n^R Policy Directive j;9<+76.00-5
RCRA GUIDANCE MANUAL
FOR
SUBPART G CLOSURE AND
POST-CLOSURE CARE STANDARDS AND
SUBPART H COST ESTIMATING REQUIREMENTS
Prepared by
ICF Incorporated
for
Permits Branch, Office of Solid Waste
U.S. Environmental Protection Agency
EPA/530-SW-87-010
January 1987
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OSUTR Policy Directive #9476.00-5
RCRA GUIDANCE MANUAL
FOR
SUBPART G CLOSURE AND
POST-CLOSURE CARE STANDARDS AND
SUBPART H COST ESTIMATING REQUIREMENTS
Prepared by
ICF Incorporated
for
Permits Branch, Office of Solid Waste
U.S. Environmental Protection Agency
EPA/530-SW-87-010
January 1987
-------
OSWTR Policy Directive
#9476.00-5
TABLE OF CONTENTS
Page
CHAPTER 1. INTRODUCTION 1-1
1.1 SUMMARY OF CLOSURE/POST-CLOSURE CARE REQUIREMENTS 1-2
1.2 ORGANIZATION AND USE OF MANUAL 1-3
CHAPTER 2. CLOSURE AND POST-CLOSURE CARE REQUIREMENTS 2-1
2.1 APPLICABILITY OF CLOSURE AN'D POST-CLOSURE CARE REGULATIONS ... 2-1
2.1.1 Applicability of Closure Regulations 2-1
2.1.2 Applicability of Post-Closure Care Regulations 2-4
2.1.3 Units Subject to Contingent Plan Requirements 2-5
2.2 CLOSURE REQUIREMENTS TO BE ADDRESSED IN THE CLOSURE PLAN 2-5
2.2.1 Facility Description 2-7
2.2.2 Partial Closure 2-9
2.2.3 Maximum Extent of Operations 2-10
2.2.4 Management of Maximum Inventory 2-10
2.2.5 Facility Decontamination 2-13
2.2.6 Final Cover 2-16
2.2.7 Ground-Water Monitoring 2-17
2.2.8 Ancillary Closure Activities 2-18
2.2.9 Survey Plat 2-21
2.2.10 Closure Certification 2-21
2.2.11 Partial and Final Closure Schedule 2-22
2.3 POST-CLOSURE CARE REQUIREMENTS TO BE ADDRESSED IN THE
POST-CLOSURE PLAN 2-23
2.3.1 Scope of Post-Closure Care Activities 2-25
2.3.2 Considerations Affecting the Length of the Post-
Closure Care Period 2-32
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TABLE OF CONTENTS
Page
CHAPTER 1. INTRODUCTION 1-1
1.1 SUMMARY OF CLOSURE/POST-CLOSURE CARE REQUIREMENTS 1-2
1.2 ORGANIZATION AND USE OF MANUAL 1-3
CHAPTER 2. CLOSURE AND POST-CLOSURE CARE REQUIREMENTS 2-1
2.1 APPLICABILITY OF CLOSURE AND POST-CLOSURE CARE REGULATIONS ... 2-1
2.1.1 Applicability of Closure Regulations 2-1
2.1.2 Applicability of Post-Closure Care Regulations 2-4
2.1.3 Units Subject to Contingent Plan Requirements 2-5
2.2 CLOSURE REQUIREMENTS TO BE ADDRESSED IN THE CLOSURE PLAN 2-5
2.2.1 Facility Description 2-7
2.2.2 Partial Closure 2-9
2.2.3 Maximum Extent of Operations 2-10
2.2.4 Management of Maximum Inventory 2-10
2.2.5 Facility Decontamination 2-13
2.2.6 Final Cover 2-16
2.2.7 Ground-Water Monitoring 2-17
2.2.8 Ancillary Closure Activities 2-18
2.2.9 Survey Plat 2-21
2.2.10 Closure Certification 2-21
2.2.11 Partial and Final Closure Schedule 2-22
2.3 POST-CLOSURE CARE REQUIREMENTS TO BE ADDRESSED IN THE
POST-CLOSURE PLAN 2-23
2.3.1 Scope of Post-Closure Care Activities 2-25
2.3.2 Considerations Affecting the Length of the Post-
Closure Care Period 2-32
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TABLE OF CONTENTS (continued)
Page
2.4 DESCRIPTION OF DATA SOURCES FOR CLOSURE AND POST-CLOSURE
PLANS 2-34
2.4.1 Part B Application 2-35
2.4.2 Facility Operating Record 2-36
2.4.3 Inspection Logs 2-36
2.4.4 Manifests and Other Contracts for Waste Shipments 2-37
2.4.5 Ground-Water Monitoring Data 2-37
2.4.6 Biennial Report 2-37
2.4.7 Part A Application 2-38
CHAPTER 3. PROCEDURAL ANT) ADMINISTRATIVE CLOSURE AND POST-CLOSURE
CARE REQUIREMENTS 3-1
3.1 AVAILABILITY OF PLANS AND COST ESTIMATES 3-1
3.2 CLOSURE AND POST-CLOSURE PLAN AND COST ESTIMATE REVIEW
PROCEDURES AND PUBLIC INVOLVEMENT REQUIREMENTS 3-2
3.2.1 Review of Closure and Post-Closure Plans and
Cost Estimates by the Regional Administrator or
State Director 3-2
3.2.2 Public Involvement Requirements 3-5
3.3 REQUIREMENTS FOR AMENDING CLOSURE OR POST-CLOSURE
PLANS AND COST ESTIMATES 3-12
3.3.1 Changes that Require Amendments to Plans and
Cost Estimates 3-12
3.3.2 Deadlines for Amending Plans and Cost Estimates 3-14
3.3.3 Procedures for Amending Plans and Cost Estimates 3-15
3.4 CLOSURE SCHEDULE 3-16
3.4.1 Receipt of Final Volume of Hazardous Wastes 3-16
3.4.2 Notification of Closure 3-17
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TABLE OF CONTENTS (continued)
Page
3.4.3 Completion of Closure Activities 3-17
3.4.4 Submittal of Closure Certification 3-22
3.4.5 Submittal of Survey Plat 3-22
3.4.6 Submittal of Record of Wastes 3-22
3.4.7 Submittal of Deed Notation 3-25
3.4.8 Release from Financial Assurance 3-27
3.5 PROCEDURES FOR ALTERING THE LENGTH OF THE POST-CLOSURE
CARE PERIOD 3-29
CHAPTER 4. INSTRUCTIONS FOR PREPARING CLOSURE AND POST-CLOSURE COST
ESTIMATES 4-1
4.1 APPLICABILITY OF COST ESTIMATING REQUIREMENTS 4-1
4.2 BASIC RULES FOR PREPARING COST ESTIMATES 4-3
4.2.1 Relationship Between the Closure and Post-Closure
Plans and Cost Estimates 4-4
4.2.2 Scope of the Closure Cost Estimate 4-4
4.2.3 Scope of the Post-Closure Cost Estimate 4-6
4.2.4 Inclusion of Ground-Water Monitoring Costs in Cost
Estimates 4-7
4.2.5 First- vs. Third-Party Costs 4-7
4.2.6 Disallowance of Salvage Value and Zero Credit for
Sale of Hazardous Wastes 4-8
4.3 REVISING COST ESTIMATES TO REFLECT CHANGES IN CLOSURE
AND POST-CLOSURE PLANS ' 4-9
4.3.1 Changes in the Closure or Post-Closure Plans that
May Increase the Cost Estimates 4-9
4.3.2 Changes in the Closure or Post-Closure Plans that
May Decrease the Cost Estimates 4-10
4.4 ANNUAL ADJUSTMENTS FOR INFLATION 4-11
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TABLE OF CONTENTS (continued)
Page
A.4.1 Options for Updating the Closure and Post-Closure
Cost Estimates for Inflation 4-11
4.4.2 Deadlines for Adjusting Cost Estimates for
Inflation 4-14
4 .5 DOCUMENTATION FOR COST ESTIMATES 4-17
4.5.1 Guidance Manual: Cost Estimates for Closure and
Post-Closure Plans (Subparts G and H) 4-17
4.5.2 Owner or Operator Experience 4-18
4.5.3 Contractor Estimates 4-18
4.5.4 Cost Estimating Handbooks 4-18
4.5.5 Worksheets and Workups 4-19
APPENDIX A: CLOSURE TIMELINES A-l
A.I Closure Timelines for Permitted Facilities and Interim
Status Facilities With Approved Plans: Surface
Impoundments, Waste Piles, Landfills, and Land
Treatment Units A-3
A.2 Closure Timelines for Permitted Facilities and Interim
Status Facilities With Approved Plans: Container
Storage, Tank and Incinerator Units A-4
A.3 Closure Timelines for Interim Status Facilities Without
Approved Plans: Surface Impoundments, Waste Piles,
Landfi 1 Is , and Land Treatment Units A-5
A.4 Closure Timelines for Interim Status Facilities
Without Approved Plans for: Container Storage, Tank
and Incinerator Units A-6
APPENDIX B: TECHNICAL CRITERIA AND SITE-SPECFIC FACTORS TO
CONSIDER IN DETERMINING THE LENGTH OF THE POST-CLOSURE
CARE PERIOD B-l
B.I Technical Evaluation Criteria to Consider in Determining
the Length of the Post-Closure Care Period B-l
B . 1. 1 Containment B-2
B . 1 . 2 Detection B-3
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TABLE OF CONTENTS (continued)
Page
B . 1. 3 Migration and Attenuation B-3
B. 1.4 Risk Potential B-4
B.2 Site-Specific Technical Factors Involved In Evaluating
the Length of the Post-Closure Care Period B-4
B.2.1 Facility Characteristics B-4
B.2.2 Waste Types and Characteristics B-15
B.2.3 Environmental and Health Considerations B-17
APPENDIX C: CLOSURE, CONTINGENT CLOSURE, AND
POST-CLOSURE PLAN CHECKLISTS C-l
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CHAPTER 1
INTRODUCTION
This guidance manual accompanies the Parts 264 (permitted status) and 265
(interim status) Subpart G closure and post-closure care regulations, and the
Subpart H cost estimating rules promulgated on May 19, 1980, and January 12,
1981, and later amended on May 2, 1986. These requirements are found in 40
CFR 264.110-264.120, 264.142, 264.144, 265.110-265.120, 265.142, and 265.144.
The purpose of this guidance manual is to assist the Regional and State
Offices in implementing the closure and post-closure care and cost estimate
regulations and to help owners and operators prepare plans and cost estimates
that satisfy these regulations. In particular, the manual:
clarifies the intent and scope of the closure and
post-closure plan and cost estimate regulatory
requirements ;
provides examples of the kinds of information that
should be included in closure and post-closure plans and
cost estimates;
discusses site-specific factors that may affect
closure and post-closure care activities; and
provides closure and post-closure plan checklists
to assist in preparing and reviewing plans.
The information in this manual supersedes guidance contained in two
earlier manuals published in November 1981 to accompany the May 19, 1980,
interim final rules: Final Draft Guidance for Subpart G of the Interim
Status Standards for Owners or Operators of Hazardous Waste Treatment,
Storage and Disposal Facilities, and Final Draft Guidance for the Subpart H
Cost Estimating Requirements of the Interim Status Standards for Owners or
Operators of Hazardous Waste Treatment, Storage and Disposal Facilities.
Guidance for future regulatory changes and policies, including determining
"how clean is clean", will be published at a later time.
Readers may also wish to refer to two other manuals that address closure
and post-closure cost estimates and financial responsibility requirements:
Guidance Manual: Cost Estimates for Closure and Post-Closure Plans (Subparts
G and H). Volumes I-IV, November, 1986, EPA #530-SW-86-036, OSWER Policy
Directive Number 9476.00-6; and Financial Assurance for Closure and
Post-Closure Care: Requirements for Owners and Operators of Hazardous Waste
Treatment, Storage and Disposal Facilities, U.S. EPA, Office of Solid Waste,
May 1982, EPA #SW-961, NTIS #PB 83-144-675.
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1.1 SUMMARY OF CLOSURE/POST-CLOSURE CARE REQUIREMENTS
This section summarizes the key provisions of the closure and post-closure
care regulations that are discussed in more detail in later chapters. It
should be noted that the closure and post-closure care regulations in 40 CFR
Subpart G were revised substantially by regulations published on May 2, 1986,
and effective on October 29, 1986. These rules, including the preamble
discussing the rationale for the revisions, can be found in 51 Federal
Register 16422. The major closure/post-closure care regulatory requirements
are as follows:
Owners or operators must prepare closure and
post-closure plans describing in detail the plans and
procedures to be followed for conducting closure and
post-closure care activities.
Partial closures must be addressed explicitly in the
plans.
Owners or operators must remove or decontaminate
contaminated facility equipment, structures, and soils
at partial and final closure.
Owners or operators must notify the Regional or State
Office prior to the beginning of closure of each
disposal unit and prior to final closure.
Certifications by an independent registered
professional engineer and the owner or operator that
closure has been conducted in accordance with the
approved closure plan are required at closure of each
disposal unit and at final closure.
Owners or operators must submit survey plats and
post-closure notices after closure of each disposal
unit. (Deed notices must be filed subsequent to closure
of the first and the last disposal unit.)
Owners or operators of permitted storage surface
impoundments and waste piles not designed in accordance
with specified liner design standards, and of all tank
systems without secondary containment must prepare
contingent closure and post-closure plans describing
activities required to close the unit as a landfill and
conduct post-closure care.
Owners or operators not otherwise required to prepare
contingent closure and post-closure plans oust revise
their closure plans and prepare post-closure plans if
all hazardous wastes cannot be removed at closure and
the unit must be closed as a landfill.
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Owners or operators must begin post-closure care as
soon as the unit is closed and continue it for 30 years,
or some other period approved by the Regional
Administrator or State Director.
At the completion of the post-closure care period for
each unit, an independent registered professional
engineer and the owner or operator must certify that the
activities were conducted in accordance with the
approved plan.
Cost estimates based on the plans must include the
costs of a third party performing closure and
post-closure care activities.
The cost estimates may reflect the costs of a third
party managing hazardous wastes on site i_f capacity
will be available at all times over the life of the
facility.
1.2 ORGANIZATION AND USE OF MANUAL
This manual is divided into two major parts: Chapters 1 through 4 discuss
the closure, post-closure care, and cost estimate regulatory requirements
applicable to interim status and permitted facilities; Appendices A through C
include closure timelines, discussibns of technical criteria and site-specific
factors relevant to evaluating the length of the post-closure care period, and
closure and post-closure plan checklists for most major types of unit that may
be at a facility.
Discussions of specific closure and post-closure care requirements are
presented in the following chapters:
Chapter 2 -- Closure and Post-Closure Care Requirements
Chapter 3 -- Procedural and Administrative Closure and
Post-Closure Care Requirements (e.g., amending
plans and cost estimates; notification
requirements; public involvement)
Chapter 4 -- Instructions for Preparing Closure and
Post-Closure Cost Estimates
Appendix A -- Closure Timelines
Appendix B -- Technical Criteria and Site-Specific Factors
to Consider in Determining the Length of the
Post-Closure Care Period
Appendix C -- Closure, Contingent Closure, and Post-Closure
Plan Checklists
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The closure and post-closure plan checklists in Appendix C have been made
consistent with the guidance manual on developing cost estimates: Guidance
Manual: Cost Estimates for Closure and Post-Closure Plans (Subparts G and
HJ, EPA //530-SW-86-036, OSWER Policy Directive Number 9476.00-6. This cost
estimating manual is comprised of four volumes: Volume I includes sample
worksheets of cost components applicable to closure of treatment and storage
facilities. Volume II of the cost estimating manual includes sample
worksheets and costs for waste piles, surface impoundments, land treatment,
and landfills, as well as worksheets and costs for a post-closure care cost
estimate. Volume III includes ranges of unit costs for closure and
post-closure care activities. Volume IV documents sources for the unit cost
estimates.
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CHAPTER 2
CLOSURE AND POST-CLOSURE CARE REQUIREMENTS
The Subparts G and H regulations include performance-based standards for
conducting closure and post-closure care and descriptions of the information
that must be included in closure and post-closure plans. This chapter
discusses these requirements and is organized as follows:
Section 2.1 -- Applicability of the closure and
post-closure care regulations.
Section 2.2.-- Information that must be included in
the closure plan and sources for this information.
Section 2.3 -- Information that must be included in
the post-closure plan.
Section 2.4 -- Description of data sources for closure
and post-closure plans.
2.1 APPLICABILITY OF CLOSURE AND POST-CLOSURE CARE REGULATIONS
Exhibit 2-1 summarizes the applicability of the closure and post-closure
plan regulations to various types of TSDFs. Information in this exhibit will
be discussed in the following sections.
2.1.1 Applicability of Closure Regulations
All owners or operators of hazardous waste management facilities must
prepare closure plans describing how each unit at the facility will be
closed.1 The closure and post-closure care regulations apply only to
those units at the facility that treated, stored, or disposed of wastes after
November 19, 1980.2 If a unit (e.g., landfill cell) or any part of a unit
was active on the effective date of the regulations, the entire unit is
subject to the closure and post-closure care regulations.
A hazardous waste management unit is defined as the largest area in whioh
hazardous waste constituents may be mixed.1 Examples of hazardous waste
management units include:
1 40 CFR 264.110(a), 264.112(b)(1), 265.110(a), and 265.112(b)(1).
2 See definition of "active portion" of a facility, 40 CFR 260.10.
' 40 CFR 260.10.
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EXHIBIT ?-l
APPLICABILITY OF CLOSURE AND POST-CLOSURF PLAN RFQUIRFMFNFS
OSWER Policy Directive
/T9H76.00-5
o
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5
o
^1
Process Type
Interim Status
Container storage
Tank with secondary contain-
ment
Tank without secondary con-
ta Inment
Disposal surface Impoundment
Surface Impoundment at which
owner/operator Intends to
remove ALL wastes at closure
Waste Pile
Land Treatment
Landfil 1
Incinerator
Permitted Status
Container storage
Tank with secondary contain-
ment
Tank without secondary con-
ta Inment
Disposal surface impoundment
Surface Impoundment at which
owner/operator Intends to
remove ALL wastes at clo-
sure: unit satisfies liner
design standards
1 Closure Plan
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Cont ingent
Closure Plan
X
X
Post-Closure Plan
Only if unit must be closed
as a landfi 1 1
X
Only if unit must be closed
as a landfi 1 1
Only if unit must be closed
as a landf I 1 1
X
X
Only if unit must be closed
as a landfi 1 1
X
Only if unit must be closed
as a landfi 1 1
Cont ingent
Post-Closure Plan
X
h
r>
X
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OSWrR Policy Directive
FXMIBIT 2-1 (continued)
APPLICABILITY OF CLOSURE AND POST-CLOSURE PLAN RTQUIREMtNTS
Process Type
Surface impoundment at which
owner/operator intends to
remove ALL wastes at clos-
ure: unit does not satisfy
liner design standards
Waste pile: unit satisfies
liner design standards
Waste pile: unit does not
satisfy liner design stan-
dards
Land treatment
LandfllI
IncInerator
Closure Plan
| Contingent
Closure Plan
X
X
X
Post-Closure Plan
Only if unit must be closed
as a landr iI I
X
X
ContIngent
Post-Closure Plan
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Container storage area (each container is not considered a
unit);
Tank and its associated piping and underlying containment
systems;
Surface impoundment;
Waste pile;
Land treatment area;
Landfill cell or trench area that segregates wastes (a subcell
is not a unit);
Incinerator;
Thermal treatment unit;
Area for open burning or open detonation;
Chemical, physical, and biological treatment unit; and
Underground injection well (Underground injection wells are
subject to a permit issued under an Underground Injection Control
(UIC) program under the Safe Drinking Water Act. RCRA regulations
apply to aboveground storage or treatment of wastes prior to
injection and to injection wells prior to receipt of UIC permit).
2.1.2 Applicability of Post-Closure Care Regulations
The post-closure care regulations under 40 CFR 264.117 through 264.120
and 265.117 through 265.120 apply to owners or operators of all hazardous
waste DISPOSAL units" -- landfills, land treatment areas, disposal
surface impoundments, and storage impoundments, waste piles, and tank systems
that cannot be "clean closed" and must be closed as landfills.
The post-closure care period for each unit must begin as soon as the unit
is closed and continue for 30 years or some other period specified by the
Regional Administrator or State Director (see Section 2.3). Unless an owner
or operator can demonstrate that ground-water monitoring results can be
distinguished for each unit, the post-closure care period for units closed
prior to final closure may need to be extended to be consistent with the
post-closure care period of the last disposal unit closed.
* 40 CFR 264.110(b) and 265.110(b). A disposal facility is defined in
§260.10 as:
"... a facility or part of a facility at which hazardous
waste is intentionally placed into or on any land or water,
and at which waste will remain after closure."
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2.1.3 Units Subject to Contingent Plan Requirements
PERMITTED storage surface impoundments and waste piles that are not
designed in accordance with the specified liner design standards in 40 CFR
264.221(a) and 264.251(a) (e.g., synthetic liners) and are not exempt from
these standards, and permitted and interim status tanks without secondary
containment (and not exempt) must prepare closure plans that describe
activities necessary to conduct closure under two sets of conditions. The
first plan must describe how the unit will be closed by removing all hazardous
wastes and hazardous constituents. The second is a CONTINGENT closure plan
that outlines the closure activities to be undertaken if the unit must be
closed as a landfill. In addition, these facilities must have a contingent
post-closure plan describing how the disposal units will be monitored and
maintained during the post-closure care period.* (See Appendix C for
closure plan and contingent closure plan checklists for tanks, surface
impoundments, and waste piles.) If at closure, all hazardous wastes and
hazardous constituents, including hazardous residues, liners, and surrounding
contaminated soils are successfully removed, post-closure care will not be
required.
For surface impoundments, waste piles or tank systems not subject to
the contingent plan requirement, if the owner or operator or Regional
Administrator or State Director determines that the unit must be closed as a
landfill, the owner or operator must amend the closure plan, prepare a
post-closure plan, and comply with the other post-closure care requirements
in 40 CFR 264.117-264.120 or 265.117-265.120.* See Section 3.3 for guidance
on procedures and deadlines for revising plans.
2.2 CLOSURE REQUIREMENTS TO BE ADDRESSED IN THE CLOSURE PLAN
This section describes the activities which must be described in detail in
the closure plan and gives examples of the sources of data that may be helpful
to support the discussion of these activities. Exhibit 2-2 lists the
activities, indicates the subsections of Section 2.2 where each activity is
discussed, and identifies the corresponding regulatory requirement. Closure
plan checklists for major types of hazardous waste management units
illustrating how these activities may apply to specific process types are
presented in Appendix C.
The closure and post-closure care regulations do not specify the format of
the plans, the level of detail that must be included, or the types of
documentation that should be made available to support the plans. For
example, an owner or operator of a multiple-process facility (e.g., a facility
with storage tanks, a landfill, and a surface impoundment) may address closure
1 40 CFR 264.228(c)(l), 264.258(c)(1), 264 .197(c)(1) and (2), and
265.197(c)(l) and (2).
* 40 CFR 264.HO(b)(2) and (3), 264 . 112 (c) (3) , 264.118(a), 265 .110(b) (2)
and (3), 265.112(c)(2), 265.118(a).
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EXHIBIT 2-2
CONTENTS OF CLOSURE PLAN
1
I Activities To Be
Described in Closure Plan
Facility Description
Partial closure activities
Final closure activities based
on the maximum extent of opera-
tions
Treating, removing, or dispos-
ing of the maximum amount of
invr-.tory
Facility decontamination
Finel cover1
Ground-water monitoring1
Ancillary closure activities
(e.g., leachate management,
gas monitoring, run-on and
run-off control)1
Survey plat1
Closure certification
Partial and final closure
schedule
i
Section
of Manual
2.2.1
2.2.2
2.2.3
2.2.4
2.2.5
' 2.2.6
2.2.7
2.2.8
2.2.9
2.2.10
2.2.11
i
Regulatory i
Citation |
I
!
§§ 264.111, 265.111 !
I
1
§§ 264.112(b)(l), 265.112(b)(l);
i
1
§§ 264.112(b)(2), 265.112(b)(2)|
j
1
1
i
1
§§ 264.112(b)(3), 265.112(b)(3)j
1
1
i
§§ 264.112(b)(4), 264.114, |
265.112(b)(4), 265.114 |
I
1
§§ 264.112(b)(5), 264.228, i
264.258, 264.280, 264.310, |
265.112(b)(5), 265.228, |
265.258, 265.280, 265.310 |
i
§§ 264.11200(5), 265.11200(5)1
I
§§ 264.11200(5), |
265.11200(5) I
1
1
I
1
§§ 264.116, 265.116 |
§§ 264.115, 265.115 |
i
§§ 264.11200(6), |
265.112(b)(6) |
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i
1 May not be required at all units or facilities. I
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of each unit independently or describe certain closure activities on a
facility-wide basis (e.g., ground-water monitoring, security provisions,
facility decontamination). Regardless of the format chosen for the plans, the
plans must always contain enough detail to allow the Regional and State
Offices to evaluate whether:
the activities described in the plan satisfy the
regulations;
the conditions assumed in the plan adequately reflect
the true conditions of the facility; and
the cost estimates are consistent with the activities
described in the plan.
Because changes to approved closure plans for permitted facilities require
either a permit modification or, for interim status facilities with approved
plans, approval from the Regional or State Office including, where applicable,
public involvement, the plan should, as closel- as possible, reflect the
activities that will be conducted at closure. To minimize the burdens of
permit modifications and procedures for amending plans for interim status
facilities, the owner or operator may wish to include alternative options in
the plan if it is difficult to predict future events with certainty. For
example, because it may be difficult to predict what off-site capacity will be
available at closure, the closure plan could indicate that inventory will be
sent off-site either to a landfill or to an incinerator. The cost estimate
should reflect the highest cost alternative.
The discussion of each closure activity presented in this section is
followed by examples of possible sources of information. Data sources
applicable to multiple sections of the plans are described in detail in
Section 2.4.
2.2.1 Facility Description
The closure plan should include site-specific information about the
facility that will help the Regional or State Office evaluate whether the plan
is consistent with overall facility operations and thus will satisfy the
closure performance standard. The types of information to include are:
Facility location;
General description of hydrogeologic conditions;
Description of hazardous waste management units at the
facility; and
References to other environmental permits and
exemptions.
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This information must be included in the Part B application (see 40 CFR 270.14
through 270.29). As a result, if a Part B has been prepared the closure plan
can reference the appropriate sections of the application. The contents of
these sections are describe below.
2.2.1.1 Facility Location and Sizs
The facility description should identify the political jurisdiction in
which the facility is located and include a topographic map showing hazardous
waste management areas, the location of each unit relative to other areas of
the facility, buildings, floodplain locations, surface waters, surrounding
land uses, and other key topographic features. The description and map should
also indicate the location and nature of the security systems, and traffic
patterns.
2.2.1.2 Hydrogeologic Conditions
A description of what is known about the hydrogeology of the immediate
area should be presented here, including a description of underlying soil and
ground-water conditions. Soil class, soil depth and permeability, depth to
ground water, identification of aquifers, and ground-water flow rate and
direction are the principal pieces of information needed. If applicable, a
description of the ground-w£ter monitoring systems and detection program at
the facility should also be presented, including location of monitoring wells
and sampling and analysis procedures (parameters, frequency). Finally, if the
ground water at the facility has been found to be contaminated, a description
of the extent of contamination should be included along with the engineered
corrective measures that have been and/or are being taken at the facility. In
most cases, references to Part B applications, permit conditions, or
corrective action orders should provide the necessary information.
2.2.1.3 Desription of Hazardous Waste Management Units
This section should describe the design and configurations of each unit at
the facility and identify the types and quantities of hazardous wastes
handled. The description included here should provide sufficient detail to
support the proposed closure and post-closure care procedures.
The description of the facility design should include:
Size and dimensions of each unit/area;
Design capacity or throughput;
Ancillary equipment associated with each unit (e.g.,
conveyors, decanting equipment, forklifts, etc.); and
Types of monitoring and containment systems.
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A sketch or layout drawing indicating this information is also recommended.
Because the closure plan must account for the maximum extent of operations
of the facility, this section should also describe any plans for expanding or
modifying the facility over its active life. These plans should be discussed
in similar detail to the information required for the existing unit, as
described above. For example, an expansion of the drum storage building and
corresponding increase in drum storage capacity should be indicated.
Including this information in the closure plan for permitted facilities may
preclude the need to modify the permit later on. In the case of interim
status facilities, the plan should indicate how these intended changes satisfy
the restrictions on expansions to interim status facilities listed in §270.72.
The description of wastes handled at the facility should identify the
maximum number of hazardous waste types to be handled over the active life of
the unit. If additional waste types and quantities are proposed to be handled
over what is currently being managed, then these proposed wastes should also
be identified.
For each type of hazardous waste managed, the EPA hazardous waste number
should be listed, as well as the physical state (e.g., liquid, solid, or gas),
and the principal chemical characteristics of the wastes (e.g., dilute aqueous
materials contaminated with TCE). Where certain areas of the storage unit are
dedicated to managing different types of wastes, these should also be
indicated.
2.2.1.4 References to Other Environmental Permits and Exemptions
If closure activities are to involve, in some manner, other
environmentally permitted operations at the facility, the appropriate permits
(e.g., NPDES, UIC for an injection well used to dispose of hazardous wastes,
Air Emission Source, etc.) should be reference in the closure plan. For
example, if waste inventory is to be treated and discharged via an NPDES
permitted outfall, the key provisions of the permit should be referenced.
The closure plan should include a list of any anticipated waivers or
exemptions from the RCRA regulations, and address how these will influence the
closure plan. For example, if one of the facility's wastes has been delisted,
procedures for handling of waste inventory may be adjusted accordingly. In
cases where exemptions have not yet been granted, the owner or operator may
wish to present alternative options under both scenarios to avoid the need to
revise the plan at a later date if the exemption is granted.
2.2.2 Partial Closure
The closure plan must include a description of all partial closure and
final closure activities.7 Partial closure is closure of a hazardous
40 CFR 264.112(b)(l) and (2), and 265.112(b)(1) and (2).
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waste management unit at a facility that contains other operating hazardous
waste management units. Closure of the last unit is final closure of the
facility.
Partial closures must comply with Subpart G regulations and the
process-specific requirements and be consistent with final closure
procedures. Interim measures such as working covers are not considered
partial closures because they do not satisfy completely the final cover design
standards. All closure activities apply equally to partial and final closures
with the exception of notification and certification requirements for tanks,
container storage areas, and incinerators. Notification of closure and
certification for these nondisposal units is not required until final closure
(see Sections 2.2.10 and 3.A).
2.2.3 Maximum Extent of Operations
The closure plan must describe the steps necessary to close the facility
at any given time, in the event that the facility unexpectedly was required to
stop accepting hazardous wastes 8nu begin closure procedures.1 This
"maximum extent of operations" will include, for example, the maximum
inventory and the maximum number of cells even open at a landfill. At some
facilities, the estimate of the maximum extent of operations may be equivalent
to the maximum design capacity of the facility (e.g., the maximum volume of
wastes that can be handled at a tank storage facility is governed by the
design capacity). At other facilities, owners or operators may reduce the
size of the maximum area ever open at one time by periodically performing
partial closures during the course of operations. For example, if an
owneror operator routinely closes landfill cells as they reach capacity and
never has more than two cells open at the same time, then the maximum extent
of operation described in the closure plan would be two cells while the
cumulative capacity of the landfill would be ten cells.
2.2.4 Management of Maximum Inventory
The closure plan must describe in detail the procedures for removing,
treating, transporting, and disposing of the maximum hazardous waste
inventory,' AND demonstrate that these activities will be completed
within 90 days of receiving the final volume of hazardous waste at the
facility.10 As will be discussed in Section 3.4.3, an owner or operator
may request an extension to this 90-day deadline if completion of these
activities within the allotted time is not feasible.
* 40 CFR 264.112(b)(2) and 265.112(b)(2).
' 40 CFR 264.112(b)(3) and 265.112(b)(3).
10 40 CFR 264.113(a) and 265.113(a).
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2.2.4.1 Estimate of Maximum Inventory of Hazardous Waste
The closure plan must include an estimate of maximum inventory
including all undisposed hazardous wastes and residues ever on site at any
time over the life of the facility. The amount of inventory on site should
never exceed the estimate in the closure plan. If over the life of the
facility the owner or operator increases the amount of inventory, he must
revise the estimate upward, unless he can justify to the Regional
Administrator or State Director that the inventory accumulation was caused by
an unlikely contingency and that the amount of waste will be reduced within a
short time to a quantity not exceeding the original estimate.
In estimating the maximum inventory ever on site, an owner or operator
must take into account -expected periodic accumulations of inventory that occur
when predictable events (e.g., adverse weather conditions, which affect
landfilling activities, or periodic "down times" for routine maintenance)
affect operating procedures during the life of the facility. The estimate of
the maximum inventory should include:
The maximum amount of hazardous wastes, including
residues, in all treatment, storage, and disposal units;
The maximum amount of contaminated soils and residues
from drips and spills from routine operations; and
If applicable, the maximum amount of hazardous wastes
from manufacturing/process areas and raw
material/product storage and handling areas (e.g.,
discarded commercial products, see 40 CFR 261.4).
2.2.4.2 Procedures for Handling Hazardous Waste Inventory
The closure plan must include a detailed description of how an owner or
operator will handle all hazardous wastes during the partial and final closure
period. The procedures must be consistent with the estimate of maximum
inventory and with the estimate of the total time required to handle the
maximum inventory included in the milestone schedule (see Section 2.2.11.2).
An owner or operator may handle the inventory by:
(1) on-site treatment or disposal if capacity will be
available at partial or final closure; or
(2) off-site treatment, storage, or disposal.
(1) On-Site Management. Partial and final closure activities will
often be continuations of routine operating practices. Wastes may be handled
on site if capacity will be available (either in the unit to be closed or in
another unit at the facility) at the time the unit is closed.
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The Regional Administrator or State Director may allow an owner or
operator to expand or create a new unit at closure to handle wastes if:11
The owner or operator submits a revised Part A permit
application proposing to increase the existing design
capacity of a unit at a facility;
AND
The Regional Administrator or State Director
determines that the increase in existing design capacity
is necessary due to a lack of available capacity, or the
changes or additions are necessary to prevent a threat
to human health or the environment, or to satisfy
Federal, State, or local requirements, including the
Subpart G closure requirements.
If a new unit is to be constructed at closure, the plan must include a
discussion of these activities. For example, if an owner or operator of a
landfill intends to construct an additional cell or trench at closure to
handle hazardous waste inventory, the closure plan must describe procedures
for constructing the cell, including:
Excavation;
Installation of liners, leachate collection systems,
and run-on and run-off control systems; and
Installation of ground-water monitoring wells, if
applicable.
(2) Off-Site Management. 12 If off-site removal or disposal of
hazardous waste inventory is planned, the plan should include:
An estimate of the quantity of hazardous waste to be
sent off site;
A description of any treatment to be performed prior
to transport, if applicable;
An estimate of the approximate distance to the final
TSDF to support the estimate of the costs of off -site
management ; and
11 40 CFR 270.72(b), (c).
12 Owners or operators should note that if wastes are sent off site,
they must comply with Part 262 generator requirements including manifest,
packaging, and labelling requirements.
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A description of treatment or disposal methods at the
final TSDF (e.g., incineration, landfilling).
Data Sources
Sources of information included in Section 2.4 that may be useful in
developing this portion of the closure plan are:
Part B application
Facility operating record
Manifests and other contracts for waste shipments
Biennial report
2.2.5 Facility Decontamination
The closure plan must identify all areas requiring decontamination and
describe in detail all the steps necessary to decontaminate equipment,
structures, and soils during partial or final closure.13 The closure plan
should include:
(1) A list of potentially contaminated areas and equipment;
(2) Criteria for determining the extent of decontamination needed
to satisfy the closure performance standards;
(3) Procedures for cleaning, removing, or disposing of contaminated
equipment and structures; and
(4) Methods for sampling, testing and disposing of contaminated
soils.
2.2.5.1 List of Contaminated Equipment, Structures and
Facility Areas
The plan must identify the equipment or structures that will require
decontaminating at closure. Examples include:
Tanks;
Containers;
Treatment process (e.g., clarifiers, filter presses);
15 40 CFR 264.ll2(b)(4) and 265 . li.2 (b) (4) .
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Drainage pits;
Spill containment areas;
Equipment used prior to storage or treatment in tanks
and incinerators, such as waste feed systems, bypass
systems, drainage systems, conveyors, etc.;
Piping, pumps, valves;
Floors and walls of buildings;
Facility parking lots, roads, and truck staging areas;
Earth-moving equipment, such as trucks, forklifts,
front-end loaders, bulldozers, etc.; and
Other facility structures units associated with
hazardous waste management operations (e.g., dikes,
berms, confinement structures).
2.2.5.2 Criteria for Evaluating Decontamination
The closure plan must describe and document the procedures and
criteria that will be used in determining the extent of decontamination
necessary to satisfy the closure performance standard. The closure
performance standard requires the owner or operator to control, minimize, or
eliminate the post-closure escape of all hazardous constituents.1* Agency
guidance on determining "how clean is clean" is forthcoming. Until that
guidance is available, the plan should describe procedures to be followed to
satisfy the closure performance standard.
Similarly, in describing procedures for demonstrating "clean closure" of
an impoundment, waste pile, or tank, the closure plan should demonstrate that
any hazardous constituents left at the unit will not impact any environmental
media in excess of Agency-established exposure levels (e.g., water quality
standards and criteria as specified in 45 FR 79318 and 50 Et 30784, November
28, 1980; health-based limits based on verified reference doses developed by
EPA's Risk Assessment Forum in ECAO-CIN-475, January 1986, and Carcinogenic
Potency Factors developed by EPA's Carcinogenic Potency Factors in
OHEA/600-8-85/400F, Sepetember 1985) and that direct contact will not pose a
threat to human health and the environment.
2.2.5.3 Decontamination Procedures
The cleaning methods will vary depending on what is being cleaned and on
the type of contaminant. Information about decontamination methods and
40 CFR 264.111(b) and 265.111(b).
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procedures can be found in the Guide for Decontaminating Building,
Structures, and Equipment at Superfund Sites, U.S. EPA, Office of Research
and Development, March 1985. Until the determined level of decontamination is
achieved, all cleaning residues (e.g., sand from sandblasting, waters from
rinsing, etc.) are hazardous wastes and must be disposed of as hazardous
wastes.
2.2.5.4 Soil Decontamination
All facilities are likely to have some soil contamination as a result of
routine drips and spills (e.g., residues on drainage pits, spill containment
areas) which must be removed. The closure plan must describe the procedures
and criteria to be used for evaluating the extent of soil contamination and
demonstrate that the level of decontamination will satisfy the closure
performance standard..
The following information should be included in the closure plan:
The location for backg^und soil measurements and
background ground-water and surface-water monitoring; and
Sampling and analysis methods to be used to evaluate
the extent of contamination.
Besides determining soil contamination levels, the closure plan
must describe how contaminated soils will be managed at partial or
final closure. The plan should include the following:
An estimate of contaminated soil;
A description of on-site (if capacity is available) or
off-site treatment or disposal of contaminated soils; and
An estimate of the approximate distance to the
off-site TSDF to support the cost estimate.
Data Sources
Sources of information in Section 2.4 that owners and operators may find
useful in developing this portion of the plan are:
Facility operating record
Inspection log
Ground-water monitoring data
In addition, owners and operators may find an in-house procedures manual
and commercial reference materials useful in preparing the facility
decontamination section of the closure plan.
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In-House Procedures Manual. Some of the decontamination procedures
required at partial and final closure will be consistent with day-to-day
housekeeping procedures conducted at the facility. For example, as part of
routine operations, residues resulting from drips and spills should be cleaned
up as they occur. In-house manuals, which outline procedures for routine
housekeeping activities, may be useful sources to consult in preparing the
decontamination section of the closure plan.
Commercial Reference Materials. The following EPA guidance manuals and
engineering reference materials may provide information about decontamination
procedures for facility structures and surrounding soils and about the
criteria that are applied to demonstrate effective decontamination:
Guide for Decontaminating Buildings, Structures, and
Equipment at Superfund Sites, U.S. EPA, Office of
Research and Development, EPA/600/2 - 85/028, March 1985.
Decommissioning Handbook, W.J. Marion and S. Thomas,
DOE/EV/10128-1, 1980.
Engineering end Development Support of General Decon-
tamination Technology for the U.S. Army's Installation
Restoration Program. Task 5, Facility Decontamination,
W.E. Jones, Defense Technical Information Center,
Alexandria, Virginia, Pub. No. 49-5002-0005, July 1982.
2.2.6 Final Cover
If hazardous wastes will remain in the unit after closure, a final cover
must be installed to prevent infiltration of run-on or run-off into the unit.
The closure plan should include a detailed description of the design of the
cap, which may include drawings, and specifications that demonstrate that
the cover will satisfy the closure performance standard, and a discussion of
procedures for cover installation.1* Engineering sketches or drawings
delineating final surface contours of the closed unit may help to demonstrate
the adequacy of proposed run-on and run-off structures for erosion and slope
stability. The plan should also outline the specifications of the cap (e.g.,
type of cover materials, thickness of materials).
Data Sources
If units have been previously closed, sketches or engineering drawings and
documentation on procedures for installing the cap, including design
specifications, labor and materials used, may be available from in-house
records.
11
40 CFR 264.112(b)(5) and 265.112(b)(5).
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If an owner or operator does not have information from previous partial
closures, the following manuals may provide information relevant for the
closure plan:
Draft RCRA Guidance Document: Surface Impoundments--
Liner Systems, Final Cover and Freeboard Control,
Chapters E and F only, 1982, available for copying from
EPA Headquarters, (202) 382-4654.
Draft RCRA Guidance Document: Landfill Design--Liner
Systems and Final Cover, Chapter E only, 1982,
available for copying from EPA Headquarters,
(202) 382-4654.
Evaluating Cover Systems for Solid and Hazardous
Waste, EPA #SW-867; GPO #055-000-00228-2. The manual
provides a guide to examining soil, topographical, and
climatological data and recommends cover evaluation
procedures.
Construction Quality Assurance for Hazardous Waste
Land Disposal Facilities. 1985, EPA/530-SW-85-021,
available through RCRA Hotline or EPA Headquarters,
(202) 382-4654.
Closure of Hazardous Waste Surface Impoundments,
1982, EPA #SW-873; GPO #055-000-00227-4.
Permit Writer's Guidance Manual for Hazardous Waste
Land Treatment, Storage, and Disposal Facilities,
EPA/530-SW-84-004; available through GPO
#055-000-00240-1.
2.2.7 Ground-Water Monitoring
Owners or operators of landfills, waste piles, surface impoundments, and
land treatment units must comply with the ground-water monitoring requirements
of Subpart F during the active life of the facility, including the partial and
final closure period.1' The closure plan must describe the types and
frequency of analyses required during the partial and final closure period and
maintenance that may be required to ensure that the monitoring equipment is in
working order for the start of the post-closure care period. Because the
monitoring required during the closure period should be consistent with that
conducted during the unit's operation, the closure plan may simply refer to
the Part B application, the permit, or the interim status ground-water
l* 40 CFR 264.90(a) and 265.90(a). Ground-water monitoring requirements
apply to permitted, but not to interim status, waste piles.
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monitoring plan. If facility conditions change over the course of the
facility's active life, the closure plan must be revised to reflect the new
ground-water monitoring requirements.
Data Sources
References can be made to the Part B permit application, or, for interim
status facilities, to:
Ground-water sampling and analysis plan for sampling
indicator parameters which outlines procedures and
techniques for sample collection, sample preservation
and shipment, analytical procedures, and chain of
custody. This plan must be kept at the facility;
Outline of a ground-water quality assessment program
which summarizes a ground-water monitoring program more
comprehensive than detection monitoring to determine the
extent of potential contamination;
Ground-water quality assessment plan required if
contamination has been detected at an interim status
facility;
Records of all ground-water monitoring analyses
conducted to date. These records must be maintained
throughout the life of the facility, and, for disposal
units, throughout the post-closure care period; and
Annual reports of ground-water monitoring which are
sumitted to the Region or State no later than March 1 of
each calendar year.
2.2.8 Ancillary Closure Activities
Depending on the type of unit being closed, the following activities may
be necessary to ensure that all partial closures and the final closure satisfy
the closure performance standards:17
Leachate management;
Gas monitoring;
Run-on and run-off control; and
Security.
I 7
40 CFR 264.112(b)(5) and 265.112(b)(5).
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2.2.8.1 Leachate Management
The owner or operator must describe in the closure plan procedures for
continuing to operate the leachate monitoring, collection, removal, and
treatment system during the closure period. In most cases, these
procedures should be a continuation of activities conducted during the
operating life.11 For example, if leachate is routinely collected and
diverted to a wastewater treatment unit with a NPDES permit, the plan should
refer to the permit or Part B application for information or describe the
procedures and note the NPDES permit number. If leachate routinely is
collected in a tank for periodic removal, the plan should estimate the
quantity of leachate that will be collected during the closure period, and
specify how it will be disposed.
For units or facilities that will require post-closure care, the closure
plan should note that routine maintenance and repairs to the system, such as
replacement or reinstallation of parts, will be conducted as needed, to ensure
that the leachate monitoring and collection system is operating properly when
the post-closure care period begins.1'
2.2.8.2 Gas Monitoring
Some landfills may be required to have a gas collection and control system
for controlling and venting the vertical and horizontal movement of produced
gases. If such a system is required as a permit condition, the closure plan
should describe how it will be monitored and how gases will be collected and
managed during partial and final closure. Again, if these are routine
operations, the owner or owner or operator may be able to refer to the permit
or permit application. In addition, the plan should describe the types of
routine maintenance that may be required to ensure that the system is in
working order during the post-closure care period.
11 Leachate collection systems are required for new units, lateral
expansions, and replacement units of existing permitted and interim status
landfills, surface impoundments, and waste piles. In addition, owners and
operators of all surface impoundments must retrofit all units to meet these
standards by November 8, 1988. See 40 CFR 264.221, 264.251, 264.301, 265.221,
265.251, and 265.301, and the preamble to the July 15, 1985 codification rule,
50 Federal Register 28705.
11 Under the current rules, only permitted land disposal units must
continue to operate the leachate collection system during the post-closure
care period. The Agency proposed on March 28, 1986 (see 51 Federal Register
10706) to require that all permitted and interim status land disposal units
continue monitoring and managing leachate until the end of the post-closure
care period.
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2.2.8.3 Run-On and Run-Off Control
The closure plan must describe the p/ocedures that will be used to ensure
that run-on and/or run-off due to rain or melting snow do not infiltrate or
erode the final cover. The plan should also describe the methods that will be
used to treat, remove, or dispose of the excess water that may accumulate as a
result of run'-on and run-off and how any temporary containment systems will be
decontaminated or removed.
2.2.8.4 Security
All owners or operators of TSDFs must maintain a security system
throughout the closure period that prevents access of persons or livestock
onto the facility, unless it can be demonstrated that access will cause no
damage to human health or the environment.20 The following security devices
are required at an operating facility:21
Signs with the legend "Danger--Unauthorized
Personnel Keep Out," posted at each entrance and at
Oulier locations and a 24-hour surveillance system (e.g.,
television monitoring, guards) which continuously
monitors and controls entry onto the active portions of
the facility;
OR
A fence surrounding the active portions of the
facility and a means to control access to the active
portions of the facility at all times.
The closure plan should note which of these security devices will be operating
during closure.
Owners or operators may be required to continue any or all of the
security measures noted above during part or all of the post-closure
period if wastes MAY remain exposed after closure, or access by the public
or livestock may pose a threat to human health.22 Thus, for facilities with
disposal units, the closure plan should describe any maintenance that will be
required at closure.
Data Sources
In most cases, these ancillary closure activities will be continuations of
activities that were conducted throughout the active life of the facility.
28 40 CFR 264.14(a) and 26S.14(a).
21 40 CFR 264.14(b) and (c), and 265.14(b) and (c).
22 40 CFR 264.117(b) and 265.117(b).
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Therefore, the plan may simply cross-reference sections of the Part B permit
applcation. Other sources of information in Section 2.4 that owners and
operators may find useful are:
Facility operating record
Inspection log
Biennial report
In addition, owners and operators may find information available from the
following in-house documents:
Waste analysis plan outlining analyses to identify
leachate characteristics;
In-house employees' manuals outlining security
requirements and procedures for leachate management, and
for controlling run-on and run-off; and
EPA guidance manuals (e.g., Management of Hazardous
Waste Leachate. EPA tfSW-871; GPO #055-000-00224-0).
2.2.9 Survey Plat
After closure pf each disposal 'unit, an owner or operator must submit
a survey plat, prepared and certified by a professional lend surveyor
licensed in the State where the facility is located, t« the local land
authority and to the Regional Administrator or State Director. The plat
must indicate the location and dimensions of landfill cells or other hazardous
waste disposal units with respect to permanently surveyed benchmarks.2* The
closure plan should note the locations of the permanently surveyed benchmarks
that will be used as the basis of the survey plat.
Data Sources
Information on licensed land surveyors generally can be found by
consulting the yellow pages or the American Congress on Surveying and
Mapping, located in Falls Church, Virginia.
2.2.10 Closure Certification
As part of closure of each hazardous waste surface impoundment, waste
pile, land treatment, and landfill UNIT, an independent registered
professional engineer and the owner or operator must certify that closure has
been conducted in accordance with the approved closure plan. Certification
21 40 CFR 264.116 and 265.116.
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of container storage, tank storage or treatment, and incinerator units may
be delayed until final closure. Closure of a land treatment unit may be
certified by an independent qualified soil scientist in lieu of an independent
registered professional engineer. The regulations do not specify the types of
registered professional engineers (or qualified soil scientists for land
treatment units) that may certify closure.2* Therefore, owners and
operators should consider the training, experience, and other qualifications
necessary to properly certify closure when choosing an independent registered
professional engineer or soil scientist.
Supporting documentation of the certification must be made available to
the Regional Administrator or State Director upon request until the owner or
operator has been released from closure financial assurance requirements.21
The closure plan should describe the types of documentation that will be
maintained. At a minimum, the owner or operator should maintain a copy of the
professional engineer's or soil scientist's inspection report and results of
sampling and analyses which should include the following information:
Activities conducted during inspections;
Field reports documenting each on-site visit; and
List of in-house records that were reviewed (e.g.,
manifests, sampling data, laboratory results, contractor
logs of activities performed, engineering drawings of
the cover).
Sample certifications are included in Section 3.4 of this manual.
2.2.11 Partial and Final Closure Schedule
The closure plan must include a schedule for closure of each hazardous
waste management unit and for final closure of the facility. The schedule
must include, at a minimum, the total time required to close each hazardous
waste management unit and the time required for intervening closure activities
(e.g., time to remove all inventory, install final cap).2' Section 3.4
provides additional details on regulatory deadlines for closure activities.
2fc 40 CFR 264.115, 264.280(b), 265.115, and 265.280(e). An
"independent" engineer cannot be directly employed by the owner or operator,
or be the owner or operator himself.
21 40 CFR 264.115 and 265.115.
2* 40 CFR 264.112(b)(6) and 265.112(b)(6).
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2.2.11.1 Expected Year of Closure
Owners and operators of the following types of facilities must include an
estimate of the expected year of closure in the closure plan:27
Permitted facilities using trust funds to
demonstrate closure or post-closure care financial
assurance AND expecting to close prior to the
expiration of the permit;
Interim status facilities without approved closure
plans; and
Interim status facilities with approved plans using
trust funds to demonstrate financial assurance and
with a remaining facility operating life of less than 20
years. (See Financial Assurance for Closure and
Post-Closure Care: A Guidance Manual, EPA #5W-955, May
1982, for additional information on payment schedules
for owners or operators using trust 'unds to demonstrate
financial responsibility for closure and post-closure
care.)
Factors to consider when estimating the expected year of closure are the
remaining capacity of the units, projected shutdown of the manufacturing
plant, expiration date of contracts with customers who currently send
hazardous waste to the facility, and expected retirement date.
2.2.11.2 Milestone Chart of Partial and Final Closure Activities
A milestone chart from which the progress of partial or final closure can
be determined should be prepared. There is no required format for the
milestone chart. Exhibit 2-3 illustrates one possible format that may be
used. Milestone charts may vary depending on the process type and wastes
handled, the number of activities, and the length of time the activities will
take to implement.
2.3 POST-CLOSURE CARE REQUIREMENTS TO BE ADDRESSED IN THE
POST-CLOSURE PLAN
Units or facilities at which hazardous wastes will remain after partial or
final closure are subject to post-closure care requirements (see Section
2.1.2) and must have post-closure plans addressing these requirements. As
discussed in Section 2.1.3, owners or operators of permitted storage/treatment
27 40 CFR 264.112(b)(7) and 265.112(b)(7). 40 CFR 264.112(a)(4) and
265.112(a) (4) previously required every owner or operator to include an
expected year of closure in the closure plan. The Agency revised this
requirement on May 2, 1986 (51 FR 16422).
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EXHIBIT 2-3
SAMPLE CLOSURE PLAN HUES TONE CHART
Closure or Landrill Unit
WEEKS
Activity I 2 3 M 3 6 7 8 910 II 12 13 \H 13 16 1716 19 20 21 22 23 2ji_ 25
Construction of closure cell
Landfill ing of all Inventory f
Decontamination of all equipment '
and structures, and landfill Ing of *
all surrounding contaminated soils
Installation of final cap
Vegetation of cover
Preparation of survey plat
Certification of closure of
landfill unit
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surface impoundments and waste piles not designed in accordance with the
specified liner design standards, and permitted and interim status tank
systems that do not have secondary containment and must also prepare
contingent closure and contingent post-closure plans, unless exempted from
these requirements.2*
2.3.1 Scope of Post-Closure Care Activities
The post-closure plan must address:
Monitoring and maintenance of the unit or facility;
Name of contact person during the post-closure care
period;
Filing post-closure care notices; and
Certification of the completion of post-closure care
activities for each unit.
2.3.1.1 Monitoring and Maintenance Activities
The post-closure plan must describe the monitoring and maintenance
activities to be conducted after closure of each disposal unit and the
frequency of these activities.2S The post-closure plan should include
provisions for the kinds of monitoring and maintenance activities that
reasonably can be expected during the post-closure care period. Because it
may be difficult to predict with certainty the types of activities that will
be required during the post-closure care period, the owner or operator may
wish to describe in the plan a range of possible alternatives to avoid
modifying the permit or, for interim status facilities with approved plans,
following the procedures for modifying approved plans.
Monitoring Activities. The ground-water monitoring activities
proposed for the post-closure care period should be consistent with current
conditions at the unit or facility." If the ground-water monitoring
requirements applicable to the unit or facility change, the post-closure plan
must be revised.11 The plan should indicate:
21 40 CFR 264.228(c)(l), 264.258(c)(1), 264.197(c), and 265.197(c).
25 40 CFR 264.118(b)(l) and (2), and 265.118(c)(1) and (2).
10 40 CFR 264.90 and 265.90.
11 If corrective action is required, the post-closure plan does not have
to describe the corrective measures to be undertaken. These activities should
be addressed in the corrective action plan.
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The number, location, and depth of wells;
The frequency and procedures for sampling;
Types of analyses; and
Party responsible for monitoring activities.
The owner or operator may wish to reference the facility's ground-water
monitoring plan included in the permit (or Part B application if a permit has
not been issued), or a copy of the ground-water sampling and analyses plan
required under 40 CFR 265.92(a).
The post-closure plan must include procedures for operating the leachate
collection and removal system during the post-closure care period or until
leachate is no longer detected.12 The description of procedures and a
schedule to be followed during the post-closure care period should include:
Estimated quantity of leachate collected and removed;
Procedures for collecting and pumping leachate (e.g.,
leachate may be collected in a sump and pumped out by
means of a vacuum truck);
Procedures for disposing of leachate on site if other
units are still operating (e.g., surface impoundments,
tanks);
Procedures for discharging leachate to public waters
in accordance with NPDES permit conditions, if
applicable;
Procedures for sending leachate, including any
residues from leachate treatment, off site; and
Party responsible for handling leachate.
At some units or facilities, other types of monitoring activities such as
soil monitoring, leak detection monitoring, and gas monitoring may be
required. The sane guidelines apply to these types of activities as for
ground-water monitoring. The discussion of monitoring in the post-closure
plan should always be consistent with conditions at the unit or facility. If
monitoring activities will differ during the post-closure care period, the
plan should explain the reasons for the changes.
11 40 CFR 264.118 and 264.310(b)(2). Existing units at interim status
landfills are not required to have leachate collection and removal systems.
Interim status facilities also are not required to manage leachate during the
post-closure period. The Agency has proposed in 51 Federal Register 10706 to
require that interim status facilities manage leachate during the post-closure
care period.
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Maintenance Activities. The closure plan must include a description
and the planned frequency of all activities necessary to maintain the
integrity of the hazardous waste containment systems and the function of the
monitoring equipment and security systems, where applicable. The
post-closure plan should include maintenance provisions for any events that
reasonably could be expected to occur over a 30-year period. The owner or
operator is not expected, however, to establish the capability to handle
extraordinary calamities such as a total liner failure brought about by a
major earthquake.
The post-closure plan should include a description and schedule of the
following kinds of post-closure maintenance activities that will be needed at
most facilities:
Routine facility inspections;
Maintenance of the function and integrity of the waste
containment system, if applicable;
Continuation of processes necessary to continue waste
degradation at land treatment facilities;
Maintenance of the monitoring systems; and
Maintenance of security systems, if applicable.
(1) Routine Inspections. The plan should include procedures and a
schedule for periodically inspecting all of the facility systems that must be
maintained during the post-closure care period. In addition, the plan should
also indicate the party responsible for conducting these inspections. If
other units of the facility are still operating, inspections of the partially
closed areas can probably be integrated into the routine inspection schedule
as required under §§ 264.15 and 265.15. The post-closure plan should address
explicitly, however, procedures for inspections after the entire facility has
been closed when staff may no longer be available for inspections.
Components that should be inspected include:
Final cover;
Run-on and run-off control system;
Surveyed benchmarks;
Ground-water monitoring system;
Leachate collection system, if applicable;
Leak detection system, if a double liner system is
present;
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Unsaturated zone soil monitoring system, if
applicable; and
Security systems, if required by the Regional
Administrator.
The regulations do not specify the frequency of these activities. The
owner or operator should rely on past experience and good engineering
practices.
(2) Maintenance of Waste Containment Systems. The majority of the
routine maintenance operations should be directed at maintaining the integrity
of the waste containment systems (i.e., the final cap or vegetation) and
controlling erosion. The post-closure plan must contain a description of
the types and frequencies of activities required to maintain the integrity of
the final cover and/or vegetation. If vegetation has not been planted, the
post-closure plan should include a description of procedures necessary to
stabilize the cover and maintenance to repair damages to the cover caused by
routine weather conditions. This may be especially true in the early years of
the post-closure care period when the cover may not yet be well established.
These activities should include:
Mowing;
Fertilizing;
Reseeding and mulching bald spots and eroded areas;
Sprinkling;
Replacing soil lost to erosion;
Maintaining drainage channels and culverts which
direct surface run-on and run-off away from the disposal
area and prevent surface water from infiltrating the
cover; and
Controlling rodents as necessary to counter
infestations (e.g., filling of rodent burrows, applying
insecticide).
The type of activity and the site-specific conditions at the site will
affect the frequency of each activity. Some activities will be required
annually (e.g., inspections, erosion control, mowing, sprinkling). Others
will be required routinely but may not be required with the same frequency
over the entire period. For example, fertilization may be required more
frequently in the early years of the post-closure care period when the
vegetation has not become firmly established.
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The frequency of other post-closure care activities, such as the extent to
which the final cover will require remedial care, may be more difficult to
predict. Because the post-closure plan should describe all activities likely
to be required over the 30-year period, the plan should describe contingency
plans for damages caused by severe storms or other periodic natural events
that could be predicted to occur during the post-closure care period. Much of
this information may be based on historical records or the owner's or
operator's own experience. The plan may need to be revised as new information
becomes available.
(3) Continuation of Hazardous Waste Degradation at Land Treatment
Facilities. Unlike other process types, the post-closure care period for
land treatment facilities operates in part as an extension of the operating
life of the facility. During the post-closure care period, the owner or
operator must continue those activities necessary to enhance degradation and
transformation and sustain immobilization of hazardous constituents in the
treatment zone.'' The post-closure care plan should describe procedures for:
Disking;
Fertilizing;
Liming to ensure proper pH balance;
Irrigating;
Controlling run-on and run-off from the treatment
fields;
Repairing erosion damage;
degrading and replanting as needed; and
Controlling wind dispersal of particulates.
Because these activities may be needed more frequently in the early years of
the post-closure care period, the plan should include a schedule and a
discussion of how the proposed schedule of activities will achieve the desired
objectives of ensuring the continued degradation of hazardous constituents.
The plan should also indicate the party responsible for conducting the
activities. The owner or operator roust also comply with all food chain crop
prohibitions specified in the permit and in 40 CFR 264.276 and 265.276.
40 CFR 264.280 and 265.280.
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An owner or operator of a land treatment facility must continue to
conduct post-closure care activities until the level of hazardous
constituents in the treatment zone no longer exceeds the background value of
the constituents by a statistically significant amount.lk If an owner or
operator expects that the constituents will degrade before the end of the
30-year period, he may submit such a demonstration to the Regional or State
Office in accordance with the provisions in 40 CFR 264.280(d).
If an owner or operator intends to demonstrate that hazardous constituents
are no longer present at the facility, the plan should describe the procedures
for making this demonstration, including:
Constituents requiring reestablishment of background
values;
Number of soil increments to be analyzed; and
Procedures for conducting analyses to test the level
of hazardous constituents in the treatment zone.
(4) Maintenance of the Monitoring Systems. The post-closure plan
must describe provisions and include a schedule for maintaining the ground-
water and soil monitoring systems, and the leachate collection and leak
detection systems, as applicable. Maintenance may include:
Replacing or redrilling monitoring wells;
Replacing seals, piping, and caps;
Repairing or replacing pumps; and
Other kinds of routine equipment maintenance.
Some of these activities may be required annually, while others will be needed
at irregular intervals during the post-closure care period (e.g., ground-water
well replacement). Since monitoring during the post-closure pare period will
generally be a continuation of monitoring performed during facility
operations, an owner or operator will gain experience on maintenance needs
over the life of the facility. Again, the owner or operator may need to
revise the post-closure plan as more data become available.
(5) Maintenance of the Security System. Some hazardous waste
disposal units or facilities will be required by the Regional or State Office
to maintain security devices (e.g., fences, warning signs) during the
post-closure care period. If the owner or operator does not intend to provide
for security measures during the post-closure care period, he should explain
in the plan why such provisions are not needed to ensure the protection of
human health and the environment.
3 k
40 CFR 264.280(d).
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If security measures will be needed, the post-closure plan should describe
the proposed maintenance activities and estimate the frequency of those
proposed activities to ensure that the security system remains reliably
functional throughout the post-closure care period. For example, if a
perimeter fence is required during the post-closure care period, it will
periodically require replacement of sections as a result of normal wear,
severe weather conditions, and vandalism. Similarly, if a warning sign is
required, it will require periodic replacement.
2.3.1'.2 Name of Contact Person of Office
The post-closure plan must include the name, address and phone number of
the person or office to contact about the unit or facility during the
post-closure care period.'* This person must maintain a copy of the post-
closure plan during the post-closure care period.
2.3.1.3 Post-Closure Care Notices
Owners or operators of disposal units must submit to the Regional
Administrator or State Director and to the local le^H authority, or authority
with jurisdiction over land use, a record of the type, location, and
quantity of hazardous wastes disposed within each disposal unit.1* The
record must be filed no later than 60 days after certification of closure of
each disposal unit.
After closure of the first and last disposal unit, the owner or operator
must also record a notation on the deed to the facility property noting
that the property has been used to manage hazardous wastes, its use is
restricted, and a survey plat and record of wastes have been filed with the
appropriate local land authority and with the Regional Administrator or State
Director. The owner or operator must also submit to the Regional
Administrator or State Director a copy of the notation to the deed and a
certification signed by himself stating that the notation has been
filed." Section 3.4 provides further information on the procedural
requirements associated with filing these notices.
2.3.1.4 Post-Closure Certification
No later than 60 days after the completion of the 30-year post-closure
care period for each unit, the owner or operator must submit to the Regional
Administrator 01 State Director certifications signed by himself and an
independent registered professional engineer (or an independent qualified
soil scientist for land treatment units) stating that post-closure care has
** 40 CFR 264.118(b)(3) and 265.118(c)(3).
" 40 CFR 264.119(a) and 265.119(a).
" 40 CFR 264.119(b) and 265.119(b).
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been completed in accordance with the approved plan.3* The guidelines for
post-closure certifications and the types of information to be included in the
post-closure plan are consistent with the discussion in Section 2.2.10 on
closure certifications. The plan should indicate the types of documentation
that will be maintained at the facility and made available upon request.
The main purposes of the post-closure certification are to verify that the
post-closure care activities have been conducted in accordance with the
approved plan and to ensure that terminating the post-closure care period will
not pose a threat to human health and the environment. The independent
registered professional engineer or independent qualified soil scientist
obviously will not be able to verify that every activity has been conducted at
the specified frequency over the previous 30 years. Therefore, the
independent registered -professional engineer or independnet qualified soil
scientist should use his best judgment based on visual inspections of facility
conditions and a review of internal documents (e.g., owner or operator
inspection reports, ground-water monitoring results, invoices for maintenance
activities) to evaluate whether all post-closure care activities have been
performed adequately.
At a minimum, the owner or operator should maintain a copy of the
professional engineer's or soil scientist's inspection report and results of
any sampling and analyses or soil scientist engineer, which should include the
following information:
Activities conducted during inspections;
Field reports documenting each on-site visit; and
List of in-house records that were reviewed (e.g.,
owner's or operator's log of inspections, laboratory
results, chain of custody reports to verify that
adequate sampling was conducted, contractor's logs of
activities performed).
2.3.2 Considerations Affecting the Length of the Post-Closure
Care Period
The Subpart G regulations specify 30 years of post-closure care for each
disposal unit, but give the Regional Administrator or State Director the
authority to extend or reduce the period on a case-by-case basis. The
Regional Administrator or State Director also may temporarily extend or
reduce the length of the period or temporarily suspend certain types of
activities based on cause. In addition, the owner or operator or any member
of the public may petition the Regional Administrator or State Director to
alter the length of the post-closure care period.1'
11 40 CFR 264.120 and 265.120. (40 CFR 264.280(b) and 265.280(e) allow
closure of a land treatment unit to be certified by an independent qualified
soil scientist in lieu of an independent registered professional engineer.)
" 40 CFR 124.5(a), 265.118(g), and 27Q.41.
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The regulations do not specify the conditions that warrant an extension or
reduction of the post-closure care period. Consequently, such determinations
will be site-specific based on the facility's expected performance. For
example, the period may be reduced if leachate or ground-water monitoring
results, characteristics of the hazardous wastes, or management technologies
indicate that the hazardous waste management unit is secure. Alternatively,
the period may be extended if leachate or ground-water monitoring results
indicate a potential for migration of hazardous wastes at levels which may be
harmful to human health and the environment.48 At facilities with multiple
disposal units that are closed at different times during the facility's life,
unless each unit has its own ground-water monitoring system, the Regional
Administrator or State Director may find it appropriate to extend the length
of the post-closure care period for units previously closed, to be consistent
with the post-closure .care period for the remainder of the units.
Owners or operators must provide financial assurance to cover the
costs of 30 years of post-closure care unless the Regional Administrator or
State Director reduces or extends the length of the post-closure care period
prior to FINAL closure of the facility. Until final closure of the facility,
post-closure cost estimates and the amount of financial assurance must be
increased whenever a modification of the post-closure plan increases the cost
of post-closure care.1"1 Once final closure of the facility has been
certified, the amount of financial assurance need not be increased even if the
post-closure care period is lengthened. See Section 4.3 of this manual for a
discussion of modifications to the post-closure cost estimate. Readers should
also refer to Financial Assurance for Closure and Post-Closure Care: A
Guidance Manual. May 1982, EPA #SW-955 or NTIS #APB 82-237-595 for
information on revising financial instruments.
This section briefly presents some broad technical evaluation criteria and
site-specific technical factors that may deserve consideration when evaluating
the appropriate length of the post-closure care period. Appendix B
describes these factors in more detail and presents hypothetical scenarios
illustrating how this information might be used to support an extension or
reduction in the length of the post-closure care period at a particular
facility. This kind of supporting data could also be included in a
post-closure plan to justify a request to modify the length of the
post-closure care period. In many cases, this information may be available
from the facility Part B application. In all cases, decisions will be
determined by site-specific conditions.
Four general evaluation criteria are key to determining how well a unit
or facility will protect human health and the environment. They are:
(1) Containment - How long will the unit or facility contain hazardous
wastes after closure? The liner, cover, and cap are the key
components of the containment system. Because all containment systems
eventually fail and because many wastes degrade slowly under
containment, releases may occur after the end of the 30-year
fc° 40 CFR 264.l]7(a)(2) and 265.117(a)(2).
fcl 40 CFR 264.144(c): and 265.144(c).
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post-closure care period. The extent of contamination will depend
largely on factors such as waste types and environmental conditions.
(2) Detection - Will monitoring systems at the unit or facility detect
releases of hazardous wastes if they should occur? Lags between
leachate generation and release, and migration to the monitoring well
may delay detection.
(3) Migration and Attenuation - Will the hazardous wastes migrate off
site, or will the leachate be attenuated in the environment? The rate
it which leachate moves through the environment and the extent to
which the wastes degrade will affect the potential for contamination.
(4) Risk Potential.- What risks are posed to human health and the
environment? The likelihood of exposure and the concentration of
leachate at the point of exposure will determine the risks posed.
In addition to these four general evaluative criteria, three categories
of site-specific factors also should be examined. fhey are:
(1) Facility Characteristics - How do the type of unit (e.g., landfill vs.
land treatment), facility design (e.g., liners), operating practices,
and corrective actions required to date influence the ability of a
facility to contain wastes over a long period?
(2) Waste Types and Characteristics - Do the chemical and physical
properties of the wastes suggest that they are likely to migrate
quickly off site or be attenuated? The properties of the wastes
(e.g., degradation, solubility) will determine how widely the waste
may be dispersed in the environment and, in part, whether a release is
likely to lead to human exposure.
(3) Environmental and Health Considerations - How does the population
density, uses of ground and surface water, and present and potential
surrounding land use affect potential exposures and cumulative levels
of risks?
Appendix B applies these considerations to hypothetical facilities and
presents possible recommendations. Again, in all cases, site-specific
conditions must dictate the decisions.
2.4 DESCRIPTION OF DATA SOURCES FOR CLOSURE AND POST-CLOSURE
PLANS
This section contains descriptions of the data sources which may be useful
in preparing several components of closure and post-closure plans. These
sources include: the Part B application; the facility operating record; the
inspection log, manifests and other contracts for waste shipments;
ground-water monitoring data; the biennial report; and the Part A
application. The particular data needed to describe the individual activities
that must be included in a closure or post-closure plan will differ from
activity to activity.
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2.4.1 Part B Application
All owners or operators who are required to have a permit (with the
exception of facilities covered by permits by rule) must submit a Part B
application. All interim status facilities with land disposal units were
required to submit their Part B applications by November 8, 1985, or lose
their interim status on that date. Owners or operators of incinerators were
required to submit the Part B application no later than November 8, 1986, or
lose interim status on November 8, 1989; owners or operators of all other
types of units must submit their Part B applications by November 8, 1988, or
lose interim status on November 8, 1992.42
Information submitted with the Part B application that may be relevant to
the closure and post-closure plan includes:11'
General facility description, including location
(e.g., location in floodplain, seismic area);
Topographic map delineating surface waters,
surrounding land uses, site boundaries, all hazardous
waste units and associated buildings and ancillary
structures;
Chemical and physical analyses of hazardous wastes
handled, including the waste analysis plan;
Description of the security system;
Copy of the facility inspection schedule;
Description of procedures, structures, or equipment
used to prevent runoff, flooding, etc.; and
Ground-water monitoring information if required under
40 CFR Subpart F.
In addition to this general information, the Part B application must
contain data specific to the units being permitted as outlined in 40 CFR
270.15 through 270.21. Process-specific information includes data on design
specifications, monitoring requirements, operating, parameters, waste
characterizations, etc.
"2 RCRA 3005(c)(2) and 3005(e)(3).
kl 40 CFR 270.14
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2.4.2 Facility Operating Record
All owners and operators of TSDFs are required to maintain a written
operating record at the facility at all times until final closure** that
addresses all in-house waste management activities conducted from the time the
waste was generated or received from another facility until its ultimate
disposal or shipment off site. The operating record must be continuously
updated as each additional hazardous waste is received or handled. The
following types of information are included in the operating record:
Description of each hazardous waste handled at the
facility, its common name(s), and its EPA hazardous
waste number;
Quantity of each waste handled at all stages of
operations. If the waste generated or received is
subsequently treated, the operating record should
inr1"de the physical form and weight before and after
treatment;
Methods used to handle each type of hazardous waste
(e.g., evaporation, chemical treatment, landfilling)
including any intermediate processing steps;
Location of each hazardous waste within the facility
(e.g., for landfills, the operating record must include
a map or diagram indicating the exact location and
dimensions of each cell with respect to permanently
surveyed benchmarks, the contents of each cell, and the
location of each waste type within each cell);
Results of waste analyses; and
For land treatment facilities, application rate and
dates on which hazardous waste is applied.
2.4.3 Inspection Logs
Owners or operators must develop a written schedule and maintain it at
the facility for inspecting monitoring equipment, safety and emergency
equipment, security devices, and operating and structural equipment. In
addition, the owner or operator roust record inspections in an inspection log
or summary. Records must be retained for at least three years from the date
of inspection. The records must include at a minimum:
Date and time of inspection;
Name of inspector;
40 CFR 264.73 and 265.73.
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Notation of observations made; and
Nature of any repairs or other remedial actions.
2. 4. 4 Manifests and Other Contracts for Waste Shipments
If hazardous waste is removed to an off-site facility, these off-site
shipments must be accompanied by a Uniform Hazardous Waste Manifest.*1
Copies of these manifests must be kept on site for at least three years. The
following information may be found on the manifests:
Type and quantity of each waste included in every
shipment ;
Number and types of containers used for each waste
type;
Date of shipment;
Total quantity of all wastes included in each
shipment; and
Name, address, end EPA ID number of the designated
TSDF.
Sources of other applicable information include contract agreements with
waste transporters and TSDFs and bills of lading for off -site shipments.
2.4.5 Ground-Water Monitoring Data
Ground-water monitoring data are available from the following sources:
Ground-water sampling and analysis plan;
Ground-water monitoring results during the operating
life;
Ground-water assessment outline during the operating
life; and
Corrective action plan, if applicable.
2.4.6 Biennial Report
Generators and owners or operators of TSDFs located in States without an
authorized RCRA program must file a report recording their facility's
hazardous waste activities of the previous year on a biennial basis (once
every two years). State law may also require owners or operators to submit
k I
40 CFR 262.20, 264.71(c), and 265.71(c).
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annual or biennial reports of hazardous waste activities. The following
information is included in the biennial report -- EPA Form 8700-13A
(Generator Report) and 8700-I3B (TSDF Report):
A description of each waste that was treated or stored
for more than 90 days, or disposed of on site, during
the reporting year;
The name, address, and EPA ID number of all off-site
TSDFs used during the reporting year;
The quantity and identity of each type of waste
shipped off-site during the reporting year;
Quantity of waste shipped to each off-site facility in
the preceding year;
Total quantity of waste handled on site that was in
storage on December 31 of the reporting year;
Handling methods for all wastes handled on site,
including handling prior to off-site shipment; and
Quantity of wastes received from each generator (or
the amount generated on site and handled on site).
2.4.7 Part A Application
The Part A application contains information on the types of activities
conducted at a TSDF, the types of wastes handled, and the structures of the
facilities. The owner or operator of an interim status facility must update
the Part A application if hazardous wastes not previously identified in the
Part A application are to be handled at the facility, or if additional
processes are to be used.** Permitted facilities must submit a request to
modify their permit. The information required in a Part A application
includes the following:
Design capacity of each unit and each process at the
facility;
Topographic map of the facility indicating the
location of each waste management unit;
Scale drawing of the facility, including designation
of areas currently operating and areas of past and
future treatment, storage, and disposal activities;
k (
40 CFR 270.72(a), (b), and (c).
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Photographs of the facility clearly delineating all
existing structures and existing treatment, storage, or
disposal areas;
A description of each waste handled at the facility by
EPA hazardous waste number;
List of other environmental permits under other EPA
programs (e.g., NPDES permit under the Clean Water Act
allowing a point source discharge; ocean dumping permit
under the Marine Protection, Research, and Sanctuaries
Act) which will ensure that procedures for handling
wastes at partial or final closure are consistent with
other facility requirements.
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CHAPTER 3
PROCEDURAL AND ADMINISTRATIVE CLOSURE AND POST-
CLOSURE CARE REQUIREMENTS
This chapter describes procedural and administrative requirements that
apply to owners or operators of TSDFs. These requirements are discussed in
the following sections and include:
Section 3.1 -- Availability of plans and cost estimates;
Section 3.2 -- Closure and post-closure plan and cost
estimate review procedures and public involvement
requirements;
Section 3.3 -- Requirements for amending the closure or
post-closure plans and cost estimates;
Section 3.4 -- Closure schedule; and
Section 3.5 -- Procedures for altering the length of the
post-closure care period.
3.1 AVAILABILITY OF PLANS AND COST ESTIMATES
Owners or operators must include a copy of their closure and post-closure
plans and most recent cost estimates with their Part B applications. The
reviewed and approved plans will be incorporated as a condition of the
permit. (Cost estimtes are not part of the permit.) Owners or operators of
interim status facilities must submit their plans for approval to the Regional
or State Office prior to final closure or closure of the first disposal unit
to be closed after October 29, 1986,* whichever is earlier (see Section
3.2). In some cases, approval of the closure and post-closure plans may
precede receipt of a permit. For facilities with permits or approved plans
under interim status, the most recent approved plans should be available at
the Regional or State office.
Until final closure of the facility has been certified, copies of the
closure and post-closure plans and all plan revisions must be made available
to the Regional Administrator or State Director, or his authorized
representatives, upon request, including request by mail.* (In the case of
1 The May 2, 1986 rule (effective on October 29, 1986) required closure
plans to be submitted prior to closure of the first disposal unit. Before
the May 2, 1986 rulemaking, plans were submitted for approval prior to final
closure of the facility.
2 40 CFR 264.ll2(a)(2), 264.118(c), 265.112(a), 265.118(b).
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permitted facilities and interim status facilities with approved plans, the
plans already should be on file with EPA.) Interim status facilities without
approved plans must furnish the most current plans on the day of a site
inspection.' If an owner or operator maintains the plans at an office other
than at the facility (e.g., corporate headquarters), the owner or operator
must be certain that a copy of the most current plans can be delivered quickly
in the event of an inspection.
After final closure of the facility has been certified, a copy of the
approved post-closure care plan must be kept by the contact person or office
indicated in the plan during the remainder of the post-closure care
period.k If the contact point changes during the post-closure care period,
the owner or operator will be responsible for notifying the Regional
Administrator of the change. Because the contact is described in the
post-closure plan, a change in the name, address, or phone number during the
post-closure period will require an amendment to the plan (as a change in
operating plans) and a minor modification of the post-closure permit (40 CFR
270.42 describes requirements for minor modifications of the permit).
Until final closure, the owner or operator must keep the latest closure
and post-closure cost estimates at the facility as part of the facility
operating record.* These cost estimates must be furnished upon request and
made available at all reasonable times for inspection.' Although the
regulations do not require explicitly that the cost estimate for post-closure
care be retained after the end of the active life of the facility, an owner or
operator should retain a copy at the contact point for reference purposes.
3.2 CLOSURE AND POST-CLOSURE PLAN AND COST ESTIMATE REVIEW
PROCEDURES AND PUBLIC INVOLVEMENT REQUIREMENTS
Closure and post-closure plans oust be approved by the Regional
Administrator or State Director and are subject to public review. This
section addresses the procedures for submitting and reviewing closure and
post-closure plans and cost estimates, and describes public involvement in
these activities.
3.2.1 Review of Closure and Post-Closure Plans and Cost Estimates
by the Regional Administrator or State Director
The requirements for review of closure and post-closure plans and cost
estimates by the Regional Administrator or State Director vary depending on
whether the owner or operator of the facility is applying for a RCRA permit,
1 40 CFR 265.112(a) and 265.118(b).
* 40 CFR 264.118(c) and 265.118(b).
* 40 CFR 264.73(b)(8), 264.142(d), 264.144(d), 265.73(b)(7), 265.142(d)
and 265.144(d).
* 40 CFR 264.74(a) and 265.74(a).
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is already operating with a permit, or is operating under interim status.
Plans and cost estimates for a facility seeking a permit or a permit
modification, must be submitted to the Regional Administrator or State
Director for review in the following situations:
Closure and post-closure plans and the most recent
cost estimates, including contingent plans and
estimates, must be submitted with the Part B permit
application.7
Amended closure or post-closure plans must be
submitted with a written request for a permit
modification to authorize a change in the approved
closure or.post-closure plan (amended cost estimates
need not be submitted).*
Amended closure or post-closure plans prepared by the
owner or operator of a surface impoundment, waste pile,
or tank unit not otherwise required to have a contingent
closure or post-closure plan must be submitted following
a decision by the owner or operator or the Regional
Administrator or State Director that the unit must be
closed as a landfill.'
Amended closure or post closure plans must be
submitted in response to a request by the Regional
Administrator or State Director to modify the closure or
post-closure plans.1'
The procedures outlined in 40 CFR Parts 124 and 270 will apply to the plan
review.
Closure and post-closure plans for an interim status facility must be
submitted to the Regional Administrator or State Director for review in the
following situations: (An owner or operator of an interim status facility
is not required to submit the cost estimates for review until the Part B
application is sumbitted, or unless they are requested explicitly under the
provision of 40 CFR 265.74.)
7 40 CFR 270.14(b)(13), (15), and (16).
§ 40 CFR 264.112(c) and 264.118(d).
' 40 CFR 264.112(c)(3), 264.118(a) and (d), and 264.197(c).
le 40 CFR 264.112(c)(4) and 264.118(d)(4).
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Owners or operators of land disposal units without
approved closure and post-closure plans must submit
those plans 180 days prior to the date the owner or
operator expects to begin closure of the first land
disposal unit or final closure, whichever is earlier.
Owners or operators of facilities with no land disposal
units must submit their plans 45 days prior to final
closure. 1 1
Owners or operators of surface impoundments, waste
piles, or tanks with secondary containment who intended
to remove all hazardous wastes at closure must submit
revised plans following a decision by the owner or
operator or by the Regional Administrator or State
Director that the unit must be closed as a landfill.12
The revised closure plan must be submitted within 60
days of the determination that the unit must be closed
as a landfill (or 30 days if the determination occurs
during the closure period). The post-closure plan roust
be submitted within 90 days.
If the closure or post-closure plans h^ve been
approved, modifications to the closure or post-closure
plans must be submitted with a written request to the
Regional Administrator or State Director to authorize a
change to the approved closure or post-closure plans.11
Closure and post -closure plans must be furnished upon
request by the Regional Administrator or State
Director. Ifc
Once the Regional Administrator or State Director has received the closure
and post-closure plans for an interim status facility, he will take the
following steps:11
11 40 CFR 265.112(d)(l) and 265.118(e). Owners or operators who closed
disposal units prior to the effective date of the May 2, 1986 rules -- October
29, 1986 -- must submit their plans for approval prior to closure of the next
disposal unit or final closure, whichever is earlier.
12 40 CFR 265.112(c)(3), 265.118(a) and (d)(3) and (4), and 265.197(b).
1J 40 CFR 265.112(c) and 265.118(d).
l" 40 CFR 265.112(a) and 265.118(b).
11 40 CFR 265.112(d)(4) and 265.118(f).
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(1) Publish a newspaper notice no later than 30 days
after receiving the plans to provide an opportunity for
public comments on the plan. (The public involvement
requirements are described in more detail in Section
3.2.2.)
(2) Within 90 days after receipt of the plans, the
Regional Administrator or State Director will
approve, modify, or disapprove them.
(3) If the Regional Administrator or State Director does
not approve the plans, he must provide the owner or
operator with a detailed written statement of the
reasons. .Within 30 days after receiving the written
statements of reasons why the plan was not approved,
the owner or operator must modify the plan, or submit a
new plan for approval.
(4) The Regional Administrator or State Director will
either approve the new or modified plan within 60 days
after he receives it, or he will modify the plan. The
plan, as modified by the Regional Administrator or
State Director, then becomes the approved closure or
post-closure plan. A copy of the modified plan with a
detailed statement of reasons for the modifications
will be mailed to the owner or operator. Exhibit 3-1
provides a sample letter (and a detailed statement of
reasons) accompanying a modified closure plan.
3.2.2 Public Involvement Requirements
All closure and post-closure plans, including revisions to the plans
that are considered major permit modifications or major modifications to
approved interim status plans, are subject to public notice and
comment. * *
The purposes of the public notice and comment requirements are to:
Allow members of the public who might be affected by
the closure and post-closure care of the facility to
review and recommend changes to the closure and
post-closure plans;
14 40 CFR 124.5, 124.10, 265.112(c)(3), 265.118(d)(4), and
270.41.
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EXHIBIT 3-1
SAMPLE LETTER FROM REGIONAL ADMINISTRATOR
MODIFYING CLOSURE PLAN*
RE: Resource Conservation and
Recovery Act (RCRA)
EPA I.D. #
Dear
EPA has reviewed the closure plan submitted by
on , and .with this letter we are transmitting the modified
closure plan. Pursuant to the regulations at 40 CFR 265.112(c), this
modified plan is the approved plan and it must be implemented within the
stipulated time period. We have included in the Attachment to the Plan all
the modifications that we deemed necessary under the regulations. This
Attachment is to be treated as part of the Plan as if fully i-^grated therein.
[Summary of modifications]
EPA's major concern with the plan relates to .
The RCRA regulations require greater detail in the description of the
procedures for . The closure plan has been modified
accordingly.
Sincerely,
Regional Administrator
If the facility is in an authorized State, these requirements will be
fulfilled by the State Director instead of the Regional Administrator.
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EXHIBIT 3-1 (continued)
SAMPLE CLOSURE PLAN APPROVAL FOLLOWING
MODIFICATION BY REGIONAL ADMINISTRATOR*
CLOSURE PLAN FOR CLOSURE OF [Facility Namel
AT [Location]
The facility operator, , and the facility
owner, , submitted a proposed plan fdr the closure
of the to EPA on , as required
by the federal hazardous waste regulations. Pursuant to 40 CFR 265.112(c),
EPA has modified the proposed plan, thereby making this modified plan the
approved plan.
The facility operator must conduct the closure activities of this plan
within the specified time periods.
Approval of this plan is based on the premise that the information
submitted in the proposed closure plan is accurate and that the closure
activities will be implemented as specified in the plan.
Approval of this plan has been duly authorized by:
Director Regional Administrator
Waste Management Division
Date Date
If the facility is in an authorized State, these requirements will be
fulfilled by the State Director instead of the Regional Administrator.
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EXHIBIT 3-1 (continued)
SAMPLE PLAN MODIFICATIONS AND
DETAILED EXPLANATION*
ATTACHMENT: EPA Modifications to Closure Plan
A) The steps for cleaning the heat exchanger described on page 2 are modified
as follows:
"1. An 8 percent hydrochloric acid solution will be heated to between 160
and 180°F and circulated continuously through the exchanger for about
three hours. It will be discharged with the dissolved scale and
deposits to a storage tank supplied by the operator. The exchanger
will then be water flushed to remove acidic residues. The water will
be discharged to the storage tank."
"2. A pressure test will be conducted to verify the integrity of the
exchanger. The pressure test will be conducted by pressurizing the
exchanger to one and one-half (1.5) times the operating pressure, but
net over maximum design pressure of the tubes. Inis elevated pressure
will be held for a period of time not less than one hour. EPA will
allow a deviation of .01 percent during this test. The front plate to
the unit will be removed and visually inspected for leaks during
testing. Should the unit fail the pressure test or if visual leakage
is observed, then the unit will be dismantled and ooth sides cleaned.
The collected waste from cleaning will be handled as listed hazardous
waste K050 and shipped to an EPA approved disposal facility."
"3. A 1 percent soda ash solution will be circulated for corrosion control
to ensure that a neutral or slightly basic condition exists in the
heat exchanger."
"4. Lime will be added to the wastewater/acid solution in the storage tank
until a pH of 8.5 is reached for precipitation of trivalent chromium.
The treated waste will then be pumped and water flushed out of the
tank to the sewer (leading to the separator and pond system) where
solids will settle out in the separator. This procedure is consistent
with 40 CFR 261.3."
This modification is required for two reasons: First, the closure plan,
as submitted, did not describe how the pressure test would be conducted or the
actions that would be taken in case of failure. Second, the closure plan, as
submitted, did not provide for steps to remove scale prior to testing.
Removal of scale will allow any cracks in the tubes to be more easily noticed
and recorded.
If the facility is in an authorized State, these requirements will be
fulfilled by the State Director instead of the Regional Administrator.
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Provide procedures and deadlines for public comment on
the plans to facilitate communication between the owner
or operator, the public, and the Regional Administrator
or State Director concerning contents of the plans; and
Clarify any issues concerning the plans.
3.2.2.1 Public Involvement in the Permitting Process
For many facilities, public notice and comment on the closure and/or
post-closure plans and cost estimates will occur during the permitting
process.17 Following public notice that the draft permit is available,
interested persons will be given a minimum of 45 days to comment on the draft
permit, including the closure and post-closure plans in the permit. If
written opposition to the Agency's intent to issue a permit and a request for
a hearing are received during the comment period, a public hearing must be
held.11 The Regional Administrator may also, at his own discretion, decide
to hold a public hearing. For example, he may wish to hold a hearing if he
believes it would clarify any issue concerning the plan. Notification of the
hearing is issued at least 30 days prior to the scheduled date of the hearing,
and the public comment period is extended until the close of the public
hearing.
Public notice and comment during the permitting process is not addressed
in this guidance manual. EPA has prepared a Guidance Manual on Public
Involvement in the RCRA Permitting Program. OSWER Policy Directive Number
9500.00-1A, (herein called Guidance on Public Involvement) that outlines the
key activities during the permitting process for implementing the Agency's
policy on public involvement and provides guidance on techniques for
conducting public involvement activities. Portions of the Guidance on Public
Involvement discuss specifically the role of the public in reviewing plans
and should be referred to directly.
3.2.2.2 Public Involvement for Facilities Closing Under Interim
Status
Requirements for public notice and comment and hearings for interim
status facilities are triggered by the following circumstances:
When the owner or operator submits a closure or post-
closure plan for approval.1'
17 40 CFR 264.112(a)(l), 264.118(a), 270.14(b)(13), (15), and
(16), 124.10, and 124.11.
11 40 CFR 124.12.
" 40 CFR 265.112(d)(4), 265.118(f).
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When the owner or operator submits a request for a
major modification to the approved closure or
post-closure plan.2'
When the Regional or State office, owner or operator,
or a member of the public proposes to alter the length
of the post-closure care period.2i
Upon receipt of a closure or post-closure plan from the owner or operator,
the Regional Administrator or State Director must provide the owner or
operator and the public, through a newspaper notice, the opportunity to
submit Written comments on the closure or post-closure plan and request that
modifications to the plan be submitted no later than 30 days from the date of
the notice.22 Thirty-day public notice must also be provided when the owner
or operator requests a'major modification to the closure or post-closure plan,
or when the Regional Administrator or State Director decides that such a major
modification must be made.
The following procedures should be adopted for a newspaper notice to
ensure that adequate notice is given and an adequete record that the formal
notice was given is preserved. (Additional guidance is provided in Guidance
on Public Involvement.):
Separate notices should be published for the closure plan ar>~
the post-closure plan to avoid any possibility of a subsequent
challenge to the sufficiency of the notice, on the grounds that a
consolidated notice was confusing or lacked specificity.
The notice should be clearly labeled "Public Notice."
The notice may appear in the legal notice section of the
newspaper or some other local-events section of the newspaper,
and should be printed preferably in the lower left-hand corner of
the right-hand page.
The Regional Administrator or State Director should place the
notice in a general circulation paper published, if possible, in
the county where the facility is located.
Readers may wish to refer to Chapter 4, Section 4.5 of the Guidance on
Public Involvement which discusses various techniques for promoting the
effectiveness of a public notice and provides evaluative questions for asses-
sing the quality of the public notice. The Appendices to that manual provide
samples of different formats of both required and suggested RCRA public
2i 40 CFR 265.112(c) and 265.118(d).
21 40 CFR 265.118(g).
22 40 CFR 26S.112(d)(4) and 265.118(f).
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involvement materials. In particular, Appendix B of that guidance manual
contains sample public notices for facility closure and corrective action.
The Regional Administrator or State Director, in response to a request
or at his own discretion, may hold a public hearing.21 Thirty-day notice
of a hearing must be provided to the public. In providing notice of the
hearing, the Regional Administrator should adopt the following procedures:
If there is a strong likelihood, based on the Regional
Administrator's initial assessment of the plan and knowledge of
the degree of public interest in the plan, that a hearing will
eventually be held, the Regional Administrator should give notice
of the hearing at the same time that notice is given of the
opportunity to comment on the plan.
The notice of hearing should identify the matters to be
discussed at the hearing, with an indication of the Agency's
tentative determination (if any) concerning those matters provide
the date and place of the hearing, and explain how persons
wishing to present testimony can notify the Regional
Administrator or State Director of their intent to participate.
Examples of public hearing notices and registration forms are
included in Appendix B of Guidance on Public Involvement.
Newspaper notice of a hearing should be provided according to
the same basic procedures described previously for giving
newspaper notice of opportunity to comment.
Additional information on the types of information that should be
addressed at a public hearing and formats for scheduling hearings is included
in the Guidance on Public Involvement. In addition, the reader should refer
to a U.S. Department of Justice Technical Assistance Guide (TAG) for
instructions on accommodating the mobility, hearing, and visually impaired as
required by the Rehabilitation Act. The TAG is comprised of three sections:
(1) Access to public meetings, (2) Assistive Listening Devices, and (3) Access
to printed information by visually impaired persons.2*
2 >
40 CFR 265.112(d)(4), 265.118(f), and (g).
2k TAG-5-85-1 specifies, for example, the steps to ensure the hearing
impaired recieve notification of public hearings, the number and
qualifications of interpreters and signers that should be provided, facility
conditions that would render the interpreters and signers most effective,
special instructions for formatting printed materials, facility lighting
specifications, instructions for those delivering oral presentations,
recommendations for seating arrangements, and extra personnel that may be
necessary. TAG-5-85-2 describes various types of Assistive Listening Devices
(ALDs) used as alternatives to conventional amplification systems. TAG-5-85-3
discusses how to accommodate the visually impaired person by adjusting
specific printing factors that affect the readability of printed material
(e.g., type size, type selection, line leading, proportional spacing and
hyphenation, columns, paragraphs, contrast and color, finish, and color
screens and reversals).
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3.3 REQUIREMENTS FOR AMENDING CLOSURE OR POST-CLOSURE
PLANS AND COST ESTIMATES
Owners or operators rnust amend closure or post-closure plans and cost
estimates as necessary to remain consistent with facility conditions. This
section describes:
The factors specified in the regulations that require
amendments to the plans and cost estimates;
When amendments to the plans and cost estimates must
be made; and
The procedures to be followed.
3.3.1 Changes that Require Amendments to Plans and Cost Estimates
Owners or operators must amend closure and post-closure plans if:zs
(1) A change in operating plans or facility design
affects the closure or post-closure plan, or
(2) An unexpected event occurs while conducting partial
or final closure activities, that affects the closure
plan, or
(3) An unexpected event occurs during the active life,
including partial and final closures, that affects .the
post-closure plan, or
(4) There is a change in the expected year of closure
for facilities required to include an expected closure
date in the closure plan.
Chapter 4 discusses the conditions under which the cost estimates must be
revised.
The following are examples of changes in facility design or operation
that would require a revision to the closure or post-closure plan:
Increases in facility size and/or capacity;
Changes in the partial closure schedule (e.g., an
owner or operator partially closes a landfill less
frequently than originally intended, thus increasing the
maximum extent of the operation);
as 40 CFR 264.112(c)(2), and 264.118(d)(2), 265.112(c)(1), and
265.118(d)(l).
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Increases in the estimate of maximum inventory;
Changes in regulatory requirements that affect closure
or post-closure care activities (e.g., new treatment
standards imposed as a prerequisite for landfilling
certain wastes);
Shifts from on-site to off-site disposal of wastes at
closure;
Requirements for more extensive ground-water
monitoring as a result of an owner's or operator's
operating experience or the availability of new data
that were previously unavailable (e.g., increases in the
number of samples taken or in the frequency of sampling);
Contingencies that arise during the active life or the
post-closure care period that affect the types of
activities that will be required at closure or during
the post-closure care period (e.g., as a result of a
spill, more contaminated soil removal will be necessary
at closure);
extensions or reductions to the length of the
post-closure care period for one or more units;
Changes in routine post-closure maintenance
activities, including changes in the nature and
frequency of the activities required (e.g., a moie
extensive erosion control program is required); and
Changes in surrounding land use (e.g., an increase in
population density surrounding the facility warrants
increased security provisions during the post-closure
care period; expanded ground-water monitoring
requirements due to a change in how the underlying
ground water is used).
If an unexpected event occurs while performing partial or final closure
activities which affects the closure plan, or if an unexpected event occurs
which affects the post-closure plan, the owner or operator must revise the
plans.2' For example, if an owner or operator of a storage surface
impoundment, waste pile or tank unit not otherwise required to prepare a
contingent plan cannot remove ALL wastes at closure, he must close the unit
as a landfill, and amend the closure plan to reflect this unexpected event.
In addition, the owner or operator must prepare a post-closure plan.
2 (
40 CFR 264.112(c)(2), 264.118(d)(1), 265.112(c) (1) , and 265.118(d)(1)
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3.3.2 Deadlines for Amending Plans and Cost Estimates
The regulations establish four deadlines for amending closure or
post-closure plans and cost estimates:
(1) For both permitted and interim status facilities with plans approved
prior to final closure, requests to amend the closure plan may be made at any
time prior to the notification of partial or final closure of the
facility.27 Requests to amend the post-closure plan may be made at any time
during the active life of the facility or during the post-closure care
period.2'
(2) Requests to revise the plans must be made at least 60 days PRIOR to a
change in facility design or operation or no later than 60 days AFTER an
unexpected event occurs which affects the plans.2' If the unexpected event
occurs during the partial or final closure period and affects the closure
plan, the request to modify the closure plan must be made no later than 30
days AFTER the event has occurred."
(3) If an owner or operator of a storage surface impoundment, waste pile,
or tank not otherwise required to prepare a contingent closure plan must close
the unit as a landfill, he must submit an amended closure plan to the Regional
Administrator.31 If closure has not yet begun, the amended plan must be
submitted no later than 60 days after the date that it is determined that the
unit must be closed as a landfill. If the determination is made during
partial or final closure, the amended plan must be submitted no later than 30
days from the date of the determination that the unit must be closed as a
landfill. An owner or operator must also prepare and submit a post-closure
plan for approval no later than 90 days after the date it is determined that
"clean closure" is not practicable and that the unit must be closed as a
landfill.12
27 40 CFR 264.112(c)(l) and 265.112(c).
21 40 CFR 264.118(d)(l) and 26S.118(d).
2> 40 CFR 264.112(c)(3), 264. 118(d) (3) , and 265 . 112(c) (2) , and
265.118(d)(3).
i o
40 CFR 264.112(c)(3) and 265.112(c)(3).
J1 40 CFR 264.112(c)(3), 264.197(c), 265.112(c)(3) , and 265.197(c). The
decision to close an interim status unit as a landfill constitutes a change in
facility operations which requires an amendment to the plans under
265.112(c)(3).
3 2
40 CFR 264.118(d)(3), 264.197(b), 265.118(d)(3), and 265.197(b).
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t>) Cost estimates must be revised if a modification to the closure or
post-closure plan increases the cost estimate. For interim status facilities
without approved plans, the cost estimates must be revised no later than 30
days after a revision has been made to the closure or post-closure plan. For
a permitted facility or an interim status facility with an approved plan, the
cost estimates must be revised no later than 30 days after the Regional
Administrator has approved a request to modify the closure or post-closure
plan."
3.3.3 Procedures for Amending Plans and Cost Estimates
The procedures for amending closure and post-closure plans and cost
estimates differ depending on whether the facility is permitted or has interim
status.
For permitted facilities, the approved closure and post-closure plans
(but not the cost estimates) become conditions of the RCRA permit.
Therefore, amendments to the plans require a permit modification. For
interim status facilities with approved plans, the owner or operator must
obtain approval from the Regional Administrator or State Director to amend
the plans."* In both cases, the owner or operator must take the following
steps:1S
(1) Submit a written request to the Regional Administrator
or State Director for a permit modification to
authorize a change in the approved closure or
post-closure plan (or for approval to amend the plans
for interim status facilities) in accordance with the
deadlines listed in Section 3.2.2;
and
(2) Include in the written request a copy of the amended
closure plan or the amended post-closure plan for
approval by the Regional or State Office.
The Regional Administrator or State Director will approve, disapprove, or
modify the amended plan and, for permitted facilities, modify the permit in
accordance with the procedures in 40 CFR Parts 124 and 270.
For interim status facilities without approved plans, the owner or
operator must amend the closure and post-closure plans as required to keep
those plans up to date. The amendments need not be submitted to the Regional
Administrator or State Director unless requested.
11 40 CFR 264.142(c), 264.144(c), 265.142(c), and 265.144(c).
Jk 40 CFR 265.112(c) and 265.118(d).
JS 40 CFR 264.112(0 and (c)(3), 264.118(d) and (d)(3), 265.112(c) and
(O(3), and 265.118(d) and (d)(3).
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Owners or operators of both permitted and interim status facilities must
revise their cost estimates to be consistent with the most recent plans but
are not required to modify their permits or obtain prior approval from EPA.
3.4 CLOSUR-E SCHEDULE
The closure plan must contain a schedule of closure activities showing the
total time required to close each hazardous waste management unit and the time
required for intervening closure activities." The regulations also
establish procedures that an owner or operator must use to apply for variances
or extensions of time if unusual circumstances or events make it impossible to
meet the standard closure schedules. Both the activities that occur under a
standard closure schedule and the deadlines that can be extended through a
variance or extension are described in the subsections that follow. Appendix
A illustrates graphically through the use of timeline? the deadlines that
apply to closure of the various types of hazardous waste management units.
3.4.1 Receipt of Final Volume of Hazardous Wastes
Closure must begin no later than 30 days after receipt of the final
volume of hazardous wastes. However, if the owner or operator can show that
there is a "reasonable possibility" that the unit will receive additional
volumes of hazardous wastes, closure may be delayed until no later than one
year after receipt of the most recent volume of hazardous wastes.17 The
Regional Administrator or State Director also may extend the deadline past one
year on a case-by-case basis if the owner or operator can demonstrate to the
Regional Administrator or State Director that:1*
(1) the hazardous waste management unit has the capacity
to receive additional wastes and
(2) the owner or operator has taken and will continue to
take steps to prevent threats to human health and the
environment, including compliance with all applicable
regulations.
Among the factors that should be taken into account are the following:
Unit or facility characteristics (e.g., capacity,
operating conditions);
Demand for the facility, including the presence or
absence of potential disposers (e.g., contracts for
disposal at the facility, operating plant with on-site
disposal needs);
'* 40 CFR 264.112(b)(6) and 265.112(b)(6).
J7 40 CFR 264.112(d)(2') and 265 .112(d) (2).
j i
40 CFR 264.112(d)(2) and 265.112(d)(2).
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Owner's or operator's business plans (e.g., sales of
necessary equipment, plans to cease business operation);
and
History of facility operations (e.g., compliance
records, business cycles).
Exhibit 3-2 shows how some of these factors may help to determine whether the
receipt of the final volume of hazardous wastes has occurred, or whether a
"reasonable possibility" exists of receipt of additional hazardous wastes.
3.4.2 Notification of Closure
Exhibit 3-3 summarizes the deadlines for notifying the Regional or State
Office of the intent to close a unit or facility." An owner or operator of
a permitted facility or an interim status facility with a previously approved
closure plan, must notify the Regional Administrator or State Director of
his intent to begin closure of a hazardous waste surface impoundment, waste
pile, landfill, or land treatment unit, at least 60 days before closure is
scheduled to begin. If final closure involves a disposal unit, 60-day
notice is also required. No notification is required for partial closures
involving only container storage, tank or incinerator units. Final
closure involving only non-disposal units requires 45 days notice.
An owner or operator of an interim status facility without an approved
plan must submit the closure and post-closure plans at least 180 days prior to
closure of the first disposal unit closed after October 29, 1986, or final
closure, whichever is earlier. If the facility has no disposal units to be
closed after October 29, 1986, an owner or operator must submit the closure
plan for approval at least 45 days prior to the beginning of FINAL closure.
An owner or operator may remove hazardous wastes or decontaminate or dismantle
equipment at any time before or after notification of partial or final
closure.*" For example, an owner or operator may remove liquids from an
impoundment prior to notifying EPA of closure or, for interim status
facilities, of submitting the plan for final approval.
No specific form is required for notification of closure. A sample notice
format, including the minimum data requirements of 40 CFR 264.112(d) and
265.112(d), is provided in Exhibit 3-4.
3.4.3 Completion of Closure Activities
Owners or operators must treat, remove from the unit or facility, or
dispose of on-site all hazardous wastes within 90 days after receiving the
final volume of hazardous wastes in accordance with the approved closure
l* 40 CFR 264.1l2(d)(l), 265.112(d)[2), and 265.118(e).
fc" 40 CFR 264.112(e) and 265.112(«).
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OSWER Policy Directive
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EXHIBIT 3-2
RECEIPT OF FINAL VOLUME OF HAZARDOUS WASTES
FACTORS SUGGESTING RECEIPT OF
FINAL VOLUME OF HAZARDOUS WASTES
FACTORS SUGGESTING "REASONABLE
POSSIBILITY" OF RECEIPT OF ADDITIONAL
HAZARDOUS WASTES
No additional capacity in unit or
facility
Termination of contracts with
generators
Sale by owner or operator of equip-
ment, land, or other necessary fac-
tors for operation
Unit or facility will require exten-
sive rebuilding or retrofitting
before additional hazardous wastes
could be received
On-site generator has terminated
operations
Additional capacity available in unit
or facility
Contract or contract negotiations
for continu0^ion of disposal service
Sale or potential sale of closed
plant to another operator
Record of previous downtimes in
certain months of year
On-site generator can show plan to
reopen closed plant
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EXHIBIT 3-3
NOTIFICATION REQUIREMENTS
OSWER Policy Directive
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FACILITY TYPE
NOTIFICATION DEADLINE
(1) Permitted Facilities and Interim Status
Facilities With Previously Approved Plans
(a) Partial Closures '
Disposal Unit
Nondisposal Unit
(container storage, tank, or
incinerator)
(b) Final Closure
Disposal Unit
Nondisposal Unit
60 days notice
No notification required
60 days notice
45 days notice
(2) Interim Status Facilities Without
Approved Plans
(a) Partial Closures
Disposal Unit
Nondisposal Unit
(b) Final Closure
Disposal Unit
Nondisposal Unit
180 days notice and
submittal of closure and
post-closure plans
No notification required
180 days notice and
submittal of closure and
post-closure plans
45 days notice and
submittal of closure plans
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EXHIBIT 3-4
SAMPLE FORMAT FOR NOTIFICATION OF CLOSURE
Regional Administrator
US EPA, Region
City, State
I am the [owner or operator] of the following hazardous waste management
facility [or facilities]:
[Insert name, address, and EPA identification number of each facility]
This letter provides notice, as required under 40 CFR 264.112(d) and
265.112(d), that I intend to begin closure of the (t^pe of facility or unit,
e.g., surface impoundment, waste pile, etc.] [facility or unit) on [date] .
[signature of owner or operator]
[datej
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plan or, for interim status facilities, within 90 days after approval of the
closure plan, whichever is later.kl Partial or final closure must be
completed within 180 days after receipt of the final volume of hazardous
wastes.*2 An owner or operator may be granted an extension to either of
these deadlines if he submits a request to the Regional Administrator or State
Director at least 30 days prior to the expiration of the 90- or 180-day
periods. Alternatively, requests for extensions may be incorporated into the
original closure plan (or subsequent modifications to the plan) or Part B
application. In requesting an extension, the owner or operator must
demonstrate that:*'
The partial and final closure activities will, of necessity,
take longer than 90 or 180 days to complete, or
The hazardous waste management unit or facility has the
capacity to receive additional hazardous wastes; and
He or another person is likely to recommence operation of
the hazardous waste management unit or facility within one
year; and
Closure of the hazardous waste management unit or facility
would be incompatible with continued operation of the site;
AND
He is complying with all applicable permit requirements.
The following examples of facility conditions could warrant extensions to
the closure deadlines:
More time is required to complete land treatment.
Closure does not typically, if ever, coincide with the
cessation of all treatment processes, which often take
several years to complete. During closure, the owner or
operator must continue the waste degradation,
transformation, or immobilization process until a final
vegetation cover can be placed. Depending on site-
specific processes or environments, the appropriate time
period before establishing the vegetation cover could
exceed 180 days; or
More time is required for waste processing activities,
such as evaporation or neutralization.
41 40 CFR 264.113(a) and 265.113(a).
42 40 CFR 264.113(b) and 265.113(b).
43 40 C7R 264.113(a)(l) and v'2), 264 . 113(b) (1) and (2), 265.113(a) (1)
and (2j, and 265.113(b) (1) and (2).
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The owner's or operator's operating log may be one of the best sources
available to support the claim that an extension to the closure deadline is
needed. The operating log must record the date of storage, treatment, and
disposal of all wastes at the facility and thus would document the length of
time required to complete routine treatment practices.
3.4.4 Submittal of Closure Certification
Certification of closure of each hazardous waste surface impoundment,
waste pile, land treatment, and landfill unit must be submitted within 60 days
of completion of closure of each unit. Certification of container storage,
tanks, and incinerator units must be submitted within 60 days of completion
of FINAL closure. Although certification of the non-disposal units may be
delayed until final closure or closure of the next disposal unit, the owner or
operator must be able to demonstrate that closure was in accordance with the
approved plan (see Section 2.2.10).
Certifications must be signed by the owner or operator and by an
independent registered professional engineer. (The owner or operator and
the independent registered professional engineer may either both sign the same
certification, or submit separate documents.) Examples of closure
certifications by the owner or operator and by the independent registered
professional engineer are provided in Exhibits 3-5 and 3-6. Similar documents
could be used for post-closure care certifications. Documentation supporting
closure and post-closure care certifications (e.g., inspection reports, and
quality assurance/quality control demonstrations) need not be submitted with
the certifications, but must be retained by the owner or operator and be made
available to the Regional Administrator or State Director upon request.
Documentation must be retained until the owner or operator has been released
from the financial assurance requirements.**
3.4.5 Submittal of Survey Plat
A survey plat must be submitted to the Regional Administrator or State
Director and to the local zoning authority, or the authority with jurisdiction
over local land use, for each land disposal unit no later than the submittal
of the closure certification (i.e. within 60 days of completion of closure
of each unit) (see Section 2.2.9).*1
3.4.6 Submittal of Record of Wastes
No later than 60 days after certification of closure of each hazardous
waste disposal unit, the owner or operator must submit to the local zoning
authority, or authority with jurisdiction over local land use, and to the
Regional Administrator or State Director a record of the type, location, and
quantity of hazardous wastes within each unit. For hazardous wastes that
** 40 CFR 264.115, 265.115, 264.120 and 265.120.
*' 40 CFR 264.116 and 265.116.
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EXHIBIT 3-5
SAMPLE OWNER OR OPERATOR
CLOSURE CERTIFICATION
The undersigned, (Name of Owner or Operator) ,
a (1) Corporation, incorporated under the laws in the State of
and licensed to do business in , or (2) (Partnership,
Individual. Municipality or Other Entity), with its principal place of
business at
(Address) , which formerly owned or
operated a hazardous waste (Description of Hazardous Waste Activity) (herein-
after "Facility") known as (Name of Hazardous Waste Facility) and
located at (Location)
in County, (State) , has completed and
permanently ceased the active operation of the facility and has fully
implemented all measures relating to the closure of the facility as set forth
in the Closure Plan approved by (Region or State) for said facility.
NOW, THEREFORE, I (we) (Name of Owner/Operator)
hereby swear and affirm that the above-named hazardous waste facility has been
closed in accordance with the facility's Closure Plan approved in writing by
(name of Regional Administrator or State Director) on ,
19 , that all measures relating to the closure of the facility required by
the Closure Plan and the rules and regulations of (regulatory citation) have
been fully implemented, and that to the best of my (our) knowledge, no
violations continue to exist that may have arisen prior to closure.
(Signature)
(Title)
(Address)
Taken, sworn and subscribed before me, this
day of A.D. 19
(Notary)
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EXHIBIT 3-6
SAMPLE INDEPENDENT REGISTERED
PROFESSIONAL ENGINEER
CLOSURE CERTIFICATION
I,
(Name)
Professional Engineer registered pursuant to the Professional Engineers
Registration Law, , hereby certify that I have reviewed the
Closure Plan for the (Type of Facility)
at
(Name of Hazardous Waste Facility)
(Location)
("facility"),
located at
that I am familiar with' the rules and regulations of (regulatory citation)
pertaining to closure of such facility, and that I personally have made visual
inspection(s) of the aforementioned facility, and that the closure of the
aforementioned facility has been performed in full and complete accordance
with the facility's closure plan approved in writing by (Regional
Administrator or State Director) on , 19 , and the
rules and regulations of (regulatory citation).
(Date)
(Signature)
(Professional Engineering License Number)
(Business Address)
(Seal)
(Telephone Number)
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were disposed of before January 12, 1981, the owner or operator must identify
the type, location and quantity of the hazardous wastes to the best of his
knowledge and in accordance with any records that he has kept.*'
3.4.7 Submittal of Deed Notation
Within 60 days of certification of closure of the FIRST and LAST
hazardous waste disposal unit, the owner or operator must record a notation,
in accordance with State law, on the deed to the facility property (or on
some other instrument such as a restrictive covenant or easement which is
normally examined during title search) that states that hazardous wastes have
been disposed on the property and that property use is restricted under 40 CFR
Subpart G regulations. The deed notice must also indicate that a survey plat
and record of waste have been filed.*"7 The owner or operator may also wish
to notify any current holders of easements to ensure that they are aware of
the restrictions on the property.
Each state has some form of recording statute that provides for the
maintenance in each county of a permanent public record of land titles and
other legal interests in land. The record is usually kept in an office at the
county seat known as the County Recorder's Office, the County Clerk's Office,
the Circuit Court Clerk's Office, the County Registrar's Office, or the Bureau
of Land Records. The public record of title documents is different from the
central file of property records maintained by most lc,cal land use
authorities. Because title documents differ by locality, the form of the
notice can be expected to vary from State to State and even within States.
Exhibit 3-7 provides a sample deed notice. At a minimum, the notation on the
title document should include:
the owner's name and address;
the address and legal description of the property;
a reference to the use of the property as a hazardous
waste disposal facility;
the date the facility began to receive hazardous
wastes;
a reference to the Subpart G land use restrictions;
the need for all future purchasers and lessees of the
property to inform themselves concerning the
requirements of the federal regulations and the types
and locations of wastes on the property;
*' 40 CFR 264.119(a) and 265.119(a).
47 40 CFR 264.119(b)(l) and 265.119(b)(1).
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EXHIBIT 3-7
SAMPLE NOTICE IN DEED
TO WHOM IT MAY CONCERN:
I, (owner or operator) the
undersigned, of
(street address) , City of
, County of , State of
, hereby give the following notice as required
by 40 CFR 264.119 or 265.119:
1. I am, and since , 19 have been in possession of the
following described lands (legal description)
2. Since , 19 , I have disposed of hazardous chemical
wastes under the terms of regulations promulgated by the United States
Environmental Protection Agency on/in the above-described land.
3. The future use of the above-described land is restricted under the
terms of 40 CFR Subpart G: the post-closure use of the property must never be
allowed to disturb the integrity of either the containment system or the
facility's monitoring system, unless the Regional Administrator or State
Director determines that the proposed use (1) will not increase the potential
threat to human health or the environment, or (2) is necessary to reduce the
threat to human health or the environment.
4. Any and all future purchasers of this land should inform themselves of
the requirements of the regulations and ascertain the amount and nature of
wastes disposed of on/in the above-described property.
5. I have filed a survey plat with the (name and address of local land
authority) and with the Regional Administrator of EPA, Region # (or State
Director, State of ), at (address of Regional Administrator
or State Director) showing the location and dimensions of landfill cells and
a record of the type, location and quantity of waste disposal within each area
of the facility.
Signed:
(owner or operator) date
(notary public) date
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a reference to the survey plat and record of waste in
the files of a (specifically named) local land use
authority pursuant to §§264.119 and 265.119; and
notarized signature of the owner or operator.
Local recording requirements also vary from jurisdiction to jurisdiction
across the country. Some jurisdictions will allow re-recording of an amended
instrument with a note on the first page that refers to the changes made.
Other jurisdictions require that a wholly new deed be recorded if more than a
mere correction is intended. To find out what the local requirements are for
a recording notice on a deed, owners or operators should contact the local
deed recorder, usually located in the city or county clerks office of the city
or county where the property is located.
The owner or operator must submit to the Regional Administrator or
State Director a certification signed by himself, stating that he has
recorded the deed notation, and include a copy of the document in which the
notation has been placed.fci Exhibit 3-8 is an example of an owner's or
operator's certification.
Under some limited circumstances, an owner or operator may wish to remove
hazardous wastes from the disposal unit after closure. If he so chooses, he
must request a modification to the post-closure permit in accordance with the
applicable requirements in 40 CFR 124.5, 270.41, and 270.42. For facilities
with interim status, the owner or operator must request a modification to the
approved post-closure plan, in accordance with the provisions of
§265.118(g)."' In addition, he must demonstrate that the removal of
hazardous wastes is necessary to the proposed use of the property and will not
increase risks at the facility, or is necessary to reduce risks.*" If the
owner or operator is granted approval to remove all hazardous wastes, he may
request that:s*
the notation on the deed indicating that the land has
been used as a disposal facility be removed; or
a notation to the deed or instrument indicating the
removal of the hazardous waste be added to the notice.
3.4.8 Release from Financial Assurance
Within 60 days after the Regional Administrator or State Director receives
certification of final closure of a facility and certification of the
completion of the post-closure care period for each unit, the Regional
Administrator or State Director will notify the owner or operator that either:
fct 40 CFR 264.119(b)(2) and 265.119(b)(2).
k> 40 CFR 265.119(c) and 265.119(c).
*' 40 CFR 264.117(c) and 265.117(c).
11 40 CFR 264.119(c) and 265.119(c).
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EXHIBIT 3-8
SAMPLE CERTIFICATION OF DEED NOTICE
I (owner1 or operator name) of the hazardous waste facility located
at (complete address) , certify that a
notation on the deed to the facility has been recorded, as required by 40 CFR
264. H9(b) (2) or 265.119(b)(2), at the (town, city, or county) recorder
of deeds, located at ' (complete address) ,
on (date of recording). A certified copy of the document in which the
recorded notice has been placed is attached.
signed:
(owner or operator) date
(notary public) date
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1) he is no longer required to maintain financial assurance
for final closure or post-closure care, whichever is
applicable, or
2) he is not being released from the financial
responsibility requirements because closure or
post-closure care has not been completed in accordance
with the approved plans.
If the owner or operator is not being released from the financial
responsibility requirements, he will receive a detailed written statement from
the Regional Administrator or State Director which explains why he believes
that closure or post-closure care has not been conducted in accordance with
the approved closure or post-closure plan.*2
3.5 PROCEDURES FOR ALTERING THE LENGTH OF THE POST-CLOSURE
CARE PERIOD
The post-closure care period for each hazardous waste management unit
begins immediately after completion of closure of the unit and continues for
30 years after that date.53 The post-closure care period may be extended
or shortened at the discretion of the Regional Administrator or State
Director, based on whether an extended period is necessary, or a reduced
period is sufficient, to protect human health and the environment. Section
2.3.2 and Appendix B discuss factors that may deserve consideration in
evaluating the length of the post-closure care period. The post-closure care
period for a hazardous waste management unit can be lengthened or
shortened:s k
at any time preceding closure of the hazardous waste
disposal unit;
at any time preceding final closure; or
at any time during the post-closure period for the
hazardous waste disposal unit.
42 40 CFR 264.143(i), 264.145(i), 265.143(h), and 265.145(h).
13 40 CFR 264.117(a)(l) and 265.117(a)(1).
S4 40 CFR 264.!17(a)(2) and 265.117(a)(2).
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CHAPTER 4
INSTRUCTIONS FOR PREPARING CLOSURE
AND POST-CLOSURE COST ESTIMATES
Owners and operators must prepare detailed written estimates of the
current costs of closing their facilities and, for disposal facilities, the
costs of monitoring and maintaining them after closure.1 The cost
estimates must be based on the activities described in the closure and
post-closure plans. These cost estimates are used to determine the level of
financial assurance required.
This chapter discusses the assumptions to be used in developing estimates
as follows:
Section 4.1 -- Applicability of cost estimating
requirements;
Section 4.2 -- Basic rules for preparing cost
estimates;
Section 4.3 -- Revising cost estimates to refle__
changes in closure and post-closure plans;
Section 4.4 -- Annual adjustments for inflation; and
Section 4.5 -- Documentation for cost estimates.
This chapter supplements the information included in Guidance Manual:
Cost Estimates for Closure and Post-Closure Plans (Subparts G and H)
(hereinafter referred to as Cost Estimate Guidance Manual), EPA
#530-SW-86-036, OSVER Policy Directive Number 9476.00-6. That document
includes sample worksheets outlining the cost components that should be
included in a closure or post-closure cost estimate for various process
types. In addition, that document presents unit costs (or ranges of costs)
for each of the activities.
4.1 APPLICABILITY OF COST ESTIMATING REQUIREMENTS
Exhibit 4-1 summarizes the applicability of the cost estimating
regulations as follows:
(1) Owners or operators of ALL TSDFs with the exception
of Federal or State government agencies, must prepare
closure cost estimates based on the closure plans.2
1 40 CFR 264.142(a), 264.l44(a), 265.142(a), and 265.144(a).
2 40 CFR 264.140 and 265.140.
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APPLICABILITY OF CLOSURE AND POST-CLOSURE COST ESTIMATES
OSWER Policy Directive
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o
-n
i
3D
Process Type
Permitted facilities
Coma iner
Tank with secondary containment
Tank without secondary containment
IncInerator
LandfiI I
Land treatment
Disposal surface impoundment
Storage or treatment surface Impoundment:
satisfies liner design standards
Storage or treatment surface impoundment:
does not satisfy liner design standards
Waste pile: satisfies liner design
standards
Waste pile: does not satisfy liner
design standards
Interim Status Facilities
Container
Tank with secondary containment
Tank without secondary containment
Incinerator
Landfi11
Land treatment
Disposal surface Impoundment
Storage or treatment surface Impoundment
Waste pile
Closure
Cost Estimate
X
X
x»
X
X
X
X
X
Cont ingent
Closure
Cost Estimate
X
X
X»
X
X
X
X
X
X"
.Post-Closure Cost Estimate^
Required only if it is determined prior to
certification of final closure that the unit mur
be closed as a landfill.
X
X
Required only if it is determined prior to the
certification of closure that the unit must be
closed as a landfill.
Required only if it is determined prior to the
certification of closure that the unit must be
closed as a landfill.
Required only if it is determined prior to
certification of final closure that the unit must
be closed as a landfill
X
X
Required only if it Is determined prior to the
certification of closure that the unit must be
closed as a landfiI I.
Required only if it is determined prior to the
certification of closure that the unit must be
closed as a landfi I I .
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(2) Owners or operators of ALL facilities with disposal
units must prepare estimates of the costs of conducting
30 years of post-closure care based on the post-closure
plan. Disposal units include landfills, land
treatment, and disposal surface impoundments.
(3) ALL owners or operators of surface impoundments, waste
piles, and tanks required to prepare contingent
closure and post-closure plans must prepare closure
and post-closure cost estimates consistent with the
contingent plans.1 Owners or operators of tanks
must prepare a closure cost estimate consistent with
the contingent closure plan if those costs are higher
than the costs of "clean closure".* (See Section
2.1.3 of this manual for further discussion on
contingent plans.)
(4) Owners or operators of ALL storage or treatment
surface impoundments, waste piles, or tanks not
otherwise required to prepare contingent plans and
cost estimates must revise the closure cost estimate
and prepare a post-closure cost estimate if it is
determined prior to the certification of final closure
that the unit must be closed as a landfill.1
4.2 BASIC RULES FOR PREPARING COST ESTIMATES
The following sections describe the assumptions that should be used when
preparing closure and post-closure cost estimates:
Section 4.2.1 -- Relationship between the closure and
post-closure plans and cost estimates;
Section 4.2.2 -- Scope of the closure cost estimate;
Section 4.2.3 -- Scope of the post-closure cost
estimate;
Section 4.2.4 -- Inclusion of ground-water monitoring
costs in cost estimates;
1 40 CFR 264.228(c) and 264.258(c).
* 40 CFR 264.197(c) and 265.197(c).
* 40 CFR 264.112(c), 264.118(a) and (c), 264.197(b), 265.112(c),
265.118(a) and (d), and 265.197(b).
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Section 4.2.5 -- First- vs. third-party costs; and
Section 4.2.6 -- Disallowance of salvage value and zero credit
for sale of hazardous wastes.
4.2.1 Relationship Between the Closure and Post-Closure Plans
and Cost Estimates
The closure and post-closure cost estimates must be based on activities
described in the closure and post-closure plans (or contingent plans).
Exhibit 4-2 lists the key activities that must be included in the closure and
post-closure cost estimates. Closure and post-closure cost estimates must
include a cost for each activity or sub-activity outlined in the closure and
post-closure plans. The cost components included in the cost estimate
should correspond to the activities described in the plan.
The cost estimates may be prepared on a per-unit basis or for the whole
facility. Appendix C of this manual includes sample closure and post-closure
p^an checklists prepared on a per-unit basis that may be useful in identifying
cost components to include in the cost estimates. The Cost Estimate Guidance
Manual also presents costs on a per-unit basis. Owners or operators of
facilities with multiple units may prefer to estimate certain costs (e.g.,
final cover installation, incineration of inventory, removal of wastes from an
impoundment) on a per-unit basis and others on a facility-wide basis (e.g.,
ground-water monitoring, testing for soil contamination, removal of
contaminated soil and residues, decontamination of facility equipment and
structures, and certification of final closure).
4.2.2 Scope of the Closure Cost Estimate
The closure cost estimate should reflect the costs of conducting closure
in the year that the estimate is prepared. Annually thereafter, the owner
or operator must update this estimate for inflation either by using an
inflation adjustment factor, or by recalculating the cost estimate based on
current costs of that year (see Section 4.4).
The closure cost estimate must be based on the most expensive cost of
closure at any time over the life of the facility.' The closure cost
estimate should always be high enough to ensure that if, at any time, the
facility had to begin closure, the costs of closure would not exceed the cost
estimate. For example, the cost estimate must account for the costs of
managing the maximum inventory over the life of the facility, including the
costs of constructing a new cell to handle the wastes, if necessary, if the
wastes are to be disposed on-site, and closing the maximum number of cells of
a landfill even open, including those no longer receiving wastes but not yet
completely closed. The conditions on which the cost estimate is predicated
may differ significantly from the conditions anticipated at the end of normal
facility life.
40 CFR 264.142(a)(l) and 265.142(a)(1).
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EXHIBIT 4-2
KEY ACTIVITIES TO BE INCLUDED IN THE CLOSURE
AND POST-CLOSURE COST ESTIMATES
ACTIVITIES
CLOSURE
POST-CLOSURE CARE
Inventory management
- transportation to off-site TSDF
- on-site treatment or disposal
Facility decontamination
Monitoring activities
Final cover installation
Maintenance of security
Survey plat
Closure certification
Monitoring
Leachate management
Routine maintenance
Filing post-closure notices
Maintenance of security
Post-closure certification
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4-6 OSWER Policy Directive
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In some cases, owners or operators may intend to expand the capacity or
capabilities of the facilities by constructing new hazardous waste management
units or expanding existing ones. The cost estimate must equal the maximum
costs of closing all units currently active at the facility. If an owner or
operator does not close units prior to expanding or constructing new ones, the
maximum extent of operation over the life of the facility will be
significantly greater than at the time the cost estimate was first prepared
and subsequently updated. Owners and operators must revise their cost
estimates whenever the cost of closing the units currently active at the
facility increases. When new units are constructed or existing units are
expanded, the cost estimate must be increased within 60 days prior to the
initial receipt of hazardous waste at the new (or expanded) unit.
The cost estimate need not include the costs of responding to highly
unusual contingencies unless such circumstances apply at the time the owner or
operator prepares the initial cost estimate. For example, the cost estimate
need not account for costs resulting from the effects of the 100-year flood or
a liner failure that requires all hazardous wastes in a trench to be dug up
and disposed elsewhere. If such an event occurs during the life of the unit
or facility, thus causing the original maximum inventory estimate to be
exceeded, the owner or operator should revise the closure plan and cost
estimate to account for the new conditions, unless the maximum inventory will
be reduced to the level originally estimated quickly.
To account for the maximum costs of closure, the cost estimate should
reflect fully loaded costs, including cost of labor, fuel and maintenance,
contingency fees which are routinely incorporated into contractor cost
estimates. Finally, the closure cost estimates must be based on the costs of
hiring an independent party to conduct closure (see Section 4.2.5).
4.2.3 Scope of the Post-Closure Cost Estimate
The post-closure cost estimate must reflect the costs of monitoring and
maintaining each disposal unit of the facility for the entire post-closure
care period.7 When preparing the cost estimate, the owner or operator
should assume a 30-year post-closure care period unless the Regional
Administrator or State Director extends or reduces the length of the period
prior to final closure of the facility. Because the timing of the
post-closure care period may vary by unit (i.e., some units will be closed
while others will be operating) at some facilities it may be easiest to
calculate post-closure care costs on a per-unit basis.
The post-closure cost estimate for each unit is calculated by multiplying
the current ANNUAL post-closure cost estimate by the number of years of
40 CFR 264.144(a) and 265.144(a).
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4-7 OSVER Policy Directive
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post-closure care required.1 The estimate roust include the cost of
activities conducted annually over the post-closure care period (e.g., ground-
water monitoring and inspections), and activities required less frequently,
such as: extensive soil replacement and maintenance or replacement of
equipment (e.g., ground-water monitoring wells).
The post-closure cost estimate should reflect the costs of 30 years of
post-closure care in the year that the estimate is prepared and should be
adjusted annually thereafter until final closure has been certified (see
Section 4.4). The post-closure cost estimate should also incorporate fully
loaded costs and third-party costs (see Section 4.2.5).
4.2.4 Inclusion of Ground-Water Monitoring Costs in Cost Estimates
The cost estimate for ground-water monitoring during the closure and
post-closure care periods, should be consistent with the costs of monitoring
activities conducted during the operating life. If a corrective action
program has been instituted at a unit or facility, the costs of conducting
corrective action do not need to be included in the cost estimates.' The
costs of compliance monitoring, however, must be included.
4.2.5 First- vs. Third-Party Costs
The regulations specify that the closure and post-closure cost estimates
must be based on the costs to the owner or operator of hiring a THIRD PARTY
to conduct the activities specified in the closure and post-closure
plans.18 Parents or subsidiaries of the owner or operator cannot be
considered third parties.11 The regulations do not require that the
estimates be prepared by a third party.
§ 40 CFR 264.144(a)(2) and 265.144(a)(2).
* Regulations requiring financial assurance for corrective action are
currently being developed under the authority of RCRA Sections 3004(a) and
(u). Financial assurance for corrective action was proposed on October 24,
1986 in 51 Federal Register 37854.
18 40 CFR 264.142(a)(2), 264.144(a)(1), 265.142(a)(2), and 265.144(a)(1).
11 40 CFR 264.142(a)(2), 264.144(a)(1), 265.142(a)(2), and
265.144(a) (1). A parent is a corporation that directly owns 50 percent or
more of the voting stock of the corporation that owns or operates the
facility. A corporation is considered a subsidiary of the owner or operator
if 50 percent or more of its stock is owned by the owner or operator (40 CFR
264.141(d) and 265.141(d)).
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The following assumptions should be used when preparing the estimates:
Hazardous wastes may be treated or disposed of on
site or at an off-site TSDF. However, if an owner or
operator chooses on-site management, he must demonstrate
that on-site capabilities will be available at all times
over the life of the facility. For example, if an owner
or operator intends to dispose of wastes in tanks by
deep welling them on site, the plan must indicate that
the underground injection wells will be open and
operating and are allowed to accept the wastes from the
tank. In addition, if the owner or operator intends to
dispose of wastes on site, he must demonstrate that
disposal capacity will be available at all times over
the life of the facility. (If the owner or operator
intends to dig a trench or cell at closure to handle
remaining inventory, the costs of cell design and
construction must be included in the cost estimate.)
The estimate of costs of managing hazardous wastes
on site must be sufficient to cover routine maintenance
that may be required at any time over the life of the
facility (e.g., operating and maintenance costs for
incinerators).
The cost estimates must incorporate the costs of a
third party conducting all closure and post-closure care
activities including managing hazardous wastes on
site, if applicable. For example, the estimate must
include the costs of hiring a third party to pretreat
wastes and dispose of them on site.
Although the estimates must be based on the costs of a third party
conducting all closure and post-closure care activities, the owner or operator
or a corporate parent or subsidiary may conduct the activities specified in
the closure and post-closure plans. Under all circumstances, however, closure
and post-closure care certifications must be completed by an INDEPENDENT
registered professional engineer.12
4.2.6 Disallowance of Salvage Value and Zero Credit for Sale of
Hazardous Wastes
An owner or operator may intend to recycle all remaining hazardous wastes
or sell equipment, land, or hazardous waste. While these practices are
encouraged, an owner or operator may not deduct the potential salvage value
of these items from the closure cost estimate.11 Similarly, owners or
operators may not assign a zero value to the costs of disposing of wastes
that are expected to have economic value at closure.1"
12 40 CFR 264.115, 264.120, 265.115 and 265.120.
11 40 CFR 264.142(a)(3) and 265.142(a)(3).
lfc 40 CFR 264.142(a)(4) and 265.142(a)(4).
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4-9 OStfER Policy Directive
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4.3 REVISING COST ESTIMATES TO REFLECT CHANGES IN
CLOSURE AND POST-CLOSURE PLANS
Prior to certification of final closure of the facility, owners or
operators must revise the closure and post-closure cost estimate whenever a
change in the closure or post-closure plan INCREASES the cost estimate.11
(See Section 3.3 of this manual for a discussion of deadlines and procedures
for revising the plans and estimates.) If the Regional or State Office
determines prior to final closure that post-closure care for any or all of the
units must continue for longer than 30 years, the owner or operator must
increase the post-closure cost estimate accordingly. If an owner or operator
of a storage or treatment impoundment, waste pile, or tank system not
otherwise required to prepare a post-closure cost estimate must close the unit
as a landfill, the owner or operator must prepare a post-closure cost
estimate. An owner or operator may revise the cost estimates if a change in
the plans results in a decrease in the costs.
4.3.1 Changes in the Closure or Post-Closure Plans that May
Increase the Cost Estimates
The following changes in facility conditions or activities could increase
the closure or post-closure cost estimate:
An increase in facility size and/or capacity;
Changes in the partial closure schedule (e.g., an
owner or operator conducts partial closures of the
facility less frequently than originally scheduled, thus
increasing the maximum extent of the operation);
An increase in the estimate of maximum inventory;
Changes in the types of hazardous wastes to be handled
at closure;
Changes in regulatory requirements that affect the
costs of closure activities (e.g., pretreatment
standards that must be satisfied to landfill certain
hazardous wastes;
1 4
40 CFR 264.142(c), 264.144(c), 265.142(c), and 265.144(c).
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More extensive ground-water monitoring requirements as
a result of an owner's or operator's operating
experience or the availability of new data that were
previously unavailable;
Contingencies over the operating life of the facility
which affect the types of activities that will be
required at closure or during the post-closure care
period;
For surface impoundments, wastes piles, and tanks not
otherwise subject to the contingent plan and cost
estimate requirements, extensive soil contamination
results in .the need to close the unit as a landfill and
conduct post-closure care;
Extensions to the length of the post-closure care
period for one or more units;
Changes in annual or intermittent post-closure care
maintenance activities, including changes in the nature
and frequency of the activities required; and
Changes in surrounding land use (e.g., an increase in
population density surrounding the facility warrants
increased security provisions during the post-closure
care period; expanded ground-water monitoring is
required due to a change in the underlying ground-water
usage).
4.3.2 Changes in the Closure or Post-Closure Plans that May Decrease the
Cost Estimates
The closure cost estimate may be reduced ONLY if the new estimate still
accounts for the maximum costs of closing operating units at any time over the
life of the facility. The following changes in facility conditions may
justify a decrease in the closure or post-closure cost estimate:
Reductions in the size of the facility remaining to be
closed over the remaining life of the facility (e.g.,
if the maximum cost of closure over the life of the
facility includes the costs of closing two landfill
cells and four tanks, the cost estimate may be reduced
after closure of the entire landfill if only the storage
tanks were operating for the remaining life of the
facility);
Reduction in the size of the facility subject to
post-closure care (e.g., fewer cells of a landfill are
operated than were originally intended);
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Changes in manufacturing processes reduce the
quantities of hazardous wastes to be handled at closure;
Reduction in the number of years of post-closure care
remaining for units closed prior to final closure of the
facility.
4.4 ANNUAL ADJUSTMENTS FOR INFLATION
The closure and post-closure cost estimates must equal the current costs
of closing the facility and conducting 30 years of post-closure care. To
account for annual inflation, an owner or operator may either: (1)
recalculate estimates every year using that year's current prices; or (2)
every year multiply the current estimate by an inflation factor that measures
the general trend in prices in the economy.11 The cost estimates must be
updated until final closure of the facility.
4.4.1 Options for Updating the Closure and Post-Closure Cost Estimates
for Inflation
Owners or operators may choose to update their cost estimates for
inflation by recalculating the costs using current dollar-:, for example, if
the owner or operator prepared the initial cost estimates in 1985 using the
prevailing prices in 1985, in 1986 he may recalculate the estimates using the
prices prevailing in 1986.
If the owner or operator chooses to update the cost estimates annually
using an inflation factor, this factor must be derived from the most recent
Annual Implicit Price Deflator for Gross National Product (GNP) and the
Annual Implicit Price Deflator of the previous year.17 The implicit price
deflator is an index that reflects the increase or decrease in the general
price level over the past year, using prices from the year 1982 as the base.
Owners or operators using the implicit price deflator to adjust their cost
estimates for inflation should follow these three steps:
Step 1. Obtain the most recent annual Implicit Price
Deflator and the annual Implicit Price Deflator of
the previous year.
Step 2. Calculate the inflation factor.
Step 3. Multiply the inflation factor by the cost estimate
to derive the new cost estimate.
14 40 CFR 264.142(b), 264.144(b), 265.142(b), and 265.144(b).
17 40 CFR 26A.142(b), 264.144(b), 265.142(b), and 265.144(b).
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STEP 1. Obtain the MOST RECENT Annual Implicit Price Deflator and the
Annual Deflator for the previous year from the following sources:11
(1) The Survey of Current Business;
(2) Economic Indicators;
(3) Regional or State EPA Office; and
(4) RCRA/Superfund Hotline.
(1) The Survey of Current Business, is published monthly by the U.S.
Department of Commerce, Bureau of Economic Analysis. The figures for the
Annual Implicit Price Deflators are included in the section of the Survey of
Current Business called "National Income and Product Accounts Tables." The
deflators are generally found in Table 7.1, entitled "Implicit Price Deflators
for Gross National Product." Exhibit 4-3 includes a sample page from the
November 1985 issue. The Implicit Price Deflator that is used to adjust the
cost estimate is the cr.e specified for Gross National Product (GNP) -- line 1
in Table 7.1 (see line 1 on Exhibit 4-3). The most recent annual deflator and
the annual deflator of the previous year must be used. Therefore, the owner
or operator should refer only to the annual totals for GNP and ignore all
quarterly data. The most recent annual deflator in this issue is for 1984 --
223.43; the deflator for the previous year (1983) is 215.34. (See "A" on
Exhibit 4-3.)
Subscriptions of Survey of Current Business may be obtained for $30.00
per year by contacting the Superintendent of Documents, U.S. Government
Printing Office, Washington, D.C., 20402. It also should be available in most
large public libraries. If the publication is not available in the owner's or
operator's library, the owner or operator may wish to urge the library to
obtain the document from a Federal Depository Library. The Federal Depository
Library Program provides government publications free of charge to designated
libraries. Because of lag times in publishing and distribution, if the
current month's issue is not available, the owner or operator should use the
annual price deflators from the most recent issue available.
lf Because the Department of Commerce derives the Annual Implicit Price
Deflator by averaging prices throughout the calendar year, the Annual Implicit
Price Deflator is generally not available until February of the following
calendar year. Therefore, the most recent Annual Implicit Price Deflator will
reflect inflation of the previous calendar year. For example, cost estimates
adjusted for inflation in April 1987 will be updated using the Annual Implicit
Price Deflator for 1986.
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--13
EXHIBIT 4-3
SURVEY OF CURRENT BUSINESS
OSWER Policy Directive
Table 3.2.Federal Government Receipt* and Expenditure*
Table 7.1.Implicit Price Deflator* for Grou National Product
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1*72 WeifhU
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1194 1183
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1
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1 Gr» *om*»t,f purtKaMB ««uai* CNP ^m^ tipon* DIM unporu final aalai u>
trtawn qu*i» Tinai mm t<>at tsporu pin* imporu
ICF INCORPORATED
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4-14 OSWER Policy Directive
#9476.00-5
(2) Economic Indicators is published monthly by the Council of Economic
Advisors. The same GNP annual deflators as are published in the Survey of
Current Business are published on page 2 of Economic Indicators in a table
entitled 'Implicit Price Deflators for Gross National Product. Exhibit 4-4
includes a sample page from the November 1985 issue. As discussed above, the
owner or operator should refer to the most recent annual figure for GNP and
the annual figure for the previous year. (See "B" on Exhibit 4-4.)
Subscriptions may be obtained from the Superintendent of Documents, U.S.
Government Printing Office, Washington, D.C. 20402, for $27.00 per year. It
also should be available in most large public libraries or through the Federal
Depository Library Program.
(3) The EPA Regional or State Office should maintain a subscription to
Survey of Current Business or Economic Indicators.
(4) The owner or operator may also contact the RCRA/Superfund Hotline
toll free from 8:30 to 4:30 EST at 800-424-9346. In Washington, D.C., the
number is 202-382-3000. The owner or operator -hould be sure to request the
most recent Annual Implicit Price Deflator and tlie final Annual Implicit
Price Deflator for the previous year.
STEP 2. Calculate the inflation factor by dividing the most recent
annual implicit price deflator by the annual implicit price deflator of the
previous year. Using the figures included in the November 1985 issue of
Survey of Current Business or Economic Indicators (shown in Exhibits 4-3 and
4-4) as an example, the inflation factor would be calculated as follows:
Most recent GNP Annual Implicit Price Deflator, 1984 (223.43)
Previous Year's Annual GNP Implicit Price (215.34)
Deflator, 1983
The result is an inflation factor of 1.04.
STEP 3. Adjust the cost estimates for inflation by multiplying the most
recent closure and post-closure cost estimates by the inflation factor. For
example, if a closure cost estimate of $100,000 prepared in December 1984 were
adjusted for inflation in December 1985, the new cost estimate would be
$104,000 (i.e., $100,000 times the inflation factor of 1.04). Each subsequent
update for inflation will adjust the cost estimates updated the previous
year. Using the above example, in December 1986, the owner or operator will
multiply the new cost estimate of $104,000 by an inflation factor derived from
the 1985 and 1984 Deflators.
4.4.2 Deadlines for Adjusting Cost Estimates for Inflation
Owners and operators must update their closure and post-closure cost
estimates within 60 days PRIOR to the anniversary date of the establishment
of the financial assurance instrument. Owners or operators who use the
financial test to demonstrate financial assurance must update their cost
ICF
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4-15
OSWER Policy Directive
#9476.00-5
EXHIBIT 4-4
GROSS NATIONAL PRODUCT IN 1972 DOLLARS
(Mellon, ,,( is;-.I dnllir< (|Uin»rh din ii -rxoriilly adjusted annual raiet)
Gnw«
Pr»riixi rutionii
product
Ptrtoni!
ron-
^uTiptiuii
xprndi-
lurrs
ljrn«* pmit* ' K sport*
domino investment : «i.J i
Nonren-
> demitl
! fixed
i Phtriff I :
^ I rr ! £. ! -
n( podl I Gmemmetii nurrhaies ef
unices i foods and ten ires
! ! ; Federal ,' Km.!
pun- : Imports : Total Nillo(l,| j N
1.463.5
1 .503 4
1.507.5
1.530.P
1.549.3
1.565.4
1.579.3
1.61? .5
1.614.6
1.6456
1.6444
1.663.0
1.6864
IMPLICIT PRICE DEFLATORS FOR GROSS NATIONAL PRODUCT
Column
one
T
rout
Prnod nationaJ
product
1976 132.34
1977 140.05
1976 15042
1979 16345
I960 176.42
1961 19560
!9"2 20736
IS6?- 215 34
19M 223 43
1962 UI 206 53
IV 21027
1963 1 21267
11 . 21425
III ... 215 Rf
IV 216.21
196-1 I 220.5*"
II 22:' 4"
III 22457
IV x-6 10
1965 I 229 07
II J3055
III'.. 231 66
.<«,.-« l>p.rw». .< < om~". B.
(1972-
PereonaJ consumption
eipenditures
Total ^.
131 7 1239
1393 129.2
1491 1 1364
162.5 i 1450
1790! 156.2
194 5 ' 167 1
2060 174 .5
2136 ' 177 7
2204 1790
2076 175.5
2096 1756
2107 ' 1766
2126 1766
2146 178.0
2160 , 1793
2160 ' 1790
219.2 ' 179.5
221 5 ' 179.2
2226 1764
224 6 179 1
226.2 ; 1"64
227 4 176 1
irtu of LrofxmiK AIUIII
1
Nondur- i
ablr
foods :
1
137.2 j
143.6
1534 !
1699 '
166 1
202 5 '
2067
2130
2177
2096
, 210.5
2102
212.6
214 5
1 214.6
217.4
2164
! i!7.6
, 2194
2201
221 2
221 7
,
100 quarterly data are aeaionally
' Gross private
1 domestic i
1
Sonntsi-
Sen'ice* dentiat
1 feed
I
129.6 : 138.6
1393 j 146.3
150.0 ' 157.2
162.3 i 170.8
178.6 : 186.2
196 .8 : 202.2
213.6 ' 209.5
2260 : 2064
237 6 ' 207.6
1
215.6 2068
219.4 ; 210.1
2219 2071
2249 205.2
227.3 : 205 1
2297 208 1
232.6 206.3
236 0 207 4
239 7 i 208 0
242 0 209 4
2452 ' 211.6
246.1 ' 212.1
251 2 ' 214 6
nvettment
Rtsiden-
tiaJ feed
140.7
1560
178.3
200.5
216.5
234 1
241.3
2464
2557
241 8
240.0
245.2
243.0
: 2467
1 248.3
i
! 2494
2559
2586
2591
2586
2593
1 2605
adjusted)
Eipons and
foods and
1
Exports j
[
155 3 ,
161.9
172.6
192.5
212.9 '
230 9 '
236.0
241 0
2494
2362
235.3
' 2377
2394
! 241.5
2454
247 7
2504
- 250 1
; 2496
I
1
I 2510
l 252.0
251 4
imports of ,
services ',
1
Import! i
|
1
1856
205.5
214 1
246 1 !
2894 i
2936
279.3
271.5
2660
280.9
280.1
2676
271.0
276.3
270.3
267.9
2696
2633
2637
252.6
257 .1
2556
Government purchases of foods and
l
Toul '
!
133 5
142 6 '
153 1 '
1R4 6
185.2
207.6
221 4
232 1
241.2
223.2
223.6
2294
2308
232.8
2356
238.5
2406
241.5
2437
2464
250 1
246.2
services
Federal
National ! Son. and loca!
defense ', defense
1324 ; 135 7 136 3
1419 1446 1464
152.7 153 6 1597
1660 1625 1737
187. 5 180.6 191 .'
209 1 204 7 2' >s 0
227. (' 2(19 a 222 j
236 B 221' 0 236 7
247.2 224 7 25 1 7
2274 2139 2247
233.1 2062 2264
2337 i 2194 231 5
234 6 2203 234 9
237.9 219 1 2364
2400 i 221 4 241 6
]
245.1 1 2155 2464
24fi4 , 225 1 25<"'
247 4 ' 227 1 253.5
249.6 i 226.2 256 9
2524 ! 231 5 2609
i 2556 ! 235 .2 264 7
: 255 4 230 9 267 9
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4-16 OSWER Policy Directive
#9476.00-5
estimates for inflation within 30 days AFTER the end of the firm's fiscal
year and prior to the submission of financial test documentation to the
Regional or State Office.
Prior to October 29, 1986 (the effective date of the May 2, 1986 rules),
cost estimates were updated for inflation on the anniversary date of the cost
estimate rather than on the anniversary date of the financial assurance
mechanism. This change in deadlines may result in a number of one-time
adjustment rules that apply the first time an owner or operator of an existing
facility renews the financial instrument (or resubmits financial test
documentation), or updates the cost, estimates under the revised regulations.
The rule for calculating the inflation adjustment factor for the first
time under the May 2, 1986 rules will depend on when the cost estimate was
last adjusted for inflation under the previous regulations AND the
anniversary date of the financial assurance mechanism (or the fiscal
year-end date for financial test users). These rules are discussed below.
Rule ' If the cost estimate was last updated between
October 29, 1985 and March 1, 1986, and the next
update is required between October 29, 1986 and
March 1, 1987 (i.e., the anniversary date of the
financial instrument or the fiscal year-end date
falls within this period), the inflation
adjustment factor is calculated by dividing the
1985 Deflator by the 1984 Deflator.1'
Rule II: If the cost estimate was last updated between
March 1, 1986 and October 28, 1986, and the next
update is required between October 29, 1986 and
March 1, 1987, no adjustment for inflation is
required until the period between October 29, 1987
to March 1, 1988. These owners or operators have
already updated their estimates to account for
1985 inflation.
Rule 111: If the cost estimate was last updated between
October 29, 1985 and March 1, 1986, and the next
update is required between March 1, 1987 and
October 28, 1987, the inflation adjustment factor
is calculated by dividing the 1986 Deflator by the
1984 Deflator. These owners or operators must
adjust their estimates to reflect 1984 and 1985
inflation.
l* Owners or operators with financial instrument renewal dates between
October 29, 1986 and December 27, 1986, will not have the full 60 days to
update their cost estimates. Similarly, owners or operators using a financial
test with a fiscal year ending between October 1, 1986 and October 27, 1986
will have less than 30 days to update their estimates. In these situations,
owners or operators may wish to contact the Regional or State Office or the
RCRA Hotline to obtain the Deflators as quickly as possible.
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4-17 OSWER Policy Directive
I, x-r . * . UO-5
Rule IV: If the cost estimate was last updated between
March 1, 1986 and October 28, 1986, and the next
update is required between March 1, 1987 and
October 28, 1987, the inflation adjustment factor
is calculated by dividing 1986 Deflator by the
1985 Deflator.
4.5 DOCUMENTATION FOR COST ESTIMATES
Although the regulations do not specify the format to be used for closure
and post-closure cost estimates or the level of detail to be provided, the
cost estimates must contain sufficient detail to allow the Regional or State
Office to evaluate their, accuracy. Documentation for the cost estimates
should clearly delineate all activities and subactivities consistent with
those described in the closure and post-closure plans and include the fully
loaded costs of closure and post-closure care, including the costs of labor,
equipment, and contingency fees. Documentation supporting cost estimates
should also clearly reflect that such estimates are based on third-party costs
where required. Five sources that might be used in developing cost estimates
for the activities listed in the closure and post-closure plan are:
(1) Guidance Manual: Cost Estimates for Closure and Post-
Closure Plans (Subparts G and H), November 1986,
available through EPA Regional Offices (OSWER Policy
Directive Number 9A76.00-6);
(2) Owner or operator experience;
(3) Contractor estimates;
(4) Cost estimating handbooks; and
(5) Worksheets and workups.
These data sources are described in more detail below.
4.5.1 Guidance Manual: Cost Estimates for Closure and Post-Closure
Plans (Subparts G and H)
This EPA guidance manual contains guidance and information on key cost
components and ranges of unit costs applicable to closure and post-closure
care activities. The manual is organized into four volumes:
Volume I contains worksheets outlining cost components
applicable to facilities with tank, container storage,
and incinerator units;
Volume II contains worksheets outlining cost
components applicable to land disposal units;
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4-18 OSWER Policy Directive
#9476.00-5
Volume III contains information on unit costs of key
closure and post-closure care activities (e.g., final
cover, certification); and
Volume IV contains detailed documentation of the unit
costs.
4.5.2 Owner or Operator Experience
In many cases, the most readily available source of cost information for
existing facilities will be operating records. For example, if an owner or
operator routinely ships wastes off site to a TSDF and intends to follow the
same procedures during .closure, an estimate of the costs of treating or
disposing of inventory at closure may be derived from contractor invoices. If
an owner or operator intends to construct a cell as part of closure
procedures, records of the costs of excavation, installing liners,
ground-water monitoring, etc., should be available from internal records.
Records from previous partial closures including contracts and invoices for
installing final covers, decontaminating facility equipment and soil, and
installing security equipment also may provide information to support the cost
estimate. Similarly, the costs of ground-water monitoring during the closure
and post-closure care period may be similar to the costs of monitoring during
the facility's active life.
The cost estimates must be based on the cost of hiring a third party to
conduct closure and post-closure care activities. Thus, the owner or
operator must include a factor for hiring third-party labor if current
practices include in-house labor and activities.
4.5.3 Contractor Estimates
Many cost estimates, particularly for those services that are to be
purchased from a contractor or contractors, may be obtained from the
contractor themselves. It is not necessary for documentation purposes to have
written and validated cost estimates; a record of the party contacted, the
date of the contact, and the estimates given is sufficient.
4.5.4 Cost Estimating Handbooks
Three widely used cost estimating handbooks are the Means Mechanical
Cost Data, the Means Construction Cost Data, and the Means Site Work Cost
Data, which are published and updated annually by Robert Snow Means Company,
Inc. Care should be taken in using such manuals. For example, some manuals
include costs of administration, normal contingencies, and profits in their
unit costs estimations, whereas others do not. In some cases, theoretical
work rates must be adjusted to normal field conditions and to include
administrative costs.
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4-19 OSWER Policy Directive
#9476.00-5
4.5.5 Worksheets and Workups
Detailed workups of the costs should include an estimate of labor,
equipment, energy, and material needs; the basis for these assumptions and the
total time required for each activity should be included in the workup. Costs
for supervision and administration should be added and adjustments made to
account for fully loaded labor and equipment costs.
ICF INCORPORATED
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OSWER Policy Directive
#9476.00-5
APPENDIX A
CLOSURE TIMELINES
This appendix contains four timelines that reflect key closure activities
and the timeframes in which those activities are conducted. The activities
include those performed by the owner or operator in conducting closure and the
administrative activities performed by the Regional or State Office during the
review and approval of closure plans. These timelines assume that closure
activities and plan approval are completed by the deadlines specified in
Subpart G. However, the timelines also identify points in time at which
extensions to the deadlines may be granted.
The timelines are based on the status of closure plan approval.
Therefore, the four timelines address:
(1) Permitted and interim status facilities with approved plans for
surface impoundment, waste pile, landfill, and land treatment
units, Exhibit A-l);
(2) Permitted and interim status facilities with approved plans for
container storage, tank, and incineration units (Exhibit A-2);
(3) Interim status facilities without approved plans for surface
impoundment, waste pile, landfill, and land treatment units
(Exhibit A-3); and
(A) Interim status facilities without approved plans for container
storage, tank, and incineration units (Exhibit A-4) .
The following notes may be helpful when using the timelines:
Receipt of the final volume of hazardous waste occurs at day
zero;
The days correspond to days before or after receipt of the
final volume of hazardous waste, with events that occur before
that point taking place on "negative" days. The regulations
generally measure the closure deadlines from the date of receipt
of the final volume of hazardous waste. The deadlines for
submission of closure plan and notification of closure, however,
are triggered by the "expected date of closure (i.e., within 30
days after the final receipt of hazardous wastes or longer if
approved by the Regional or State Office)." In order to minimize
confusion that might result if deadlines used different
benchmarks, all deadlines including those for submitting the
closure plan and notification, use receipt of the final volume of
hazardous waste as a benchmark. For example an owner or operator
must notify of the intent to close a landfill cell 60 days prior
to the expected date of closure. This deadline is denoted on
Exhibit A-l as 30 days prior to the final receipt of hazardous
waste;
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A-2 OSWER Policy Directive
#9476.00-5
The timelines are designed so that the deadline is the last
possible day that an event may take place, unless a variance or
extension of time is obtained by the owner or operator;
The legend indicates the points in time when extensions or
variances may be requested;
The description of the event taking place occurs immediately
above and to the right of the day by which it must take place; and
"0/0" refers to the facility owner or operator and "RA" refers
to the Regional Administrator.
ICF
INCORPORATED
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A-3
OSWER Policy Directive
?;9476.00-5
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ICF
INCORPORATED
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F.XHIBIT A-3
CLOSURE TIMELINES FOR INTERIM STATUS
FACILITIES WITHOUT APPROVED PLANS:
Surface Impoundments, Waste Piles, Landfills,
and Land Treatment Units
-150
-120
-90 -60
-30
300
30 years 60 days 120 days
LEGEND
A Extension may be granted
|| Change in timeline scale
C
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' The O/O must submit his closure plan to Ihe RA at least 180 days prior to Ihe date he expects to begin closure.
21 '
-------
EXHIBIT A-4
CLOSURE TIMELINES FOR INTERIM STATUS FACILITIES
WITHOUT APPROVED PLANS
Container Storage, Tank and Incinerator Units
-IS
0
A
15 75 105 165 225 255 315
A
345 405 465
A
Bfc
LEGEND
A Extension may be granted
|| Change in timeline scale
o
11
o
1
I
o
' The O/O must submit his closure plan to the RA at least 45 days prior to the date he expects to begin closure.
2 O/O may begin conducting limited closure activities prior to plan approval bul Is nol required to complete removal o[ invenlory until 90 days after
the plan is approved.
O
O
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OSVER Policy Directive
#9476.00-5
APPENDIX B
TECHNICAL EVALUATION CRITERIA AND SITE-SPECIFIC
FACTORS TO CONSIDER IN DETERMINING THE LENGTH
OF THE POST-CLOSURE CARE PERIOD
The Subpart G regulations give the Regional Administrator or State
Director the authority to extend the length of the post-closure period beyond
30 years or reduce it on a case-by-case basis. He also may temporarily extend
or reduce the length of the period or temporarily suspend certain activities
based on causa. In addition, the owner or operator or member or the public
may petition the Regional Administrator or State Director to change the length
of the period.J
This section suggests factors that may be appropriate to consider in
evaluating the length of the post-closure care period and in preparing
documentation to support a petition to extend or reduce the period. Section
B.I discusses broad technical criteria that should be examined and Section B.2
presents facility-specitic technical factors that may affect the decision.
This appendix also presents a number of hypothetical scenarios
illustrating how site-specific information might be used to support an
extension or reduction in the length of the period. Although all of the
scenarios are hypothetical, they indicate the types of information that should
be examined and how the technical criteria and site-specific factors may be
evaluated.
The hypothetical scenarios referenced in this appendix are not intended to
represent all the possible situations that could be encountered. Rather, the
scenarios describe the types of information that should be considered given a
hypothetical set of facility conditions, present a decision under these
particular conditions, and describe the rationale for the hypothetical
decision.
B.I Technical Evaluation Criteria to Consider in Determining
the Length of the Post-Closure Care Period
The following four technical evaluation criteria provide a framework for
assessing how well a unit or facility will protect human health and the
environment:
(1) Containment - How long will the unit or facility
contain the wastes after closure?
(2) Detection - Will the systems currently in place at
the unit or facility detect releases of hazardous
wastes?
40 CFR 124.5(a), 265.118(g), and 270.41.
ICF INCORPORATED
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B-2 OSWER Policy Directive
#9476.00-5
(3) Migration and Attenuation - Will the wastes migrate off site,
and will the leachate be attenuated in the environment?
(4) Risk Potential - Who potentially will be exposed to a waste
release, how toxic are the waste constituents., and, consequently,
what risks are involved?
B.1.1 Containment
The first and foremost objective for the design and operation of any
disposal unit is the isolation of the hazardous wastes. Thus, when
evaluating the containment criteria, emphasis should be placed on determining
when a likely release of leachate will occur and its potential magnitude.
The most important parts of a containment system are the liner (single,
double, or triple) and the cover or cap. The purpose of the liner is to
contain the wastes in place and minimize ground-water contamination. The cap
is designed to minimize infiltration of water into the unit, and thereby
prevent the formation of leachate. (Generally, land treatment units are not
capped because they »re designed for waste degradation rather than waste
containment. This distinction is discussed more fully in Section B.2.1.1.)
Improvements in landfill technologies (e.g., double synthetic liners)
generally will result in longer, though not permanent, waste containment.
Virtually every disposal facility, no matter what the design, will eventually
leak and realease leachate. Releases due to improper design, construction,
installation, or operation of the unit are more likely to occur and be
detected prior to the end of the 30-year post-closure care period. Releases
due to the eventual degradation or wearing-out of the containment devices may
take longer than 30 years to occur. Nevertheless, because most wastes
contained within landfills undergo limited chemical or biological degradation
as a result of the isolation, toxicity, and volumes of the wastes, releases
caused by the eventual wearing-out of a facility will still pose a significant
risk to human health and the environment. The processes and rates of
hazardous waste degradation will vary for different chemicals and for
site-specific conditions found at facilities, including chemical/physical
properties (e.g., anaerobic or aerobic conditions, potential pH) and
biological properties (e.g., the specific microbial population within the
landfill cell). In most cases, biological degradation of hazardous waste
constituents will occur at very slow rates because microbial populations are
limited by the highly contaminated environment. In addition, many of the
constituents that promote microbial growth, and therefore chemical
degradation, such as light, water, and oxygen, are restricted by the landfill
cover. Therefore, significant degradation of hazardous wastes will not begin
until the wastes have been released from the containment systems.
In summary, based on purely technical considerations concerning
containment, any slowly degradable toxic waste that is placed in a landfill or
other containment facility has the potential to damage human health and the
ICF INCORPORATED
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B-3 CEWER Policy Directive
#9476.00-5
environment. Moreover, this damage may occur ov=er fl -merry long timeframe swell
in excess of the standard 30-year post-closure caxe :peziod. As a result.,
monitoring until all the soluble hazardous wastes -have been removed or towe
leached off site, or until the owner or operator .has demonstrated that local
environmental conditions will limit potential grouTvd-»a±er contamination to
acceptable levels may be appropriate.
B.I. 2 Detection
Monitoring for leachate generation and releases serves as the most
effective means of checking the integrity of a hazardous waste management unit
during the post-closure care period. If wastes /are -delected beyond the
containment boundaries, corrective action can be taken to prevent continued
migration of the wastes off site. In evaluating ground-water monitoring
results, it is important to keep in mind that ttaexe ±s A lag between leadbarte
generation and release and migration to the point oi detection. In addition,,
in some cases, improper well placement in relation tc containment facility
configuration, well construction, ground-water movement, and characteristics
of the leachate migration may preclude detection o-f * release. If leachatae is
detected, the results may indicate that either corr£ETdJ.'£ action is warranted
or extended post-closure monitoring is needed to ensirr* that the release does
not pose a threat to human health and the environment.
B.I.3 Migration and Attenuation
The extent to which leachate will migrate and jnaasa1. a threat is a function
of two general factors: (I) environmental transport <(*.g., ground-water
discharge rates) and (2) waste characteristics (e.g.,,, adsntrjrtivity and
degradability).
If migration of a release is expected to be very sQx>w, then virtually mo
risks may be associated with a release over the start fcerm because the waasiaers
will not contaminate drinking water supplies that air* in use. In such a case,
post-closure care monitoring would have to be extended over a very long period
to ensure that a slowly moving contaminant plume would :be detected. On the
other hand, rapid migration would allow for earlier nkrtection but may also
pose a greater threat to drinking water supplies.. Thus, the predicted
migration patterns and rates will affect the determ.iivirt.ion of an appropriate
duration for post-closure care monitoring.
The extent to which wastes have degraded during containment is also
important to the evaluation of the Jong-term hazards.. For example, land
treatment facilities are designed to promote continuing degradation;
therefore, the danger of serious releases from those units or facilities
presumably will decline over time. In contrast, the isolation of wastes ±21
landfills can actually inhibit degradation, thereby .maintaining the hazardous
constituents over a longer period. In addition, many -hazardous wastes simply
do not readily degrade.
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B-4 OSWEi, Policy Directive
#9476.00-5
B.I.4 Risk Potential
The overall risks stemming from hazardous waste management are determined
by the likelihood of exposure to the waste, and the effects associated with
that exposure.. The severity of a release is a function of the leachate
concentration at the point of release, and more importantly, the leachate
concentration at the point of exposure. If a unit's containment systems
degrade very slowly, the structure of the liners (if present) should attenuate
the leachate migration rate and limit the releases to low concentrations over
long periods of time. In addition, the leachate may further adsorb, degrade,
and otherwise be attenuated in the environment. Finally, only low levels of
risk may be associated with chronic exposures at low concentrations to certain
waste constituents. If only "low toxicity" wastes are present in a unit or
facility, the risk associated with exposure to these wastes would be
relatively low. These several factors, alone or in combination, may limit the
risks associated with a release from a unit or facility and, therefore, lessen
the need to extend the post-closure ground-water monitoring period.
B.2 Site-Specific Technical Factors Involved in Evaluating
the Length of the Post-Closure Care Period
Exhibit B-l summarizes the relationship between the general evaluation
criteria discussed in Section B.I and the site-specific technical factors.
The exhibit also identifies the types of information that could support a
request to the Regional Administrator or State Director to alter the length of
the post-closure care period. The three categories of facility-specific
factors are:
(1) Facility characteristics;
(2) Waste type and characteristics; and
(3) Environmental and health considerations.
Although these three categories are addressed separately, they cannot and
should not be assessed independently of one another. For example, in
assessing the adequacy of a facility's design, its environmental setting and
the types of wastes that are being contained must also be examined. To help
illustrate how site-specific technical factors may influence the length of the
post-closure care period, the following sections refer to hypothetical
scenarios summarized on Exhibit B-2. These scenarios are intended for
illustrative purposes only and should not be considered directly applicable to
any particular facility. However, they may help to clarify the kinds of
information that deserve consideration.
B.2.1 Facility Characteristics
An assessment of the following facility characteristics will give a
general indication of the expected ability of the facility to contain wastes
over the long term:
ICF
INCORPORATED
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EXHIBIT B-1
SUMMARY Of CONSIDERATIONS FOR EVALUATING THE
LENGTH Of THE POST-CLOSURE CARE PfRlOO
OSWER Pol Icy Directive
|9'i76.00-5
GENERAL
EVALUATION CRITERIA
SITE-SPECIFIC
TECHNICAL FACTORS
ContaInment
Detection
Cap
Liner
Faci 1 1 ty Design
Post-Closure Care Experience
Envl ronment
Waste Characteristics
Corrective Action
Leachate Collection
Ground -Water Monitoring
ANALYTICAL COMPONENTS
Materials (clays, synthetics), permeability, soil and vegetative
cover
Materials (clays, synthetics), permeab I I I ty, compaction
Structural stability, topography
Maintenance, Inspections, repair procedures
Precipitation, flood plains, soil types, depth to ground water
Effect on containment, long-term degradabl I I ty
Effect on containment, maintenance
Possibility of "short-circuit" of leachate through collection
system, stability, sampling and analysis schedule, history of
leachate collected
Hydrogeology, well location, well number and depth, background
concentrations, sampling and analysis schedule
tn
Migration and
Attenuation
Unsaturated Zone Monitoring
Ground Water
Surface Water
Waste Characteristics
Subsurface Media
Soil type, waste degradation rates, sampling and analysis schedule,
history of waste concentration measurements
Depth to ground water, hydraulic gradient, hydraulic conductivity
Slope, precipitation, flood plains
Adsorptivl ty, degra labl II ty, reactivity, solubility, volatility.
vi scosl ty
Adsorption sites, geochemistry
o
n
o
a
3
I
o
Risk Potential
Waste Toxlclty
Exposures
Population Characteristics
Environmental Considerations
Acute and chronic toxlclty, general health hazards, ecotoxicity
Drinking water well locations and depths, surface waters,
bloaccumulatIon
Populations of drinking water users, age distributions
Surface waters, wetlands, land use, agriculture, ecologically
sensitive habitat
-------
EXHIBIT 0-?
MYPOIIIE!ICAL SCENARIOS ILLUSIRATING DECISIONS
ON THE LENGTH OE THE POST-CLOSURE CARE PERIOD
OSWER Policy Directive
/T9H76.00-5
Scenario/Description
I. A land treatment facility
contains mildly hazardous
waste and Is being closed.
The surrounding soil has
low permeability and the
treatment zone is three feet
above the seasonally high
water table. Ground water
is the sole source of
drinking water for a nearby
town. Unsaturated soil
monitoring results indi-
cate contamination levels
slightly above background.
Factors to Consider
- Amount and type of wastes
disposed in the facility
- Depth to the water table
- Potential migration of con-
taminants from the'facility
- Direction and rate of
ground water flow
- Likely contamination of
drinking water wells
- Analysis of monitoring
results to determine whether
contamination is statis-
tical ly detectable
Dec i s ion
Rat iona le
Maintain the length of the
post-closure care period at 30
years. The RA can reeval-
uate unsaturated zone moni-
toring results at a later
date to determine whether the
post-closure care period may
be reduced or should be
extended.
The combination of mildly
hazardous wastes, low soil
permeability, and a large
treatment zone in a well-
run facility suggest that
ground-water contamination
should be minimal. However,
because the ground water is
a sole drinking water
source, monitoring should
not be terminated until
results indicate that
background levels are no
longer exceeded.
2. The facility contains a
double-lined disposal
surface Impoundment
equipped with a leachate
detection system which
satisfies tO CFR 261.22T(c).
The impoundment contains
mildly toxic wastes.
No leaks have been detected
6 years Into the post-
closure care period.
The ground water table is
located 80 feet below
the bottom of the
impoundment (deep
qtiifer). The aquifer
is a poor drinking water
source. The facility Is
located In a sparsely
populated area.
- Size of Impoundment
- Integrity of the liner
system/containment system
- Amount and type of waste
substances disposed in the
facl Nty
- Environmental fate of the
waste substances
- Population at risk
- Future uses of the ground
water
Temporary reduction of post-
closure care activities on
a trial basi s.
Ground water source is deep,
and is a poor drinking water
source. If containment
system fails, ground-water
source Is deep and of such
poor quality that minimal
threat exists to human
health and the environment.
Aquifer Is not hydro logicaIly
connected to aquifers cur-
rently or potentially used as
drinking water sources in a
way that would allow conta-
minants to migrate to these
waters. Limited population
at risk. Post-closure acti-
vities may be reinstated if a
release Is detected.
JANUARY 1987 DRAFT
-------
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ICF INCORPORATED
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EXHIBIT B-2
HYPOTHETICAL SCENARIOS ILLUSIRATING DECISIONS
ON THE LENGTH OF THE POST-CLOSURE CARE PERIOD
OSWER Policy Directive
091176.00-5
O
Tl
§
3
Scena rIo/Desc rIp t i on
5. A one hundred acre land-
fill Is located In a 100-
year riood plain. The
facility Is designed to
handle 330,000 tons/yr
at maximum design capac-
ity. The site is fiI led In
20-acre units. The land-
fill is equipped with a
well-designed liner and a
leachate collection and
removal system capable of
removing leachate gene-
rated as well as rainfall
which enters the active
portion of the cell. At
this point In time, 3
cells have been closed
The cells contain a variety
of wastes Including metals
such as lead. One closed
unit has experienced
several leaks which have
been repaired. The peri-
meter dike was flooded
during a 100-year storm
event and has been
replaced. Leachate and
run-off generated during
the flooding event con-
tained metals, trlchloro-
ethylene, and benzene in
high concentrations.
Ground-water monitoring
systems are designed for
each Individual eel I.
Factors to Consider
Dec i s ion
Rati'ona le
Characteristics
I Iner and fInaI
of the
cover
Maintenance of the ground-
water monitoring system,
the leachate control sys-
tem, and the run-off con-
trol system at the facil-
ity
Amount and type of waste
In the landfi11
Mobility and expected rate
of migration of waste
Site location, topography,
and surrounding land use
Geological and soil pro-
files, and surace and
subsurface hydrology
The owner/operator must per-
form 30-year post-closure care
on the two cells that have
already been closed. For
the third closed cell that
has experienced leaks, the
post-closure care period is
extended beyond thirty years
to ensure continued ground-
water monitoring. At the
time of closure of the
remaining two cells, facil-
ity conditions will be
reexamined to assign post-
closure care periods to
these units and evaluate
whether the periods for the
previously closed cells
should be extended.
Because the landfill cells
are designed with independ-
ent monitoring systems, the
post-closure periods are
assigned on a per-unit
basis. However, the facil-
ity's location and the
toxicity, virtual non-degrad-
ability, and potential for
migration in the environment
of the metal wastes make it
appropriate to reevaluate
facility conditions as each
unit is closed. Especially
because one closed cell has
experienced leaks, it is
prudent to ensure that
ground-water monitoring
continues long enough to
detect releases from all
units.
JANUARY 1987 DRAFT
-------
OSWER Policy Directive
(T9U76.00-5
SeenarIo/DescrlptI on
6. Severn) lined surface
Impoundments on a site
are to be closed. The
closure plan provides
Tor the removal of all
standing liquids, and
stabilization of remain-
ing wastes, waste resi-
dues and contaminated
materials. The first
phase of the closure plan
wiI I result In: (I) the
removal of all liquids;
(?) the chemical fixation
of all sludges In the
ponds; (3) the backfill-
ing of the ponds with
clean sol I. Wastes
placed in the disposal
unit contain toluene,
carbon tetrachlorIde, and
methylene chloride. The
final cover will consist
of a synthetic membrane
liner, a drainage layer,
and protective and vege-
tative covers. Leachate
will be sampled for pH,
chlorinated organics and
specific conductance.
The aquifer underlying
the site is used as a
drinking water source.
EXHIBIT n-2
HYPOTHETICAL SCENARIOS ILLUSTRATING DECISIONS
ON THE LENGTH Of THE POST-CIOSURE CARE PFRIOO
factors to Consider
Permeability of thn liner
materiaIs--clay and geo-
textIles
Pressure head of leachate
on IIner
Climatic conditions in
area
Physical and chemical
properties of soil that
supports IIner
Potential for damage to
the IIner system
Volume of leachate/run-off
produced at the facility
Options for managing
leachate/run-off collec-
ted at the fact 11ty
Design of the ground water
monitoring system; sampl-
ing schedule for wells
Amount and type of waste
disposed In tiie facility
Migration of the wastes
In the event of a release
Potential population exposed
to a release and at risk
Dec i s ion
Rat lonale
The owner/operator must per-
form 30 years of post-closure
care. An extension to the
care period may be needed if
contaminant concentrations
exceed ground-water standards
set for the aqui fer.
The aquifer under the site
is currently used and
supplies drinking water
to a large town located ?
miles from the site. The e-
fore, there is a signifir nt
population at risk.
o
O
I
I
JANUARY 1987 DRAFT
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OSWER Policy Directive
EXHIBIT B-2
HYPOTHETICAL SCENARIOS ILLUSTRATING DECISIONS
ON THE LENGTH OF THE POST-CIOSURE CARE PERIOD
Scenario/Description
7. The facility is a 50-acre
landfl11 located in a
remote and arid area.
The faclIIty Is IIned
with a 2-foot, thick
clay liner. Annual pre-
cipitation is low, but
the area Is subject to
heavy rains In the early
spring. Wastes have accu-
mulated to a maximum of
20 feet above grade. The
wastes disposed In the
facility include waste
solvents, pesticides, tar
residues, and oily sludges.
The site Is located In
sandy-clay soils with slow
to moderate permeability.
Depth to ground water
varies from 15-30 feet.
The aquifer Is currently
In use. The ground
water serves as the water
supply for a sparsely
populated residential
area. A small stream
containing game fish Is
located approximately 1/3
mile from the site. The
slope of the landfill Is
slightly eroded, and run-
off Is reaching the
stream, contributing to
occasional flooding dur-
ing peak rainfalls. Low
levels of chlorinated
organics have been
detected in the drinking
water supply of residents
located near the cite
In the 20th year of
the fact IIty s post-
closure care period.
Factors to Consider
- Integrity of clay mate-
rials lining the facility
- Stability of western
slope of landfi11
- Volume of leachate gene-
rated and integrity of
the leachate collection
system
- Limits of the permeabil-
ity of the clay
- Solubility of the waste
materials
- Concentration of consti-
tuents In the run-off
reaching the stream
- Ground water gradient and
flow rate
- Amount and type of wastes
in the landfl11
- Population at risk
Deci si on
The post-c lostire care period
should be extended by five
years to ensure that levels
of contaminants in drinking
water do not increase the
risk of harm to human health.
Reqrading of western slope
shouM also be undertaken to
ensure the structural integrity
of the landfill. The period
will be reevaluated after
five years to determine if
another extension is re-
qu i red.
Rat ionale
An extension is appropriate
because the potential exists
for extensive ground-water
contamination and for fur-
ther failures of the land-
rill, which could both in-
crease human health risks
and danger to the environ-
ment.
JANUARY 1987 DRAFT
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B-ll OSWER Policy Directive
#9476.00-5
(a) Process type;
(b) Facility design;
(c) Waste management (operational) practices; and
(d) Corrective action activities.
B.2.1.1 Process Type
Landfills, land treatment units, and disposal surface impoundments retain
hazardous wastes after closure. In addition, storage impoundments, waste
piles and tank systems that cannot be "clean closed" also must be closed as
landfills.
Land treatment is designed to promote the degradation of constituents
placed in or on the treatment zone, to transform them into non-hazardous
constituents, or to immobilize them. The purpose of the post-closure care
period is to allow continuing degradation of the. wastes in the unit. Thus,
the post-closure care period in effect serves as an extension of the active
life of the land treatment unit. If an owner or operator of a land treatment
unit expects that the waste constituents will degrade before the end of the
30-year post-closure care period, he may submit a demonstration to the
Regional Administrator or State Director in accordance with the provisions in
40 CFR 264.280(d) showing that the level of hazardous constituents in the
treatment zone does not exceed background values. (See Scenario 1 in Exhibit
B-2.) In contrast to land treatment facilities where hazardous constituents
are assumed to become non-hazardous over time, post-closure activities at all
other types of units closed as landfills are designed exclusively to contain
the hazardous wastes over the long term.
B.2.1.2 Facility Design
The function of a waste management system is to CONTAIN and DETECT the
formation and minimize the escape of teachate, gases, and solids from the unit
into the environment. Facility design characteristics which may influence
the length of the post-closure care period are:
Facility size;
Liner;
Final cover;
Leachate collection, detection and removal systems;
Control of run-on and run-off, and
Ground-water monitoring system.
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Facility Size. Facility size could be important if the facility has
numerous disposal units and operates for a large number of years. A typical
landfill operation closes individual cells as their disposal capacity is
reached. Therefore, for facilities that contain many cells and continue
operating over a long time span, an individual cell could be receiving
hazardous waste 30 years or more after the first cell at the facility was
closed. In this situation, some units will be conducting post-closure care
activities while others will be actively receiving wastes. Unless the cells
are hydrologically independent and have separate containment and monitoring
systems, it may be appropriate to evaluate the length of the post-closure care
period on a facility-wide rather than on a per-unit basis.
Liner. Liners are required for landfills, surface impoundments and
waste piles to contain and prevent migration of leachate from a unit or
facility. The effectiveness of a liner or liner system may vary according to
the number of liners, the liner thickness, and the liner materials.2
Disposal units are often lined with compacted clay soils or synthetic
materials. Both types of liners can react with certain wastes thus causing
liner degradation and increasing the permeability of the liners over time.
For example, strong acids capable of dissolving soil components increase the
permeability of clay barriers, and some organic solvents degrade synthetic
liners. The likelihood of liner degradation should be evaluated individually,
because the processes depend on the site-specific composition of both the
leachate and the liner material.
Although liners may remain effective in preventing waste migration from
the unit until well after closure, their principal role occurs during the
active life of the unit. While the unit is operational, the liner is relied
upon to contain the hazardous wastes. Liquids are removed during operation of
the facility, at closure, and during post-closure care, to further protect the
integrity of the liner. Scenario 2 in Exhibit B-2 illustrates how the
integrity of the liner system nay influence the decision about the length of
the post-closure care period.
Final Cover. A final cover that remains viable prevents releases by
minimizing leachate formation through infiltration. Cover materials may
include clay, synthetic liners, or natural soil, all of which may vary in
thickness and may or may not have an upper vegetative covering. The
regulations specify, however, that the cover must be at least as impermeable
as the bottom liner.1 In addition, if a synthetic layer is used in the
2 40 CFR 264.221(c), 264.301(c), 265.221(a), and 265.301(c) require
double liners and leachate collection systems for new impoundments and
landfills, and §§264.251 and 265.251 require single liners and leachate
collection systems for new waste piles which will reduce some of the
variations currently found in facility designs.
1 40 CFR 264.310 and 265.310.
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B-13 OSWER Policy Directive
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bottom liner, a synthetic layer must also be used in the cover. Because of
the importance of the final cover in preventing releases, the Regional
Administrator or State Director should consider how well the cover has
performed during the post-closure care period to date.
Leachate collection, detection, and removal systems. Most surface
impoundments, waste piles and landfills are required to have leachate
detection and removal systems installed above the lowest liner. New landfill
units must have leachate collection systems both above and below the upper
liner.* The owner and operator must continue to operate the leachate
collection and removal system during the post-closure care period until
leachate is no longer detected. If leachate is generated well into the
post-closure care period, this could suggest a cover or liner failure
warranting an extension of the post-closure care period. On the other hand,
if leachate is not detected or collected in the system, the Regional
Administrator or State Director should evaluate whether the leachate
collection system is functioning properly, i.e., whether it is capable of
withstanding chemical attack from leachate-containing materials in the
facility, whether it can withstand pressure from the weight of the overlying
waste, and whether it functions without clogging.
Control of run-on and run-off. Various structures such as dikes,
berms, freeboard, foundations and above-ground structures must be maintained
during the post-closure care period to control run-on and run-off and aid
containment. Because such structures are integral to the prevention of
leachate formation, both the design of the structure and its maintenance will
affect the facility's ability to prevent releases and may influence the
appropriate length of the post-closure care period.
Ground-water monitoring system. Ground-water monitoring is the primary
means of detecting leachate releases and must be continued at disposal
facilities throughout the post-closure care period. In addition to reviewing
the results of monitoring tests, the reliability and sensitivity of the
ground-water monitoring system should be examined before accepting the results
at face value. Contaminants in ground water experience relatively little
mixing or dispersion, and, as a result, plumes of these contaminants remain
concentrated. The plumes move slowly through most aquifers (generally in the
range of five to 50 feet/year) and typically remain for many years. An
individual plume may underlie only a very small part of the land surface and
therefore can be extremely difficult to detect. If, for example, the
integrity of the containment is in doubt yet the ground-water monitoring
system has not detected any contamination, the construction of additional
wells and continuation of the monitoring period may be appropriate.
* 40 CFR 264.221U), 264.251(c), 264.301(c), 265.221(a), 265.254, and
265.301(a).
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B-14 OSVER Policy ^'-ec
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B.2.1.3 Waste Management (Operational) Practices
Even the best-designed unit or facility must be managed properly in order
to prevent releases. Improper management during a facility's active life
(including early years of post-closure care for units closed prior to final
closure) could put excessive stress on facility structures or could result in
contamination of subsoils that might only be discovered as ground-water
contamination during the post-closure care period. The following management
practices are among those that help to ensure facility integrity:
Routine maintenance and inspections designed to
detect equipment malfunctions and physical damage to
final cover (e.g., cracks, erosion);
Emergency procedures to handle natural disasters
and catastrophic events (e.g., flooding caused by a
meteorological event);
Fast and efficient responses to accidents/spills
that may occur; and
Good compliance records.
Although sound waste management practices are not in themselves sufficient
to justify a reduction in the length of the post-closure care period, a
well-managed facility is more likely to maintain its structural integrity and
have monitoring records that could support such a reduction. On the other
hand, poor management practices may justify an extension of the period to the
extent that these practices have increased the likelihood of a serious release
occurring which would result in a threat to human health and the environment
and the potential need for corrective action. For example, a history of
frequent spills during the operating life' of a facility may suggest that the
post-closure care period should be extended to increase the likelihood that
future ground-water contamination resulting from these spills is detected and
corrective action is undertaken if needed. Information on waste management
practices (e.g., reports from on-site inspections; records of violations and
compliance orders issued; documentation regarding closure plan review; and
partial and final closure certifications) should be readily available to the
Regional Administrator or State Director.
B.2.1.4 Corrective Action Activities.
Depending on the timing of a release and the duration of the corrective
action, the compliance period and corrective action may extend beyond the
30-year post-closure care period. The regulations do not specify, however,
whether the post-closure period should be extended to be consistent with these
requirements. Nevertheless, the Agency may consider requiring an extension
of the post-closure period when the corrective action continues beyond the
thirty-year post-closure care period to ensure that the contamination
problem is not exacerbated by new releases from the containment system.
Although compliance monitoring is conducted along with the corrective action,
continued post-closure care detection monitoring would alert the Regional
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B-15 OSWER Policy Directive
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Administrator of contamination that is more wide-spread than originally
believed, or to additional releases that may occur. Scenario 3 in Exhibit B-2
illustrates the factors that should be considered at a facility undergoing
corrective action.
B.2.2 Waste Types and Characteristics
As discussed in Section B.I, the migration and attenuation of the waste
determine how widely the waste may be dispersed in the environment and whether
the release will ultimately lead to human exposure. Thus, these factors
determine the risk potential for the waste. If a unit contains toxic
wastes which pose a significant environmental hazard due to their persistence
and mobility, all else being equal, it may be appropriate to consider
extending the post-closure care period. Waste characteristics are defined by
the physical and chemical properties of the wastes, including:
Degradability: The degradation rate is a function of the
wastes' environment or surroundings. For example, a waste
exposed to the atmosphere may be degraded by the process of
photolysis (solar degradation) or hydrolysis (breakdown in
water). In the soil, biodegradation may result from enzymatic
actions. Degradation rates are higher in the uppermost portions
of a soil profile because there is greater exposure to air,
microorganisms and other biota which promote degradation.
Therefore a substance remaining in the upper levels of soil will
be more subject to degradation than one moving rapidly through
the soil. Similarly, certain biodegradable substances, such as
organic chemicals, are less likely to migrate to ground water in
a hazardous state than non-biodegradable substances because
microorganisms in the upper levels of the soil will cause them to
degrade before they reach greater soil depths and the ground
water.
Volatility: The volatility of a substance refers to its
tendency to separate into liquid and gas. This tendency depends
upon such factors as the concentration of the substance,
temperature, and vapor pressure. Certain organic solvents are
highly volatile.
Solubility: Solubility is the ability of a substance to be
dissolved in liquids. A waste with highly soluble hazardous
components (e.g., formaldehyde and phenol) would form a leachate
with higher concentrations of hazardous constituents than a waste
with hazardous components low in solubility (e.g., metals), given
equal amounts of water and waste. Wastes with a high solubility
will more readily travel from the waste disposal unit as leachate
if water infiltrates through the cover and into the waste
disposal unit and be more likely to contaminate the ground water
than insoluble compounds. Moreover, wastes that are not readily
degradable will have an even higher potential for contaminating
ground water.
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B-16 OSVER Policy Directive
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Adsorptivity: Adsorptivity measures the tendency of a
substance to cling to soil particles. Wastes containing
substances with high adsorptivity, such as PCBs and lead, are
easily bound to the soil, thus restricting their movement through
soil to ground water. Therefore, while lead is not
biodegradable, lead concentration in leachate will be attenuated
due to adsorption.
Bioaccumulation: Substances with a high bioaccumulation
rate,* such as PCBs, tend to accumulate in the tissues of
plants or wildlife.
Kinematic viscosity: The kinematic viscosity of a substance
indicates the relative rate at which a fluid containing the
substance would flow. Substances with low kinematic viscosity,
such as many organic solvents, would *orm a leacha».e which flows
more rapidly than water. Like adsorptivity, kinematic viscosity
would indicate how rapidly a leachate might move toward ground
water.
Toxicity: A chemical causes acute toxicity if it leads
to death or an illness soon after exposure. Chronic toxicity
is associated with low levels of exposure to certain chemicals
over long periods of time (e.g., exposures to a contaminated
drinking water source). Chronic responses may include cancer or
birth defects. A chemical may cause both acute and chronic toxic
responses. The type of response is generally a function of
the level and pathway of exposure. However, some substances
can be acutely toxic even in minute quantities (e.g., arsenic,
lead, mercury, and toxaphene).
In summary, an evaluation of the chemical and physical properties of a
waste should indicate the potential for a waste reaching the ground water.
For example, a waste with a very slow degradation rate but a low level of
toxicity may cause less harm to the environment than a waste that degrades
rapidly but is highly toxic. Consequently, post-closure care and monitoring
may be extended for those wastes that would impose a higher degree of hazard
over the long-term if released. Scenarios 4 and 5 in Exhibit B-2 illustrate
how information about waste characteristics might be used in a facility
evaluation.
* The octanol-water partition coefficient is often used as a relative
measure of the ability of a chemical to partition into the fatty tissues of an
organism and therefore bio-accumulate.
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B-17 OSWER Policy Directive
#9476 .. 5
B.2.3 Environmental and Health Considerations
Environmental considerations include information about the soil,
ground water, topography, and climate such as:
Unsaturated zone (soil)
identity of the subsurface media (e.g., soil and/or rock);
chemical composition of soil subsurface media;
soil porosity/bulk density/hydraulic conductivity;
type of. surface soils.
Saturated zone (ground water)
depth to 6round wat^, distance to wells;
hydraulic gradient and hydraulic conductivity;
structural/geologic features (e.g., existence of
aquitards, regions of relative impermeability acting as
barriers to the movement of ground water);
ground water use;
direction and rate of ground-water flow.
Topography and Geography
distance to surface water;
distance to property boundaries;
land formations, and other relevant features of the
facility and site;
surface run-off patterns.
Climatological Conditions
weather patterns;
precipitation;
temperature.
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? ' " OSWT" " .*./" -ec
#9476.00-5
Waste constituents or their subsequent degradation or transformation
products released to the environment also may pose risks to human health.
While consumption of contaminated drinking water directly threatens human
health, consumption of food products which have bioaccunmlated toxic
substances indirectly affects human health. Population density, uses of
ground and surface water, and present and potential surrounding land use
should be considered when gauging potential exposures and thus the
cumulative level of risk.' Scenarios 6 and 7 in Exhibit 6-2 describe
situations in which the population at risk would enter into the deliberations
concerning post-closure care.
' Strategies for protecting ground water have been a recent subject of
EPA attention. Several states have also begun developing ground-water
protection strategies. See: Environmental Protection Agency, "A Ground Water
Protection Strategy for the Environmental Protection Agency," August 1984.
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OSWER Policy Directive
APPENDIX C #9476.00-5
CLOSURE, CONTINGENT CLOSURE, AND
POST-CLOSURE PLAN CHECKLISTS
This appendix contains checklists which identify the necessary types of
information that should be addressed in a closure or post-closure plan. A
closure plan checklist is provided for seven major types of hazardous waste
management units:
Container Storage and Handling Units;
Tank Storage and Treatment Systems;
Surface Impoundments;
Waste Piles;
Land Treatment;
Landfills; and
Incineration Systems.
Also included is a checklist identifying the activities to be included in
a contingent closure plan required for permitted surface impoundments and
waste piles that do not satisfy the specified liner requirements, and for
permitted and interim status tank systems without secondary containment (see
Section 2.1.3 of the main text). In addition, a post-closure plan checklist
applicable to all facilities with disposal units is provided.
This appendix does not include checklisks for miscellaneous hazardous
waste technologies, such as placement of wastes in underground mines, thermal
treatment other than incinerators (e.g., molten-salt pyrolysis, wet-air
oxidation), open burning/open detonation of explosive wastes, certain
chemical, physical, and biological treatment units, some water disposal
activities, and research in miscellaneous units. These checklists may be
provided at a later date as updates to this guidance manual.
The purpose of the checklists is to indicate the types of information to
be included in a plan and to present a suggested format for organizing the
information. The checklists also include the applicable regulatory citations
for reference. The closure plan checklists are organized into three major
sections:
Facility Description -- Discusses design and operating
information about the unit and the relationship of the unit to
other hazardous waste management units, if any, at the facility to
provide a basis for discussions of closure procedures;1
1 Where a Part B permit application has been submitted for the unit,
much if not all of the information listed under Facility Description will have
been presented in the application. The closure plan need o.ily reference the
appropriate sections of the Part B application where this information is to be
found.
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Closure Procedures -- Describes the steps necessary to
perform closure of the unit; and
Closure Schedule -- Presents timing and scheduling
information for all of the partial and final closure activities.
The suggested format for the post-closure plan checklist conforms to the key
post-closure care activities, namely monitoring and routine maintenance
activities.
Each checklist is designed to address all the possible types of
information that may be necessary to include in a plan for that specific
process type unit. Because site-specific conditions play a considerable role
in shaping closure and .post-closure plans, not all items on the checklist may
be applicable to a particular unit or facility. For example, if all waste
inventory from the closure of a tank storage system is to be sent off site for
disposal, there will be no need to describe on-site treatment or disposal
methods for these wastes. Similarly, if it can be demonstrated that there
will always be sufficient capacity available in an operating landfill cell to
dispose of waste inventory at any time during the active life of the facility,
then there will be no need to provide information on the design and
construction of a new cell.
For the convenience of the checklist user, each item on the checklist
includes a space to note whether the specific information is provided in the
plan or is "not applicable". In addition, it includes a corresponding space
on the page to accommodate a brief written comment or note explaining why
certain information is not applicable. This information may help to serve as
an outline in preparing the closure plan, as well as a management tool for
reviewing the plans.
In preparing or reviewing a closure plan for a multiple process facility,
the user should refer to each of the applicable process-specific checklists.
For example, for a facility comprised of container storage and handling units,
tank treatment, and landfills, all three checklists should be used. Because
the checklists address activities on a per-unit basis, the landfill checklist,
for example, does not address the procedures for removing and handling the
waste inventory associated with the treatment tank system. In preparing the
closure plan, however, the owner or operator may choose to describe certain
closure activities on a per-facility basis (see Section 2.2 of the main text).
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CLOSURE PLAN CHECKLIST:
CONTAINER STORAGE AND HANDLING UNITS
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OSWER Policy Directive
#9476.00-5
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Page 2 of 3
EPA 1.0.
NO I
SUBJECT REQUIREMENT PART 26M/265 PROVIDED APPLICABLE COMMENIS
o On-slte treatment
o On-slte disposal
o Transportation distance off-site
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2.3 Procedures for decontamination 26U.112(b)(1)/265.112(b)('i);
and/or disposal: 26H.1 Hi/265.1 Hi; 26«4.228(a)/
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List or sketch of potentially
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PART 261/265
PROVIDED
NO I
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COMMENTS
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Testing and analyses to be performed
Criteria Tor evaluating adequacy
Schedule of inspections
Types of documentation
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o Total time to close
3.U Request for extension to deadlines
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CLOSURE PLAN CHECKLIST:
LANDFILLS
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CLOSURE PLAN CHECKLIST
LANDfILLS
EPA 1.0.
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SUBJECT REQUIRfMENT
PART
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1. EACLLITY OESCRIJMION
1.1 General description (e.g., size,
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1.? Topographic map
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o Corrective actions
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-------
Page 2 of
CLOSURE PLAN CHECKLIST
LANDMLIS
EPA l.O.
SUBJECT REQUIREMENT
PAST 26'l/265
PROVIDED
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26i|. 11?(b)(3)
265.112(b)(3)
Trench excavation ft
InstaIlation
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Leachate system Installation
Run-on and run-off control system
Ground-water monitoring system
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Equipment to be used
Special requirements for incompatible,
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Soil, other material, and labor
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Equipment/structures demolition
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-------
EPA 1.0.
CLOSURF PLAN CMFCKI1ST
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o Procedures Tor contaminated soil removal
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CLOSURE PLAN CllfCKLIST
INCINERATION SYSTEMS
EPA 1.0.
SUBJECT REQUIREMENT
PART 26'i/265
PROVIDED
NO I
APPLICABLE
COMMENTS
2. CLOSURE PROCEDURES
2.1 Estimates of maximum quantity of
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o Bulk liquid wastes
o Bulk solid wastes
o Incineration residuals (ash,
scrubber effluents)
2.2 Procedures for handling wastes to
be incinerated on-site:
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I
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261.112(b)(3)/265.1l2(b){3)
26H.112(b)(3)/265.112(b)(3);
26M.3'i5/265.3'i5
o quantities
o Waste types
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o Cleaning agent/rlnsewater treatment or
disposal (address quantities, waste
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On-site treatment/disposal
261.112(b)(i|)/265.112(b)(iO;
26H.351/265.351
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Page 14 of
CLOSURE PLAN CHECKLIST
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CPA l.O.
SUBJECT REQUIREMENT
PART 261/265
rnovioro
NOF
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3.
-------
OSVER Policy Directive
on-s
POST-CLOSURE PLAN CHECKLIST
ICF INCORPORATED
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