oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9545.00-2
TITLE: RCRA Permit Quality Protocol
APPROVAL DATE:
EFFECTIVE DATE: 7/1/86
ORIGINATING OFFICE: osw
FINAL
D DRAFT
STATUS:
t ]
A- Pending OMB approval
B- Pending AA-OSWER approval
i C- For review &/or comment
[ ] D- In development or circulating
REFERENCE (Other document*): headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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EPA
Wasnmgton. DC 20460
OSWER Directive Initiation Request
9545.00-2
Name of Contact Person
r.i 1 i an Ranns
Mail Code - Branch
Teiepnone Numoer
Lead Office
D OERR
D OSW
D OUST
LJ OWPE
LJ AA-OSWER
Approved for Review
Signature of Office Director
Date
Tale
RCRA Permit Quality Protocol
Summary of Directive
SUMMARY
SUBJECT: Review of Permits/Closure Plans to Determine Quality.
AUDIENCE: HQ, Regions, and States
Document provides a format for evaluating the quality of RCRA permits
and closure plans issued by States or EPA.Regions and is designed to
identify omissions or inadequate provisions/conditions.
Key Words:
Permit, Closure
Type of Directive /Manual. Policy Directive. Announcement, etc./
Status
D Draft
LJ Final
LJ New
I I Revision
Does this Directive Supersede Previous Directive(s;> fj Yes |_J No Does It Supplement Previous Directives)' (_J Yes [j No
If "Yes" to Either Question. What Directive (number, tulei
Review Plan
D AA-OSWER D OUST
D OERR D OWPE
U OSW LJ Regions
D OECM
D OGC
LJ OPPE
a
his Request Meets OSWER Directives System Format
igrature of Lead Office Directives Officer
1 Date
gnature of OSWER Directives Officer
! Date
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FPA SOLID WASTE
RCRA PERMIT QUALITY
PROTOCOL
U.S. Environmental Protection Agency
August
1986
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RCRA PERMIT QUALITY
PROTOCOL
This publication was prepared
for the Office of Solid Waste
under Contract No. 68-01-7038
by
A.T. Kearney, Inc.
Baker Engineers
E.H. Pechan & Associates
U.S. Environmental Protection Agency
August
1986
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DISCLAIMER
This document was furnished to the Environmental Protection Agency
by A.T. Kearney, Inc., in fulfillment of Contract No. 68-01-7038,
Assignments Nos. HOO-04-01 and HOO-OA-03. The opinions, findings, and
conclusions expressed are based on the best information currently
available. As new data and information are obtained, the manual may be
revised to reflect that situation. Mention of company or product names
is not to be considered as an endorsement by the Environmental
Protection Agency.
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TABLE OF CONTENTS
Title Page No.
General Instructions
Introduction 1
Background Information 2
Procedural Requirements 2
RCRA Permit Checklist 3
Permit Condition Evaluation Guidance 4
References 6
Part 1 - Background Information 1-1
Part 2 - Procedural Requirements
Administrative Records 2-1
Public Notice and Comment 2-2
Records of Modification 2-2
Review by Counsel 2-3
Part 3 - Permit Checklist
I - Standard Conditions 3-1
II - General Facility Conditions 3-3
III - Storage in Containers 3-9
IV - Storage or Treatment in Tanks 3-10
V - Surface Impoundments 3-11
VI - Waste Piles • 3-13
VII - Land Treatment 3-15
VIII - Landfills 3-18
IX - Incineration 3-21
X - Groundwater Monitoring - Detection Monitoring
Program 3-25
XI - Groundwater Monitoring - Compliance Monitoring
Program 3-26
XII - Groundwater Monitoring - Corrective Action
Program 3-27
Part 4 - Permit Condition Evaluation Guidance
I - Standard Conditions 4-1
II - General Facility Conditions 4-3
III - Storage in Containers 4-9
IV - Storage or Treatment in Tanks 4-12
V - Surface Impoundments 4-13
VI - Waste Piles 4-34
VII - Land Treatment Units 4-51
VIII - Landfills 4-62
IX - Incineration 4-87
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TABLE OF CONTENTS
- continued -
Title Page No.
X - Groundwater Monitoring - Detection Monitoring
Program 4-92
XI - Groundwater Monitoring - Compliance Monitoring
Program 4-99
XII - Groundwater Monitoring - Corrective Action
Program 4-105
Appendix A - Checklist for RCRA Research, Development and
Demonstration Permits A-l
Appendix B - Protocol for Evaluating Permit Conditions
Related to Corrective Action for Continuing
Releases B-l
ii
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RCRA PERMIT QUALITY PROTOCOL
GENERAL INSTRUCTIONS FOR PERMIT REVIEWS
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GENERAL INSTRUCTIONS FOR PERMIT REVIEWS
INTRODUCTION
This protocol has been developed to provide a format for evaluating
the quality of RCRA permits issued by states or by EPA Regions. It is
intended for use by technical or non-technical personnel, and is de-
signed to assist in detecting omissions and inadequate permit con-
ditions. Effective use of the protocol requires a working knowledge of
the RCRA regulations and Agency policy and guidance, along with some
familiarity with the format and content of RCRA permits. EPA and State
staff also may find the protocol a useful aid in reviewing permit
applications and drafting permits.
The protocol is divided into four major parts. These are:
o Part 1 - Background Information
o Part 2 - Procedural Requirements
o Part 3 - Permit Checklist
o Part 4 - Permit Condition Evaluation Guidance
Certain requirements of the Hazardous and Solid Waste Amendments of
1984 are addressed in Appendices. Appendix A provides a checklist of
permit conditions required in Research, Development and Demonstration
(R.D&D) permits. Because of the process-specific nature of R,D&D permit
conditions, no permit condition evaluation guidance is provided.
Appendix B contains a protocol for evaluating permit conditions related
to corrective action for continuing releases for solid waste management
units.
The structure of the protocol lends itself to a multi-level review
of a permit. After determining that the administrative record for a
facility is complete and the appropriate procedural requirements were
followed, the reviewer can use Parts 3 and 4 of the protocol to deter-
mine if the permit contains the required conditions and if the con-
ditions are technically sound and enforceable.
Field testing of the protocol has shown that use of the Checklist
for Permit Conditions (Part 3) to determine if the permit contains all
required conditions results in a rapid, preliminary indication of the
quality of a permit. This suggests two approaches to auditing permits.
A large number of permits can be examined rather rapidly using only
Parts 1 through 3 of the protocol. The reviewer may wish to confirm the
conclusions of that process by spot checking the quality of a few permit
conditions using the evaluation criteria of Part 4 of the protocol.
Alternatively, the reviewer may want to focus on fewer permits by
applying the entire protocol to each permit examined. Although more
time consuming, this approach results in a thorough audit of each permit
examined.
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Field testing of the protocol showed that audit of a storage permit
using only Part 1 through 3 requires only a couple of hours, while
auditing a land disposal permit in the same fashion requires four to
five hours. Full audit (using Parts 1-4) of a storage permit requires
approximately four hours. Full audit of a land disposal permit requires
eight hours or more.
The most effective use of the protocol may be to combine these two
approaches. That is, Parts 1 through 3 of the protocol are applied to
all permits to be audited, with certain of those permits selected for
more intense scrutiny utilizing the Part 4 evaluation guidance.
Below is a brief description of each part of the protocol, with
comments on their use.
PART 1 - BACKGROUND INFORMATION
This portion of the protocol focuses on data and information about
the facility and the wastes handled. Most of the information needed to
complete the form can be obtained from three sources: 1) the appli-
cant's Part A application; 2) the General Facility Description contained
in the Part B application; and 3) the Fact Sheet or Statement of Basis
associated with the permit.
Completion of the background information form provides the reviewer
with the information needed to determine what portions of the Permit
Checklist (Part 3) and the Permit Condition Evaluation Guidance (Part 4)
are applicable to the permit undergoing review. It also enables the
reviewer to recognize which conditions (such as those related to the
handling of reactive, ignitable or incompatible wastes) must be in the
permit.
PART 2 - PROCEDURAL REQUIREMENTS
The procedural requirements checklist guides the reviewer in
evaluating the following:
1) whether the administrative record is complete;
2) whether the proper steps have been taken in soliciting public
comment and in issuing the draft permit;
3) whether adjustments to the permit have been made to reflect
substantive public comments; and
4) whether any modifications to the permit have been properly
made.
A key consideration is the permit file or administrative record.
The materials found in the administrative record should document and
support permit conditions. The evaluation of permit conditions con-
ducted under Part 4 of this protocol relies heavily upon scrutiny of the
various documents found in the administrative record. Inventory of the
administrative record enables the reviewer not only to assess its
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completeness, but also to become familiar with its contents in prepara-
tion for evaluating the permits.
PART 3 - RCRA PERMIT CHECKLIST
The RCRA permit checklist is a structured listing of all regulatory
permit conditions. The checklist is organized in twelve sections
loosely paralleling the organization of a permit. They are:
I Standard Conditions
II General Facility Conditions
III Storage in Containers
IV Storage or Treatment in Tanks
V Surface Impoundments
VI Waste Piles
VII Land Treatment
VIII Landfills
IX Incineration
X Groundwater Monitoring - Detection Monitoring Program
XI Groundwater Monitoring - Compliance Monitoring Program
XII Groundwater Monitoring - Corrective Action Monitoring
Program
Sections I (Standard Conditions) and II (General Facility Condi-
tions) are found in all permits. The remaining sections address the
various units that a given facility may contain and their regulatory
status. This approach allows the reviewer to check for all permit
conditions or to spot check by checking those conditions associated with
certain sections of the permit.
The checklist is intended to be an administrative checklist for
recording the presence or absence of each required permit condition.
The actual quality (or adequacy) of a condition is considered in greater
detail in Part 4 of the protocol. Checklist items included in the
protocol are denoted with a "+" symbol in the left-hand margin.
If a required condition is not found in the permit, the reviewer
must check the permit file or the administrative record prior to record-
ing that condition as missing. An explanation must be provided for any
requirement intentionally waived or deleted from the permit. If a fact
sheet has been prepared for the facility, the explanation must be
provided in the fact sheet.
In completing the checklist the reviewer simply marks each item as
provided (denoted by Y), not provided (denoted by N), or as not appli-
cable (denoted by NA) and indicates the location of the item. The
comments column may be used by the reviewer for any notations desired.
For example, the reviewer may provide a reminder to check a certain
permit condition using the Permit Condition Evaluation Guidance
(Part A). Or, the reviewer may provide a notation to discuss the
rationale for a condition with the permit writer.
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PART 4 - PERMIT CONDITION EVALUATION GUIDANCE
Part 4 of the protocol provides a format and guidance for evaluat-
ing the adequacy of selected permit conditions. The conditions included
in this portion of the protocol are those generally believed to be more
critical to the proper regulation of hazardous waste management units
and/or those having a high potential for problems in translating regu-
latory requirements to permit conditions. These items are denoted on
the permit checklist with a "+" in the left-hand margin.
Part 4 is designed to evaluate permit conditions for three
criteria:
1) consistency with regulations and applicable guidance;
2) technical soundness; and
3) enforceability.
The evaluation guidance for each permit condition consists of a
matrix with four columns - regulatory requirement, evaluation criteria,
references, and findings/comments.
The regulatory requirement consists of a brief statement defining
what the permit condition must address or encompass. This enables the
reviewer to evaluate if the developed permit condition is consistent
with regulations and appropriate guidance. This protocol addresses two
types of permit conditions - those directly mandated by regulation (such
as those required by 40 CFR Part 270) and those which specify the steps
to be taken by the permittee in meeting performance standards specified
by statute or regulation. The latter type occurs most frequently when
considering design, construction, and operation of TSD units.
The evaluation criteria consider technical soundness and enforce-
ability. Technical soundness encompasses both technical correctness and
proper documentation and supporting evidence for the technical content
of a permit condition. This protocol does not consider the direct
evaluation of technical adequacy, but rather identifies the technical
items that must be addressed by the condition and those documents,
analyses, etc., that support the condition and must be in the adminis-
trative record. This should enable the reviewer to ascertain whether
the permit condition was properly derived and whether the process
followed is properly documented in the record.
Every permit condition should be enforceable in some manner.
Enforcement mechanisms include document submittal and monitoring and
recordkeeping by the owner/operator, and inspection of facilities and
records by the agency. Enforcement mechanisms, other than agency
inspection, must be-stated as permit conditions.
The enforceability of a permit condition is often a function of the
specific wording in the permit. For example, a permit condition stating
that "... a run-on/runoff control system must be inspected weekly",
leaves no doubt, or point for argument, as to the required frequency of
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inspection. However, a similar permit condition stating that "...
run-on/runoff control systems will be inspected as deemed necessary"
would be more difficult to enforce because the definition of "as deemed
necessary" could be argued by the permittee. Therefore, in order for a
permit condition to be enforceable, it must be stated in a clear,
concise, and definitive manner that will minimize the possibility of
misinterpretation.
The column headed "References" lists those guidance documents and
other sources where the reviewer can obtain additional guidance or
clarification. In the interest of brevity, the document titles are
abbreviated. The following four pages contain a listing of references
cited in this protocol and their corresponding abbreviations.
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REFERENCES
ABBREVIATION
General Facility
Conditions
PAGM-GFS
PAGM-CLAEAR
REFERENCE
PWGD-HW Tanks
PAGM
Containers
PWGD-Containers
Tanks
PWGD-HW Tanks
Tank Guidance Memo
Waste Piles
WPDLS
Liner Systems
PWGM
U.S. EPA. 1983. Permit Applicant's Guidance
Manual for the General Facility Standards of
Part 264.
U.S. EPA. 1984. Permit Writers' Guidance Manual
for Hazardous Waste Land Storage and Disposal
Facilities - Criteria for Location Acceptability
and Existing Applicable Regulations.
U.S. EPA. Undated. Draft Permit Writers' Guidance
Manual for Hazardous Waste Tanks. U.S. EPA
Region II. New York.
U.S. EPA. 1984. Permit Applicants' Guidance
Manual for Hazardous Waste Land Treatment,
Storage, and Disposal. EPA/530 SW-84-004.
U.S. EPA. 1982. Draft Guidance for Permit
Writers - Facilities Storing Hazardous Waste in
Containers. U.S. EPA, Office of Solid Waste.
Washington, D.C.
U.S. EPA. Undated. Draft Permit Writers' Guidance
Manual for Hazardous Waste Tanks. U.S. EPA
Region II. New York.
Skinner, John H. Undated. Draft Memorandum to
Regional RCRA Branch Chiefs - Guidance on
Permitting of Hazardous Waste Treatment/Storage
Tanks.
U.S. EPA. 1982. Draft RCRA Guidance Document:
Waste Pile Design.
U.S. EPA. 1983. Permit Writers' Guidance Manual
for Hazardous Waste Land Treatment, Storage, and
Disposal Facilities.
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ABBREVIATION
REFERENCE
SW-846
NSF9
SW-870
SW-869
SW-84-001
SW-925
GDLS
Surface Impoundments
PWGM
PAGM
HSWA
Liner Memo
GDLS
SW-846
NSF
U.S. EPA. 1982. Test Methods for Evaluating Solid
Waste - Physical and Chemical Methods. SW-846.
National Sanitation Foundation. 1983. Stan-
dard 54: Flexible Membrane Liners.
U.S. EPA. 1983. Lining of Waste Impoundment and
Disposal Facilities. SW-870.
U.S. EPA. 1983. Landfill and Surface Impoundment
Performance Evaluation. SW-869.
U.S. EPA. 1984. Procedures for Modeling Flow
Through Clay Liners to Determine Required
Thickness. EPA/530-SW-84-001.
U.S. EPA. 1984. Soil Properties, Classification,
and Hydraulic Conductivity Testing. SW-925.
U.S. EPA. 1984. Draft Minimum Technology Guidance
on Double Liner Systems for Landfills and
Surface Impoundments—Design, Construction, and
Operation.
U.S. EPA. 1983. Permit Writers' Guidance Manual
for Hazardous Waste Land Treatment, Storage, and
Disposal Facilities.
U.S. EPA. 1984. Permit Applicants' Guidance
Manual for Hazardous Waste Land Treatment,
Storage, and Disposal. EPA/530 SW-84-004.
Hazardous and Solid Waste Amendments of 1984.
McGraw, Jack. 1985. Draft Guidance Memorandum -
Implementation of Minimum Technology Require-
ments of HSWA of 1984, Respecting Liners and
Leachate Collection Systems.
U.S. EPA. 1984. Draft Minimum Technology Guidance
on Double Liner Systems for Landfills and
Surface Impoundments—Design, Construction, and
Operation.
U.S. EPA. 1982. Test Methods for Evaluating Solid
Waste - Physical and Chemical Methods. SW-846.
National Sanitation Foundation. 1983.
dard 54: Flexible Membrane Liners.
Stan-
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ABBREVIATION
REFERENCE
SW-870
SW-869
SW-84-001
SW-925
Landfills
HSWA
Liner Memo
PWGM
GDLS
CQA
BLM
SW-846
NSF
SW-870
SW-869
U.S. EPA. 1983. Lining of Waste Impoundment and
Disposal Facilities. SW-870.
U.S. EPA. 1983. Landfill and Surface Impoundment
Performance Evaluation. SW-869.
U.S. EPA. 1984. Procedures for Modeling Flow
Through Clay Liners to Determine Required
Thickness. EPA/530-SW-84-001.
U.S. EPA. 1984. Soil Properties, Classification,
and Hydraulic Conductivity Testing. SW-925.
Hazardous and Solid Waste Amendments of 1984.
McGraw, Jack. 1985. Draft Guidance Memorandum -
Implementation of Minimum Technology Require-
ments of HSWA of 1984, Respecting Liners and
Leachate Collection Systems.
U.S. EPA. 1983. Permit Writers' Guidance Manual
for Hazardous Waste Land Treatment, Storage, and
Disposal Facilities.
U.S. EPA. 1984. Draft Minimum Technology Guidance
on Double Liner Systems for Landfills and
Surface Impoundments—Design, Construction, and
Operation.
U.S. EPA. 1985. Construction Quality Assurance
for Hazardous Waste Land Disposal Facilities.
Draft. EPA/530-SW-850021.
U.S. EPA. 1985. Prohibition on the Disposal of
Bulk Liquid Hazardous Wastes in Landfills.
Statutory Interpretive Guidance. Draft (May 6).
U.S. EPA. 1982. Test Methods for Evaluating Solid
Waste - Physical and Chemical Methods. SW-846.
National Sanitation Foundation. 1983. Stan-
dard 54: Flexible Membrane Liners.
U.S. EPA. 1983. Lining of Waste Impoundment and
Disposal Facilities. SW-870.
U.S. EPA. 1983. Landfill and Surface Impoundment
Performance Evaluation. SW-869.
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ABBREVIATION
REFERENCE
SW-8A-001
SW-925
PAGM
LDFC
SW-867
Land Treatment
PGM-HWLTD
PGM/UZM-HWLT
HWLT
PAGM
Incineration
GM-HWIP
MP
EH-HWI
Groundwater Monitoring
PWGM-GWP
MGWSP
U.S. EPA. 198A. Procedures for Modeling Flow
Through Clay Liners to Determine Required
Thickness. EPA/530-SW-84-001.
U.S. EPA. 1984. Soil Properties, Classification,
and Hydraulic Conductivity Testing. SW-925.
U.S. EPA. 1984. Permit Applicants' Guidance
Manual for Hazardous Waste Land Treatment,
Storage, and Disposal. EPA/530 SW-84-004.
U.S. EPA. 1982. Draft RCRA Guidance Document -
Landfill Design. Liner Systems and Final Cover.
U.S. EPA. 1982. Evaluating Cover Systems for
Solid and Hazardous Wastes. SW-867.
U.S. EPA. 1984. Permit Guidance Manual on
Hazardous Waste Land Treatment Demonstrations.
EPA/530-SW-84-015.
U.S. EPA. 1984. Permit Guidance Manual on
Unsaturated Zone Monitoring for Hazardous Waste
Land Treatment Units. EPA/530-SW-84-016.
U.S. EPA. 1983. Hazardous Waste Land Treatment.
SW-874.
U.S. EPA. 1984. Permit Applicants' Guidance
Manual for Hazardous Waste Land Treatment,
Storage, and Disposal. EPA/530 SW-84-004.
U.S. EPA. 1983. Guidance Manual for Hazardous
Waste Incinerator Permits.
U.S. EPA. 1983. Model Permit for Hazardous Waste
Treatment, Storage and Disposal Facilities.
U.S. EPA. 1980. Engineering Handbook for
Hazardous Waste Incineration.
U.S. EPA. 1983. Permit Writers' Guidance Manual
for 264 Subpart F Groundwater Protection.
U.S. EPA. 1981. Manual of Groundwater Quality
Sampling Procedures.
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ABBREVIATION REFERENCE
ACLG U.S. EPA. 1985. Alternate Concentration Limit
Guidance Based on §264.94(b) Criteria. Part
Information Required in ACL Demonstrations.
TEGD U.S. EPA. 1986. RCRA Groundwater Monitoring
Technical Enforcement Guidance Document.
10
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RCRA PERMIT QUALITY PROTOCOL
PART 1. BACKGROUND INFORMATION
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RCRA PERMIT QUALITY PROTOCOL
BACKGROUND INFORMATION
Facility Name:
Location:
EPA I.D. Number:
Owner/Operator:
Treatment/Storage/Disposal Units Addressed by Permit:
Existing New
Unit Unit
Container Storage
Storage in Tanks
Treatment in Tanks
Waste Piles
Storage Surface Impoundments
Disposal Surface Impoundments
Landfills
Land Treatment Demonstration
Land Treatment Units
Incinerator (Short-term Operations)
Incinerator (Full Operations)
Other
Does the permit cover all treatment, storage and disposal units at the
facility?
Yes No
List the major wastes or types of wastes handled at the facility.
Are wastes from off-site generators handled at the facility?
Yes No
Are reactive or ignitable wastes handled at the facility?
Yes No
1-1
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RCRA PERMIT QUALITY PROTOCOL
BACKGROUND INFORMATION
- Continued -
Are incompatible wastes handled at the facility?
Yes No
List the TSD units where reactive, ignitable or incompatible wastes
are handled.
If groundwater monitoring is required at the facility, do the data
obtained during the interim status monitoring program show any evidence
of groundwater contamination?
Yes No N.A.
Have there been identified at the facility any solid waste management
units (SWMU) other than the hazardous waste management units covered
in the permit?
Yes No
Have any releases (or probable releases) been identified that require
corrective action or that require additional studies to characterize?
Yes No
Have any enforcement actions been taken against the owner/operator of
the facility?
Yes No Enforcement files
not reviewed
If yes, briefly describe.
1-2
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RCRA PERMIT QUALITY PROTOCOL
BACKGROUND INFORMATION
- Continued -
Type of permit: Draft Final
Issuing Agency: EPA Region State Joint
Reviewer:
Date:
1-3
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RCRA PERMIT QUALITY PROTOCOL
PART 2. PROCEDURAL REQUIREMENTS
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RCRA PERMIT QUALITY PROTOCOL
PROCEDURAL REQUIREMENTS
ADMINISTRATIVE RECORDS
The contents of the administrative record (file) associated with the
permit must be inventoried. Indicate below the items contained in the
file.
Permit application (Parts A and B) and any support data, technical
reports, etc., provided by the applicant.
Documentation resulting from the agency's completeness review of
the permit application.
Any notices of deficiency sent to the applicant, along with the
applicant's amended or supplemental information.
Pre-permit site inspection report.
Documentation resulting from the agency's technical evaluation of
the permit application.
Exposure Information Report (EIR) along with documentation of
agency's review findings.
Applicant's report addressing solid waste management units (SWMU)
and releases and the agency's RCRA Facility Assessment (RFA) or
Preliminary Assessment/Site Investigation (PA/SI) Report.
Applicant's certification (see §270.73) of compliance with
groundwater monitoring and financial responsibility requirements
(for land disposal facilities only).
Applicant's certification of waste minimization.
The draft permit.
Statement of basis or fact sheet.
All documents cited in statement of basis or fact sheet.
If the permit is a final permit, note the presence of the following
additional items in the file.
Public Notice(s).
All comments received during the public comment period.
Tape or transcript of any hearings held and any written materials
submitted at hearings.
Responses to significant comments posed during the comment period
and/or hearing.
2-1
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Final permit.
Explanation of changes from draft to final permit.
Where applicable, materials relating to:
o Consistency determinations under Coastal Zone Management Act
o Consultation under the Endangered Species Act
o Determination under Section 403(c) of the Clean Water Act
o Consistency with the Wild and Scenic Rivers Act
o Cooperation with the National Historic Preservation Act
o Consistency with the Fish and Wildlife Coordination Act
o Other (state, local) laws and regulations
Where applicable, appropriate documentation for modification of the
permit (including public participation activities, where
necessary).
PUBLIC NOTICE AND COMMENT
Was a public notice issued announcing availability of the draft permit
and providing an opportunity for comment at least 45 days prior to final
permit decision?
Yes No
If a public hearing was held, was a notice of public hearing issued at
least 30 days prior to the hearing?
Yes No
Was a summary response to significant comments raised during the comment
period and/or hearing prepared and issued at the time of final permit
decision?
Yes No
RECORDS OF MODIFICATION (to be completed if the permit was modified, or
revoked and reissued)
Was the permit modified pursuant to 40 CFR 270.41?
If yes, specify the basis identified in the permit documentation
(alterations; new information; new regulations; compliance schedules;
variance request; reopener)
Yes No
2-2
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Did cause exist for modification or revocation and reissuance pursuant
to 40 CFR 270.41(a)?
Yes No
If yes, specify the cause:
a. Cause exists for termination, as provided in 40 CFR 270.43 (noncom-
pliance; misrepresentation of or failure to disclose facts; endan-
germent to human health or environment; change in condition);
b. Transfer of permit;
c. Other (specify)
Does the permit documentation indicate that the procedures of 40 CFR
124.5 for permit modification, revocation and reissuance or termination
were followed?
Yes No
Were minor modifications made to the permit?
Yes No
If yes, indicate the specific reasons as per 270.42.
Does the administrative record contain documentation of consent by
permittee to those minor modifications?
Yes No
REVIEW BY COUNSEL
Does the administrative record contain documentation of review and
approval of the permit by agency counsel?
Yes No
Reviewer:
Date:
2-3
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RCRA PERMIT QUALITY PROTOCOL
PART 3. PERMIT CHECKLIST
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Fac iIi ty Name
ID No.
RCRA PERMIT CHECKLISr
Prov ided
(Y/N) or NA
Locat ion
Comments
I STANDARD CONDITIONS
A Effect of Permit [§§270.4, 270.30(g)J
B Permit Actions (§270.30(f)J
C SeverabiIity [§124.16(a)]
D Duties and Requirements
D-1 Duty to comply [§270.30(a>]
D-2 Duty to reapply [§§270.30(b), 270.10(h)J
D-3 Permit expiration [§270.51]
D-U Need to halt or reduce activity not a
defense .[§270.30(c)J
D-5 Duty to mitigate [§270.30(d)J
D-6 Proper operation and maintenance
[§270.30(e)J
D-7 Duty to provide information [§§270.30(h ),
26«l.7l4(a) J
D-8 Inspection and entry [§270.30(i)J
D-9 Monitoring and records [§§270.30(j ),
270.30(I)(H)]
D-10 Reporting planned changes [§£70.30(I)(1) ]
D-11 Certification of construction or modification
[§270.30(l)(2)(i)J
D-12 Anticipated noncompIiance [§270.30( I )(2 ) ]
D-13 Transfer of permits [§§270.30(I)(3 ), 270.UOJ
+D-1U Compliance schedules [§270.30(I ) (5) ]
D-15 Twenty-four hour reporting [§§270.30(I)(6),
26H.56(d) and (j)]
3-1
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Provided
(Y/N) or NA Location Comments
0-16 Manifest discrepancy reports and unmanifestod
waste reports [§270.30(I)(7) and (8))
D-17 Biennial report [§270.30( I ) (9) )
D-18 Other noncompliance [§270.30(I)(10)J
D-19 Other information [§270.30( I )( 11 ) ]
E Signatory Requirements [§§270.11,
270.30(k)J
F Confidential Information [§270.12]
-t-G Documents to be Submitted Prior to Operation
[§§270.32, 270.33)
H Documents to be Maintained at Facility Site
H-1 Waste analysis plan [ §26
-------
Provided
(Y/N) or NA Location Comments
II GENERAL FACILITY CONDITIONS
A Design and Operation of Facility [§26(4.31]
B Regui red Notices [§264.12]
C General Waste Analysis [§26*1.13]
C-1 Parameters to be analyzed for in each waste
[§264.13(b)(1)]
C-2 Analytical methods [§264.13(b)(2) ]
C-3 Methods to sample wastes [§264.13(b)(3 ) ]
C-4 Frequency of analysis [§264.13(b ) (4 ) ]
C-5 Wastes f.rom off-site [ §264. 1 3(a ) ( 4) and (b)(5)J
C-6 Waste characterization requirements for
specific types of treatment and disposal
[§264.13(b)(6)]
D Securi ty [§264.14]
D-1 Description of barrier and means to control '
entry (or 24-hour surveillance system)
(§264.14(b))
D-2 Description of warning signs [§264.14(c>]
E General Inspection Requirements*
[§264.151
+E-1 General inspection schedule [§264.15(b)J
E-la items to be inspected [§264.15(b) (1 ) ]
E-1b type of problems for which each item is
inspected [§264.15(b ) (3 ) ]
E-lc inspection frequency [§264.15(b) (4 ) ]
E-2 Container storage areas [§264.174]
E-3 Tank storage/treatment areas [§264.194]
E-3a overfilling controls [§264.194(a ) (1 ) )
*ltems E-2 through E-8 to be reviewed when applicable.
3-3
-------
Provided
(Y/N) or NA Location Comments
E-3b monitoring equipment data [§264.194(a ) (2 ) ]
E-3c level of waste (uncovered tanks)
[§264.194(a)(3)l
E-3d tank construction materials [§264.294(a ) (4) ]
E-3e area surrounding tank [§264.194(a)(5)]
+E-3f schedule and procedure for assessing tank
condition and shell thickness [§264.194(b ) ]
E-4 Waste piles [§264.254]
E-4a run-on/runoff control [§264.254(b)(1)]
E-4b leak detection systems [§264.254(b)(2) ]
E-4c wind dispersal control [§264.254(b)(3)]
E-4d leachate collection/removaI system
[§264.254(b)(4)|
+E-5 Surface impoundments [§264.226]
E-5a overtopping control system [§264.226(b)(1)]
E-5b level of impoundment contents [§264.226(b) (2 ) ]
E-5c liquids in leak detection systems
[§264.226(b)(3)l
E-5d dike deterioration [§264.226(b)(4) ]
E-5e certification of dike's structural
integrity [§264.226(c) ]
E-6 Incinerators [§264.347]
E-6a incinerator/associated equipment [§264.347(b) ]
E-6b waste feed cut-off system testing [§264.347{c) ]
E-7 LandfiI Is [§264.303]
E-7a run-on/runoff control [§264.303(b)(1) ]
E-7b liquids in leak detection system
[§264.303(b)(2>]
E-7c wind dispersal control [§264.303(b) (3 ) ]
3-4
-------
Provided
(Y/N) or NA Location Comments
E-7d leachate coIlection/removaI system
[§264.303(b)(4)J
E-8 Land treatment units [§264.273]
E-8a run-on/runoff control [§264.273(g ) (1)]
E-8b wind dispersal control [§264.273(g ) (2) ]
F Personnel Training [§264.16]
F-1 Program director [§264.16(a ) (2) ]
F-2 Training program contents [§264.16(a)(3) ]
F-3 Frequency of training [§264.16(6) and (c)]
G General Requirements for Igm'table.
Reactive, or Incompatible Waste [§264.17]
G-1 Ignitable or reactive (§264.17(a)]
G-2 Incompatibles [§264.17(b)J
H Location Standards [§§264.18, 270.14(b ) (11 ) ]
H-1 Seismic considerations [§264.18(a)]
+H-2 Flood proofing description/drawings (§264.18(b)]
+H-3 Flood plan [§264.18(b)]
I Preparedness and Prevention
1-1 Required equipment [§264.32]
I-2 Testing and maintenance of equipment
[§264.33]
I-3 Access to communications or alarm system
[§264.34]
I-4 Required aisle space [§264.35]
I-5 Arrangements with local authorities [§264.37]
J Contingency Plan
J-1 Implementation of plan [§264.51]
J-2 Copies of plan [§264.53]
J-3 Amendments to plan [§264.54]
3-5
-------
Prov i ded
(Y/N) or NA Location Comments
J-4 Contents of contingency plan [§264.52]
J-4a response procedures [§264.52(a>]
J-4b coordination agreements [§264.52(c)]
J-4c emergency coordinators [ §§264. 52(d ), 264.551
J-4d emergency equipment [§264.52(e)J
J-4e evacuation plan [§264.52(f) ]
J-5 Emergency procedures [§264.56]
J-5a notification [§264.56(a)l
J-5b identification of hazardous materials
(§264.56][b) J
J-5c assessment of hazards [§264.56(c>]
J-5d notification in event of threat to human
health or the environment [§264.56(d)J
J-5e prevention of recurrence or spread of fires,
explosions, or releases [§264.56(e)J
J-5f monitoring following cessation of operations
[§264.56(f))
J-5g storage and treatment of released materials
[§264.56(g)J
J-5h incompatible wastes [§264.56(h)(1) 1
J-5i post-emergency equipment maintenance
[§264.56(h)(2J]
J-5J notification and reports [§264.56(i) and (j)]
+J-6 Unit-specific control procedures (where
applicable
J-6a tanks [§264.194(c)]
J-6b waste piles [§§264.252(b ), 264.253(b)]
J-6c surface impoundments (§264.227)
K Manifest System [§§264.71, 264.72]
L Recordkeeping and Reporting
L-'l Operating record [§264.73)
3-6
-------
Provided
(Y/N) or NA Location Comments
L-2 Availability of records [§264.74)
L-3 Biennial report [§264.75)
L-4 UnmaniTested waste report [§264.76)
M General Closure Requirements*
M-1 Requirement for written plan [§264.112(a(]
M-2 Content of closure plan [§264.112(b) ]
M-2a description of final closure [§264.112(b)(2) )
M-2b maximum waste inventory [§264.112(b)(3 ) )
M-2c decontamination or removal procedures
(§§264.112(b)(4), 264.114]
M-2d other activities required to meet closure
standard [§264.112(b ) (5 ) I
M-2e closure schedule [§§264.112(b)(6 ), 264.113]
M-2f estimated year of final closure (where
applicable) [§264.112(b)(7 )
M-3 Amendment of plan [§264.112(c ) ]
M-4 Notification of partial closure and final
closure [§264.112(d)]
M-5 Removal of wastes and decontamination or
dismantling of equipment [§264.112(e ) ]
M-6 Certification of closure [§264.115]
M-7 Survey plat (where applicable) [§264.116]
N General Post-Closure Requirements
N-1 Post-closure care period [§264.117(a ) (1 ) ]
N-2 Security requirements (where applicable)
[§264.117(b)]
N-3 Post-closure use of property [§264.117(c)]
N-4 Requirement for a written plan (§264.118(a)
and (c)1
*The general closure requirements applicable to all types of hazardous waste management units are listed under item M. The
specific technical requirements applicable to each type of unit are listed under those units.
3-7
-------
Provided
(Y/N) or NA Location Comments
N-5 Contents of post-closure plan [ §264. 1 18( b ) ]
N-5a groundwater monitoring program (see Section XII
of checklist) [ §26*4 . 1 18( b) ( 1 ) ]
N-5b maintenance activities [ §26*4. 118( b) ( 2 ) ]
N-5c post-closure contact [ §26U. 1 18( b ) ( 3 ) ]
N-6 Amendment of post-closure plan [ §26U. 1 18(d ) J
N-7 Post-closure notices [§264.119]
N-7a notice to local land authority [ §264. 1 19( a ) ]
N-7b notice in deed (disposal facilities only)
(§26U.119(b) J
N-7c revision of deed notice [ §264. 1 19(c ) ]
0 Cost Estimate for Facility Closure and
Post-Closure [§§26U.1U2, 26t.mil
P Financial Assurance for Facility Closure
Q Liability Requirements [§26'4.1U7]
R Incapacity of Owners or Operators.
Guarantors, or Financial Institutions
[ §2614.1118]
3-8
-------
Provided
(Y/N) or NA Location Comments
III STORAGE IN CONTAINERS
A Condition of Containers [§264.171]
B Compatibility of Containers with Wastes
TI264.172]
C Management Requirements [§26*4.1731
+D Construction and Maintenance of Containment
System [§264.175]
D-1 Base or liner material* [§264.175(b)( 1 ) J
D-2 Design features for drainage of leaks and
spiI Is |§264.175(b)(2)l
0-3 Containment system capacity* [§264.175(b)(3 ) ]
D-4 Prevention of run-on [§264.175(b)(4 )
D-5 Procedures for removal of spills and
accumulated precipitation [§264.175(b) (5 ) ]
E Special Requirements for Ignitable or
Reactive Wastes (§264.1761
F Special Requirements for Incompatible Wastes
[§264.177]
*These requirements do not apply to container storage areas where solids only (i.e., no free liquids) are stored.
3-9
-------
Prov ided
(Y/N) or NA Location Comments
IV STORAGE OR TREATMENT IN TANKS*
B Tank Design and Construction (§264.191)
+B-1 Minimum shell thickness
B-2 Dimensions and volume of tank
B-3 Materials of construction
B-4 Tank foundation
B-5 Structural supports
B-6 Seams
B-7 Pressure controls (for closed tanks)
C General Operating Requirements [§264.192]
C-1 Measures for protection from accelerated
erosion, corrosion or abrasion [§264.192(a ) ]
C-2 Features or procedures to protect from
overfiI I ing [§264.192(b) ]
C-3 Special requirements for ignitable or
reactive wastes (NFPA buffer zone
compliance) [§264.198]
D Special Requirements for Incompatible
Wastes [§264.199]
E Special Requirements for Hazardous Wastes
F02Q, F021. F022. F023. F026. and F027
[§264.200]
*This portion of the checklist is based upon the tank regulations in effect until December.
3-10
-------
Provided
(Y/N) or NA Location Comments
V SURFACE IMPOUNDMENTS
A Impoundment Design and Construction
l§§26'4.221, 26«4.226]
A-1 Impoundment dimensions and capacity
A-2 Dike design and construction
+A-2a design specifications
A-2b material specifications
A-2c construction specifications
A-2d construction inspection program
+A-3 Hydraulic features
A-3a inlet and outlet structures
A-3b measures to prevent overtopping
A-3c freeboard maintenance
B Operating Procedures ( §26'4. 221 ( f) ]
B-1 Procedures to prevent overtopping
B-2 Specification of outflow destination
B-3 Emergency location for wastes
C Liner System* [ §26'». 221 ( a ) and (c))
+C-1 Liner system description
C-2 Synthetic liner
+C-2a synthetic liner material, thickness and
manufacturer
+C-2b synthetic liner bedding
+C-2c synthetic liner installation procedures,
including seaming
+C-2d inspection and quality assurance program
*Note: Some sites may be exempt from the liner system requirements or may have modified liner requirements.
3-11
-------
Prov ided
(Y/N) or NA Location Comments
+C-2e exposure prevention
C-3 So iI Iiner
+C-3a soil liner thickness and material
spec i f icat ions
+C-3b soil liner construction specifications
+C-3c construction inspection and monitoring program
C-4 Leachate detection system
+C-4a design specifications
+C-4b material specifications
+C-4c installation specifications
C-4d inspection program during installation
+C-5 Liner foundation preparation
D Maintenance [§§264.221, 264.227]
D-1 Leachate detection system maintenance
procedures
D-2 Liner repairs
D-3 Maintenance of dikes
E Special Requirements for Iqnitable or
Reactive Wastes t§264.2291
F Special Requirements for Hazardous Wastes
F020. F021. F022. F023. F026. and F027
f§264.231 J
G Closure Plan for Impoundments to be Closed*
With Wastes in Place (§264.2281 - see
checklist item I and J under VI I I - LANDFILLS
* Impoundments to be clean closed require contingent closure and post-closure plans.
3-12
-------
Provided
(Y/N) or NA Location Comments
VI WASTE PILES
A Design and Operating Requirements [§264.251]
A-1 Liner system* [§264.251(a ) ]
+A-1a description of liner systems
+A-1b synthetic liner
o synthetic liner material, thickness and
manufacturer
o synthetic liner bedding
o synthetic liner installation procedures,
including seaming
o inspection and quality assurance program
during instaIlat ion
o exposure prevention
+A-1c soiI Iiner
o soil liner thickness and material
spec i ficat ions
o soil liner construction procedures
o construction inspection and monitoring
prog ram
+A-1d leachate collection/detection system
o design description
o material specifications
o leachate head restriction
o installation procedures
o inspection and monitoring procedures
during instaIlat ion
+A-1e liner system foundation preparation
A-1f maintenance procedures
*Note: Some sites may be exempt from the liner system requirements or may have modified liner requirements.
3-13
-------
Prov ided
(Y/N) or NA Location Comments
o maintenance of leachate collection
detection system
o Iiner repa i rs
A-2 Run-on control system [§§270.18(b ), 264.250(c)]
A-2a design and performance
A-2b construction
A-2c ma intenance
A-3 Management of collection and holding units
A-U Control of wind dispersal I§§270.18(b),
26U.250(c)]
B Special Requirements for Ignitable or Reactive
Wastes (where applicable) |§264.256]
C Special Requirements for Incompatible Wastes
(where applicable) [126/4.257]
D Special Requirements for Hazardous Wastes
F020. F021. F022. F023. F026. and F027
[§264.259]
E Contingent Closure and Post-Closure Plans
(§?6U.258(c)] - see checklist i tems i and J
under VI I I - LANDFILLS
3-14
-------
Provided
(Y/N) or NA Location Comments
VI I LAND TREATMENT*
+A Wastes to be Treated and Hazardous
Constituents Requiring Degradation
H264.271(a)(1) and (b))
+B Treatment Zone Description [§264.271(c )]
C Treatment Demonstrations [§264.272]
C-1 Field plot demonstration - see requirements
under D through L below
+C-2 Laboratory demonstrations [§264.272(b) and (c)]
C-2a test duration [§264.272(b ) ]
C-2b test procedures [§264.272(b) and (c)(1)]
C-2c analytical procedures [§264.272(b ) ]
C-2d personnel protection [§264.272(c ) (3 ) )
D Design and Operating Procedures (§264.273]
+D-1 Waste application method [§264.273(a ) (1 ) ]
+D-2 Waste application rate [§264.273(a)(1 ) ]
+D-3 Measures to control soil pH [§264.273(a ) (2 ) ]
+D-4 Measures to enhance microbial and chemical
reactions [§264.273(a )(3 ) ]
+D-5 Measures to control moisture content in the
treatment zone [§264.273(a ) (4 ) ]
+D-6 Run-on/runoff control [§264.273(b)/(c)/(d)/(e ) ]
D-7 Wind disposal control [§264.273(f ) ]
+D-8 Inspection procedures [§264.273(g ) ]
+E Unsaturated Zone Monitoring Plan [§264.278J
E-1 Soil pore liquid [§264.278(a)-(f) ]
o location
o frequency
*Permits may be issued for land treatment demonstrations, land treatment operations, or both.
3-15
-------
Prov i ded
(Y/N) or NA Location Comments
o parameters
o equipment
o i nstaI I at ion
o sampling procedures
o analytical procedures
o chain-of-custody
o background values
o statistical analyses
E-2 Soil cores [§264.278(a )-(f)]
o loca t ion
o frequency
o parameters
o equipment
o sampling procedures
o analytical procedures
o chain-of-custody
o background values
o statistical analyses
F Notification for Statistically Significant
Differences [§264.278(g) and (h)|
G Food Chain Crops - Specification of Species
(§264.276]
Recordkeepinq [§264.279]
Closure and Post-Closure [§264.280]
Continuation of treatment [§264.280(a)(1 )
and (c)(1)J
I-2 Runoff control [§264.280(a)(2)]
I-3 Run-on control [§264.280(a ) (3) and (c)(3)]
3-16
-------
Provided
(Y/N) or NA Location Comments
1-4 Runoff management system [§264.280(a)(4)
and (c)(4)]
1-5 Wind dispersal control [ §26<4.280( a ) ( 5 )
and (c)(5)]
1-6 Food crop restrictions [§264.280(a)(6 )
and
-------
Prov ided
(Y/N) or NA Location Comments
VIM LANDFILLS
A Design and Operations - General [§264.301]
A-1 Staging plan
A-2 Excavation procedures
B Liner System* [§§264.301(a) and (c), 264.303]
+B-1 Description of liner system
+B-2 Synthetic liner
o synthetic liner material, thickness and
manufacturer
o synthetic liner bedding
o synthetic liner installation procedures,
including seaming
o inspection and quality assurance program
during installation
o exposure prevention
+B-3 So iI Iiner
o soil liner thickness and material
spec i f icat ions
o soil liner construction procedures
o construction inspection and monitoring
program
+B-4 Leachate collection/detection system
o design description
o material specifications
o leachate head restriction
o installation procedures
o inspection and monitoring procedures during
instaI lat ion
+B-5 Liner system foundation preparation
*Note: Some sites may be exempt from the liner system requirements or may have modified liner requirements.
3-18
-------
Prov ided
(Y/N) or NA Location Comments
B-6 Maintenance procedures
o maintenance of leachate collection
detection system
o Iiner repa i rs
C Run-on Control [§264.301(f) ]
+D Runoff Control System [§264.301(g ) ]
E Run-off Management Facilities [ §264.301(h)1
F Procedures to Control Wind Dispersal
TT264.301( i ) ]
G Surveying and Recordkeep ing [§264.309]
H Special Requirements for Ignitable or Reactive
Wastes |§264.3121
+1 Restrictions Against Free Liquids [§264.314]
1-1 Procedures to treat or stabilize wastes
to eliminate free I iquids[§264.314(a) ]
I-2 Elimination of free liquids in containers
[§264.3T4(b)J
J Containerized Wastes [§264.315]
J-1 Lab packs [§264.316]
K Special Requirements for Hazardous Wastes
F020. F021. F022. F023. F026. and F027
[§264.317]
L LandfiI I Closure [§264.310]
L-1 Stabilization of wastes (including removal of
I iqu ids)
L-2 Final cover [§264.310(a)]
+L-2a cover design
L-2b material specifications
L-2c construction specifications and construction
inspection program
3-19
-------
Prov i ded
(Y/N) or NA Location Comments
M Post-Closure Plan* | §26*4. 3 10( b ) ]
M-1 Inspection program [§264.310(b)]
o cover
o run-on and runoff control structures
o groundwater monitoring system
M-2 Maintenance program [§264.310(b) ]
o cover
o groundwater monitoring system
o run-on/runoff control system
o surveyed benchmarks
o leachate detection/collection system
M-3 Continued operation of leachate detection/
collection system [§264.310(c)]
M-4 Groundwater monitoring program
(§26t».310(b)(4)] - See Section XI of
check!i st
*Note I tern K): Not all post-closure plan items will be applicable to all situations.
3-20
-------
Prov i dec!
(Y/N) or NA Location Comments
IX INCINERATION
A Construction (new facilities) or Maintenance
( ex i sting faci I i t ies) 1 §264. 343]
o incinerator plans and specifications
o manufacturer's name and model number
o type of incinerator
o liner dimensions of incinerator unit including
cross-sectional area of combustion chamber
o description of auxiliary fuel system
(type/feed)
o capac-ity of prime mover
o description of automatic waste feed cut-off
system! s)
o stack gas monitoring (CO) and pollution
control equipment
o nozzle and burner design
o construction materials
o location a.nd description of temperature,
pressure, and flow indicating devices and
control devices
o Compliance with certification of construc-
tion or modification
B Performance Standards [§264.343]
B-1 ORE for each POHC in the permit [ §26<4. 3U3( a ) ]
B-1a 99.99 percent ORE of Part 261
Appendix VIII constituents [ §26U. 343( a ) ( 1 ) ]
B-1b 99.9999 percent ORE of listed wastes
F020, F021, F022, F023, F026, and F027
t§26*4.3l43(a)(2))
B-1c notification of intent to incinerate wastes
F020, F021, F022, F023, F026, and F027
[§26'l.3U3(a)(2)]
B-2 Hydrogen chloride removal [ §264. 343( b ) ]
3-21
-------
Prov i ded
(Y/N) or NA Location Comments
B-3 Particulate matter removal [§264.343(c) ]
B-U Relation of operating conditions to
performance standards [§264.343(d)]
+C Limitation on Wastes* [§264.344(a)]
C-1 Option 1 (physical and chemical character-
istics of each waste)
C-2 Option 2 (list of allowable wastes)
+D Operating Conditions for Each Waste Feed*
[§264.345]
D-1 Stack gas carbon monoxide level [§264.345(b ) (1 ) ]
D-2 Combustion temperature [§264.345(b ) (2 ) ]
D-3 Indicator(s) of combustion gas velocity
[§264.345(b)(3)J
D-4 Air pollution control system operating
conditions related to HCI and participate
standards [§264.345(b ) (6) ]
D-5 Precluded waste feed during start-ups,
shutdowns, and upsets [§264.345(c ) ]
D-6 Fugitive emissions control [§264.345(d ) ]
+D-7 Waste feed cut-off [§264.345(e ) ]
D-8 Cessation of operation [§264.345(f)]
+E Moni toring* [§264.347]
E-1 Monitoring system and purpose (i.e., must
include combustion temperature, waste feed
rate, indicator(s) of combustion gas
velocity, and stack gas carbon monoxide
level; monitoring systems for each speci-
fied operating condition must be provided)
[§264.347(a)J
E-2 Frequency of monitoring for each system
(e.g., continuous monitoring of combustion
temperature) [§264.347(a ) ]
*Note: I terns C through G are given in the permit for the pre-trial burn skakedown period, the trial burn, the post-trial burn
period, and the normal operating period.
3-22
-------
Prov i ded
(Y/N) or NA Location Comments
E-3 Frequency of testing for each system
E-t» Frequency of calibration for each system
[§26U.3i47(a)]
F Sampling and Analysis of Wastes and Exhaust
Emissions upon Request of Regional
Administrator* I §26U. 3U7( a) (3) 1
G Record and Maintain Monitoring and Inspection
Data* [§26U.3i+7(d) J
H Tr i a I Bu rn [§26U.3UU. 270.62]
H-1 Shakedown period [§§26U.3UU(c)(1 ), 270.62(a)] .
o durat.ion of shakedown period
(less than or equal to 720 hours,
1 extension of 720 hours)
+H-2 Trial burn period [§§270.19(b), 270.62(b)]
H-2a trial burn plan .
o analysis of each waste _____
o engineering description of incinerator
o sampling, analysis and monitoring procedures,
including QA/QC plan ________
o trial burn schedule
o test protocols
o emissions control equipment description
and operating conditions .
o emergency shutdown procedures •
o identification of sources of fugitive
emissions
o measurement of operating conditions
(e.g., temperature, CO, etc.)
H-2b trial burn POHC's for each waste
H-2c trial burn determinations .
*Note: Items C through G are given in the permit for the pre-trial burn skakedown period, the trial burn, the post-trial burn
period, and the normal operating period.
3-23
-------
Provided
(Y/N) or NA
Locat ion
Comments
H-2d trial burn submissions (data and
cert i ficat ion)
H-3 Duration of Post Trial Burn Period
[§§26U.3HH(c)(3), 270.62(c)J
3-24
-------
Provided
(Y/N) or NA Location Comments
X. GROUNDWATER MONITORING - DETECTION MONITORING PROGRAM (§§264.98, 270.14(c ) (6 ) i
+A Indicator Parameters. Waste Constituents.
Reaction Products to be Monitored
[§§264.98(3), 270.14(c)(6)( i)]
+B Description of Wei Is [§§264.98(b),
270.14(c)(6)( i i )]
C Background Va I Lies [ §§264 . 98(c),
270.14(c)(6)( i i i)]
C-1 Data currently available, or
C-2 Plan for establishing groundwater quality
data
C-2a we I I locat ion
C-2b sampling frequency
C-2c sampling quantity
C-2d background values
D Sampling. Analysis and Statistical Procedures
[§§264.98(c)/(d)/(f), 270.14(c)(6)(iv)|
+D-1 Sample collection
D-2 Sample preservation and shipment
D-3 Analytical procedure
D-4 Detection Iimi ts
D-5 Chain of custody
D-6 Additional requirements for compliance
point monitoring (§264.98(d ) J
D-6a sampling frequency
D-6b compliance point groundwater quality values
D-7 Annual determination [§264.98(e)J
D-8 Statistical determination
+D-8a statistical procedure [§264.98(g>]
D-8b results [§26'».98h>]
3-25
-------
riuviUKU
(Y/N) or NA Location Comments
XI GROUNDWATER MONITORING - COMPLIANCE MONITORING PROGRAM [§§270.14(c)(7), 264.99]
+A Hazardous Constituents to be Monitored
[§§264.99, 270.14(c)(7)( i i i)]
+A-1 Concentration limits, or
A-2 Alternate concentration limits _____
+B Description of We I Is [ §270.14(c)(7)(v)
C Background Values [§§270.14(c ) (7 ) (vi),
264.97(g)]
C-1 Data currently available, or
C-2 Plan for establishing groundwater quality
data
C-2a we I I location
C-2b sampling frequency
C-2c sampling quantity
D Sampling. Analysis and Statistical Procedures
l§270.14(c)(7)(vi(]
+D-1 Sample collection
D-2 Sample preservation and shipment
D-3 Analytical procedure
D-4 Detect ion Iimi ts
D-5 Additional requirements for compliance
point monitoring
D-5a sampling frequency
D-5b testing for Appendix VIII hazardous
const i tuents
D-6 Annual determination
D-7 Statistical determination
+D-7a statistical procedure
D-7b results
3-26
-------
Provided
(Y/N) or NA Location Comments
XII GROUNDWATER MONITORING - CORRECTIVE ACTION PROGRAM [§§270.1U(c)(8), 26<4.100]
+A Concentration Limits [§270.1U(c)(8)( ii)]
B Alternate Concentration Limits
H, 270.14(c)(8)]
C Corrective Action Plan [ §270. 14(c ) (8)( i i i ) ]
C-1 Location
C-2 Construction detail
C-3 Plans for removing wastes
C-U Treatment technologies
C-5 ReinjectJon system
C-6 Operation and maintenance
C-7 Closure and post-closure plans
+D Description of wells [ §§270. Tt( c ) ( 7 ) ( v) and
E Background values [ §§270. 1U( c ) ( 8) , 26<4.97(g)]
E-1 data currently available, or
E-2 plan for establishing groundwater quality
data
o background data
o we I I I oca t ion
o sampling frequency
o sampling quantity
F Sampling. Analysis and Statistical Procedures
[§§270.1li(c)(8), 264. 99(g), (h)]
+ F-1 Sample collection
F-2 Sample preservation and shipment
F-3 Analytical procedure
F-U Chain of custody
3-27
-------
Prov ided
(Y/N) or NA Location Comments
F-5 Additional requirements for compliance point
moni tor ing
F-5a sampling frequency
F-5b testing for Appendix VIM hazardous
const i tuents
F-6 Annual determination
+F-7 Statistical determination
F-8 Results
3-28
-------
RCRA PERMIT QUALITY PROTOCOL
PART 4. PERMIT CONDITION EVALUATION GUIDANCE
-------
Throughout Part 4 of the Protocol, reference is made to many guidance
documents and other sources where the reviewer can obtain further
guidance or explanation. In the interest of brevity the document titles
are abbreviated. The full bibliographic entries corresponding to the
abbreviations are enumerated on pages 6 through 10 of the General
Instructions.
-------
I STANDARD CONDITIONS
D Duties and Requirements
D-1U Compliance schedules
REGULATORY REQUIREMENT
Some permits contain a
compliance schedule.
The compliance schedule
must identify specific
tasks to be completed
and the timeframe for
completing each task (40
CFR 270.33).
EVALUATION CRITERIA
Technical Soundness
Compliance schedules must identify specific steps
or tasks that the permittee must complete in order
to bring the facility into compliance with
Part 264. Milestone dates must be provided to
enable EPA or the State to monitor the permittee's
progress.
Enforceab i I i t.v
The permit must require the permittee to submit
progress reports within 14 days following each
interim milestone date and the final date of
compliance. This condition must appear in the
Standard Conditions whenever a permit incorporates
a compliance schedule.
REFERENCES
FINDINGS/COMMENTS
Effective
June 30, 1983
-------
I STANDARD CONDITIONS
G Documents to be Submitted Prior to Operation
REGULATORY REQUIREMENT
When appropriate, the
permit must specify the
documents to be sub-
mitted prior to opera-
tion of the facility and
the schedule for sub-
mitting them (1*0 CFR
270.30, 270.32 and
270.33).
EVALUATION CRITERIA
Technical Soundness
When appropriate, the permit must specify the
documents to be submitted prior to operation of
the facility or of specific units. Such documents
may include as-built plans, chemical and physical
characterization of wastes, etc. The permit also
must establish a schedule for submission of each
document.
Enforceabi I i t.y
The permit condition(s) must clearly state the
documents to be submitted, and must specify a date
for each submittal.
REFERENCES
FINDINGS/COMMENTS
Effective
June 30, 1983
-------
II GENERAL FACIUTY CONDITIONS
E General Inspection Requirements
E-1 General inspection schedule
REGULATORY REQUIREMENT
The general inspection
schedule appended to the
permit identifies the
general facility items
to be inspected, the
problems for which these
items are to be
inspected, and the fre-
quency of inspections
(UO CFR 26U.15(b) and
(c)).
EVALUATION CRITERIA
Technical Soundness
The general inspection schedule must include the
following items, as applicable:
o monitoring equipment
o safety and emergency equipment
o security devices
o operating/structural equipment
o loading/unloading areas
It must identify specific problems to be looked
for during the inspection of each item and a
specific frequency for inspecting each item. For
example, an inspection frequency of "semi-
annual ly" is appropriate, while a frequency of "as
used" is inappropriate because it defeats the
inspection objective of preventative detection of
hazards.
The permit also must specify the specific remedies
to be implemented when inspections disclose
probI ems.
Enforceabi I i t.v
The permit must specify that the permittee conduct
inspections in accordance with the inspection
schedule. It also must specify that the permittee
record these inspections in a log which is
available for examination by agency personnel.
REFERENCES
FINDINGS/COMMENTS
Effective
January 31,
1985
-------
II GENERAL FACILITY CONDJTIONS
E General Inspection Requirements
E-3 Tank storage/treatment areas
E-3f schedule and procedure for assessing tank condition
REGULATORY REQUIREMENT
The inspection schedule
appended to the permit
must specify the pro-
cedures to be followed
for periodically empty-
ing and inspecting the
interior of tanks (t»0
CFR 26U.19<*(b)).
EVALUATION CRITERIA
Technical Soundness
The inspection schedule for tanks must include a
procedure for emptying them periodically and
inspecting their interiors for cracks, leaks,
corrosion or erosion, or wall thinning. The
procedure must identify how each tank will be
emptied, where the waste will be temporarily
stored, and how each tank will be cleaned anr)
vented to prepare it for inspection. The proce-
dure also must describe the equipment to be used
during the inspection, the items to be inspected,
and the problems for which each item is to be
inspected.
In addition, the procedure must address protection
of the personnel inspecting the tank interiors,
including testing of air quality, adequate light-
ing, appropriate protective clothing, and standby
equipment and services.
Enforceab i I i t.v
The permit will require the permittee to inspect
the tank interiors in accordance with these
procedures and to record the inspection results in
a log, which is available for examination by
agency personnel.
REFERENCES
PWGD-HW Tanks
pp. 8-7, 8-10
FINDINGS/COMMENTS
Effective
January 12,
1981
-------
II GENERAL FACI LITY CONDITIONS
E General Inspection Schedule
E-5 Surface impoundments
REGULATORY REQUIREMENT
The inspection schedule
appended to the permit
must describe the pro-
cedures for inspecting
surface impoundment
overtopping controls,
content levels, leak
detection systems, and
dikes (40 CFR
264.226(b)).
EVALUATION CRITERIA
Technical Soundness
In addition to the four items specified in section
264.226(b), the inspection schedule must include
soil layers protecting synthetic liners from sun-
,light, wind, and machinery used to remove sludge
from the impoundment.
The inspection schedule must include a procedure
for inspecting each of the items. In particular,
the procedure for thoroughly inspecting the
impoundment dikes must be described. It must
include the following:
o cracks and erosion
o settlement, depressions, or sink holes
o evidence of movement
o seepage and damp areas
o animal burrows, trees, and brush growth
o spillway obstruction or deterioration
EnforceabiIi ty
The permit will require the permittee to inspect
the surface impoundments in accordance with this
procedure and to document the inspection results
in a log, which is available for examination by
the agency.
REFERENCES
PAGM-GFS
FINDINGS/COMMENTS
PAGM
pp. 5-U2, 5-U3
Effective
January 31,
1985
4-5
-------
H-2
II GENERAL FACILITY CONDITIONS
H Location Standards
Flood proofing descriptions/drawings
REGULATORY REQUIREMENT
If the faciIity is
located within a 100-
year f loodpla in, the
permit must specify
flood protection or a
flood plan as per UO CFR
270.1t(b)(11) and
26U.18(b). These
criteria are for review
of flood protection.
Flood plan review is
contained on the
following page.
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain the neces-
sary documentation supporting the design of
devices to protect the facility from washout
during a 100-year recurrence interval flood. The
source of 100-year flood data must be stipulated.
This data must be obtained from a Federal
Emergency Management Agency (FEMA), Federal
Insurance Administration (FIA), Flood Insurance
Study (FIS) or equivalent analytical and mapping
procedures.
The record may include an engineering report and
drawings for the design of flood protection
devices. An engineering analysis of the various
hydrodynamic and hydrostatic forces resulting from
a 100-year flood must be provided. The design
of the flood protection devices must provide
engineering information demonstrating that these
devices will prevent facility washout from the
100-year flood.
In addition, the record must contain some form of
documentation showing that the agency conducted a
technical review of the flood protection devices.
EnforceabiIity
The permit must require certification by a pro-
fessional engineer that flood protection devices
are constructed as designed as per UO CFR
270.30(k)(2). The permit must include a written
inspection plan and schedule to be followed as per
40 CFR 264.15. In addition, the permit must
require that records be maintained of all inspec-
tions and repairs or corrective actions for the
Iife of the faciIity.
REFERENCES
PAGM-GFS
pp. 5-1U2 & 5-1U3
PWGM-CLAEAR
pp. 2-12 to 2-18
pp. 3-5 to 3-8
PWGM
pp. U-5
FINDINGS/COMMENTS
Effect ive
January 12, 1981
4-6
-------
II GENERAL FACILITY CONDITIONS
H Location Standards
H-3 Flood plan
REGULATORY REQUIREMENT
If the fac iIi ty is
located within a 100-
year floodplain, the
permit must specify
flood protection or a
flood plan as per UO CFR
270.14(b)(11) and
26i+.18(b). These
criteria a re for rev i ew
of a flood plan.
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain the neces-
sary documentation supporting a facility flood
plan. A flood plan consists of formulated pro-
cedures to safely remove hazardous wastes from a
flood prone facility, before flood waters can
reach the facility, to an eligible facility at a
location that is not vulnerable to flood waters.
The plan must specify a schedule of activities
required to move the hazardous wastes. The
schedule must include the time allowed for each
activity. Timing of activities is to be based on
relative flood levels. The plan must specify
the equipment and personnel to be used to move
hazardous wastes. The plan must also describe the
location the wastes will be moved to and demon-
strate that those facilities are eligible to
receive hazardous wastes.
• Enforceab i I i t.v
These conditions are enforceable through the
agency's enforcement inspection program.
REFERENCES
PAGM-GFS
pp. 5-1U2 & 5-1U3
PWGM-CLAEAR
pp. 2-12 to 2-18
pp. 3-5 to 3-8
FINDINGS/COMMENTS
Effect ive
January 12,
1981
-------
II GENERAL FACILITY CONDITIONS
J Contingency Plan
J-6 Specific control procedures
REGULATORY REQUIREMENT
The contingency plan
appended to the permit
must contain specific
procedures for respond-
ing to leaking tanks (UO
CFR 264.19U(c)) and
sudden drops in the
contents of a surface
impoundment (*40 CFR
26V277(c)).
EVALUATION CRITERIA
Technical Soundness
The contingency plan must contain specific proce-
dures for responding to leaking tanks and surface
impoundment failures.
The tank procedures must address removal of leaked
or spilled waste, including temporary storage of
waste removed from the tanks. A general procedure
for assessing the nature and extent of tank damage
and determining the appropriate repair mechanism
must be included.
The surface impoundment procedures must address
the following:
o Stopping waste addition to the impoundment
o Containing leakage
o Stopping the leak
o Preventing catastrophic failure
The procedures for emptying the impoundment must
address the rate of liquid removal and temporary
storage of the impoundment's contents. Note that
the recommended rate of liquid removal is one foot
per day to prevent dike failure.
EnforceabiIi ty
The permit will require the permittee to maintain
the Contingency Plan on-site and to implement its
procedures when necessary. The permittee also is
required to file a report with the Regional Admin-
istrator when the Contingency Plan is implemented.
REFERENCES
FINDINGS/COMMENTS
PAGM
pp. 5-U8 to 5-50
Effective
July 26, 1982
4-8
-------
Ill STORAGE IN CONTAINERS
D Construction and Maintenance of Containment System
REGULATORY REQUIREMENT
The container storage
area design plans and
specifications attached
to the permit must
comply with §264.175.
They must specifically
address or show via
design drawings:
the base
mater ia I
or I iner
containment system
capaci ty
design features for
drainage of leaks
and spi I I s
prevention of
run-on
EVALUATION CRITERIA
Technical Soundness
The design plans must specify the material of
which the base of the storage area is constructed
(usually concrete) or lined. It must be suf-
ficiently impervious to contain spills, leaks or
precipitation. For existing storage areas, a
pre-permitting inspection must confirm that all
cracks, gaps and construction joints are sealed.
The design specifications for new storage areas
must specify that construction joints will be
sea led.
The containment system must have sufficient
capacity to contain 10 percent of the vo I Lime of
containers, or the volume of the largest con-
tainer, whichever is greater (§26U.175(b)(3 )).
Containers that do not contain free liquids need
not be considered. The permit application must
contain calculations demonstrating the required
capacity. The administrative record must contain
some type of documentation that the calculations
were checked during technical evaluation of the
appI icat i on.
If containers are not elevated on pallets or other
device, the design plans must specify a sloped
base or other design feature so that leaks, spills
and precipitation will drain off (usually to a
collection sump). The procedures for and timing
of removal of liquids from the collection sump
must be specified in the permit. This generally
will include a procedure for determining if the
accumulated liquid is hazardous.
The design plans and drawings must show that the
containment system is elevated above grade or is
protectedlfrom run-on by a waI I or other feature.
If no protection from run-on is shown, the con-
tainment system must have sufficient extra
capacity to contain run-on. That is, water must
not be allowed to flow into, through and then out
of the storage area. If the facility does not
have a roof with sufficient overhang or sides to
prevent accumulation of precipitation then addi-
tional secondary containment for rainfall from a
2U-hour, 25-year storm event must be provided.
REFERENCES
PWGD-Conta iners
pp. i»-1«4 to U-16
FINDINGS/COMMENTS
PWGD-Conta iners
pp. U-12 to U-15
PWGD-Conta iners
pp. U-16 to U-17
Effect ive
November 6,
1981
4-9
-------
Ill STORAGE IN CONTAINERS
D Construction and Maintenance of Containment System
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
Enforceabi I i t.v
In the case of a new container storage area, the
permit must contain a condition requiring that an
engineer certify that the facility was constructed
in accordance with the design plans, and that the
certification be submitted to the agency at the
completion of construction.
The permit must also contain a condition requii—
ing that cracks or gaps which may develop in the
base or liner will be sealed or appropriately
repaired. This should be clearly stated in the
inspection schedule required by 40 CFR 264.15.
Note: When enforceabiI ity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-10
-------
Ill STORAGE IN CONTAINERS
G Special Requirements for Incompatible Wastes
REGULATORY REQUIREMENT
Where incompatible
wastes are stored, the
permit must specify
special design and
operating features to
prevent leaks of
incompatible materials
from com ing I ing (see
§26U.177).
EVALUATION CRITERIA
Technical Soundness
The administrative record must document that,
during technical evaluation of the permit appli-
cation, an agency representative either determined
waste incompatibilities or verified the appli-
cant's assessment of waste incompatibilities.
When determining if incompatibIes exist, the
applicant must not only look at the hazardous
wastes themselves, but also must consider any
materials stored nearby. Each area for compatible
hazardous waste storage must provide secondary
containment for the containers stored in that
a rea.
The most common method of meeting the requirements
of §264.177 is the division of the container
storage area into two or more cells separated by a
wall, curb or other device. This must be shown
clearly on the design drawings, with the cells
labeled. There must be a permit condition
specifying the specific wastes to be placed in
each ceI I.
Where there is no design feature (e.g. wall, curb)
to positively separate areas containing incom-
patible wastes, a permit condition specifying that
containers holding incompatible wastes be placed
in overpack drums is often included in the permit.
REFERENCES
FINDINGS/COMMENTS
PWGD-Conta i ne rs
pp. U-11 to U-12
The permit also must contain a condition specify-
ing that a hazardous waste cannot be placed in an
unwashed container previously holding an incom-
patible waste or material.
Enforceabi I i t.v
These conditions are generally enforced through
certification of construction by a registered
engineer and continued inspection of the facility
by the agency.
Effective
January 12,
1981
-------
IV STORAGE OR TREATMENT IN TANKS
B Tank Design and Construction
B-1 Minimum shell thickness
REGULATORY REQUIREMENT
As per §26*4.191 the
permit must specify a
minimum tank she I I
thickness. The permit
condition must state
that when that shell
thickness is reached (as
a result of corrosion,
erosion, etc.) the tank
must be taken out of
service.
EVALUATION CRITERIA
Technical Soundness
The major determinants of required shell thickness
for structural integrity of a tank are the tank
size and shell material and the nature and
specific gravity of the tank contents. The permit
application must contain a determination of
required shell thickness based on these
pa rameters.
The required shell thickness can be determined by
several methods. The most common is the appl i-
cation of a code or design standard. If an appli-
cant has obtained required shell thickness from a
code, such as API (American Petroleum Institute)
650, API 620 or ASTM 03299, the administrative
record must contain documentation that a reviewer
determined that the proper code was used and that
the code was properly applied.
Alternatively, standard formulas can be used to
compute required shell thickness based on struc-
tural criteria. These are generally applicable to
metal tanks. If the applicant computed shell
thickness using standard formulas, the admin-
istrative record must show that a reviewer has
verified those computations.
When permitting existing tanks, the current,
actual shell thickness of each tank must be
determined prior to the issuance of a draft
permit. Those data must be included in the
Part B permit application.
Enforceabi I i t.v
The tank inspection schedule in the permit must
require periodic (annual, etc.) shell thickness
testing by ultrasound or other non-destructive
testing methods.
REFERENCES
FINDINGS/COMMENTS
PWGM-HW Tanks
Chapters 3 &
Tank Guidance Memo
Effective
January 12,
1981
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-12
-------
REGULATORY REQUIREMENT
The permit must describe
dike design specifica-
tions including erosion
protection as per (+0 CFR
270.17(b)(3) and
261.221(d).
V SURFACE IMPOUNDMENTS
A Impoundment Design and Construction
A-2 Dike design and construction
A-2a design specifications
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain an engi-
neering report and drawings supporting dike design
specifications including erosion protection.
Dikes must be designed with sufficient structural
integrity to prevent massive failure. The follow-
ing elements must be incorporated in the dike
des ign:
o foundation conditions
o embankment materials
o impoundment liner
o waste material
Long-term effects of external factors such as
frost, wind, rain, temperature, vegetation, etc.,
must be evaluated. Dike stability assessments
must be conducted assuming no functional liner.
Information on dike integrity must include:
REFERENCES
PWGM
pp. 6-78 to 6-85
PAGM
pp. 5-27 to 5-32
PWGM
pp. 6-133 & 6-13U
PAGM
pp. 5-U5 to 5-U8
FINDINGS/COMMENTS
design plans,
scheduIes
technical specifications and
o results of field and laboratory investiga-
tions of strength, compressibility, Atterberg
Iimi ts, etc.
materiaIs
for foundation and dike
o data on geologic, hydrogeologic, and hydro-
logic conditions including groundwater
levels, bedrock conditions, and seismic
sett ing
o slope stability and failure assessments for
various loading conditions including rapid
drawdown, partial pool, steady state seepage,
earthquakes, foundation soil bearing failure,
failure of dike slopes, or failure of
drainage systems, covers, or liners
o erosion potential from rainfall, surface
water runoff, leakage through dikes, and
contact with wastes
Effective
July 26, 1982
-------
V SURFACE IMPOUNDMENTS
A Impoundment Design and Construction
A-2 Dike design and Construction
A-2a design specifications
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
o evaluation of Iiquification tendencies
o evaluation of seismic effects
All references, analytical methods, computer
models, and field and laboratory test data must be
ident i fied.
In addition, the record must show via
calculations, notes or other date that a tec'.^ical
review was conducted on the dike design
spec i ficat ions.
Enforceabi I i t.v
The permit must include a certification by a quali-
fied engineer which attests to the structural
integrity of the dike as per UO CFR 270.17(e).
4-14
-------
V SURFACE IMPOUNDMENTS
A Impoundment Design and Construction
A-3 Hydraulic features
REGULATORY REQUIREMENT
The permit must specify
the design of hydraulic
features to prevent im-
poundment overtopping as
per 1*0 CFR 264.221(c).
The design may incorpor-
ate hydraulic features,
such as channels, spill-
ways, pipes, pumps,
etc., to be operated
either manually or auto-
matical ly.
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain an engi-
neering report and drawings having the necessary
documentation supporting the design of all hydrau-
lic features to prevent overtopping. Report and
drawing information should include the size and
capacity calculations of all hydraulic structures
such as pumps, pipes, weirs, principal and ernei—
gency spillways, channels, reservoir level con-
trollers, etc. The impoundment, including appur-
tenant hydraulic structures, must be designed to
prevent overtopping from a 100-year, 24-hour storm
event. A table or graph correlating reservoir
storage and elevation may be provided.
The magnitude of the 100-year, 24-hour storm must
be determined using data from the U.S. Weather
Bureau Technical Publication 40 or other accept-
able data. In the event that runoff from the
surrounding area enters the impoundment,
calculations must be provided for the peak
discharge and/or volume resulting from a 100-year,
24-hour storm event.
If foolproof overtopping controls are not
employed, the administrative record must contain a
water balance study for the life of the impound-
ment. The study must verify that the impoundment
will not be overtopped during normal operations
and the 100-year, 24-hour storm event. The study
may involve normal inflow and outflow volumes,
evaporation, the 100-year, 24-hour storm runoff
volume, and freeboard.
The impoundment design must include run-on control
through either inclusion of run-on volumes within
the impoundment or diversion of run-on from the
impoundment. Wind effects on the impoundment must
be calculated in accordance with U.S. Bureau of
Reclamation "Design of Small Dams," U.S. Army
Corps of Engineers ETL 1110-2-221 "Wave Runup and
Wind Setup on Reservoir Embankments," or other
acceptable procedures. The administrative record
must provide documentation (e.g., calculations,
notes) that the surface impoundment is operated
and designed to prevent overtopping.
REFERENCES
PAGM
pp. 5-24 to 5-27
PWGM
pp. 6-64 to 6-77
PAGM
PP. 5-37
pp. 5-42 to 5-44
FINDINGS/COMMENTS
Effect ive
July 26, 1982
4-15
-------
V SURFACE IMPOUNDMENTS
A Impoundment Design and Construction
A-3 Hydraulic features
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
In addition, the record must show that a technical
review was conducted on the design of the
impoundment and all appurtenant structures.
Enforceabi I i t.v
The permit must specify the monitoring and inspec-
tion plan to be followed during construction as
per 1)0 CFR 270.17(d) and include an inspection
plan to be followed during impoundment operation
as per i»0 CFR 226(b). The operation inspection
plan must specify that the impoundment and all
hydraulic structures be inspected weekly and after
storms and earthquakes. The permit must also
stipulate that records be maintained of all
inspect ions.
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-16
-------
V SURFACE IMPOUNDMENTS
C Liner System
C-1 Description of liner system
REGULATORY REQUIREMENT
Except as noted, the
permit must contain a
description of a double
liner system to be in-
staI led at the s i te.
Included with the
description must be a
design drawing of the
system (§261.221 ].
Effective
January 31,
EVALUATION CRITERIA
Technical Soundness
Except ions:
a) No liner system is required for existing
units (i|0 CFR 264.221), except that all sites must
be retrofitted with a double liner system by
November 8, 1988 or closed.
REFERENCES
FINDINGS/COMMENTS
HSWA
Liner Memo
b) An exemption from the
requirements can be granted
des igns.
double liner system
for a Iternat ive
c) Other exemptions and exceptions as outlined
in guidance memo.
The permit must contain a description of the
double liner system. The double liner system
should consist of the following:
o top flexible membrane liner
o leachate detection system, with provisions
for collection of any leakage
o bottom liner consisting of a soil liner at
feet thick or a 3-foot-thick soil liner
a second flexible membrane liner.
least 3
directly beneath
Documentation would include drawings showing the
area! extent of the liner system with a detailed
cross-sectional drawing of the liner system.
To be exempt under the existing portion rule, the
administrative record must include documentation
of the extent of the existing portion in the form
of a drawing and written description. In addi-
tion, the record must indicate the dates when the
facility was constructed and waste was placed.
Other exemptions and the required documentation
are complex. Therefore refer to the noted refer-
ence or to current guidance from Headquarters.
These exemptions could consist of an exemption
from the double liner requirement (i.e., only use
a single liner or no liner at all) and are based
on site-specific design and/or operating pro-
cedures. To be granted, these other exemptions
will require extensive documentation along with a
1985
4-17
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V SURFACE IMPOUNDMENTS
C Liner System
C-1 Description of liner system
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
detailed technical review. The administrative
record must contain documentation of that review
and a notification of the approval of exemption by
the RA. Finally, the permit fact sheet should
include a justification of the exemption.
Double liner systems installed by the operator
prior to permit issuance which meet the require-
ments may fall under the good faith compliance
rule and may not need to be replaced; see
guidance.
Enforceab iIi ty
The permit must include provisions for
certification as per 140 CFR 270.30(k)(2) and
inspection during construction as per 40 CFR
226(a).
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
-------
V SURFACE IMPOUNDMENTS
C Liner System
C-2 Flexible membrane liner
C-2a flexible membrane liner material, thickness.
and manufacturer
REGULATORY REQUIREMENT
The permit must contain
flexible membrane liner
specifications. Each
surface impoundment
unit, except for exempt
un i ts (see D-1) is
required to have two or
more Ii ners
[§§264.221(a) and (c)].
EVALUATION CRITERIA
Technical Soundness
Guidance requires that at least one of the liners
be a flexible membrane liner. The permit may
indicate the brand name and manufacturer of the
flexible membrane liner. In most cases a detailed
material specification of more than one specific
liner will be provided with a note that the final
selection will be made at the time of installation
subject to final approval of the RA.
The permit must indicate that the double liner
system will consist of a top flexible membrane
liner that is at least 30 mils thick and is
compatible with the waste and leachate. In
addition, unless documentation is provided in the
administrative record that the soil liner is thick
enough to contain the leachate (see Section D-3);
the bottom liner must also include a 30 mil or
thicker flexible membrane liner.
Documentation of flexible membrane liner compati-
bility should consist of test results from EPA
Method 9090 testing of the flexible membrane
liner. In some cases other data, such as
historical or existing site data, may be used.
Documentation of sufficient liner strength should
consist of calculations computing the loads and
stresses, such as operational and construction
loads or waste loads, which are applied to the
flexible membrane liner along with a comparison of
those loads against the strength of the flexible
membrane liner as determined by the Method 9090
test ing.
i
Finally, the administrative record must contain
documentation that all the calculations and data
dealing with the flexible membrane liner have been
reviewed for technical adequacy and have been
accepted. .The documentation usually will consist
of a checklist or review form indicating that the
calculations and data have been checked or
reviewed and are acceptable. Also, in some cases
verification calculations by the technical
reviewer may be provided.
REFERENCES
GDLS
PWGM
pp. 6-11 to 6-61
GDLS
pp. 2-8
p. 13
pp. 38-45
SW-8U6
NSF
FINDINGS/COMMENTS
Effective
January 31,
1985
-------
V SURFACE
C Liner System
C-2 Flexible membrane liner
C-2a flexible membrane liner material, thickness, and manufacturer
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
Enforceab i I i t.v
The permit must include provisions for certifi-
cation as per 40 CFR 270.30(k)(2) and inspection
during construction as per iiO CFR 264.226(a).
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-20
-------
C-2b
V SURFACE.IMPOUNDMENTS
C Liner System
C-2 Flexible membrane liner
flexible membrane liner bedding
REGULATORY REQUIREMENT
The permit must include
a description for the
bedding material used
both above and below the
flexible membrane liner
to protect it
(§264.221 (a)].
EVALUATION CRITERIA
Technical Soundness
The material must be (SP)
classified by the Unified
System.
material or finer, as
So iI Class i f icat ion
REFERENCES
GDLS
pp. 16-17
PWGM
pp. 6-11 to 6-31
FINDINGS/COMMENTS
Documentation would consist of material specifi-
cations for the materials to be used for the
layers of the liner system that the flexible
membrane liner rests on and that are placed on the
flexible membrane liner. In some cases other
material will be used for bedding, in which case
documentation such as calculations, historical
data, or test data must be provided that indicates
equivalent protection of the liner. If calcu-
lations or test data are provided, the admin-
istrative record must contain documentation that
the data have been technically reviewed and
approved.
In some cases no protective layer will be provided
for the top flexible membrane liner. In those
cases the flexible membrane liner thickness will
likely need to be greater than 30 mils.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per UO CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 26U.226(a).
Effect ive
July 26, 1982
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-21
-------
V SURFACE IMPOUNDMENTS
C Liner System
C-2 Flexible membrane liner
C-2c flexible membrane liner installation procedures, including seaming
REGULATORY REQUIREMENT
The permit must include
deta iled flexible
membrane liner material
specifications and
installation procedures
[§261.221].
EVALUATION CRITERIA
Technical Soundness
Included within the specifications must be such
i teirrs as:
o liner manufacturer (optional),
o liner brand name (optional),
o Iiner thickness,
o liner chemical and physical properties,
o method of liner field seaming,
o method of liner subgrade preparation,
o method of anchoring the liner,
o handling procedures, and
o placement procedures.
Enforceabi I i t.y
The permit must include provisions for certifi-
cation as per 10 CFR 270.30(k)(2) and inspection
during construction as per UO CFR 264.226(a).
REFERENCES
FI NO INGS/COMMENTS
SW-870
pp. 298-305
pp. 3U5-373
pp. 10
GDLS
pp. 38-45
Effect ive
July 26, 1982
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-22
-------
C-2d
V SURFACE IMPOUNDMENTS
C Liner System
C-2 Flexible membrane liner
inspection and quality assurance program
REGULATORY REQUIREMENT
The permit must include
a detailed construction
quality assurance
program [§264.221].
EVALUATION CRITERIA
Technical Soundness
The plan must indicate or provide the following:
o qualifications of inspectors,
o frequency of inspections,
o testing procedures to be used to test the
I iner seams, and
o 'documentation procedures to be used.
EnforceabI Ii ty
The permit must include provisions for certifi-
cation as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.226(a).
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
REFERENCES
FINDINGS/COMMENTS
GLDS
pp. 38-45
SW-870
pp. 250-253
CQA
Effective
July 26, 1982
4-23
-------
V SURFACE IMPOUNDMENTS
C Liner System
C-2 Flexible membrane liner
C-2e exposure prevention
REGULATORY REQUIREMENT
The permit must include
provisions for protec-
tion of the flexible
membrane liner from
exposure l§26U.221].
EVALUATION CRITERIA
Technical Soundness
Protection is usually provided by placing a cover
layer of soil or other material over the flexible
membrane Iiner.
If this is not done, or if the flexible membrane
Iiner will be exposed for long periods due to
phased construction, then the record must contain
test data demonstrating that sunlight, wind, rain,
freeze/thaw, etc., will not harm the liner. The
record must include documentation (e.g., notes,
calculations) that such data have been technically
reviewed and approved. In addition, it is likely
that the flexible membrane liner thickness will
have to exceed 30 mils.
EnforceabiIi ty
The permit must include provisions for certifica-
tion as per UO CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.226(a).
REFERENCES
PWGM
pp. 6-11 to 6-31
FINDINGS/COMMENTS
Effect ive
July 26, 1982
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-24
-------
C-3a soiI
V SURFACE IMPOUNDMENTS
C Liner System
C-3 So iI Ii ner
liner thickness and material
spec i ficat ions
REGULATORY REQUIREMENT
The permit must contain
specifications for a
so i I I i ner. Each sur-
face impoundment unit
except for exempt units
(see D-1) is required to
have a bottom soil liner
which is at least 3 feet
thick with a permea-
biIity of 1x10~7 cm/sec
or less (§264.221(a) and
(c). (Note: If only
one flexible membrane
liner is present, then
the soil liner thickness
must be computed.)
Effective
July 26, 1982
EVALUATION CRITERIA
Technical Soundness
If the bottom liner consists of a flexible
membrane Iiner placed on a soiI I iner, the soiI
liner must be at least 3 feet thick with a minimum
permeability of 1x10~7 cm/sec and the flexible
membrane liner must be placed directly on the soil
Iiner.
If the bottom liner does not contain a flexible
membrane liner component, then the soil liner must
be at least 3 feet thick with a minimum
permeability of 1x10"7 cm/sec and the
administrative record must contain calculations
which model the soil liner. The model is used to
determine the necessary soil liner thickness, and
the soiI Iiner must be thick enough so that any
leachate generated by the surface impoundment does
not flow completely through the soil liner during
the active life, closure period, and 30-year
post-closure period. When doing the calculations,
it must be assumed (as per agency guidance) that
the top flexible membrane liner began leaking
during the first year of operation. The admin-
istrative record must include documentation, such
as a checklist or supporting calculations,
indicating that the soil liner thickness evr. na-
tion.has been technically reviewed and accepted.
The administrative record must contain docu-
mentation (i.e., testing data) that the soil liner
is compatible with the leachate expected to be
generated at the facility.
The administrative record must contain docu-
mentation that the soil liner has sufficient
strength to resist the loads and stresses placed
on it.
In some cases the administrative record may con-
tain test data indicating the permeability of the
soil proposed for use as the soil liner. Or, the
record may indicate that in-place soil is to be
amended with bentonite or other material to lower
its permeability; in which case, a mix design
supported by test data would be provided. If test
data are provided, they must include a description
of the testing procedures, the test results, and
an analysis of the results.
REFERENCES
FINDINGS/COMMENTS
GDLS
p. 17
pp. U5-U8
SW-869
SW-814-001
SW-925
pp. 29-30
4-25
-------
V SURFACE IMPOUNDMENTS
C I. i ne r System
C-3 So iI Ii ner
C-3a soil liner thickness and material specifications
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The administrative record must contain a check-
list, or other documentation, which indicates that
the design data have been technically reviewed and
were accepted.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per UO CFR 270.30(k)(2) and inspection
during construction as per UO CFR 264.226(a).
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-26
-------
V SURFACE IMPOUNDMENTS
C Liner System
C-3 So i I I iner
C-3b soil liner construction specifications
REGULATORY REQUIREMENT
The permit most include
detailed material and
construction specifica-
tions for placement of
the soiI Iiner
[§264.221].
EVALUATION CRITERIA
Technical Soundness
I terns addressed must include:
o removal of rocks, roots and other unsuitable
material from the soil,
o placed in lifts that are less than 6 inches
thick,
o requires the breaking up of soil clods if
necessa ry,
o proper addition of water if necessary,
o not constructed of frozen soil, along with
prevention of freezing of compacted mate-
rial, and
o sea I-roll ing of final lift for smooth
surface.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 140 CFR 270.30(k)(2) and inspection
during construction as per UO CFR 26U.226(a).
REFERENCES
FINDINGS/COMMENTS
GDLS
pp. 18-20
Effective
July 26, 1982
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency p!"->,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-27
-------
V SURFACE IMPOUNDMENTS
C L. iner System
C-3 So iI Ii ner
C-3c construction inspection and monitoring program
REGULATORY REQUIREMENT
The permit must contain
a construction quality
assurance plan for deter-
mining that the so iI
Iiner has been con-
structed as per the
plans and specifica-
tions 1§26U.226).
EVALUATION CRITERIA
Technical Soundness
Included must be:
o testing of soil material for permeability,
classification, and density;
o procedures for in-place permeability testing;
o inspection of the material during placement
and the placement and compaction procedures;
o documentation procedures; and
o qualifications of the inspectors.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 140 CFR 270.30(k)(2) and inspection
during construction as per UO CFR 26*4.226(3).
REFERENCES
FINDINGS/COMMENTS
GDLS
pp. 38-UU
CQA
. ion
Note: When enforceabiIity of a permit condi
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
Effective
July 26, 1982
4-28
-------
V SURFACE IMPOUNDMENTS
C Liner Systems
C-4 Leachate detection system
C-Ma design specifications
REGULATORY REQUIREMENT
Each surface impoundment
unit, except for exempt
uni ts (see D-1) is
requ i red to have a
leachate detection zone
located beneath the top
flexible membrane liner
and above the bottom
I iner [ §264.221(c) J.
The design plans
attached to the permit
must contain specifi-
cations for a leachate
detection system.
EVALUATION CRITERIA
Technical Soundness
The permit must contain the
leachate detection system:
foI lowing for the
o A description, including drawings, of the
operation and design of the system.
o Each portion of the system must have a
minimum slope of 2%.
o A graded granular filter or filter fabric to
prevent clogging of the system is required.
o The granular material should have a per. .la-
bility of 1x10~7 cm/sec or greater and must
be at least 12 inches thick.
o The granular layer may be replaced by an
artificial drainage material provided it has
equivalent flow capacity.
o A drainage tile system of appropriate size
and spacing with a sump pump or other means
to efficiently remove leachate is required.
The administrative record must contain the
following for the leachate detection system:
o Drawings showing the extent of the system,
pipe layouts, slopes, and typical cross-
sections must be provided.
o Data showing the chemical compatibility of
all components of the system with the waste
and leachate must be provided.
o If a granular filter is used, the record must
include calculations which show compliance
with the requirements discussed on pages
9-94 through 9-97 of the reference (PWGM).
o The record must contain documentation, either
with test data or acceptable engineering
analysis, of the permeability of the granular
material or equivalent capacity of artificial
drainage material.
REFERENCES
GDLS pp. 4-11 pp.
PWGM
pp. 9-60 to 9-108
SW-869
FINDINGS/COMMENTS
Effect ive
January 31,
1985
4-29
-------
V SURFACE IMPOUNDMENTS
C Liner Systems
C-*4 Leachate detection system
C-Ua design specifications
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
o The record must include calculations which
verify that the pipe sizing and spacing have
sufficient capacity.
o The administrative record must contain
documentation in the form of engineering
analysis that the granular drainage layer
is stable under the loads and stresses
p I aced on it.
o Calculations along with material properties
which show that all components of the system
have sufficient strength to support the loads
that they will be subjected to must be
prov ided.
The 12-inch-thick layer of granular material on a
2% slope with pipe requirements can be waived if
an equivalent drainage system is provided. In
that case the record must contain calculations and
data which show that the designed system has flow
capacity equivalent to the recommended 12-inch
granular layer. Criteria to be judged for
equivalence are listed on pages 9, 10, 35 and 36
of the reference (GDLS).
The record must also contain documentation, such
as checklists or supporting calculations, indi-
cating that all engineering calculations and test
data have been technically reviewed and are
approved.
Enforceab i I i t.y
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 26U.226(a).
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-30
-------
REGULATORY REQUIREMENT
The permit must contain
detailed material speci-
fications for all
components of the
leachate detection
system [§264.221J.
V SURFACE IMPOUNDMENTS
C Liner Systems
C-4 Leachate detection system
C-4b material specifications
EVALUATION CRITERIA
Technical Soundness
Included must be such items as applicable:
o pipe specifications,
o granular material gradations,
o artificial drainage material specifications,
o pump specifications, and
o sump specifications.
EnforceabiIi ty
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.226(a).
REFERENCES
FINDINGS/COMMENTS
GDLS
pp. 39-44
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
Effective
July 26, 1982
4-31
-------
V SURFACE IMPOUNDMENTS
C Liner Systems
C-4 Leachate detection system
C-4c installation specifications
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must contain Technical Soundness GDLS
detailed construction pp. 39-44
specifications for con- The construction specifications should address the
structing the leachate following procedures.
detection system
[§264.221]. o pipe placement procedures,
o protection of the liners during placement of
the systems,
o construction procedures for the sumps, and
o placement of the granular material and
f iIters.
EnforceabI Ii ty
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.226(a).
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
Effective
July 26, 1982
4-32
-------
REGULATORY REQUIREMENT
The liner system must be
placed on a foundation
capable of supporting
the liner system and
resistant to forces
which could result in
Iiner fa ilure due to
settlement, compression,
or uplift [§26U.221(a)].
Effective
July 26, 1982
V SURFACE IMPOUNDMENTS
C Liner Systems
C-5 Liner foundation preparation
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain geo-
technical data and engineering calculations which
describe the liner system foundation and verify
that it has sufficient strength to support the
liner and prevent failures. Detailed discussions
of the data requirements and the analyses are
included in the reference.
Items which must generally be included are items
normally included in the documentation in support
of liner foundation design and to demonstrate
sufficient strength include the following.
REFERENCES
GDLS pp. 39-UU
PWGM
pp. 6-U6 to 6-58
CQA
FINDINGS/COMMENTS
test boring information (i.e.,
and boring logs);
location plan
o results of soil and/or rock testing;
o engineering calculations for settlement
analysis, bearing capacity analysis, and
landfill slope analysis; and
o discussion of the potential excess gas or
hydrostatic uplift pressure and subsidence
and sinkhole potential.
The record also must contain detailed foundation
construction specifications and a construction
quality assurance procedure for preparation of the
foundation. The necessary
specific, but are discussed
references.
for preparation of
items are very site
in genera I in the
Finally, the record must contain documenta t •'•-.!,
such as checklists or supporting calculations,
indicating that all engineering calculations and
test data have been technically reviewed and are
approved.
Enforceab iIi ty
The permit must include provisions for certi-
fication as per '»0 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 26<4.226(a).
4-33
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner system
A-1a description of liner system
REGULATORY REQUIREMENT
Except as noted, the
permit must contain a
description of a liner
system to be installed
at the site. Included
with the description
.must be a design
drawing o-f the system
(UO CFR 261.251).
Effect ive
July 26, 1982
EVALUATION CRITERIA
Technical Soundness
Except ions:
a) No liner system is required for existing units
(HO CFR 26*4.251 ).
b) No liner system is required for encloc.J dry
piles (40 CFR 264.250).
c) Sites which have been based on site con-
ditions or alternative design.
d) Other exemptions and exceptions as outlined
in guidance memo.
The permit must contain a description of the liner
system. The liner system must consist of the
foI Iow i ng:
o leachate collection system
o synthetic or soil liner
Documentation would include drawings showing the
aerial extent of the liner system with a detailed
cross-sectional drawing of the liner system.
To be exempt under the existing portion rule, the
administrative record must include documentation
of the extent of the existing portion in the form
of a drawing and written description.
To be exempt under the enclosed dry pile, the
administrative record must include documentation
(e.g., testing data, design plans, specifications)
verifying the following (i\0 CFR 264.250(c) ):
o liquids or wastes containing free liquids are
not placed in the pile,
o the pile is inside a structure which prevents
run-on,
o wind dispersal control is by other means than
wett ing,
o the waste in the pile does not generate
leachate.
REFERENCES
WPDLS
PWGM
pp. 7-9 to 7-51
FINDINGS/COMMENTS
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner system
A-1a description of liner system
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COHMENTS
Other exemptions and the required documentation
are complex and only in draft form as this is
prepared. Therefore refer to the noted reference
or to current guidance from Headquarters.
Some liner systems installed by the operator which
do not meet the requirements could fall under the
good faith compliance rule and do not need to be
replaced; see guidance.
Enforceab iIi ty
New construction must be certified by a registered
engineer; and that certification must be submitted
to the agency. The requirement to maintain the
facility as it is depicted in the plans and speci-
fications is enforced through the agency's
enforcement inspection program.
4-35
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner system
A-1b synthetic liner
o synthetic liner material, thickness, and manufacturer
REGULATORY REQUIREMENT
Each waste pile unit,
except for exempt units
(see B-1) is required to
have a Iiner. The
permit must specify the
liner material, thick-
ness and manufacturer
(140 CFR 26U.251(a)(1 )).
EVALUATION CRITERIA
Technical Soundness
If the liner is a synthetic liner, the permit must
indicate the brand name and manufacturer of the
synthetic liner. In most cases more than one will
be provided with a note that the final selection
will be made at the time of installation subject
to final approval of the RA.
The permit must indicate that the synthetic liner
must be at least 30 mils thick and that it is com-
patible with the waste and leachate.
Documentation of synthetic liner compatibility
must generally consist of test results from EPA
Method 9090 testing of the synthetic liner. In
some very limited cases, other data, such as
historical or existing site data, may be "used.
Documentation of sufficient liner strength must
consist of calculations computing the loads and
stresses, such as operational and construction
loads or waste loads, which are applied to the
synthetic liner along with a comparison of those
loads against the strength of the synthetic liner
as determined by the Method 9090 testing.
Finally the administrative record must contain
documentation that all the calculations and data
dealing with the synthetic liner have been
reviewed for technical adequacy and have been
accepted. The documentation will usually consist
of a checklist or review form indicating that the
calculations and data have been checked or
reviewed and are acceptable. Also, in some cases
verification calculations by the technical
reviewer may be provided.
Enforceab iIi ty
The permit must include provisions for certifi-
cation as per UO CFR 270.30(k)(2) and inspection
during construction as per <40 CFR 26U.25U(a).
REFERENCES
PWGM
pp. 7-16 to 7-51
SW-846
NSF
WPDLS
FINDINGS/COMMENTS
Effect ive
July 26, 1982
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-36
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VI WASTE PILES
A Design and Operating Requirements
A-1 Liner system
A-1b synthetic liner
o synthetic liner bedding
REGULATORY REQUIREMENT
The permit must include
a description for the
bedding material used
both above and below the
synthet ic Iiner to
protect it (40 CFR
264.251(a)(1)).
EVALUATION CRITERIA
Techn ica I Soundness
The materiaI
suggested by
(USGS).
should be (SP) material or finer, as
the Unified Soil Classification
Documentation would consist of material specifi-
cations for the materials to be used to protect
the synthetic liner. In some cases other material
will be used for bedding, in which case documenta-
tion such as calculations, historical data, or
test data must be provided that indicate equiva-
lent protection of the liner. If calculations or
test data are provided, the administrative record
must contain documentation that the data have been
technically reviewed and approved.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.254(3).
REFERENCES
WPDLS
PWGM
pp. 7-16 to 7-51
FINDINGS/COMMENTS
Effect ive
July 26, 1982
Note; When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-37
-------
REGULATORY REQUIREMENT
The permit must include
detailed synthetic liner
material specifications
and instaI I at ion
procedures (HO CFR
26U.251(a)(1)).
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner system
A-1b synthetic liner
o synthetic liner installation procedures, including seaming
EVALUATION CRITERIA
Technical Soundness
Included within the specifications must be such
items as:
o liner manufacturer,
o Iiner brand name,
o liner thickness,
o liner chemical and physical properties,
o method of liner field seaming,
o method of liner subgrade preparation,
o method of anchoring the liner,
o handling procedures, and
o placement procedures.
Enforceab iIi ty
The permit must include provisions for certifi-
cation as per UO CFR 270.30(k)(2) and inspection
during construction as per i|0 CFR 264.25U(a).
REFERENCES
SW-870
pp. 298-305
pp. 345-373
PP. uos-un
PWGM
pp. 7-16 to 7-51
WPDLS
FINDINGS/COMMENTS
Effective
July 26, 1982
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-38
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner system
A-lb synthetic liner
o inspection and quality assurance program during installation
REGULATORY REQUIREMENT
The permit must include
a detailed construction
qua Iity assurance
program (UO CFR
26U.251(a)(1)).
EVALUATION CRITERIA
Technical Soundness
The plan must provide the following:
o qualifications of inspectors,
o frequency of inspections,
o testing procedures to be used to test the
Ii ner seams, and
o documentation procedures to be used.
EnforceabiIity
The permit must include provisions for certifi-
cation as per 140 CFR 270.30(k)(2) and inspection
during construction as per UO CFR 264.25U(a).
REFERENCES
SW-870
pp. 250-253
PWGM
pp. 7-16 to 7-51
WPDLS
FINDINGS/COMMENTS
Effect ive
July 26, 1982
4-39
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner system
A-lb synthetic liner
o exposure prevention
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must include Technical Soundness PWGM
provisions for protec- pp. 7-16 to 7-51
tion of the synthetic Protection is usually provided by placing a cover
liner from exposure layer of soil or other material over the synthetic WPDLS
(§264.251(a)), liner.
If this is not done, or if the synthetic liner
will be exposed for long periods due to phased
construction, then the record must contain test
data demonstrating that sunlight, wind, rain,
freeze/ thaw, etc., will not harm the liner. The
record must include documentation (e.g., notes,
calculations) that such data have been technically
reviewed and approved.
EnforceabiIity
The permit must include provisions for certifica-
tion as per UO CFR 270.30(k)(2) and inspection
during construction as per HO CFR 26U.254(a).
Effect ive
July 26, 1982
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner system
A-lc so iI Iiner
o soil liner thickness and material specifications
REGULATORY REQUIREMENT
The permit must contain
specifications for a
soil liner. Each waste
pile unit except for
exempt units (see B-1)
is required to have a
Iiner. If a soiI Iiner
is used, it must be at
least 2 feet thick with
a permeability of 1x10
cm/sec or less (UO CFR
264.251(a)(1)).
EVALUATION CRITERIA
Technical Soundness
If a soil liner is used, then it must be at least
2 feet thick and the administrative record must
contain calculations which model liquid movement
through the soil liner. The model is used to
determine the necessary soil liner thickness, and
the soil liner must be thick enough so that any
leachate generated by the waste pi le does not flow
completely through the soil liner during the
active life and closure period. When doing the
calculations it must be assumed that the leachate
collection system is clogged. The administrative
record must include documentation, such as a
checklist or supporting calculations, indicating
that the soil liner thickness evaluation has been
technically reviewed and accepted.
In some cases the administrative record may
contain test data indicating the permeability of
the soil proposed for use as the soil liner. Or,
the record may indicate that in-place soil is to
be amended with bentonite or other material to
lower its permeability; in which case a mix design
supported by test data would be provided. If test
data are provided, it must include a description
of the testing procedures, the test results, and
an analysis of the results. The administrat.ve
record must contain a checklist, or other docu-
mentation, which indicates that the data has been
technically reviewed and was accepted.
EnforceabiIity
The permit must include provisions for certifica-
tion as per HO CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.254(a).
REFERENCES
WPDLS
SW-869
SW-8U-001
SW-925
pp. 29-30
PWGM
pp. 7-9 to 7-51
FINDINGS/COMMENTS
Effective
July 26, 1982
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner system
A- 1c so iI Ii ner
o soil liner construction procedures
REGULATORY REQUIREMENT
The permit must include
detailed material and
construction specifica-
tions for placement of
the so iI Iiner
(§26U.251)(a)(1)).
EVALUATION CRITERIA
Technical Soundness
I terns addressed must include:
o removal of rocks, roots and other unsuitable
material from the soil,
o placed in lifts that are less than 6 inches
thick,
o requires the breaking up of soil clods if
necessa ry,
o proper addition of water if necessary,
o not constructed of frozen soil along with
prevention of freezing of compacted material,
and
o sea I-roll ing of final lift for smooth
surface.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 1*0 CFR 270.30(k)(2) and inspection
during construction as per UO CFR 26U.25U(a).
REFERENCES
PWGM
pp. 7-16 to 7-51
WPDLS
FINDINGS/COMMENTS
Effect ive
July 26, 1982
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner system
A-1c so iI Ii ner
o construction inspection and monitoring program
REGULATORY REQUIREMENT
The permit must contain
a construction quality
assurance plan for deter-
mining that the so iI
Iiner has been con-
structed as per the
plans and specifica-
tions (§264.254).
EVALUATION CRITERIA
Technical Soundness
Included must be:
o testing of soil material for permeability,
classification, and density;
o inspection of the material during placement
and the placement and compaction procedures;
o documentation procedures; and
o qualifications of the inspectors.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.254(a).
REFERENCES
PWGM
pp. 7-16 to 7-51
WPOLS
FINDINGS/COMMENTS
Effective
July 26, 1982
4-43
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner systems
A-1d leachate collection system
o design description
REGULATORY REQUIREMENT
Each waste pile unit,
except for exempt units
(see B-1) is required to
have a leachate col-
lection system placed
above the liner (40 CFR
26U.251(a)(2)).
EVALUATION CRITERIA
Technical Soundness
The permit must contain the following for the
leachate collection system:
o A description must be provided including
drawings of the operation and design of
the system.
o Each portion of the system must have a
minimum slope of 2%.
o The layer must be at least 12 inches thick.
o A graded granular filter or filter fabric to
prevent clogging of the system must be
included in the design.
o The granular material should have a permea-
bility of IxlO"7 cm/sec or greater and must
be at least 12 inches thick.
o The granular layer may be replaced by an
artificial drainage material, provided it has
equivalent flow capacity.
o A drainage collection system of appropriate
size and spacing with a sump pump or other
means to efficiently remove leachate is
requi red.
The administrative record must contain the
following for the leachate collection system:
o Drawings showing the extent of the system,
pipe layouts, slopes, and typical cross-
sections must be provided.
o Data showing the chemical compatibility of
all components of the system with the waste
and leachate must be included.
REFERENCES
PWGM
pp. 7-51 to 7-100
SW-869
GDLS
pp. 9-10
pp. 35-36
WPDLS
FINDINGS/COMMENTS
If
it a granular filter is used, the record must
include calculations which show compliance
with the requirements discussed on pages
7-81 through 7-U6 of the reference.
Effect ive
July 26, 1982
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner systems
A-1d leachate collection system
o design description
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
o The record should contain documentation
either with test data or acceptable engineer-
ing analysis of the permeability of the
granu lar mater ia I .
o The record should include calculations which
verify that the pipe sizing and spacing have
sufficient capacity.
o The record should include calculations along
with material properties which show that all
components of the system have sufficient
strength to support the loads that they
will be subjected to.
The 12-inch-thick layer of granular material on a
2% slope with pipe requirements can be waived if
an equivalent drainage system is provided. In
that case the record must contain calculations and
data which show that the alternate system has a
flow capacity equivalent to that of the recom-
mended 12-inch granular layer. Criteria to be
judged for equivalence are listed on pages 9, 10,
35 and 36 of the reference.
The record must also contain documentation, such
as checklists or supporting calculations, indi-
cating that all engineering calculations and test
data have been technically reviewed and are
approved.
Enforceab iIi tv
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per UO CFR 264.254(a).
4-45
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner systems
A-1d leachate collection system
o material specifications
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must contain Technical Soundness PWGM
detailed material speci- pp. 7-51 to 7-100
fications for all com- Included must be such items as applicable:
ponents of the leachate WPDLS
collection system (40 o pipe specifications,
CFR 26U.251(a)(2)J.
o granular material gradations,
o pump specifications, and
o sump specifications.
Enforceab iIi tv
The permit must include provisions for certifica-
tion as per UO CFR 270.30(k)(2) and inspection
during construction as per UO CFR 264.25U(a).
Effect ive
July 26, 1982
4-46
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner systems
A-1d leachate collection system
o leachate head restriction
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must contain Technical Soundness PWGM
a provision that the pp. 7-51 to 7-100
maximum leachate in the The record must contain verified engineering
leachate collection calculations showing that leachate collection WPDLS
system cannot exceed one system has sufficient capacity to maintain a
foot (<40 CFR leachate depth of less than or equal to one foot.
26U.251(a)(2)). A detailed discussion of the necessary calcula-
tions is contained on pages 7-55 through 7-62 of
the reference.
The record also must contain documentation, such
as checklists or supporting calculations, indi-
cating that the engineering calculations have been
technically reviewed and are approved.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 26k. 25t»(a ).
Effect ive
July 26, 1982
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner systems
A-1d leachate collection system
o installation procedures
REGULATORY REQUIREMENT
The permit must contain
detailed construction
specifications for con-
structing the leachate
collection system (40
CFR 26U.251(a)(2)).
EVALUATION CRITERIA
Technical Soundness
Included must be such items as applicable:
o pipe placement procedures,
o protection of the liners during placement of
the systems,
o construction procedures for the sumps, and
o placement of the granular material and
fiIters.
Enforceabi I i t.v
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.254(a).
REFERENCES
PWGM
pp. 7-51 to 7-100
WPDLS
FINDINGS/COMMENTS
Effective
July 26, 1982
4-48
-------
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner systems
A-1d leachate collection system
o inspection and monitoring procedures during installation
REGULATORY REQUIREMENT
The permit must contain
a construction quality
assurance plan to assure
that the leachate col-
lection system is
constructed in accor-
dance with, the plans and
specifications (40 CFR
26U.25U).
EVALUATION CRITERIA
Technical Soundness
Included as applicable must be such items as:
o qualifications of the inspectors,
o testing procedures,
o inspection during placement of the materials,
and
o documentation procedures.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per UO CFR 270.30(k)(2) and inspection
during construction as per 46 CFR 26U.25U(a ).
REFERENCES
PWGM
pp. 7-51 to 7-100
WPDLS
FINDINGS/COMMENTS
Effective
July 26, 1982
4-49
-------
REGULATORY REQUIREMENT
The permit must specify
procedures for liner
foundation preparation.
The Iiner system must be
placed on a foundation
capable of supporting
the liner system and
resistant to forces
which could result in
liner failure due to
settlement, compression,
or up I ift (140 CFR
264.251(a)(1)( i i ))..
VI WASTE PILES
A Design and Operating Requirements
A-1 Liner systems
A-1e liner system foundation preparation
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain geo-
technical data and engineering calculations which
describe the liner system foundation and verify
that it has sufficient strength to support the
liner and prevent failures. Detailed discussions
of the data requirements and the analyses are
included in the reference.
I terns normally provided in support of the liner
foundation design include the following.
REFERENCES
PWGM
pp. 7-37 to 7-39
WPDLS
FINDINGS/COMMENTS
test boring information
and boring logs);
i.e.
location plan
o results of soil and/or rock testing;
o engineering calculations for settlement
analysis, bearing capacity analysis;
o discussion of the potential excess gas or
hydrostatic uplift pressure and subsidence
and sinkhole potential.
The record also must contain detailed foundation
construction specifications and a construction
quality assurance procedure for preparation t-f the
foundation. Here again the necessary items are
very site specific but are discussed in general in
both references.
Finally, the record must contain documentation,
such as checklists or supporting calculations,
indicating that all engineering calculations and
test data have been technically reviewed and are
approved.
Enforceab iIi ty
The permit must include provisions for
certification as per 40 CFR 270.30(k)(2) and
inspection during construction as per UO CFR
26U.251*.
Effect ive
July 26, 1982
-------
VII LAND TREATMENT UNITS
A List of Wastes and Hazardous Constituents
REGULATORY REQUIREMENT
The permit must specify
the wastes to be applied
to the land treatment
unit (40 CFR 1 ) ).
264.271(a)(1 )). The
permit must specify the
hazardous constituents
in the wastes that must
be degraded, transformed
or immobilized (40 CFR
264.271(b)).
HWLT pp. 107-134
EVALUATION CRITERIA REFERENCES
Technical Soundness
The parameters analyzed must include those listed
on Table 2.1 of the PGM-HWLTD along with the
Appendix VIII constituents reasonably expected to
be in or derived from the wastes to be land
treated (Table 2.2 of PGM-HWLTD).
The administrative record must include waste
analyses to verify the presence of hazardous con-
stituents in the wastes to be land treated.
The administration record must contain details of
the demonstration waste analysis plan including:
o Sampling - The waste must be sampled in
accordance with scientific methods to ensure
that accurate, representative samples are
obta ined.
o Sample Collection - The waste must be
collected and composited to provide samples
which are representative of the waste used
in the demonstration.
o Sample Handling and Storage - The samples
must be handled and stored (preserved) to
maintain the chemical integrity of the
samples until analysis.
o Sample Analysis - The method used to analyze
the waste must be approved by EPA.
The administrative record also must contain docu-
mentation (notes, etc.) showing that a technical
review of the waste analysis plan was conducted
and that copsideration was given to the afore-
mentioned details of the plan in determining its
technical soundness.
Enforceab i I i t.y
The permit must include a condition requiring
maintenance of records of the wastes applied to
the land treatment unit as per 40 CFR 264.73 and
264.279.
FINDINGS/COMMENTS
Effect ive
July 26, 1982
4-51
-------
VII LAND TREATMENT UNITS
B Treatment Zone Description
REGULATORY REQUIREMENT
The permit must specify
the horizontal and
vertical dimensions of
the treatment zone
(10 CFR 26U.271(C)).
EVALUATION CRITERIA
Technical Soundness
As per 40 CFR 264.271(c), the treatment zone must
extend no more than 1.5 meters below the soil
surface, and the lower limit of the treatment zone
must be at least one meter above the seasonal high
table.
The administrative record must contain the
necessary documentation supporting the depth of
the treatment zone. This information must include
a soil boring log and the results of all soil
sample analyses. These analyses must verify the
fact that the depth of the treatment zone does not
exceed 1.5 meters below the existing soil surface.
Results of studies documenting the depth of the
seasonal high water table, including boring logs
and depth-to-water table measurements, must be
included. These analyses must show that the
seasonal high water table is located at least one
meter below the lower boundary of the treatment
zone.
Enforceab iIi ty
The requirement that all treatment take place
within the treatment zone is enforced through
permit conditions requiring the monitoring and
notification activities of «40 CFR 278.
REFERENCES
FINDINGS/COMMENTS
PAGM
pp. 7-UU to 7-146
Effect ive
July 26, 1982
4-52
-------
VI I LAND TREATMENT
C Treatment Demonstrations
C-2 Laboratory demonstration conduct
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must specify Technical Soundness PGM-HWLTD
the types of tests used pp. 43-59
in the demonstration and The permit must identify the specific laboratory
the analytical proce- procedures in the subject demonstration. The
dures used (UO CFR following items pertaining to laboratory treatment
26U.272(b)). demonstrations should be addressed.
o Laboratory Demonstration Methodologies - The
permit must include specification of the type
of test(s) to be used, and the materials and
methods to be employed. The test used must
simulate conditions in the land treatment
unit including waste loading rates, soil
conditions, and climatic conditions.
o Analytical Procedures - The permit must
include the type of analytical procedures to
be used in the analysis of demonstration
wastes and soil core and soil-pore liquid
samples. This must include the sampling
methods, sample handling protocol, and
analysis procedures.
o Worker Protection - The permit must specify
the steps to be taken to ensure worker pro-
tection during the laboratory demonstration.
This includes such items as safety equipment
and emergency plans. In all cases, the
demonstration must show that hazardous con-
stituents in the waste can be transformed,
immobilized, or degraded.
Enforceab iIi ty
The conduct of laboratory demonstrations is
enforceable by agency inspection under 40 CFR
270.30(i), and through the recordkeeping require-
ments of HO CFR 270.30(j).
Effect ive
April 1, 1983
4-53
-------
VI I LAND TREATMENT
D Unit Operating Procedures
D-1 Waste application methods
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must specify Technical Soundness
the methods of waste
application and incor- The administrative record must contain documenta-
poration to be employed tion that the method for waste application/
at the land treatment incorporation was selected considering potential
unit C40 CFR variations in climatic conditions and waste
26*4.273(a )(1 )). composition.
Enforceab i I i t.v
The method used for waste application/
incorporation can be enforced by agency inspection
under 270.30( i )(3).
Effect ive
July 26, 1982
-------
VII LAND TREATMENT UNITS
D Unit Operating Procedures
D-2 Waste application rate
REGULATORY REQUIREMENT
The permit must specify
the rate of waste appli-
cation onto the treat-
ment zone (UO CFR
26i4.273(a)(1)).
o
Effect ive
July 26, 1982
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain information
supporting the waste application rate. The record
must contain the applicable results from the land
treatment demonstration used in setting the waste
loading rates.
For each waste to be landtreated, the record must
specify the following three constituents:
o Rate Limiting Constituent (RLC) - that com-
pound or element which restricts the amount
of waste which can be appl fed per year
(kg/ha/yr).
Application Limiting Constituent (ALC) - that
compound or element which restricts the
amount of waste which can be applied per
appIicat ion (kg/ha/appIicat ion).
o Capacity Limiting Constituent (CLC) - that
compound or element which restricts the total
amount of waste which can be applied to the
soil over the life of the treatment unit
(kg/ha).
In settling the loading rate, consideration must
be given to the following major classes of con-
stituents in the waste:
o Organic constituents in terms of their
potential for volatilization, leaching,
runoff, and degradation
o Metals content of the waste from the stand-
point of immobilization (or leaching) poten-
tial based on the cationic exchange capacity
of the soiI
o Nitrogen and phosphorus content of the waste
o Soluble salts content of the waste
o Water content of the waste.
The record also must contain some form of docu-
mentation showing that a technical review was
conducted on the proposed loading rate giving
consideration to each of the aforementioned items.
REFERENCES
FINDINGS/COMMENTS
HWLT
pp. 373-405
4-55
-------
VII LAND TREATMENT UNITS
D Unit Operating Procedures
D-2 Waste application rate
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
Enforceab iIi ty
The permit must include a condition requiring
maintenance of records of waste application rates,
as per HO CFR 26U.279 and 261.73.
-------
VII LAND TREATMENT UNITS
D Unit Operating Procedures
D-3 Measures to control soil pH
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must specify Technical Soundness HWLT pp. i»65-U68,
the measures used to PAGM pp. 7-t<1
control soil pH (*40 CFR The administrative record must contain documenta-
26U.273(a)(2)). tion supporting the measures to control soil pH.
This documentation must contain a description and
technical verification of the following items
related to soil pH control.
o Sampling Protocol - The record must include a
description of the frequency, location, and
sampling and analysis procedures used to
determine so iI pH.
o pH Control Calculations - The record must
specify the method used to calculate soil
amendments for pH control and must specify
the range of pH to be maintained.
o pH Control Methods - The record must specify
the chemicals to be used to control soil pH
and describe how they will be added to the
treatment zone.
Enforceab i I i t.v
Methods to control soil pH (including monitoring
requirements) are enforceable by inspection under
HO CFR 270.30( i )(3).
Effective
July 26, 1982
4-57
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VII LAND TREATMENT UNITS
D Unit Operating Procedures
D-U Measures to enhance microbial and chemical reactions
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must specify Technical Soundness HWLT p. 372
the measures to enhance PAGM pp. 7-M1
microbial and chemical The administrative record must provide documenta-
reactions (40 CFR tion supporting the measures to enhance microbial
26U.273(a){3)). and chemical reactions. This documentation must
contain a description and technical verification
of the following items.
o Sampling Protocol - The record must include a
description of the frequency, location, and
sampling and analysis procedures used to
determine soil additions to enhance microbial
and chemical reactions.
o Nutrient Additions - The record must specify
the method used to calculate soil amendments
and must specify the C:N ratio to be
ma inta ined.
o Soil Nutrient Control Methods - The record
must specify the chemicals to be used to
enhance microbial and chemical reactions and
describe how they will be added to the
treatment zone.
Enforceab iIi ty
Methods to enhance microbial and chemical
reactions are enforceable by agency inspection
under t(0 CFR 270. 30( i ) ( 3 ).
Effective
July 26, 1982
4-58
-------
VII LAND TREATMENT UNITS
D Unit Operating Procedures
D-5 Measures to control soil moisture content in the treatment zone
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must specify Technical Soundness PAGM
the measures to control pp. 7-41
soil moisture content in The administrative record must provide documenta-
the treatment zone (UO tion supporting the measures to control soil
CFR 26*4.273( a ) ( U) ). moisture in the treatment zone. This documenta-
tion must include a description of the methods
used to monitor soil moisture, the range of soil
moisture to be maintained, and the methods to be
used to control soil moisture.
The record also must contain evidence (e.g.,
notes, calculations) of a technical review of the
above-mentioned items to ensure that the soil
moisture control measures proposed are adequate.
Enforceab iIi ty
Proper control of soil moisture is enforceable by
inspection under 'tO CFR 270. 30( i )('»).
Effective
July 26, 1982
4-59
-------
REGULATORY REQUIREMENT
The permit must specify
that the uni t wiI I be
constructed and managed
to prevent runoff of
hazardous constituents
from the treatment zone
(40 CFR 264.273(b) and
(d) and (e)).
Effective
July 26, 1982
VII LAND TREATMENT UNITS
D Design and Operating Procedures
D-6 Run-on/runoff control
o construction to prevent runoff
EVALUATION CRITERIA
Technical Soundness
The permit must contain design plans and drawings
for features to control runoff. The
administrative record must contain information to
demonstrate that the unit construction and
operation will prevent runoff of hazardous
constituents from the treatment zone. This
includes such items as:
o Cross-sectional drawings of diversion
structures,
o Hydrologic analyses to demonstrate that the
unit will prevent runoff from a 214-hour,
25-year storm event.
REFERENCES
PAGM
pp. 7-46, 49-51
HWLT
pp. 425-427
FINDINGS/COMMENTS
o
Design specifications of waste water
treatment facilities.
Of particular importance with respect to docu-
mentation of runoff prevention is the presence of
a technical review of the information. This
technical review must contain a verification of
all calculations and specifications used in the
design and construction of the runoff prevention
structures.
EnforceabiIity
The runoff prevention structures must be inspected
and maintained under 40 CFR 264.273(g ) (1 ).
4-60
-------
VII LAND TREATMENT UNITS
E Unsaturated Zone Monitoring
REGULATORY REQUIREMENT
The permit must specify
an unsaturated zone
monitoring plan (40 CFR
264.271(a)(3)). This
plan must meet the
requirements of 40 CFR
264.278.
EVALUATION CRITERIA
Technical Soundness
The unsaturated zone monitoring program must be
designed to detect the movement of hazardous
constituents below the treatment zone.
The administrative record must contain extensive
documentation relating to the unsaturated zone
monitoring plan. The information provided must
include specific details on monitoring in the
unsaturated zone, including both soil cores and
soil-pore liquid. The record must both specify
and verify by way of a technical review the
foI Iowi ng i terns.
o Sampling Locations - The location of so i I -
pore liquid and soil core samples must be
established randomly to ensure representative
placement of the samples. Additional "hot
spots" such as the toe of slopes also may
be selected in addition to the random
samples.
o Samp I ing Frequency - Sampling of soiI cores
must be conducted quarterly; sampling of
soil-pore liquid must be conducted
quarterly, preferably following leachate
generating precipitation.
o Analysis Parameters - The parameters to be
monitored must consist of the hazardous con-
stituents reasonably expected to be present
in the waste or principal hazardous con-
stituents. Principal hazardous constituents
are hazardous constituents contained in the
waste that are the most difficult to treat.
Enforceab iIi ty
The permit must include a provision for reporting
of unsaturated zone monitoring results as per 40
CFR 264.278(g).
REFERENCES
FINDINGS/COMMENTS
PGM/UZM-HWLT
Chapters 2-4,
pp. 532-544
HWLT
Effect ive
July 26, 1982
4-61
-------
B-1
VI I I LANDFILLS
B Liner System
Description of liner
system
REGULATORY REQUIREMENT
The permit must contain
specifications for a
double Iiner system.
Except as noted, the
permit must contain a
description of a double
liner system to be in-
staI led at the s i te.
Included with the
description must be a
design drawing of the
system (10 CFR
26U.301(a) and (c)).
EVALUATION CRITERIA
Technical Soundness
Except ions:
a) No liner system is required for existing
units (40 CFR 261.301).
b) An exemption from the double liner system
requirements can be granted for alternative
des igns.
c) Other exemptions and exceptions as outlined
in guidance memo.
The permit must contain a description of the
double liner system. The double liner system
should consist of the following:
o top flexible membrane liner
o leachate detection system, with provisions
for collection of any leakage
o bottom liner consisting of a second flexible
membrane liner at least 30 mils thick with a
3-foot-thick soil liner directly beneath the
second flexible membrane liner.
Documentation would include drawings showing the
areaI extent of the liner system with a detailed
cross-sectional drawing of the liner system.
To be exempt under the existing portion rule, the
administrative record must include documentation
of the extent of the existing portion in the form
of a drawing and written description. In addi-
tion, the record must indicate the dates when the
facility was constructed and waste was placed to
assure compliance with the dates provided in the
agency guidance.
Other exemptions, and the required documentation,
are complex and currently in draft form. There-
fore refer to the noted reference or to current
guidance from Headquarters. These exemptions are
based on site-specific design and/o.r operating
REFERENCES
FINDINGS/COMMENTS
HSWA
Liner Memo
Effective
July 15, 1985
4-62
-------
VIII LANDFILLS
B Liner System
B-1 Description of liner system
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
procedures, and will require extensive.
documentation along with a detailed technical
review. The administrative record must contain
documentation of that review and a notification of
the approval of the exemption by the RA. Finally,
the permit fact sheet should include a
justification of the exemption. (No exemptions
are allowed in Alabama per 40 CFR 264. 332( k). )
Double liner systems installed by the operator
which do not meet the requirements could fall
under the good faith compliance rule and may not
need to be replaced; see guidance.
Enforceab i I i t.V
The permit must contain design plans and speci-
fications for the liner system. The permit also
must contain conditions requiring inspection
during construction as per UO CFR 264.303(a) and
certification as per UO CFR 270.30(k)(2).
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-63
-------
VIM LANDFILLS
B L i ner System
B-2 Flexible membrane liner
o flexible membrane liner material, thickness,
and manufacturer
REGULATORY REQUIREMENT
Each landfiII uni t,
except for exempt units
(see C-1) is required to
have two or more liners
(10 CFR 26U.301(a) and
(c)).
EVALUATION CRITERIA
Technical Soundness
Guidance requires that at least one of the liners
be a flexible membrane liner. The permit may
indicate the brand name and manufacturer of the
flexible membrane liner. In most cases a detailed
material specification for more than one specific
liner will be provided with a note that the final
selection will be made at the time of liner
installation, subject to final approval of the RA.
The permit must indicate that the double liner
system must consist of a top flexible membrane
liner that is at least 30 mils thick and that it
is compatible with the waste and leachate. In
addition, unless documentation is provided in the
administrative record that the soil liner is thick
enough to contain the leachate (see Section B-3);
the bottom liner must also include a 30 mil or
thicker flexible membrane liner.
Documentation of flexible membrane liner compati-
bility usually must consist of test results from
EPA Method 9090 testing of the flexible membrane
liner. In some very limited cases, other data,
such as historical or existing site data, may be
used.
Documentation of sufficient liner strength must
consist of calculations computing the loads and
stresses, such as operational and construction
loads or waste loads, which are appl ied to the
flexible membrane liner along with a comparison of
those loads against the strength of the flexible
membrane liner as determined by the Method 9090
test i ng.
Finally the administrative record must contain
documentation that all the calculations and data
dealing with the flexible membrane liner have been
reviewed for technical adequacy and have been
accepted. The documentation will usually consist
of a checklist or review form indicating the
calculations and data have been checked or
reviewed and are acceptable. Also, in some cases
check calculations by the technical reviewer may
be provided.
REFERENCES
PWGM
pp. 9-10 to 9-30
GDLS
pp. 2-8
p. 13
pp. 38-U5
SW-8U6
NSF
FINDINGS/COMMENTS
Effective
July 15, 1985
4-64
-------
VIM LANDFILLS
B Liner System
B-2 Flexible membrane liner
o flexible membrane liner material, thickness, and manufacturer
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
EnforceabiIi ty
The permit must include provisions for certifi-
cation as per (40 CFR 270.30(k)(2) and inspection
during construction as per ^0 CFR 26U.303(a).
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-65
-------
VI I I LANDFILLS
B Liner System
B-2 Flexible membrane liner
flexible membrane liner bedding
REGULATORY REQUIREMENT
The permit must include
a description for the
bedding material used
both above and below the
flexible membrane liner
to protect it
(40 CFR 264.301).
EVALUATION CRITERIA
Technical Soundness
The material should be (SP) material or finer, as
classified by the Unified Soil Classification
System.
Documentation would consist of material specifi-
cations for the materials to be used for the
layers of the liner system that the flexible
membrane liner rests on and that are placed on the
flexible membrane liner. In some cases, other
material will be used for bedding, in which case,
documentation such as calculations, historical
data, or test data must be provided that indicates
equivalent protection of the liner. If calcu-
lations or test data are provided, the admin-
istrative record must contain documentation that
the data have been technically reviewed and
approved.
Ent'orceab i I i ty
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.303(a).
REFERENCES
FINDINGS/COMMENTS
GDLS
pp. 16-17
PWGM
pp. 9-27
Effective
July 26, 1982
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-66
-------
VIII LANDFILLS
B Liner System
B-2 Flexible membrane liner
o flexible membrane liner installation procedures, including seaming
REGULATORY REQUIREMENT
The permit must include
deta iled flexible
membrane liner material
specifications and
installation procedures
(40 CFR 264.301 ).
EVALUATION CRITERIA
Technical Soundness
Included within the specifications must be such
i terns as:
o liner manufacturer (optional),
o liner brand name (optional),
o Iiner th ickness,
o liner chemical and physical properties,
o method of liner field seaming,
o method of liner subgrade preparation,
o method of anchoring the liner,
o handling procedures, and
o placement procedures.
Enforceab i I i t.v
The permit must include provisions for certifi-
cation as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.303(a).
REFERENCES
FINDINGS/COMMENTS
SW-870
pp. 298-305
pp. 345-373
pp. 40
GDLS
pp. 38-45
Effect ive
July 26, 1982
4-67
-------
REGULATORY REQUIREMENT
The permit must include
a detailed construction
qua Ii ty assurance
program (40 CFR
264.301).
Effective
January 31, 1985
VI I I LANDFILLS
B Liner System
B-2 Flexible membrane liner
o inspection and quality assurance program during installation
EVALUATION CRITERIA
Technical Soundness
The plan must indicate or provide the following:
o qualifications of inspectors,
frequency of inspections.
o
o
testing procedures to be used to test the
Iiner seams, and
o documentation procedures to be used.
Enforceab iIi ty
The permit must include provisions for certifi-
cation as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.303(a).
REFERENCES
FINDINGS/COMMENTS
GLDS
pp. 38-45
SW-870
pp. 250-253
CQA
4-68
-------
VI I I LANDFILLS
B Liner System
B-2 Flexible membrane liner
o exposure prevention
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must include Technical Soundness PWGM
provisions for protec- pp. 9-27 to 9-30
tion of the flexible Protection usually is provided by placing a cover
membrane liner from layer of soil or other material over the flexible
exposure (UO CFR membrane liner.
261.301).
If this is not done, or if the flexible membrane
I iner will be exposed for long periods due to
phased construction, then the record must contain
test data demonstrating that sunlight, wind, rain,
freeze/thaw, etc.. will not harm the liner. The
record must include documentation that such data
have been technically reviewed and approved.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.303(a).
Effect ive
July 26, 1982
4-69
-------
o so iI Ii ner
VIII LANDFILLS
B Liner System
B-3 SoiI Iiner
thickness and material
spec i ficat ions
REGULATORY REQUIREMENT
Each landfiII uni t
except for exempt units
(see C-1) is required to
have a bottom soil liner
which is at least 3 feet
thick with a permeabil-
ity of 1x10~7 cm/sec or
less (UO CFR 26U.301(a)
and (c)). (Note: If
only one fI ex i ble
membrane Iiner is
present, then the soil
liner thickness mus.t be
computed.
EVALUATION CRITERIA
Technical Soundness
If the bottom liner consists of a flexible
membrane liner placed on a soil liner, the soil
liner must be at least 3 feet thick with a minimum
permeability of 1x10~7 cm/sec or less and the
flexible membrane liner must be placed directly on
the so i I I i ner.
If the bottom liner does not contain a flexible
membrane liner component then the soil liner must
be at least 3 feet thick with a minimum permea-
bility of 1x10"r cm/sec or less and the admin-
istrative record must contain calculations which
model the soil liner. The model is used to detei—
mine the necessary soil liner thickness, and the
soil liner must be thick enough so that any
leachate generated by the landfill does not flow
completely through the soil liner during the
active life, closure period, and 30-year post-
closure period. When doing the calculations, it
must be assumed that the top flexible membrane
liner began leaking during the first year of
operation (as per agency guidance). The admin-
istrative record must include documentation, such
as a checklist or supporting calculations,
indicating that the soil liner thickness evalua-
tion has been technically reviewed and accepted.
The administrative record must contain docu-
mentation that the soil liner is compatible \-ith
the leachate expected to be generated at the
faciIi ty.
The record also must contain documentation that
the soil liner has sufficient strength to resist
the loads and stresses placed on it.
In some cases the administrative record may
contain test data indicating the permeability of
the soiI proposed for use as the soiI Iiner. Or,
the record may indicate that in-place soil is to
be amended with bentonite or other material to
lower its permeability; in which case, a mix
design supported by test data would be provided.
If test data are provided, they must include a
description of the testing procedures, the test
results, and an analysis of the results.
REFERENCES
FINDINGS/COMMENTS
GDLS
p. 17
pp. U5-U8
SW-869
SW-84-001
SW-925
pp. 29-30
Effect ive
January 31,
1985
4-70
-------
VIM LANDFILLS
B Liner System
B-3 SoiI I iner
o soil liner thickness and material specifications
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The administrative record must contain a check-
list, or other documentation, which indicates that
the design data has been technically reviewed and
was accepted.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per UO CFR 26U.303(a).
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-71
-------
VI I I LANDFILLS
B Liner System
B-3 So i I I iner
o soil liner construction procedures
REGULATORY REQUIREMENT
The permit must include
detailed material and
construction specifica-
tions for placement of
the so iI Iiner
(40 CFR 264.301).
EVALUATION CRITERIA
Technical Soundness
I terns addressed include:
o removal of rocks, roots and other unsuitable
material from the soil,
o placed in lifts that are less than 6 inches
thick,
o requires the breaking up of soil clods if
necessa ry,
o proper addition of water if necessary,
o not constructed of frozen soil along with
prevention of freezing of compacted
material, and
o sea I-roll ing of final lift for smooth
surface.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.303(a).
REFERENCES
FINDINGS/COMMENTS
GDLS
pp. 18-20
Effective
January 31,
1985
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are cjearly defined.
4-72
-------
VI I I LANDFILLS
B Liner System
B-3 SoiI I iner
o construction inspection and monitoring program
REGULATORY REQUIREMENT
The permit must contain
a construction quality
assurance plan for deter-
mining that the so iI
Iiner has been con-
structed as per the
plans and specifica-
tions (40 CFR 26U.301
and 261.303).
EVALUATION CRITERIA
Technical Soundness
The construction testing and monitoring program
specified in the permit must contain, at a
min imum:
o testing of soil material for permeability,
classification, and density;
o inspection of the material during placement
and the placement and compaction procedures;
o procedures for in-place permeability testing;
o documentation procedures; and
o qualifications of the inspectors.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 10 CFR 270.30(k)(2) and inspection
during construction as per io CFR 26U.303(a).
REFERENCES
FINDINGS/COMMENTS
GDLS
pp. 38-UU
CQA
Effective
January 31,
1985
4-73
-------
VI I I LANDFILLS
B Liner Systems
B-U Leachate collection/detection system
o design description
REGULATORY REQUIREMENT
The permit must contain
specifications for
leachate detection and
collection systems.
Each landfiII un i t,
except for exempt units
(see B-1) is required to
have a leachate collec-
tion system placed above
the top flexible
membrane liner and a
leachate detection zone
located beneath the. top
flexible membrane liner
and above the bottom
Iiner (UO CFR 264.301 ) .
EVALUATION CRITERIA
Technical Soundness
.The permit must contain the following for both the
leachate collection system and for the leachate
detection system:
o A description including drawings of the
operation and design of each system must be
prov i ded.
o Each portion of the systems must have a
minimum slope of 2%.
o A graded granular filter or filter fabric to
prevent clogging of the system should be
spec i ffed.
o The granular material should have a permea-
bility of 1x10'7 cm/sec or greater, and must
be at least 12 inches thick.
o The granular layer may be replaced by an
artificial drainage material provided it has
equivalent flow capacity.
o A drainage tile system of appropriate size
and spacing with a sump pump or other means
to efficiently remove leachate must be
spec i f fed.
The administrative record should contain the
following for both the leachate collection system
and for the leachate detection system:
o Drawings showing the extent of the system,
pipe layouts, slopes, and typical cross-
sections should be included.
o Data showing the chemical compatibility of
all components of the systems with the waste
and leachate should be included.
o If a granular filter is used, the record must
include calculations which show compliance
with the requirements discussed on pages
9-9U through 9-97 of the reference (PWGM).
REFERENCES
GDLS
pp. U-11
pp. 31-4H
PWGM
pp. 9-60 to 9-108
SW-869
FINDINGS/COMMENTS
Effect ive
July 26, 1982
-------
VI I I LANDFILLS
B Liner Systems
B-U Leachate collection/detection system
o design description
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
o The record must contain documentation in the
form of test data or acceptable engineering
analysis of the permeability of the granular
material or equivalent capacity of any
artificial drainage material.
o The administrative record must contain
documentation in the form of engineering
analysis that the granular drainage layer
is stable under the loads and stresses
placed on it.
o The record must include calculations which
verify that the pipe sizing and spacing have
sufficient capacity. Each system must have
its own sumps and they cannot be
i nterconnected.
o Calculations along with material properties
which must be provided show that all com-
ponents of the systems have sufficient
strength to support the loads to which they
will be subjected.
The 12-inch-thick layer of granular material on a
2% slope with pipe requirements can be waived if
an equivalent drainage system is provided. In
that case, the record must contain calculations
and data which show that the designed system has
flow capacity equivalent to that of the recom-
mended 12-inch granular layer. Criteria to be
judged for equivalence are listed on pages 9, 10,
35 and 36 of the reference (GDLS).
The record must also contain documentation, such
as checklists or supporting calculations, indi-
cating that all engineering calculations and test
data have been technically reviewed and are
approved.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per UO CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 26l*.303(a).
4-75
-------
VI I I LANDFILLS
B L i ner Systems
B-4 Leachate collection/detection system
o material specifications
REGULATORY REQUIREMENT
The permit must contain
detailed material speci-
fications for all
components of the
leachate collection and
detection systems
(40 CFR 261.301 ).
EVALUATION CRITERIA
Technical Soundness
The material specifications should address, at a
minimum, the following items.
o pipe specifications,
o granular material gradations,
o artificial drainage material specifications,
o pump specifications, and
o sump specifications.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.303(a).
REFERENCES
FINDINGS/COMMENTS
GDLS
pp. 39-44
Effective
July 26, 1982
4-76
-------
VIII LANDFILLS
B Liner Systems
Leachate collection/detection system
o leachate head restriction
REGULATORY REQUIREMENT
The permit must contain
a provision that the
maximum leachate in the
leachate collection
system cannot exceed one
foot (40 CFR 264.301).
EVALUATION CRITERIA
Technical Soundness
The record must contain verified engineering
calculations showing that leachate collection
system has sufficient capacity to maintain a
leachate depth of less than or equal to one foot.
A detailed discussion of the necessary calcu-
lations is contained on pages 9-6U through 9-71 of
the reference.
The record also must contain documentation, such
as checklists or supporting calculations, indi-
cating that the engineering calculations have been
technically reviewed and are approved.
Enforceab i I i t.v
The permit must include provisions for certifica-
tion as per UO CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 26<4.303(a).
REFERENCES
PWGM
pp. 9-6U to 9-71
FINDINGS/COMMENTS
Effect ive
January 31,
1985
/f-77
-------
VIII LANDFILLS
B Liner Systems
B-U Leachate collection/detection system
o installation procedures
REGULATORY REQUIREMENT
The permit must contain
detailed construction
specifications for con-
structing the leachate
collection and detection
systems (1*0 CFR
264.301 ).
EVALUATION CRITERIA
Technical Soundness
The installation procedures specified in the
permit should address, at a minimum, the following
i terns.
o pipe placement procedures,
o protection of the liners during placement of
the systems,
o construction procedures for the sumps, and
o placement of the granular material and
f i I ters.
Enforceab iIi ty
The permit must include provisions for certifica-
tion as per UO CFR 270.30(k)(2) and inspection
during construction as per <40 CFR 26U.303(a).
REFERENCES
FINDINGS/COMMENTS
GDLS
pp. 3
Effect ive
July 26, 1982
4-78
-------
VI I I LANDFILLS
B Liner Systems
B-4 Leachate collection/detection system
o inspection and monitoring procedures during installation
REGULATORY REQUIREMENT
The permit must contain
a construction quality
assurance plan to assure
that the leachate col-
lection and detection
systems are constructed
in accordance with the
plans and specifica-
tions (40 CFR 264. 301
and 264.303).
EVALUATION CRITERIA
Technical Soundness
The construction inspection and monitoring
procedures addressed in the permit should include:
o qualifications of the inspectors,
o testing procedures,
o inspection during placement of the materials,
and
o documentation procedures.
Enforceab i I i t.v
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.303(a).
REFERENCES
FINDINGS/COMMENTS
GDLS
pp.
CQA
Effect ive
July 31, 1985
-------
B
VI I I LANDFILLS
B Liner Systems
-5 Liner system foundation preparation
REGULATORY REQUIREMENT
The liner system must be
placed on a foundation
capable of supporting
the liner system and
resistant to forces
which could result in
Iiner fa ilure due to
settlement, compression,
or uplift (40 CFR
264.301(8)).
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain geotech-
nical data and engineering calculations which
describe the liner system foundation and verify
that it has sufficient strength to support the
liner and prevent failures. Detailed discussions
of the data requirements and the analyses are
included in the reference.
General items which should be addressed in support
of the foundation preparation procedures include:
o test boring information (i.e., location plan
and boring logs);
o results of soil and/or rock testing;
o engineering calculations for settlement
analysis, bearing capacity analysis, and
landfill slope analysis; and
o discussion of the potential excess gas or
hydrostatic uplift pressure and subsidence
and sinkhole potential.
The record also must contain detailed foundation
construction specifications and a construction
quality assurance procedure for preparation of the
foundation. The necessary items are very s'' c-
specific, but are discussed in general in the
references.
Finally, the record must contain documentation,
such as checklists or supporting calculations,
indicating that all engineering calculations and
test data have been technically reviewed and are
approved.
EnforceabiIity
The permit must include provisions for certifica-
tion as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.303(a).
REFERENCES
GDLS pp. 39-44
PWGM
pp. 9-31 to 9-50
CQA
FINDINGS/COMMENTS
Effective
July 26, 1982
4-80
-------
VIM LANDFILLS
Runoff Control System
o des i gn
REGULATORY REQUIREMENT
The permit must describe
the runoff control
design as per 40 CFR
270.21(b)(3) and
264.301(g). The design
may incorporate features
such as channels, hold-
ing basins and tanks,
pipes, spiIIways,
ditches, ponds, etc.
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain an engi-
neering report and drawings having the necessary
documentation supporting the design of the runoff
control system. The runoff control system is
required to collect and control, at a minimum,
runoff from active landfill areas resulting from
the 25-year, 24-hour storm event.
Information must include the size and capacity
calculations of all hydraulic structures such as
pumps, pipes, weirs, spillways, channels, tanks,
ponds, etc. The magnitude of the 25-year, 24-hour
storm may be determined using data from the U.S.
Weather Bureau Technical Publication 40 or other
acceptable data. Calculations must be provided
for the runoff peak discharge and/or volume
resulting from a 25-year, 24-hour storm event.
Peak discharge and/or volume must be calculated
in accordance with the U.S. Department of Agri-
culture Soil Conservation Service procedures or
similar procedures. Units used to hold runoff
must meet the applicable 40 CFR 264 standards
(Subpart K for Surface Impoundments, Subpart J for
Tanks, etc.).
In addition, the record must contain documentation
in the form of calculations, notes, etc., to show
that a technical review was conducted on the
runoff control system design.
REFERENCES
PWGM
pp. 9-127 to 9-134
PAGM
pp. 8-33 to 8-37
FIND INGS/COMMENTS
Effect ive
July 26, 1982
4-81
-------
VIM LANDFILLS
D Runorr Control System
o construction procedures
REGULATORY REQUIREMENT
The permit must specify
construction procedures
for the runoff control
system as per UO CFR
270.21(b)(3) and
26U.301(g).
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain an engi-
neering report and drawings having the necessary
documentation supporting construction procedures.
The information must include detailed construction
and material specifications. A detailed descrip-
tion of the construction quality control program
also must be provided.
In addition, the record must contain documentation
(e.g., calculations, notes) showing that a tech-
nical review was conducted of the construction
procedures.
Enforceabi I i t.v
The permit must specify the monitoring and inspec-
tion plan to be followed during construction as
per '<0 CFR 270.21 (d). The permit must require
certification by a professional engineer that the
runoff control system has been constructed as
designed as per UO CFR 270.30(k)(2 ).
REFERENCES
PWGM
pp. 9-127
PAGM
pp. 8-33
PWCM
pp. 9-1U7 to 9-177
and pp. 14-5
PAGM
pp. 8-U4 to 8-U8
CQA
FINDINGS/COMMENTS
Effect ive
July 26, 1982
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-82
-------
VI I I LANDFILLS
Runoff Control System
o ma i ntenance
REGULATORY REQUIREMENT
The permit must specify
a maintenance plan for
the runoff control
system as per 40 CFR
270.21(b)(3) and
EVALUATION CRITERIA
Technical Soundness
The administrative record must contain an engi-
neering report having the necessary documentation
supporting' the maintenance plan. The plan must
contain a detailed description of all maintenance
operations and the schedule for completing each
operat ion.
In addition, the record must show that a technical
review was conducted of the maintenance plan.
Enforceab iIi tv
The permit must specify an inspection plan for
operation of the landfill as per 1)0 CFR 270.21(d).
The operation inspection plan must stipulate that
the runoff control system be inspected for damage
and malfunction weekly and after storms. The
permit must specify the repairs that will be
performed in the event that inspection discloses
damage or malfunction. The permit also must
require that records be maintained of a I I
inspections and repairs or corrective actions.
REFERENCES
PWGM
pp. 9-127
PAGM
pp. 8-33
PWGM
pp. 9-177 to 9-183
PAGM
pp. 8-49 to 8-50
FINDINGS/COMMENTS
Effect ive
July 26, 1982
Note: When enforceabiIity of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-83
-------
REGULATORY REQUIREMENT
Bulk and containerized
liquid wastes can only
be placed in landfills
under certain very
controlled conditions
(HO CFR 26U.31U).
VI I I LANDFILLS
Liquids in LandfiI Is
EVALUATION CRITERIA
Technical Soundness
Liquid wastes can only be placed in landfills if
they have been solidified. This includes bulk or
noncontainerized liquids and containerized
liquids. The ban also applies to both hazardous
and nonhazardous liquids.
Except ions:
no other method of disposal
lined in 40 CFR 26«4.31U(e)
exists as out-
some 'liquids can be placed in the landfill
for beneficial purposes (see guidance)
if
REFERENCES
BLM
(Add i t ionaI
guidance on the
placement of
liquids in
landfiI Is was
being drafted as
this is prepa red.
Th i s guidance will
address beneficial
purposes and was
to be distributed
in ApriI of 1986. )
FINDINGS/COMMENTS
The administrative record must contain docu-
mentation that the method of liquid stabilization
is not an absorbent operation, as discussed in the
references. It also must indicate the procedures
to be followed in testing, handling, and disposing
of these wastes within the landfill.
Enforceab iIi ty
The permit must contain a provision for testing
wastes using the "Paint Filter Test" (Method 9095)
as required by 40 CFR 270.30(j).
The permit also must contain a condition requiring
the owner/operator to maintain records of the
testing results in accordance with 40 CFR
270.30U).
Effect ive
April 30,
1985
4-84
-------
VI I I LANDFILLS
L LandfiI I Closure
L-2 Final cover
L-2a cover design
REGULATORY REQUIREMENT
Each landfill unit must
be covered at closure
with a cover which mini-
mizes the migration of
Iiquid through the
cover, requires little
maintenance, promotes
drainage, minimizes
erosion, accommodates
settling and subsidence
and has a permeability
less than or equal to
the Iiner (40 CFR
264.310). The permit
must include a
detailed description and
drawings of the cover to
be used. These condi-
t ions a I so apply to
surface impoundments and
waste piles closed as
landfiI Is.
EVALUATION CRITERIA
Technical Soundness
Guidance reports indicate that the EPA recommended
cover should consist of the following (from bottom
to top):
o a 2-foot-thick soil layer having a permea-
bi I i ty of 1x10~7 cm/sec or less,
o a 20 mil or thicker flexible membrane liner,
o a 12-inch-thick drainage layer,
o a 2-foot-thick soil layer, and
o a vegetation crop.
The slope of the final cover surface should be at
least 3%.
Applicants are not required to use the recommended
cover; therefore, some permits will contain covers
that are different than the one described above.
The detailed description and drawings of the cover
generally should include the following items.
o drawings showing overall plan view of cover
with dimensions and cross-sections showing
slopes, layers, and thicknesses;
o the name, species, and variety of the cover
crop;
o strength, thickness, brand name, and manu-
facturer (or detailed material specifica-
tions) of flexible membrane liner;
o description of drainage layer;
o characteristics, thickness, permeability of
low permeable soil layer;
o potential settlement of the cover;
o potential for gas generation; and
o effects of freeze-thaw cycles on the cover.
REFERENCES
LDFC
pp. 23-33
PWGM
pp. 9-187 to 9-201
SW-867
FINDINGS/COMMENTS
Effect ive
July 26, 1982
-------
VI I I LANDFILLS
L LandfiI I Closure
L-2 F i naI cove r
L-2a cover design
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA' REFERENCES FINDINGS/COMMENTS
Also included must be detailed engineering cal-
culations addressing:
o erosion of the cover soils,
o free drainage of precipitation off of the
cover,
o free drainage of the drainage layer, and
o potential of clogging of the drainage layer.
In cases where a cover design other than the
recommended cover is used, the record must contain
detailed engineering calculations which address:
o Long-term minimization of liquids through the
cover.
o A demonstration that the permeability of the
cover equals or is less than that of the
landfill liner or subsoils.
Documentation such as checklists or supporting
calculations must be included in the record to
show that the engineering analyses provided by the
appIicant 'have been technically reviewed and are
approved.
Enforceab iIi ty
The permit must include provisions for certifica-
tion of closure as per UO CFR 264.115.
4-86
-------
IX INCINERATION
Limitation on Wastes
REGULATORY REQUIREMENT
The hazardous waste con-
stituents specified in
the permit must be those
which were burned
successfully at least to
a 99.99 percent ORE
during the trial burn,
or constituents which
exhibit higher heats of
combustion (40 CFR
EVALUATION CRITERIA
Technical Soundness
The types and quantities of hazardous waste con-
stituents to be burned in the incineration system
must be limited in the permit. A permittee is not
permitted to burn hazardous waste constituents
whose heat of combustion values (the accepted
measure of the degree of difficulty for the
constituents to burn) are lower tha.n the POHC's
successfully incinerated in the trial burn. Waste
constituents may only be restricted if they are
listed in Appendix VIII of 40 CFR Part 261.
There are two options for identifying the
allowable waste feed to the incinerator. The
first option covers situations where it is not
practical to list all of the wastes that a
facility might be permitted to burn. In this
option, criteria are identified to establish
limitations on the physical and chemical char-
acteristics of the waste input to the incinerator.
The second option is more appropriate for so-
called "on-site" incinerators used as a part of a
chemical process or manufacturing operation.
In that instance, it is usually straightforward to
specifically identify the waste constituents or
classes of wastes that the permittee is permitted
to burn.
Limitations must be established for each type of
waste fed to the incineration system. For
example, if.the incinerator accepts both solid and
liquid feeds, limitations for e<'ich must be set in
the permit based on the trial burn results.
Enforceab iIi ty
Quantitative limitations on waste feed must be set
forth in the permit. In addition, the waste
analysis provisions (Section II) must specify a
frequency for verifying that the waste feed is
within the physical and chemical composition
limits. [Section 264.341(b)]
REFERENCES
GM-HWIP
pp. 4-16 through
4-24
FINDINGS/COMMENTS
MP
pp. VI-2 through
VI-3
Effect ive
April 1, 1983
4-87
-------
IX INCINERATION
D Operating Conditions for Each Waste
Feed
.REGULATORY REQUIREMENT
The permit must specify
operating conditions for
each waste feed stream
to the incinerator to
assure that the incin-
eration facility meets
the performance stan-
dards (140 CFR 264.3U3
and 261.3U5).
EVALUATION CRITERIA
Technical Soundness
It is possible that an incineration system can be
permitted for more than one waste feed (e.g., the
incinerator could operate on one definable waste
feed during the summer and another during the
winter). In such cases, a complete set of opera-
ting limits must be specified for each waste feed.
The permit operating conditions for each waste
feed must include each of the following: carbon
monoxide concentration in the stack gas, waste
feed rate, combustion temperature, and a measure
of combustion gas flow rate. Other operating con-
ditions can be set where the permit writer finds
it necessary to assure compliance with the ORE,
HCI, and particulate standards. Examples are air
pollution control system operating 'conditions
(e.g., wet scrubber water recirculating rate and
pH). The limits set forth in the permit must be
based on the trial burn results.
The operating conditions should allow for varia-
tions in incineration system operating procedures.
For example, combustion temperature could be
specified as a minimum of 2350 degrees F. Some
allowance for normal variations is needed in order
to protect against unnecessary activation of the
waste feed cut-off system.
Enforceab iIi ty
Each set of operating conditions must directly
relate to achieving the performance standards. A
key purpose of the trial burn is to identify oper-
ating conditions that prevail when it is demon-
strated through extensive sampling and analyses
that the incineration system is in compliance with
the performance standards. EPA does not intend to
require the permittee to conduct frequent trial
"burns, which are both costly and time-consuming.
Thus, for purposes of permit enforcement, compli-
ance with the operating conditions set forth in
the permit is regarded by EPA as compliance with
the performance standards | 26U. 3<43(d ) ]. If the
permittee complies with the permit operating con-
ditions, but it is later shown that the perform-
ance standards are not being attained, the permit
may be modified or revoked and reissued.
REFERENCES
FINDINGS/COMMENTS
GM-HWIP
pp. U-2 through
GM-HWIP
pp. 5-7
Effect ive
April 1, 1983
4-88
-------
IX INCINERATION
D-7 Waste feed cut-off
REGULATORY REQUIREMENT
A system must be speci-
fied in the permit to
automatically cut off
waste feed to the
incinerator whenever the
operating conditions
deviate from the limits
designated in permit
(UO CFR 26t.3U5(e)).
EVALUATION CRITERIA
Technical Soundness
The purpose of the automatic waste feed cut-off
system is to shut off all waste feed to the incin-
erator whenever the operating conditions are out-
side the limits specified in the permit. The
cutoff valves on the waste feed lines must be
interlocked to the appropriate operating condi-
tions (e.g., stack gas carbon monoxide level,
combustion temperature). A calibration frequency
and test frequency must be specified in the per-
mit. The regulations [26U.3U7(c)] require weekly
testing, but monthly testing can be allowed where
the permittee has demonstrated that weekly testing
will be disruptive and that monthly inspection is
suff ic ient.
Enforceab iIi ty
Numerical limits must be set for each permitted
operating condition which activates the automatic
waste feed cut-off system. The calibration and
test frequency must be recorded in the operating
log. The log can be reviewed during site inspec-
tions by EPA or state personnel.
REFERENCES
GM-HWIP
pp. U-Hi through
U-16 and H-25
FINDINGS/COMMENTS
Effect ive
June 24, 1982
4-89
-------
IX INCINERATION
E Monitoring
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must specify Technical Soundness
a monitoring system for
each specified operating Monitoring systems must be specified for each of
condition (40 CFR the operating conditions (e.g., combustion temper-
264.347). ature, waste feed rate, carbon monoxide concen-
tration in the stack gas) listed in the permit.
The frequency of monitoring, testing, and calibra-
tion must be specified along with the method for
recording the monitoring data. Combustion tempei—
ature, waste feed rate, combustion gas velocity
indicator and CO stack gas concentration must be
recorded continuously.
Enforceab i I i t.v
Frequencies for monitoring each operating condi-
tion must be specified in the permit. The permit
must include a provision for recording and main-
taining monitoring data pursuant to 264.347(d).
Effective
June 24, 1982
4-90
-------
REGULATORY REQUIREMENT
A permit for incinera-
tion may be granted to
conduct a trial burn, to
operate the incinerator,
or both. When a permit
includes provisions for
a trial burn, permit
conditions must address
the requirements of UO
CFR 26U.3U4(c)(2) and
270.62.
IX INCINERATION
H-2 Trial burn period
EVALUATION CRITERIA
Technical Soundness
The trial burn forms the foundation of a hazardous
waste incineration system permit. The trial burn
must demonstrate compliance with performance
standards and establish operating conditions to
ensure continuous long-term compliance with the
performance standards.
REFERENCES
FINDINGS/COMMENTS
GM-HWIP
Chapter 2
The permit must include the complete
plan as an attachment. The trial bu
include all of the information requi
270.62(b)(2).
trial burn
chment. The trial burn plan must
of the information required in
The permit must specify one or more principal
organic hazardous constituents (POHC's) for each
hazardous waste stream to be burned during the
trial burn. These POHC's could be major con-
stituents of the waste stream or could be
materials having relatively low BTU content used
to "spike" the waste stream. A review of
Chapter 2 of the Guidance Manual for Hazardous
Waste Incineration Permits is required to assure
that appropriate POHC's have been specified in the
permit. Since the Regional Administrator can only
approve the trial burn plan only if it gives
enough information to establish operating con-
ditions, the applicant must modify the plan to
include all POHC's the Regional Administrator
spec i fies.
The permit must specify that the permittee must
make the determinations required by
270.62(b)(6)(i)-( ix). The permit also must
require the permittee to submit to EPA a copy of
all data collected during the trial burn and the
results of a I I the determinations required by
270.62(b)(6) within 90 days after the completion
of the trial burn.
Enforceab iIi ty
The trial burn plan provides protocols and
schedules which are incorporated into the permit.
All aspects of the trial burn plan thus are
enforceable.
Effective
June 24, 1982
4-91
-------
X GROUNDWATER MONITORING - DETECTION MONITORING PROGRAM
A Indicator Parameters, Waste Constituents, Reaction Products to be Monitored
REGULATORY REQUIREMENT
The permit must specify
the parameters and/or
constituents to be
routinely monitored
under the detection
monitoring program (40
CFR 264.98(a)).
EVALUATION CRITERIA
Technical Soundness
The indicator parameters and/or waste constituents
specified in the detection monitoring program must
be selected so as to be consistent with the goal
of detection monitoring -- to a I low the earl iest
possible indication of leakage from the facility.
As such, the chosen parameters/constituents must
be representative of the waste. In addition, the
parameters/constituents must be relatively mobile,
stable, and persistent in the subsurface
env i ronment.
The administrative record must contain results of
waste characterization, including analysis to
identify both the hazardous and nonhazardous con-
stituents of the facility's waste. In addition,
the record must identify any constituents likely
to form through chemical reaction.
The record must identify those constituents which
would be most mobile and persistent, considering
all potential attenuation mechanisms. Usually,
the most mobile and persistent constituents will
be various anions (i.e., chlorides, nitrates,
etc.), cations with low adsorption potential, and
certain highly mobile organics.
Attention also must be given in the record to
background levels of proposed parameters/
constituents in the facility's groundwater
compared to levels anticipated in the waste's
leachate. If background levels are too high, it
may not be possible to correctly identify that
groundwater contamination is occurring.
There must be documentation (e.g., notes, testing
data) in the record that the permit writer ensured
consideration of all the above factors supporting
parameter/constituent selection, including
presence in the waste, mobility/persistence, and
detectab iIi ty.
Enforceab iIi ty
for
The permit must specify reporting requirements
detection monitoring in accordance with 40 CFR
264.98(g), (h), and (i), and 40 CFR 270.31(c).
The permit must specify recordkeeping provisions
for detection monitoring in accordance with 40 CFR
REFERENCES
PWGM-GWP
pp. 190-192,
199-200
FINDINGS/COMMENTS
Effect ive
July 26, 1982
4-92
-------
X GROUNDWATER MONITORING - DETECTION MONITORING PROGRAM
A Indicator Parameters, Waste Constituents, Reaction Products to be Monitored
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
H70.30U). The permit must include provisions for
certification of detection monitoring records as
per 40 CFR 270.30(k)(4). The permit must also
reserve the right of the agency to sample or
monitor at specified times to assure compliance as
per 40 CFR 270.30(i)(U).
4-93
-------
X GROUNDWATER MONITORING - DETECTION MONITORING PROGRAM
B Description of Wells
REGULATORY REQUIREMENT
As per 40 CFR 26<4.97(a)
and (c), the permit must
specify, in detail, the
individual elements of
the detection monitoring
system, including the
number, location,
sampling depths, and
design features of a I I
background and com-
pliance point wells.
EVALUATION CRITERIA
Technical Soundness
The monitoring well system must first and foremost
be consistent with supporting information in the
Part B application defining the "uppermost aqui-
fer" and associated groundwater flow rates and
directions. The definition of "aquifer" as pre-
sented in 40 CFR 260.10 is "... a geologic forma-
tion, group of formations, or part of a formation
capable of yielding a significant amount of
groundwater to wells or springs." However, in
keeping with the detection monitoring goal of
earliest possible indication of leakage, the
agency considers an aquifer to be any hydrogeo-
logic unit that provides a migration pathway to
any existing or potential point of use or dis-
charge. This important distinction must be con-
sidered in selecting well locations and depths.
In general, this will dictate the placement of
compliance point wells very close to the down-
gradient boundary of the regulated unit and in the
uppermost permeable, saturated horizon.
The information provided by the applicant to sup-
port the uppermost aquifer identification and
related well locations must be sufficient to
identify and define all logical pathways from the
facility. The site specific data offered must
consist of subsurface boring logs and hydrogeo-
logic cross-sections, the number of which should
be commensurate with the subsurface complexity of
the site. Also required are groundwater level
data and groundwater contour mapping based on
on-site well measurements sufficient to define
seasonal variations in groundwater gradient, flow
direction and rate. Boring logs and well con-
struction details must be included for existing
wells used to determine hydraulic gradients and
groundwater flow direction.
The number of wells required for a given facility
is site specific and is not based on any particu-
lar agency guidance. The number must be suffi-
cient to provide reasonable certainty that if
leakage were to occur, it would be readily
detected. Thus, the required number of wells is
proportional to the number of potential migration
routes. In some cases, multiple depth monitoring
REFERENCES
PWGM-GWP
pp. 15-82, 194
FINDINGS/COMMENTS
Effective
July 26, 1982
-------
X GROUNDWATER MONITORING - DETECTION MONITORING PROGRAM
B Description of Wells
- Cont i nued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
may be required where the likely vertical migra- TEGD
tion route cannot be adequately defined. In
determining the number of wells, consideration
must be given to the nature of the leakage (if it
occurs). At unlined facilities, leakage is likely
to be diffuse and affect a large portion of the
facility, while facilities with synthetic liners
may undergo "pinpoint" leaks of high rate but
small area. Thus, a lined facility may actually
require more detailed monitoring to detect small
plumes than a comparable unlined facility.
Well design and construction features must be
consistent with agency guidance. Inert well con-
struction materials, proper sealing techniques,
and adequate security features must be incorpor-
ated. The record must include a description of
the well drilling methods used or proposed. The
addition of foreign materials such as drilling
muds or fluids into the drilled hole must be
avoided. For existing wells, the permit must
contain as-built construction drawings or speci-
fications with actual dimensions of depth and
screened interval. For proposed wells, a typical
design must be included showing anticipated
d imens ions.
Enforceab I I i t.v
Assurance that the monitoring network is
constructed and maintained as specified in the
permit is obtained via agency inspection of
monitoring facilities as per UO CFR 270.30( i ) (U ).
4-95
-------
X GROUNDWATER MONITORING - DETECTION MONITORING PROGRAM
D Sampling, Analysis, and Statistical Procedures
D-1 Sample collection
REGULATORY REQUIREMENT
As per *40 CFR
26U.97(d)(1), the permit
must specify the pro-
cedures and techniques
to be used for ground-
water sample collection.
EVALUATION CRITERIA
REFERENCES
FINDINGS/COMMENTS
Technical Soundness
The sampling procedures specified in the permit
must be consistent and designed to ensure monitor-
ing results that provide a reliable indication of
groundwater quality. Procedures for evacuating
stagnant water from the well prior to sampling, as
well as procedures for withdrawal of the actual
sample must be specified. Also, sample collection
procedures should specify the method of water
level measurement in each well. Of particular
importance with regard to sample collection are:
PWGM-GWP
pp. 83-109,
194-195
MGWSP
o
use or inert materials in sampling eqii'.nen
to ensure that samples are not contaminated
or altered by foreign materials.
o Use of sampling methodology which does not
result in excessive exposure to the atmosphere
or other gases causing chemical alteration.
o Specification of adequate procedures tc pre-
vent cross-contamination; the procedures
specified must be chosen to fit the nature
of the sample analysis to be performed.
The administrative record must contain documenta-
tion that sample collection procedures were re-
viewed for technical adequacy and were found to be
suitable for the type of well construction and the
nature of monitoring parameters to be analyzed.
This review must include comparison of the pro-
posed procedures to agency guidance with any
necessary modifications specified in the permit.
Enforceab 1^ I i ty
The permit must include provisions to require that
sampling and measurement during monitoring be
representative as per 10 CFR 270.30(j)(1). The
permit must also include provisions for certifi-
cation of monitoring results as per 10 CFR
270.30(k)(1) and inspection of monitoring activi-
ties as per 10 CFR 270.30(i ) (1).
Effect ive
July 26, 1982
-------
REGULATORY REQUIREMENT
The permit
procedures
must specify
to determine
whether there has been a
statistically signifi-
cant change over back-
ground, indicative of
facility leakage, for
each parameter monitored
at the compliance point
(40 CFR 264.98(g)(1),
264.97(h)).
X GROUNDWATER MONITORING - DETECTION MONITORING PROGRAM
D Sampling, Analysis, and Statistical Procedures
D-8 Statistical determination
D-8a statistical procedure
EVALUATION CRITERIA
Technical Soundness
The administrative record must demonstrate that
the statistical procedures specified in the permit
are suitable for comparing detection monitoring
parameter values to background levels. The basic
statistical technique -- the Students' t-test --
is specified in detail in the regulations under 40
CFR 264.97(h)(1)( i ). The permit writer has the
option of specifying the basic statistical tech-
nique or some other valid technique which may be
suitable under the circumstances. Several alter-
native procedures are available as outlined in the
agency guidance such as the Mann-Whitney U lest.
Such alternative procedures are applicable only
when water quality data exhibits specific charac-
teristics. In specifying the basic Students'
t-test or an alternative procedure, the permit
writer must ensure that the observed character-
istics of the monitoring data are such that the
procedure is appropriate. For example, the basic
Students' t-test is appropriate only when the
background levels of a particular parameter are
normally distributed (background sample coeffi-
cient of variation less than 1.00). The adminis-
tra^tive record must contain sufficient background
data from previous monitoring to allow such a
determination. Alternatively, the permit may
specify a statistical procedure based on probable
characteristics for background data with the under-
standing that a permit modification may be neces-
sary if subsequently obtained background data indi-
cates this procedure is not suitable.
The administrative record must document that suit-
able statistical procedures have been specified
which achieve a reasonable balance between the
probability of falsely identifying a non-contam-
inating facility and the probability of failing to
identify a contaminating facility. The record
also must document that the specified procedure(s)
are suitable in light of background characteris-
tics.
EnforceabiIi ty
The permit must specify reporting requirements for
detection monitoring as per 40 CFR 264.98(g), (h).
REFERENCES
PWGM-GWP
pp. 127-155,
192-194
FINDINGS/COMMENTS
Effect ive
July 26, 1982
4-97
-------
X GROUNDWATER MONI 1 OR ING - DETECTION MONITORING PROGRAM
D Sampling, Analysis, and Statistical Procedures
D-8 Statistical determination
D-8a statistical procedure
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
and (i), and 40 CFR 270.31(c). The permit must
specify recordkeeping requirements as per 40
CFR 270.30(j). The permit must also include
provisions for certification of statistical
results as per MO CFR 270.30(k)(4).
4-98
-------
XI
GROUNDWATER MONITORING - COMPLIANCE
A Hazardous Constituents to be
MONITORING
Mon i to red
PROGRAM
REGULATORY REQUIREMENT
The permit must specify
the hazardous con-
stituents to be
routinely monitored
under the compliance
monitoring program (40
CFR 264.93 and 264.99).
Effect ive
July 26, 1982
EVALUATION CRITERIA
Technical Soundness
Section 26*4.93 of Subpart F establishes the
following criteria for specifying hazardous
constituents in the permit:
REFERENCES
FINDINGS/COMMENTS
Const i tuent
40 CFR Part
is included
261.
in Append ix VI I I of
Constituent has been detected in groundwater
in the uppermost aquifer under the regulated
un i t.
When hazardous constituents have been detected in
the groundwater, the owner/ operator is required
to sample to determine the presence of a I I Appen-
dix VIII constituents in the groundwater in sup-
port of establishing a compliance monitoring pro-
gram. Documentation must be provided showing that
the monitoring network and sampling and analysis
procedures used in the program were adequate. The
permit writer must ensure that this program was
sufficient to identify all Appendix VIII consti-
tuents in the facility's groundwater, not just
some limited set of constituents.
In general, all Appendix VIII constituents identi-
fied in the groundwater must be specified in the
"groundwater protection standard" for that facil-
ity and be included in the list of hazardous con-
stituents to be routinely monitored. The follow-
ing exclusions/exemptions are possible according
to agency guidance:
o The constituent(s) cannot reasonably be
expected to be in or derived from the waste
contained in the facility.
o The constituentfs) cannot pose a substantial
present or potential hazard to human health
or the environment.
Recent agency guidance allows permit writers a
certain amount of latitude relative to
Appendix VIII parameters required for monitoring.
If there is any question regarding the parameters
specified in the permit, discuss the issue with
the permi t wri ter.
PWGM-GWP
pp. 158-164
4-99
-------
XI GROUNDWATER MONITORING - COMPLIANCE MONITORING PROGRAM
A Hazardous Constituents to be Monitored
- Continued -
REGULATORY REQUIREMENT
EVALUATION CRITERIA
The administrative record must document (e.g.,
notes, testing data) that all specified compliance
monitoring constituents meet the above criteria;
if any constituents which 'meet these criteria are
not included, supporting documentation/rationaIe
must be provided.
Enforceab i I i t.v
The permit must establish a groundwater protection
standard which specifies hazardous constituents to
be monitored as per 40 CFR 26*4.93. The pernr':-.
must specify reporting requirements for compliance
monitoring as per '10 CFR 26*4.99(h), (i), and (j),
and <40 CFR 270.31(c). The permit must specify
recordkeeping provisions as per UO CFR 270.30(j),
and certification of records as per <40 CFR
270.30(k)(4). The permit also must reserve the
right of the agency to sample or monitor at
specified times to assure compliance as per UO CFR
270.30( i )(<*).
REFERENCES
FINDINGS/COMMENTS
-100
-------
XI COMPLIANCE MONITORING PROGRAM
A-1 Concentration Limits
REGULATORY REQUIREMENT
The permit must specify
concentration limits in
the facility's ground-
water for each hazardous
constituent specified in
the permit for com-
pliance monitoring (40
CFR 264.94 and 264.99).
EVALUATION CRITERIA
Technical Soundness
The criteria specified in Section 264.94 are
designed to allow no degradation of water quality
unless it can be shown that no substantial adverse
public health or environmental effects can occur.
For constituents where Maximum Concentration
Limits (MCL's) have been established in the
regulations, the MCL is normally the concentration
limit. For other constituents, or where back-
ground levels exceed a particular MCL, the
following options exist:
o The concentration limit is set such that no
degradation beyond background quality is
a I I owed.
o An alternate concentration limit (ACL) is set
for the constituent based on an acceptable
level of degradation not adversely affecting
public health or the environment. Detailed
agency guidance exists on the subject of
ACL's.
The administrative record must document that the
above criteria were followed in establishing
concentration limits for each constituent. Where
MCL's exist, the technical basis may be simple and
straightforward. Where MCL's are not in place,
the specification of limits will either require
firmly establishing background levels and
statistical methods for comparison, or an exten-
sive and detailed study supporting ACL's.
Enforceab iIi ty
The permit must establish a groundwater protection
standard which specifies concentration limits for
each hazardous constituent to be monitored as per
40 CFR 264.94. The permit must specify that wher-
ever the groundwater protection standard is
exceeded, or whenever hazardous constituents from
the facility exceed concentration limits in
groundwater between the compliance point and the
downgradient facility boundary, the owner/operator
must institute a corrective action program under
40 CFR 264.100.
REFERENCES
FINDINGS/COMMENTS
Genera I:
PWGM-GWP
pp. 164-187
ACL1s:
ACLG
Effective
July 26, 1982
4-101
-------
XI COMPLIANCE MONITORING PROGRAM
A-1 Concentration Limits
- Continued -
REGULATORY REQUIREMENT EVALUATION CRITERIA REFERENCES FINDINGS/COMMENTS
The permit must specify reporting requirements for
compliance monitoring as per l\Q CFR 26*4.99(h),
(i), and (j), and UO CFR 270.31(c). The permit
must specify recordkeep i ng provisions as per '40
CFR 270.30(j), and certification of records as per
UO CFR 270.30(k)(U). The permit also must reserve
the agency's right to sample or monitor at
specified times to assure compliance as per 40 CFR
270.30( i )(U).
4-102
-------
XI COMPLIANCE MONITORING PROGRAM
D Sampling, Analysis, and Statistical Procedures
D-1 Sample collection
REGULATORY REQUIREMENT
The permit must specify
the procedures and
techniques for sample
collection under the
compliance monitoring
program (40 CFR
264.97(d)(1)).
EVALUATION CRITERIA
Technical Soundness
The specified procedures must be vaI id for the
particular hazardous constituents monitored in the
compliance monitoring program. In addition
sampling procedures must be specified for the
annual Appendix VIII sampling to detect the
arrival of any additional hazardous constituents.
Sampling procedures established under the detec-
tion monitoring or interim status program may be
applicable, but must be reviewed/modified to
account for changes in the list of constituents to
be tested. See Section XI I.D-1 (Detection
Monitoring Program - Sample Collection) for ^di-
tional notes.
Enforceab i I I t.v
The permit must include provisions to require that
sampling and measurement during monitoring be
representative as per 40 CFR 270.30(j )(1 ). The
permit must also include provisions for certifi-
cation of monitoring results as per 40 CFR
270.30(k)(4) and inspection of monitoring activi-
ties as per 40 CFR 270.30(i)(4 ).
REFERENCES
FINDINGS/COMMENTS
PWGM-GWP
pp. 83-109,
211-213
MGWSP
Effect ive
July 26, 1982
4-103
-------
XI COMPLIANCE MONITORING PROGRAM
D-7 Statistical Determination
D-7a statistical procedure
REGULATORY REQUIREMENT
The permit must specify
the statistical proce-
dures used to determine
whether a statistically
significant increase
over background values
has occurred for each
hazardous constituent
monitored at the com-
pliance point (40 CFR
26U.97(h),
26U.99(h)(1)).
EVALUATION CRITERIA
Technical Soundness
The statistical procedure must be adequate to
compare monitoring data with the established
concentration limits to identify violations of the
facility's groundwater protection standard. No
'basic procedures (e.g.. Students' t-test) are
specified in the regulations for compliance
monitoring. The procedure chosen will be site
specific and dependent on the nature of the
concentration limits established in the permit
(background concentrations vs. specific concen-
tration limits).
Concentration limits based on background values
require procedures to account for sampling/
analysis variability as well as spatial and
seasonal variability of background levels. See
Section XII.D-8a (Detection Monitoring Program -
Statistical Procedure) for additional notes con-
cerning this subject.
Concentration limits based on specific limits
(MCL's or ACL's) rather than background values
require accounting only for variability introduced
by sampling/analysis. The most straightforward
comparison uses no statistical test at all. Where
it is desirable to account for measurement
variability, multiple sampling/analysis for each
well followed by a statistical analysis such as
the Students' t-test may be specified in the
pe rm i t.
Enforceab iI i tv
The permit must specify reporting requirements for
compliance monitoring as per UO CFR 26U.98(g),
(h), and (i), and MO CFR 270.31(c). The permit
must specify recordkeeping requirements as per UO
CFR 270.30(j). The permit also must include
provisions for certification of statistical
results as per 40 CFR 270.30(k)(U).
REFERENCES
PWGP-GWP
pp. 127-155,
206-207
FINDINGS/COMMENTS
Effect ive
July 26, 1982
4-104
-------
XII CORRECTIVE ACTION PROGRAM
A Concentration Limits
REGULATORY REQUIREMENT
The permit must specify
concentration limits for
each hazardous con-
stituent included in the
groundwater protection
standard (40 CFR
264.100(a)(1)).
EVALUATION CRITERIA
Technical Soundness
See notes provided under Sections XI.A (Hazardous
Constituents to be Monitored) and XI.A-1 (Con-
centration Limits) of this protocol. The ground-
water protection standard established for the
compliance monitoring program is also applicable
under a Subpart F corrective action program (CAP).
Enforceab iIi ty
The permit must establish a groundwater protection
standard which specifies concentration limits for
each hazardous constituent to be monitored as per
40 CFR 2614.9*4. The permit must specify that
'wherever the groundwater protection standard is
exceeded, or whenever hazardous constituents from
the facility exceed concentration limits in
groundwater between the compliance point and the
downgradient facility boundary, the owner/operator
must institute a corrective action program under
«40 CFR 26*4.100.
The permit must specify reporting requirements for
compliance monitoring as per 40 CFR 26U.99(h),
(i), and (j), and '|0 CFR 270.31(c). The permit
must specify recordkeeping provisions as per 40
CFR 270.30(j), and certification of records as per
t)0 CFR 270.30(k)(4). The permit also must reserve
the agency's right to sample or monitor at
specified times to assure compliance as per 40 CFR
270.30( i )(4).
REFERENCES
Genera I:
PWGM-GWP
pp., 16*4-187
ACL's: ACLG
FINDINGS/COMMENTS
Effect ive
July 26, 1982
4-105
-------
XII CORRECTIVE ACTION PROGRAM
F Sampling, Analysis, and Statistical Procedures
F-1 Sample collection
REGULATORY REQUIREMENT
The permit must specify
the procedures and tech-
niques for sample col-
lection to be performed
under the corrective
action program (40 CFR
26U.97(d)(1)).
EVALUATION CRITERIA
Technical Soundness
As in compliance monitoring, the specified samp-
ling procedures must be valid for the particular
hazardous constituents to be monitored in associ-
ation with the CAP. See Section XI.D-1 (Com-
pliance Monitoring Program - Sample Collection) of
this protocol for notes related to sample collec-
tion from compliance point wells.
For monitoring wells located beyond the point of
compliance, less sophisticated sampling procedures
for key indicators may be specified for wells
known to be grossly contaminated. As concentra-
tions approach acceptable limits, compliance point
procedures must be applied.
Enforceabi I i t.v
The permit must include provisions to require that
sampling and measurement during monitoring be
representative as per UO CFR 270.30(j )(1 ). The
'permit also must include provisions for certifi-
cation of monitoring results as per UO CFR
270.30(k)(4 ) and inspection of monitoring activi-
ties as per MO CFR 270.30( i ) (4 ).
REFERENCES
PWGM-GWP
pp. 83-109,
211-213, 260
A I so, Man u a I o_T
Ground-Water
Samp I i ng
Procedures (Sea If,
FINDINGS/COMMENTS
e.t
1981
Effect ive
July 26, 1982
4-106
-------
XII CORRECTIVE ACTION PROGRAM
F-7 Statistical Determination
REGULATORY REQUIREMENT
The permit must specify
statistical procedures
to be followed in demon-
strating that corrective
measures are effective
and in determining
whether the facility is
in compliance with the
groundwater protection
standard (MO CFR
2614.97(h),
264.99(h)(1)).
EVALUATION CRITERIA
Technical Soundness
Statistical procedures to determine whether the
facility has been brought back into compliance may
generally follow the guidance given under Section
XI.D-7a (Compliance Monitoring Program - Statis-
tical Procedure) of this protocol. Until ground-
water quality improves to a level near compliance,
there generally is no need to perform this
statistical analysis.
When a CAP is in place, statistical analysis must
be specified to show that the CAP effectively is
reclaiming the facility's groundwater. Generally,
a substantial data base must be generated before
such statistical determinations are possible,
especially where a large area beyond the com-
pliance point is contaminated. Where it is found
by the permit writer to be impractical to specify
statistical measures to determine effectiveness,
the following must be specified in the permit:
o A description of the water quality data base
to be developed.
o A dead I ine date for assessing the data to
determine whether statistical measures to
establish effectiveness may be instituted.
Enforceab i I i t.v
•The permit must specify reporting requirements for
corrective action program monitoring as per 40 CFR
264.98(g), (h), and (i), and 40 CFR 270.31(c).
The permit must specify recordkceping requirements
as per 40 CFR 170.30(j). The permit also must
include provisions for certification of statisti-
cal results as per 40 CFR 270.30(k)(4).
REFERENCES
PWGM-GWP
pp. 127-155,
206-207, 260
FINDINGS/COMMENTS
Effect ive
July 26, 1982
4-107
-------
4-108
-------
APPENDIX A
CHECKLIST FOR RCRA RESEARCH,
DEVELOPMENT AND DEMONSTRATION PERMITS
-------
Fac M i ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Provided i
(Y/N) or NA Location Comments
I STANDARD CONDITIONS
A Effect of Permit [§§270.'I, 270.30(g))
B Permi t Actions [§270.30(f)J
C Severabi I i t.v [ §124.16(a ) ]
D Duties and Requirements
D-1 Duty to comply l§270.30(a)]
n-2 Duty to reapply [§§270.30(b), 270.10(h)]
D-3 Permit expiration (§270.51)
D-4 Need to halt or reduce activity not a
defense (§270.30(c)]
D-5 Duty to mitigate [§270.30(d)J
D-6 Proper operation and maintenance
[§270.30(e>]
D-7 Duty to provide information (§§270.30(h ),
26<4.7U(a)J
D-8 Inspection and entry (§270.30(i))
D-9 Monitoring and records [§§270.30(j ),
270.30(I)(U)]
D-10 Reporting planned changes [§270.30( I ) ( 1 ) ]
D-11 Certification of construction or modification
(§270.30(l)(2)( i )]
D-12 Anticipated noncompIiance [§270.30(I ) (2 ) ]
D-13 Transfer of permits [§§270.30(I)(3), 270.40]
Yote: Under the provisions of i»0 CFR 270.65. R.D&D permits may be issued for a period up to one year. The Administrator may
waive permit requirements, except those regarding financial responsibility and those related to public participation.
Thus, the reviewer may expect to see a great deal of variation in R.D&D permits. If there are hazardous waste storage
facilities associated with the experimental process units, they must be permitted in accordance with the requirements of
40 CFR Parts 270 and 26*4. Those permit conditions may be evaluated using Sections I through IV of the Permit Quality
Protocol.
A-l
-------
Fac i Ii ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Provided
(Y/N) or NA Location Comments
D-14 Compliance schedules [§270.30(I)(5)1
D-15 Twenty-four hour reporting [§§270.30( I ) (6 ),
26U.56(d) and (j)]
D-16 Manifest discrepancy reports and unmanifested
waste reports [§270.30(I)(7) and (8)]
D-17 Biennial report [§270.30( I ) (9) ]
D-18 Other noncompliance [§270.30(I )(10)]
D-19 Other information [§270.30(I )(11 ) ]
E Signatory Requirements [§§270.11,
270.30(k)]
F Confidential Information [§270.12]
G Documents to be Submitted Prior to Operation
[§§270.32, 270.33]
H Documents to be Maintained at Facility Site
H-1 Waste analysis plan [§26U.13(b ) ]
H-2 Personnel training documents/records
[§26U.16(d)J
H-3 Contingency plan [26U.53(a>]
H-U Closure plan/post-closure plan [§26U.112(a) ]
H-5 Closure cost estimate/post-closure cost
estimate [§264.1U2(d ) ]
H-6 Operating record [§264.73]
H-7 Inspection schedule(s) [§264.15(b)]
H-8 Other documents
A-2
-------
Fac iIi ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Provided
(Y/N) or NA Location Comments
II GENERAL FACILITY CONDITIONS
A Design and Operation of Facility [§264.31]
B Requi red Notices [§264.12]
C General Haste Analysis [§2614.13]
C-1 Parameters to be analyzed for in each waste
[§264.13(b)(1)]
C-2 Analytical methods [§264.13(b) (2 ) ]
C-3 Methods to sample wastes [§264.13(b)(3 ) ]
C-4 Frequency of analysis [§264.13(b ) (4 ) J
C-5 Wastes from off-site [§264.13(a )(4 ) and (b)(5)|
C-6 Waste characterization requirements for
specific types of treatment and disposal
|§264.13(b)(6)]
D Security [§264.14)
D-1 Description of barrier and means to control
entry (or 24-hour surveillance system)
[§264.14(b)J
D-2 Description of warning signs [§264.14(c)]
E General Inspection Requirements*
[§264.15];
E-1 Inspection schedule [§264.15(b)l
E-2 I terns to be inspected [§264.15(b)(1)]
E-3 Type of problems for which each item is
inspected [§264.15(b) (3 ) ]
E-4 Inspection frequency [§264.15(b) (4) ]
F Personnel Training [§264.16]
F-1 Program director [§264.16(a ) (2 ) ]
F-2 Training program contents [§264.16(a)(3 ) ]
A-3
-------
Fac iIi ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Prov ided
(Y/N) or NA Location Comments
F-3 Frequency of training (§264.16(b) and (c)]
G General Requirements for Ignitable,
Reactive, or Incompatible Waste I §264.17)
G-1 Ignitable or reactive [§264.17(a)J
G-2 Incompatibles [§264.17(b(]
H Location Standards [§§264.18, 270.14(b) (11 ) J
H-1 Seismic considerations (§264.18(a ) ]
H-2 Flood proofing description/drawings [§264.18(b) ]
H-3 Flood plan [§264.18(b ) J
I Preparedness and Prevention
1-1 Required equipment [§264.32]
I-2 Testing and maintenance of equipment
[§264.33]
I-3 Access to communications or alarm system
(§264.34]
I-4 Required aisle space [§264.35]
1-5 Arrangements with local authorities [§264.37]
J Contingency Plan
J-1 Implementation of plan [§264.51]
J-2 Copies of plan (§264.53]
J-3 Amendments to plan [§264.54]
J-4 Contents of contingency plan (§264.52]
J-4a response procedures [§264.52(a)]
J-4b coordination agreements [§264.52(c|]
J-4c emergency coordinators [§§264.52(d ), 264.55]
J-4d emergency equipment [§264.52(e)J
A-4
-------
Fac iIi ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Provided
(Y/N) or NA Location Comments
J-4e evacuation plan [§264.52(f)]
J-5 Emergency procedures [§264.56]
J-5a notification (§264.56(a)]
J-5b identification of hazardous materials
[§264.56(b>]
J-5c assessment of hazards [ §26*4.56(c) ]
J-5d notification in event of threat to human
health or the environment [§264.56(d)J
J-5e prevention of recurrence or spread of fires,
explosions, or releases [§264.56(e>]
J-5f monitoring following cessation of operations
I§264.56(f)J
J-5g storage and treatment of released materials
(§264.56(g)]
J-5h incompatible wastes (§264.56(h)(1 ) ]
J-5i post-emergency equipment maintenance
[§264.56(h)(2)J
J-5J notification and reports [§264.56(i) and (j)]
J-6 Unit-specific control procedures
K Manifest System [§§261.71, 264.72)
L Recordkeeping and Reporting
L-1 Operating record [§26U.73]
L-2 Availability of records [§264.7'*]
L-3 Biennial report [§26U.75]
L-4 Unmanifested waste report [§264.76]
A-5
-------
FaciIi ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Prov i ded
(Y/N) or NA Location Comments
M General Closure Requirements*
M-1 Requirement for written plan [§264.112(a ) ]
M-2 Content of closure plan [ §26*4.112( b ) ]
M-2a description of final closure [§264.112(b) (2))
M-2b maximum waste inventory [§264.112(b ) (3 ) ]
M-2c decontamination or removal procedures
[§§264.112(b)(4), 264.114]
M-2d other activities required to meet closure
standard (§264.112(b) (5 ) ]
M-2e closure schedule [§§264.112(b ) (6 ), 264.113]
M-2f estimated year of final closure (where
applicable) [§264.112(b) (7)
M-3 Amendment of plan [§264.112(c ) ]
M-4 Notification of partial closure and final
closure [§264.112(d ) ]
M-5 Removal of wastes and decontamination or
dismantling of equipment [§264.112(e) ]
M-6 Certification of closure [§264.115]
N Cost Estimate for Facility Closure
[§§264.142]
0 Financial Assurance for Facility Closure
[§§264.143, 264.145]
P Liability Requirements [§264.147]
Q Incapacity of Owners or Operators.
Guarantors, or Financial Institutions
[§264.148]
*The general closure requirements applicable to all types of hazardous waste management units are listed under item M. The
specific technical requirements applicable to each type of unit are listed under those units.
A-6
-------
Fac iIi ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Provided
(Y/N) or NA Location Comments
III DESIGN AND OPERATING CONDITIONS
A Process Description
A-1 Unit processes (including treatment chemicals)
A-2 Process flow
B Design and Construction of Process Units
B-1 Design pJans and specifications
B-la process units
B-1b pollution control equipment
B-2 Materials of construction
B-3 Construction procedures and specifications
{for new uni ts )
B-4 Construction monitoring and inspection
C Operat ions
C-1 Wastes
C-la allowable types and quantities of wastes
C-1b waste feed rates
C-1c sources of wastes (where applicable)
C-1d specific prohibitions or exclusions
C-2 Operating limits
C-2a operating limits (e.g., flow rates,
temperature, pressure)
C-2b chemical feed rates
C-2c retention times, mixing rates, etc.
C-3 Operating procedures
C-4 Operating controls
A-7
-------
Fac iIi ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Provided
(Y/N) or NA Location Comments
C-Ua monitoring and instrumentation
C-Ub process controls (valves, etc.)
C-5 Procedures for treating and disposing of
by-products or off-spec product
C-6 Process monitoring and reporting (to
evaluate efficacy of the process)
C-6a parameters to be monitored
C-6b monitoring and sampling methods and
instrumentat ion
C-6c analytical methods (where appropriate)
C-6d required form of data
C-6e statistical procedures (where appropriate)
C-6f recordkeeping requirements (related to
process efficiency)
C-6g reporting requirements (related to
process efficiency)
A-8
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APPENDIX B
PROTOCOL FOR EVALUATING PERMIT
CONDITIONS RELATED TO CORRECTIVE
ACTION FOR CONTINUING RELEASES
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PROCEDURES FOR EVALUATING RCRA PERMIT CONDITIONS
FOR CORRECTIVE ACTION FOR CONTINUING RELEASES
Introduction
Unlike other RCRA permitting requirements included in this evalua-
tion protocol, EPA had not issued final guidance and regulations for
permitting requirements pursuant to Section 3004(u) of RCRA at the time
that this protocol was prepared. Therefore, the evaluation criteria
presented here are conceptual in nature. These criteria are intended to
suggest a thought process which will facilitate an efficient and focused
review of permit conditions related to corrective action. As EPA's
policies and requirements in this area evolve, these evaluation criteria
may be revised accordingly.
The criteria utilize the results of the RCRA Facility Assessment
(RFA) as the point of departure for the permit evaluation process. For
purposes of this process, it is assumed that an RFA has been performed
for the facility, and that it is technically sound and well documented
in the administrative record. The major objectives of the permit
evaluation are:
o To evaluate the responsiveness of the permit conditions to the
RFA conclusions and recommendations;
o
To evaluate how clearly and precisely the permit conditions
place enforceable requirements on the permittee; and
To evaluate the completeness of documentation in the adminis-
trative record regarding the permit conditions.
For ease of evaluating it is recommended that the review be con-
ducted in two steps: The first step is a comparison of the scope of the
permit conditions with the RFA conclusions and recommendations to
determine if the major concerns identified in the RFA have been
B-l
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addressed. The second step involves a more detailed review of con-
ditions to assess their technical soundness and enforceability.
Step 1 - Review of Scope of Permit
The permit conditions should be reviewed and a tabulation of the
following items prepared:
o identification of each solid waste management unit (SWMU) or
area of the facility to which corrective action conditions
apply;
o for each SWMU or area, the "environmental media which are
addressed (groundwater, surface water, air, subsurface gas,
soils); and
o for each SWMU or area, the generic type(s) of action required
(remedial investigation, corrective measures, interim cor-
rective action requirements, etc.).
The RFA documentation should then be reviewed and a tabulation of
the same types of information prepared. The RFA may not identify the
specific follow-up actions required, but rather may recommend "further
analytical study" or "additional data collection" through a RCRA
Facility Investigation (RFI). For purposes of this review, recom-
mendations involving information collection should be considered as RCRA
Facility Investigation recommendations.
A comparison of the permit conditions with the RFA recommendations
and conclusions will provide an indication of whether the conditions
address all major concerns identified in the RFA. Any discrepancies
should be noted, since they will be considered in more depth in the
second step of the evaluation process.
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Step 2 - Review of Quality of Permit Conditions
The second step in the process involves reviewing selected aspects
of the permit conditions to assess their technical soundness and
enforceability, with the evaluation criteria as a guide. The first set
of criteria again addresses the responsiveness of the conditions to the
recommendations and conclusions of the RFA, with the review at a greater
level of detail than that performed in the first step of the process.
In particular, if the permit conditions do not address all major con-
cerns of the RFA (or conversely, if there are conditions required which
do not appear to be discussed in the RFA documentation), then an eval-
uation of the administrative record should be made to determine if this
apparent discrepancy has been explained.
The second set of criteria addresses the degree of specificity with
which corrective actions are applied to individual units or to particu-
lar areas of the facility. In certain cases, it may not be possible or
desirable to apply permit conditions to each individual SWMU. For
example, data might not be sufficient at the time that the RFA is
conducted to correlate environmental contamination with individual units
likely to be the sources of contamination. On the other hand, even if
individual units can be identified as contamination sources there may be
cases where remedial investigations or clean-up activities can most
effectively be performed for a group of units or for areas of the
facility. The evaluation criteria are directed toward determining if
the permit unambiguously defines the units or areas to which the con-
ditions apply, and if the documentation provides the rationale for
applying these conditions across several units or over major portions of
the facility.
The next two sets of criteria are designed to assess whether the
permit conditions are structured to provide for sufficient oversight of
corrective action activities required of the facility owner/operator.
If the permit calls for the development of a release characterization
plan, the owner/operator should be required to submit this plan to EPA
and/or the state for approval by a certain date. In addition, the
B-3
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permit should have clear, distinct milestones which provide specific
direction to the owner/operator and reporting requirements to assure
that the owner/operator has complied with the milestones.
Evaluation criteria also are included addressing interim corrective
measure requirements. If the RFA recommendations call for interim
measures to reduce the risks to human health and environment, the permit
should include interim corrective action requirements responsive to
these recommendations, unless the administrative record provides an
explanation for excluding them (for example, they were addressed in an
enforcement action such as a §3008(a) or §106 order). The record also
should show that any interim measures specified in the permit are
appropriate by describing the health and environmental factors which
were considered in developing the measures.
The remaining evaluation criteria are directed to any RCRA Facility
Investigation (RFI) requirements which may be part of the permit
conditions. Since RCRA Facility Investigations must be designed on a
case-by-case basis and RFI requirements will vary widely, the permit
evaluation process must be directed to determining if certain general
principles are followed. For purposes of this review, these general
principles are:
o The objectives of the RFI should be clearly identified in the
permit documentation. As described in the evaluation
criteria, the objectives will depend on the degree to which
conclusions regarding environmental contamination can be
derived during the RFA. RFA conclusions can vary widely, from
a simple conclusion that a release is "likely" to a detailed
analysis from which corrective measures can be designed. The
objectives of the RFI must be consistent with the RFA con-
clusions. For example, if the RFA could only conclude that a
release i-s "likely," the RFI objectives should include a
confirmation that a release has actually occurred. On the
other hand, if sufficient data were available during the RFA
B-4
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to confirm a release, the objectives of the RFI permit con-
ditions might be directed toward obtaining additional data on
the nature, rate, and extent of contamination. The RFI is
expected to produce information to facilitate the design of
appropriate remedial measures.
RCRA Facility Investigation requirements should clearly and
specifically define the major elements to be included in RFI
plans. The evaluation criteria address RFI plans on a medium-
by-medium basis, and identify those elements which must, as a
minimum, be required. Not all permits will require the same
types of investigations — for example, it may not be neces-
sary to perform a hydrogeologic assessment as part of a
ground-water remedial investigation if sufficient hydro-
geologic data were available for the RFA. However, if a
hydrogeologic assessment is needed, the permit conditions
should define the elements of the required hydrogeologic
assessment plan, including as a minimum the elements identi-
fied in the evaluation criteria.
B-5
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PE
REQUIREMENT
EVALUATION CRITE.
REVIEWER FINDINGS/COMHE,
RCRA Facility Investiga-
tion plan - air.
1. Air monitoring plan.
2. Sampling and analysis
p Ian.
If an air monitoring plan is required as part of
the remedial investigation, the plan must include
the numbers and locations of all proposed upwind
and downwind monitors with a demonstration of the
adequacy of monitor placement to meet investigation
object ives.
If air monitoring is required as part of the
remedial investigation, a sampling and analysis
plan must be required which includes the following:
o List of parameters selected for analysis and
rationale for their selection.
o Proposed locations for sampling and rationale
for their selection.
o Proposed sampling procedures and equipment.
o Proposed frequency and duration of sampling.
o Proposed sample handling and preservation
procedures, including chain of custody
procedures.
o Proposed laboratory analytical techniques,
including QA/QC procedures.
w
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PE.
REQUIREMENT
EVALUATION CRITEI
REVIEWER FINDINGS/COMMEK
RCRA Facility Investiga-
tion plans - surface
waters.
1. Hydro logic assessment
plan.
to
I
2. Surface water
monitoring plan.
3. Sampling and analysis
plan.
If a hydroIogic assessment plan is required in
order to assess the potential of surface water
contamination by surface or subsurface migration of
contaminants from the SWMU or area of the facility
of concern, the plan must include the following, as
necessary:
o Identification of surficial features (e.g.,
topographic locations, manmade barriers,
soil/vegetative cover descriptions, etc.)
relevant to characterization of drainage
patterns between the SWMU or area of the
facility of concern and adjoining bodies of
surface water. This evaluation is not
necessary if releases to surface waters via
surface pathways are not of concern.
o Identification of types of recharge and
discharge between surface waters and aquifers
potentially contaminated by the SWMU or area
of the facility of concern. This evaluation
is not necessary if releases to surface
waters via subsurface pathways are not
of concern.
o Characterization of all bodies of surface
waters potentially affected by the SWMU or
area of the facility of concern (e.g., flow
rates, seasonaI/diurnaI variation in flows,
delineation of 100-year floodplain, etc.).
If a surface water monitoring plan is required as
part of the remedial investigation, tin- plan must
include the numbers, locations, and depths of all
proposed upstream and downstream monitoring points
with a demonstration of the adequacy of monitor
placement to meet investigation objectives.
If surface water monitoring
the remedial investigation,
plan must be required which
is required as part of
a sampling and analysis
includes the following:
o Proposed sampling procedures and equipment.
o Proposed frequency of sampling and number of
samples to be obtained during each sampling
eye Ie.
o Proposed sample handling and preservation
procedures, including chain of custody
procedures.
o Proposed laboratory analytical techniques,
including QA/QC procedures.
o Proposed list of parameters selected for
analysis, and rationale for their selection.
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Pt
REQUIREMENT
RCRA Facility Investiga-
tion p lans - so iI.
1. Soil sampling plan.
EVALUATION CRITE.
REVIEWER FINDINGS/COMHE.
If soil sampling is required as part of the RFI,
the sampling plan must include proposed number and
locations of samples and/or proposed grid system
and depths and each sampling location. Locations
to obtain background samples must be identified. A
demonstration of the adequacy of the proposed
sampling approach to meet investigation objectives
must be made.
2. Sampling and analysis
plan.
If soil sampling is required as part of the RFI,
a sampling and analysis plan must be required, to
include the following:
o Proposed sampling procedures and equipment.
o Proposed sample handling and preservation
procedures, including chain of custody
procedures.
o Proposed laboratory analytical techniques,
including QA/QC procedures.
o Proposed list of parameters selected for
analysis, and rationale for their selection.
00
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PROCEDURES FOR EVALUATING RCRA PERMIT CONDITIONS
FOR CORRECTIVE ACTION FOR CONTINUING RELEASES
Introduction
Unlike other RCRA permitting requirements included in this evalua-
tion protocol, EPA had not issued final guidance and regulations for
permitting requirements pursuant to Section 3004(u) of RCRA at the time
that this protocol was prepared. Therefore, the evaluation criteria
presented here are conceptual in nature. These criteria are intended to
suggest a thought process which will facilitate an efficient and focused
review of permit conditions related to corrective action. As EPA's
policies and requirements in this area evolve, these evaluation criteria
may be revised accordingly.
The criteria utilize the results of the RCRA Facility Assessment
(RFA) as the point of departure for the permit evaluation process. For
purposes of this process, it is assumed that an RFA has been performed
for the facility, and that it is technically sound and well documented
in the administrative record. The major objectives of the permit
evaluation are:
o To evaluate the responsiveness of the permit conditions to the
RFA conclusions and recommendations;
o To evaluate how clearly and precisely the permit conditions
place enforceable requirements on the permittee; and
o To evaluate the completeness of documentation in the adminis-
trative record regarding the permit conditions.
For ease of evaluating it is recommended that the review be con-
ducted in two steps; The first step is a comparison of the scope of the
permit conditions with the RFA conclusions and recommendations to
determine if the major concerns identified in the RFA have been
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PL f REQUIREMENT
EVALUATION CRITL
REVIEWER FINDINGS/COMML.
RCRA Facility Investiga-
tion plans - groundwater
1. Hydrogeolog ic
characterization plan.
If a hydrogeologic characterization plan is
required as part of the RCRA Facility Investi-
gation, it should provide the following:
o Description of hydrogeologic properties (e.g.,
depth, thickness, hydraulic conductivity,
lithology, etc.) of a I I hydrogeologic units of
concern.
o Description of aquifers of concern (e.g.,
depth, vertical and horizontal flow com-
ponents, water level contour maps, areas of
recharge and discharge, etc.), including a
description of manmade influences, and
natural seasonal and diurnal influences.
2. Groundwater monitoring
plan.
a groundwater monitoring plan is required as
•t of the remedial investigation, it must include
If
part
the fo I lowing:
to
I
vo
o Numbers and locations of all proposed
background and downgradient wells, with a
demonstration of the adequacy of well
p I acement .
o Description of each proposed well (e.g., size,
depth, screening intervals, materials of
construction, etc.).
o Description of proposed well
completion procedures.
development and
3. Sampling
plan.
and analysis
If groundwater monitoring is required as part of
the RFI plan, a sampling and analysis plan must be
required, to include the following:
o Proposed sampling procedures (e.g., well
i evacuation procedure, sample withdrawal
procedures, etc. )
o Proposed frequency of sampling and number of
samples to be obtained during each sampling
eye le.
o Proposed sample handling and preservation
procedures, including chain of custody
procedures.
o Proposed laboratory analytical techniques,
including QA/QC procedures.
o Proposed list of parameters selected for
analysis and rationale for their selection.
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PE,
REQUIREMENT
EVALUATION CRITEI
REVIEWER FINDINGS/COMMEI.
RCRA Facility Investi-
gation plans -
introduct ion.
Two general approaches may be taken in requiring
permittees to perform RCRA Facility Investigations.
The permittee can be required to prepare a proposed
RFI plan and submit it to the regulatory authority,
or the permit conditions may specify the RFI plan.
The specific elements of the plan will vary on a
case-by-case basis depending on the objectives of
the investigation. For example, if the sufficient
nydrogeologic data is available at the time the RFA
is performed, it may not be necessary to require
any additional hydrogen logic assessment studies.
However, if such studies are necessary, there are
certain types of information which should be
included in the hydrogeologic assessment plan.
In many cases the submission of a Release Charac-
terization Plan (RCP) is necessary. In such cases,
the permit will contain specific conditions aimed
at characterizing releases.
The following criteria identify the minimum types
of information which must be included in permit
conditions defining RCRA Facility Investigation
plan requirements for each environmental medium.
I
I—•
o
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PL
REQUIREMENT
EVALUATION CRITE,
REVIEWER FINDINGS/COMME.
Objectives of RCRA
Facility Investigations.
Technical Soundness
The objectives of remedial investigations to be
conducted must be clearly described in the permit
documentation. These objectives and the specific
types of investigations required depend on the
degree to which conclusions could be drawn in the
RFA. In general, there are five levels of detail
in conclusions which result from an RFA, depending
on the quality of information available at the time
of the assessment:
o Inability to arrive at any conclusion regard-
ing releases: In this case, no data are
available, and no conclusion can be reached.
Permit conditions will focus on monitoring
the various media to obtain evidence regard-
ing releases. In some cases it will be
necessary to sample the unit (e.g., landfill)
first to characterize its contents and to
define the hazardous constituents of concern.
o Determination that a release is "likely": In
this case, information was too sparse to
enable a positive determination that a
release has actually occurred. Permit con-
ditions, of necessity, must include require-
ments to obtain the data needed to make a
positive determination.
o Determination (either through qur.;.c i ta t i ve
environmental data or qualitative evidence
such as vegetative stress) that a release has
occurred, but no determination regarding the
extent of the release: In this case, permit
conditions will probably be directed toward
obtaining new information to quantify the
potential extent and nature of the release.
o Determination that a release has occurred,
with limited data to enable a general charac-
terization of the extent of contamination:
In this case, permit conditions would
probably be directed toward obtaining
specific quantitative data to fully charac-
terize the nature and extent of the release
and to provide information required to define
the remedial alternatives to be considered.
o Determination that a release has occurred,
with enough data to define the extent of con-
tamination and design corrective measures:
In this case, permit conditions would
possibly not require additional remedial
investigations, but would be directed
toward the design of corrective measures.
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f REQUIREMENT
EVALUATION CRITL
REVIEWER FINDINGS/COMML
Interim corrective action
requi rements.
Technical Soundness
Permit conditions must include interim corrective
action requirements for all units and/or areas of
facility where such measures are recommended in the
RFA or any enforcement action. If there are units
or areas for which interim steps are recommended,
but for which no such permit conditions are
provided, the permit documentation must provide an
explanat ion.
The permit documentation must show that each
interim corrective action requirement is appro-
priate to reduce the threat to human health and the
environment by indicating the factors considered in
developing the requirement. Factors considered
i ncIude:
o Actual or potential exposure to hazardous
wastes or constituents by nearby populations,
animals, or food chain;
o Actual or potential contamination of drinking
water supplies or sensitive ecosystems;
o High levels of hazardous wastes or constitu-
ents in soils largely at or near surface,
that may migrate;
o Weather conditions that may cause hazardous
wastes or constituents to migrate or be
re I eased;
o Potential for exposure to hazardous wastes or
constituents as a result of an accident, fire,
explosion or failure of a container or handl-
ing system;
o Potential for exposure to hazardc-.o wastes or
constituents as a result of a release or
potential for release from a transportation-
related source;
o Other situations or factors which may pose
threats to human health or the environment.
Enforceab i I i t.v
Interim corrective action requirements must be
clearly defined and include specific date(s) for
compliance.
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PE
REQUIREMENT
EVALUATION CRITE.
REVIEWER FINDINGS/COMME-.
Definitions of
of progress.
milestones Technical Soundness
The permit conditions define discrete milestones
for implementing the corrective action requirements
of the permit. The milestones must identify
specific actions to be taken, and define any
results which are to be obtained. While the mile-
stones will be tailored to individual facilities
and units, examples of milestones which might be
included in permit conditions include:
o Initiation of interim corrective action
requ i rements
o Preparation and submittal of proposed
hydrologic, geohydrologic assessment plans
o Preparation and submittal of proposed
monitoring plans
o Installation of sampling/monitoring equipment
o Submittal of sampling monitoring results (may
be on a periodic basis)
o Submittal of proposed corrective measures
The RFI guidance may combine some of these mile-
stones (i.e., "phased" monitoring approach).
Enforceab iIi ty
Milestones must include specific compliance
measures and date(s). Reporting requirements must
be included for each milestone unless they are
clearly inappropriate.
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PEi
REQUIREMENT
Requirements for sub-
mitting RCRA Facility
Investigation (RFI) plans
for approvaI.
EVALUAT ION CR I TE(.
REVIEWER FINPINGS/COMMEN
Technical Soundness
The permit conditions must require that proposed
RCRA Facility Investigation plans developed by the
applicant be submitted to the regulatory authority
for approval. If the RFI plan is developed in
discrete phases (e.g., geohydrologic characteriza-
tion plan, well installation plan, sampling and
analysis plan), the permit conditions must identify
distinct milestones at which portions of the plan
are to be submitted to the resulting authority for
approval. In those rare cases where a RFI plan is
well defined by permit conditions, this evaluation
is not necessary as part of the permit quality
review.
EnforceabiIi ty
The requirements for submitting remedial
gation plan specify date(s) for submittal
as elements to be included in the plan.
investi-
, as we I I
I
»—'
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PL
REQUIREMENT
EVALUATION CRITt
REVIEWER FINDINGS/COMML
Identification of SWMU; or
areas of facility subject
to permit conditions
I
I—'
Ln
Technical Soundness
The permit administrative record must clearly and
consistently specify the SWMUs or areas of the
facility for which corrective action permit
conditions are required. The rationale for
selecting the geographic coverage of the permit
conditions must be provided in the permit
documentation. There are several approaches which
might be taken in defining the geographic area to
be covered:
o SWMU specific requirements: If requirements
apply to individual units, the nomenclature
used to identify these units must be specific
and consistent with the nomenclature in the
permit documentation (e.g., "Unit #3 -
Construction Landfill"). The permit docu-
mentation must provide the rationale for
recommending corrective actions for each unit.
o Multiple SWMU study area requirements: If
corrective action permit conditions are
applied to a block of units, the permit and
documentation should identify the individual
SWMUs within each study area. The permit
documentation should provide the rationale
for combining the units into one study area
(e.g., "close proximity of units; similar
wastes managed in units and RFA could not
distinguish between sources of contamina-
tion").
o Facility-wide requirements: If the permit
conditions are applied on a facility-wide
basis, or for major areas within the
facility, the boundaries of the facility
should be specified. The permit documenta-
tion should provide the rationale for the
facility-wide approach (e.g., "groundwater
contamination was found in monitoring wells
across the facility").
EnforceabiIi ty
Nomenclature to identify individual SWMUs should be
consistent in the permit and permit documentation.
In certain cases, the exact location of the unit
within the facility may not be known; in this case,
identification of the unit covered by permit
conditions must be especially clear.
Permit conditions applied to areas of the facility
must reasonably define the geographic area covered
by the conditions to minimize ambiguity.
-------
PE,
REQUIREMENT
EVALUATION CRITEi
REVIEWER FINDINGS/COMMEU
Responsiveness of permit
conditions to RFA
cone I us ions and
recommendat ions.
Technical Soundness
Every SWMU or area of facility for which further
action is recommended in the RFA must be covered
with corrective action permit conditions. If no
permit conditions are provided for SWMU, or areas
for which the RFA recommends further action, the
permit documentation must provide an explanation.
For each SWMU or area of the facility for which
further action is recommended in the RFA, all
environmental media of concern considered in the
recommendations must be addressed in the permit
conditions. If particular environmental media are
not addressed, the permit documentation must
provide an explanation.
For each SWMU or area of the facility for which
further action is recommended, all specific recom-
mendations (e.g., "groundwater investigations
should include analyzing for X contaminant") must
be reflected in the permit conditions. Permit
conditions will vary in level of detail since the
release characterization plan must provide flexi-
bility for evolving investigations. If particular
recommendations are not addressed, the permit
documentation must provide an explanation.
Enforceab iIi ty
The types of corrective actions specified in the
permit conditions must be consistent with the
recommendations in the permit documentation.
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