a defense to any order issued or any action brought  under
Sections 3008(a), 3008(h), 3013, or 7003 of RCRA; Sections 106(a), 104 or
107 of the Comprehensive Environmental Response, Compensation,  and
Liability Act of 1980 (42 U.S.C. 9601 et seq..  commonly known as CERCIA),
or any other law providing for protection of public health or the
environment. [40 CFR 270.4,  270.30(g)]

I.E. PERMIT ACTIONS

     I.B.I.    Permit Modification. Revocation and Reissuance.  and
               Termination

               This Permit may be modified,  revoked and reissued,  or
               terminated for cause, as specified in 40 CFR 270.41,
               270.42,  and 270.43.  The filing of a request for a  permit
               modification, revocation and reissuance, or termination,
               or the notification of planned changes or anticipated
               noncompliance on the part of the Permittee, does not  stay
               the applicability or enforceability of any permit
               condition.   [40 CFR 270.4(a)  and 270.30(f)]
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                                                           September 1988
     I.B.2.     Permit Renewal

               This Permit may be renewed as specified in 40 CFR
               270.30(b) and Permit Condition I.E.2.   Review of any
               application for a Permit renewal shall consider
               improvements in the state of control and measurement
               technology, as well as changes in applicable regulations.
               [40 CFR 270.30(b), HSWA Sec. 212]

I.C. SEVERABILITY

The provisions of this Permit are severable, and if any provision of this
Permit, or the application of any provision of this Permit to any
circumstance is held invalid, the application of such provision to other
circumstances and the remainder of this Permit shall not be affected
thereby. [40 CFR 124.16(a)]

I.D. DEFINITIONS

For purposes of this Permit, terms used herein shall have the same
meaning as those in 40 CFR Parts 124, 260, 264, 266,  268, and 270, unless
this Permit specifically provides otherwise; where terms are not defined
in the regulations or the Permit, the meaning associated with such terms
shall be defined by a standard dictionary reference or the generally
accepted scientific or industrial meaning of the term.  "Regional
Administrator" means the Regional Administrator of EPA Region 	,  or
his designee or authorized representative.

I.E. DUTIES AND REQUIREMENTS

     I.E.I.    Duty to Comply

               The Permittee shall comply with all conditions of this
               Permit, except to the extent and for the duration such
               noncompliance is authorized by an emergency Permit.  Any
               Permit noncompliance, other than noncompliance authorized
               by an emergency Permit, constitutes a violation of RCRA
               and is grounds for enforcement action; for Permit
               termination, revocation and reissuance, or modification;
               or for denial of a Permit renewal application. [40 CFR
               270.30(a)]

     I.E.2.    Duty to Reapply

               If the Permittee wishes to continue an activity allowed by
               this Permit after the expiration date of this Permit, the
               Permittee  shall submit a complete application for a new
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                                                      September 1988
          Permit at least 180 days prior to Permit expiration.  [40
          CFR 270.10(h), 270.30(b)]

I.E.3.    Permit Expiration

          Pursuant to 40 CFR 270.50,  this Permit shall be effective
          for a fixed term not to exceed ten years.   As long as EPA
          is the Permit-issuing authority,  this Permit and all
          conditions herein will remain in effect beyond the
          Permit's expiration date, if the Permittee has submitted a
          timely, complete application (see 40 CFR 270.10, 270.13
          through 270.29) and, through no fault of the Permittee,
          the Regional Administrator has not issued a new Permit, as
          set forth in 40 CFR 270.51.

I.E.4.    Need to Halt or Reduce Activity Not a Defense

          It shall not be a defense for the Permittee, in an
          enforcement action that it would have been necessary, to
          halt or reduce the Permitted activity in order to maintain
          compliance with the conditions of this Permit. [40 CFR
          270.30(c)]

I.E.5.    Duty to Mitigate

          In the event of noncompliance with this Permit, the
          Permittee shall take all reasonable steps to minimize
          releases to the environment and shall carry out such
          measures, as are reasonable,  to prevent significant
          adverse impacts on human health or the environment. [40
          CFR 270.30(d)]

I.E.6.    Proper Operation and Maintenance

          The Permittee shall at all times properly operate and
          maintain all facilities and systems of treatment and
          control (and related appurtenances) which are installed or
          used by the Permittee to achieve compliance with the
          conditions of this Permit.   Proper operation and
          maintenance includes effective performance, adequate
          funding, adequate operator staffing and training, and
          adequate laboratory and process controls,  including
          appropriate quality assurance/quality control procedures.
          This provision requires the operation of back-up or
          auxiliary facilities or similar systems only when
          necessary to achieve compliance with the conditions of
          this Permit. [40 CFR 270.30(e)]
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                                                      September 1988
I.E.7.     Duty to Provide Information

          The Permittee shall furnish to the Regional Administrator,
          within a reasonable time,  any relevant information which
          the Regional Administrator may request to determine
          whether cause exists for modifying, revoking and
          reissuing, or terminating this Permit, or to determine
          compliance with this Permit.  The Permittee shall also
          furnish to the Regional Administrator, upon request,
          copies of records required to be kept by this Permit. [40
          CFR 264.74(a), 270.30(h)]

I.E.8.     Inspection and Entry

          Pursuant to 40 CFR 270.30(i), the Permittee shall allow
          the Regional Administrator, or an authorized
          representative, upon the presentation of credentials and
          other documents, as may be required by law, to:

     I.E.8.a.  Enter at reasonable times upon the Permittee's
               premises where a regulated facility or activity is
               located or conducted, or where records must be kept
               under the conditions of this Permit;

     I.E.S.b.  Have access to and copy, at reasonable times, any
               records that must be kept under the conditions of
               this Permit;

     I.E.S.c.  Inspect at reasonable times any facilities, equipment
               (including monitoring and control equipment),
               practices, or operations regulated or required under
               this Permit; and

     I.E.S.d.  Sample or monitor, at reasonable times, for the
               purposes of assuring Permit compliance or as
               otherwise authorized by RCRA, any substances or
               parameters at any location.

I.E.9.     Monitoring and Records

     I.E.9.a.  Samples and measurements taken for the purpose of
               monitoring shall be representative of the monitored
               activity.  The method used to obtain a representative
               sample of the waste to be analyzed must be the
               appropriate method from Appendix I of 40 CFR Part 261
               or an equivalent method approved by the Regional
               Administrator.  Laboratory methods must be those
               specified in Test Methods for Evaluating Solid Waste:

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                                                      September 1988
               Physical/Chemical Methods SW-846.  Standard Methods o
               Wastewater Analysis, or an equivalent method, as
               specified in the Waste Analysis Plan (See Permit
               Attachment II-l).   [40 CFR 270.30(j)(1)]

     I.E.9.b.  The Permittee shall retain records of all monitoring
               information, including all calibration and
               maintenance records and all original strip chart
               recordings for continuous monitoring instrumentation,
               copies of all reports and records required by this
               Permit, the certification required by 40 CFR
               264.73(b)(9),  and records of all data used to
               complete the application for this Permit for a period
               of at least 3 years from the date of the sample,
               measurement, report, record, certification,  or
               application.  These periods may be extended by
               request of the Regional Administrator at any time and
               are automatically extended during the course of any
               unresolved enforcement action regarding this
               facility.  [For tanks and land treatment,  storage, and
               disposal units:  The Permittee shall maintain records
               from all ground-water monitoring wells and associated
               ground-water surface elevations for the active life
               of the facility, and for disposal facilities for the
               post-closure care period as well.] [40 CFR 264.74(b)
               and 270.30(j)(2)]

          I.E.9.C.  Pursuant to 40 CFR 270.30(j)(3),  records of
                    monitoring information shall specify:

               i.   The dates,  exact place, and times of sampling or
                     measurements;

               ii.  The individuals who performed the sampling or
                    measurements;

               iii.  The dates analyses were performed;

               iv.  The individuals who performed the analyses;

               v.   The analytical techniques or methods used;  and

               vi.  The results of such analyses.

I.E.10.    Reporting Planned Changes

          The Permittee shall give notice to the Regional
          Administrator,  as soon as possible, of any planned

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                                                      September 1988
          physical alterations or additions to the Permitted
          facility.  [40 CFR 270.30(1)(1)]

I.E.11.    Reporting Anticipated Noncompliance

          The Permittee shall give advance notice to the Regional
          Administrator of any planned changes in the permitted
          facility or activity which may result in noncompliance
          with permit requirements.  [40 CFR 270.30(1)(2)]

I.E.12.    Certification of Construction or Modification

          [Note:  This condition only applies if the facility is
          new, modified, or contains,  or will contain, new units,
          unit expansions, or modified units.  Delete this condition
          if the Permit is for an existing facility containing
          existing units only.]

          The Permittee may not commence [insert appropriate method:
          treatment, storage, or disposal] of hazardous waste
          [insert as appropriate:  "at the facility" or "in the
          modified portion of the facility"] until the Permittee has
          submitted to the Regional Administrator, by certified mail
          or hand delivery, a letter signed by the Permittee and a
          registered professional engineer stating that the facility
          has been constructed or modified in compliance with the
          Permit; and

     I.E.12.a. The Regional Administrator has inspected the modified
               or newly constructed facility and finds it is in
               compliance with the conditions of the Permit; or

     I.E.12.b. The Regional Administrator has either waived the
               inspection or has not within 15 days notified the
               Permittee of his intent to inspect. [40 CFR
               270.30(1)(2>]

I.E.13.    Transfer of Permits

          This Permit is not transferable to any person, except
          after notice to the Regional Administrator.  The Regional
          Administrator may require modification or revocation and
          reissuance of the Permit pursuant to 40 CFR 270.40.
          Before transferring ownership or operation of the facility
          during its operating life, the Permittee shall notify the
          new owner or operator in writing of the requirements of 40
          CFR Parts 264 and 270 and this Permit.   [40 CFR
          270.30(1)(3), 264.12(c)]

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                                                      September 1988
I.E.14.   Twenty-Four Hour Reporting

     I.E.14.a. The Permittee shall report to the Regional
               Administrator any noncompliance which may endanger
               health or the environment.  Any such information
               shall be reported orally within 24 hours from the
               time the Permittee becomes aware of the
               circumstances.   The report shall include the
               following:

               i.    Information concerning release of any hazardous
                    waste  that may cause an endangerment to public
                    drinking water supplies.

               ii.  Any information of a release or discharge of
                    hazardous  waste,  or of a fire or explosion from
                    the hazardous waste management facility which
                    could  threaten the environment or human health
                    outside the facility.

     I.E.14.b. The description of the occurrence and its cause shall
               include:

               i.    Name,  address, and telephone number of the owner
                    or operator;

               ii.  Name,  address, and telephone number of the
                    facility;

               iii. Date,  time,  and type of incident;

               iv.  Name and quantity of materials involved;

               v.    The extent of injuries,  if any;

               vi.  An assessment of actual or potential hazards to
                    the environment and human health outside the
                    facility,  where this is applicable;  and

               vii. Estimated  quantity and disposition of recovered
                    material that resulted from the incident.

     I.E.14.C. A written submission shall also be provided within
               five days of the time the Permittee becomes aware of
               the circumstances.   The written submission shall
               contain a description of the noncompliance and its
               cause;  the  period(s) of noncompliance (including

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                                                           September 1988
                    exact dates and times);  whether the noncompliance has
                    been corrected; and,  if  not,  the anticipated time it
                    is expected to continue;  and steps taken or planned
                    to reduce,  eliminate,  and prevent recurrence of the
                    noncompliance.  The Regional Administrator may waive
                    the five-day written notice requirement in favor of a
                    written report within 15 days.   [40 CFR 270.30(1)(6)]

     I.E.15.   Other Noncompliance

               The Permittee shall report all other instances of
               noncompliance not otherwise required to be reported above,
               Permit Conditions I.E.10.  - 15., at the time monitoring
               reports are submitted.   The reports shall contain the
               information listed in Permit  Condition I.E.14 [40 CFR
               270.30(1)(10)]

     I.E.16.   Other Information

               Whenever the Permittee becomes aware that it failed to
               submit any relevant facts in the Permit application, or
               submitted incorrect information in a Permit application or
               in any report to the Regional Administrator, the Permittee
               shall promptly submit such facts or information. [40 CFR
               270.30(1)(11)]

I.F. SIGNATORY REQUIREMENT

All applications, reports, or information submitted to or requested by
the Regional Administrator, his designee,  or authorized representative,
shall be signed and certified in accordance  with 40 CFR 270.11 and
270.30(k).

I.G. REPORTS, NOTIFICATIONS. AND SUBMISSIONS TO THE REGIONAL
     ADMINISTRATOR

All reports, notifications, or other submissions which are required by
this Permit to be sent or given to the Regional Administrator should be
sent by certified mail or given to:
[Note:  Provide the address and telephone number of the Regional
Administrator or appropriate Regional Division Director.]
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                                                           September 1988
I.H. CONFIDENTIAL INFORMATION

In accordance with 40 CFR 270.12, the Permittee may claim confidential
any information required to be submitted by this Permit.

I.I. DOCUMENTS TO BE SUBMITTED PRIOR TO OPERATION

[Note:  Include here:  (1) requirements to submit any documents not
complete or ready at time of Permit issuance (e.g., an updated
Contingency Plan) and (2) the schedules for such submissions.]

1.   The Permittee shall submit the following documents to the Regional
     Administrator by the dates shown:

          Document                 Due Date
2.   Prior to operation, the Permittee shall submit as-built plans of the
     [insert units for which plans must be submitted] 	.   At a
     minimum, these plans shall indicate:  	.

[Note:  Insert any items which should be included on the as-built plans.
For example, for a container storage area, the as-built plans should
include:  (1) the dimensions of each storage bay; (2) stacking
arrangements for containers; and (3) aisle space in each bay.] [40 CFR
270.32, 270.33]

I.J. DOCUMENTS TO BE MAINTAINED AT THE FACILITY

The Permittee shall maintain at the facility, until closure is completed
and certified by an independent, registered professional engineer, the
following documents and all amendments, revisions and modifications to
these documents:

1.   Waste Analysis Plan, as required by 40 CFR 264.13 and this Permit.

2.   Inspection schedules,  as required by 40 CFR 264.15(b)(2) and this
     Permit.

3.   Personnel training documents and records,  as required by 40 CFR
     264.16(d) and this Permit.

4.   Contingency Plan, as required by 40 CFR 264.53(a) and this Permit.

5.   Operating record, as required by 40 CFR 264.73 and this Permit.

6.   Closure Plan, as required by 40 CFR 264.112(a) and this Permit.
                                  I - 9

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                                                           September 1988
[Note:  Under 40 CFR 264.197(c), 264.228(c) and 264.258(c), owners and
operators of certain tanks,  surface impoundments,  and waste piles must
have Contingent Closure Plans.   If the Permit will require the Permittee
to have a Contingent Closure Plan, then add the plan to this list.]

7.   Post-Closure Plan, as required by 40 CFR 264.118(a) and this Permit.

[Note:  Only owners and operators of disposal units are required to have
Post-Closure Plans.  Under 40 CFR 264.197(c), 264.228(c) and 264.258(c),
owners and operators of certain tanks, surface impoundments, and waste
piles must have Contingent Post-Closure Plans.  If the Permit will
require the Permittee to have a Contingent Post-Closure Plan, then add
the plan to this list.]

8.   Annually-adjusted cost estimate for facility closure  [and post-
     closure], as required by 40 CFR 264.142(d) [and 264.144(d)] and this
     Permit.

9.   All other documents required by Module I, Permit Condition E.9
      [insert as appropriate:  and Modules 	, Permit Conditions
                                                                               
                                  I -  10

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                                                           September 1988
                 MODULE II - GENERAL FACILITY CONDITIONS
[Note:  This permit module contains conditions covering the general
facility requirements of 40 CFR Part 264, Subparts B - H.  This module
must be included in all RCRA Permits, except that the following Permit
conditions are optional:  II.B.I, II.B.2, II.G, II.H, II.I.I, II.I.2,
II.I.3, II.I.4, II.K, and II.N.]

[Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]

II.A.     DESIGN AND OPERATION OF FACILITY

The Permittee shall construct, maintain and operate the facility to
minimize the possibility of a fire, explosion, or any unplanned, sudden
or nonsudden release of hazardous waste constituents to air, soil,  or
surface water which could threaten human health or the environment, as
required by 40 CFR 264.31.

II.B.     REQUIRED NOTICES

[Note:  Permit Condition B.I should be included in the Permit only if the
facility receives waste from a foreign source.  Permit Condition B.2
should be included in the Permit only if the facility receives waste from
off site.  If Permit Condition B.I is inapplicable, the Permit should
specify that the Permittee may not receive hazardous waste from a foreign
source.  Similarly, if Permit Condition B.2 is inapplicable, the Permit
should specify that the Permittee may not receive hazardous waste from
off site.]

     II.B.I.    Hazardous Waste Imports

               The Permittee shall notify the Regional Administrator in
               writing at least four weeks in advance of the date the
               Permittee expects to receive hazardous waste from a
               foreign source, as required by 40 CFR 264.12(a).   Notice
               of subsequent shipments of the same waste from the same
               foreign source in the same calendar year is not required.

     II.B.2.    Hazardous Waste from Off-Site Sources

               When the Permittee is to receive hazardous waste from an
               off-site source (except where the Permittee is also the
               generator), he must inform the generator in writing that
               he has the appropriate Permits, and will accept the waste
                                 II  - 1

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                                                           September 1988
               the generator is shipping.   The Permittee must keep a copy
               of this written notice as part of the operating record.
               [40 CFR 264.12(b)]

II.C.     GENERAL WASTE ANALYSIS

The Permittee shall follow the waste analysis procedures required by 40
CFR 264.13, as described in the attached Waste Analysis Plan, Permit
Attachment II-1.

The Permittee shall verify the analysis of each waste stream annually as
part of its quality assurance program, in accordance with Test Methods
for Evaluating Solid Waste: Physical/Chemical Methods. EPA Publication
SW-846, or equivalent methods approved by the Regional Administrator.  At
a minimum, the Permittee shall maintain proper functional instruments,
use approved sampling and analytical methods, verify the validity of
sampling and analytical procedures, and perform correct calculations.  If
the Permittee uses a contract laboratory to perform analyses, then the
Permittee shall inform the laboratory in writing that it must operate
under the waste analysis conditions set forth in this Permit.

[Note:  The waste analysis plan included in the Part B Permit Application
should be attached to the Permit.  As applicable, the plan must cover the
requirements of 40 CFR 264.17, 264.177, 264.198, 264.199, 264.229,
264.230, 264.256, 264.257, 264.272, 264.276, 264.281, 264.282, 264.312,
264.313, 264.314, 264.316, and 264.341.]

II.D.     SECURITY

The Permittee shall comply with the security provisions of 40 CFR
264.14(b)  [select either (1) or  (2) based upon the information in the
Part B Permit Application] and (c) and Permit Attachment II-2.

[Note:  Specific security provisions should be included in the Permit, if
necessary, to ensure compliance with 40 CFR 264.14(b). In addition,
specific security provisions needed to implement the performance standard
in 264.14(a) should be included in the Permit.  For example, specify  the
language of signs required by 264.14(c), if the facility is near the
Canadian or Mexican border.  If the Permittee successfully demonstrates,
in accordance with 40 CFR 264.14(a), that the security requirements in
264.14(b) and (c) are not necessary, a security permit condition is not
needed.  This demonstration must be documented in the Administrative
Record.]

II.E.     GENERAL INSPECTION REQUIREMENTS

The Permittee shall follow the inspection schedule set out in Permit
Attachment II-3.  The Permittee shall remedy any deterioration or
                                  II  -  2

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                                                           September 1988
malfunction discovered by an inspection, as required by 40 CFR 264.15(c).
Records of inspection shall be kept, as required by 40 CFR 264.15(d).

[Note:  The inspection schedules included in the Part B Permit
Application should be attached to the Permit.  As applicable, the
specific inspection requirements of 40 CFR 264.174, 264.193(i), 264.195,
264.226(b), 264.254(b), 264.273(g), 264.303(b), 264.347(b) and (c) must
be covered by the attached schedules.]

II.F.     PERSONNEL TRAINING

The Permittee shall conduct personnel training, as required by 40 CFR
264.16.  This training program shall follow the attached outline, Permit
Attachment II-4.   The Permittee shall maintain training documents and
records, as required by 40 CFR 264.16(d) and (e).

[Note:  The outline of personnel training included in the Part B Permit
Application should be attached to the Permit.  It must demonstrate how
the Permittee will comply with 264.16.]

II.G.     SPECIAL PROVISIONS FOR IGNITABLE. REACTIVE. OR INCOMPATIBLE
          WASTE

[Note:  This condition should be included in the Permit only if the
facility handles ignitable, reactive, or incompatible wastes.]

The Permittee shall comply with the requirements of 40 CFR 264.17(a).
The Permittee shall follow the procedures for handling ignitable,
reactive, and incompatible wastes set forth in Permit Attachment II-5.

[Note:  Permits must include specific handling procedures tailored to the
types of hazardous wastes to be treated, stored, or disposed at the
facility and the types of units in which the wastes will be handled.  The
procedures described by the Permittee in the Part B Permit Application
should be attached to the Permit.  In addition, permit conditions
specific to the units will be specified in the appropriate module of the
Permit.]

II.H.     LOCATION STANDARDS

[Note:  EPA is preparing guidance on locating hazardous waste management
facilities in sensitive locations, such as karst terrain.  If a facility
will be located in a sensitive area, the Permit Writer can insert permit
conditions deemed necessary to protect human health and the environment.
For example, more frequent facility inspections, special operating
restrictions, or construction of thicker floors or liners could be
required.  Such permit conditions are authorized by 40 CFR 270.3,
270.32(a), and 270.32(b)(2).]
                                  II  -  3

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                                                           September 1988
[Note:  For facilities located in a 100-year floodplain,  the Permit must
either set forth conditions by which the Permittee will meet the
requirements of 40 CFR 264.18(b) or contain a compliance schedule (see 40
CFR 270.14(b)(ll)(v) and 270.33).  These requirements do not apply to
existing surface impoundments, waste piles, land treatment units, and
landfills if the Permittee has demonstrated, in accordance with 40 CFR
264.18(b)(1)(ii), that there will be no adverse effects on human health
or the environment from washout.  This demonstration must be documented
in the Administrative Record.  If the facility is not located in a 100-
year floodplain, the Permit Writer should delete this provision from the
Permit and re-letter subsequent provisions accordingly (i.e.,  1 becomes
H).

Example permit conditions are provided below.  The first condition should
be placed in the Permit only if the Permittee will use flood proofing
and/or flood protection measures to prevent washout during a 100-year
flood.  The second condition should be included in the Permit only if the
Permittee will implement procedures to remove the waste from the facility
prior to arrival of 100-year flood waters.]

The Permittee shall [construct,] operate, and maintain the facility to
prevent washout of any hazardous waste by a 100-year flood, as required
by 40 CFR 264.18(b)(l) and as specified in the attached plans and
specifications, Permit Attachment II-6.

In the event of a 100-year flood, the Permittee shall remove all
hazardous waste, before flood waters can reach the facility, to a
location where the wastes will not be vulnerable to the flood waters, as
required by 40 CFR 264.18(b)(1)(i) and in accordance with the attached
100-year flood response procedures, Permit Attachment II-7.

II.I.     PREPAREDNESS AND PREVENTION

     II.I.I.   Required Equipment

               At a minimum, the Permittee shall maintain at the facility
               the equipment set forth in the Contingency Plan, Permit
               Attachment II-8. as required by 40 CFR 264.32.

                [Note:  The list of equipment required by 264.52(e) to be
               in the Contingency Plan must meet the requirements of
               264.32.  If the Permittee has successfully demonstrated,
               in accordance with 40 CFR 264.32, that any of the
               equipment is not required, the decision should be
               documented in the Administrative Record and Permit
               Condition II.I.I should be deleted.]
                                  II -  4

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                                                           September 1988
     II.I.2.   Testing and Maintenance of Equipment

               The Permittee shall test and maintain the equipment
               specified in Permit Condition II.I.I, as necessary, to
               assure its proper operation in time of emergency, as
               required by 40 CFR 264.33.

               [Note:  Specific testing and maintenance procedures needed
               to implement this condition should be included in the
               inspection schedule, Permit Condition II.E.]

     II.I.3.   Access to Communications or Alarm System

               The Permittee shall maintain access to the communications
               or alarm system, as required by 40 CFR 264.34.

               [Note:  If the Permittee has successfully demonstrated
               that such a device is not required under 40 CFR 264.32,
               the decision should be documented in the Administrative
               Record and Permit Condition 1.3 should be deleted.]

     II.I.4.   Required Aisle Space

               At a minimum, the Permittee shall maintain aisle space, as
               required by 40 CFR 264.35 and the attached plans and
               specifications,  Permit Attachment II-8A.

               [Note:  If the Permittee has successfully demonstrated
               that aisle space is not needed, the decision should be
               documented in the Administrative Record.  The "plans and
               specifications"  to be referenced here generally will be
               the design plans and specifications for the hazardous
               waste management units.]

     II.I.5.   Arrangements with Local Authorities

               The Permittee shall maintain arrangements with state and
               local authorities, as required by 40 CFR 264.37.  If state
               or local officials refuse to enter into preparedness and
               prevention arrangements with the Permittee, the Permittee
               must document this refusal in the operating record.

II.J.      CONTINGENCY PLAN

     II.J.I.   Implementation of Plan

               The Permittee shall immediately carry out the provisions
               of the Contingency Plan, Permit Attachment II-8 .  whenever
                                 II  - 5

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                                                           September 1988
               there is  a fire,  explosion,  or  release  of hazardous  waste
               or constituents which  could  threaten human health or the
               environment.

               [Note:  The contingency plan included in the Part B  Permit
               Application should be  attached  to the Permit.   As
               applicable, the plan must cover the requirements of  40 CFR
               264.200,  and 264.227(c).]
     II. J. 2.    Copies of Plan
               The Permittee shall comply with the requirements of 40 CFR
               264.53.

     II.J.3.    Amendments to Plan

               The Permittee shall review and immediately amend,  if
               necessary, the Contingency Plan,  as required by 40 CFR
               264.54.

     II.J.4.    Emergency Coordinator

               A trained emergency coordinator shall be available at all
               times in case of an emergency, as required by 40 CFR
               264.55.

               [Note:  For new facilities, add the following sentence to
               Permit Condition II.J.4.]

               The names, addresses, and phone numbers of all persons
               qualified to act as emergency coordinators shall be
               supplied to the Regional Administrator at the time of
               certification.  [40 CFR 264.52(d)].

U.K.      MANIFEST SYSTEM

The Permittee shall comply with the manifest requirements of 40 CFR
264.71, 264.72, and 264.76.

[Note:  This condition should be included in the Permit only if the
facility accepts off-site waste.]

ILL.    RECORDKEEPING AND REPORTING

In addition to the recordkeeping and reporting requirements specified
elsewhere in this Permit, the Permittee shall do the following:
                                  II  -  6

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                                                           September 1988
     II.L.I.   Operating Record
               The Permittee shall maintain a written operating record at
               the facility, in accordance with 40 CFR 264.73.
     II.L.2.   Biennial Report

               The Permittee shall comply with the biennial reporting
               requirements of 40 CFR 264.75.

II.M.     GENERAL CLOSURE REQUIREMENTS

[Note:  Owners and operators of certain tank systems, surface
impoundments, and waste piles are required to have contingent closure
plans by 40 CFR 264.197(c), 264.228(c), and 264.258(c), respectively.
For Permits for these facilities, insert "Contingent Closure Plan" after
Closure Plan and append the Contingent Closure Plan as Permit Attachment
11-10.  Be sure to renumber subsequent attachments.]

     II.M.I.   Performance Standard

               The Permittee shall close the facility, as required by 40
               CFR 264.111 and in accordance with the Closure Plan,
               Permit Attachment II-9.

               [Note:  The Closure Plan must meet the requirements of 40
               CFR 264.112(a) and (b).  The specific closure requirements
               of 264.178, 264.197, 264.228, 264.258, 264.280, 264.310,
               and 264.351 also must be covered by the attached plan.]

     II.M.2.   Amendment to Closure Plan

               The Permittee shall amend the Closure Plan,  in accordance
               with 40 CFR 264.112(c), whenever necessary.

     II.M.3.   Notification of Closure

               The Permittee shall notify the Regional Administrator in
               writing at least 60 days prior to the date on which he
               expects to begin closure of any of the following: [insert
               as appropriate:  surface impoundment, waste pile, land
               treatment unit, or landfill] or final closure of the
               facility,  as required by 40 CFR 264.112(d).

               [Note:  Permit Condition II.M.3 should be used for
               facilities using surface impoundments, waste piles, land
               treatment units, or landfills.  For facilities using only
                                 II  - 7

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                                                      September 1988
          tanks,  containers,  or incinerators,  substitute the
          following condition.]

          The Permittee shall notify the Regional Administrator in
          writing at least 45 days prior to the date on which he
          expects to begin final closure of the facility,  as
          required by 40 CFR 264.112(d).

II.M.4.    Time Allowed For Closure

          After receiving the final volume of hazardous waste, the
          Permittee shall treat, remove from the unit or facility,
          or dispose of on site all hazardous waste and shall
          complete closure activities,  in accordance with 40 CFR
          264.113 and the schedules specified in the Closure Plan,
          Permit Attachment II-9.

          [Note:   If the Permittee is granted a longer time frame
          for treating, removing,  or disposing of waste or for
          completing closure activities, the basis for granting the
          extra time must be documented in the Administrative
          Record.]

II.M.S.    Disposal or Decontamination of Equipment. Structures, and
          Soils

          The Permittee shall decontaminate [and/or] dispose of all
          contaminated equipment,  structures,  and soils, as required
          by 40 CFR 264.114 and the Closure Plan, Permit Attachment
          II-9.

II.M.6.    Certification of Closure

          The Permittee shall certify that the facility has been
          closed in accordance with the specifications in the
          Closure Plan, as required by 40 CFR 264.115.

II.M.7.    Survey Plat

          The Permittee shall submit a survey plat no later than the
          submission of certification of closure of each hazardous
          waste disposal unit,  in accordance with 40 CFR 264.116.

          [Note:   This Permit condition should be included only if
          the facility contains hazardous waste disposal units.]


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                                                           September 1988
II.N.     GENERAL POST-CLOSURE REQUIREMENTS

[Note:  Owners and operators of certain tank systems, surface
impoundments, and waste piles are required to have contingent post-
closure plans by 40 CFR 264.197(c), 264.228(c), and 264.258(c),
respectively.  For Permits for these facilities, insert "Contingent Post-
Closure Plan" after Post-Closure Plan and append the Contingent Post-
Closure Plan as Permit Attachment 11-12.  Be sure to renumber subsequent
attachments.]

     II.N.I.    Post-Closure Care Period

               The Permittee shall begin post-closure care for each
               [insert as appropriate:  tank system, surface impoundment,
               waste pile, land treatment unit, landfill] after
               completion of closure of the unit and continue for 30
               years after that date.   Post-closure care shall be in
               accordance with 40 CFR 264.117 and the Post-Closure Plan,
               Permit Attachment 11-11.

               [Note:  The Post-Closure Plan included in the Part B
               Permit Application should be attached to the Permit.  It
               must meet the requirements of 40 CFR 264.118(a) and (b).
               The specific post-closure requirements of 264.197,
               264.228, 264.258, 264.280, and 264.310 also must be
               covered by the attached plan.]

     II.N.2.    Post-Closure Security

               The Permittee shall maintain security at the facility
               during the post-closure care period, in accordance with
               the Post-Closure Plan,  Permit Attachment 11-11. and 40 CFR
               264.117(b).

               [Note:  This condition should be included in the Permit
               only if hazardous wastes may remain exposed after
               completion of closure,  or access by the public or domestic
               livestock may pose a hazard to human health.]

     II.N.3.    Amendment to Post-Closure Plan

               The Permittee shall amend the Post-Closure Plan in
               accordance with 40 CFR 264.118(d),  whenever necessary.

     II.N.4.    Post-Closure Notices

          II.N.4.a.  No later than 60 days after certification of closure
                    of each hazardous  waste disposal unit, the Permittee
                                 II - 9

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                                                           September 1988
                    shall  submit  records  of  the  type,  location,  and
                    quantity of hazardous waste  disposed within each cell
                    or  disposal unit,  in  accordance  with 40  CFR
                    264.119(a).

          II.N.4.b.  Within 60 days  of  certification  of closure of the
                    first  hazardous waste disposal unit and  the last
                    hazardous waste disposal unit, the Permittee shall do
                    the following:

                    i.   Record a notation on the  deed to the facility
                        property,  in  accordance with 40 CFR
                        264.119(b)(l).

                    ii. Submit a certification  that a notation, in
                        accordance with  40  CFR  264.119(b)(2), has been
                        recorded.

          II.N.4.C.  The Permittee shall  request  and  obtain a Permit
                    modification  prior to post-closure removal of
                    hazardous wastes,  hazardous  waste residues, liners,
                    or  contaminated soils,  in accordance with 40 CFR
                    264.119(c).

     II.N.5.    Certification of Completion  of Post-Closure Care

               The Permittee shall  certify  that  the  post-closure care
               period was  performed in accordance  with the specifications
               in the Post-Closure  Plan,  as  required by 40 CFR 264.120.

II.0.      COST ESTIMATE FOR FACILITY CLOSURE [ANP  POST-CLOSURE]

     II.0.1.    The Permittee's most recent  closure [insert as applicable
               "and post-closure"]  cost estimate,  prepared in accordance
               with 40  CFR 264.142   264.144, 264.197(c)(3) and (5),
               264.228(c)(2), and 264.258(c)(2], [is/are] specified in
               Permit Attachment  11-11.

     II.0.2.    The Permittee must adjust  the closure [and post-closure]
               cost estimate for  inflation  within  60 days prior to the
               anniversary date of  the establishment of the financial
               instrument(s) used to comply with 40  CFR 264.143 [and
               264.145] and Permit  Condition II.P  or when using an
               approved state-required mechanism,  upon such date as
               required by the state.  [40 CFR 264.142(b)]

               [Note:  If the Permittee is  using the financial test or
               corporate guarantee, substitute the following condition.]
                                 II - 10


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                                                           September 1988
               The Permittee must adjust the closure cost estimate [and
               post-closure cost estimate] for inflation within 30 days
               after the close of the firm's fiscal year and before
               submission of updated information to the Regional
               Administrator, as specified in 40 CFR 264.142(b) [and
               264.144(b)].

     II.0.3.   The Permittee must revise the closure cost estimate [and
               post-closure cost estimate] whenever there is a change in
               the facility's Closure Plan [and Post-Closure Plan], as
               required by 40 CFR 264.142(c) [and 264.144(c)].

     II.0.4.   The Permittee must keep at the facility the latest closure
               cost estimate [and post-closure cost estimate] as required
               by 40 CFR 264.142(d) [and 264.144(d)].

II.P.     FINANCIAL ASSURANCE FOR FACILITY CLOSURE [AND POST-CLOSURE]

The Permittee shall demonstrate continuous compliance with 40 CFR
[insert as appropriate 264.143, 264.145, 264.146] by providing
documentation of financial assurance,  as required by 40 CFR 264.151 or
264.149, in at least the amount of the cost estimates required by Permit
Condition II.0.  Changes in financial assurance mechanisms must be
approved by the Regional Administrator pursuant to 40 CFR 264.143
[,264.145] or 264.149.

[Note:  For new facilities, the Permittee shall demonstrate compliance
with this permit condition by submitting the required documentation to
the Regional Administrator at least 60 days before first receiving
hazardous waste for treatment,  storage or disposal.  [See, for example,
40 CFR 264.143(a)(l).]  The Permittee's financial assurance must be
effective prior to the Permittee's first receipt of hazardous waste.]

II.Q.     LIABILITY REQUIREMENTS

The Permittee shall demonstrate continuous compliance with the
requirement of 40 CFR 264.147(a) to have and maintain liability coverage
for sudden and accidental occurrences in the amount of at least $1
million per occurrence,  with an annual aggregate of at least $2 million,
exclusive of legal defense costs.

[Note:  For facilities containing surface impoundments, landfills, and
land treatment units, add the following condition.]

The Permittee also shall demonstrate continuous compliance with the 40
CFR 264.147(b) requirement to have and maintain liability coverage for
nonsudden accidental occurrences in the amount of at least $3 million per
                                 II - 11

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                                                           September 1988
occurrence, with an annual aggregate of at least $6 million,  exclusive of
legal defense costs.

[Note:  The Regional Administrator may grant a variance from the above
levels of financial responsibility in accordance with 40 CFR 264.147(c)
and (d).   For new facilities, the Permittee shall demonstrate its
compliance with this permit condition by submitting the required
documentation to the Regional Administrator at least 60 days before first
receiving hazardous waste for treatment or storage.  The Permittee's
liability coverage must be effective before the Permittee's first receipt
of hazardous waste,]

II.R.     INCAPACITY OF OWNERS OR OPERATORS. GUARANTORS. OR FINANCIAL
          INSTITUTIONS

The Permittee shall comply with 40 CFR 264,148, whenever necessary.
                                 II - 12

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                                                           September 1988
      PERMIT ATTACHMENTS REFERENCED IN MODULE II - GENERAL FACILITY
                                CONDITIONS

This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.   The Permit Writer may select
other numbering schemes, as appropriate, when preparing actual Permits.

   Permit
Attachment No.             	Plan or Document	
                           (from the Part B Permit Application)

1-1                        Waste Analysis Plan

II-2                       Security Plan

II-3                       Inspection Schedule

II-4                       Personnel Training Outline

II-5                       Procedures for Handling Ignitable, Reactive,
                           or Incompatible Waste

II-6                       Flood Proofing/Flood Protection Plans and
                           Specifications

II-7                       100-Year Flood Response Procedures

II-8                       Contingency Plan

II-8A                      Plans and Specifications showing the spacing
                           of aisles

II-9                       Closure Plan

11-10                      Contingent Closure Plan

11-11                      Post-Closure Plan

11-12                      Contingent Post-Closure Plan

11-13                      Closure Cost Estimate

11-14                      Post-Closure Cost Estimate
                                 II -  13

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                                                           September 1988
                         MODULE III - CONTAINERS

 [Note:  This permit module should be included when the Permittee is
 storing or treating hazardous waste in containers.  The Permit Writer
 should specify in the title whether this module is for storage or
 treatment in containers.  Waste analysis requirements (40 CFR 264.13) and
 closure requirements (40 CFR 264.178) for storage and treatment in
 containers normally are contained as attachments to the Permit in the
 Waste Analysis Plan and Closure Plan.]

 [Note:  In general, a single permit module should be used if multiple
 container areas will be covered by the same Permit for a given facility.
 However, it is acceptable to include multiple container modules if, in
 the Permit Writer's judgment, the characteristics and permit conditions
 for each area are sufficiently different to warrant multiple modules.]

 [Note:  The Permit Writer should refer to the RCRA Permit Quality
 Protocol for additional guidance in developing or reviewing permit
 conditions.  See discussion of the RCRA Permit Quality Protocol in the
 Introduction to this Model Permit.]

 III.A.    MODULE HIGHLIGHTS

 [The Permit Writer should include a general discussion of the activities
 covered by this module.  The discussion should contain the following
 information:  description and dimensions of each container area, maximum
 amount and type(s) of wastes that may be handled, description of the
 containers used, description and capacities of primary and secondary
 containment systems,  any unique or special features associated with the
 activity, and a reference to any special permit conditions.]

 III.B.    PERMITTED AND PROHIBITED WASTE IDENTIFICATION

     III.B.I.  The Permittee may 	 [specify store and/or treat]
               the following wastes in containers at the facility,
               subject to the terms of this Permit and as follows:

                                                   Maximum
 Description of    EPA Hazardous    Maximum     Number and Type
 Hazardous Waste   Waste Number     Volume       of Containers

 [Example:
 Waste Halogen-      F001          11,000       200 55-gal.
 ated Solvents                     gallons         drums]

 [Note:  Under "Description of Hazardous Waste," the Permit Writer should
provide only a brief generic description, not comprehensive
                                 III - 1

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                                                           September 1988
characteristics, where a Hazardous Waste Number Is provided for
reference.]

[Note:  If the location is critical, the Permit should also specifically
identify the location (e.g., room or storage hay) in which containers of
waste may be stored and/or treated.  For example, incompatible wastes
might be restricted to designated storage bays.]

     1II.B.2.  The Permittee is prohibited from storing or treating
               hazardous waste that is not identified in Permit Condition
               III.B.I.

[Note:  The Permit Writer may also include here a list of specific wastes
or materials that are prohibited.]

III.C.    CONDITION OF CONTAINERS

If a container holding hazardous waste is not in good condition (e.g.,
severe rusting, apparent structural defects) or if it begins to leak, the
Permittee shall transfer the hazardous waste from such container to a
container that is in good condition or otherwise manage the waste in
compliance with the conditions of this Permit.   [40 CFR 264.171]

III.D.    COMPATIBILITY OF WASTE WITH CONTAINERS

The Permittee shall assure that the ability of the container to contain
the waste is not impaired, as required.  [40 CFR 264.172]

[Note:  Specific procedures (e.g., testing of waste) or equipment
required to assure compliance with Permit Condition III.D. should be
Included in the Permit by inserting a specific condition or by attaching
procedures or equipment lists from the Part B Permit Application.]

III.E.    MANAGEMENT OF CONTAINERS

The Permittee shall keep all containers closed during storage, except
when it is necessary to add or remove waste, and shall not open, handle,
or store containers in a manner which may rupture the container or cause
it to leak.  [40 CFR 264.173]

III.F.    CONTAINMENT SYSTEMS

[Note:  This condition should be included in the Permit only if the
container area must have a secondary containment system under 40 CFR
264.175.]
                                 III - 2

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                                                           September 1988
The Permittee shall [construct and] maintain the containment system in
accordance with the attached plans and specifications, contained in
Permit Attachment III-l.  [40 CFR 264.175]

III.G.    INSPECTION SCHEDULES AND PROCEDURES

The Permittee shall inspect the container area weekly, in accordance with
the Inspection Schedule, Permit Attachment II-3.  to detect leaking
containers and deterioration of containers and the containment system
caused by corrosion and other factors.  [40 CFR 264.174]

III.H.    RECORDKEEPING

The Permittee shall place the results of all waste analyses and trial
tests [and any other documentation showing compliance with the
requirements of Permit Conditions III.K.I and III.K.2 and 40 CFR
264.17(b) and 264.177] in the facility operating record. [40 CFR 264.73]

III.I.    CLOSURE

At closure of the container area, the Permittee shall remove all
hazardous waste and hazardous waste residues from the containment system,
in accordance with the procedures in the Closure Plan, Permit Attachment
II-9. [40 CFR 264.178]

III.J.    SPECIAL CONTAINER PROVISIONS FOR IGNITABLE OR REACTIVE WASTE

[Note:  Permit Condition III.J should be included in the Permit only if
ignitable or reactive wastes will be stored or treated in containers or
is of concern (i.e., not prohibited in III.B.2.]

     III.J.I.  The Permittee shall not locate containers holding
               ignitable or reactive waste within 15 meters (50 feet) of
               the facility's property line.   [40 CFR 264.176]

     III.J. 2.  The Permittee shall take precautions to prevent accidental
               ignition or reaction of ignitable or reactive waste and
               follow the procedures specified in Permit Attachment
               III-2.   [40 CFR 264.17(a) and 264.176]

III.K.    SPECIAL CONTAINER PROVISIONS FOR INCOMPATIBLE WASTE

[Note:  Permit Condition III.K should be included in the Permit only if
incompatible wastes will be stored or is of concern at the facility.]

     III.K.I.  The Permittee shall not place incompatible wastes,  or
               incompatible wastes and materials,  in the same container
                                 III -  3

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                                                           September 1988
               unless the procedures in Permit Attachment III-3 are
               followed.   [40 CFR 264.177(a)]

     III.K.2.   The Permittee shall not place hazardous waste in an
               unwashed container that previously held an incompatible
               waste or material.  [40 CFR 264.177(b)]

     III.K.3.   The Permittee shall separate containers of incompatible
               wastes.  [40 CFR 264.177(c)]

               [Note:  The attached plans or procedures should address
               the layout of the hazardous waste storage facility, aisle
               space, and stacking height of containers holding ignitable
               and reactive wastes.  Note that the National Fire
               Protection Association's Flammable and Combustible Liquids
               Code recommends that containers of ignitable waste be
               stored no more than two high.]

III.L.    COMPLIANCE SCHEDULE

[Note:  The Permit Writer should include this section if the Permittee is
required to complete specific steps within a specific time period, beyond
those covered by other conditions of the Permit, as a criteria for
retaining this operating Permit.  Compliance schedules are generally used
in cases where requirements that are supposed to be met by the Permittee
before the Permit is issued are deferred for good cause until after
Permit issuance.  Appropriate compliance schedules included in the Part B
Permit Application should be attached to, or incorporated in, the Permit.
If the application does not include a compliance schedule, the Permit
Writer should prepare one and attach it to the Permit.  Each compliance
schedule should have at least two columns  - one identifying the activity
and one identifying the milestone or completion dates.  The following is
an example of a condition that may apply for a container area.]

The Permittee shall provide the following  information to the Regional
Administrator:

     Item                          Date Due to the Regional Administrator

      [Example:
     1.  Documentation that the                    June 26, 1989]
         surface of the containment
         system has been refinished
         with an impervious
         coating using the
         materials described in
         Specifications Section
         19A, dated 3/18/88
                                 III - 4

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I
                                                                         September  1988
                      PERMIT ATTACHMENTS REFERENCED IN MODULE III - CONTAINERS


             This  list  is provided  to assist the Permit Writer in  checking  that all
             Permit Attachments referenced  in this module are attached  to the Permit.
             The purpose of  the numbering scheme used here is to facilitate cross-
             walking with the model permit  conditions.  The Permit Writer may select
             other numbering schemes, as appropriate, when preparing  actual Permits.

             Permit Attachment No.      	Plan or Document	
                                         (from the Part B Permit Application)

             II-3                       Facility Inspection Schedule

             II-9                       Closure Plan

             III-l                     Secondary Containment Plans and Specifications

             III-2                     Ignitable or Reactive Waste Procedures

             III-3                     Incompatible Waste Procedures
                                              III - 5

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                                                           September 1988
                            MODULE  IV  -   TANKS

[Note:  This permit module should be included when the Permittee is
storing or treating hazardous waste in tanks.  The Permit Writer should
specify in the title whether the module is for storage and/or treatment
in tank systems.  This module is based on the federal tank rule published
in the Federal Register on July 14, 1986, and on relevant guidances and
policies issued to implement this rule.  The definitions of existing and
new tank systems under that rule are different from the definitions of
existing and new facilities for the purposes of determining eligibility
for interim status.  Existing tank systems are defined as tank systems in
operation on July 14, 1986, or for which installation commenced prior to
July 14, 1986.  A new tank system is defined as a tank system for which
installation commenced after July 14, 1986.]

[Note:  Waste analysis requirements (40 CFR 264.13) and closure
requirements (40 CFR 264.197) for tank systems are normally contained as
attachments to the Permit in the Waste Analysis Plan and Closure Plan.
Post-closure requirements for tank systems, when necessary (40 CFR
264.117), are contained in the Post-Closure permit module (Module XIII).]

[Note:  In general, a single permit module should be used if multiple
tank systems will be covered by the same Permit for a given facility.
However, it is acceptable to include multiple tank system modules if, in
the Permit Writer's judgment, the characteristics and permit conditions
for each tank system are sufficiently different to warrant multiple
modules.]

[Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]

IV.A.     MODULE HIGHLIGHTS

[The Permit Writer should include a general discussion of the activities
covered by this module.   The discussion should contain the following
information:   brief description of each tank system,  including feed
systems, safety cut-offs,  bypass systems, and pressure controls (e.g.,
valves); capacity of each tank system; whether the tank system (including
ancillary equipment) is  aboveground,  inground,  underground,  or onground;
age of existing tank system; general description of types of wastes
stored and/or treated;  brief description of any treatment processes;
description and capacity of the secondary containment system for each
tank system;  any unique  or special features associated with the activity;
and a reference to any special permit conditions.]
                                  IV  - 1

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                                                           September 1988
IV. B.
PERMITTED AND PROHIBITED WASTE IDENTIFICATION
     IV.B.I.   The Permittee may
               total volume of
                               [specify store and/or treat] a
                              gallons of hazardous waste in
               terms
            tanks [specify the number of tanks],  subject to the
           of this Permit and as follows:
Tank No.
                          Secondary
 Capacity   Dimensions   Containment
 (Gallons)   of Tank       Required
                            Description
                            of Hazardous  Hazardous
                                Waste     Waste No.
[Example:
 Tank System A:
 CF-101      8,000
             8 ft(diam)  yes-in place
             x 21 ft
                             Waste organic
                               solvents
F005
 Tank System B:
 CF-102
 CF-103
   8,000
  10,000
 8 ft(diam)  yes-due by      Wastewater
 x 21 ft     March 18,  1990    treatment
                               sludge

10 ft(diam)  yes-due by      Wastewater
 x 17 ft     March 18,  1990    treatment
                               sludge
                                                                   F006
                                                                   F006]
     IV.B.2.
     [Note:  Under "Description of Hazardous Waste," the Permit
     Writer should provide only a brief generic description,
     not comprehensive characteristics, where a Hazardous Waste
     Number is provided for reference.]

     The Permittee is prohibited from storing or treating
     hazardous waste that is not identified in Permit Condition
     IV.B.I.
[Note:  The Permit Writer may also include here a list of specific wastes
or materials that are prohibited.]
IV. C.
SECONDARY CONTAINMENT AND INTEGRITY ASSESSMENTS
[Note:  The Permit Writer should include Permit Condition IV.C.I. for
existing tank systems that do not have secondary containment.  If the
Permittee is granted a variance from secondary containment requirements
according to 40 CFR 264.193(g), Permit Condition IV.C.2. applies;
otherwise, the Permittee is subject to Permit Conditions IV.C.3. and
IV.C.4. for existing tanks (tanks used solely to store or treat hazardous
waste, which contain no free liquids and are situated inside a building
with an impermeable floor, and tanks, including sumps, as defined in 40
                                  IV  -  2

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                                                           September 1988
 CFR 260.10, that serve as part of a secondary containment system to
collect or contain releases of hazardous wastes are exempt from secondary
containment requirements.] [40 CFR 264.190(a)]

     IV.C.I.   For tank systems used to store or treat materials that are
               defined as hazardous waste in the future, the Permittee
               must obtain a written assessment of the existing tank
               system integrity within 12 months from the date the waste
               is defined as hazardous. [40 CFR 264.191(c)j   The
               assessment shall be certified by an independent,
               qualified, registered professional engineer.  [40 CFR
               264.191(a) and (b)]

     IV.C.2.   The Permittee shall design, construct, operate, and
               maintain the tank system according to the detailed plans
               and reports contained in Permit Attachment IV-1 to
               maintain the variance from the requirements for secondary
               containment.  [40 CFR 264.193(g) and 264.193(h)(4)]

               [Note:  The Permit Attachment for this condition must
               contain the detailed plans and engineering and
               hydrogeologic reports contained in the Part B Permit
               Application that demonstrate how the Permittee will meet
               the applicable requirements of 40 CFR 264.193(g).]

     IV.C.3.   The Permittee shall design, construct, and operate the
               secondary containment system,  in accordance with the
               detailed design plans and descriptions contained in Permit
               Attachment IV-2. [40 CFR 264.193(b)-(f)]

               [Note:  The Permit Attachment for this condition must
               contain the detailed plans and descriptions contained in
               the Part B Permit Application that demonstrate how the
               Permittee will meet the requirements of 40 CFR 264.193(b)-
               (f)-]

               [Note:  Because the time frame for requiring secondary
               containment varies with the age of the tank,  available
               documentation regarding the tank age, or the waste
               handled, the Permit Writer should specify the date by
               which secondary containment is required for each tank
               system.  The following are the required time frames for
               the various scenarios:  [40 CFR 264.193(a)]

               New tank systems or components - prior to their being put
               into service.

               Existing tanks handling F020.  F021. F022. F023. F026.
               and/or F027 Wastes - no later than January 12, 1989.

                                  IV  -  3

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                                                      September 1988
          Existing tank systems  with  documented age  -  no later than
          January 12,  1989  or when the  system reaches  15 years of
          age,  whichever comes later.

          Existing tank systems  where the  age cannot be documented -
          no later than January  12,  1995;  however,  if  the age of the
          facility is  greater than seven years, then secondary
          containment  must  be provided  by  the time  the facility
          reaches 15 years  of age or  by January 12,  1989, whichever
          comes later.

          For tank systems  that  store or treat materials that are
          defined hazardous in the future  -  within  the time
          intervals described above,  except  that the date the
          material is  defined a  hazardous  waste, plus  two years,
          shall be used in  place of January  12, 1989.]

IV.C.4.    The Permittee shall comply  with  the following conditions
          until such time as secondary  containment  that meets the
          requirements of 40 CFR 264.193 is  provided:

          [Note:  Include Permit Conditions  IV.C.4.a., IV.C.4.C.,
          and IV.C.4.d. for non-enterable  underground  tanks; include
          Permit Conditions IV.C.4.b.,  IV.C.4.C., and  IV.C.4.d. for
          tank systems comprised of other  than non-enterable
          underground tanks.]

     IV.C.4.a.  For non-enterable underground tanks,  a  leak test (or
               other tank integrity method as approved or required
               by the Regional Administrator) shall  be conducted
               annually using the procedures in Permit Attachment
               IV-3.  [40 CFR 264.193(i)(l)]

               [Note:   The  Permit Writer may specify more frequent
               testing, if  it is warranted,  given the  design,
               condition, and operation of the system.]

     IV.C.4.b.  For other than non-enterable  underground tanks, a
               leak test (or other tank integrity method as approved
               or required  by the Regional Administrator) must be
               conducted 	 (The Permit Writer shall
               establish the frequency.) using the  procedures in
               Permit Attachment IV-3.   [40  CFR 264.193(i)(2)]
                             IV  - 4

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                                                           September 1988
          IV.C.4.C. For ancillary equipment, a leak test (or other
                    integrity method as approved by the Regional
                    Administrator) must be conducted annually using the
                    procedures in Permit Attachment IV-3.   [40 CFR
                    264.193(i)(3)]

                    [Note:  The Permit Writer may specify more frequent
                    testing, if it is warranted, given the design,
                    condition, and operation of the system.  The leak
                    test, internal inspection, or other integrity
                    examination must be performed during the 12-month
                    period prior to the due date of the integrity
                    assessment.  The date the original leak test,
                    internal inspection, etc. was performed becomes the
                    anniversary date to perform subsequent tests.]

          IV.C.4.d. If a tank system or component is found to be leaking
                    or unfit for use as a result of the leak test or
                    assessment, the Permittee shall comply with Permit
                    Condition IV.E. of this Permit and notify the
                    Regional Administrator, in accordance with Permit
                    Condition IV.G. of this Permit. [40 CFR
                    264.193(i)(4)]

IV.D.     OPERATING REQUIREMENTS

     IV.D.I.   The Permittee shall not place hazardous wastes or
               treatment reagents in the tank system if they could cause
               the tank, its ancillary equipment, or a containment system
               to rupture, leak, corrode, or otherwise fail.   [40 CFR
               264.194(a)]

     IV.D.2.   The Permittee shall prevent spills and overflows from the
               tank or containment systems using the methods described in
               Permit Attachment IV-4.  [40 CFR 264.194(b)]

IV.E.     RESPONSE TO LEAKS OR SPILLS

In the event of a leak or a spill from the tank system, from a secondary
containment system, or if a system becomes unfit for continued use,  the
Permittee shall remove the system from service immediately and complete
the following actions:  [40 CFR 264.196(a)-(f)]

     IV.E.I.   Stop the flow of hazardous waste into the system and
               inspect the system to determine the cause of the release.

     IV.E.2.   Remove waste and accumulated precipitation from the system
               within 24 hours of the detection of the leak to prevent
               further release and to allow inspection and repair of the

                                  IV  -  5

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                                                      September 1988
          system.   If the  Permittee  finds  that  it  will  be impossible
          to meet  this time  period,  the  Permittee  shall notify the
          Regional Administrator  and demonstrate  that the longer
          time period is required.

          [Note:   The permit condition may specify a time period
          that is  more than  24 hrs.   This  would be part of the
          approved design.]

          If the collected material  is a RCRA hazardous waste, it
          must be  managed  in accordance  with all  applicable
          requirements of  40 CFR  Parts 262-264.   The Permittee shall
          note that if the collected material is  discharged through
          a point  source to  U.S.  waters  or to a POTW, it is subject
          to requirements  of the  Clean Water Act.   If the collected
          material is released to the environment, it may be subject
          to reporting under 40 CFR  Part 302.

IV.E.3.    Contain  visible  releases to the  environment.   The
          Permittee shall  immediately conduct a visual inspection of
          all releases to  the environment  and based on that
          inspection:  (1) prevent further migration of the leak or
          spill to soils or  surface  water  and (2)  remove and
          properly dispose of any visible  contamination of the soil
          or surface water.

IV.E.4.    Close the system in accordance with the Closure Plan,
          Permit Attachment  II-9. unless the following actions are
          taken:

          [Note:   Include  Permit  Condition IV.E.4.a. for all tank
          systems; Permit  Condition  IV.E.4.b. for tank systems with
          secondary containment;  Permit  Condition IV.E.4.C. for tank
          systems  with components below  ground that do not have
          secondary containment;  Permit  Condition IV.E.4.d. for tank
          systems  with aboveground components that do not have
          secondary containment;  and Permit Condition IV.E.4.e. for
          tank systems with  components that are not readily
          accessible for visual inspection (e.g.,  the bottom of an
          inground or onground tank). Permit Condition IV.E.4.f.
          need only be used when Permit  Conditions IV.E.4.C.,
          IV.E.4.d., or IV.E.4.e. apply.]

     IV.E.4.a. For a release caused  by a spill that has not damaged
               the integrity of the  system, the Permittee shall
               remove the  released waste and make any necessary
               repairs to  fully restore  the integrity of the system
               before returning the  tank system to service.
                             IV  -  6

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                                                           September 1988
          IV.E.4.b. For a release caused by a leak from the primary tank
                    system to the secondary containment system, the
                    Permittee shall repair the primary system prior to
                    returning it to service.

          IV.E.4.C. For a release to the environment caused by a leak
                    from a component of the tank system that is below
                    ground and does not have  secondary containment, the
                    Permittee must provide this component with secondary
                    containment that meets the requirements of 40 CFR
                    264.193 before the component can be returned to
                    service.

          IV.E.4.d. For a release to the environment caused by a leak
                    from the aboveground portion of the tank system that
                    does not have secondary containment,  and can be
                    visually inspected, the Permittee shall repair the
                    tank system before returning it to service.

          IV.E.4.e. For a release to the environment caused by a leak
                    from the portion of the tank system component that is
                    not readily available for visual inspection, the
                    Permittee shall provide secondary containment that
                    meets the requirements of 40 CFR 264.193 before the
                    component can be returned to service.

          IV.E.4.f. If the Permittee replaces a component of the tank
                    system to eliminate the leak,  that component must
                    satisfy the requirements  for new tank systems or
                    components in 40 CFR 264.192 and CFR 40 264.193.

     IV.E.5.    For all major repairs to eliminate leaks or restore the
               integrity of the tank system,  the Permittee must obtain a
               certification by an independent, qualified, registered
               professional engineer that the repaired system is capable
               of handling hazardous wastes without release for the
               intended life of the system before returning the system to
               service.  Examples of major repairs are:  installation of
               an internal liner, repair of a ruptured tank, or repair or
               replacement of a secondary containment vault.

IV.F.      INSPECTION SCHEDULES AND PROCEDURES

     IV.F.I.    The Permittee shall inspect the tank systems, in
               accordance with the Inspection Schedule, Permit Attachment
               II-3.  and shall complete the items in Permit Conditions
               IV.F.2.  and IV.F.3.  as part of those inspections:
                                 IV - 7

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                                                      September 1988
IV.F.2,    The Permittee shall Inspect the overfill controls,  in
          accordance with the schedule in Permit Attachment II-3.
          [40 CFR 264.195(a)]

IV.F.3.    The Permittee shall inspect the following components of
          the tank system once each operating day:  [40 CFR
          264.195(b)]

     IV.F.S.a. Aboveground portions of the tank system, if any, to
               detect corrosion or releases of waste;

     IV.F.3.b. Data gathered from monitoring and leak detection
               equipment (e.g., pressure or temperature gauges,
               monitoring wells) to ensure that the tank system is
               being operated according to its design;

     IV.F.S.c. Construction materials and the area immediately
               surrounding the externally accessible portion of the
               tank system, including the secondary containment
               system, to detect erosion or signs of releases of
               hazardous waste (e.g., wet spots, dead vegetation).

               [Note:  The Permit Writer may require more frequent
               inspections for the tank system, if necessary.]

     [Note:  The Permit Writer should include Permit Condition
     IV.F.4. only if a cathodic protection system is used.]

     IV.F.4.   The Permittee shall inspect cathodic protection
               systems, in accordance with the following schedule:
               [40 CFR 264.195(c)]

               a.   The proper operation of the cathodic protection
                    system must be confirmed within six months from
                    initial installation and annually thereafter and

               b.   All sources of impressed current must be
                    inspected and tested every other month.

               [Note:  The Permit Writer may require more frequent
               inspections for cathodic protection systems, if
               necessary.]

     IV.F.5.   The Permittee shall document compliance with Permit
               Conditions IV.F.2. through IV.F.4. and place this
               documentation in the operating record for the
               facility.   [40 CFR 264.195(d)]
                             IV -

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                                                           September 1988
IV.G.      RECORDKEEPING AND REPORTING

     IV.G.I.    The Permittee shall report to the Regional Administrator,
               within 24 hours of detection, when a leak or spill occurs
               from the tank system or secondary containment system to
               the environment.   [AO CFR 264.196(d)(1)]   (A leak or spill
               of one pound or less of hazardous waste,  that is
               immediately contained and cleaned-up,  need not be
               reported.)  [40 CFR 264.196(d)(2)]  (Releases that are
               contained within a secondary containment  system need not
               be reported).  If the Permittee has reported the release
               pursuant to 40 CFR Part 302,  this report  satisfies the
               requirements of this Permit Condition.   [40 CFR
               264.196(d)(l)]

     IV.G.2.    Within 30 days of detecting a release  to  the environment
               from the tank system or secondary containment system,  the
               Permittee shall report the following information to the
               Regional Administrator:  [40 CFR 264.196(d)(3)]

               a.   Likely route of migration of the  release;

               b.   Characteristics of the surrounding  soil (including
                    soil composition, geology, hydrogeology, and
                    climate);

               c.   Results of any monitoring or sampling conducted in
                    connection with the release.  If  the Permittee finds
                    it will be impossible to meet this  time period,  the
                    Permittee should provide the Regional Administrator
                    with a schedule of when the results  will be
                    available.  This schedule must be provided before the
                    required 30-day submittal period  expires;

               d.   Proximity of downgradient drinking water, surface
                    water, and populated areas;  and

               e.   Description of response  actions taken or planned.

     IV.G.3.    The Permittee shall submit to the Regional Administrator
               all certifications of major repairs to correct leaks
               within seven days from returning the tank system to use.
               [40 CFR 264.196(f)]

     [Note:   The Permit Writer should include Permit  Condition IV.G.4.
     for new tank systems or components,  and Permit Condition IV.G.5.  for
     existing tank systems without secondary containment.]
                                 IV - 9

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                                                           September 1988
     IV.G.4.    The Permittee shall obtain,  and keep on file at the
               facility,  the written statements by those persons required
               to certify the design and installation of the tank system.
               [40 CFR 264.192(g)]

     IV.G.5.    The Permittee shall keep on file at the facility the
               written assessment of the tank system's integrity.  [40
               CFR 264.191(a)j

     IV.G.6.    The Permittee shall maintain at the facility a record of
               the results of leak tests and integrity tests conducted,
               in accordance with Permit Conditions IV.C.4.a. through
               IV.C.4.c.

IV.H.     CLOSURE AND POST-CLOSURE CARE

     [Note:  Permit Condition IV.H.I. applies to all tanks.  The Permit
     Writer should include Permit Condition IV.H.2. in all tank permits
     as a contingency in case the tank cannot be "clean" closed at the
     time of closure.]

     IV.H.I.    At closure of the tank system(s), the Permittee shall
               follow the procedures in the Closure Plan, Permit
               Attachment II-9.    [40 CFR 264.197(a)]

               [Note:  Since all tanks are required to seek clean
               closure, the Closure Plan must address clean closure, but
               may also need a contingent closure plan referenced in
               Permit Condition IV.H.2.]

     IV.H.2.    If the Permittee demonstrates that not all contaminated
               soils can be practically removed or decontaminated, in
               accordance with the Closure Plan, then the Permittee shall
               close the tank system(s) and perform post-closure care
               following the contingent procedures in the Closure Plan
               and in the Post-Closure Plan, Permit Attachment 11-11.
               [40 CFR 264.197(b) and (c)]

               [Note:  A contingent post-closure plan is required at the
               time a permit is issued for tank systems that do not have
               secondary containment.]

               [Note:  The Permit Writer should use the Post-Closure
               Permit Module (Module XIII) to define the requirements
               that the Permittee shall follow for post-closure care.]
                                 IV - 10

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                                                           September 1988
IV. I.     SPECIAL TANK PROVISIONS FOR IGNITABLE OR REACTIVE WASTES

[Note:  The Permit Writer should include this section if ignitable or
reactive wastes are treated or stored in the tank system.]

     IV.I.I.   The Permittee shall not place ignitable or reactive waste
               in the tank system or in the secondary containment system,
               unless the procedures specified in Permit Attachment IV-5
               are followed.  [40 CFR 264.198(a)]

               [Note:  The Permit Writer should ensure that Permit
               Attachment IV-5 clearly documents how the Permittee will
               comply with the requirements of 40 CFR 264.198(a).  Per 40
               CFR 264.198(a), the Permittee shall not place ignitable or
               reactive waste in the tank system, unless the waste is
               treated, rendered, or mixed before or immediately after
               placement in the tank system, so that:  (a) the resulting
               waste, mixture, or dissolved material no longer meets the
               definition of ignitable or reactive waste in 40 CFR 261.21
               or 261.23  (The General Requirements for Ignitable and
               Reactive Wastes) and the precautions in 40 CFR 264.17(b)
               are complied with; (b) the waste is managed in such a way
               that it is protected from any material or conditions which
               may cause it to ignite or react; or (c) the tank system is
               used solely for emergencies.]

     IV.I.2.   The Permittee shall comply with the requirements for the
               maintenance of protective distances between the waste
               management area and any public ways, streets, alleys, or
               an adjoining property line that can be built upon, as
               required in Tables 2-1 through 2-6 of the National Fire
               Protection Association's "Flammable and Combustible
               Liquids Code" (1977 or 1981).  [40 CFR 264.198(b)]

IV.J.     SPECIAL TANK PROVISIONS FOR INCOMPATIBLE WASTES

[Note:  The Permit Writer should include this section if incompatible
wastes are treated or stored in the tank system.]

     IV.J.I.   The Permittee shall not place incompatible wastes, or
               incompatible wastes and materials, in the same tank system
               or the same secondary containment system,  unless the
               procedures specified in Permit Attachment IV-6 are
               followed.   [40 CFR 264.199(a)]

               [Note:  The Permit Writer should ensure that Permit
               Attachment IV-6 clearly demonstrates how the Permittee
               will comply with the requirements of 40 CFR 264.17(b).]
                                 IV - 11

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                                                           September 1988
     IV.J.2.    The Permittee shall not place hazardous waste in a tank
               system that has not been decontaminated and that
               previously held an incompatible waste or material, unless
               the requirements of Permit Condition VI.J.I.  are met.  [40
               CFR 264.199(b)]

IV.K.     COMPLIANCE SCHEDULE

[Note:  The Permit Writer should include this section if the Permittee is
required to complete specific steps within a specific time period, beyond
those covered by other conditions of the Permit, as a criteria for
retaining this operating Permit.  Compliance schedules are generally used
in cases where requirements that are supposed to be met by the Permittee
before the Permit is issued are deferred for good cause until after
permit issuance.  Appropriate compliance schedules included in the Part B
Permit Application should be attached to, or incorporated in, the Permit.
If the application does not include a compliance schedule, the Permit
Writer should prepare one and attach it to the Permit.  Each compliance
schedule should have at least two columns - one identifying the activity
and one identifying the milestone or completion dates.  The following is
an example of a condition that may apply for a tank system.]

The Permittee shall provide the following information to the Regional
Administrator:

               Item                Date Due to the Regional Administrator

      [Example:
      1.  ABC Engineering Design                  June 26, 1989
         Report on the Above-
         ground Secondary Contain-
         ment System for Tank
         System B (CF-102 and
         CF-103)

      2.  Documentation that a high-              October 1,  1989
         level alarm was installed
         on Tank System A (CF-101)

      3.  As-built construction                   April 1, 1990]
         drawings for the secondary
         containment system for Tank
         System B
                                 IV - 12

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                                                           September 1988
            PERMIT ATTACHMENTS REFERENCED  IN MODULE  IV  - TANKS
This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.  The Permit Writer may select
other numbering schemes, as appropriate, when preparing actual permits.

Permit Attachment No.         	Plan or Document	
                              (from the Part B Permit Application)

II-3                               Facility Inspection Schedule

II-9                               Facility Closure Plan

11-11                              Facility Post-Closure Plan

IV-1                               Plans and reports to support a
                                   variance from the requirements for
                                   secondary containment

IV-2                               Detailed plans and other information
                                   describing secondary containment
                                   systems

IV-3                               Procedures for conducting leak tests

IV-4                               Procedures for preventing spills and
                                   overflows from the tanks or
                                   containment systems

IV-5                               Procedures for handling ignitable or
                                   reactive waste

IV-6                               Procedures for handling incompatible
                                   wastes
                                 IV -  13

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                                                                 September 1988

                           MODULE V - SURFACE IMPOUNDMENTS
      [Note:  Include this permit module when the Permittee is storing,
      treating, or disposing hazardous waste in surface impoundments.  Waste
      analysis requirements (40 CFR 264.13), closure and post-closure
      requirements (40 CFR 264.228), and emergency repair/contingency plan
      requirements (40 CFR 264.227) for surface impoundments are contained as
      attachments to the Permit in the Waste Analysis Plan, Closure and Post-
      Closure Plan, and Contingency Plan, respectively.  Permit conditions for
      Post-Closure (40 CFR 264.117) for surface impoundments are contained in
      the Post-Closure Care Permit Module (Module XIII).  The Post-Closure Care
      Plan is incorporated in Module II which covers General Facility
      Conditions.]

      [Note:  The Permit Writer should refer to the RCRA Permit Quality
      Protocol for additional guidance in developing or reviewing permit
      conditions.  See discussion of the RCRA Permit Quality Protocol in the
      Introduction to this Model Permit.]

      V.A. MODULE HIGHLIGHTS

      [The Permit Writer should include a general discussion of the activities
      covered by this module.   The discussion should contain the following
      information: general description (including dimensions and capacity);
      location; liner description (including type of material and thickness);
      description of leachate collection and removal system; description of
      dike (including type of material and height, any freeboard
      specifications);  description of types of wastes stored, treated, or
      disposed; any unique or special features associated with the operation;
      and a reference to any special permit conditions.]

      V.B. PERMITTED AND PROHIBITED WASTE IDENTIFICATION

      The Permittee may manage hazardous wastes under the following conditions:

           V.B.I.    The Permittee may [specify store, treat, or dispose of]
                     the following hazardous wastes in surface impoundments,
                     subject to the terms of this Permit:

Surface                                             Description
Impoundment   Type of   Capacity    Dimensions of  of Hazardous  Hazardous
Designation     Unit    (gallons)   Impoundment       Waste      Waste No.

[Example:
 South        Storage   15,000      33 ft(l) x     Electroplating  F006]
 Lagoon                             15 ft(w) x     Sludge
                                     4 ft(d)
                                        V - 1

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                                                           September 1988
     [Note:  Under "Description of Hazardous Waste," the Permit Writer
     should provide only a brief generic description,  not comprehensive
     characteristics, where a Hazardous Waste Number is provided for
     reference.]

     V.B.2.    The Permittee is prohibited from storing, treating,  or
               disposing in surface impoundments any hazardous waste that
               is not identified in Permit Condition V.B.I.

[Note:  The Permit Writer may also include here a list of specific wastes
or materials that are prohibited.]

V.C. DESIGN. CONSTRUCTION. AND OPERATING REQUIREMENTS

[Note:  Permit Conditions V.C.I., V.C.4., and V.C.5. apply in each of the
following cases:   a surface impoundment that received waste beginning May
8, 1985, each new surface impoundment, each new surface impoundment unit
at an existing facility, each replacement of an existing surface
impoundment unit, and each lateral expansion of an existing surface
impoundment.  A surface impoundment that received waste prior to May 8,
1985, and is no longer active, shall be closed in accordance with the
requirements of 40 CFR 264.228 and is not subject to any of these
conditions.]

[Note:  If a Permittee is granted an exemption from the double liner
requirement [40 CFR 264.221(c)], in accordance with 40 CFR 264.221(d),
then only Permit Conditions V.C.2., V.C.4., and V.C.5. apply to the
surface impoundment.  The Permit Writer should add a condition to the
Permit stating that the Permittee is exempt from 40 CFR 264.221(c) and is
subject to the requirements of 40 CFR 264.221(d).]

[Note:  If a Permittee has a monofill and is granted an exemption from
the double liner requirement  [40 CFR 264.221(c)], in accordance with
40 CFR 264.221(e), then only Permit Conditions V.C.3., V.C.4., and V.C.5.
apply to the surface impoundment.  The Permit Writer should add a
condition to the Permit stating that the Permittee is exempt from 40 CFR
221(c) and is subject to the requirements of 40 CFR 264.221(e).j

[Note:  The Permit Writer should document the basis for granting
exemptions in the Administrative Record for this facility.]

     V.C.I.    The Permittee shall install and maintain two [or more]
               liners, and a leachate collection and removal system
               between such liners, in accordance with the design plans
               and reports contained in Permit Attachment V-l. [40 CFR
               264.221(c)]  The Permittee shall manage the leachate
               collected from the leachate collection and removal system
               in accordance with the design plans and reports contained
               in Permit Attachment V-l.  [The Permit Writer should
                                  V - 2

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                                                      September 1988

          specify in the Permit how collected leachate will be
          managed.]

          [Note:  Detailed design drawings of each liner and of the
          leachate collection and removal system and engineering
          reports, contained in Permit Attachment V-l. must
          demonstrate how the Permittee will meet all the
          requirements of 40 CFR 264.221(c).]

          [Note:  The Permit Writer should provide a brief
          description of the liners (e.g., construction materials,
          thickness, permeability) and leachate collection and
          removal system (e.g., construction materials, thickness
          and permeability of drainage layer).   Example language is
          as follows:  The primary liner shall consist of a 0.45-mil
          HDPE liner that is seam-welded and a composite secondary
          liner, located four feet below the primary liner,
          consisting of a 0.4-mil HDPE liner and three feet of
          compacted clay having a permeability not greater than 10
          cm/sec.  The leachate collection and removal system shall
          consist of a drainage tile system, embedded in a course
          sand media of 1x10 "* cm/sec or greater permeability,
          discharging to a sump with a level-controlled positive
          displacement pump, discharging to Tank 002 for subsequent
          testing and discharge to NPDES-regulated Outfall 002 or to
          the leachate treatment system.]

[Note:  Use Permit Condition V.C.2. if the Regional Administrator
finds that a surface impoundment with alternative design and
operating practices, together with location characteristics, will
prevent the migration of any hazardous constituents into the ground
water or surface water, at least as effectively as the requirements
of 40 CFR 264.221(c).]

V.C.2.    The Permittee shall [design, construct, operate, and]
          maintain the surface impoundment in accordance with the
          plans and reports contained in Permit Attachment V-l.  [40
          CFR 264.221(d)]

          [Note:  Permit Attachment V-l should contain comprehensive
          detailed plans and engineering and hydrogeologic reports
          of the alternative design and operating practices.]

[Note:  Use Permit Condition V.C.3. if the Regional Administrator
waives the double liner requirements for a monofill, in accordance
with the requirements of 40 CFR 264.221(e).]

V.C.3.    The Permittee shall [design, construct, operate, and]
          maintain a monofill,  in accordance with the plans and
          reports contained in Permit Attachment V-l. [40 CFR
          264.221(e)]
                             V - 3

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                                                           September 1988
               [Note:  Permit Attachment V-l should contain detailed
               plans and engineering and hydrogeologic reports of the
               alternative design and operating requirements.  The Permit
               Writer should specify in the Permit any additional
               operating practices and location characteristics that are
               necessary to ensure compliance with 40 CFR 264.221(e).]

     V.C.4.     The Permittee shall [design, construct, operate, and]
               maintain the surface impoundment to prevent overtopping,
               in accordance with the detailed design plans and operating
               practices contained in Permit Attachment V-2 .  [40 CFR
               264.221(f)J

     V.C.5.     The Permittee shall [design, construct, and] maintain the
               surface impoundment dikes according to the detailed design
               plans and operating practices contained in Permit
               Attachment V-3.  [40 CFR 264.221(g)]

V.D. LEAK CONTROL PROCEDURES

     V.D.I.     The Permittee shall monitor separately, each leak
               detection system at each surface impoundment,  for the
               presence of liquids daily, during the active life of the
               facility.  The Permittee shall completely remove all
               liquid from each leak detection system as expeditiously as
               possible.  The Permittee shall manage this liquid
               according to the plans and procedures described in Permit
               Attachment V-4 .  The Permittee shall mitigate leakage into
               the leak detection system.

     V.D. 2.     In the event of a sudden drop in the liquid level of the
               surface impoundment, that is not known to be caused by
               changes in the flow into or out of the impoundment, or  if
               the dike leaks, the Permittee shall remove the surface
               impoundment from service immediately and complete the
               following actions:  [40 CFR 264. 227 (a) - (b) ]

               o     Immediately shut off the flow or stop the addition of
                     wastes into the impoundment;

               o     Immediately contain any surface leakage which has
                     occurred or is occurring;

               o     Immediately stop the leak;

               o     Take any necessary steps to stop or prevent
                     catastrophic failure; and

               o     If a leak cannot be stopped by any other means, empty
                     the impoundment .
                                  V - 4

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                                                           September 1988
     V.D.3.    A surface impoundment that has been removed from service
               pursuant to this permit condition may be returned to
               service only if the portion of the impoundment which was
               failing is repaired and the following steps are taken:
               [40 CFR 264.227(d)]

          V.D.S.a.  If the impoundment was removed from service as the
                    result of actual or imminent dike failure, the dike's
                    structural integrity must be recertified by a
                    qualified, registered professional engineer,  in
                    accordance with 40 CFR 264.226(c).

          V.D.S.b.  If the impoundment was removed from service as the
                    result of a sudden drop in the liquid level,  then for
                    any existing portion of the impoundment, a liner must
                    be installed in compliance with 40 CFR 264.221(a),
                    and for any other portion of the impoundment, the
                    repaired liner system must be certified by a
                    qualified, registered professional engineer as
                    meeting the design specifications contained in Permit
                    Condition V.C.

     V.D.4,    A surface impoundment that has been removed from service,
               in accordance with the requirements of 40 CFR 264.227, and
               is not being repaired, must be closed in accordance with
               the provisions of 40 CFR 264.228. [40 CFR 264.227(e)]

V.E. INSPECTION SCHEDULES AND PROCEDURES

     V.E.I.    The Permittee shall inspect the surface impoundment in
               accordance with the inspection schedule, Permit Attachment
               II-3.  and shall complete the following as part of these
               inspections:

     [Note:  Include Permit Conditions V.E.2. through V.E.4. for new or
     expanded impoundments;  otherwise, only Permit Condition V.E.4. is
     necessary.]

     V.E.2.    The Permittee shall inspect the liners and cover systems
               during construction and installation for uniformity,
               drainage, and imperfections. [40 CFR 264.226(a)]

     V.E.3.    The Permittee shall inspect the surface impoundment
               immediately after construction or installation.  [40 CFR
               264.226(a)]

          V.E.3.a.  Synthetic liners and covers must be inspected to
                    ensure tight seams and joints and the absence of
                    tears, punctures, or blisters.
                                  V -  5

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                                                           September 1988

          V.E.3.b.   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.

     V.E.4.     If the surface impoundment  is  removed from service for
               more than six (6)  months,  then prior to returning to
               service,  the Permittee shall obtain a certification from a
               qualified,  registered professional  engineer that the
               surface impoundment's dike, including that portion of any
               dike which provides freeboard, has  structural integrity.
               The certification  must establish  that the dike: [40 CFR
               264.226(c)]

          V.E.A.a.   Will withstand the stress of the pressure exerted by
                    the types and amounts  of  wastes to be placed in the
                    surface impoundment.

          V.E.4.b.   Will not fail due to scouring  or piping, without
                    dependence on any liner system included in the
                    surface impoundment construction.

     [Note:   The Permit Writer may specify additional items to be covered
     by the certification.  These could include  permeability measurements
     or requiring the testing of  all the synthetic liner seam welds.]

V.F. RECORDKEEPING AND REPORTING

The Permittee shall notify the Regional Administrator, in writing, within
seven (7) days from detecting either a leak in the surface impoundment
dike or a sudden drop in the liquid level (and the drop is not caused by
changes in the flows into or out  of the impoundment).  [40 CFR
264.227(b)(6)j

V.G. CLOSURE AND POST-CLOSURE CARE

[Note:  Closure plan and post-closure plan requirements for surface
impoundments are:

     o    Double-lined storage and treatment impoundments  -- closure plan
          required but no contingent post-closure plan;

     o    Storage and treatment impoundments that are not double lined - -
          closure plan and contingent post-closure plan required; and

     o    Disposal impoundments -- closure and post-closure plans
          required.

Permit Condition V.G.I, applies to all surface impoundments.  The Permit
Writer should include Permit Condition V.G.2. for storage  or treatment
                                  V - 6

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                                                           September 1988

impoundments that are not equipped with double liners, as a contingency,
in case the surface impoundment cannot be 'clean" closed at the time of
closure.  The Permit Writer should include Permit Condition V.G.3. for
disposal surface impoundments.]

     V.G.I.    At closure of the surface impoundment, the Permittee shall
               follow the procedures in the approved Closure Plan
               contained in Permit Attachment II-9.  [40 CFR 264.228(a)]

     V.G.2.    If, after closure, waste residues or contaminated
               materials are left in place or all contaminated subsoils
               cannot be removed during closure to the levels specified
               in the closure plan, then the Permittee shall follow the
               procedures in the approved contingency portion of the
               Closure Plan and the contingent Post-Closure Plan
               contained in Permit Attachments II-9 and 11-11 and the
               Post-Closure Care Permit Module (Module XIII). [40 CFR
               264.228(b) and (c)]

     V.G.3.    For disposal surface impoundments (where hazardous waste,
               waste residues,  or contaminated materials are left in
               place at final closure),  the Permittee shall follow the
               plans and procedures in the approved Post-Closure Care
               Plan in Permit Attachment 11-11 and in the Post-Closure
               Permit Module (Module XIII). [40 CFR 264.228(b)]
V.H. SURFACE IMPOUNDMENT RETROFITTING PLANS OR WAIVER APPLICATION
     REQUIREMENTS

[Note:  Any valid multiple liner waiver request application under section
3005(j)(5) of HSVA must have been sent to EPA no later than November 8,
1986.  If no waiver was requested by November 8, 1986, or if a waiver
request was denied by the Regional Administrator, the Permittee must
proceed to retrofit the surface impoundment in accordance with Permit
Condition V.H.I.]

     V.H.I.    Surface Impoundment Retrofitting Plans

          V.H.I.a.   Draft Construction Plan

                    The Permittee, within 60 days [or some reasonable
                    time frame determined by the Permit Writer] of the
                    effective date of the Permit [or denial of the waiver
                    request or change in conditions], must submit a
                    Draft Construction Plan for the retrofitting of
                    surface impoundments [The Permit Writer should
                    identify the specific surface impoundments covered by
                    this condition.]  to the Regional Administrator for
                    review.  This plan must comply with the Minimum
                    Technology Requirements of 40 CFR 264.221.
                                  V -  7

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                                                      September 1988
     V.H.l.b.   Final  Construction Plan
               Following receipt of the  Draft Construction Plan,  the
               Regional Administrator will provide comments to the
               Permittee as to any corrections or modifications
               which must be made to the Draft Construction Plan.
               Within 30 days [or some reasonable time frame
               determined by the Permit Writer]  of receipt of such
               comments, the Permittee must submit a Final
               Construction Plan to the Regional Administrator.

     V.H.l.c.   Initiation of Construction

               Within 30 days [or some reasonable time frame
               determined by the Permit Writer]  of the Regional
               Administrator's approval of the Final Construction
               Plan, the Permittee shall initiate the approved Final
               Construction Plan, pursuant to the terms and schedule
               set forth in the plan.

     V.H.l.d.   Construction Completion

               The surface impoundments [The Permit Writer should
               identify the specific surface impoundments covered by
               this condition.] must be completely retrofitted to
               comply with the Minimum Technology Requirements of 40
               CFR 264.221, in accordance with the approved Final
               Construction Plan, no later than November 8, 1988.

     V.H.l.e.   Construction Quality Assurance Documentation Report

               The Permittee shall submit a final Construction
               Quality Assurance Documentation Report, including
               as-built drawings, to the Regional Administrator
               within 60 days [or some reasonable time frame
               determined by the Permit Writer] of completion of any
               retrofitted surface impoundments.

V.H.2.    Waiver Application Plans

[Note:  Section 3005(j) of RCRA provides for four categories of
exemptions to the Minimum Technological Requirements for surface
impoundments.   The following is a listing of the criteria for each
category.  The Permit Writer shall include Permit Condition V.H.2.
to obtain information from the Permittee regarding the schedule
and/or status of information to substantiate the exemption.
                             V -

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                                                      September 1988

Exemption No. 1:  An interim status surface impoundment must:

     o    Have at least one liner for which there is no evidence
          that such liner is leaking;

     o    Be located more than one-quarter mile from an underground
          source of drinking water; and

     o    Be in compliance with generally applicable ground-water
          monitoring requirements for facilities with Permits under
          subsection (c) of Section 3005.

Exemption No. 2:  A surface impoundment must be one which:

     o    Contains treated waste water during the secondary or
          subsequent phases of an aggressive biological treatment
          facility subject to a permit issued under section 402 of
          the Clean Water Act (or which holds such treated waste
          water after treatment and prior to discharge);

     o    Is in compliance with generally applicable ground-water
          monitoring requirements for facilities with RCRA Permits;
          and

     o    Is part of a facility in compliance with Section 301(b)(2)
          of the Clean Water Act; or in the case of a facility, for
          which no effluent guidelines required under Section
          304(b)(2) of the Clean Water Act are in effect and no
          Permit under section 402(a)(1) of such Act implementing
          Section 301(b)(2) of such Act has been issued, is part of
          a facility in compliance with a Permit under Section 402
          of such Act,  which is achieving significant degradation of
          toxic pollutants and hazardous constituents contained in
          the untreated waste stream and which has identified those
          toxic pollutants and hazardous constituents in the
          untreated waste stream to the appropriate permitting
          authority.

Exemption No. 3:  The Agency, after notice and opportunity for
comment, may modify the requirements for any surface impoundment if
the Permittee demonstrates that such surface impoundment is located,
designed and operated so as to assure there will be no migration of
any hazardous constituent into ground water or surface water at any
future time.  The Regional Administrator shall take into account
locational criteria established under Section 3004(o)(7).

Exemption No. 4:  The Agency may modify the surface impoundment
retrofitting requirements in the case of a surface impoundment for
which the Permittee, prior to October 1, 1984, has entered into, and
is in compliance with,  a consent order, decree, or agreement with
the Agency with an authorized program,  mandating corrective action
                             V - 9

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                                                           September 1988

     with respect to such surface impoundment,  that provides a degree of       I
     protection of human health and the environment which is,  at a
     minimum,  equivalent to the Minimum Technological Requirements.]

     V.H.2.     The Permittee shall submit information that substantiates
               the exemption to the Minimum Technological Requirements,
               in accordance with the schedules in Permit Attachment V-5.

     V.H.3.     Permit Modification Request

               The Permittee shall not receive, store, treat,  or dispose
               of hazardous waste after November 8, 1988, and must
               commence closure of surface impoundments [The Permit
               Writer should identify the specific surface impoundments
               covered by this condition.] by December 8, 1988. [53 FR
               24719, June 30, 1988]  The Permittee shall submit a
               request for modification of the  closure plan to reflect
               closure of this (these) unit(s)  within 60 days from the
               effective date of this Permit or date of waiver denial or
               change in conditions.

V.I. SPECIAL SURFACE IMPOUNDMENT PROVISIONS FOR IGNITABLE OR REACTIVE
     WASTES

[Note:  The Permit Writer should include this condition if the Permittee
places ignitable or reactive wastes in the surface impoundment.]

The Permittee shall not place ignitable or reactive waste in surface
impoundments [The Permit Writer should identify the specific surface
impoundments covered by this condition.], unless the procedures specified
in Permit Attachment V-6 are followed. [40 CFR 264.229(b)]

[Note:  The Permit Writer should specify in brief terms how the Permittee
shall comply with 40 CFR 264.229.  In accordance with the regulations,
ignitable or reactive wastes can be placed in a surface impoundment if:
(a) the waste is treated or mixed before or immediately after placement
in the surface impoundment so that the resulting waste, mixture, or
dissolution of material no longer meets the definition of ignitable or
reactive waste and 40 CFR 264.17 (General Requirements for Ignitable,
Reactive, or Incompatible Wastes) is complied with, or (b) the waste is
managed in such a way that it is protected from any material or
conditions which may cause it to ignite or react, or  (c) the surface
impoundment is used solely for emergencies.  The Permit Writer should
indicate which one of these three conditions applies to the Permit.]

V.J. SPECIAL SURFACE IMPOUNDMENT PROVISIONS FOR INCOMPATIBLE WASTES

[Note:  The Permit Writer should include this condition if the Permittee
places incompatible wastes in the surface impoundment.]
                                  V -  10

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                                                           September 1988

The Permittee shall not place incompatible wastes, or incompatible wastes
and materials, in the same surface impoundment, unless the procedures
specified in Permit Attachment V-7 are followed.  [40 CFR 264.230]

[Note:  The Permit Writer should specify how the Permittee shall comply
with 40 CFR 264.17(b) and (c).

V.K. SPECIAL SURFACE IMPOUNDMENT PROVISIONS FOR HAZARDOUS WASTES F020.
     F021. F022. F023. F026. AND F027 [HSWA]

[Note:  The Permit Writer should include this condition if the Permittee
stores, treats, or disposes special T" wastes in the surface
impoundment.]

The Permittee may place hazardous wastes [specify which of the following]
F020, F021, F022, F023, F026, or F027 in the surface impoundment [The
Permit Writer should identify the specific surface impoundments covered
by this condition.], in accordance with the waste management plan
contained in Permit Attachment V-8. [40 CFR 264.231]

[Note:  The Regional Administrator must approve the waste management plan
developed under 40 CFR 264.231.]

V.L. SPECIAL SURFACE IMPOUNDMENT PROVISIONS FOR HAZARDOUS WASTES
     RESTRICTED FROM SURFACE IMPOUNDMENT UNITS [HSWA]

[Note:  The Permittee may continue to place restricted hazardous waste,
as defined in 40 CFR Part 268, in a surface impoundment beyond the
prohibition date if the Permittee has been granted an extension to the
date [40 CFR 268.1(c)(l)] or the Permittee has been granted an exemption
from the prohibition [40 CFR 268.l(c)(2)],  or the waste is contaminated
soil or debris resulting from a response action taken under CERCLA
Sections 104 or 106 or a corrective action taken under RCRA [40 CFR
268.l(c)(3)].  (These wastes may be disposed only until November 8,
1988.)  The Permit Writer should include this condition in the Permit if
one or more of these situations occur.  The Permit Writer should document
the basis for granting all exceptions to the land disposal restrictions
in the Administrative Record for this Permit.]

     V.L.I.    The Permittee may place the  following restricted hazardous
               waste(s) in a surface impoundment, subject to the terms of
               this Permit and as described below:
                                 V  - 11

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                                                           September 1988

Surface Impoundment   Hazardous   Description of    Type of   Expiration       *
	Designation	   Waste No.   Hazardous Waste   Approval     Date

[Example:
 South Lagoon         F001      Tetrachloroethylene Exemption  August 13,
                                                               1998]

     [Note:  The Permit Writer should include Permit Conditions V.L.2. -
     V.L.4. in situations where case-by-case extensions to the
     prohibition date have been granted under 40 CFR 268.5.]

     V.L.2.    All restricted waste placed in the surface impoundment
               must be generated at the facility covered by this RCRA
               Permit unless the restricted waste is from another
               generating facility that is covered by an EPA or State
               approved application for a restricted waste capacity
               extension that specifically allows placement into the
               Permittee's surface impoundment.  [40 CFR 268.5(d)]

     V.L.3.    The Permittee shall immediately notify the Regional
               Administrator as soon as he has knowledge of any change in
               the conditions certified in his approved application for
               the case-by-case capacity extension, dated 	.  [40
               CFR 268.5(f)]

     V.L.4.    The Permittee shall submit written progress reports
               regarding the approved case-by-case capacity extension
               that:  (a) describe the overall progress made toward
               constructing or otherwise providing alternative treatment,
               recovery or disposal capacity; (b) identify any event
               which may cause or has caused a delay in the development
               of the capacity; and (c) summarize the steps taken to
               mitigate the delay.  The progress reports must be
               submitted in accordance with the  schedule in Permit
               Attachment V-9.  [40 CFR 268.5(g)]

     [Note:  Permit Conditions V.L.5. and V.L.6. only apply to a new
     landfill or surface impoundment unit, replacement of an existing
     surface impoundment unit, and each lateral  expansion of an existing
     surface impoundment unit.]
      Extensions may  be  granted  for up  to one year  from  the prohibition
      date, plus one  additional  year with proper demonstration.   [40  CFR
      268.5(e)]
      Exemptions shall be no  longer than the term of  the RCRA  Permit  for
      the  unit.   [40  CFR 268.6(h)]
                                  V - 12

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                                                           September 1988

     V.L.5.    The Permittee shall comply with all applicable
               requirements of 40 CFR Subpart F to protect ground water
               and all applicable requirements of 40 CFR 264.301(c), (d)
               and (e).

     V.L.6.    The Permittee shall comply with all applicable
               requirements of 40 CFR Subpart F to protect ground water
               and all applicable requirements of 40 CFR 264.221(c), (d),
               and (e).

     [Note:  Permit Condition V.L.7 applies only to surface impoundments
     that treat restricted waste, to the performance standards specified
     in 40 CFR 268 Subpart D, and ship the treated waste or treatment
     residue to another land disposal facility.]

     V.L.7.    The Permittee shall submit a certification to the
               receiving facility for each shipment of waste, or
               treatment residue of a restricted waste, that is shipped
               to a land disposal facility.  The certification shall
               indicate that the waste or treatment residue has been
               treated to the performance standards specified in 40 CFR
               268 Subpart D.  The Permittee shall use the certification
               language in 40 CFR 268.7(b)(2)(i).   [40 CFR 268.7(b)(2)]

     V.L.8.    The Permittee shall maintain records of notices and
               certifications received from generators and waste
               treatment facilities that restricted waste is accepted
               from,  and obtain copies of waste analysis data to
               determine that the wastes are in compliance with the
               applicable treatment standards in 40 CFR 268.41.  [40 CFR
               268.7(c)]

V.M. COMPLIANCE SCHEDULE

[Note:  The Permit Writer should include this condition if the Permittee
is required to complete specific steps within a specific time period,
beyond those covered by other conditions of the Permit, as a criteria for
retaining this operating Permit.  Compliance schedules are generally used
in cases where requirements that are supposed to be met by the Permittee
before the Permit is issued are deferred for good cause until after
Permit issuance.  Appropriate compliance schedules included in the Part B
Permit Application should be attached to, or incorporated in, the Permit.
If the application does not include a compliance schedule, the Permit
Writer should prepare one and attach it to the Permit.  Each compliance
schedule should have at least two columns - one identifying the activity
and one identifying the milestone or completion dates.  The following is
an example of a condition that may apply for a surface impoundment.]
                                 V  -  13

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                                                           September 1988

The Permittee shall provide the following information to the Regional
Administrator:

               Item                Date Due to the Regional Administrator

          [Example:
          1.  Revised Closure Plan                May 10, 1989

          2.  Plans and Procedures
              for Leachate Management             June 15, 1989]
                                  V -  14

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                                                           September 1988

     PERMIT ATTACHMENTS REFERENCED IN MODULE V -  SURFACE IMPOUNDMENTS

This list  is provided  to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.  The Permit Writer may select
other numbering schemes, as appropriate, when preparing actual Permits.

Permit Attachment No.              	Plan or Document	
                                   (from the Part B Permit Application)

II-3                               Facility Inspection Schedule

II-9                               Closure Plan

11-11                              Post-Closure Care Plan

V-l                                Design Plans and Reports for
                                   Installing Liners and Leachate
                                   Collection and Removal System and
                                   Operating the LCRS (or for an
                                   alternative design) (or for a monofill
                                   where the Agency has waived the double
                                   liner requirement)

V-2                                Design Plans and Operating Practices
                                   to Prevent Overtopping

V-3                                Design Plans and Operating Practices
                                   to Prevent: Massive Failure of the
                                   Dikes

V-4                                Plans and Procedures for Leachate
                                   Management

V-5                                Schedules for Submitting Required
                                   Exemption Information

V-6                                Procedures for Managing Ignitable or
                                   Reactive Wastes

V-7                                Procedures for Managing Incompatible
                                   Wastes

V-8                                Waste Management Plan for Special "F"
                                   Wastes

V-9                                Schedule for Submitting Progress
                                   Reports on Developing Alternatives for
                                   Handling Land-Banned Wastes
                                  V  -  15

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                                                           September 1988
                         MODULE VI - WASTE PILES
 [Note:  This permit module should be included when the Permittee is
 storing and/or treating hazardous waste in waste piles (waste piles that
 are closed with wastes in place are regulated as landfills.)  When using
 this module in a permit, the Permit Writer should specify in the title
whether this module is for storage and/or treatment of waste in waste
piles.  Waste analysis requirements (40 CFR 264.13) and closure
 requirements (40 CFR 264.197) for waste piles are normally contained as
 attachments to the Permit in the Waste Analysis Plan and the Closure
 Plan.  Post-closure requirements for waste piles, when necessary (40 CFR
 264.117), are contained in the post-closure permit module (Module XIII).]

 [Note:  In general, a single permit module should be used if multiple
waste piles will be covered by the same Permit for a given facility.
However, it is acceptable to include multiple waste pile modules if, in
 the Permit Writer's judgment, the characteristics and permit conditions
 for each waste pile are sufficiently different to warrant multiple
modules.]

 [Note:  The Permit Writer should refer to the RCRA Permit Quality
 Protocol for additional guidance in developing or reviewing permit
 conditions.  See discussion of the RCRA Permit Quality Protocol in the
 Introduction to this Model Permit.]
VI. A.
MODULE HIGHLIGHTS
[The Permit Writer should include a general discussion of the activities
covered by this module.  The discussion should contain the following
information:  description, capacity and location of each waste pile;
description of the types of waste handled; any unique or special features
associated with the activity; and a reference to any special permit
conditions.1
VLB.
PERMITTED AND PROHIBITED WASTE IDENTIFICATION
     VI.B.I.   The Permittee may
                                  [specify store and/or treat]
               the following hazardous wastes in waste piles, subject to
               the terms of this permit and as described below:
Waste Pile
Designation

[Example:
 Incinerator
 Ash Pile
        Area
     Dimensions
    [or overall
    surface areal
     20 ft. high x
     20 ft. base
     diameter
  Capacity
(cubic yards)
   100 yd3
Description of
Hazardous Waste
 Ash from Still
 Bottoms
 Incinerator
Hazardous
Waste No.
   K009]
                                 VI  -  1

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                                                           September 1988      .

[Note:  Under "Description of Hazardous Waste," the Permit Writer should
provide only a brief generic description, not comprehensive
characteristics, where a Hazardous Waste Number is provided for
reference.]

     VLB. 2.   The Permittee is prohibited from storing or treating
               hazardous waste that is not identified in Permit Condition
               VI.B.I.

[Note:  The Permit Writer may also include here a list of specific wastes
or materials that are prohibited.]

VI.C.     DESIGN. CONSTRUCTION. AND OPERATING REQUIREMENTS

      [Note:  Permit Conditions VI.C.I. through VI.C.6. do not apply to a
     waste pile that is inside or under a structure that provides
     protection from precipitation so that neither run-off nor leachate
     is generated and (1) liquids or materials containing free liquids
     are not placed in the pile; (2) the pile is protected from surface
     water run-on; (3) where necessary, wind dispersal of the waste is
     controlled by means other than wetting; and (4) the pile will not
     generate leachate.] [40 CFR 264.250(c)]

      [Note:  Permit Conditions VI.C.I. and VI.C.2. apply only to new
     units and lateral expansions and replacements of existing units at
      interim status waste piles.  If the Permittee has successfully
     demonstrated, in accordance with 40 CFR 264.251(b), that alternative
     design and operating practices, together with location
     characteristics, will prevent the migration of any hazardous
     constituents into the ground water or surface water at any future
      time and, consequently, is granted an exemption from 40 CFR
     264.251(a), the decision should be documented in the Administrative
     Record for the facility.  Where an exemption is granted, the Permit
     Writer should specify in the Permit all design and operating
     practices necessary to ensure that the requirements of 40 CFR
      264.251(b) are satisfied. Permit Conditions VI.C.3. through VI.C.6.
      apply to all waste piles.]

     VI.C.I.   The Permittee shall design, construct, and install a liner
               that will prevent any migration of wastes out of the waste
               pile, in accordance with the design plans and
               specifications contained in Permit Attachment VI-1.  [40
               CFR 264.251(a)(l)]

                [Note:  Detailed design drawings of each liner and the
               leachate collection and removal system and engineering
               reports, contained in Permit Attachment VI-1, must
               demonstrate how the Permittee will meet all of the
               requirements of 40 CFR 264.301(c).]
                                  VI -  2

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                                                      September 1988

          [Note:  The Permit Writer should provide a brief
          description  (in Permit Conditions VI.C.I. and VI.C.2.) of
          the liners (e.g., construction materials, thickness,
          permeability) and leachate collection and removal system
          (e.g., construction materials, thickness and permeability
          of drainage layer).  Example language is as follows:  The
          primary liner shall consist of a 0.45-mil HDPE liner that
          is seam-welded and a secondary liner, located four feet
          below the primary liner, consisting of a 0.4-mil HDPE
          liner and three feet of compacted clay having a
          permeability not greater that 10" cm/sec.  The leachate
          collection and removal system shall consist of a drainage
          tile system, embedded in a course sand media of 1x10~^
          cm/sec or greater permeability, discharging to a sump with
          a level-controlled positive displacement pump, discharging
          to Tank 002 for subsequent testing and discharge to NPDES-
          regulated Outfall 002 or to the leachate treatment
          system.]

VI.C.2.   The Permittee shall design, construct, maintain, and
          operate a leachate collection and removal system
          immediately above the liner that will collect and remove
          leachate from the waste pile, in accordance with the
          design plans, specifications, and operating practices
          contained in Permit Attachment VI-2.   [40 CFR
          264.251(a)(2)j

          [Note:  The Permit Writer should specify additional design
          and operating conditions, as necessary,  as part of this
          permit condition to ensure that the leachate depth over
          the liner does not exceed one foot.]   [40 CFR
          264.251(a)(2)]

VI.C.3.   The Permittee shall [design, construct,] operate, and
          maintain a run-on control system in accordance with the
          design plans, specifications, and operating practices
          contained in Permit Attachment VI-3.   This control system
          must be capable of preventing flow onto the active portion
          of the pile during peak discharge from at least a 25-year
          storm.  [40 CFR 264.251(c)]

VI.C.4.   The Permittee shall [design, construct,] operate, and
          maintain a run-off management system in accordance with
          the design plans, specifications, and operating practices
          contained in Permit Attachment VI-4.   This management
          system must be capable of collecting and controlling at
          least the water volume resulting from a 24-hour, 25-year
          storm.  [40 CFR 264.251(d)]

          [Note:  The Permit Writer should specify additional
          conditions,  as necessary, to ensure the proper management
                            VI  - 3

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                                                           September 1988      .

               of run-off.   The following conditions  are for example
               purpo se s only:

               a.   The Permittee shall measure the volumetric flow rate
                    of any run-off from the waste pile.

               b.   The Permittee shall sample run-off once each day and
                    analyze each sample for pH, conductivity,  total
                    organic carbon,  and chromium concentration.

               c.   The Permittee shall record and maintain all data
                    compiled In accordance with Permit Condition VI.C.4.

               d.   The Permittee shall obtain an NPDES permit for
                    run-off discharged to a surface water body.

               e.   The Permittee shall manage the residue generated from
                    the run-off management system as  a hazardous waste.]

     VI.C.5.    The Permittee shall empty or otherwise manage run-on and
               run-off collection and holding facilities associated with
               the run-on and run-off control system(s) to maintain the
               design capacity of the system(s) in accordance with the
               design plans, specifications, and operating practices
               contained in Permit Attachment VI -_5. [40 CFR 264.251(e)]

     [Note:  The Permit Writer should include Permit  Condition VI.C.6.  if
     the waste pile contains particulate matter that  is potentially
     subject to wind dispersal.]

     VI.C.6.    The Permittee shall cover or otherwise manage the waste
               pile to control wind dispersal of particulate matter in
               accordance with the methods contained  in Permit Attachment
               VI-6.  [40 CFR 264.251(f)]

VI.D.     INSPECTION SCHEDULES AND PROCEDURES

The Permittee shall inspect the waste pile in accordance with the
Inspection Schedule, Permit Attachment 11 - 3 . and shall complete the
following as part of those inspections.

     [Note:  The Permit Writer should include Permit Condition VI.D.l.,
     tailored to each facility, where liners or cover systems (e.g.,
     membranes, sheets, or coatings) will be constructed or installed at
     the waste pile.]

     VI.D.l.    The Permittee shall inspect liners and cover systems
               during construction or installation for uniformity,
               damage, and imperfections [e.g., holes, cracks, thin
               spots, or foreign materials].  The Permittee shall inspect
                                 VI  -  4

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                                                           September 1988

               liners and cover systems immediately after construction
               and installation as follows:  [40 CFR 264.254(a)]

               a.   Synthetic liners and covers [if applicable] to ensure
                    tight seams and joints, and the absence of tears,
                    punctures, or blisters; and/or

               b.   Soil-based and admixed liners [if applicable] for
                    imperfections including lenses,  cracks, channels,
                    root holes, and other structural nonuniformities that
                    may cause an increase in the permeability of the
                    liner or cover.

     VI.D.2.   The Permittee shall inspect the waste pile on a weekly
               basis and immediately after storms to detect evidence of
               the following:  [40 CFR 264.254(b)]

               a.   Deterioration, malfunctions, or improper operation of
                    the run-on and run-off control system;

               b.   Proper functioning of the wind dispersal control
                    system [if applicable]; and

               c.   Presence of leachate in,  and proper functioning of,
                    leachate collection and removal systems [if
                    applicable].

VI.E.     RECORDKEEPING

The Permittee shall record and maintain in the operating record for this
Permit all monitoring and inspection data compiled under the requirements
of this permit module.  [40 CFR 264.73]

VI.F.     CLOSURE AND POST-CLOSURE CARE

     [Note:  Permit Condition VI.F.I. applies to all waste piles.  The
     Permit Writer should include Permit Condition VI.F.2. for all waste
     piles that do not comply with the liner requirements of 40 CFR
     264.251(a)(1) and are not exempt from them in accordance with 40 CFR
     264.250(c) or 264.251(b).  Permit Condition VI.F.2. is a contingency
     in case the waste pile cannot be "clean" closed at the time of
     closure.]

     VI.F.I.   At closure of the  waste pile,  the Permittee shall follow
               the procedures in  the Closure Plan, Permit Attachment II-
               9.  [40 CFR 264.258(a>]

               [Note:  Since all  waste piles are required to seek clean
               closure, the Closure Plan must address clean closure, but
               may also need a contingent closure plan referenced in
               Permit Condition VI.F.2.]
                                 VI  - 5

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                                                           September 1988
     VI.F.2    If after closure,  the Permittee finds that not all
               contaminated soils can be practically removed or
               decontaminated in accordance with the Closure Plan,  then
               the Permittee shall close the waste pile and perform post-
               closure care following the procedures in the contingency
               portion of the Closure Plan  and the contingent Post-
               Closure Plan, Permit Attachments II-9 and 11-11 and in the
               Post-Closure Permit Module (Module XIII).   [40 CFR
               264.258(b) and (c)]

               [Note:  A contingency portion in the Closure Plan and a
               contingent Post-Closure Plan are required at the time a
               permit is issued for waste piles that do not comply with
               the liner requirements and are not exempt from them.]

VI.G.     GROUND WATER. SURFACE WATER. AND SUBSURFACE SOIL MONITORING
          EXEMPTIONS

     [Note:  The Permit Writer should include Permit Condition VI.G.I. if
     the waste pile is inside or under a structure that provides
     protection from precipitation so that neither run-off nor leachate
     is generated.]

     VI.G.I.   The Permittee is not subject to the design and operating
               requirements for waste piles listed in 40 CFR 264.251 or
               the ground water protection standards listed in 40 CFR
               Subpart F, provided that the following conditions are met:
               [40 CFR 264.250(c)]

               a.   The Permittee shall design, construct, and operate
                    the waste pile in accordance with the design plans,
                    specifications, and operating practices contained in
                    Permit Attachment VI-7:

               b.   The Permittee shall not place liquids or materials
                    containing free liquids in the waste pile;

               c.   The Permittee shall protect the waste pile from
                    surface water run-on by the structure or in some
                    other manner;

               d.   The Permittee shall control dispersal of the waste by
                    wind, by means other than wetting; and

               e.   The Permittee shall ensure the pile will not generate
                    leachate through decomposition or other reactions.

     [Note:  The Permit Writer should include Permit Condition VI.G.2. if
     the Permittee qualifies under 40 CFR  264.251(b) for exemption to the
                                  VI  -  6

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                                                           September 1988

     minimum technological requirements for a liner, and leachate
     collection and removal system required under 40 CFR 264.251(a).]

     VI.G.2.   The Permittee shall [construct and] operate the waste pile
               as specified in Permit Attachment VI-8 so as to prevent
               the migration of any hazardous constituents into the
               ground water or surface water, at least as effectively as
               the liner and leachate collection systems would, as
               described in 40 CFR 264.251(a).  [40 CFR 264.251(b)].

VI.H.     SPECIAL WASTE PILE PROVISIONS FOR IGNITABLE OR REACTIVE WASTE

[Note:  The Permit Writer should include this condition if the Permittee
places ignitable or reactive wastes in the waste pile.]

The Permittee shall not place ignitable or reactive waste in the waste
pile unless the procedures specified in Permit Attachment VI-9 are
followed.

[Note:  The Permit Writer should ensure that Permit Attachment VI-9
clearly documents how the Permittee will comply with the requirements of
40 CFR 264.198(a).  Per 40 CFR 264.198(a), the Permittee shall not place
ignitable or reactive waste in a waste pile, unless the waste is treated,
rendered, or mixed before or immediately after placement in the waste
pile system so that: (a) the resulting waste, mixture, or dissolved
material no longer meets the definition of ignitable or reactive waste in
40 CFR 261.21 or 261.23 and the precautions in 40 CFR 264.17(b) (the
General Requirements for Ignitable and Reactive Wastes) are complied with
or (b) the waste is managed in such a way that it is protected from any
material or conditions which may cause it to ignite or react.]
VI.I.     SPECIAL WASTE PILE PROVISIONS FOR INCOMPATIBLE WASTES

[Note:  The Permit Writer should include this condition if the Permittee
places incompatible wastes in waste piles.]

     VI.1.1.    The Permittee shall not place incompatible wastes, or
               incompatible wastes and materials in the same waste pile,
               unless the procedures described in Permit Attachment VI-10
               are followed.  [40 CFR 264.257(a)].

               [Note:  The Permit Writer should ensure that Permit
               Attachment VI-10 clearly demonstrates how the Permittee
               will comply with the requirements of 40 CFR 264.17(b)]

     VI.I.2.    The Permittee shall separate a pile  of hazardous waste
               from any incompatible hazardous waste or other materials
               stored nearby in containers, other waste piles, open
               tanks, or surface impoundments, or protect the pile from
                                 VI  - 7

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                                                           September 1988
               the waste or materials by a dike,  berm,  wall, or other
               device.  [40 CFR 264.257(b)]

     VI.I.3.    The Permittee shall not place hazardous  wastes on the same
               base where incompatible wastes or materials were
               previously piled, unless the base has been decontaminated
               sufficiently to ensure compliance with 40 CFR 264.17(b).

VI.J.     SPECIAL WASTE FILE PROVISIONS FOR HAZARDOUS WASTES F020. F021.
          F022. F023. F026. AND F027 [HSWA]

[Note:  The Permit Writer should include this condition if the Permittee
stores or treats, any of the "F" wastes on the waste pile.]

The Permittee may place hazardous wastes [specify which of the following]
F020, F021, F022, F023, F026, or F027 in the waste pile in accordance
with the waste management plan contained in Permit Attachment VI-11.

[Note:  The Regional Administration must approve the waste management
plan developed under 40 CFR 264.259.  In evaluating a proposed waste
management plan, the following factors must be considered:

     1.   Volume of the wastes;

     2.   Chemical and physical characteristics of the wastes, including
          their potential to migrate through soil or to volatilize or
          escape into the atmosphere;

     3.   Attenuative properties of underlying and surrounding soils or
          other materials;

     4.   Mobilizing properties of other materials co-disposed with these
          wastes; and

     5.   Effectiveness of additional treatment, design, or monitoring
          techniques.

In evaluating the proposed plan, the Regional Administrator may determine
that additional design, operating, and monitoring requirements are
necessary in order to reduce the possibility of migration of these wastes
to ground water, surface water, or air to protect human health and the
environment.]

VI.K      SPECIAL WASTE PILE PROVISIONS FOR HAZARDOUS WASTES RESTRICTED
          FROM WASTE PILE UNITS [HSWA]

[Note:  The Permittee may continue to place restricted hazardous waste,
as defined in 40 CFR Part 268, in a waste pile beyond the prohibition
date if the Permittee has been granted an extension to the date [40 CFR
268.1(c)(l)] or the Permittee has been granted an exemption from the
prohibition [40 CFR 268.l(c)(2)], or the waste is contaminated soil or
                                  VI -  8


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                                                           September 1988

debris resulting from a response action taken under CERCLA Sections 104
or 106 or a corrective action taken under RCRA [40 CFR 268.l(c)(3)].
(These wastes may be disposed only until November 8, 1988).  The Permit
Writer should include this section in the Permit if one or more of these
situations occur.  The Permit Writer should document the basis for
granting all exceptions to the land disposal restrictions in the
Administrative Record for this Permit.]

     VI.K.I.   The Permittee may place the following restricted hazardous
               waste(s) in the waste pile subject to the terras of this
               permit and as described below:

Waste Pile       Hazardous  Description of        Type of   Expiration
Designation      Waste No.  Hazardous Waste       Approval     Date

[Example:
 Degreasing Area   F001      Tetrachloro-         Exemption  August 31,
                             ethylene                        1998]

     [Note:  The Permit Writer should include Permit Conditions VI.K.2 -
     VI.K.4. in situations where case-by-case extensions to the
     prohibition date have been granted under 40 CFR 268.5.]

   VI.K.2.     All restricted waste placed in the waste pile must be
               generated at the facility covered by this RCRA permit,
               unless the restricted waste is from another generating
               facility that is covered by an EPA- or State-approved
               application for a restricted waste capacity extension that
               specifically allows placement into the Permittee's waste
               pile.  [40 CFR 268.5(d)]

   VI.K.3.     The Permittee shall immediately notify the Regional
               Administrator as soon as he has knowledge of any change in
               the conditions certified in his approved application for
               the case-by-case capacity extension, dated 	.  [40
               CFR 268.5(f>]

   VI.K.4.     The Permittee shall submit written progress reports
               regarding the approved case-by-case capacity extension
               that: (a) describe the overall progress made toward
               constructing or otherwise providing alternative treatment,
               recovery or disposal capacity; (b) identify any event
               which may cause, or has caused, a delay in the development
               of the capacity; and (c) summarize the steps taken to
     Extensions may be granted for up to one year from the prohibition
     date,  plus one additional year with proper demonstration.  [40 CFR
     268.5(e)]
     Exemptio'hs shall be no longer than the term of the RCRA permit for
     the unit.  [40 CFR 268.6(h)]
                                 VI  -  9

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                                                           September 1988
               mitigate the delay.   The  progress  reports  must be
               submitted in accordance with the schedule  in Permit
               Attachment VI-12.   [40 CFR 268.5(g)]

   [Note:   Permit Conditions VI.K.5. and VI.K.6.  only apply to new waste
   piles,  replacements of an existing waste pile,  and each lateral
   expansion of an existing waste pile.]

   VI.K.5.      The Permittee shall  comply with all applicable
               requirements of 40 CFR Subpart F to protect ground water
               and all applicable requirements of 40 CFR  264.301(c),  (d),
               and (e).

   VI,K.6.      The Permittee shall  comply with all applicable
               requirements of 40 CFR Subpart F to protect ground water
               and all applicable requirements of 40 CFR  264.221(c),  (d),
               and (e).

   VI.K.7.      The Permittee shall  maintain records of notices and
               certifications received  from generators and waste
               treatment facilities that restricted waste is accepted
               from, and obtain copies  of waste analysis  data to
               determine that the wastes are in compliance with the
               applicable treatment standards in  40 CFR 268.41.  [40 CFR
               268.7(c)]

VI.L.     COMPLIANCE SCHEDULE

[Note:  The Permit Writer should include this section if the Permittee is
required to complete specific steps within a specific time period, beyond
those covered by other conditions of the Permit,  as a criteria for
retaining this operating permit.   Compliance schedules are generally used
in cases where requirements that are supposed to  be met by the Permittee
before the permit Is issued are deferred for good cause until after
permit issuance.  Appropriated compliance schedules included in the Part
B Permit Application should be attached to, or incorporated in, the
Permit.  If the application does not include a compliance schedule, the
Permit Writer should prepare one and attach it to the Permit.  Each
compliance schedule should have at least two columns - one identifying
the activity, and one identifying the milestone or completion dates.  The
following is an example of a condition  that may apply for a waste pile.]

The Permittee shall provide the following information to  the Regional
Administrator:
                                 VI - 10

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                                                      September 1988

                         Date Due to the Regional Administrator
[Example:
1.   Operation and                 December 31, 1988]
     Maintenance
     Procedures for the
     Run-Off Management
     System
                            VI  -  11

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                                                           September 1988
         PERMIT ATTACHMENTS REFERENCED IN MODULE VI  - WASTE PILES

This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.   The Permit Writer may select
other numbering schemes, as appropriate, when preparing actual permits.

Permit Attachment No.         	Plan or Document	
                              (from the Part B Permit Application)

II-3                          Facility Inspection Schedule

II-9                          Facility Closure Plan

11-11                         Facility Post-Closure Plan

VI-1                          Design Plans and Specifications for
                              Installing a Liner

VI-2                          Design Plans and Specifications, and
                              Operating Practices for Installing and
                              Operating a Leachate Collection System

VI-3                          Design Plans and Specifications, and
                              Operating Practices for Installing and
                              Operating a Run-On Control System

VI-4                          Design Plans and Specifications, and
                              Operating Practices for Installing and
                              Operating a Run-Off Management System

VI-5                          Design Plans and Specifications, and
                              Operating Practices for Managing Run-On and
                              Run-Off

VI-6                          Procedures for Controlling Wind Dispersal

VI-7                          Design Plans, Specifications and Operating
                              Practices for a Waste Pile Inside or Under
                              a Structure

VI-8                          Design Plans, Specifications and Operating
                              Practices for Exemptions to 40 CFR
                              264.251(a).

VI-9                          Ignitable and Reactive Waste Management
                              Plan

VI-10                         Incompatible Waste Management Plan
                                 VI  - 12


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                                                           September 1988

Permit Attachment No.         	Plan or Document	
                              (from the Part B Permit Application)

VI-11                         Special "F" Waste Management Plan

VI-12                         Schedule for Submitting Progress Reports on
                              Developing Alternatives for Handling
                              "Banned" Waste(s)
                                 VI  -  13

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                                                           September 1988

                MODULE VII(A) - LAND TREATMENT OPERATIONS
[Note:  This permit module should be included for land treatment
operations only after the Permittee has successfully demonstrated that
hazardous constituents in the waste can be completely degraded,
transformed, or immobilized according to the conditions in Permit Module
VII(B) - Land Treatment Demonstrations.]

[Note:  In general, a single permit module should be used if multiple
land treatment units will be covered by the same Permit for a given
facility.  However, it is acceptable to include multiple land treatment
modules if, in the Permit Writer's judgment, the characteristics and
permit conditions for each unit are sufficiently different to warrant
multiple modules.]

[Note:  Waste analysis requirements (40 CFR 264.13) and closure
requirements (40 CFR 264.280) for land treatment normally are contained
as attachments to the Waste Analysis Plan and the Closure Plan.
Post-Closure requirements (40 CFR 264.280) normally are contained in the
Post-Closure Permit Module (Module XIII).  The Post-Closure Care Plan is
attached to Permit Module II which covers general facility conditions.]

[Note:  The Permit Writer should refer to the RGRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]

VII(A).A.  MODULE HIGHLIGHTS

[The Permit Writer should include a general discussion of the activities
covered by this module.  The discussion should contain the following
information:  description of each land treatment unit (including
dimensions, location, run-on control system, and run-off management
system); wind control devices (i.e., tillage or aeration system);
description of wastes that may be handled; specify any food-chain crops
that may be grown; any unique or special features associated with the
activity; and a. reference to any special permit conditions.]

VII(A).B.  PERMITTED AND PROHIBITED WASTE IDENTIFICATION

The Permittee may treat hazardous wastes under the following conditions:

     VII(A).B.I.     The Permittee may treat the following wastes in the
                    land treatment program, subject to the terms of this
                    permit and as described below:  [40 CFR
                    264.271(a)(l); 264.271(b);  and 264.273(a)(1)]
                               VII(A)  -  1

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                                                           September 1988
                                   Significant
Description of    Hazardous   Hazardous Constituents        Waste
Hazardous Waste   Waste No.    [from Appendix VIII1     Application Rate

[Example:
 Tank Bottoms       K052         Tetraethyl Lead,      bbls/acre/
                                 Benzene, Toluene      application]

[Note:  Under "Description of Hazardous Waste," the Permit Writer should
provide only a brief generic description, not comprehensive
characteristics.]

     VII(A).B.2.    The Permittee is prohibited from treating wastes that
                    are not identified in Permit Condition VII(A).B.I.

[Note:  The Permit Writer may also include here a list of specific wastes
or materials that are prohibited.]

VII(A).C.  TREATMENT PROGRAM

The Permittee may implement a land treatment program that is designed to
ensure that hazardous constituents placed in or on the treatment zone are
degraded, transformed or immobilized within the treatment zone according
to Permit Attachment VIICA)-!.   [40 CFR 264.271(a)]

[Note:  The treatment program must include the following elements:

      1.   Specification of wastes that are capable of being treated at
          the unit based on a land treatment demonstration.

      2.   List of hazardous constituents that are expected to be in, or
          derived from, the wastes to be land treated based on waste
          analysis.

      3.   Description of the theory behind the type of treatment  (e.g.,
          biodegradation) and the expected by-products.

      4.   Unsaturated zone monitoring provisions meeting the requirements
          of 40 CFR 264.278.

      5.   Vertical and horizontal dimensions of the treatment zone.  The
          maximum depth of the treatment zone must not be more than five
          feet from the initial  soil surface and more than three feet
          above the seasonal high water table.

      6.   Description of the barrier between the initial soil surface and
          the seasonal high water table.]
                                VII(A)  -  2

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                                                           September 1988
VII(A).D.  DESIGN. CONSTRUCTION. AND OPERATING REQUIREMENTS

The Permittee shall design and operate the land treatment system
according to the following requirements:

     VII(A).D.l.    The Permittee shall [design, construct] operate, and
                    maintain the treatment unit according to the plans
                    and specifications contained in Permit Attachment
                    VII(A)-2.  [40 CFR 264.273(a)]

                    [Note:  The Permit Writer should briefly specify the
                    rate and method of waste application to the treatment
                    zone, method of introducing oxygen, measures to
                    control soil pH, measures to enhance microbial or
                    chemical reactions, and measures to control moisture
                    and nutrient content.]

     VII(A).D.2.    The Permittee shall [design, construct] operate, and
                    maintain the treatment zone to minimize run-off of
                    hazardous constituents during the active life of the
                    land treatment unit, according to the plans and
                    specifications contained in Permit Attachment
                    VII(A)-3.  [40 CFR 264.273(b)]

     VII(A).D.3.    The Permittee shall [design, construct] operate, and
                    maintain the run-on control system, according to the
                    plans and specifications contained in Permit
                    Attachment VII(A)-4. [40 CFR 264.273(c)]

                    [Note:  The plans and specifications contained in
                    Permit Attachment VII(A)-4 must demonstrate that the
                    run-on control system is capable of preventing flow
                    onto the treatment zone during peak discharge from at
                    least a 24-hour, 25-year storm.]

     VII(A).D.4,    The Permittee shall [design, construct] operate, and
                    maintain a run-off management system, according to
                    the plans and specifications contained in Permit
                    Attachment VII(A)-5. [40 CFR 264.273(d)]

                    [Note:  The plans and specifications contained in
                    Permit Attachment VII(A)-5 must demonstrate how the
                    run-off management system will collect and control at
                    least the water volume resulting from a 24-hour,
                    25-year storm.]

     VII(A).D.5.    The Permittee shall manage the run-on and run-off
                    collection and holding facilities to maintain the
                    design capacity of the systems, according to the
                               VII(A)  -  3

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                                                           September 1988
                    design plans and operating practices specified in
                    Permit Attachment VII(A)-6.  [40 CFR 264.273(e)]

     VII(A).D.6.     The Permittee shall manage the treatment zone to
                    control wind dispersal of particulate matter,
                    according to the methods specified in Permit
                    Attachment VII(A)-7. [40 CFR 264.273(f)]

                    [Note:  Include Permit Condition VII(A).D.6. if the
                    treatment zone contains particulate matter that is
                    potentially subject to wind dispersal.  If Permit
                    Condition VII(A).D.6. does not apply, tbe Permit
                    Writer should include a condition which prohibits
                    placement of dispersible particulate matter in the
                    treatment zone.]

VII(A).E.  UNSATURATED ZONE SAMPLING AND MONITORING

The Permittee shall establish an unsaturated zone monitoring program that
meets the following conditions:

     VII(A).E.l.     The Permittee shall monitor the soil and soil-pore
                    liquid to determine if any of the hazardous
                    constituents specified in Permit Condition
                    VII(A).B.I. migrate out of the treatment zone.  [40
                    CFR 264.278(a)]

                    [Note:  The Permit Writer may require monitoring for
                    principal hazardous constituents (PHCs) in lieu of
                    the constituents specified in Permit Condition
                    VII(A).B.I.  PHCs are hazardous constituents,
                    contained in the wastes to be applied at the unit,
                    that are the most difficult to treat, considering the
                    combined effects of degradation, transformation, and
                    immobilization. The Permit Writer can establish PHCs
                    if, based on waste analyses, treatment
                    demonstrations, or other data, that effective
                    degradation, transformation, or immobilization of the
                    PHCs will assure treatment to at least equivalent
                    levels for the other hazardous constituents in the
                    wastes.  The PHCs should be specified in Permit
                    Condition VII(A).E.l.]

     VII(A).E.2.     The Permittee shall  [design, install] operate, and
                    maintain an unsaturated zone monitoring system,
                    according to the plans and specifications contained
                    in Permit Attachment VII(A)-8. [40 CFR 264.278(b)]
                                VII(A)  -  4

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                                                      September 1988
               [Note:  These plans and specifications should include
               sampling locations, points and depths, and procedures
               for selecting sampling locations and sampling
               equipment.]

VII(A).E.3.    The Permittee shall [specify or establish] a
               background value for each hazardous constituent
               (identified in Permit Condition VII(A).E.I.) to be
               monitored.  [40 CFR 264.278(c)]

               [Note:  The Permit Writer should specify the
               background values for each constituent or the
               procedures to be used to calculate the background
               values according to 40 CFR 264.278(c).]

VII(A).E,4.    The Permittee shall conduct soil monitoring and
               soil-pore liquid monitoring immediately below the
               treatment zone,  according to the procedures contained
               in Permit Attachment VII(A)-9. [40 CFR 264.278(d)]

               [Note:  The Permit Writer should specify the
               frequency and timing of soil-pore liquid monitoring
               after considering the frequency, timing, and rate of
               waste application and precipitation events and the
               soils permeability.)

VII(A).E,5.    The Permittee shall follow the sampling and analysis
               procedures, according to the plans and procedures
               contained in Permit Attachment VII(A)-10. [40 CFR
               264.278(e)]

               [Note:  As a minimum, Permit Attachment VII(A)-10
               should specify procedures and techniques for sample
               collection, sample preservation and shipment,
               analytical procedures, and chain-of-custody control.]

VII(A).E.6.    The Permittee shall determine whether there is a
               statistically significant change over background
               values for any hazardous constituent monitored under
               Permit Condition VII(A).E.I. each time the monitoring
               required by Permit Condition VII(A).E.4. is
               conducted.   [40 CFR 264.278(f)]  This determination
               shall be made using the statistical procedures
               contained in Permit Attachment VII(A)-11. [40 CFR
               264.278(f)(l) and (3)]  The Permittee shall make this
               determination within 	 days after completion of
               sampling.  [40 CFR 264.278(f)(2)]
                          VII(A)  -  5

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                                                           September 1988
                    [Note:   The Permit Writer should specify the time
                    period for making the determination in accordance
                    with 40 CFR 264.278(f)(2).   The Permit Writer should
                    consider the complexity of the statistical test and
                    the availability of laboratory facilities to conduct
                    the analyses of soil and soil-pore liquid samples.]

     VII(A).E.7.     If the Permittee determines, pursuant to Permit
                    Condition VII(A).E.6., that there is a statistically
                    significant increase of hazardous constituents below
                    the treatment zone, he shall notify the Regional
                    Administrator of this finding in writing within seven
                    days, indicating which constituents have shown
                    statistically significant increases, and apply for a
                    permit modification within 90 days to modify the
                    operating practices at the facility to maximize the
                    success of degradation, transformation, or
                    immobilization processes in the treatment zone. [40
                    CFR 264.278(g)]

     VII(A).E.8.     The Permittee need not submit the permit modification
                    required by Permit Condition VII(A).E.7., if he
                    successfully demonstrates in writing to the Regional
                    Administrator within 90 days, that a source other
                    than the regulated unit caused the increase or that
                    the increase resulted from an error in sampling,
                    analysis or evaluation.  The Permittee shall apply
                    for & permit modification within 90 days to modify
                    the unsaturated zone monitoring program at the
                    facility.  [40 CFR 264.278(h)]

VII(A).F.  INSPECTION SCHEDULES AND PROCEDURES

The Permittee shall inspect the land treatment unit weekly, after storms,
and in accordance with the inspection schedule in Permit Attachment II-3
to detect evidence of:   [40 CFR 264.273(g)]

     VII(A).F.l.     Deterioration, malfunctions, or improper operation of
                    the run-on and run-off control system.

     VII(A).F.2.     Improper functioning of wind dispersal control
                    measures [if applicable].

VII(A).G.  RECQRDKEEPING AND REPORTING

The Permittee shall include hazardous waste application dates and rates
in the operating record.   [40 CFR 264.279].
                                VII(A)  -  6

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                                                           September 1988
VII(A).H. CLOSURE AND POST-CLOSURE CARE

     VII(A).H.I.    The Permittee shall close-the land treatment unit,
                    according to the procedures in the Closure Plan,
                    Permit Attachment II-9.  and shall perform the
                    following as part of the closure:  [40 CFR 264.280]
          VII(A).H.I.a.
          VII(A).H.l.b.
          VII(A).H.l.d.
          VI1(A).H.l.e.
          VII(A).H.l.f.
The Permittee shall continue all operations
(including pH control) that are necessary to
maximize degradation, transformation, or
immobilization of hazardous constituents within
the treatment zone, in accordance with Permit
Conditions VII(A).D.I. and VII(A).D.2., except
to the extent such measures are inconsistent
with Permit Condition VII(A).H.I.g., during the
closure period.

The Permittee shall continue all operations in
the treatment zone to minimize run-off of
hazardous constituents, in accordance with
Permit Condition VII(A).D.3.,  during the closure
period.

The Permittee shall maintain the run-on control
system, in accordance with Permit Condition
VII(A).D.4., during the closure period.

The Permittee shall maintain the run-off
management system,  in accordance with Permit
Condition VII(A)D.5., during the closure period.

The Permittee shall control wind dispersal of
particulate matter, in accordance with Permit
Condition VII(A).D.7., during the closure
period.

[Note:  The Permit Writer should include Permit
Condition VII(A).H.l.e. only if the treatment
zone contains particulate matter that is
potentially subject to wind dispersal.]

The Permittee shall continue to comply with any
prohibition or condition concerning growth of
food-chain crops, in accordance with Permit
Condition VII(A).I.,  during the closure period.

The Permittee shall continue unsaturated zone
monitoring, in accordance with Permit Condition
VII(A).E., except that soil-pore liquid
                               VII(A)  - 7

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                                                           September 1988
                         monitoring may be terminated 90 days after the
                         last application of waste to the treatment zone,
                         during the closure period.

          VII(A).H.1.h.   The Permittee shall establish a vegetative cover
                         on the portion of the unit being closed,  at such
                         time that the cover will not substantially
                         impede degradation, transformation,  or
                         immobilization of hazardous constituents  in the
                         treatment zone.

                         [Note:  The vegetative cover must be capable of
                         maintaining growth without extensive
                         maintenance.]

     VII(A).H.2.    When closure is completed, the Permittee  should
                    submit to the Agency a certification by an
                    independent, qualified soil scientist that the unit
                    has been closed in accordance with the specifications
                    in the approved closure plan.

     VII(A).H.3.    After final closure,  the Permittee shall  follow the
                    plans and procedures in the approved Post-Closure
                    Plan contained in Permit Attachment 11-11 and the
                    Post-Closure Permit Module (Module XIII).  [40 CFR
                    264.280]

VII(A).I.  SPECIAL REQUIREMENTS FOR FOOD-CHAIN CROP PROTECTION

[Note:  The Permit Writer should include Permit Condition VII(A).I.I. if
the Permittee has successfully demonstrated that there is no substantial
risk to human health from the growth of food-chain crops in or on the
treatment zone, in compliance with 40 CFR 264.276(a).  If this condition
does not apply, the Permit Writer should add a condition to Permit
Condition VII(A).D. prohibiting the growth of food-chain crops.]

     VII(A).I.l.    The Permittee shall grow  [the Permit Writer should
                    specify the food-chain crops that may be grown in or
                    on the treatment zone], according to the plans and
                    procedures specified in Permit Attachment VIKA) -12.
                    [40 CFR 264.276(a)]

                    [Note:  Permit Attachment VII(A)-12 must demonstrate
                    how the Permittee shall comply with 40 CFR
                    264.276(a).  It should include the following:

                    (a)  Characteristics of the food-chain crop for which
                         the demonstration will be made.
                                VII(A)  -  8

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                                                           September 1988
                    (b)  Characteristics of the waste, treatment zone,
                         and waste application method and rate to be used
                         in the demonstration.

                    (c)  Procedures for crop growth, sample collection,
                         sample analysis, and data evaluation.

                    (d)  Establish a maximum concentration of hazardous
                         constituents to be found in the crop.

                    (e)  Characteristics of the comparison crop including
                         the location and conditions under which it was
                         or will be grown.]

                    [Note:  The Permit Writer should include Permit
                    Condition VII(A).I.2. if cadmium is contained in the
                    wastes placed in the treatment zone.]

     VII(A).I.2.    The Permittee shall not grow food-chain crops in the
                    treatment zone (where waste containing cadmium is
                    present),  unless all of the conditions of 40 CFR
                    264.276(b) are met.

VII(A).J.  SPECIAL LAND TREATMENT PROVISIONS FOR IGNITABLE OR REACTIVE
          WASTES

[Note:  The Permit Writer should include this condition if a land
treatment unit receives ignitable or reactive wastes.]

The Permittee shall not place ignitable or reactive waste in the land
treatment unit,  unless the procedures specified in Permit Attachment
VII(A)-13 are followed.  [40 CFR 264.281]

[Note:  The Permit Writer should ensure that Permit Attachment VII(A)-13
clearly documents how the Permittee will comply with the requirements of
40 CFR 264.281.   Perm 40 CFR 264.281(a), the Permittee shall not place
ignitable or reactive waste in the treatment zone, unless the waste is
immediately incorporated into the soil so that:  (1) the resulting waste,
mixture, or dissolution of material no longer meets the definition of
ignitable or reactive waste in 40 CFR 261.21 or 261.23 (The General
Requirements for Ignitable and Reactive Wastes) and the precautions in 40
CFR 264.17(b) are complied with or (2) the waste is managed in such a way
that it is protected from any materials or conditions which may cause it
to ignite or react.]

VII(A).K.   SPECIAL LAND TREATMENT PROVISIONS FOR INCOMPATIBLE WASTES

[Note:  The Permit Writer should include this condition if a land
treatment unit stores incompatible wastes.]
                               VII(A)  -  9

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                                                           September 1988
The Permittee shall not place incompatible wastes,  or incompatible wastes
and materials, in or on the same treatment zone, unless the procedures
specified in Permit Attachment VII(A)-14 are followed.   [40 CFR
264.17(b)]

[Note:  The Permit Writer should ensure that Permit Attachment VII(A)-15
clearly specifies how the Permittee shall comply demonstrate how the
Permittee will comply with the requirements of 40 CFR 264.17(b).]

VII(A).L. SPECIAL LAND TREATMENT PROVISIONS FOR HAZARDOUS WASTES  F020.
          F021. F022. F023. F026 and F027 [HSWA]

[Note:  The Permit Writer should include this section if the land
treatment unit manages any of the special "F" wastes.]

The Permittee may place hazardous wastes [specify which of the following]
F020, F021, F022, F023, F026, or F027 in a land treatment unit in
accordance with the waste management plan contained in Permit Attachment
VII(A)-16. [40 CFR 264.283]

[Note:  The Agency must approve the waste management plan developed under
40 CFR 264.283.  In evaluating a proposed waste management plan,  the
following factors must be considered:

      1.   Volume and application rate of the waste;

      2.   Chemical and physical characteristics of the wastes, including
          their potential to migrate through soil or to volatilize or
          escape into the atmosphere;

      3.   Attenuation properties of underlying and surrounding soils or
          other materials;

      4.   Mobilizing properties of other materials co-disposed with these
          wastes; and

      5.   Effectiveness of additional treatment, design, or monitoring
          techniques.

In evaluating the proposed plan, the Regional Administrator may determine
that  additional design, operating, and monitoring requirements are
necessary in  order to reduce the possibility of migration of these wastes
to ground water, surface water, or air to protect human health and the
environment.]
                               VII(A)  - 10

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                                                      September 1988
Item                          Date Due to the Regional Administrator

[Example:
1.  Soil Monitoring and                 June 25, 1989
    Soil-Pore Liquid Monitoring
    Procedures

2.  Sampling and Analysis               July 30, 1989
    Procedures

3.  Documentation of background         September 30, 1989]
    values for each constituent
                         VII(A)  -  13

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     PERMIT ATTACHMENTS REFERENCED IN MODULE VII(Al
                                OPERATIONS
                                                           September 1988
                         -  LAND TREATMENT
This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.  The Permit Writer may select
other numbering schemes, as appropriate, when preparing actual permits.
Permit Attachment No.


  II-3

  II-9

  11-11
  VII(A)-2


  VII (A) -3



  VII(A)-4


  VII (A) -5


  VII (A) -6




  VII(A)-7


  VII (A) -8


  VII(A)-9
          Plan or Document
(from the Part B Permit Application)

Facility Inspection Schedule

Facility Closure Plan

Post-Closure Care Plan

Land Treatment Program

Design Plans and
Spec ifications

Treatment Zone Run-Off
Control Plans and
Specifications

Run-On Control System
Plans and Specifications

Run-Off Management System
Plans and Specifications

Run-On And Run-Off
Collection and Holding
Facilities Design Plans
and Operating Practices

Wind Dispersal Control
Program

Unsaturated Zone
Monitoring System

Soil Monitoring and
Soil-Pore Liquid
Monitoring Procedures
                               VII(A)  -  14

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Permit Attachment No.
VII (A) -10
                                                         September 1988
                                   Plan or Document
                           (from the Part B Permit Application)

                           Sampling and Analysis
                           Procedures
                         Statistical Procedures
VII (A) -12
                           Food-Chain Crops
                           Plans and Procedures
                         Ignitable or Reactive Waste
                         Plans and Procedures
VII (A) -14
                           Incompatible Waste Management
                           Plan
                         Special "F" Waste Management
                         Plan
                         Schedule for Submitting Progress
                         Reports on Developing Alternatives
                         for Handling "Banned" Waste(s)
                             VII(A) - 15

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                                                           September 1988
              MODULE VII(B) - LAND TREATMENT DEMONSTRATIONS
[Note:  Before waste can be applied to a land treatment zone, the
Permittee must demonstrate that hazardous constituents in the waste can
be completely degraded, transformed, or immobilized.  If the Permittee
intends to conduct field tests or laboratory analyses to make this
demonstration, the Permittee must obtain a treatment or disposal permit
under 40 CFR 270.63.  This module covers the necessary permit conditions
for a demonstration under 40 CFR 270.63(a) and (b).   When a land
treatment demonstration program has been successfully completed, the
Permit Writer should use Permit Module VII(A) to provide for compliance
with all of the requirements of 40 CFR Part 264, Subpart M.]

[Note:  In general, a single permit module should be used if multiple
land treatment demonstrations will be covered by the same permit for a
given facility.  However, it is acceptable to include multiple land
treatment demonstration modules if, in the Permit Writer's judgment, the
treatment characteristics and permit conditions are sufficiently
different for each demonstration to warrant multiple modules.]

[Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]

VII(B).A.  MODULE HIGHLIGHTS

[The Permit Writer should include a general discussion of the activities
covered by this module.  The discussion should contain the following
information:  description of wastes that may be handled and their
application rates; a description of the unit that will be simulated in
the demonstration including treatment zone characteristics, theory of
treatment, climatic conditions including range of optimal conditions
(i.e., percent of moisture, pH, and nutrient level), a description of
field tests, laboratory analyses, available data or operating data; any
special features associated with the operation; and a reference to any
special permit conditions.]

VII(B).B.   PERMITTED AND PROHIBITED WASTE IDENTIFICATION
     VII(B).B.I.    The Permittee may treat hazardous wastes under the
                    following conditions:  the Permittee may conduct a
                    land treatment demonstration for the wastes listed
                    below.   Any field test or laboratory analysis
                    conducted in order to make this demonstration must be
                    likely to show that the following hazardous

                               VII(B)  -  1

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                                                           September 1988
                    constituents will be completely degraded,
                    transformed, or immobilized in the treatment zone of
                    the existing or proposed land treatment unit:  [40 CFR
                    264.272]

Description of   Hazardous       Data       Type of         Waste
Hazardous Waste  Waste No.       Source        Test     Application Rate

[Example:
Refinery DAF      K048      a. Literature  Field test   bbls/acre/test]
sludge                         sources     at the
                            b. Bench-scale facility
                               test report

[Note:  Under "Description of Hazardous Waste," the Permit Writer should
provide only a brief generic description, not comprehensive
characteristics.]

     VII(B).B.2.    The Permittee is prohibited from treating wastes that
                    are not identified in Permit Condition VII(B).B.I.

VII(B).C. DURATION OF DEMONSTRATIONS

Field tests and laboratory analyses during land treatment demonstration
shall be completed by 	.

[Note: The Permit Writer should specify the completion date(s) for field
tests and laboratory analyses.]

VII(B).D. LAND TREATMENT DEMONSTRATION REQUIREMENTS

The Permittee shall conduct the demonstrations in accordance with the
plans and specifications contained in Permit Attachment VII(B)-1. [40 CFR
264.272]

[Note:  The Permit Writer should specify the testing, analytical, design,
and operating requirements (including, in the case of field tests, the
horizontal and vertical dimensions of the treatment zone, waste
application rates, factors to be controlled (e.g., moisture, pH,
nutrients), monitoring parameters and procedures, closure, and clean-up
activities), in accordance with the requirements of 40 CFR 264.272(b).]

VII(B).E.  DEMONSTRATION TESTS AND ANALYTICAL PROCEDURES

The Permittee shall conduct the demonstration using the testing,
analytical procedures, and data sources specified in Permit Attachment
VII(B)-2. [40 CFR 264.272(c)]
                                VII(B)  -  2

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                                                           September 1988
[Note:  The Permit Writer should specify testing and analytical
requirements [40 CFR 264.272(c)] that are necessary to conduct a
demonstration,]

VII(B).F. RECORDKEEPING AND REPORTING

     VII(B).F.I.    The Permittee shall enter all monitoring, testing,
                    and analytical data obtained, pursuant to Permit
                    Conditions VII(B).D. and VII(B).E., in the operating
                    record.  [40 CFR 264.73]

     VII(B).F.2.    The Permittee shall report the results of the
                    demonstration program to the Regional Administrator
                    not later than 	 days after completion of the
                    analyses.

                    [The Permit Writer should specify the time frame
                    required for submitting the demonstration report.]

     VII(B).F.3.    The Permittee shall submit a certification, signed by
                    a person authorized to sign a permit application or
                    report under 40 CFR 270.11, that the field tests and
                    laboratory analyses have been carried out in
                    accordance with the conditions specified in the
                    Permit for conducting such tests and analyses.

                [Note:  Include Permit Condition VII(B).F.3. if the
               Permittee has been issued a two-phase permit and has
               completed the treatment demonstration.]
                               VII(B)  -  3

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                                                           September 1988      .
     PERMIT ATTACHMENTS REFERENCED IN MODULE VII(B) - LAND TREATMENT
                             DEMONSTRATIONS

This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.  The Permit Writer may select
other numbering schemes, as appropriate, when preparing actual Permits.
Permit Attachment No.         	Plan or Document	
                              (from the Part B Permit Application)

VII(B)-1                      Plans and Specifications for the
                              Land Treatment Demonstration

VII(B)-2                      Testing, Analytical Procedures, and Data
                              Sources
                                VII(B)  -  4

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                                                           September 1988
                         MODULE VIII - LANDFILLS
[Note:  Include this permit module when the Permittee is disposing of
hazardous waste in landfills.  Waste analysis requirements (40 CFR
264.13) and closure requirements (40 CFR 264.310) for landfills are
normally contained as attachments to the Permit in the Waste Analysis
Plan and Closure Plan.  Post-closure requirements (40 CFR 264.310) for
landfills normally are contained in the Post-Closure permit module
(Module XIII).  The Post-Closure Care Plan is incorporated in Module II
which covers general facility conditions.]

[Note:  In general, a single permit module should be used if two or more
landfills will be covered by the same permit for a given facility.
However, it is acceptable to include two or more landfill modules if, in
the Permit Writer's judgment, tank system characteristics and permit
conditions are sufficiently different to warrant multiple tank system
modules.]

[Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]

VIII.A.   MODULE HIGHLIGHTS

[The Permit Writer should include a general discussion of the activities
covered by this module.  The discussion should contain the following:
general description (including dimensions and capacity [cubic yards]),
liner description (including type of material and thickness for each
liner), description of leachate collection and removal system,
description of type of wastes disposed; any unique or special features
associated with the activity, and a reference to any special permit
conditions.]

VIII.B.  PERMITTED AND PROHIBITED WASTE IDENTIFICATION

The Permittee may dispose of specific hazardous wastes under the
following conditions:

     VIII.B.I.  The Permittee may dispose of the following hazardous
               wastes in [specify landfills and/or landfill cells],
               subject to the terms of this Permit:
                                VIII  -  1

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                                                           September 1988
Landfill and/or             Dimensions of
Landfill Cell             [Specify Landfill    Description of   Hazardous
Designation   Capacity  and/or Landfill Celll   Hazardous Waste  Waste No.

[Example:
South Cells   2,200 yd3  20 ft x 60 ft x       Dust from steel     K061
1 and 2                  50 ft deep            furnace
                                               Lead smelting       K069]
                                               dust

[Note:  If the hazardous wastes disposed in the landfill are numerous,
the Permit Writer may provide a reference here to an attachment, and
attach to this permit module a list of these wastes.  Under "Description
of Hazardous Waste," the Permit Writer should provide only a brief
general description, not comprehensive characteristics where a Hazardous
Waste Number is provided for reference.]

     VIII.B.2. The Permittee is prohibited from disposing in landfills
               any hazardous waste that is not included in Permit
               Condition VIII.B.I.

[Note:  The Permit Writer may also include here a list of specific wastes
or materials that are prohibited. ]

VIII.C.   DESIGN AND OPERATING REQUIREMENTS

[Note:  Permit Conditions VIII.C.I. -VIII.C.3., and VIII.C.5.  -
VIII.C.8. apply to the following:  a landfill that first received waste
on or after November 8, 1984, and continued to receive waste unitl May 8,
1985, each new landfill, each new landfill cell at an existing  facility,
each replacement of an existing landfill cell, and each lateral expansion
of an existing landfill unit.  A landfill that last received waste prior
to May 8, 1985 and is no longer active must be closed in accordance with
the requirements of 40 CFR 264.310 and is not subject to any of these
conditions.]

 [Note:  If a Permittee is granted an exemption from the double  liner
requirements  [40 CFR 264.301(c)] in accordance with 40 CFR 264.301(d),
then Permit Conditions VIII.C.3. - VIII.C.8. apply to the landfill.  In
addition, the Permittee is exempt from Permit Condition VIII.C.I. and is
subject to the requirements of 40 CFR 264.301(d).  This exemption must be
specified in the Permit.  The Permit Writer should add a condition to the
Permit stating the following:  "The Permittee is exempt from the double
liner requirement and is subject to the requirements of 40 CFR
264.301(d)."]
                                 VIII -  2

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                                                           September 1988
[Note:  If a Permittee has a monofill and is granted an exemption from
the double liner requirement [40 CFR 264.301(c)], in accordance with  40
CFR 264.301(e), then Permit Conditions VIII.C.4.- VIII.C.8. apply, to the
landfill.]

[Note:  The Permit Writer's justification for granting any exemptions
from the double liner requirements should be included in the
Administrative Record for this Permit.]

The Permittee shall design and operate the landfill(s) under the
following conditions:

     VIII.C.I. The Permittee shall install two [or more] liners and a
               leachate collection and removal system (one above and one
               between the liners) for each cell [or trench or area], in
               accordance with the design plans and reports contained in
               Permit Attachment VIII-1.  [40 CFR 264.301(c)]

               [Note:   Detailed design drawings of each liner and the
               leachate collection and removal system and engineering
               reports contained in Permit Attachment VIII-1. must
               demonstrate how the Permittee will meet all of the
               requirements of 40 CFR 264.301(c).]

               [Note:   The Permit Writer should provide a brief
               description of the liners (e.g., construction materials,
               thickness, permeability) and leachate collection and
               removal system (e.g., construction materials, thickness
               and permeability of drainage layer).   Example language is
               as follows:  The primary liner shall consist of 0.45-mil
               HOPE liner that is seam-welded and a composite secondary
               liner,  located four feet below the primary liner,
               consisting of a 0.4-mil HDPE liner and three feet of
               compacted clay having a permeability not greater than 10
               cm/sec.  The leachate collection and removal system shall
               consist of a drainage tile system embedded in a course
               sand media of 1x10"^ cm/sec or greater permeability,
               discharging to a sump with a level-controlled positive
               displacement pump, discharging to Tank 002 for subsequent
               testing and discharge to NPDES-regulated Outfall 002 or to
               the leachate treatment system.]

     VIII.C.2. Collected leachate must be managed in accordance with the
               design plans and reports contained in Permit Attachment
               VIII-2.
                                VIII - 3

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                                                      September 1988
          [Note:   In addition,  the Permit Writer should specify in
          the Permit how collected leachate will be managed.   The
          following conditions  are offered as examples:

          1.    Collected leachate shall be collected in the leachate
               storage tank,  T-105, and subsequently transported off
               site within 90 days to a permitted hazardous waste
               management facility.

          2.    The Permittee shall obtain an NPDES permit by October
               1, 1989 for the leachate discharged to the Wabash
               River.]

     [Note:  Use Permit Condition VIII.C.3. if the Regional
     Administrator finds that a landfill with alternative design and
     operating practices, together with location characteristics,
     will prevent the migration of any hazardous constituents into
     the ground water or surface water at least as effectively as
     the requirements of 40 CFR 264.301(c).  The Permit Writer
     should specify in the Permit all design and operating practices
     and location characteristics that are necessary to ensure
     compliance with 40 CFR 264.301(d).  Refer to the detailed plans
     and engineering and hydrogeologic reports of the alternative
     design and operating practices contained in Permit Attachment
     VIII-1.]

VIII.C.3. The Permittee shall locate, [construct,] operate, and
          maintain the landfill as specified in Permit Attachment
          VIII-l(a). so as to prevent the migration of any hazardous
          constituents into the ground watr or surface water, at
          least as effectively as the liners and leachate collection
          and removal systems oulined in 40 CFR 264.301(c).  [40 CFR
          264.301(d)]

          [Note:  Use Permit Condition VIII.C.4. if the Agency
          waives the double liner requirements for a monofill in
          accordance with the 40 CFR 264.301(e).  Permit Attachment
          VIII-1 should contain detailed plans and engineering and
          hydrogeologic reports of the alternative design and
          operating requirements.  The Permit Writer should specify
          in the Permit any additional operating practices and
          location characteristics that are necessary to ensure
          compliance with 40 CFR 264.301(e).  Note that conditions
          imposed by the Regional Administrator override any
          conflicting plans contained in the permit application.]

VIII.C.4. The Permittee shall design, construct, operate, and
          maintain the monofill in accordance with the plans and

                           VIII  -  4

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                                                           September 1988
               reports contained in Permit Attachment VIII-1 (monofill
               alternative).  [40 CFR 264.301(e)]

     VIII.C.5. The Permittee shall design, construct, operate,  and
               maintain a run-on control system in accordance with the
               design plans, specifications, and operating practices
               contained in Permit Attachment VIII-3.  [40 CFR
               264.301(f)j

     VIII.C. 6. The Permittee shall design, construct, operate,  and
               maintain a run-off management system in accordance with
               the design plans, specifications, and operating practices
               contained in Permit Attachment VIII-4.  [40 CFR
               264.301(g)]

     VIII.C.7. The Permittee shall empty or otherwise manage run-on and
               run-off collection and holding facilities to maintain the
               design capacity of the system(s) in accordance with the
               design plans and operating practices specified in Permit
               Attachment VIII-5.  [40 CFR 264.301(h)]

               [Note:  The Plans and specifications contained in Permit
               Attachment VIII-5 (or the Administrative Record) must
               demonstrate that the run-on and run-off control system(s)
               can collect and control at least the water volume
               resulting from a 24-hour, 25-year storm.]

               [Note:  Use Permit Condition VIII.C.8. if the landfill
               contains particulate matter that is subject to wind
               dispersal.  If Permit Condition VIII.C.8. does not apply,
               the Permit Writer should add a condition to prohibit
               placement of dispersable particulate matter in the
               landfill.]

     VIII.C.8. The Permittee shall cover or otherwise manage the landfill
               to control wind dispersal of particulate matter, in
               accordance with the methods specified in Permit Attachment
               VIII-6.  [40 CFR 264.301(i)]
VIII.D.
INSPECTION SCHEDULES AND PROCEDURES
[Note:  The Permit Writer should include Permit Conditions VIII.D.I. -
VIII.D.3. for new or expanded landfills; otherwise only Permit Condition
VIII.D.3. is necessary.]

The Permittee shall inspect the landfill in accordance with the following
conditions:
                                VIII  -  5

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                                                           September 1988
     VIII.D.I.  The Permittee shall inspect the liners and cover systems
               during construction and installation for uniformity,
               damage,  and imperfections (e.g.,  holes,  cracks,  thin
               spots, or foreign materials).  [40 CFR 264.303(a)]

     Vni.D.2.  The Permittee shall inspect the landfill immediately after
               construction or installation.   [40 CFR 264.303(a)]

          VIII.D.2.a.    Synthetic liners and covers must be inspected to
                         ensure tight seams and joints and the absence of
                         tears, punctures, or blisters.

          VIII.D.2.b.    Soil-based and admixed liners and covers  must be
                         inspected for imperfections including lenses,
                         cracks, channels, root holes,  or other
                         structural nonuniformities that may cause an
                         increase in the permeability of the liner or
                         cover.

     VIII.D.3.  The Permittee shall inspect the landfill (including the
               liner and leachate collection system) in accordance with
               the inspection schedule, Permit Attachment II-3.  [40 CFR
               264.303(b)]

               The landfill 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 systems.

               2.    Proper functioning of wind dispersal control systems
                     [if applicable].

               3.    The presence of leachate in, and proper functioning
                    of, leachate collection and removal systems [if
                    applicable].

     [Note:  The Permit Writer should confirm that the Permittee has
     addressed all major parameters in the proposed inspection schedule.
     These parameters include monitoring well condition, cover, liner(s),
     gas collection system, and leachate collection system components.]

VIII.E.   CELL LOCATION SURVEYING

The Permittee shall maintain the following items in the operating record:
[40 CFR 264.73 and 40 CFR 264.309]
                                VIII  -  6

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                                                           September 1988
     1.   A map with the exact location and dimensions (including depth)
          of each cell with respect to permanently surveyed benchmarks.

     2.   The types of waste in each cell and the approximate location of
          each hazardous waste type within each cell.

VIII.F.   CLOSURE AND POST-CLOSURE CARE

The Permittee shall conduct closure and post-closure activities in
accordance with the following conditions:

     VIII.F.I. At final closure of the landfill, or upon closure of any
               cell, the Permittee shall follow the procedures in the
               approved closure plan contained in Permit Attachment II-
               9.   [40 CFR 264.310(a)]

     VIII.F.2. After final closure, the Permittee shall follow the plans
               and procedures in the approved Post-Closure Care Plan in
               Permit Attachment 11-11 and in the Post-Closure Permit
               Module (Module XIII).  [40 CFR 264.310(b)]
VIII.G.   SPECIAL LANDFILL PROVISIONS FOR IGNITABLE OR REACTIVE WASTES

[Note:  The Permit Writer should include this section if ignitable or
reactive wastes are disposed in the landfill.]

The Permittee shall manage ignitable or reactive wastes in accordance
with the following conditions:

     VIII.G.I. The Permittee shall not place ignitable or reactive waste
               in the landfill, unless the procedures specified in Permit
               Attachment VIII-7 are followed. [40 CFR 264.312]

               [Note:  The Permit Writer should ensure that Permit
               Attachment VIII-7 clearly documents how the Permittee will
               comply with 40 CFR 264.312(a).  In accordance with the
               regulations, ignitable or reactive wastes can be placed in
               a landfill if:  (a) the waste is treated or mixed before
               or immediately after placement in the landfill so that the
               resulting waste, mixture, or dissolution of material no
               longer meets the definition of ignitable or reactive waste
               and (b) compliance with 40 CFR 264.17 (General
               Requirements for Ignitable, Reactive, or Incompatible
               Wastes) is attained.]

               [Note:  Ignitable wastes in containers may be landfilled
               without meeting the requirements of Permti Condition

                                VIII  -  7

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                                                           September 1988
               VIII.G.I.,  if they are disposed in such a way that they
               are protected from any material or conditions that may
               cause them to ignite.   Minimum requirements are listed in
               40 CFR 264.312(b).   Use Permit Condition VIII.G.2. if
               ignitable wastes in containers will be disposed.]

     VIII.G.2.  Ignitable wastes in containers may be disposed of  in the
               landfill cells designated in Permti Condition VIII.B.I.
               provided that the following conditions are met:  [40 CFR
               264.312(b)]

          VIII.G.2.a     Ignitable wastes must be disposed of in  non-
                         leaking containers which have been inspected
                         just prior to being placed in the landfill.

          VIII.G.2.b     Containers must be handled and placed in the
                         landfill in a manner to avoid heat, sparks,
                         rupture,  or other conditions that might  cause
                         ignition of the wastes.

          VIII.G.2.c     Ignitable wastes must be covered daily with six
                         inches of soil or other non-combustible
                         material.

          VIII.G.2.d     Containers must not be placed in cells that
                         contain or will contain other wastes that may
                         generate heat sufficient to cause ignition of
                         the waste.

VIII.H.   SPECIAL LANDFILL PROVISIONS FOR INCOMPATIBLE WASTES

[Note:  The Permit Writer should include this condition if the landfill
receives incompatible wastes.]

The Permittee shall not place incompatible wastes, or incompatible wastes
and materials,  in the same landfill cell, unless the procedures specified
in Permit Attachment VIII-8 are followed. [40 CFR 264.217(b)]

[Note:  The Permit Writer should ensure that Permit Attachment VIII-8
clearly specifies how the Permittee shall comply with the requirements of
40 CFR 264.17(b) and (c).

VIII.I.   SPECIAL LANDFILL PROVISIONS FOR HAZARDOUS WASTES F020.  F021.
          F022. F023. F026. and F027  [HSWA]

[Note:  The Permit Writer should include this section if the landfill
receives any of the special "F" wastes.]
                                VIII  -

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                                                           September 1988
The Permittee may place hazardous wastes [specify which of the following]
F020, F021, F022, F023, F026, or F027 in the landfill in accordance with
the waste management plan contained in Permit Attachment VIII-9.

[Note:  The Regional Administrator must approve the waste management plan
developed under 40 CFR 264.317.  In evaluating a proposed waste
management plan, the following factors must be considered:

     1.   Volume of the wastes;

     2.   Chemical and physical characteristics of the wastes, including
          their potential to migrate through soil or to volatilize or
          escape into the atmosphere;

     3.   Attenuation properties of underlying and surrounding soils or
          other materials;

     4.   Mobilizing properties of other materials co-disposed with these
          wastes; and

     5.   Effectiveness of additional treatment, design, or monitoring
          techniques.

In evaluating the proposed plan, the Regional Administrator may determine
that additional design, operating, and monitoring requirements are
necessary in order to reduce the possibility of migration of these wastes
to ground water, surface water, or air to protect human health and the
environment.]

VIII.J.   SPECIAL LANDFILL PROVISIONS FOR HAZARDOUS WASTES RESTRICTED
          FROM LANDFILL UNITS [HSWA]

[Note:  The Permittee may continue to place restricted hazardous waste,
as defined in 40 CFR Part 268, in a landfill beyond the prohibition date
if the Permittee has been granted an extension to the date [40 CFR
268.1(c)(l)]  or the Permittee has been granted an exemption from the
prohibition [40 CFR 268.l(c)(2)], or the waste is contaminated soil or
debris resulting from a response action taken under CERCLA Sections 104
or 106 or a corrective action taken under RCRA [40 CFR 268.l(c)(3)]:
These wastes may be disposed only until November 8, 1988).  The Permit
Writer should include this section in the Permit if one or more of these
situations occur.  The Permit Writer should document the basis for
granting all exceptions to the land disposal restrictions in the
Administrative Record for this Permit.]

     VIII.J.I. The Permittee may place the following restricted hazardous
               waste(s) in a landfill subject to the terms of this permit
               and as described below:

                                VIII  - 9

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                                                           September 1988
Landfill and/or
Landfill Cell

[Example:
 South Cell
Hazardous
Waste No.
 F001
 Description of
 Hazardous Waste
Tetrachloro-
  ethylene
Type of
Approval
Expiration
_Date-
Exemption
 August 31,
   1998]
     [Note:  The Permit Writer should include Permit Conditions VIII.J.2
     - VIII.J.4. in situations where case-by-case extensions to the
     prohibition date have been granted under 40 CFR 268.5.]

   VIII.J.2.   All restricted waste placed in the landfill must be
               generated at the facility covered by this RCRA permit,
               unless the restricted waste is from another generating
               facility that is covered by an EPA- or State-approved
               application for a restricted waste capacity extension that
               specifically allows placement into the Permittee's
               landfill.  [40 CFR 268.5]

   VIII.J.3.   The Permittee shall immediately notify the Regional
               Administrator as soon as he has knowledge of any change in
               the conditions certified in his approved application for
               the case-by-case capacity extension, dated 	.    [40
               CFR 268.5(f>]

   VIII.J.4.   The Permittee shall submit written progress reports
               regarding the approved case-by-case capacity extension
               that: (a) describe the overall progress made toward
               constructing or otherwise providing alternative treatment,
               recovery or disposal capacity; (b) identify any event
               which may cause or has caused a delay in the development
               of the capacity; and (c) summarize the steps taken to
               mitigate the delay.  The progress reports must be
               submitted in accordance with the schedule in Permit
               Attachment VIII-10.  [40 CFR 268.5(g)]

     [Note:  Permit Conditions VIII.J.5. and VIII.J.6. only apply to new
     landfill, replacements of an existing landfill, and each lateral
     expansion of an existing landfill unit.]
     Extensions may be granted for up to one year from the prohibition
     date, plus one additional year with proper demonstration.   [40 CFR
     268.5(e)]
     Exemptions shall be no longer than the term of the RCRA permit for
     the unit.  [40 CFR 268.6(h)]

                                VIII - 10

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                                                           September 1988
   VIII.J.5.   The Permittee shall comply with all applicable
               requirements of 40 CFR Subpart F to protect ground water
               and all applicable requirements of 40 CFR 264.301(c), (d)
               and (e).

   VIII. J. 6.   The Permittee shall comply with all applicable
               requirements of 40 CFR Subpart F to protect ground water
               and all applicable requirements of 40 CFR 264.221(c), (d),
               and (e).

   VIII.J.7.   The Permittee shall maintain records of notices and
               certifications received from generators and waste
               treatment facilities that restricted waste is accepted
               from,  and obtain copies of waste analysis data to
               determine that the wastes are in compliance with the
               applicable treatment standards in 40 CFR 268.41.   [40 CFR
               268.7(c)]

VIII.K.   SPECIAL LANDFILL PROVISIONS FOR LIQUID WASTE

   VIII.K.I.   The Permittee shall not place bulk or non-containerized
               liquid wastes or waste containing free liquids in a
               landfill.  [40 CFR 264.314(b)]

   VIII.K.2.   The Permittee shall demonstrate the absence of free
               liquids in either a containerized or a bulk waste by the
               following test:   "Method 9095 (Paint Filter Liquids Test)"
               as described in "Test Methods for Evaluating Solid Wastes,
               Physical/Chemical Methods" (EPA Publication No. SW-846).

   VIII.K.3.   The Permittee shall not place containers holding free
               liquid in the landfill unless: [40 CFR 264.314(d)]

     VIII.K.3.a.     All  free-standing liquid:  (i) has been removed by
                    decanting,  or other methods;  (ii) has been mixed with
                    absorbent or solidified so that free-standing liquid
                    is no longer observed; or (iii) has been otherwise
                    eliminated;  or

     VIII.K.3.b.     The  container is no larger than an ampule; or

     VIII.K.3.c.     The  container is designed to hold free liquids for
                    use  other than storage (e.g., batteries, capacitors);
                    or
     VIII.K.3.d.     The container is a lab pack as defined in 40 CFR
                    264.316 and is disposed of in accordance with Permit
                    Condition VIII.M.

                                VIII - 11

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                                                           September 1988
VIII.L.   SPECIAL REDUCTION REQUIREMENTS FOR EMPTY CONTAINERS

The Permittee shall not dispose of any containers that are larger than
ampules in the landfill unless they are at least 90 percent full when
placed in the landfill or they are crushed, shredded, or similarly
reduced in volume to the maximum practical extent before placement in the
landfill. [40 CFR 264.315]

VIII.M.   PROVISIONS FOR THE CONTAINERIZED LANDFILL DISPOSAL OF LAB PACKS

[Note:  The Permit Writer should include this section if the landfill
disposes of small containers of hazardous waste in overpacked drums (lab
packs).]

The Permittee shall dispose of any small containers of hazardous waste in
overpacked drums (lab packs) in accordance with the detailed plans and
procedures contained in Permit Attachment VIII-11. [40 CFR 264.316]

VIII.N.   COMPLIANCE SCHEDULE

[Note:  The Permit Writer should include this condition if the Permittee
is required to complete specific steps within a specific time period,
beyond those covered by other conditions of the Permit, as a criteria for
retaining this operating Permit.  Compliance schedules are generally used
in cases where requirements that are supposed to be met by the Permittee
before the Permit is issued are deferred for good cause until after
permit issuance.  Appropriate compliance schedules included in the Part B
Permit Application should be attached to, or incorporated in,  the
Permit.  If the application does not include a compliance schedule, the
Permit Writer should prepare one and attach it to the Permit.  Each
compliance schedule should have at least two columns - one identifying
the activity, and one identifying the milestone or completion dates.  The
following is an example of a condition that may apply for a landfill.]

The Permittee shall provide the following information to the Regional
Administrator:

          Item                Date Due to the Regional Administrator

   [Example:
   1.  Wind Dispersal Control                  March 10, 1989
       System

   2.  Design Plans,                           June 15, 1989]
       Specifications, and Operating
       Practices for Run-Off
       Management System

                                VIII - 12

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                                                           September 1988
         PERMIT ATTACHMENTS REFERENCED IN MODULE VIII - LANDFILLS
This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.  The Permit Writer may select
other numbering schemes, as appropriate, when preparing actual Permits.
Permit Attachment No.


11-3

II-9

11-11

VIII-1



VHI-l(a)
VIII-1  (monofill
alternative)

VIII-2
VIII-3


VIII-4


VIII-5



VIII-6

VI1I-7
          Plan or Document
(from the Part B Permit Application)

Facility Inspection Plan

Closure Plan

Post-Closure Care Plan

Design Plans and Operating Practices for
Liners and Leachate Collection and Removal
Systems

Alternative Design Plans and Operating
Practices for Liners and Leachate
Collection and Removal Systems

Design Plans and Operating Practices
for a Monofill

Design Plans and Operating Practices for
the Leachate Collection, Removal, and
Management System

Design Plans and Operating Practices for
the Run-On Control System

Design Plans and Operating Practices for
the Run-Off Management System

Design Plans and Operating Practices for
the Run-On and Run-Off Collection and
Holding Facilities

Wind Disposal Control System

Ignitable and Reactive Waste Management
Plan
                                VIII - 13

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                                                           September 1988
                                                4
Permit Attachment No.


VIII-8

VIII-9

VIII-10



VIII-11
          Plan or Document
(from the Part B Permit Application)

Incompatible Waste Management Plan

Special "F" Waste Management Plan

Schedule for Submitting Progress Reports on
Developing Alternatives for Handling Land-
Banned Wastes

Plans and Procedures for the Disposal of
Small Containers (Lab Packs) of Hazardous
Waste
                                VIII - 14

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                                                           September 1988
                       MODULE IX(A) - INCINERATION
[Note:  This module, plus Module IX(B) for Short-Term Incineration,
covers the four major phases of incineration operation:  (1) shakedown;
(2) trial burn; (3) post-trial burn operation; and (4) final operation.
This module provides the conditions for final operation for both existing
and new incineration units.  The Short-Term Incineration Module covers
the shakedown, trial burn, and post-trial burn operating phases for new
incineration units only.  These phases of operation are discussed in 40
CFR 264.344(c).]

[Note:  This module is not used for incineration units that qualify for
an automatic exemption under 40 CFR 264.340(b).  These units must comply
only with the waste analysis and closure requirements.  For units that
are granted an exemption under 40 CFR 264.340(c), parts of this module
may be appropriate to use on a case-by-case basis.  The Permit Writer
should document the basis for granting exemptions in the Administrative
Record for this facility.]

[Note:  For facilities with more than one incineration unit, a separate
permit module should be used for each unit.]

[Note:  Waste analysis requirements (40 CFR 264.13) and closure
requirements (40 CFR 264.197) for incineration units are generally
contained as attachments to the Permit in the Waste Analysis Plan and
Closure Plan.  The Waste Analysis Plan and Closure Plan must cover the
requirements of 40 CFR 264.341 and 40 CFR 264.351, respectively, in
accordance with 40 CFR 264.340(b).]

[Note:  For new incinerators, some permit conditions will initially be
tentative and will need to be finalized after the trial burn results have
been evaluated.  In this module, the conditions that may be subject to
change for new incinerators are marked with an asterisk (*).  In crafting
actual permit conditions,  the Permit Writer should mark tentative
conditions with an asterisk, or other designation, and include a note
such as the following..,*The number in this permit condition is tentative
and will be made final after the trial burn results have been evaluated.
In the case of maximums, EPA reserves the right to specify any number
less than this value as the shut-off limit.  In the case of minimums, EPA
reserves the right to specify any value higher.]

[Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]
                                IX(A) - 1

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                                                           September 1988
IX(A).A.  MODULE HIGHLIGHTS

[The Permit Writer should include a general discussion of the activities
covered by this module.  The discussion may include some or all of the
following information:  type of incineration system; types of air
pollution control equipment used; system capacity in terms of either heat
rate or mass flow rate; key operating conditions, such as combustion
temperature (and whether these conditions were based on trial burn
results, or data in lieu of a trial burn);  a general description of the
automatic waste feed cut-off system; the types of waste that may be
burned; the principal organic hazardous constituents selected and the
rationale for this selection; any unique or special features associated
with the operation; and a reference to any special permit conditions.]

IX(A).B.  IDENTIFICATION CRITERIA FOR PERMITTED AND PROHIBITED WASTE

[Note:  There are two general options for identifying the allowable waste
feed to the incinerator, pursuant to 40 CFR 264.344(a).  The first option
covers situations where it is not practical to name all the wastes that a
facility might be permitted to burn.  This is a common situation for a
commercial off-site facility.  In this case, the Permit Writer should
identify a set of criteria that establishes limitations on the general
physical and chemical characteristics of the waste feed to the
incinerator.  The second option is most appropriate for incinerators that
are used to burn waste from specific processes, such as on-site
incinerators.  Here, it is usually possible to identify the specific
wastes or classes of wastes that the Permittee shall be permitted to
burn.  For example, a manufacturer of Freon might be permitted to burn
the chlorofluorocarbon POHC and other related wastes associated with the
production process.  Examples of recommended language addressing these
two options are presented in Permit Conditions IX(A).B.l. and IX(A).B.2.J

Except during the periods specified in the conditions for Short-Term
Incineration under Shakedown Period, Trial Burn and Post-Trial Burn, the
Permittee may incinerate the following hazardous wastes, as specified in
this Permit and only under the terms of this Permit.  The Permittee may
only feed the hazardous wastes as identified below  [or in Permit
Attachment IX(A)-1. List of Wastes] at the facility subject to Permit
Conditions IX(A).C. through IX(A).F., and IX(A).H,

     IX(A).B.l.     [Option 1. - Off-Site Commercial Facility:  Include
                    the following conditions for each waste stream.] The
                    Permittee shall incinerate only hazardous wastes
                    meeting the following criteria:
                                IX(A) - 2

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                                                      September 1988
               o    No hazardous constituents shall have a heat of
                    combustion less than that of 	
                    [POHC]  (	 BTU/lb).

                    [Note:  Using the heat of combustion method of
                    incinerability ranking,  the specified POHC
                    should be the facility's POHC with the lowest
                    heat of combustion.   It should be noted that
                    other methods of incinerability ranking, such as
                    thermal stability at low oxygen are available.
                    (See preamble to proposed incineration
                    amendments,  Summer 1988.)  Use of another
                    ranking system in addition to, or instead of,
                    heat of combustion would require modification of
                    this model condition.]

               o    The ash content of the waste shall be no greater
                    than 	  percent by weight.*

               o    The total halide content of the waste shall be
                    no greater than 	 percent by weight.*

               o    The physical state of the waste feed shall be 	
                    	.   [specify solid or liquid]

               o    No waste, or combination of wastes, with a
                    heating value of less than 	 BTU/lb [or
                    other appropriate unit of measure], shall be fed
                    to the secondary chamber of the incinerator [or
                    ( in the  case of a single chamber liquid
                    injection incinerator) to the incinerator]
                    unless fed in conjunction with auxiliary fuel.

               o    The viscosity of waste fed to the secondary
                    chamber [or incinerator,  in the case of single
                    chamber liquid injection incinerator] burner
                    number 	 shall not exceed 	 cp.

IX(A).B.2.      [Option 2 - On-Site Facility]  The Permittee may
               incinerate only the following hazardous wastes:
                           IX(A)  -  3

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                                                           September 1988
Hazardous Waste No.
   Description
     Feed Rate
[Example:
 D003, D004, D008
 D001
Freezon 123b reactor
bottoms ("Tars")
Freezon 122b rich
liquid
(Specify rate of input
in appropriate units--
Ib/hr)

(Specify rate of input
in appropriate units--
Ib/hr)]
[Note:  The Permit Writer may impose other limitations, such as those
under Option 1 above, on the waste feed, as necessary, to ensure
compliance with the performance standards of 40 CFR 264.343.  All such
limitations, however, should be derived from the results of the trial
burn or from the data submitted in lieu of a trial burn, or for
conditions such as waste feed viscosity, from the burner manufacturer's
specifications.]

     IX(A).B.3.     Throughout operation, the Permittee shall conduct
                    sufficient analysis in accordance with the Waste
                    Analysis Plan, Permit Attachment 11 -1.  to verify that
                    waste fed to the incinerator is within the physical
                    and chemical composition limits specified in this
                    Permit.

     [Note:  The Permit Writer may also include here a list of specific
     wastes or materials that are prohibited.]

IX(A).C.  CONSTRUCTION. INSTRUMENTATION. AND OPERATIONAL PERFORMANCE
          REQUIREMENTS

     [Note:  Permit Condition IX(A).C.l. applies only to new facilities;
     Permit Condition IX(A).C.2. applies only to existing facilities.]

     IX(A).C.l.     The Permittee shall construct and maintain the
                    incinerator in accordance with the design plans and
                    specifications contained in Permit Attachment IX(A)-
                    2. The Permittee shall not feed hazardous wastes to
                    the incinerator until Permit Condition I.E.12
                    (Certification of Construction or Modification) has
                    been complied with.

     IX(A).C.2.     The Permittee shall maintain the incinerator in
                    accordance with the design plans and specifications
                    contained in Permit Attachment IXCA)-2.
                                IX(A) - 4

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                                                      September 1988
               [Note:  40 CFR 264.345(b)(5) requires that the Permit
               specify any allowable variations in system design
               during the operation of the incinerator.  The Permit
               Writer should develop additional conditions,  as
               necessary, to cover these variations and/or provide a
               description of these variations as an attachment to
               the Permit, Permit Attachment IX(A)-3.]

IX(A).C.3.     The Permittee shall install and test all
               instrumentation in accordance with the design plans,
               performance specifications, and maintenance
               procedures contained in Permit Attachment IX(A)-2
               prior to handling hazardous wastes in the incinerator
               unit.

The Permittee shall [design, construct,  and] maintain the
incinerator so that when operated, in accordance with the operating
requirements specified in this permit, it will meet the performance
standards specified in Permit Conditions IX.(A).C.4. through
IX.(A).C.6.  [40 CFR 264.343]

IX(A).C.4.     The incinerator shall achieve a destruction and
               removal efficiency (DRE)  of 99.99 percent for each of
               the following principal organic hazardous
               constituents (POHC) for each waste feed.  The DRE
               value shall be determined using the method specified
               in 40 CFR 264.343(a)(1).   [40 CFR 264.343(a)(1)]

               [Note:  Any incinerator burning hazardous wastes
               F020, F021, F022, F023, F026, or F027 must achieve a
               DRE of 99.9999 percent for each designated POHC.
               These POHCs, designated by the Permit Writer, must be
               more difficult to incinerate than tetra-, penta-, and
               hexachlorodibenzo-p-dioxins and dibenzofurans.] [40
               CFR 264.343(a)(2)]
                       Waste Feed                    POHC(s)
                           IX(A) - 5

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                                                           September 1988
     IX(A).C.5.      The Permittee shall control hydrogen chloride (HC1)
                    emissions,  such that the rate of emissions is no
                    greater than the larger of either 1.8 kilograms per
                    hour (4 pounds/hour) or one percent of the HC1 in the
                    stack gas,  prior to entering any pollution control
                    equipment.   [40 CFR 264.343(b)]

     IX(A).C.6.      The incinerator shall not emit particulate matter in
                    excess of 180 milligrams per dry standard cubic meter
                    (0.08 grains per dry standard cubic foot) when
                    corrected for the amount of oxygen in the stack gas,
                    in accordance with the formula specified in 40 CFR
                    264.343(c).  [40 CFR 264.343(c)]

                    [Note:  The Permit Writer should add the appropriate
                    correction procedure to this condition in cases where
                    a facility operates vmder conditions of oxygen
                    enrichment.  [40 CFR 264.343(c)]

[Note:  40 CFR 264.345(b)(1)-(4) requires the Permit Writer to establish
operating limits for carbon monoxide, waste-feed rate, combustion
temperature, and a combustion gas velocity indicator.  Permit Conditions
IX(A).C.7. through IX(A).C.10.  cover those requirements.  40 CFR
264.345(b)(6) requires the Permit Writer to establish any other operating
requirements (conditions) necessary to ensure compliance with the
performance standards.  Permit Conditions IX(A).C.11. through IX(A).C.22.
are example permit conditions that serve this purpose.  These permit
conditions incorporate the list of key operating parameters provided by
the EPA Guidance on Trial Burn Reporting and Setting Permit Conditions.
This guidance should be consulted for assistance in determining which of
these conditions apply for a specific facility and the specific method of
setting each condition, given the design and operation of the facility
and the results of the trial burn or data in lieu of a trial burn.]

Except during the periods specified in the Permit Conditions for Short-
Term Incineration under the Shakedown Period, Trial Burn Period, and
Post-Trial Burn Period, the Permittee shall feed the wastes described in
Permit Condition IX(A).B. to the incinerator only under the following
conditions:  [40 CFR 264.345]

     IX(A).C.7.     Carbon monoxide concentration in the stack exhaust
                    gas, monitored as specified in Permit Condition
                    IX(A).E., and corrected for the amount of oxygen in
                    the stack gas, shall not exceed 	 ppm over a one
                    hour rolling average [or under the alternative format
                    for CO limits, 	 PPm at any time, or 	 ppm for
                    more than 	 minutes in any clock hour].*
                                IX(A) - 6

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                                                      September 1988
IX(A).C.8.     The Permittee shall be limited to the following waste
               feed rates in the following locations:

               [Note:  The Permit should specify the feed rate of
               each waste stream type (i.e., solid waste, organic
               liquid waste) to each combustion chamber.  The
               following are example conditions.  The Permit Writer
               shall select the condition(s) that are most
               appropriate for the Permit being prepared.]

               (a)  Maximum primary chamber organic liquid waste
                    feed rate of 	 lb/hr.*

               (b)  Maximum primary chamber aqueous waste feed rate
                    of 	 lb/hr.*

               (c)  Maximum primary chamber solid waste feed rate of
                    	 lb/hr.*

               (d)  Maximum secondary chamber organic liquid waste
                    feed rate of 	 lb/hr.*

               (e)  The size of waste containers fed to the primary
                    chamber shall not exceed 	 gallons of
                    capacity.*

IX(A).C.9.     Combustion temperature,  monitored as specified in
               Permit Condition IX(A).E., shall be maintained at
               	 F (or C) or greater.*

               [Note:  For dual-chamber incinerators,  a minimum
               temperature should be set for each chamber.]

IX(A).C.10.    Combustion gas velocity,  monitored as specified in
               Permit Condition IX(A).E., shall be no greater than
               	 ft/s.*

IX(A).C.ll.    The mass feed rates of toxic metals to the
               incinerator shall not exceed:
          Arsenic:
          Barium:
          Chromium:
          Beryllium:
          Cadmium:
(grams/min)   Antimony:
(grams/min)   Lead:
(grams/min)   Mercury:
(grams/min)   Silver:
(grams/min)   Thallium:
(grams/min)
(grams/min)
(grams/min)
(grams/min)
(grams/min)
                           IX(A)  -  7

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                                                      September 1988
               [Note:   An option to Permit Condition IX(A).C.ll.,
               which would be more straightforward to enforce,  is  to
               set the limit on the actual concentration of metals
               in the  waste feed.  Then only the concentration value
               is required to determine compliance,  rather than the
               concentration and waste feed rate at a specific point
               in time.  However, this approach provides the
               Permittee with less flexibility to feed higher
               concentrations of metals when operating the
               incinerator at low feed rates.

IX(A).C.12.     Atomization fluid pressure (e.g., steam, air) shall
               be no less than 	 psig.

IX(A).C.13.     The turndown ratio for the waste burner shall be no
               greater than 	.

[Note:  Permit Conditions IX(A).C.14. through IX(A).C.16 relate to
ensuring compliance with the HC1 emission standard in 40 CFR
264.343(b).   The Permit Writer must determine which conditions are
appropriate for a specific facility depending on the control devices
present.]

IX(A).C.14.     The - ratio to the absorber, monitored as specified
                   G
               in Permit Condition IX(A).E., shall be maintained at
               no less than 	  [sometimes expressed as gals per
               thousand cubic feet though usually dimensionless].*

IX(A).C.15.     The scrubber effluent pH, monitored as specified in
               Permit Condition IX(A).E., shall be maintained at a
               minimum pH of 	.*

IX(A).C.16.     The scrubber water delivery (nozzle) pressure,
               monitored as specified in Permit Condition IX(A).E.,
               shall be maintained at no less than 	 psig.

[Note:  Permit Conditions IX(A).C.17. through IX(A).C.22. relate to
ensuring compliance with the particulate emission standard in 40 CFR
264.343(c).   Note, however, that most facilities will not have all
of the devices mentioned.  The Permit Writer must determine which
conditions are appropriate for a specific facility.]

IX(A).C.17.     Pressure drop across the venturi scrubber, monitored
               as specified in Permit Condition IX(A).E., shall be
               maintained at no less than 	 psi.*
                           IX(A) - 8

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                                                      September 1988
IX(A).C.18.    The scrubber blowdown rate shall be maintained at no
               less than 	 gpm.*

IX(A).C.19.    The power to the electrostatic precipitator,
               monitored as specified in Permit Condition IX(A).E.,
               shall be maintained at no less than 	 kVA.*

IX(A).C.20.    The voltage applied to the ionizing wet scrubber,
               monitored as specified in Permit Condition IX(A).E.,
               shall be no less than 	 kV.*

IX(A).C.21.    Pressure drop across the baghouse,  monitored as
               specified in Permit Condition IX(A).E., shall be no
               less than 	 psi,  nor greater than 	 psi.*

               [Note:  The Permit Writer may require the Permittee
               to specify in the Contingency Plan, provisions for
               maintaining and replacing bags.]

IX(A).C.22.    The Permittee shall control fugitive emissions from
               the combustion zone of the incinerator by maintaining
               the pressure in the primary combustion chamber,
               monitored as specified in Permit Condition IX(A).E.,
               to not exceed 	 inches of mercury.   [40 CFR
               264.345(d)]

               [Note:  The Permit Writer may specify another method
               for controlling fugitive emissions.  The method must
               be demonstrated in the Part B Permit Application;
               this information should be attached to the Permit,
               Permit Attachment IX(A)-4. and referenced.]

IX(A).C.23.    Compliance with the operating conditions specified in
               Permit Conditions IX(A).C.7.  through IX(A).C.22. will
               be regarded as compliance with the  required
               performance standards in Permit Conditions IX(A).C.4.
               through IX(A).C.6.   However,  evidence that compliance
               with these operating conditions is  insufficient to
               ensure compliance with the performance standards, may
               justify modification, revocation,  or reissuance of
               the Permit pursuant to 40 CFR 270.41.  [40 CFR
               264.343(d)]

               [Note:  It must be understood, by both the Permit
               Writer and Permittee, that violation of the permit
               operating conditions can give rise  to an enforcement
               action.  If the Permittee complies  with the permit
                           IX(A)  -  9

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                                                           September 1988
                    operating conditions,  but it is later shown that the
                    performance standards  are not being achieved, the
                    permit may be modified or revoke and reissued, but
                    enforcement actions are not available.   Thus, each
                    set of operating conditions should directly relate to
                    achieving the performance standards in 40 CFR
                    264.343.]

IX(A).D.  INSPECTION REQUIREMENTS

The Permittee shall inspect the incineration unit in accordance with the
Inspection Schedule, Permit Attachment II-3.  and shall complete the
following as part of these inspections:

     IX(A).D.l.      The Permittee shall thoroughly, visually inspect the
                    incinerator and associated equipment (including
                    pumps, valves, conveyors, pipes, etc.)  for leaks,
                    spills, fugitive emissions, and signs of tampering.
                    [40 CFR 264.347(b)]

     IX(A).D.2.      The Permittee shall thoroughly, visually inspect the
                    instrumentation for out-of-tolerance monitored and/or
                    recorded operational data.

     IX(A).D.3.      The Permittee shall test the emergency waste feed
                    cut-off system and associated alarm at least weekly
                    to verify operability, as specified in Permit
                    Condition IX(A).E.l.  [40 CFR 264.347(c)]

                    [Note:  If the Permittee demonstrates to the Regional
                    Administrator that the weekly inspections referred to
                    in Permit Condition IX(A).D.3 will unduly restrict or
                    upset operations and that less frequent inspection
                    will be adequate, the Permit Writer should specify
                    that inspection frequency in the permit condition.
                    At a minimum, operational testing must be conducted
                    at least monthly.]

IX(A).E.  MONITORING REQUIREMENTS

     IX(A).E.l.      The Permittee shall maintain, calibrate, and operate
                    monitoring equipment and record the data while
                    incinerating hazardous waste, as specified below:
                                IX(A)  -  10

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                                                           September 1988
System
Parameter

(1) Com-
bustion
Tempera -
(2) Pres-
sure drop
across
scrubber
venturi
Monitor
Type,
Instr.
No.
Type K
Thermo-
couple
TIC-900
Pressure
Sensor
PDIC-
1220

Location

[Use,
design
drawing
numbers
to show
the loca-
tion]


Recording
Process

[Indicate
whether
continuous
or not]



Calibration
Frequency

[ Frequency
at which the
unit is
calibrated



[Note:  At a minimum, this condition must specify monitoring systems that
meet the requirements of 40 CFR 264.347(a)(1) and (2).  Permit Condition
IX(A).E.l. contains example specifications for various operating
parameters that must be monitored. Specific parameters should be
addressed in the above table.  If the Part B Permit Application contains
the above information on monitoring practices, in a conveniently
organized way and adequately detailed, then the Permit Writer may attach
this information, Permit Attachment IX(A)-5. to the Permit instead of
using a table in this permit module, and reference the attachment.]

     IX(A).E.2      Upon request of the Agency, the Permittee shall
                    perform sampling and analysis of the waste and
                    exhaust emissions to verify that the operating
                    requirements established in the Permit achieve the
                    performance standards.  [40 CFR 264.347(a)(3)]

IX(A).F.  WASTE FEED CUT-OFF REQUIREMENTS

     IX(A).F.l.     The Permittee shall construct and maintain the
                    systems specified below to automatically cut off the
                    hazardous waste feed to the incinerator at the levels
                    specified below.  Hazardous wastes shall be fed to
                    the incinerator only when all instruments required by
                    this condition are on line and operating properly.
                               IX(A)  - 11

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                                                           September 1988
          Parameter
     Cut-Off Limits
    Test
  Frequency
          Operating
          parameters
          to be inter-
          locked to
          automatic
          waste-feed
          cut off i.e.,
          SCC temper-
          ature ]
     [Level at which
     waste feed will
     be cut off]
[Frequency at
which opera-
tional readiness
is checked]
[Note:  40 CFR 264.345(e) requires such systems to be constructed to
ensure that the operating conditions specified in the Permit are not
exceeded.  Most cut-off systems are composed of multiple parameters.
They include monitors for the operating conditions presented in Permit
Condition IX(A).C. along with power failure and flame-out.  If the Part B
Permit Application adequately provides the above information regarding
the automatic waste-feed cut-off system in an organized way and
adequately detailed, then the Permit Writer may attach this information,
Permit Attachment IX(A)-6. to the Permit, in lieu of using a table in
this permit module, and reference the attachment.]
     IX(A).F.2.
In case of a malfunction of the automatic waste feed
cut-off systems,  the Permittee shall perform manual
shut downs in accordance with the approved procedures
in Permit Attachment IX(A)-7.   The Permittee shall
not restart the incinerator until the problem causing
the malfunction has been located and corrected.
IX(A).G.  CLOSURE
The Permittee shall follow the procedures in the Closure Plan, Permit
Attachment II-9.  [40 CFR 264.351]

IX(A).H.  RECORDKEEPING

     IX(A).H.l.     The Permittee shall record and maintain, in the
                    operating record for this permit, all monitoring and
                    inspection data compiled under the requirements of
                                IX(A)  -  12

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                                                           September 1988
                    this Permit (see Permit Condition I.E.9.b.).  [40 CFR
                    264.73 and 40 CFR 264.347(d)]

     IX(A).H.2.     The Permittee shall record in the operating record
                    for this permit the date and time of all automatic
                    waste feed shut-offs, including the triggering
                    parameters, reason for the shut-off, and corrective
                    actions taken.  The Permittee shall also record all
                    failures of the automatic waste feed shut-offs to
                    function properly and corrective actions taken.

IX(A).I.  COMPLIANCE SCHEDULE

[Note:  The Permit Writer should include this condition if the Permittee
is required to complete specific steps within a specific time period,
beyond those covered by other conditions of the Permit, as a criteria for
retaining this operating Permit.  Compliance schedules are generally used
in cases where requirements that are supposed to be met by the Permittee,
before the Permit is issued, are deferred for good cause until after
permit issuance.  Compliance schedules included in the Part B Permit
Application should be attached to the Permit.  If the application does
not include a compliance schedule, the Permit Writer should prepare one
and attach it to the Permit.  Each compliance schedule should have at
least two columns - one identifying the activity and one identifying the
milestone or completion dates.   The following is an example of a
condition that may apply for incineration units.]

The Permittee shall provide the following information to the Regional
Administrator:

     Item                          Date Due to the Regional Administrator

     [Example:

     1.  Documentation that                    May 12, 1989
         thermocouple No. TC 2
         was installed as shown
         on Drawing No. 960,
         dated March 18, 1987

     2.  As-built construction                 February 13, 1989]
         drawings for installation
         of Pressure Sensor No. PS 4
                                IX(A)  -  13

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                                                           September 1988
                                                                              4
       PERMIT ATTACHMENTS REFERENCED IN MODULE IX(A) - INCINERATION

This list is provided to assist the Permit Writer  in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.   The Permit Writer may select
other numbering schemes, as appropriate, when preparing actual Permits.
Permit Attachment No.


II-l

II-3

II-9
IX (A) -2


IX(A)-3


IX(A)-4


IX(A)-5

IX(A)-6


IX (A) -7
       Plan or Document
(from the Part B Permit Application)

Waste Analysis Plan

Facility Inspection Schedule

Closure Plan

List of Allowable Wastes

Design Plans and Specifications, and
Maintenance Procedures

Description of Allowable Variations in
System Design

Description of Procedures for
Controlling Fugitive Emissions

Description of Monitoring Systems

Description of Automatic Waste Feed
Cut-Off Systems

Description of Manual Waste Feed Cut-
Off Systems
                                IX(A)  -  14

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                                                           September 1988
               MODULE IX(B) - SHORT-TERM TEST INCINERATION

[Note:  This permit module is applicable to facilities that perform a
trial burn and presents conditions that, during the periods specified,
supersede certain conditions found in Permit Module IX(A).  40 CFR 270.62
and 264.344(c) requires that a permit establish conditions necessary to
meet the requirements of 40 CFR 264.345 during the shakedown, trial burn,
and post trial burn periods.]

[Note: The purpose of this module is to provide permit conditions for the
operation of a new incineration unit prior to the long-term operation
period in order to:

     1.   Determine operational readiness following completion of
          physical construction;

     2.   Test compliance with the performance standards;

     3.   Determine adequate operating conditions to ensure that the
          performance standards will be maintained; and

     4.   Control operating conditions after the trial burn and prior to
          any final modifications of the operating conditions in the
          long-term portion of the permit to reflect the results of the
          trial burn.]

[Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]
                       IX(B).A.  MODULE HIGHLIGHTS

[The Permit Writer should include a general discussion of the activities
covered by this module.  The discussion may include some or all of the
following information:  type of incineration system; types of air
pollution control equipment used; system capacity in terms of either heat
rate or mass flow rate; key operating conditions, such as combustion
temperature (and whether these conditions were based on trial burn
results, or data in lieu of a trial burn); a general description of the
automatic waste feed cut-off system; the types of waste that may be
burned; the principal organic hazardous constituents selected and the
rationale for this selection; any unique or special features associated
with the operation; and a reference to any special permit conditions.]
                                IX(B) - 1

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                        IX(B).B.   SHAKEDOWN PHASE
                                                           September 1988      .
During the shakedown phase (the period beginning with the initial
introduction of hazardous wastes into the incinerator and ending with the
start of the trial burn) the Permittee shall comply with the following
conditions:

IX(B).B.l.     DURATION OF THE SHAKEDOWN PHASE

The shakedown phase shall not exceed 	 hours of operation when burning
hazardous wastes.  [40 CFR 264.344(c)(1)]

[Note:  The duration of the first shakedown phase cannot exceed 720
hours.  The Permittee may petition the Agency for one extension of the
shakedown phase for up to 720 additional hours.   The Agency may grant the
extension when good cause is demonstrated in the petition.  The Permit
Writer should modify the Permit as necessary to reflect the extension.
The modifications may be considered minor modifications.  The Permit
Writer's justification for granting an extension should be included in
the Administrative Record for this Permit.]  [40 CFR 264.344(c)(1) and 40
CFR 270.62(a)]

IX(B).B.2.     ALLOWABLE WASTE FEED

During the shakedown phase, the Permittee may feed only the following
wastes to the incinerator, at the following feed rates, and subject to
the requirements of Permit Conditions IX(B).B.3.:

[Note:  The Permit Writer should identify which waste feeds the Permittee
is allowed to incinerate during the shakedown phase and specify their
respective feed rates.  Any limitations to these waste feeds should also
be specified.  In some cases, an incinerator may accept only wastes that
are always chemically and physically uniform.  Identification may then
simply be the process name of the waste or some other equivalent
identifier.  Other facilities may accept waste feeds whose chemical and
physical properties vary.  Any limitations, and the allowable range of
variations for these waste feeds should be specified.  Determining these
conditions must be based on the Permit Writer's judgment that the
facility will meet the performance standards of 40 CFR 264.343.  The
Permit Writer may choose to limit the waste feed to easily incinerable
materials during this period, or to limit the amount of harder to
incinerate waste that can be burned during this period.  The options
presented in Permit Condition IX(A).B. of the module for long-term
incineration  [Module IX(A)] should be considered by the Permit Writer.]

IX(B).B.3.     INSTRUMENTATION AND OPERATIONAL PERFORMANCE REQUIREMENTS

[Note:  For each of the waste feed streams specified in Permit Condition
IX(B).B.2., the Permit Writer must establish operating conditions that,
in the Permit Writer's judgment, ensure compliance with the performance
standards of 40 CFR 264.343.]
                                IX(B) - 2

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                                                           September 1988
[Note:  40 CFR 264.345(b)(1)-(4) requires the Permit Writer to establish
operating limits for carbon monoxide, waste-feed rate, combustion
temperature, and a combustion gas velocity indicator.  Permit Conditions
IX(B).B.2. and IX(B).B.3.a. through IX(B).B.3.c. cover those
requirements.  40 CFR 264.345(b)(6) requires the Permit Writer to
establish any other operating requirements (conditions) necessary to
ensure compliance with the performance standards.   Permit Conditions
IX(B).B.3.d. through IX(B).B.3.n. are example permit conditions that
serve this purpose.  These permit conditions incorporate the list of key
operating parameters provided by the EPA Guidance on Trial Burn Reporting
and Setting Permit Conditions.   This guidance should be consulted for
assistance in determining which of these conditions apply for a specific
facility and the specific method of setting each condition, given the
design and operation of the facility or from data submitted in lieu of a
trial burn.]

During the shakedown phase, the Permittee shall feed the wastes described
in Permit Condition IX(B).B.2.  to the incinerator only under the
following conditions:

     IX(B).B.3.a.   Carbon monoxide concentration in the stack exhaust
                    gas,  monitored as specified in Permit Condition
                    IX(B).B.5., and corrected for the amount of oxygen in
                    the stack gas,  shall not exceed 	 ppm over a one
                    hour rolling average [or under the alternative format
                    for CO limits,  	 ppm at any time, or 	 PPm for
                    more than 	 minutes in any clock hour].

     IX(B).B.3.b.   Combustion temperature,  monitored as specified in
                    Permit Condition IX(B).B.5., shall be maintained at
                    	 F (or C)  or greater.

                    [Note:  For dual-chamber incinerators, minimum
                    temperature should be set for each chamber.]

     IX(B).B.3.c.   Combustion gas  velocity,  monitored as specified in
                    Permit Condition IX(B).B.5., shall be no greater than
                    	 ft/s.

     IX(B).B.3.d.   Atomization fluid pressure  (e.g., steam, air) shall
                    be no less  than 	 psig.

     IX(B).B.3.e.   The turndown ratio for the  waste burner shall be no
                    greater than 	.

     [Note:  Permit Conditions  IX(B).B.3.f.  through IX(B).B.3.h. relate
     to ensuring compliance with the HC1 emission standard in 40 CFR
     264.343(b).   The  Permit Writer must determine which conditions are
     appropriate for a specific facility depending on the control devices
     present.]
                                IX(B)  -  3

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                                                      September 1988
IX(B).B.3.f.
IX(B).B.3.g.
IX(B).B.3.h.
The - ratio to the absorber,  monitored as specified
    G
in Permit Condition IX(B).B.5., shall be maintained
at no less than 	 [sometimes expressed as gals per
thousand cubic feet though usually dimensionless].

The scrubber effluent pH, monitored as specified in
Permit Condition IX(B).B.5.,  shall be maintained at a
minimum pH of 	.
The scrubber water delivery (nozzle) pressure,
monitored as specified in Permit Condition
IX(B).B.5., shall be maintained at no less than
psig.
[Note:  Permit Conditions IX(B).B.3.i. through IX(B).B.3.n. relate
to ensuring compliance with the particulate emission standard in 40
CFR 264.343(c).  Note, however, that most facilities will not have
all of the devices mentioned.  The Permit Writer must determine
which conditions are appropriate for a specific facility.]

      B.3.i.    Pressure drop across the venturi scrubber, monitored
               as specified in Permit Condition IX(B).B.5., shall be
               maintained at no less than 	 psi.
IX(B).B.3.j
IX(B).B.3.k.
IX(B).B.3.1.
IX(B).B.3.m.
The scrubber blowdown rate shall be maintained at no
less than 	 pm.
The power to the electrostatic precipitator,
monitored as specified in Permit Condition
IX(B).B.5., shall be maintained at no less than
kVA.
IX(B).B.3.n.
The voltage applied to the ionizing wet scrubber,
monitored as specified in Permit Condition
IX(B).B.5., shall be no less than 	 kV.

Pressure drop across the baghouse, monitored as
specified in Permit Condition IX(B).B.5., shall be no
less than 	 psi, nor greater than 	 psi.

[Note:  The Permit Writer may require the Permittee
to specify in the Contingency Plan, provisions for
maintaining and replacing bags.]

The Permittee shall control fugitive emissions from
the combustion zone of the incinerator by maintaining
the pressure in the primary combustion chamber,
monitored as specified in Permit Condition
IX(B).B.5., to not exceed 	 inches of mercury.
[40 CFR 264.345(d)]
                           IX(B) - 4

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                                                           September 1988
                    [Note:  The Permit Writer may specify another method
                    for controlling fugitive emissions.   The method must
                    be demonstrated in the Part B Permit Application;
                    this information should be attached to the Permit,
                    Permit Attachment IX(B)-1. and referenced.]

     IX(B).B.3.o.    Compliance with the operating conditions specified in
                    Permit Conditions IX(B).B.3.a.  through IX(B).B.3.n.
                    will be regarded as compliance with the required
                    performance standards 40 CFR 264.343.  However,
                    evidence that compliance with these operating
                    conditions is insufficient to ensure compliance with
                    the performance standards, may justify modification,
                    revocation, or reissuance of the Permit pursuant to
                    40 CFR 270.41.  [40 CFR 264.343(d)]

                    [Note:  It must be understood,  by both the Permit
                    Writer and Permittee, that violation of the permit
                    operating conditions can give rise to an enforcement
                    action.  If the Permittee complies with the permit
                    operating conditions, but it is later shown that the
                    performance standards are not being achieved, the
                    permit may be modified or revoke and reissued, but
                    enforcement actions are not available.  Thus, each
                    set of operating conditions should directly relate to
                    achieving the performance standards in 40 CFR
                    264.343.]

IX(B).B.4.      INSPECTION REQUIREMENTS

The Permittee shall inspect the incineration unit in accordance with the
Inspection Schedule, Permit Attachment II-3.  and shall complete the
following as part of these inspections:

     IX(B).B.4.a.    The Permittee shall thoroughly, visually inspect the
                    incinerator and associated equipment (including
                    pumps, valves, conveyors, pipes, etc.) for leaks,
                    spills, fugitive emissions, and signs of tampering.
                    [40 CFR 264.347(b)]

     IX(B).B.4.b.    The Permittee shall thoroughly, visually inspect the
                    instrumentation for out-of-tolerance monitored and/or
                    recorded operational data.

     IX(B).B.4.c.    The Permittee shall test the emergency waste feed
                    cut-off system and associated alarm at least weekly
                    to verify operability, as specified in Permit
                    Condition IX(B).B.5.  [40 CFR 264.347(c)]
                                IX(B) -  5

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IX(B).B.5.
                                            September 1988

     [Note:  If the Permittee demonstrates to the Regional
     Administrator that the weekly inspections referred to
     in Permit Condition IX(B).B.4.c. will unduly restrict
     or upset operations and that less frequent inspection
     will be adequate, the Permit Writer should specify
     that inspection frequency in the permit condition.
     At a minimum, operational testing must be conducted
     at least monthly.]

MONITORING REQUIREMENTS
     IX(B).B.S.a.
     The Permittee shall maintain, calibrate, and operate
     monitoring equipment and record the data while
     incinerating hazardous waste, as specified below:
          System    Monitor
          Parameter Type,
                    Instr.
                    No.
                Location Recording
                         Process
Calibration
Frequency
Examples Type K
(1) Com- Thermo -
bustion couple
tempera- TIC-900
ture
(2) Pres- Pressure
sure drop Sensor
across PDIC-
scrubber 1220
venturi
[Use
design
drawing
numbers
to show
the loca-
tion]



[ Indicate
whether
continuous
or not]






[ Frequency
at which the
unit is
calibrated






[Note:  At a minimum, this condition must specify monitoring systems that
meet the requirements of 40 CFR 264.347(a)(1) and (2).  Permit Condition
IX(B).B.5.a. contains example specifications for various operating
parameters that must be monitored. Specific parameters should be
addressed in the above table.  If the Part B Permit Application contains
the above information on monitoring practices,  in a conveniently
organized way and adequately detailed, then the Permit Writer may attach
this information, Permit Attachment IX(B)-2. to the Permit instead of
using a table in this permit module, and reference the attachment.]
     IX(B).B.5.b.
     Upon request of the Agency, the Permittee shall
     perform sampling and analysis of the waste and
     exhaust emissions to verify that the operating
     requirements established in the Permit achieve the
     performance standards.  [40 CFR 264.347(a)(3)]
                                IX(B) - 6

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                                                           September 1988
IX(B).B.6.
WASTE FEED CUT-OFF REQUIREMENTS
     IX(B).B.6.a.
     The Permittee shall construct and maintain the
     systems specified below to automatically cut off the
     hazardous waste feed to the incinerator at the levels
     specified below.  Hazardous wastes shall be fed to
     the incinerator only when all instruments required by
     this condition are on line and operating properly.
          Parameter
          Cut-Off Limits
    Test
  Frequency
          Operating
          parameters
          to be inter-
          locked to
          automatic
          waste-feed
          cut off i.e.,
          SCC temper-
          ature ]
          [Level at which
          waste feed will
          be cut off]
[Frequency at
which opera-
tional readiness
is checked]
[Note:  40 CFR 264.345(e) requires such systems to be constructed to
ensure that the operating conditions specified in the Permit are not
exceeded.  Most cut-off systems are composed of multiple parameters.
They include monitors for the operating conditions presented in Permit
Condition IX(B).B.3. along with power failure and flame-out.  If the Part
B Permit Application adequately provides the above information regarding
the automatic waste-feed cut-off system in an organized way and
adequately detailed, then the Permit Writer may attach this information,
Permit Attachment IX(B)-3. to the Permit, in lieu of using a table in
this permit module, and reference the attachment.]
     IX(B).B.6.b.
     In case of a malfunction of the automatic waste feed
     cut-off systems,  the Permittee shall perform manual
     shut downs in accordance with the approved procedures
     in Permit Attachment IX(B)-4.  The Permittee shall
     not restart the incinerator until the problem causing
     the malfunction has been located and corrected.
IX(B).B.7.      RECORDKEEPING

     IX(B).B.7.a.
     The Permittee shall record and maintain,  in the
     operating record for this permit,  all monitoring and
                                IX(B)  -  7

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                                                           September 1988

                    inspection data compiled under the requirements of
                    this Permit (see Permit Condition I.E.9.b.).  [40 CFR
                    264.73 and 40 CFR 264.347(d)]

     IX(B).B.7.b.   The Permittee shall record in the operating record
                    for this permit the date and time of all automatic
                    waste feed shut-offs, including the triggering
                    parameters, reason for the shut-off, and corrective
                    actions taken.  The Permittee shall also record all
                    failures of the automatic waste feed shut-offs to
                    function properly and corrective actions taken.

IX(B).B.8.     COMPLIANCE SCHEDULE

[Note:  The Permit Writer should include this condition if the Permittee
is required to complete specific steps within a specific time period,
beyond those covered by other conditions of the Permit, as a criteria for
retaining this operating Permit.  Compliance schedules are generally used
in cases where requirements that are supposed to be met by the Permittee,
before the Permit is issued, are deferred for good cause until after
permit issuance.  Compliance schedules included in the Part B Permit
Application should be attached to the Permit.  If the application does
not include a compliance schedule, the Permit Writer should prepare one
and attach it to the Permit.  Each compliance schedule should have at
least two columns - one identifying the activity and one identifying the
milestone or completion dates.  The following is an example of a
condition that may apply for incineration units.]

The Permittee shall provide the following information to the Regional
Administrator:

     Item                          Date Due to the Regional Administrator

      [Example:

     1.  Documentation that                    May 12, 1989
         thermocouple No. TC 2
         was installed as shown
         on Drawing No. 960,
         dated March 18, 1987

     2.  As-built construction                 February 13, 1989]
         drawings for installation
         of Pressure Sensor No. PS 4
                                IX(B) - 8

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                                                           September 1988
                        IX(B).C.   TRIAL  BURN  PHASE

IX(B).C.l.   CONFORMITY TO TRIAL BURN PLAN

The Permittee shall operate and monitor the incinerator during the trial
burn phase as specified in the Trial Burn Plan, Permit Attachment IX(B)-
J5.  The Trial Burn Plan shall be revised and resubmitted by the Permittee
six (6) months prior to conducting the trial burn or a performance test
required under Permit Condition IX(A).E.2. of this permit.  The revised
Trial Burn Plan must include all applicable EPA-approved test methods and
procedures in effect at the time of the resubmittal.

[Note:  The Trial Burn Plan must meet the requirements of 40 CFR
270.62(b)(2).  The operating and monitoring requirements specified in the
plan must be adequate to meet the requirements of 40 CFR 270.62(b)(2)(v).
Additional conditions should be established, if necessary, to establish
operating conditions which will ensure compliance with the performance
standards of 40 CFR 264.343.]

IX(B).C.2.   TRIAL POHCs

The principal organic hazardous constituents (POHCs) for which DREs must
be determined are:

                  Waste Feed                    POHC(s)
[Note:  If the Permittee or Permit Writer wishes to establish different
operating conditions for various hazardous waste feeds, then POHCs must
be selected for each feed or feed group.  For example, a facility may
wish to designate two (2) waste feeds.  Number one waste feed may be a
combination of several waste streams that is relatively "easy" to burn
based on its POHCs.  Number two feed may consist of several waste streams
that are "difficult" to burn based on their POHCs.  The incinerator
operating conditions for these two feeds may be different.]

[Note:  Before selecting POHCs for the trial burn, the Permit Writer
should review the EPA "Guidance Manual for Hazardous Waste Incinerator
Permits" (SW-966),  Guidance on Trial Burn Reporting and Setting Permit
Conditions,  and other appropriate guidances.]

IX(B).C.3.    TRIAL BURN DETERMINATIONS

During the trial burn (or as soon after the trial burn as practicable),
the Permittee shall make the determinations required by 40 CFR
270.62(b)(6)(i)-(ix).
                                IX(B) - 9

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                                                           September 1988


[Note:  Any other determinations that the Permit Writer finds will be
needed to ensure that the trial burn will determine compliance with the
performance standards should be described as required by 40 CFR
270.62(b)(6)(x).]

IX(B).C.4.   TRIAL BURN DATA SUBMISSIONS AND CERTIFICATIONS

The Permittee shall submit a copy of all data collected during the trial
burn to the Regional Administrator upon completion of the burn.  The
Permittee shall submit to the Regional Administrator the results of the
determinations required by Condition IX(B).C.3 within ninety (90) days of
the completion of the trial burn.  All submissions must be certified in
accordance with 40 CFR 270.11. [40 CFR 270.62
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IX(B).D.2.
                                                           September 1988
INSTRUMENTATION AND OPERATIONAL PERFORMANCE REQUIREMENTS
[Note:  For each of the waste feed streams specified in Permit Condition
IX(B).D.l., the Permit Writer must establish operating conditions that,
in the Permit Writer's judgment, ensure compliance with the performance
standards of 40 CFR 264.343.]

[Note:  40 CFR 264.345(b)(1)-(4) requires the Permit Writer to establish
operating limits for carbon monoxide, waste-feed rate, combustion
temperature, and a combustion gas velocity indicator.  Permit Conditions
IX(B).D.l. and IX(B).D.2.a. through IX(B).D.2.c. cover those
requirements.  40 CFR 264.345(b)(6) requires the Permit Writer to
establish any other operating requirements (conditions) necessary to
ensure compliance with the performance standards.  Permit Conditions
IX(B).D.2.d. through IX(B).D.2.n. are example permit conditions that
serve this purpose.  These permit conditions incorporate the list of key
operating parameters provided by the EPA Guidance on Trial Burn Reporting
and Setting Permit Conditions.   This guidance should be consulted for
assistance in determining which of these conditions apply for a specific
facility and the specific method of setting each condition, given the
design and operation of the facility and the results of the trial burn or
from data submitted in lieu of a trial burn.]

During the shakedown phase, the Permittee shall feed the wastes described
in Permit Condition IX(B).D.l.  to the incinerator only under the
following conditions:
     IX(B).D.2.a.
     IX(B).D.2.b.
     IX(B).D.2.c.
     IX(B).D.2.d.
     Carbon monoxide concentration in the stack exhaust
     gas,  monitored as specified in Permit Condition
     IX(B).D.4.,  and corrected for the amount of oxygen in
     the stack gas, shall not exceed 	 ppm over a one
     hour rolling average [or under the alternative format
     for CO limits, 	 ppm at any time, or 	 ppm for
     more than 	 minutes in any clock hour].

     Combustion temperature,  monitored as specified in
     Permit Condition IX(B).D.4.,  shall be maintained at
     	 F (or C) or greater.

     [Note:  For dual-chamber incinerators, minimum
     temperature should be set for each chamber.]

     Combustion gas velocity,  monitored as specified in
     Permit Condition IX(B).D.4.,  shall be no greater than
     	 ft/s.

     Atomization fluid pressure  (e.g.,  steam,  air) shall
     be no less than
                               IX(B)  - 11

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                                                      September 1988
IX(B).D.2.e.
The turndown ratio for the waste burner shall be
greater than 	.
no
[Note:  Permit Conditions IX(B).D.2.f.  through IX(B).D.2.h. relate
to ensuring compliance with the HC1 emission standard in 40 CFR
264.343(b).  The Permit Writer must determine which conditions are
appropriate for a specific facility depending on the control devices
present.]
IX(B).D.2.f.
IX(B).D.2.g.
IX(B).D.2.h.
The  ratio to the absorber, monitored as specified
    G
in Permit Condition IX(B).D.4., shall be maintained
at no less than 	 [sometimes expressed as gals per
thousand cubic feet though usually dimensionless].

The scrubber effluent pH, monitored as specified in
Permit Condition IX(B).D.4., shall be maintained at a
minimum pH of 	.
The scrubber water delivery (nozzle) pressure,
monitored as specified in Permit Condition
IX(B).D.4., shall be maintained at no less than
psig.
[Note:  Permit Conditions IX(B).D.2.i. through IX(B).D.2.n. relate
to ensuring compliance with the particulate emission standard in 40
CFR 264.343(c).  Note, however, that most facilities will not have
all of the devices mentioned.  The Permit Writer must determine
which conditions are appropriate for a specific facility.]

      D.2.i.   Pressure drop across the venturi scrubber, monitored
               as specified in Permit Condition IX(B).D.4., shall be
               maintained at no less than 	 psi.
               The scrubber blowdown rate shall be maintained at no
               less than 	 SPm-
The power to the electrostatic precipitator,
monitored as specified in Permit Condition
IX(B).D.4., shall be maintained at no less than
kVA.
IX(B).D.2.k.
IX(B).D.2.m.
The voltage applied to the ionizing wet scrubber,
monitored as specified in Permit Condition
IX(B).D.4., shall be no less than 	 kV.

Pressure drop across the baghouse, monitored as
specified in Permit Condition IX(B).D.4., shall be no
less than 	 psi, nor greater than 	 psi.
                                                                          i
                           IX(B)  -  12

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     IX(B).D.2.n.
     IX(B).D.2.0.
IX(B).D.3.
                                            September 1988

     [Note:  The Permit Writer may require the Permittee
     to specify in the Contingency Plan, provisions for
     maintaining and replacing bags.]

     The Permittee shall control fugitive emissions from
     the combustion zone of the incinerator by maintaining
     the pressure in the primary combustion chamber,
     monitored as specified in Permit  Condition
     IX(B).D.4., to not exceed 	 inches of mercury.
     [40 CFR 264.345(d)]

     [Note:  The Permit Writer may specify another method
     for controlling fugitive emissions.  The method must
     be demonstrated in the Part B Permit Application;
     this information should be attached to the Permit,
     Permit Attachment IX(B)-1. and referenced.]

     Compliance with the operating conditions specified in
     Permit Conditions IX(B).D.2.a. through IX(B).D.2.n.
     will be regarded as compliance with the required
     performance standards 40 CFR 264.343.  However,
     evidence that compliance with these operating
     conditions is insufficient to ensure compliance with
     the performance standards, may justify modification,
     revocation, or reissuance of the  Permit pursuant to
     40 CFR 270.41.  [40 CFR 264.343(d)]

     [Note:  It must be understood, by both the Permit
     Writer and Permittee, that violation of the permit
     operating conditions can give rise to an enforcement
     action.  If the Permittee complies with the permit
     operating conditions, but it is  later shown that the
     performance standards are not being achieved, the
     permit may be modified or revoke  and reissued, but
     enforcement actions are not available.  Thus, each
     set of operating conditions should directly relate to
     achieving the performance standards in 40 CFR
     264.343.]
INSPECTION REQUIREMENTS
The Permittee shall inspect the incineration unit in accordance with the
Inspection Schedule, Permit Attachment II-3.  and shall complete the
following as part of these inspections:
     IX(B).D.3.a.
     The Permittee shall thoroughly,  visually inspect the
     incinerator and associated equipment (including
     pumps,  valves,  conveyors,  pipes,  etc.)  for leaks,
     spills, fugitive emissions,  and signs of tampering.
     [40 CFR 264.347(b)j
                               IX(B)  - 13

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                                                           September 1988

     IX(B).D.3.b.    The Permittee shall  thoroughly,  visually inspect the
                    instrumentation for  out-of-tolerance  monitored and/or
                    recorded operational data.

     IX(B).D.3.c.    The Permittee shall  test the emergency waste feed
                    cut-off system and associated alarm at least weekly
                    to verify operability,  as specified in Permit
                    Condition IX(B).D.4.  [40 CFR 264.347(c)]

                    [Note:   If the Permittee demonstrates to the Regional
                    Administrator that the  weekly inspections referred to
                    in Permit Condition  IX(B).D.3.c. will unduly restrict
                    or upset operations  and that less frequent inspection
                    will be adequate,  the Permit Writer should specify
                    that inspection frequency in the permit condition.
                    At a minimum, operational testing must be conducted
                    at least monthly.]

IX(B).D.4.      MONITORING REQUIREMENTS
     IX(B).D.4.a.    The Permittee shall maintain,  calibrate,  and operate
                    monitoring equipment and record the data while
                    incinerating hazardous waste,  as specified below:

          System    Monitor    Location Recording   Calibration
          Parameter Type,               Process     Frequency
                    Instr.
                    No.
4
Examples Type K
(1) Com- Thermo -
bustion couple
tempera- TIC- 900
ture
(2) Pres- Pressure
sure drop Sensor
across PDIC-
scrubber 1220
venturi
[Use
design
drawing
numbers
to show
the loca-
tion]



[ Indicate
whether
continuous
or not]






[ Frequency
at which the
unit is
calibrated






[Note:  At a minimum, this condition must specify monitoring systems that
meet the requirements of 40 CFR 264.347(a)(1) and (2).  Permit Condition
IX(B).D.4.a. contains example specifications for various operating
parameters that must be monitored. Specific parameters should be
addressed in the above table.  If the Part B Permit Application contains
the above information on monitoring practices,  in a conveniently
                                IX(B)  -  14

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                                                           September 1988

organized way and adequately detailed, then the Permit Writer may attach
this information, Permit Attachment IX(B)-2. to the Permit instead of
using a table in this permit module, and reference the attachment.]

     IX(B).D.4.b.   Upon request of the Agency, the Permittee shall
                    perform sampling and analysis of the waste and
                    exhaust emissions to verify that the operating
                    requirements established in the Permit achieve the
                    performance standards.   [40 CFR 264.347(a)(3)]

IX(B).D.5.     WASTE FEED CUT-OFF REQUIREMENTS
     lX(B).D.5.a.   The Permittee shall construct and maintain the
                    systems specified below to automatically cut off the
                    hazardous waste feed to the incinerator at the levels
                    specified below.  Hazardous wastes shall be fed to
                    the incinerator only when all instruments required by
                    this condition are on line and operating properly.
                                                 Test
          Parameter      Cut-Off Limits        Frequency
          Operating      [Level at which     [Frequency at
          parameters     waste feed will     which opera-
          to be inter-   be cut off]         tional readiness
          locked to                          is checked]
          automatic
          waste-feed
          cut off i.e.,
          SCC temper-
          ature ]
[Note:  40 CFR 264.345(e) requires such systems to be constructed to
ensure that the operating conditions specified in the Permit are not
exceeded.  Most cut-off systems are composed of multiple parameters.
They include monitors for the operating conditions presented in Permit
Condition IX(B).D.2. along with power failure and flame-out.  If the Part
B Permit Application adequately provides the above information regarding
the automatic waste-feed cut-off system in an organized way and
adequately detailed, then the Permit Writer may attach this information,
Permit Attachment IX(B)-3. to the Permit, in lieu of using a table in
this permit module,  and reference the attachment.]
                               IX(B)  - 15

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                                                           September 1988

     IX(B).D.5.b.    In case of a malfunction of the automatic waste feed
                    cut-off systems,  the Permittee shall perform manual
                    shut downs in accordance with the approved procedures
                    in Permit Attachment IX(B)-4.   The Permittee shall
                    not restart the incinerator until the problem causing
                    the malfunction has been located and corrected.

IX(B).D.6.      RECORDKEEPING

     IX(B).D.6.a.    The Permittee shall record and maintain, in the
                    operating record for this permit, all monitoring and
                    inspection data compiled under the requirements of
                    this Permit (see Permit Condition I.E.9.b.).   [40 CFR
                    264.73 and 40 CFR 264.347(d)]

     IX(B).D.6.b.    The Permittee shall record in the operating record
                    for this permit the date and time of all automatic
                    waste feed shut-offs, including the triggering
                    parameters, reason for the shut-off, and corrective
                    actions taken.  The Permittee shall also record all
                    failures of the automatic waste feed shut-offs to
                    function properly and corrective actions taken.

IX(B).D.7.      COMPLIANCE SCHEDULE

[Note:  The Permit Writer should include this condition if the Permittee
is required to complete specific steps within a specific time period,
beyond those covered by other conditions of the Permit, as a criteria for
retaining this operating Permit.  Compliance schedules are generally used
in cases where requirements that are supposed to be met by the Permittee,
before the Permit is issued, are deferred for good cause until after
permit issuance.  Compliance schedules included in the Part B Permit
Application should be attached to the Permit.  If the application  does
not include a compliance schedule, the Permit Writer should prepare one
and attach it to the Permit.  Each compliance schedule should have at
least two columns - one identifying the activity and one identifying the
milestone or completion dates.  The following is an example of a
condition that may apply for incineration units.]

The Permittee shall provide the following information to the Regional
Administrator:
I
                                IX(B)  -  16

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ft
                                                           September 1988


     Item                          Date Due to the Regional Administrator

     [Example:

     1.  Documentation that                    May 12, 1989
         thermocouple No. TC 2
         was installed as shown
         on Drawing No. 960,
         dated March 18, 1987

     2.  As-built construction                 February 13, 1989]
         drawings for installation
         of Pressure Sensor No. PS 4


        IX(B).E.   REPORTING NON-COMPLIANCE DURING THE TRIAL BURN

If based upon the analytical results of the trial burn and before
submitting the required trial burn results, the Permittee determines that
the incinerator failed to achieve any of the performance standards
specified in 40 CFR 264.343, the Permittee shall notify the Regional
Administrator within twenty-four (24) hours of making the determination.
Upon the request of the Regional Administrator, the Permittee shall cease
feeding hazardous waste to the incinerator.  The Permittee may apply to
the Regional Administrator for a permit modification pursuant to 40 CFR
270.41 and for a new trial burn pursuant to 40 CFR 270.62(b).
                                              IX(B) - 17

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                                                           September 1988

        PERMIT ATTACHMENTS REFERENCED IH MODULE IX (B) - SHORT-TERM
                            TEST INCINERATION

This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.   The Permit Writer may select
other numbering schemes, as appropriate,  when preparing actual Permits.
Permit Attachment No.
II-3
IX(B)-2

IX(B)-3


IX(B)-4


IX(B)-5
       Plan or Document
(from the Part B Permit Application)

Facility Inspection Schedule

Description of Procedures for
Controlling Fugitive Emissions

Description of Monitoring Systems

Description of Automatic Waste Feed
Cut-Off Systems

Description of Manual Waste Feed Cut-
Off Systems

Trial Burn Plan
                                IX(B)  -  18

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                                                           September 1988

               MODULE  X -  GROUND-WATER  DETECTION MONITORING
[Note:  This permit module contains conditions that apply to storage,
treatment, or disposal of hazardous wastes in any of the following units:
surface impoundments, waste piles, land treatment units or landfills.
These units require ground-water monitoring unless exempted under 40 CFR
264.90(b).]  The goal of detection monitoring is to ensure the earliest
possible detection of contaminant leakage from the regulated units.
Detection monitoring requires detected leakage to be characterized and
determines if further action is warranted.  Detection monitoring entails
the following:

     1.   Development of a list of ground-water indicator parameters and
          monitoring constituents used to indicate a release from the
          regulated unit(s).

     2.   Establishment of sampling and statistical analysis requirements
          to determine if a release has occurred.

     3.   Establishment of additional requirements if a statistically
          significant release occurs.]

[Note:  On July 9, 1987, a federal rule was finalized to require analysis
for 40 CFR 261, Appendix IX, rather than Appendix VIII, hazardous
constituents pursuant to 40 CFR 264.98 and 264.99, if a statistically
significant increase occurs for any detection monitoring parameters or
constituents.  The Appendix IX list is an abbreviated Appendix VIII list
with several constituents added.  This permit module incorporates the new
rule.]

[Note:  Under 40 CFR 264.91(b) the Regional Administrator may include one
or more of the following programs in a permit: (1) detection monitoring
(Module X), (2) compliance monitoring (Module XI), and (3) corrective
action [Module XII(A)].  If more than one program is included in the
Permit, the Permit Writer is to specify the circumstances or conditions
under which each program will be required.  It is possible that more than
one program will be operable at the same time at a facility, or that the
programs will be conditional based on a sequence of events.  For example,
the sequence set up in the Permit could include a detection monitoring
program that triggers an Appendix IX analysis that triggers a Permittee
option to apply for a variance (e.g., other contamination source or
sampling error) and if the Permittee fails to seek or fails to obtain a
variance, then compliance monitoring is triggered.  The Permit could also
set the ground water protection standard, with a provision for the
Permittee to apply for an Alternate Concentration Limit (ACL),  and in the
absence of an ACL application or denial of an ACL, or exceedence of an
ACL or pre-set limit, the triggering of the corrective action program.
The corrective action program could include plume assessment, corrective
measures study and design, and implementation of corrective action.
Setting up such a sequence in the Permit reduces the number of permit

                                  X - 1

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                                                           September 1988

modifications that may be needed and decreases the administrative time
needed to get on with subsequent steps in the process and ultimately, the
time required to get corrective action under way, if needed.]

[Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]

X.A.   MODULE HIGHLIGHTS

[The Permit Writer should include a general discussion of the activities
covered by this module.  The discussion should contain the following
information:  description of the waste management units (including type
and number that require detection monitoring); number, location and depth
of wells; which wells are upgradient and downgradient; the indicator
parameters and monitoring constituents specified and their background
concentrations; any unique or special features associated with the
operation; and a reference to any special permit conditions.]

X.B.   WELL LOCATION. INSTALLATION AND CONSTRUCTION

[Note:  For specific Agency guidance on monitoring well design and
construction, hydrogeologic site characterization and location of
monitoring wells, consult the EPA RCRA Ground-Water Monitoring Technical
Enforcement Guidance Document (September 1986).]

The Permittee shall install and maintain a ground-water monitoring system
as specified below:  [40 CFR 264.97]

     X.B.I.    The Permittee shall  (install and) maintain ground-water
               monitoring wells at  the locations specified on the map in
               Permit Attachment X-l and in conformance with the
               following list:

               [Note:  The map must show all monitoring well locations
               and provide unique identifiers for each well.  The number
               and location of monitoring wells utilized for ground-water
               monitoring is site-specific.  The number and location of
               the wells must meet  the requirements of 40 CFR 264.95
               (Point of Compliance) and 40 CFR 264.97(a) and (b), if
               applicable (number,  location, and depth of wells).  The
               ground-water monitoring system must:  yield samples in
               upgradient wells that represent the quality of the
               background ground water unaffected by  leakage from any
               regulated unit(s), and in downgradient wells yield samples
               that represent the quality of water passing the point of
               compliance.  The number and location of monitoring wells
               must be sufficient to identify and define all logical
               release pathways from the regulated units based on site-
               specific hydrogeologic characterization.  The Permit

                                  X - 2

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                                                           September 1988

               Writer may require the Permittee to selectively monitor a
               hydrologic zone which the Permittee has not described as
               part of the uppermost aquifer (e.g., perched water table),
               if based on hydrogeological characteristics,  the
               hydrologic zone is an area of concern for the migration of
               hazardous constituents from regulated units that can be
               transported to any exposure point.]

     X.B.2.    The Permittee shall (construct and) maintain the
               monitoring wells identified in Permit Condition X.B.I., in
               accordance with the detailed plans and specifications
               presented in Permit Attachment X-2.

               [Note:  The plans and specifications must meet the
               requirements of 40 CFR 264.97(a) and (c), and should
               consist of design drawings and design criteria applicable
               to all wells, and individual well specifications
               identifying total well depth and location of screened
               intervals.]

     [Note:  If determined to be necessary to protect human health or the
     environment, the Permit Writer should include Permit Condition
     X.B.3., specifications on how monitoring wells are plugged and
     abandoned.  HSWA Section 212 provides EPA with this authority.
     Several states also have regulations which cover monitoring well
     abandonment.]

     X.B.3.    All wells deleted from the monitoring program shall be
               plugged and abandoned in accordance with Permit Attachment
               X-3.   Well plugging and abandonment methods and
               certification shall be submitted to the Regional
               Administrator within [The Permit Writer should specify the
               submittal period.] from the date the wells are removed
               from the monitoring program.

X.C.   INDICATOR PARAMETERS AND MONITORING CONSTITUENTS

[Note:  The Permit Writer may use background data from interim status
monitoring to establish background concentrations for detection
monitoring, to the extent that the same parameters continue to be used in
detection.]

     X.C.I.    The Permittee shall monitor [The Permit Writer should
               specify the well numbers], as described in Permit
               Condition X.B.,  for the following parameters and
               constituents: [40 CFR 264.98(a)]

               Parameter or Constituent           Established Background
                                                  Concentrations
                                  X - 3

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                                                      September 1988

          [Note:  The Permit Writer should develop a list of
          detection monitoring parameters and constituents using the
          following information: waste analysis plan, waste
          characterization, site hydrogeologic characterization, and
          proposed monitoring parameters and constituents.]

[Note:  Include Permit Condition X.C.2. when the Permittee has not
established background values at the time the Permit is issued in
accordance with 40 CFR 264.97(g).]

X.C.2.    For those parameters and constituents in Permit Condition
          X.C.I, for which no background values are established at
          the time the Permit is issued, the Permittee shall
          establish background values in accordance with the
          following procedures.  [The Permit Writer should specify
          that the procedures in Permit Conditions X.C.2.a. and
          X.C.2.b. be used to establish the background values.]  [40
          CFR 264.97(g)(1)]

     X.C.2.a.  Background ground-water quality for a monitoring
               parameter or constituent shall be based on data from
               quarterly sampling of the well [or wells] upgradient
               from the waste management unit for one (1) year. [40
               CFR 264.97(g)(l)]

                [Note:  The Permit Writer may allow the determination
               of background quality based on samples from wells
               that are not upgradient from the waste management
               area if:  (i) hydrogeologic conditions do not allow
               the Permittee to determine which wells are
               upgradient; or (ii) sampling at other wells will
               provide an indication of background ground-water
               quality that is as representative, or more
               representative, than that provided by the upgradient
               wells.] [40 CFR 264.97(g)(3)]

     X.C.2.b.  The Permittee shall take a minimum of one sample from
               each well and a minimum of four samples from the
               entire system used, to determine background ground-
               water quality for each parameter and/or constituent
               each time the system is sampled. [40 CFR
               264.97(g)(4)]    [Note:  These samples are required
               for the development of the data base for the entire
               monitoring system.  The Permit Writer can require the
               collection of additional samples.  At least one
               sample should be collected from each monitoring well
               every quarter.  At the end of one year, a minimum of
               sixteen samples must be obtained from which the
               background ground-water quality will be established.]
                             X - 4

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                                                           September 1988

X.D.   SAMPLING AND ANALYSIS PROCEDURES

The Permittee shall use the following techniques and procedures when
obtaining and analyzing samples from the ground-water monitoring wells
described in Permit Condition X.B.: [40 CFR 264.97(d) and (e)]

     X.D.I.    Samples shall be collected using the techniques described
               in Permit Attachment X-4.

     X.D.2.    Samples shall be preserved [and shipped (when shipped off
               site for analysis)], in accordance with the procedures
               specified in Permit Attachment X-4.

     X.D.3.    Samples shall be analyzed in accordance with the
               procedures specified in Permit Attachment X-4.

     X.D.4.    Samples shall be tracked and controlled using the chain-
               of-custody procedures specified in Permit Attachment X-4.

               [Note:  The Permittee must submit all of the above
               information, which is required under 40 CFR 264.97(d) and
               (e), 264.98(g) and 270.14(c)(7)(vi).]

               [Note:  The sampling and analytical procedures must be
               designed to provide a reliable indication of the quality
               of the ground water below the facility, pursuant to 40 CFR
               264.97(d) and (e).]

X.E.   ELEVATION OF THE GROUND-WATER SURFACE

     X.E.I.    The Permittee shall determine the elevation of the ground-
               water surface at each well each time the ground water is
               sampled, in accordance with Permit Condition X.G.2.   [40
               CFR 264.97(f)]

               [Note:  The Permit Writer should include Permit Condition
               X.E.2. if new monitoring wells are installed.  The
               surveyed ground surface elevation of all existing
               monitoring wells is required on the facility map in the
               Part B Permit Application.]

     X.E.2.    The Permittee shall record the surveyed elevation of the
               monitoring well(s) when installed (with as-built
               drawings).   [Note:  The total depth of the well and the
               elevations of the following should be recorded: top of
               casing, ground surface and/or apron elevation, and the
               protective casing.]
                                  X - 5

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                                                           September 1988

X.F.   STATISTICAL PROCEDURES

[Note:  40 CFR 264, Subpart F regulations were undergoing revisions at
the time this permit module was prepared.  The new regulations will
specify six performance standards that the statistical methods and
sampling procedures must meet.  The statistical procedures in this permit
module are based on 40 CFR 264, Subpart F, July, 1987.]

When evaluating the monitoring results in accordance with Permit
Condition X.G., the Permittee shall use the following procedures:

     X.F.I.    When a constituent's background value has a sample
               coefficient of variation less than 1.00, the Permittee
               shall conduct the following statistical procedures:

               The Permittee shall take [at least] four portions from a
               sample at each well, at the compliance point, and
               determine whether the difference between the mean of the
               constituent at each well (using all portions taken) and
               the background value for the constituent is significant,
               at the 0.05 level, using the Cochran's Approximation to
               the Behrens-Fisher Student's t-test, as described in
               Permit Attachment G.W.2 to this permit module.  If the
               test indicates that the difference is significant, the
               Permittee shall repeat the same procedure (with at least
               the same number of portions as used in the first test)
               with a fresh sample from the monitoring well.  If this
               second round of analysis indicates that the difference is
               significant, the Permittee shall conclude that a
               statistically significant change has occurred.  [40 CFR
               264.97(h)(l)(i)]

               [Note:  As an alternative to the above condition, the
               Permittee may use an equivalent statistical procedure for
               determining whether a statistically significant change has
               occurred.  The Permit Writer may specify such a procedure
               in the Permit if the alternative procedure reasonably
               balances the probability of falsely identifying a non-
               contaminating regulated unit and the probability of
               failing to identify a contaminating regulated unit, in a
               manner that is comparable to that of the statistical
               procedure described in Permit Condition X.F.I.] [40 CFR
               264.97(h)(l)(ii)]

     X.F.2.    The Permittee shall conduct the statistical procedures as
               presented in Permit Attachment X-5  .

               [Note:  In all other situations in a detection monitoring
               program, the Permittee must use a statistical procedure
               providing reasonable confidence that the migration of
               hazardous constituents from a regulated unit into and

                                  X - 6

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                                                           September 1988

               through the aquifer will be indicated.  The Permit Writer
               must specify a. statistical procedure in the Permit that:

               o    Is appropriate for the distribution of the data used
                    to establish background values or concentration
                    limits and

               o    Provides a reasonable balance between the probability
                    of falsely identifying a non-contaminating regulated
                    unit and the probability of failing to identify a
                    contaminating regulated unit.] [40 CFR
                    264.97(h)(2)(i) and (ii)]

X.G.   MONITORING PROGRAM AND DATA EVALUATION

     X.G.I.    The Permittee shall collect, preserve, and analyze samples
               pursuant to Permit Condition X.D.

     X.G.2.    The Permittee shall determine ground-water quality at each
               monitoring well at the compliance point [Note:  The Permit
               Writer should specify the sampling frequency, but must
               require these determinations at least semi-annually.  Some
               state agencies require quarterly determinations.] during
               the active life of a regulated unit, including the closure
               period (and post-closure care period for land disposal
               units which do not clean close).  [40 CFR 264.98(d)]  The
               Permittee shall express the ground-water quality at each
               monitoring well in a form necessary for the determination
               of statistically significant increases (i.e., means and
               variances).  [40 CFR 264.97(h)]

     X.G.3.    The Permittee shall determine the ground-water flow rate
               and direction in the uppermost aquifer at least annually.
               [40 CFR 264.98(e)]

     X.G.4.    The Permittee shall determine whether there is a
               statistically significant increase over the background
               values for each parameter identified in Permit Condition
               X.C.I, each time ground-water quality is determined at the
               compliance point.   In determining whether such an increase
               has occurred, the Permittee must compare the ground-water
               quality at each monitoring well specified in Permit
               Condition X.B.I, to the background value specified in
               Permit Condition X.C.I., in accordance with the
               statistical procedures specified in Permit Condition X.F.
               [40 CFR 264.98(g)]
     X.G.5.    The Permittee shall perform the evaluations described in
               Permit Condition X.G.4. within [Note:  The Permit Writer
               should specify the number of days.   The report time

                                  X - 7

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                                                           September 1988

               required by the Permit Writer should take into
               consideration the availability of laboratory services to
               the Permittee and the type of statistical analysis
               employed by the Permittee.] after completion of sampling.
               [40 CFR 264.98(g)(2)]

X.H.   RECORDKEEPING AND REPORTING

     X.H.I.    The Permittee shall enter all monitoring, testing, and
               analytical data obtained in accordance with Permit
               Condition X.G. in the operating record.  [40 CFR
               264.73(b)(6)]  The data must include all computations,
               calculated means, variances, t-statistic values, and
               t-test results (or results of statistical tests that the
               Regional Administrator has determined to be equivalent).

     [Note:  The Permit Writer should include Permit Condition X.H.2. if
     background values were not established prior to permit issuance.
     The Permit Writer should specify when the year-long quarterly sample
     analyses and computations for background values must be submitted if
     they were not included or acceptable in the Part B Permit
     Application.]

     X.H.2.    The established background values and the computations
               necessary to determine background values must be submitted
               to the Regional Administrator.

     [Note:  The regulations do not require the Permittee to routinely
     submit all the ground-water sampling analytical results, statistical
     evaluations or results of the annual determination of the ground-
     water flow rate and direction.  Such information is required to be
     submitted when there are significant changes in hazardous
     constituent concentrations or there are changes in the ground-water
     flow rate or direction which negate or adversely alter monitoring
     system effectiveness.  The Permit Writer may require this "routine"
     information.  Include Permit Condition X.H.2. if the facility is to
     submit the information on a regular basis.]

     X.H.3.    The Permittee shall submit the analytical results required
               by Permit Conditions X.G.2. and X.G.3. and the results of
               the initial statistical analyses required by Permit
               Condition X.G.4., in accordance with the following
               schedule:   [Note:  The Permit Writer should specify the
               reporting schedule for ground-water sampling, the
               statistical determination of ground-water sampling, and
               the annual ground-water flow rate and direction
               determination.]
                                  X  -

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                                                      September 1988

          [The following is an example of a Quarterly Reporting
          Schedule:

          Samples to be Collected
          During the Preceding              Results Due to
          	Months of	     the Regional Administrator By

          January - February                 April 15
          April - May                        July 15
          July - August                      October 15
          October - November                 January 15]

X.H.4.    If the Permittee determines, pursuant to Permit Condition
          X.G.,  there is a statistically significant increase above
          the background values for the indicator parameters
          specified in Permit Condition X.C.I., the Permittee shall:

     X.H.4.a.  Notify the Agency in writing within seven days.  [40
               CFR 264.98(h)(l)]

     X.H.4.b.  Immediately sample the ground water in all wells and
               determine the concentration of all constituents
               identified in Appendix IX of 40 CFR 261. [40 CFR
               264.98(h)(2)]

     X.H.4.C.  Establish the background values for each Appendix IX
               constituent found in the ground water. [40 CFR
               264.98(h)(3)]

     X.H.4.d.  Within 90 days, submit to the Agency an application
               for a permit modification to establish a compliance
               monitoring program.  [40 CFR 264.98(h)(4)]  The
               application must include the following information:

               X.H.4.d.l      An identification of the concentration
                              of each Appendix IX constituent found
                              in the ground water at each monitoring
                              well at the compliance point.   [40 CFR
                              264.98(4)(i)]

               X.H.4.d.2      Any proposed changes to the ground-
                              water monitoring system at the
                              facility necessary to meet the
                              requirements of compliance monitoring
                              as described in 40 CFR 264.99.  [40
                              CFR 264.98(h)(4)(ii)]

               X.H.4.d.3      Any proposed changes to the monitoring
                              frequency, sampling and analysis
                              procedures,  or methods or statistical
                              procedures used at the facility

                             X - 9

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                                                      September 1988

                              necessary to meet the requirements of
                              compliance monitoring as described in
                              40 CFR 264.99.   [40 CFR
                              264.98(h)(4)(iii)]

               X.H.4.d.4      For each hazardous  constituent found
                              at the compliance point, a proposed
                              concentration limit, or a notice of
                              intent to seek an alternate
                              concentration limit for a hazardous
                              constituent [40 CFR 264.98(h)(4)(iv)]

     X.H.4.e.  Submit a corrective action feasibility plan to the
               Agency within 180 days.  [40 CFR 264.98(h)(5)]

X.H.5.    If the Permittee determines, pursuant to Permit Condition
          X.G.,  there is a statistically significant increase above
          the background values for the parameters specified in
          Permit Condition X.C.I., he may demonstrate that a source
          other than a regulated unit caused the increase or that
          the increase resulted from error in sampling, analysis, or
          evaluation. In such cases, the Permittee shall:

     X.H.S.a.  Notify the Regional Administrator in writing within
               seven (7) days that he intends to make a
               demonstration.  [40 CFR 264.98(i)(1)]

     X.H.S.b.  Within 90 days, submit a report to the Regional
               Administrator which demonstrates that a source other
               than a regulated unit caused the increase, or that
               the increase resulted from error in sampling,
               analysis, or evaluation.  [40 CFR 264.98(i)(2) ]

     X.H.5.C.  Within 90 days, submit to the Regional Administrator
               an application for a permit modification to make any
               appropriate changes to the detection monitoring
               program at the facility.  [40 CFR 264.98(1) (3) ]

     X.H.S.d.  Continue to monitor in accordance with the detection
               monitoring program at the facility.   [40 CFR
               264.98(i)(4)]

      [Note:  The Permittee need not submit a corrective action
     feasibility plan, in accordance with 40 CFR 264.98(h)(5)(ii),
     if the concentrations of all hazardous constituents identified
     under Permit Condition X.H.5.b. do not exceed the respective
     values listed in Table 1 of 40 CFR 264.94, or the Permittee has
     sought an ACL variance for every hazardous constituent
     identified under Permit Condition X.H.S.b.l
                             X -  10

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                                                           September 1988

X.I. ASSURANCE OF COMPLIANCE

The Permittee shall assure the Regional Administrator that ground-water
monitoring and corrective action measures necessary to achieve compliance
with the ground-water protection standard under 40 CFR 264.92 are taken
during the term of the Permit.  [40 CFR 264.98(k)]

X.J. SPECIAL REQUIREMENTS IF SIGNIFICANT INCREASES OCCUR IN VALUES FOR
     PARAMETERS OR CONSTITUENTS

If the Permittee has determined a statistically significant increase over
the background values for any of the parameters and/or constituents
identified in Permit Condition X.C.I., in accordance with statistical
procedures specified in Permit Condition X.F., the Permittee must:

     X.J.I.    Notify the Regional Administrator in writing, within seven
               (7) days.  The notification must indicate what parameters
               or constituents have shown statistically significant
               increases.  [40 CFR 264.98(h)(1)]

     X.J. 2.    Immediately sample the ground water in all wells and
               determine the concentration of all constituents identified
               in Appendix IX of 40 CFR 261.  [40 CFR 264.98(h)(2)]

     X.J.3.    Establish background values for each Appendix IX
               constituent found in the ground water. [40 CFR
               264.98(h)(3)]

     X.J.4.    Within 90 days, submit to the Regional Administrator an
               application for a permit modification to establish a
               compliance monitoring program.  [40 CFR 264.98(h)(4)]

     X.J. 5.    Submit to the Regional Administrator a corrective action
               feasibility plan within 180 days.  [40 CFR 264.9800(5)]

               [Note:  The Permittee need not submit a corrective action
               feasibility plan, in accordance with 40 CFR
               264.98(h)(l)(ii), if the concentrations of all hazardous
               constituents identified under Permit Condition X.H.4.b. do
               not exceed the respective values listed in Table 1 of 40
               CFR 264.94, or the Permittee has sought an ACL variance
               for every hazardous constituent identified under Permit
               Condition X.H.4.b.]

X.K.   REQUEST FOR PERMIT MODIFICATION

If the Permittee or the Regional Administrator determines the detection
monitoring program no longer satisfies the requirements of the
regulations,  the Permittee must, within 90 days of the determination,
submit an application for a permit modification to make any appropriate
                                 X  -  11

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                                                           September 1988
changes to the program which will satisfy the regulations.   [40 CFR
264.98(j)]
                                  X -  12

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                                                           September 1988
        PERMIT ATTACHMENTS REFERENCED IN MODULE X - GROUND-WATER
                           DETECTION MONITORING
This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.  The Permit Writer may select
other numbering schemes, as appropriate,  when preparing actual Permits.

Permit Attachment No.              	Plan or Document	
                                   (from the Part B Permit Application)

G.W.I                              Maximum Concentration of Constituents
                                   for Ground-Water Protection

G.W.2                              Cochrans Approximation to the Behrens-
                                   Fisher Student's T-Test

X-l*                               Facility map depicting the monitoring
                                   well locations and regulated units

X-2*                               Plans and specifications for
                                   monitoring well construction,
                                   installation and maintenance

X-3*                               Methodology for Monitoring Well
                                   Abandonment

X-4*                               Sampling and Analysis Plan

X-5*                               Alternative Statistical Procedures
     These attachments are not part of the module.   These attachments
     should be in the facility's Part B Permit or may, as in the case of
     Alternative Statistical Procedures,  be supplied by the Regional
     Administrator.
                                 X  -  13

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                                                           September 1988
                            ATTACHMENT G.W.I
            (to Module X - Ground-Water Detection Monitoring)

                Maximum Concentration of Constituents for
                         Ground-Water Protection
Constituent                        Maximum concentration
                                   (Milligrams per liter)

Arsenic                                      0.05
Barium                                       1.0
Cadmium                                      0.01
Chromium                                     0.05
Lead                                         0.05
Mercury                                      0.002
Selenium                                     0.01
Silver                                       0.05
Endrin (1,2,3,4,10,10-
  hexachloro-l,7-epoxy-l,4,
  4a,5,6,7,8,9a-octahydro-1,
  4-endo, endo-5,8-dimethano
  naphthalene)                               0.0002
Lindane (1,2,3,4,5,6-
  hexachlorocyclohexane,
  gamma isomer)                              0.004
Methoxychlor (1,1,1-
  Trichloro-2,2-bis (p-
  methoxyphenylethane)                       0.1
Toxaphene  (C10H10C16,
  Technical chlorinated
  camphene, 67-69 percent
  chlorine)                                  0.005
2,4-D (2,4-Dichlorophenoxyacetic
  acid)                                      0.1
2,4,5-TP Silvex (2,4,5-
  Trichlorophenoxypropionic
  acid)                                      0.01
Source:  40 CFR 264.94, Table 1, July 1987.
                                  X -  14

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                                                           September 1988
                             ATTACHMENT G.W.2
            (To Module X - Ground-Water Detection Monitoring)
COCHRAN'S APPROXIMATION TO THE BEHRENS-FISHER STUDENT'S T-TEST

Using all the available background data (n^, readings), calculate the
background mean (Xg) and background variance (Sg ).  For the single
monitoring well under investigation (1% reading), calculate the
monitoring mean (Xjj) and monitoring variance (Sm^) .
For any set of data (Xj_, X2-..Xn) the mean is calculated by:

                             _   X1+X2+...Xn
                             X = 	

                                     n

and the variance is calculated by:

                          (XX-X)2 + (X2-X)2...+ (Xn-X)2
                     S2 - 	

                                      n-1

where "n" denotes the number of observations in the set of data.

The t-test uses these data summary measures to calculate a t-statistic
(t*) and a comparison t-statistic (tc).  The t  value is compared to the
tc value and a conclusion reached as to whether there has been a
statistically significant change in any indicator parameter.

The t-statistic for all parameters except pH and similar monitoring
parameters is:

t                                    V  V
                              =     Xm-Xn
                                  m    nB

If the value of this t-statistic is negative then there is no significant
difference between the monitoring data and background data.  It should be
noted that significantly small negative values may be indicative of a
failure of the assumption made for test validity or errors have been made
in collecting the background data.

The t-statistic (tc),  against which t  will be compared, necessitates
finding tg and tm from standard (one-tailed) tables where,

                                  X  -  15

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                                                           September 1988
tg=t-tables with (ng-1) degrees of freedom,  at the 0.05 level of
significance.

tm=t-tables with (r^-l) degrees of freedom,  at the 0.05 level of
significance.

Finally, the special weightings Wjj and Wm are defined as:

                            9                    o
                          ST                    ^
                     Wg = 	     and      Wm = 	

                          nB                    "m

and so the comparison t-statistic is:
The t-statistic (t ) is now compared with the comparison t-statistic (tc)
using the following decision-rule:

     If t  is equal to or larger than tc then conclude that there most
     likely has been a significant increase in this specific parameter.

     If t  is less than tc then conclude that most likely there has not
     been a change in this specific parameter.

The t-statistic for testing pH and similar monitoring parameters is
constructed in the same manner as previously described except the
negative sign (if any) is discarded and the caveat concerning the
negative value is ignored.  The standard (two-tailed) tables are used in
the construction tc for pH and similar monitoring parameters.

If t  is equal to or larger than tc, then conclude that there most likely
has been a significant increase (if the initial t  had been negative,
this would imply a significant decrease).  If t  is less than tc, then
conclude that there most likely has been no change.

A further discussion of the test may be found in Statistical Methods (6th
Edition, Section 4.14) by G. W. Snedecor and W. G. Cochran, or Principles
and Procedures of Statistics (1st Edition, Section 5.8) by R. G. D. Steel
and J. H. Torrie.
                                                                              I
                                  X -  16

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                                                      September 1988
                  Standard T-Tables  for a 0.05
                     Level of Significance
Degrees
of Freedom
1 	
2 	
3 	
4 	
5 	
6 	
7 	
8 	
9 	
10 	
11 	
12 	
13 	
14 	
15 	
16 	
17 	
18 	
19 	
20 	
21 	
22 	
23 	
24 	
25 	
30 	
40 	
t- values
(1-tail)
	 6 . 314
	 2.920
	 2.353
	 2.132
	 2.015
	 	 1.943
	 	 1.895
	 	 1.860
	 	 1.833
	 	 1.812
	 1.796
	 1.782
	 1.771
	 1.761
	 1.753
	 	 1.746
	 1.740
	 1.734
	 1.729
	 	 1.725
	 1.721
	 1.717
	 1.714
	 1.711
	 1.708
	 1.697
	 1.684
t- values
(2-tail)
12.706
4.303
3.182
2.776
2.571
2.447
2.365
2.306
2.262
2.228
2.201
2.179
2.160
2.145
2.131
2.120
2.110
2.101
2.093
2.086
2.080
2.074
2.069
2.064
2.060
2.042
2.021
Adapted from Table III of "Statistical Tables for Biological
Agricultural and Medical Researcb" (1947, R. A. Fisher and
F. Yates).

[47 FR 32367, July 26, 1982]
                            X  -  17

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                                                           September 1988


             MODULE XI  -  GROUND-WATER COMPLIANCE MONITORING

[Note:  This module presents permit conditions addressing the regulatory
requirements for ground-water compliance monitoring programs (40 CFR
264.91, 264.98, and 264.99).  A compliance monitoring program must be
established at the facility if the Permittee or the Regional
Administrator determines there is a statistically significant increase in
the concentration of hazardous constituents in the ground water at the
point of compliance.   This determination is the result of either an
interim status assessment ground-water monitoring program [40 CFR 265.91]
or a detection ground-water monitoring program [40 CFR 264.98].  Federal
regulations 40 CFR 264.98(h)(4) and 270.14(c)(5) and (c)(7) require the
applicant to submit detailed plans and engineering reports describing the
proposed compliance monitoring program.]

[Note:  The goal of compliance monitoring is to determine whether and
when leakage of hazardous constituents into the ground water exceeds
specified concentration limits.  Compliance monitoring entails the
following:

     1.   Development of a list of all 40 CFR 261,  Appendix IX hazardous
          constituents present in the ground water which could have
          reasonably been derived from the facility;

     2.   Specification of a concentration limit for each hazardous
          constituent listed in the Permit;

     3.   Establishment of a ground-water protection standard at the
          compliance point; and

     4.   Establishment of the duration of the compliance period.]

[Note:  On July 9, 1987, a federal rule was finalized to require analysis
for 40 CFR 261, Appendix IX, rather than Appendix VIII, hazardous
constituents pursuant to 40 CFR 264.98 and 264.99,  (1) if a statistically
significant increase occurs for any detection monitoring parameters or
constituents, and (2) annually under compliance monitoring.  The Appendix
IX list is an abbreviated Appendix VIII list, with several constituents
added.  This permit module incorporates the new rule.]

[Note:  Under 40 CFR 264.91(b) the Regional Administrator may include one
or more of the following programs in a permit: (1)  detection monitoring
(Module X), (2) compliance monitoring (Module XI),  and (3) corrective
action [Module XII(A)].  If more than one program is included in the
Permit, the Permit Writer is to specify the circumstances or conditions
under which each program will be required.  It is possible that more than
one program will be operable at the same time at a facility, or that the
programs will be conditional based on a sequence of events.  For example,
the sequence set up in the Permit could include a detection monitoring
program that triggers an Appendix IX analysis that triggers a Permittee

                                 XI  - 1

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                                                           September 1988
option to apply for a variance (e.g., other contamination source or
sampling error) and if the Permittee fails to seek or fails to obtain a
variance, then compliance monitoring is triggered.  The Permit could also
set the ground water protection standard, with a provision for the
Permittee to apply for an Alternate Concentration Limit (ACL) , and in the
absence of an ACL application or denial of an ACL, or exceedence of an
ACL or pre-set limit, the triggering of the corrective action program.
The corrective action program could include plume assessment, corrective
measures study and design, and implementation of corrective action.
Setting up such a sequence in the Permit reduces the number of permit
modifications that may be needed and decreases the administrative time
needed to get on with subsequent steps in the process and ultimately, the
time required to get corrective action under way, if needed.]

[Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]

XI.A.     MODULE HIGHLIGHTS

[The Permit Writer should include a general discussion of the activities
covered by this module.  The discussion should include the following
information: description of the waste management units for which
compliance monitoring is being conducted; number, location, and depth of
wells; which wells are upgradient and downgradient;  hazardous
constituents and concentration limits; compliance period for each
hazardous waste management unit; special features associated with the
operation; and a reference to any special permit conditions.]

XI.B.     WELL LOCATION. INSTALLATION AND CONSTRUCTION

[Note:  For specific Agency guidance on monitoring well design and
construction, hydrogeologic site characterization, and location of
monitoring wells, the Permit Writer should consult the EPA RCRA Ground-
Water Monitoring Technical Enforcement Guidance Document (September
1986).]

The Permittee shall  (install and) maintain a ground-water monitoring
system, as specified below:  [40 CFR 264.99(b)]

     XI.B.I.   The Permittee shall (install and) maintain ground-water
               monitoring wells at the locations specified on the map
               presented in Permit Attachment XI-1.  and in conformance
               with the following list:

               [Note:  The map must show all monitoring well locations
               and provide identifiers for each well.  The number and
               location of monitoring wells utilized for ground-water
               monitoring is site specific.  The number and location of

                                  XI  -  2

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                                                      September 1988
          the wells must meet the requirements of 40 CFR 264.95
          (Point of Compliance) and 40 CFR 264.97(a) or (b) (number,
          location, and depth of wells).   The ground-water
          monitoring system must:  yield samples in upgradient wells
          that represent the quality of the background water
          unaffected by leakage from any regulated unit(s); and, in
          downgradient wells,  yield samples that represent the
          quality of water passing the point of compliance.  The
          number and location of monitoring wells must be sufficient
          to identify and define all potential release pathways from
          the regulated units based on site-specific hydrogeologic
          characterization.  The Permit Writer may require the
          Permittee to selectively monitor a hydrologic zone that
          the Permittee has not described as part of the uppermost
          aquifer (e.g., perched water table); if based on
          hydrogeological characteristics,  the hydrogeologic zone is
          an area of concern for the migration of hazardous
          constituents from regulated units that can be transported
          to any exposure point.]

XI.B.2.   The Permittee shall (construct and) maintain the
          monitoring wells identified in Permit Condition XI.B.l.,
          in accordance with the plans and specifications presented
          in Permit Attachment XI-2.

          [Note:  The plans and specifications in the Part B Permit
          Application must meet the requirements of 40 CFR 264.97(a)
          and (c).  They should consist of design drawings and
          design criteria applicable to all wells and individual
          well specifications identifying depth and screened
          intervals.]

[Note:  If determined to be necessary to protect human health or the
environment, the Permit Writer may include Permit Condition XI.B.3.,
specifications on how monitoring wells are plugged and abandoned.
HSWA Section 212 provides EPA with this authority.  Several states
have regulations which cover monitoring well abandonment.]

XI.B.3.   All wells deleted from the monitoring program shall be
          plugged and abandoned in accordance with Permit Attachment
          XI-3.   Well plugging and abandonment methods and
          certification shall be submitted to the Regional
          Administrator within [The Permit Writer should specify the
          submittal period.] from the date the wells are removed
          from the monitoring program.
                            XI  -  3

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                                                           September 1988
XI.C.      GROUND-WATER PROTECTION STANDARD
[Note:  The Permit Writer must establish concentration limits for the
constituents listed in this condition, pursuant to 40 CFR 264.94(a) to
implement the ground-water protection standard.  Concentration limits for
hazardous constituents are established at each waste management area to
determine the ground-water protection standard (GWPS) at the facility.
There are four ways to determine the concentration limits in establishing
the GWPS:  (1) use of pooled background levels of the hazardous
constituents determined from facility ground-water monitoring; (2) use of
maximum constituent concentrations listed in Table 1, 40 CFR 264.94(a) -
Permit Attachment G.W.I to this module; (3) use of alternate
concentration limits (ACLs) proposed by the Permittee; or (4) the
concentration limits may be established at upgradient wells each time the
ground water is sampled at the compliance point, if there is a high
temporal correlation.  The GWPS may be a combination of these four
methods.  For detailed information on ACLs, consult the EPA Alternate
Concentration Limit Guidance (July 1987).  The Permit Writer may
incorporate the background concentrations of hazardous constituents from
Table 1, 40 CFR 264.94(a), if background concentrations for these
constituents have not been established at the facility.]

     XI.C.1.    The Permittee shall monitor the ground water to determine
               whether regulated units are in compliance with the ground-
               water protection standard under 40 CFR 264.92.  The
               following hazardous constituents and their concentration
               limits comprise the ground-water protection standard:  [40
               CFR 264.93 and 94]

     Hazardous Constituents                  Concentration Limits
                [Note:  The Permit Writer should develop a list of
               hazardous constituents to establish initial compliance
               monitoring requirements using the following information
               submitted by the Permittee in the Part B Permit
               Application: waste analysis plan, waste characterization,
               site hydrogeologic characterization, Appendix IX ground-
               water sample analyses, and proposed monitoring
               constituents.  In addition to the hazardous constituents,
               the Permit Writer may require the Permittee to monitor for
               ground-water quality indicator parameters.]

      [Note:  The concentration limits should be determined from the mean
      of pooled background data available for the concentrations of
      hazardous constituents at the time of permitting, from Table 1 in 40
      CFR 264.94(a) or approved ACLs.  The Permittee should include Permit
      Condition XI.C.2. if the Permittee has demonstrated a high temporal
      correlation between upgradient and compliance point hazardous
      constituents.]  [40 CFR 264.99(c)(1)]

                                 XI  - 4

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                                                           September 1988
     XI.C.2.    The Permittee may establish the concentration limit by
               sampling the upgradient well(s) each time ground water is
               sampled at the compliance point.  The concentration limit
               for the hazardous constituent(s) must be determined
               according to the following procedure:

               [Note:  the Permit Writer must specify the procedures used
               for determining the concentration limit in Permit
               Condition XI.C.2.  The concentration limits may be
               determined by Permit Condition XI.C.2. only if the
               Permittee can demonstrate a high temporal correlation
               between upgradient and compliance point concentrations for
               hazardous constituents.]

     XI.C.3.    The Permittee shall monitor [The Permit Writer should
               specify the well numbers to be monitored.] at the point of
               compliance, as described in Permit Condition XI.B., and as
               designated in Permit Attachment XI-1.  [40 CFR 264.95]

     XI.C.4.    The compliance period, during which the ground-water
               protection standard applies, is equal to 	 months (or
               years) [The Permit Writer should specify the applicable
               time period.  The compliance period shall begin at the
               time the Permittee begins the compliance monitoring
               program.]  [40 CFR 264.96(b)]  If the Permittee is
               conducting corrective action at the end of the compliance
               period specified, then the compliance period shall be
               extended until the Permittee demonstrates that the ground-
               water protection standard has not been exceeded for three
               consecutive years. [40 CFR 264.96(c)]

XI.D.     SAMPLING AND ANALYSIS PROCEDURES

The Permittee shall use the following techniques and procedures when
obtaining and analyzing samples from the ground-water monitoring wells
described in Permit Condition XI.B.:  [40 CFR 264.97(d) and (e)]

     XI.D.I.    Samples shall be collected using the techniques described
               in Permit Attachment XI-4.

     XI.D.2.    Samples shall be preserved [and shipped (when shipped off
               site for analysis)], in accordance with the procedures
               specified in Permit Attachment XI-4  .

     XI.D.3.    Samples shall be analyzed in accordance with the
               procedures specified in Permit Attachment XI-4.

     XI.D.4.    Samples shall be tracked and controlled using the chain-
               of-custody procedures specified in Permit Attachment XI-4.

                                 XI  -  5

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                                                           September 1988
               [Note:  The sampling and analysis procedures described in
               the Part B Permit Application must be designed to provide
               a reliable indication of ground-water quality below the
               waste management area and be compatible with the
               statistical analysis method.]

     XI.D.5.   The Permittee must determine the concentration of
               hazardous constituents in the ground water at the
               compliance point at least quarterly during the compliance
               period which was specified in Permit Condition XI.C.3. [40
               CFR 264.99(d)]

               [Note:  The Permit Writer can require more frequent
               collection of samples, if necessary.]

     XI.D.6    The Permittee must annually analyze samples from all
               monitoring wells, at the compliance point, for all
               constituents listed in Appendix IX, 40 CFR 261, during the
               compliance period, [40 CFR 264.99(f)]

               [Note:  The Permit Writer can require more frequent
               collection of Appendix IX samples, if necessary.]

XI.E.     ELEVATION OF THE GROUND-WATER SURFACE

     XI.E.I.   The Permittee shall determine the ground-water surface
               elevation at each monitoring well each time ground water
               is sampled in accordance with Permit Condition XI.G.  [40
               CFR 264.97(f)]

     [Note:  The Permit Writer should include Permit Condition XI.E.2. if
     new monitoring wells are installed.  The surveyed ground surface
     elevation of all existing monitoring wells is required on the
     facility map from the Part B Permit Application.]

     XI.E.2.   The Permittee shall report the surveyed elevation of the
               monitoring well(s) when installed (with as-built
               drawings).  [Note: The total depth of wells and the
               elevation of the following should be recorded: top of
               casing, ground surface and/or apron elevation, and the
               protective casing.]

XI.F.     STATISTICAL PROCEDURES

[Note:  40 CFR 264, Subpart F regulations were undergoing revisions at
the  time this permit module was prepared.  The new regulations will
specify six performance standards that the statistical methods and
sampling procedures must meet.  The statistical procedures in this permit
module are based on 40 CFR 264, Subpart F, July 1, 1987.]

                                  XI  -  6
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                                                           September 1988
When evaluating the monitoring results in accordance with Permit
Condition XI.G.,  the Permittee shall use the following procedures:

[Note:  The Permittee must use a statistical procedure that provides
reasonable confidence that the migration of hazardous constituents from a
regulated unit into and through the aquifer will be indicated.  The
Permit Writer must specify a statistical procedure in the Permit that:

     o    Is appropriate for the distribution of the data used to
          establish background values or concentration limits and

     o    Provides a reasonable balance between the probability of
          falsely identifying a non-contaminating regulated unit and the
          probability of failing to identify a contaminating regulated
          unit.]   [40 CFR 264.97(c)(2)(i) and (ii)]

XI.G.      MONITORING PROGRAM AND DATA EVALUATION

The Permittee shall determine ground-water quality as follows:

     XI.G.I.   The Permittee shall collect, preserve, and analyze ground-
               water samples pursuant to Permit Condition XI.D.

     XI.G.2.   The Permittee shall determine the concentration of
               hazardous constituents (as specified in Permit Condition
               XI.C) in ground water at each monitoring well (required
               under Permit Condition XI.B.), at the compliance point,
               during the compliance period.  These determinations shall
               be made [The Permit Writer should specify the frequency.
               The frequency must be at least quarterly during the
               compliance period.]  [40 CFR 264.99(d)]

     XI.G.3.   The Permittee shall determine the ground-water flow rate
               and direction in the uppermost aquifer at least annually.
               [40 CFR 264.99(e)]

     XI.G.4.   The Permittee shall analyze samples from all monitoring
               wells,  at the compliance point,  for all constituents
               contained in 40 CFR 261, Appendix IX [The Permit Writer
               should specify the frequency.  The frequency must be at
               least annually],  to determine whether additional hazardous
               constituents are present in the uppermost aquifer.  If the
               Permittee finds additional constituents present (i.e.,  not
               listed in Permit Condition XI.C.),  their concentrations
               shall be reported to the Regional Administrator in writing
               within seven (7)  days from completion of the analysis.
               [40 CFR 264.99(f)]
                                 XI  -  7

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                                                           September 1988
     XI.G.5.    For each hazardous constituent identified in Permit
               Condition XI.C.,  the Permittee shall determine whether
               there is a statistically significant increase (i.e.,  means
               and variances) over the concentration limit for that
               parameter or constituent each time the concentration of
               hazardous constituents is monitored in ground water at the
               compliance point,  pursuant to Permit Condition XI.G.2.  In
               determining whether such an increase has occurred,  the
               Permittee shall compare the ground-water quality at each
               monitoring well specified in Permit Condition XI.C. to the
               concentration limit for that constituent, in accordance
               with the procedures specified in Permit Condition XI.F.
               [40 CFR 264.99(h)(l) and (h)(2)]

     XI.G.6.    The Permittee shall perform the statistical evaluation
               required by Permit Condition XI.G.5. within [Note:   The
               Permit Writer should specify the time period, considering
               the complexity of the statistical test and the
               availability of laboratory facilities to perform the
               ground-water sample analysis.] days from completion of the
               sampling analysis.  [40 CFR 264.99(h)(2)]

XI.H.     REPORTING AND RECORDKEEPING

     XI.H.I.    The Permittee shall enter all monitoring, testing,  and
               analytical data obtained pursuant to Permit Condition
               XI.G. in the operating record.  The data must include all
               computations, calculated means, variances, and results of
               statistical tests.  [40 CFR 264.73(b)]

     [Note:  The regulations do not require the Permittee to routinely
     submit all the ground-water sampling analytical results, statistical
     evaluations, or results of the annual determination of the ground-
     water flow rate and direction.  Such information is required to be
     submitted when there are significant changes in hazardous
     constituent concentrations or there are changes in the ground-water
     flow rate or direction which negate or adversely alter monitoring
     system effectiveness.  However, the Permit Writer may require this
     "routine" information.  Include Permit Condition XI.H.2. if the
     facility is to submit the information on a regular basis.]

     XI.H.2.    The Permittee shall submit the analytical results required
               by Permit Conditions XI.E., XI.G.2., XI.G.3., and XI.G.5.,
               in accordance with the following schedule:
                                  XI  -  8

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                                                           September 1988


               [Note:  The following is an example of a quarterly ground-
               water report schedule:

               Samples to be Collected
               During the Preceding              Results Due to
               	Months of	     the Regional Administrator By

               January - February                   April 15
               April - May                          July 15
               July - August                        October 15
               October - November                   January 15]

     XI.H.3.   If the Permittee determines, pursuant to Permit Condition
               XI.G., there is a statistically significant increase above
               the concentration limits for the constituents specified in
               Permit Condition XI.C. (indicating that the ground-water
               protection standard is being exceeded),  the Permittee
               shall notify the Regional Administrator in writing within
               seven (7) days.  (40 CFR 264.99(1)(1)]

     XI.H.4.   The Permittee shall report concentrations of any
               additional Appendix IX constituents (i.e., not listed in
               Permit Condition XI.C) to the Regional Administrator
               within seven (7) days from completion of the analysis.
               [40 CFR 264.99(f)]

XI.I.      ASSURANCE OF COMPLIANCE

The Permittee shall assure that monitoring and corrective action measures
necessary to achieve compliance with the ground-water protection standard
are taken during the term of the Permit. [40 CFR 264.99(k)(1)]

XI.J.      SPECIAL REQUIREMENT IF THE GROUND-WATER PROTECTION STANDARD IS
          EXCEEDED

     XI.J.I.   The Permittee must notify the Regional Administrator in
               writing within seven (7) days if the ground-water
               protection standard has been exceeded at any monitoring
               well.  The notification must indicate which concentration
               limits have been exceeded. [40 CFR 264.99(i)(1)]

     XI.J. 2.   The Permittee must submit to the Regional Administrator a
               permit modification to establish a corrective action
               program meeting 40 CFR 264.100 requirements within 180
               days, or within 90 days if the Permittee has previously
               submitted an engineering feasibility study. [40 CFR
               264.99(i)(2)] [Note:  The information requirements for the
               permit modification are outlined in 40 CFR 264.99(1)(2)(i)
               and (i)(2)(ii).J
                                 XI  - 9

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                                                           September 1988
     XI.J.3.    The Permittee may make a demonstration that the ground-
               water protection standard was exceeded due to sources
               other than a regulated unit or errors in sampling,
               analysis or evaluation.  [40 CFR 264.99(j)]

          Xl.J.S.a.  The Permittee must notify the Regional Administrator
                    in writing,  within seven (7)  days,  that a
                    demonstration will be made.  [40 CFR 264.99(j)(1)]

          Xl.J.S.b.  The Permittee must submit a report to the Regional
                    Administrator, within 90 days, that demonstrates that
                    a source other than a regulated unit caused the
                    ground-water protection standard to be exceeded or
                    that the apparent non-compliance was a result of an
                    error in sampling,  analysis or evaluation.  [40 CFR
                    264.99(j)(2)]

          XI.J.3.C.  The Permittee must submit to the Regional
                    Administrator within 90 days an application for a
                    permit modification to make any appropriate changes
                    in the compliance monitoring program at the facility.
                    [40 CFR 264.99(j)(3)]

          Xl.J.S.d.  The Permittee must continue the compliance monitoring
                    program in accordance with 40 CFR 264.99.

     XI.J.4.    If the Permittee or the Regional Administrator determines
               that the compliance monitoring program no longer satisfies
               the requirements of 40 CFR 264.99, the Permittee must
               submit a permit modification application within 90 days of
               the determination detailing appropriate changes to the
               compliance monitoring program. [40 CFR 264.99(k)]

XI.K.     REQUEST FOR PERMIT MODIFICATION

     XI.K.I.    If the Permittee or the Regional Administrator determines
               the ground-water protection standard is being exceeded,
               the Permittee shall submit to the Regional Administrator
               an application for a permit modification to establish a
               corrective action program. [40 CFR 264.99(i)(2)]

               [Note:  Submittal is required within 90 days if an
               engineering feasibility study has been previously
               submitted to the Regional Administrator; within 180 days
               otherwise. The application content is described  in 40 CFR
               264.99(i)(2).]
I
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                                                      September 1988
XI.K.2.   If the Permittee or the Regional Administrator determines
          the compliance monitoring program no longer satisfies the
          requirements of 40 CFR 264.99, then, within 90 days, the
          Permittee must submit an application for a permit
          modification to make any appropriate changes to the
          program. [40 CFR 264.99(k)]
                            XI - 11

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                                                           September 1988
         PERMIT ATTACHMENT REFERENCED IN MODULE XI  - GROUND-WATER
                          COMPLIANCE MONITORING

This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.   The Permit Writer may select
other number schemes, as appropriate, when preparing actual Permits.

Permit Attachment No.    	Plan or Document	
                            (from the Part B Permit Application)

G.W.I                    Maximum Concentration of Constituents for
                         Ground-Water Protection

XI-1                     Facility map depicting ground-water monitoring
                         wells and regulated units

XI-2                     Plans and specifications for monitoring well
                         construction, installation and maintenance

XI-3                     Methodology for monitoring well abandonment

XI-4                     Sampling and Analysis Plan

XI-5                     Statistical Procedures
                                 XI - 12

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                                                           September 1988
                            ATTACHMENT G.W.I
           (to Module XI - Ground-Water Compliance Monitoring)

                Maximum Concentration of Constituents for
                         Ground-Water Protection
Constituent                        Maximum concentration
                                   (Milligrams per liter)

Arsenic                                      0.05
Barium                                       1.0
Cadmium                                      0.01
Chromium                                     0.05
Lead                                         0.05
Mercury                                      0.002
Selenium                                     0.01
Silver                                       0.05
Endrin (1,2,3,4,10,10-
  hexachloro-1,7-epoxy-1,4,
  4a,5,6,7,8,9a-octahydro-l,
  4-endo,  endo-5,8-dimethano
  naphthalene)                               0.0002
Lindane (1,2,3,4,5,6-
  hexachlorocyclohexane,
  gamma isomer)                              0.004
Methoxychlor (1,1,1-
  Trichloro-2,2-bis (p-
  methoxyphenylethane)                       0.1
Toxaphene (CiQHioClg,
  Technical chlorinated
  camphene,  67-69 percent
  chlorine)                                   0.005
2,4-D (2,4-Dichlorophenoxyacetic
  acid)                                      0.1
2,4,5-TP Silvex (2,4,5-
  Trichlorophenoxypropionic
  acid)                                      0.01
Source:  40 CFR 264.94, Table 1, July 1987.
                                 XI - 13

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                                                           September 1988
          MODULE XII(A) - CORRECTIVE ACTION FOR REGULATED UNITS

[Note:  This module provides permit conditions for waste management units
which have exceeded the ground-water protection standard at any
monitoring well at the point of compliance.  If the ground-water
protection standard is exceeded at any monitoring well at the point of
compliance, a corrective action program must be implemented to bring the
unit back into compliance with the standard.  A corrective action program
may be permitted separately after receipt of an application for a permit
modification or it may be specified as part of the Permit for the com-
pliance monitoring program.]

[Note:  On July 9, 1987, a federal rule was finalized to require analysis
for 40 CFR 261, Appendix IX, rather than Appendix VIII, hazardous
constituents pursuant to 40 CFR 264.98 and 264.99, (1) if a statistically
significant increase occurs for any detection monitoring parameters or
constituents and (2) annually under compliance monitoring.  The Appendix
IX list is an abbreviated Appendix VIII list, with some additional
constituents.  This permit module incorporates this new rule.]

[Note:  Under 40 CFR 264.91(b) the Regional Administrator may include one
or more of the following programs in a permit: (1) detection monitoring
(Module X), (2) compliance monitoring (Module XI), and (3) corrective
action [Module XII(A)].  If more than one program is included in the
Permit, the Permit Writer is to specify the circumstances or conditions
under which each program will be required.  It is possible that more than
one program will be operable at the same time at a facility, or that the
programs will be conditional based on a sequence of events.  For example,
the sequence set up in the Permit could include a detection monitoring
program that triggers an Appendix IX analysis that triggers a Permittee
option to apply for a variance (e.g., other contamination source or
sampling error) and if the Permittee fails to seek or fails to obtain a
variance, then compliance monitoring is triggered.  The Permit could also
set the ground water protection standard, with a provision for the
Permittee to apply for an Alternate Concentration Limit (ACL), and in the
absence of an ACL application or denial of an ACL, or exceedence of an
ACL or pre-set limit,  the triggering of the corrective action program.
The corrective action program could include plume assessment, corrective
measures study and design, and implementation of corrective action.
Setting up such a sequence in the Permit reduces the number of permit
modifications that may be needed and decreases the administrative time
needed to get on with subsequent steps in the process and ultimately, the
time required to get corrective action under way, if needed.]
                               XII(A)  -  1

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                                                           September 1988
[Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]

XII(A).A. MODULE HIGHLIGHTS

[The Permit Writer should include a general discussion of the activities
covered by this module.  The discussion should contain the following
information:  description of the waste management unit(s) for which
corrective action is required; number, location, and depth of monitoring
wells; which wells are upgradient and downgradient; hazardous
constituents and concentration limits; compliance period for each waste
management unit; any special features associated with the operation; and
a reference to any special permit conditions.]

XII(A).B. WELL LOCATION. INSTALLATION AND CONSTRUCTION

[Note:  For specific Agency guidance on monitoring well design and
construction, hydrogeologic site characterization and location of
monitoring wells, the Permit Writer should consult the EPA RCRA Ground-
Water Monitoring Technical Enforcement Guidance Document (September
1986).]

The Permittee shall (install and) maintain a ground-water monitoring
system to comply with the requirements specified below:  [40 CFR
264.100(d)]

     XII(A).B.I.    The Permittee shall (install and) maintain ground-
                    water monitoring wells at the locations specified on
                    the map in Permit Attachment XII(A)-1 and in
                    conformance with the following list:  [40 CFR
                    264.100(a)(3) and (d)]

                    [Note:  The Permit Writer should specify the number
                    and locations of upgradient and downgradient wells.
                    A brief description of the locations of the wells,
                    relative to the regulated units and geological
                    formations, should also be provided.  The description
                    should identify the spacing of wells and screened
                    depths (intervals).]

                    [Note:  The map must show all monitoring well
                    locations and provide unique identifiers for each
                    well.  The number and location of the wells must meet
                    the requirements of 40 CFR 264.95 (Point of
                    Compliance) and 40 CFR 264.97(a) or (b) (number,
                    location, and depth of wells).  The number and

                                XII(A)  -  2
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                                                           September 1988
                    location of monitoring wells must be sufficient to
                    identify and define all potential release pathways
                    from the regulated units based on site-specific
                    hydrogeologic characterization.  The map should make
                    a distinction among point-of-compliance wells,
                    withdrawal wells (for pump and treat systems), and
                    observation wells or piezometers.  This may include
                    the area between the point of compliance and the
                    facility boundary.]

     XII(A).B.2.    The Permittee shall (construct and) maintain the
                    monitoring wells identified in Permit Condition
                    XII(A).B.l., in accordance with the plans and
                    specifications presented in Permit Attachment XII(A)-
                    2. [40 CFR 264.100(d)]

                    [Note:  The plans and specifications contained in the
                    Part B Permit Application must meet the requirements
                    of 40 CFR 264.97(c). They should consist of design
                    drawings and design criteria applicable to all wells,
                    as well as individual well specifications identifying
                    depth, and location of screened intervals.]

[Note:  If determined to be necessary to protect human health or the
environment, the Permit Writer should include Permit Condition
XII(A).B.3., specifications on how monitoring wells are plugged and
abandoned.  HSWA Section 212 provides EPA with this authority.  Several
states also have regulations which cover monitoring well abandonment.]

     XII(A).B.3.    All wells deleted from the monitoring program shall
                    be plugged and abandoned in accordance with Permit
                    Attachment XII(A)-3.  Well plugging and abandonment
                    methods and certification shall be submitted to the
                    Regional Administrator within [The Permit Writer
                    should specify the submittal period.] from the date
                    the wells are removed from the monitoring program.

XII(A).C.  GROUND-WATER PROTECTION STANDARD

[Note:  The Permit Writer must establish concentration limits for the
constituents listed in this section, pursuant to 40 CFR 264.94(a), to
implement the ground-water protection standard.  (The concentration
limits may have been established in the Compliance Monitoring Module.)
Concentration limits for hazardous constituents are established for each
waste management area to determine the ground-water protection standard
(GWPS) at the facility.  There are four ways concentration limits can be
established to set the GWPS: (1) pooled background levels of the
hazardous constituents determined from facility ground-water monitoring;

                                XII(A)  - 3

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                                                           September 1988
(2) maximum constituent concentrations listed in Table 1, 40 CFR
264.94(a) - which is Permit Attachment G.W.I to this module; (3)
alternate concentration limits (ACLs) proposed by the Permittee; or (4)
the concentration limits may be established through sampling at
upgradient wells each time the ground water is sampled at the compliance
point, if there is a high temporal correlation.  The GWPS may be a
combination of these four methods.  For detailed information on ACLs,
consult the EPA Alternate Concentration Limit Guidance (July 1987).

     XII(A).C.I.    The Permittee shall implement a corrective action
                    program to ensure that regulated units are in
                    compliance with the ground-water protection
                    standard.  [40 CFR 264.100(d)]  The following
                    hazardous constituents and their concentration limits
                    comprise the ground-water protection standard:  [40
                    CFR 264.93 and 264.94]

                Hazardous                                Concentration
               Constituents                                  Limits
     XII(A).C.2.    The Permittee shall monitor [The Permit Writer should
                    specify the identification number(s) of the well(s)
                    to be monitored.] at the point of compliance, and
                    those wells between the point of compliance and the
                    facility boundary, as described in Permit Condition
                    XII(A).B., and as designated in Permit Attachment
                    XII(A)-2.  [40 CFR 264.95 and 264.100(d)]

     XII(A).C.3.    The Permittee shall monitor for the following
                    hazardous constituents during the compliance period.
                    [The Permit Writer should specify the compliance
                    period.]  [40 CFR 264.93]

                    [Note:  The Permit Writer should develop a list of
                    monitoring constituents to establish initial
                    monitoring requirements using the following
                    information submitted by the Permittee; waste
                    analysis plan, waste characterization, site
                    hydrogeologic characterization, Appendix IX ground-
                    water sample analyses determined from compliance
                    monitoring, proposed monitoring constituents,
                    corrective action program, and engineering
                    feasibility study.]
                                XII(A)  -  4

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                                                           September 1988
XII(A).D. CORRECTIVE ACTION PROGRAM

     XII(A).D.I.    The Permittee shall begin corrective action within
                    [The Permit Writer should specify the time period.]
                    from the time the ground-water protection standard
                    was exceeded.  [40 CFR 264.100(c)]

     XII(A).D.2.    The Permittee shall implement a corrective action
                    program that prevents hazardous constituents from
                    exceeding their respective concentration limits (as
                    required under Permit Condition XII(A).D.I.) at the
                    compliance point by removing the hazardous waste
                    constituents or by treating them in place.  [40 CFR
                    264.100(b)]

     XII(A).D.3.    The Permittee shall conduct a corrective action
                    program to remove or treat in place any hazardous
                    constituents that exceed concentration limits in
                    ground water between the compliance point and the
                    downgradient facility property boundary, in
                    accordance with the procedures specified in Permit
                    Attachment XII(A)-4..   [40 CFR 264.100(e)]

                    [Note:  The Permit Writer must specify the corrective
                    action measures to be taken and the schedule in which
                    these measures are to be taken.  The corrective
                    action program and engineering feasibility study
                    submitted by the Permittee should contain all
                    appropriate measures to ensure that ground-water
                    quality will achieve compliance in a reasonable time
                    period.  The Permit Writer may want to utilize the
                    corrective action program (and the engineering
                    feasibility study) as an Attachment(s).   The
                    corrective action measures must be Initiated and
                    completed within a reasonable period of time and may
                    be terminated once the concentrations of hazardous
                    constituents are reduced to levels below their
                    respective concentration limits, as specified in
                    Permit Condition XII(A).C.] [40 CFR 264.100(f)]

     XII(A).D.4.    If the ground-water protection standard is met during
                    the compliance period, the Permittee shall continue
                    corrective action to the extent necessary to ensure
                    that the ground-water protection standard is not
                    exceeded.   If corrective action is required beyond
                    the compliance period, it must continue until the
                               XII(A)  -  5

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                                                           September 1988
                    ground-water protection standard has not been
                    exceeded for three consecutive years. [40 CFR
                    264.100(f)]

XII(A).E. SAMPLING AND ANALYSIS PROCEDURES

The Permittee shall use the following techniques and procedures when
obtaining and analyzing samples from the ground-water monitoring wells
described in Permit Condition XII(A).B.:  [40 CFR 264.97(d) and (e)]

     XII(A).E.I.    Samples shall be collected by the techniques
                    described in Permit Attachment XII(A)-5.

     XII(A).E.2.    Samples shall be preserved [and shipped (when shipped
                    off site for analysis)], in accordance with the
                    procedures specified in Permit Attachment XII(A)-5.

     XII(A).E.3.    Samples shall be analyzed according to the procedures
                    specified in Permit Attachment XII(A)-5.

     XII(A).E.4.    Samples shall be tracked and controlled using the
                    chain-of-custody procedures specified in Permit
                    Attachment XII(A)-5.

                    [Note:  The sampling and analytical procedures
                    described in the Part B Permit Application must be
                    designed to provide a reliable indication of the
                    quality of the ground water below the facility, as
                    required by 40 CFR 264.97(d) and (e), and be
                    compatible with the statistical analysis method.]

XII(A).F. GROUND-WATER SURFACE ELEVATION

     XII(A).F.I.    The Permittee shall determine the ground-water
                    surface elevation at each well each time ground water
                    is sampled, in accordance with Permit Condition
                    XII(A).H.  [40 CFR 264.97(f)]

     [Note:  The Permit Writer should include Permit Condition
     XII(A).F.2. if new monitoring wells are installed.  The surveyed
     ground surface elevation of all existing monitoring wells is
     required on the facility map in the Part B Permit Application.]

     XII(A).F.2.    The Permittee shall report the surveyed elevation of
                    the monitoring well(s) when the well(s) is (are)
                    installed.  [Note: The total depth of wells and the
                               XII(A)  -  6
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                                                           September 1988
                    elevation of the following should be reported: top of
                    casing, ground surface and/or apron elevation, and
                    the protective casing.]

XII(A).G. STATISTICAL PROCEDURES

[Note:  40 CFR 264 Subpart F regulations were undergoing revisions at the
time this permit module was prepared.  The new regulations will specify
six performance standards that the statistical method and sampling
procedures must meet.  The statistical procedures in this permit module
are based on 40 CFR 264 Subpart F, July 1, 1987.]

When evaluating the monitoring results to determine the effects of
corrective action measures, in accordance with Permit Condition
XII(A).H., the Permittee shall use the following procedures:

[Note:  The Permittee must use a procedure for determining whether a
statistically significant change has occurred.  The procedure must
reasonably balance the probability of falsely identifying a non-
contaminating regulated unit and the probability of failing to identify a
contaminating regulated unit.]

The Permittee shall conduct the statistical procedures as presented in
Permit Attachment XII(A)-6.

XII(A).H. MONITORING PROGRAM AND DATA EVALUATION

The Permittee shall establish and implement a ground-water monitoring
program to demonstrate the effectiveness of the corrective action
program.  Ground-water monitoring shall be conducted and shall be as
effective as the program for compliance monitoring under 40 CFR 264.97
and 40 CFR 264.99.  The Permittee shall determine ground-water quality as
follows:

     XII(A).H.l.    The Permittee shall collect, preserve and analyze
                    samples in accordance with Permit Condition XII(A).E.

     XII(A).H.2.    The Permittee shall determine the concentrations of
                    the hazardous constituents specified in Permit
                    Condition XII(A).C., throughout the compliance period
                    and any extensions due to corrective action
                    implementation, to demonstrate conformance with the
                    ground-water protection standard. [40 CFR 264.96]
                    The Permittee shall determine the concentration of
                    hazardous constituents in ground water at each
                    monitoring well at the compliance point, at least
                    quarterly.  [40 CFR 264.100(d)]
                               XII(A)  -  7

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                                                           September 1988
                    [Note:   The Permit Writer may specify more frequent
                    monitoring, if necessary.]

     XII(A).H.3.     The Permittee shall analyze samples from all
                    monitoring wells at the compliance point for all
                    constituents contained in 40 CFR 261, Appendix IX
                    [Note:   The frequency to be specified must be at
                    least annually.], to determine if additional
                    hazardous constituents are present in the uppermost
                    aquifer.   If the Permittee finds additional hazardous
                    constituents present (i.e., not listed in Permit
                    Condition XII(A).C.), their concentrations shall be
                    reported to the Regional Administrator in writing
                    within seven days from completion of the analysis.

     XII(A).H.4.     The Permittee shall determine the ground-water flow
                    rate and direction in the uppermost aquifer at least
                    annually.  [40 CFR 264.98(e)]

     XII(A).H.5.     The Permittee shall statistically compare the
                    measured concentration of each monitored hazardous
                    constituent with its concentration limit in the
                    ground-water protection standard each time ground-
                    water quality is determined, in accordance with
                    Permit Condition XII(A).H.2.  The Permittee must
                    compare the ground-water quality measured at each
                    point of the compliance monitoring well and any other
                    specified wells, as stated in Permit Condition
                    XII(A).C. and in accordance with the procedures
                    specified in Permit Condition XII(A).G.

XII(A).I. RECORDKEEPING AND REPORTING

     XII(A).I.I.     The Permittee shall enter all monitoring, testing and
                    analytical data obtained, according to Permit
                    Condition XII(A).H.2., in the operating record.  The
                    data must include all computations, calculated means,
                    variances, and results of the statistical test(s)
                    that the Regional Administrator has specified.  [40
                    CFR 264.73(b)(6)]

     XII(A).I.2.     The Permittee shall report, in writing, semi-annually
                    to the Regional Administrator on the effectiveness of
                    the corrective action program.  These reports shall
                    be submitted on  [April 1 and October 1, for example]
                    of each year until the corrective action program has
                    been completed.  [40 CFR 264.100(g)]
                                XII(A)  -  8

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                                                           September 1988
                    [Note:  The regulations do not require the Permittee
                    to routinely submit all the ground-water sampling
                    analytical results, statistical evaluations or
                    results of the annual determination of the ground-
                    water flow rate and direction.  Such information is
                    required to be submitted when there are significant
                    changes in hazardous constituent concentrations or
                    there are significant changes in the ground-water
                    flow rate or direction which negate or adversely
                    alter the monitoring system effectiveness.  The
                    Permit Writer may require this "routine" information.
                    Include Permit Condition XII(A).I.3. if the facility
                    is to submit the information on a regular basis.]

     XII(A).I.3.    The Permittee shall submit the analytical results
                    required by Permit Conditions XII(A).F., XII(A).H.2.,
                    XII(A).H.3., XII(A).H.4., and XII(A).H.5., in
                    accordance with the following schedule:

                    [Note:  The Permit Writer should specify the report
                    schedule for ground-water sampling, the statistical
                    evaluation of ground-water sampling results, and the
                    determination of the ground-water flow rate and
                    direction.

                    Example of a Quarterly Ground-Water Report Schedule:

               Samples to be Collected
               During the Preceding               Results Due to
               	Months  of	    the Regional Administrator By

                    January - February                 April 15
                    April - May                        July 15
                    July - August                      October 15
                    October - November                 January 15]

XII(A).J.  REQUEST FOR PERMIT MODIFICATION

If the Permittee or the Regional Administrator determines that the
corrective action program established by this Permit no longer satisfies
the regulatory requirements, then the Permittee must submit an
application for a permit modification within 90 days to make any
appropriate changes to the program. [40 CFR 264.100(h)]
                               XII(A)  -  9

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                                                           September 1988
    PERMIT ATTACHMENTS REFERENCED IN MODULE XII(A)  - CORRECTIVE ACTION
                           FOR REGULATED UNITS

This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.  The  Permit Writer may select
other numbering schemes, as appropriate, when preparing actual Permits.
Permit Attachment No.              	Plan or Document	
                                   (from the Part B Permit Application)

G.W.I                              Maximum Concentration of Constituents
                                   for Ground-Water Protection

XII(A)-1                           Facility Map depicting the monitoring
                                   well locations and regulated units

XII(A)-2                           Plans and specifications for
                                   monitoring well construction,
                                   installation and maintenance

XII(A)-3                           Methodology for Monitoring Well
                                   Abandonment

XII(A)-4                           Corrective Action Program

XII(A)-5                           Sampling and Analysis Plan

XII(A)-6                           Statistical Procedures
                               XII(A) - 10

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                                                           September 1988
                            ATTACHMENT G.W.I
        (to Module XII(A)  -  Corrective Action  for Regulated Units)

                Maximum Concentration of Constituents for
                         Ground-Water Protection
Constituent                        Maximum concentration
                                   (Milligrams per liter)

Arsenic                                      0.05
Barium                                       1.0
Cadmium                                      0.01
Chromium                                     0.05
Lead                                         0.05
Mercury                                      0.002
Selenium                                     0.01
Silver                                       0.05
Endrin (1,2,3,4,10,10-
  hexachloro-1,7-epoxy-1,4,
  4a,5,6,7,8,9a-octahydro-l,
  4-endo, endo-5,8-dimethano
  naphthalene)                               0.0002
Lindane (1,2,3,4,5,6-
  hexachlorocyclohexane,
  gamma isomer)                              0.004
Methoxychlor (1,1. '. -
  Trichloro-2,2-bis (p-
  methoxyphenylethane)                       0.1
Toxaphene (C10HioCl6,
  Technical chlorinated
  camphene, 67-69 percent
  chlorine)                                  0.005
2,4-D (2,4-Dichlorophenoxyacetic
  acid)                                      0.1
2,4,5-TP Silvex (2,4,5-
  Trichlorophenoxypropionic
  acid)                                      0.01
     Source:   40 CFR 264.94, Table 1,  July 1987.


                               XII(A)  -  11

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                                                           September 1988
MODULE XII(B) - CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS
[This Module is currently being revised and will be distributed
wben redrafted.]
                               XII(B)  - 1

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                                                           September 1988
                        MODULE XIII  -  POST-CLOSURE CARE
 [Note:  Include this permit module in all permits for landfills, surface
 impoundments, and land treatment units used for the disposal of hazardous
waste.  In addition, this module should be used for contingent post-
 closure care of surface impoundments, waste piles, and tank systems, used
 for storing or treating hazardous waste, that will be closed as landfills
because clean-closure could not be accomplished.]

 [Note:  This module should also be used for Post-Closure Permits.  Post-
 Closure Permits are required under 40 CFR 270.l(c) for "any unit which
 closes after January 26, 1983," i.e., for closing interim status
 facilities.  Relevant conditions from the other modules also need to be
 included in the permit (see discussion in the Model Permit
 introduction).]

 [Note:  The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions.  See discussion of the RCRA Permit Quality Protocol in the
 Introduction to this Model Permit.]

XIII.A.   MODULE HIGHLIGHTS

 [The Permit Writer should include a general discussion of the activities
covered by this module.  The discussion should contain the following
 information for each unit or group of units: types of wastes disposed in
 the unit; anticipated date of closure and the length of post-closure care
 for each unit; planned monitoring and maintenance activities; any special
 features associated with the post-closure care operation; and a reference
to any special permit conditions.]

XIII.B.   UNIT IDENTIFICATION

The Permittee shall provide post-closure care for the following hazardous
waste management units, subject to the terms and conditions of this
permit, and as described as follows:

Type of      Unit No.       Maximum     Description
 Waste        or Other       Waste       of Wastes        Hazardous
 Unit       Designation    Inventory     Contained         Waste No.

 [Example:
 Landfill    Cells 1       1,000 yd3     Dust from          K061
            through 9                    steel furnace
                                         Lead smelting
                                         dust               K069]
                                XIII  -  1

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                                                           September 1988
[Note:  If the number of hazardous wastes in the unit(s) subject to post-
closure care is large, the Permit Writer should use a separate attachment
(Permit Attachment XIII-1) to list the wastes,  in lieu of listing them
all directly in Permit Condition XIII.B.]

XIII.C.   POST-CLOSURE PROCEDURES AND USE OF PROPERTY

     XIII.C.I.      The Permittee shall conduct post-closure care for
                    each hazardous waste management unit listed in Permit
                    Condition XIII.B. above, to begin after completion of
                    closure of the unit and continue for 30 years after
                    that date, except that the 30-year post-closure care
                    period may be shortened upon application and
                    demonstration approved by EPA that the facility is
                    secure, or may be extended by EPA if the Regional
                    Administrator finds this is necessary to protect
                    human health and the environment.   [40 CFR
                    264.117(a)]

                    [Note:  The Regional Administrator may shorten the
                    post-closure care period if he finds that human
                    health and the environment will be protected
                    sufficiently.  This could be determined through, for
                    example, leachate or groundwater monitoring results,
                    inherent characteristics of the hazardous wastes,
                    application of treatment or other control technology
                    that indicate that the hazardous waste management
                    unit or facility is secure.] [40 CFR
                    264.117(a)(2)(i)]

                    [Note:  The Regional Administrator may extend the
                    post-closure care period if he finds that this is
                    necessary to protect human health or the
                    environment.  A basis for this determination could be
                    leachate or groundwater monitoring results that
                    indicate a potential for migration of hazardous
                    wastes at levels which may be harmful to human health
                    and the environment.]   [40 CFR 264.117(a)(2)(ii)]

                    [Note:  The length of the post-closure care period
                    may be set in the original permit,  in which case it
                    should be justified in the Administrative Record; or
                    may be shortened or extended upon a permit
                    modification.]

     XIII.C.2.      The Permittee shall maintain and monitor the ground-
                    water monitoring system and comply with all other
                    applicable requirements of 40 CFR Part 264 Subpart F
                    during the post-closure period.   [40 CFR

                                 XIII -  2

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                                                      September 1988
               264.Ill(a)(1)]  [The Permit Writer should refer to and
               use, as appropriate, Modules X, XI, and XII(A) in
               developing conditions to satisfy the Subpart F
               requirements.]

[Note:  The Permit Writer should include Permit Conditions
XIII.C.3., XIII.C.4., and/or XIII.C.5., depending on the type of
disposal units covered by the permit.  Permit Condition XIII.C.5.
should be used for surface  impoundments, waste piles, and tank
systems used for storing or treating hazardous waste that cannot be
clean-closed and must be closed as landfills.]

XIII.C.3.      The Permittee shall comply with the requirements for
               surface impoundments as follows:  [40 CFR
               264.228(b)(l) and (3)]

     XIII.C.3.a.    Maintain the integrity and effectiveness of the
                    final cover, including making repairs to the
                    cap, as necessary, to correct the effects of
                    settling,  subsidence, erosion, and other events;
                    and

     XIII.C.3.b.    Prevent run-on and run-off from eroding or
                    otherwise  damaging the final cover.

XIII.C.4.      The Permittee shall comply with the requirements for
               land treatment units as follows:  [40 CFR 264.280(c)]

     XIII.C.4.a.    Continue all operations (including pH control)
                    necessary to enhance degradation and
                    transformation and sustain immobilization of
                    hazardous  constituents in the treatment zone to
                    the extent that such measures are consistent
                    with other post-closure care activities;

     XIII.C.4.b.    Maintain a vegetative cover over closed portions
                    of the facility;

     XIII.C.4.c.    Maintain the run-on control system required
                    under 40 CFR 264.273(c);  and

     XIII.C.4.d.    Maintain the run-off management system required
                    under 40 CFR 264.273(d).

     [Note:  The Permit Writer should also include Permit Conditions
     XIII.C.4.e., XIII.C.4.f., and/or XIII.C.4.g., if applicable.]

     XIII.C.4.e.    Control wind dispersal of hazardous waste as
                    required under 40 CFR 264.273(f).

                            XIII  -  3

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                                                      September 1988
     XIII.C.4.f.    Continue to comply with any prohibitions or
                    conditions concerning growth of food-chain crops
                    required under 40 CFR 264.276.

     XIII.C.4.g.    Continue unsaturated zone monitoring required
                    under 40 CFR 264.278.

                    [Note:  The Permittee may terminate soil-pore
                    liquid monitoring 90 days after the last
                    application of waste to the treatment zone.]
                    [40 CFR 264.280(c)(7)]

XIII.C.5.      The Permittee shall comply with the requirements for
               landfills, as follows:  [40 CFR 264.310(b)]

     XIII.C.5.a.    Maintain the integrity and effectiveness of the
                    final cover, including making repairs to the
                    cap, as necessary, to correct the effects of
                    settling, subsidence, erosion,  or other events;

     XIII.C.5.b.    Continue to operate the leachate collection and
                    removal system until leachate is no longer
                    detected;

     XIII.C.5.c.    Maintain and monitor the ground-water monitoring
                    system and comply with all other applicable
                    requirements of 40 CFR Subpart F;

     XIII.C.5.d.    Prevent run-on and run-off from eroding or
                    otherwise damaging the final cover; and

     XIII.C.5.e.    Protect and maintain surveyed benchmarks used in
                    complying with the surveying and recordkeeping
                    requirements of 40 CFR 264.309.

 [Note:  The Permit Writer should include Permit Condition XIII.C.6.
 if he determines that the Permittee must continue to comply with any
 of the security requirements of 40 CFR 264.14 during part or all of
 the post-closure period.  The condition should be included when
 hazardous waste may remain exposed after completion of partial or
 final closure; or access by the public or domestic livestock may
 pose a hazard to human health.]

 XIII.C.6.      The Permittee shall comply with all security
               requirements, as specified in Permit Attachment XIII-
               2.  [40 CFR 264.117(b)]

 XIII.C.7.      The Permittee shall not allow any use of the units
               designated in Permit Condition XIII.B. which will

                            XIII -  4

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     XIII.C.8.
                                                           September 1988
          disturb the integrity of the final cover, liners, any
          components of the containment system, or the function
          of the facility's monitoring systems during the
          post-closure care period.  [40 CFR 264.117(c)]

          [Note:  The Regional Administrator may allow a
          variance to this condition if a disturbance is
          necessary to the proposed use of the property and
          will not increase the potential hazard to human
          health or the environment, or is necessary to reduce
          a threat to human health and or the environment.]
          [40 CFR 264.117(c)(l) and (2)]

          The Permittee shall implement the Post-Closure Plan,
          Permit Attachment 11-11.  All post-closure care
          activities must be conducted in accordance with the
          provisions of the Post-Closure Plan.  [40 CFR
          264.117(d) and 264.118(b)]
XIII.D.
INSPECTIONS
The Permittee shall inspect the components, structures, and equipment at
the site in accordance with the Inspection Schedule, Permit Attachment
II-3.  [40 CFR 264.117(a)(l)(ii)]
XIII.E.
NOTICES AND CERTIFICATION
     XIII.E.I.      No later than 60 days after certification of closure
                    of each permitted hazardous waste disposal unit, the
                    Permittee shall submit to the local zoning authority,
                    or the authority with jurisdiction over local land
                    use, and to the Regional Administrator a record of
                    the type, location, and quantity of hazardous wastes
                    disposed of within each cell or other disposal unit
                    of the facility.  For hazardous wastes disposed of
                    before January 12, 1981, the Permittee shall identify
                    the type, location, and quantity of the hazardous
                    wastes to the best of his knowledge and in accordance
                    with any records he has kept.  [40 CFR 264.119(a)]

     XIII.E.2.      Within 60 days of certification of closure of the
                    first and the last hazardous waste disposal unit, the
                    Permittee shall:

          XIII.E.2.a.     Record, in accordance with 	 (Permit
                         Writer should insert state name) law, a notation
                         on the deed to the facility property -- or on
                         some other instrument that is normally examined
                         during the title search -- that will in

                                XIII  - 5

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                                                      September 1988
                    perpetuity notify any  potential  purchaser of the
                    property that:

                    (i)        The land has been used to manage
                              hazardous wastes;

                    (ii)       Its use is restricted  under 40 CFR
                              Part 264 Subpart G regulations; and

                    (iii)      The survey plat and record of the
                              type,  location,  and quantity of
                              hazardous wastes disposed of within
                              each cell or other hazardous waste
                              disposal unit of the facility have
                              been filed with the Regional
                              Administrator and 	 (Permit
                              Writer should insert name of local
                              zoning authority or the authority with
                              jurisdiction over local land use).

     XIII.E.2.b.     Submit a certification to the Regional
                    Administrator,  signed by the Permittee, that he
                    has  recorded the notation specified in Permit
                    Condition XIII.E.2.a., including a copy of the
                    document in which the notation has been placed.
                    [40  CFR 264.119(b)]

XIII.E.3.      If the Permittee or any subsequent owner or operator
               of the land upon which the hazardous  waste disposal
               unit is located, wishes to remove hazardous wastes
               and hazardous waste residues, the liner, if any; or
               contaminated soils,  then he shall request a
               modification to this post closure permit in
               accordance  with the applicable requirements in 40 CFR
               Parts 124 and 270.  The Permittee or any subsequent
               owner or  operator of the land shall demonstrate that
               the removal of hazardous wastes will satisfy the
               criteria  of 40 CFR 264.117(c).   [40 CFR 264.119(c)]

               [Note:  By removing hazardous waste,  the Permittee
               may become  a generator of hazardous waste and must
               manage it in accordance with all applicable RCRA
               requirements.  If he is granted a permit modification
               or otherwise granted approval to conduct such removal
               activities, the Permittee may request that the
               Regional  Administrator approve either:
                           XIII  -  6

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ft
                                                                          September 1988
                    a.   The removal of the notation on the deed to the
                         facility property or other instrument normally
                         examined during title search or

                    b.   The addition of a notation to the deed or
                         instrument indicating the removal of the
                         hazardous waste.]

     XIII.E.4.      No later than 60 days after completion of the
                    established post-closure care period for each
                    hazardous waste disposal unit, the Permittee shall
                    submit to the Regional Administrator,  by registered
                    mail, a certification that the post-closure care for
                    the hazardous waste disposal unit was  performed in
                    accordance with the specifications in the approved
                    Post-Closure Plan.   The certification must be signed
                    by the Permittee and an independent,  registered
                    professional engineer.  Documentation supporting the
                    independent, registered professional engineer's
                    certification must be furnished to tHe Regional
                    Administrator upon request until the Regional
                    Administrator releases the Permittee from the
                    financial assurance requirements for post-closure
                    care under 40 CFR 264.145(1).  [40 CFR 264.120]

XIII.F.   FINANCIAL ASSURANCE

     XIII.F.I.      The Permittee shall maintain financial assurance
                    during the post-closure period and comply with all
                    applicable requirements of 40 CFR Part 264 Subpart H.
                    [40 CFR 264.145]

     [Note:  The Permit Writer should include conditions that cover the
     procedures the Permittee must follow to be released from financial
     assurance or to be reimbursed for post-closure care.   The procedures
     will vary according to the type of financial assurance mechanism
     used.  Permit Conditions XIII.F.2. and XIII.F.3. are sample
     conditions for cases where a post-closure trust fund is used.]

     XIII.F.2.      The Permittee shall demonstrate to the Regional
                    Administrator that the value of the financial
                    assurance mechanism exceeds the remaining cost of
                    post-closure care,  in order for the Regional
                    Administrator to approve a release of funds.  [40 CFR
                    264.145(a)(10)]

     XIII.F.3.      The Permittee (or any other person authorized to
                    conduct post-closure care) shall submit itemized
                    bills to the Regional Administrator when requesting

                                XIII -  7

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                                                           September 1988
                    reimbursement for post-closure care.   [40 CFR
                    264.145(a)(ll)]

XIII.G.   POST-CLOSURE PERMIT MODIFICATIONS

The Permittee must request a permit modification to authorize a change in
the approved Post-Closure Plan.  This request must be in accordance with
applicable requirements of 40 CFR Parts 124 and 270, and must include a
copy of the proposed amended Post-Closure Plan for approval by the
Regional Administrator.  The Permittee shall request a permit
modification whenever changes in operating plans or facility design
affect the approved Post-Closure Plan, there is a change in the expected
year of final closure, or other events occur during the active life of
the facility that affect the approved Post-Closure Plan.   The Permittee
must submit a written request for a permit modification at least 60 days
prior to the proposed change in facility design or operation, or no later
than 60 days after an unexpected event has occurred which has affected
the Post-Closure Plan.  [40 CFR 264.118(d)]

[Note:  The wording of this Permit Condition should be altered for post-
closure permits (i.e., the references to expected year of final closure
and events during the active life), and checked against the forthcoming
rule amendments regarding permit modifications.]
                                 XIII  -

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                                                           September 1988
     PERMIT ATTACHMENTS REFERENCED  IN MODULE XIII  -  POST-CLOSURE  CARE
This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions.  The Permit Writer may select
other numbering schemes, as appropriate,  when preparing actual permits.

Permit Attachment No.              	Plan or Document	
                                   (from the Part B Permit Application)

  II-3                             Facility Inspection Schedule

  11-11                            Post-Closure Plan

  XIII-1                           List of Wastes Contained in
                                   the Units Under Post-Closure
                                   Care

  XIII-2                           Security Procedures During
                                   the Post-Closure Period
                                XIII  - 9

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                                                           September 1988
                  A. SUMMARY LIST OF PERMIT ATTACHMENTS
                    FROM  PERMIT MODULES  I THROUGH XIII
MODULE NO.
Module I
ATTACHMENT NO.
     None
           PLAN OR DOCUMENT
                                   (most of these are from the Part B
                                    Permit Application)
Module II
     II-l

     II-2

     II-3

     II-4

     II-5


     II-6


     II-7

     11-8

     I1-8A


     II-9

     11-10

     11-11

     11-12

     11-13

     11-14
Waste Analysis Plan

Security Plan

Inspection Schedule

Personnel Training Outline

Procedures for Handling Ignitable,
Reactive, or Incompatible Waste

Flood Proofing/Flood Protection Plans
and Specifications

100-Year Flood Response Procedures

Contingency Plan

Plans and Specifications Showing the
Spacing of Aisles

Closure Plan

Contingent Closure Plan

Post-Closure Plan

Contingent Post-Closure Plan

Closure Cost Estimate

Post-Closure Cost Estimate
Module III
     III-l
Secondary Containment Plans and
Specifications
                                  A - 1

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MODULE NO.     ATTACHMENT NO.
                                       September 1988

                          PLAN OR DOCUMENT	
Module III
(cont'd)
III-2
                    III-3
Ignitable or Reactive Waste
Procedures

Incompatible Waste Procedures
Module IV
IV-1



IV-2



IV-3

IV-4



IV-5


IV-6
Plans and Reports to Support a
Variance From the Requirements for
Secondary Containment

Detailed Plans and Other Information
Describing Secondary Containment
Systems

Procedures for Conducting Leak Tests

Procedures for Preventing Spills and
Overflows From the Tanks or
Containment Systems

Procedures for Handling Ignitable or
Reactive Waste

Procedures for Handling Incompatible
Wastes
Module V
V-l
                    V-2
                    V-3
                    V-4
                    V-5
Design Plans and Reports for
Installing Liners and Leachate
Collection and Removal System and
Operating the LCRS (or for an
alternative design) (or for a monofill
where the Agency has waived the double
liner requirement)

Design Plans and Operating Practices
to Prevent Overtopping

Design Plans and Operating Practices
to Prevent Massive Failure of the
Dikes

Plans and Procedures for Leachate
Management

Schedules for Submitting Required
Exemption Information
                                  A - 2

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MODULE NO.
ATTACHMENT NO.
                        September 1988

           PLAN OR DOCUMENT	
Module V
(cont'd)
     V-6
                    V-7
                    V-8
                    V-9
Procedures for Managing Ignitable or
Reactive Wastes

Procedures for Managing Incompatible
Wastes

Waste Management Plan for Special "F"
Wastes

Schedule for Submitting Progress
Reports on Developing Alternatives for
Handling Land-Banned Wastes
Module VI
     VI-1
                    VI-2
                    VI-3
                    VI-4
                    VI-5
                    VI-6
                    VI-7
                    VI-8
                    VI-9
Design Plans and Specifications for
Installing a Liner

Design Plans and Specifications, and
Operating Practices for Installing and
Operating a Leachate Collection System

Design Plans and Specifications, and
Operating Practices for Installing and
Operating a Run-On Control System

Design Plans and Specifications, and
Operating Practices for Installing and
Operating a Run-Off Management System

Design Plans and Specifications, and
Operating Practices for Managing Run-
On and Run-Off

Procedures for Controlling Wind
Dispersal

Design Plans, Specifications and
Operating Practices for a Waste Pile
Inside or Under a Structure

Design Plans, Specifications and
Operating Practices for Exemptions to
40 CFR 264.251(a).

Ignitable and Reactive Waste
Management Plan
                                  A - 3

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MODULE NO.
ATTACHMENT NO.
                        September 1988

           PLAN OR DOCUMENT
Module VI
(cont'd)
     VI-10


     VI-11

     VI-12
Incompatible Waste Management Plan
                                   Special "F" Waste Management Plan

                                   Schedule for Submitting Progress
                                   Reports on Developing Alternatives for
                                   Handling "Banned" Waste(s)
Module VII (A~)
     VII(A)-1       Land Treatment Program

     VII(A)-2       Design Plans and Specifications

     VII(A)-3       Treatment Zone Run-Off Control Plans
                    and Specifications

     VII(A)-4       Run-On Control System Plans and
                    Specifications

     VII(A)-5       Run-Off Management System Plans and
                    Specifications

     VII(A)-6       Run-On And Run-Off Collection and
                    Holding Facilities Design Plans and
                    Operating Practices

     VII(A)-7       Wind Dispersal Control Program

     VII(A)-8       Unsaturated Zone Monitoring System

     VII(A)-9       Soil Monitoring and Soil-Pore Liquid
                    Monitoring Procedures

     VII(A)-10      Sampling and Analysis Procedures

     VII(A)-11      Statistical Procedures

     VII(A)-12      Food-Chain Crops Plans and Procedures

     VII(A)-13      Ignitable or Reactive Waste Plans and
                    Procedures

     VII(A)-14      Incompatible Waste Management Plan

     VII(A)-15      Special "F" Waste Management Plan
                                  A - 4

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              MODULE NO.     ATTACHMENT NO.
                                       September 1988

                          PLAN OR DOCUMENT	
              Module VII (A1)
              (cont'd)
              Module VII
VII(A)-16      Schedule for Submitting Progress
               Reports on Developing Alternatives for
               Handling "Banned" Waste(s)

VII(B)-1       Plans and Specifications for the Land
               Treatment Demonstration

VII(B)-2       Testing, Analytical Procedures and
               Data Sources
              Module VIII
VIII-1
                                  VHI-l(a)
                                  VIII-1
                                  (monofill
                                  alternative)

                                  VIII-2
                                  VIII-3


                                  VIII-4


                                  VIII-5



                                  VIII-6

                                  VIII-7


                                  VIII-8

                                  VIII-9
Design Plans and Operating Practices
for Liners and Leachate Collection and
Removal Systems

Alternative Design Plans and Operating
Practices for Liners and Leachate
Collection and Removal Systems

Design Plans and Operating Practices
for a Monofill
               Design Plans and Operating Practices
               for the Leachate Collection, Removal,
               and Management System

               Design Plans and Operating Practices
               for the Run-On Control System

               Design Plans and Operating Practices
               for the Run-Off Management System

               Design Plans and Operating Practices
               for the Run-On and Run-Off Collection
               and Holding Facilities

               Wind Disposal Control System

               Ignitable and Reactive Waste
               Management Plan

               Incompatible Waste Management Plan

               Special "F" Waste Management Plan
I
                                                A - 5

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MODULE NCK     ATTACHMENT NO.
                                       September 1988

                          PLAN OR DOCUMENT	
Module VIII
(cont'd)
VIII-10
                    VIII-11
Schedule for Submitting Progress
Reports on Developing Alternatives for
Handling Land-Banned Wastes

Plans and Procedures for the Disposal
of Small Containers (Lab Packs) of
Hazardous Waste
Module IXCA)
                    IX(A)-2


                    IX(A)-3


                    IX(A)-4


                    IX(A)-5

                    IX(A)-6


                    IX(A)-7
               List of Allowable Wastes

               Design Plans and Specifications, and
               Maintenance Procedures

               Description of Allowable Variations in
               System Design

               Description of Procedures for
               Controlling Fugitive Emissions

               Description of Monitoring Systems

               Description of Automatic Waste Feed
               Cut-Off Systems

               Description of Manual Waste Feed Cut-
               Off Systems
Module IX(B")
                    IX(B)-2

                    IX(B)-3


                    IX(B)-4


                    IX(B)-5
               Description of Procedures for
               Controlling Fugitive Emissions

               Description of Monitoring Systems

               Description of Automatic Waste Feed
               Cut-Off Systems

               Description of Manual Waste Feed Cut-
               Off Systems

               Trial Burn Plan
Module X
G.W.I
                    G.W.2
Maximum Concentration of Constituents
for Ground-Water Protection

Cochrans Approximation to the Behrens-
Fisher Student's T-Test
                                  A -

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MODULE NO.     ATTACHMENT NO.
                                       September 1988

                          PLAN OR DOCUMENT	
Module X
X-l


X-2



X-3


X-4

X-5
Facility Map Depicting the Monitoring
Well Locations and Regulated Units

Plans and Specifications for
Monitoring Well Construction,
Installation and Maintenance

Methodology for Monitoring Well
Abandonment

Sampling and Analysis Plan

Alternative Statistical Procedures
Module XI
G.W.I


XI-1


XI-2



XI-3


XI-4

XI-5
Maximum Concentration of Constituents
for Ground-Water Protection

Facility Map depicting Ground-Water
Monitoring Wells and Regulated Units

Plans and Specifications for
Monitoring Well Construction,
Installation and Maintenance

Methodology for Monitoring Well
Abandonment

Sampling and Analysis Plan

Statistical Procedures
Module XII(A)
G.W.I          Maximum Concentration of Constituents
               for Ground-Water Protection

XII(A)-1       Facility Map Depicting the Monitoring
               Well Locations and Regulated Units

XII(A)-2       Plans and Specifications for
               Monitoring Well Construction,
               Installation and Maintenance

XII(A)-3       Methodology for Monitoring Well
               Abandonment
                                  A - 7

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                                                           September 1988

MODULE NO.     ATTACHMENT NO.      	PLAN OR DOCUMENT	
Module XII(A)       XII(A)-4       Corrective Action Program
(cont'd)
                    XII(A)-5       Sampling and Analysis Plan

                    XII(A)-6       Statistical Procedures
Module XIII         XIII-1         List of Wastes Contained in the Units
                                   Under Post-Closure Care

                    XIII-2         Security Procedures During the Post-
                                   Closure Period
                                                                               I
                                  A - 8

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