United States Office of Solid Waste September A 988
Environmental Protection and Emergency Besponse^v
Agency Washington, DC 20460
Office Of Solid Waste
&EPA RCRA Permit Quality
Protocol (Draft)
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Repository Material
Permanent Collection
RCRA PERMIT QUALITY PROTOCOL
[DRAFT]
US EPA
Headquarters and Chemical Libraries
EPA West Bldg Room 3340
Maiicode 3404T
1301 Constitution Ave NW
Washington DC 20004
aoa-566-0556
U.S. ENVIRONMENTAL PROTECTION AGENCY
SEPTEMBER 1988
Hy
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ACKNOWLEDGEMENTS
This RCRA Permit Quality Protocol was compiled by A.T. Kearney, Inc.
under contract to EPA. The EPA Project Officer was Kenneth Shuster.
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RCRA PERMIT QUALITY PROTOCOL
TABLE OF CONTENTS
I. INTRODUCTION 1
PART 1. BACKGROUND INFORMATION 1-1
PART 2. ADMINISTRATIVE RECORD/PROCEDURAL REQUIREMENTS 2-1
PART 3. PERMIT CHECKLIST/CONDITIONS 3-1
PART 4. PERMIT QUALITY EVALUATION CRITERIA 4-1
RCRA PERMIT QUALITY PROTOCOL SUPPORTING DOCUMENTATION
A. CHECKLIST FOR RCRA RESEARCH, DEVELOPMENT
AND DEMONSTRATION PERMITS A-l
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PART 1
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I. INTRODUCTION
PURPOSE OF GUIDANCE. The purpose of the Protocol is to provide
a format and guidance for evaluating the quality of EPA and
State hazardous waste management facility permits, and
supporting documentation or Administrative Records, issued under
authority of Subtitle C of the Resource Conservation and
Recovery Act of 1976 (RCRA), as amended. The Protocol is also
designed to be used by Permit Writers in drafting, as well as
reviewing, permits. It may also be used by Permit Writers in
reviewing permit (Part B) applications.
The Protocol addresses the evaluation of permit quality in terms
of: completeness/omissions; adequacy of the supporting
documentation or Administrative Record; and for some permit
conditions, technical soundness/defensibility, and
enforceability. It does not provide detailed "how to"
methodology for technical reviews. Instead, it merely indicates
the types of considerations and factors that need to be
addressed and provides references that describe the "how to" for
technical reviews. Thus, it enables a determination of
inadequacy if the pertinent factors are not addressed. But if
they are addressed, it provides references that may be pursued
in order to perform the necessary calculations, etc. to
determine technical adequacy. In other words, the Protocol is
useful in determining omissions and inadequacy but, for some
permit conditions, further references may be needed to fully
determine technical adequacy.
CONTENT OF GUIDANCE. The Protocol is divided into the following
parts:
Part 1. Facility Background Information
Part 2. Administrative Record/Procedural Requirements
Part 3. Checklist of Permit Conditions
Part 4. Permit Condition Evaluation Guidance
Appendix A. Checklist for RCRA RD&D Permit Conditions.
RELATIONSHIP OF PERMIT QUALITY PROTOCOL TO MODEL PERMIT. The
RCRA Permit Quality Protocol is meant to be used in conjunction
with the Model RCRA Permit for Hazardous Waste Management
Facilities for drafting and reviewing permits.
GENERAL INSTRUCTIONS. Effective use of the Protocol requires a
working knowledge of RCRA and the RCRA regulations (40 CFR Parts
124, 260-266, 268, 270, and 271). Familiarity with Agency
guidances and policies and knowledge of technical aspects is
but not necessary for at least completeness reviews.
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The structure of the Protocol lends itself to a multi-level
review of a permit. The reviewer can: 1) use Part 2 to review
the Administrative Record for completeness and determine if the
procedural requirements were followed; 2) use Part 3 to
determine if the permit contains the required conditions (i.e.,
is complete) ; 3) use Part 4 to determine if the the permit
conditions have inadequacies in terms of technical soundness and
enforceability; and 4) use Part 4 to determine technical
soundness by utilizing the references cited for guidance in how
to do detailed technical reviews. Field testing of the Protocol
has shown that use of the Part 3 checklist of permit conditions
results in a rapid, preliminary indication of the quality of a
permit. Also, the further the level of review of permits, the
fewer the number of permits that can be reviewed in a given
time-frame. This suggests different strategies to auditing
permits, with a tradeoff in the number of permits that can be
reviewed versus the depth of review.
Field testing of the Protocol showed that audit of a storage
permit using only Parts 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 of a storage permit
(using Parts 1-4 without further reviews using the references
listed in Part 4) requires about four hours. Full audit of a
land disposal permit requires eight hours or more.
In auditing a number of' permits, an effective use of the
protocol might 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.
Following is a brief description of each part of the Protocol.
PART 1 - FACILITY BACKGROUND INFORMATION. This is simply a
short form for recording general information on the facility and
wastes handled. Most of this information can be obtained from:
1) the applicant's Part A application; 2) the General Facility
Description in the applicant's Part B application; and 3) the
Fact Sheet or Statement of Basis associated with the permit.
PART 2 - ADMINISTRATIVE RECORD/PROCEDURAL REQUIREMENTS. The
Administrative Record is a very important part of permit
development and defensibility since it is the official
documentation explaining the basis of permit conditions and the
only supporting evidence that EPA can use during appeals of
permit decisions. This part of the Protocol discusses the
content of the Administrative Record. It also discusses the
procedural aspects of permitting (e.g., proper public notice and
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"comment review) that can be grounds for permit rejection if not
properly followed. Finally, it provides a checklist for
evaluating the completeness of the Administrative Record,
"including procedural aspects. [Note: States may have different
rules governing permit procedures and the content and use of
Administrative Records in supporting and defending their
permits.]
PART 3 - CHECKLIST OF PERMIT CONDITIONS. This Checklist of
permit conditions mirrors the Model Permit conditions, and
includes a citation to each condition in the Model. It is to be
used to determine the completeness of a permit. If a required.
condition is not found in the permit, the reviewer may need to
check the permit file or Administrative Record prior to
recording that the condition is missing. An explanation must be
provided for any requirement intentionally waived or deleted
from the permit. Often, the explanation will be provided in the
Fact Sheet.
In completing the checklist, it is suggested that the reviewer
mark each item as: provided (denoted by Y), not provided
(denoted as N), or as not applicable (denoted as NA); and
indicate the location of the item in the permit.
PART 4 - PERMIT CONDITION EVALUATION GUIDANCE. This is a
checklist, for a select number of permit conditions in the Model
Permit, that gives guidance on how to evaluate the condition for
technical soundness and enforceability by listing information
and types of calculations that need to be included in the permit
or Administrative Record. This part also lists references that
may be pursued if a detailed technical review (e.g., a check on
the approach or calculations) is desired. In the checklist,
reference titles are abbreviated. A list of these references is
also included in Part 4.
APPENDIX A - CHECKLIST FOR RCRA RD&D PERMIT CONDITIONS.
Research, Development, and Demonstration Permits are issued
under authority of the Hazardous and Solid Waste Amendments of
1984 (HSWA), Section 3005(g) of RCRA. This authority was
codified in 40 CFR 270.65. This appendix has not been revised
from the previous Protocol (August 1986).
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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
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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.
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RCRA PERMIT QUALITY PROTOCOL
BACKGROUND INFORMATION
- Continued -
Type of permit: Draft Final
Issuing Agency: EPA Region State Joint
Reviewer:
Date:
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PART 2
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RCRA PERMIT QUALITY PROTOCOL
PART 2. ADMINISTRATIVE RECORD/PROCEDURAL REQUIREMENTS
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September 1988
RCRA PERMIT QUALITY PROTOCOL
ADMINISTRATIVE RECORD/
PROCEDURAL REQUIREMENTS
1. INTRODUCTION
All permitting actions, including permit denials, must be based on an
Administrative Record, which is the official document explaining the
basis for the conditions in a permit or for the denial. The timing and
content of Administrative Records are described below.
For a number of facilities, EPA and the States will be engaged in joint
permitting activities, as a result of the Hazardous and Solid Waste
Amendments of 1984. When a permit is issued jointly, EPA must establish
an Administrative Record supporting the EPA portions of the permit. The
general content of this Administrative Record is the same as when EPA is
the sole permit-issuing authority. It is not necessary, however, for EPA
to maintain an Administrative Record documenting the State portions of
the permit. As a practical matter and for the benefit of the public,
however, it is recommended that one combined Administrative Record be
made available during the public comment period.
2. RATIONALE FOR ADMINISTRATIVE RECORDS
There are three reasons for establishing Administrative Records for RCRA
permitting actions. First, EPA's regulations specify that permits shall
be based on Administrative Records (40 CFR 124.6(e) and 124.9). Second,
during the public comment period, the Administrative Record makes
available to the public all information on which EPA based its decision
to issue, deny, modify, or terminate a permit. Third, the Administrative
Record is the only supporting evidence that EPA can bring to court during
appeals of a permitting decision.
3. TIMING FOR ESTABLISHING ADMINISTRATIVE RECORDS
The Administrative Record should be started as soon as the permitting
action is begun. For permits for existing facilities, the record should
start with the 3010 Notification and/or Part A of the RCRA permit
application. If an application is submitted voluntarily, the
Administrative Record should be started as soon as the permit application
is received.
For a permit termination or a permit revocation and reissuance, the
Administrative Record is started as soon as the Agency decides to
terminate or to revoke and reissue. Relevant information (e.g., citizen
complaints) obtained or developed before this point in time must be
included in the record. Note that documentation supporting a permit
termination or revocation and reissuance can be placed either in a new
Administrative Record created for the new permitting action or in the
Administrative Record supporting the existing permit, in accordance with
EPA Regional policy.
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September 1988
4. ADMINISTRATIVE RECORD LOGISTICS
The Administrative Record is a file containing all applicable information
relevant to the permitting action. Because each EPA Regional Office has
its own policies and procedures for establishing and maintaining files,
the following guidelines contain the minimum recommended procedures for
creating Administrative Records and describe the minimum recommended
content. [For example, all incoming items may go to a central receiving
person(s) who places the original in the record and sends copies to the
Permit Writer and other appropriate persons; or each Permit Writer may be
responsible for submitting incoming items in the record.]
a. Procedures
o Each Administrative Record should contain an index identifying
each document in the record. The index serves a quality
control function, as well as a record of the contents of the
file. Each document in the record should be numbered or
lettered sequentially. The index should include the document
title, the document number/letter, the document location (which
file volume), and the document date. The document dates should
be identified consistently using either the typed date on the
document, the date received, etc.
o Administrative Records should be placed in one central
location. Access to these files must be controlled. For
example, sign-out cards can be used to identify persons using
the record. Permit Writers can maintain duplicate files at
their desks for their own use. Note that placing the
Administrative Record in a central file assures there is a
complete file if Permit Writers change during the
review/issuance process.
o The name of the treatment, storage, and disposal facility and
the facility's EPA I.D. number should be placed on each file
and document in the Administrative Record.
o Documents should be placed in the Administrative Record
chronologically within each subject area (see Section 5 which
has the checklist for suggested subject categories).
o A complete, integrated, current version of the Part B
containing all revisions and supplements submitted by the
applicant, including responses to Notices of Deficiencies, must
be placed in the Administrative Record. It is preferred to
have an integrated copy rather than the original Part B in the
file followed by sets of revised pages. Old versions may be
maintained in the Permit Writer's working files and should be
noted as obsolete.
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September 1988
o Similarly, the current copy of the Part A must be placed in the
Administrative Record. Old versions of the Part A may be kept
in the Permit Writer's working files and noted as obsolete.
b. General Content of the Administrative Record
o A copy of all letters and pertinent memoranda, preferably
showing concurrences, must be placed in the file. The yellow
tissue copy, if used, is sufficient; make sure it is date
stamped.
o All relevant correspondence received from the applicant must be
placed in the file. The date of receipt by the Agency must be
stamped on the correspondence.
o The Permit Writer should include notes from all internal
permit-related meetings and telephone conversations resulting
in decisions affecting the final permit.
o All correspondence, memoranda, telephone notes, or meeting
notes which document agreements with the applicant and/or the
basis for permit conditions must be in the record.
o Documents from State files (e.g., inspection reports) that were
used during permit development must be in the record.
o Similarly, if a permit condition beyond RCRA has been
established by the State agency, then the basis for it should
be documented in the State file. For example, State-required
ground-water monitoring parameters that are more stringent than
RCRA parameters should be explained in the file.
o Calculations verifying information in the permit application
should be included in the file. However, it is not necessary
for the Permit Writer to place other working papers he has
developed in the file unless those papers are the only
documentation supporting a permit condition.
o References used during technical evaluation of the permit
application and development of the permit should be identified
in the file. Photocopies of relevant pages should be included
in the file as well and organized in a way to facilitate cross-
walking with the permit condition(s) they support.
5. SPECIFIC CONTENT OF THE ADMINISTRATIVE RECORD
On the following pages is a listing of the information that should be
included in Administrative Records. All items may not be applicable for
each permit. The listing consists of general items that apply to all
permits and other sections that apply only to specific types of permits.
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September
The Permit Writer should use this information as a checklist in helping
to assure that Administrative Records are complete.
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September 1988
CHECKLIST TO INVENTORY ADMINISTRATIVE RECORDS/
PROCEDURAL REQUIREMENTS FOR RCRA PERMIT ACTIONS
GENERAL ITEMS FOR ALL PERMITS
Index
Notification Form 3010
Permit application
Part A
Complete, integrated, current version of the Part B containing
all revisions and supplements submitted by the applicant,
including responses to Notices of Deficiencies and any required
certifications of compliance with RCRA requirements
Support data, technical reports, and all other attachments
submitted by the applicant
Results of the Permit Writer(s) completeness and technical
evaluation of the permit application
Completeness checklist(s)
Documentation that completeness deficiencies were addressed
(e.g., additional completeness checklists)
Technical evaluation checklists
Documentation that additional technical concerns were addressed
(e.g., additional technical evaluation checklists)
Notes and calculations (including technical exhibits)
Documentation that the Permit Writer reviewed and accepted
completeness/technical review done by contractors or State
Permit Writers
Other references
Inspection reports
Pre-permit site inspection report(s) to verify application
information
Interim Status Standards inspection reports
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September 1988
State inspection reports that support the development of permit
conditions
Correspondence
Part B call-in letter (yellow tissue copy)
Notices of Deficiencies (yellow tissue copies)
Other requests for additional information (yellow tissue
copies)
Other correspondence from EPA (yellow tissue copies)
Correspondence from the applicant, including transmittal
letters
Post Office return-receipt cards or certified mail receipts
Correspondence between EPA and the State
Correspondence with other EPA program offices
Enforcement
CERCLA
Water
Other
Correspondence with other Federal or State agencies (yellow
tissue copies)
Internal notes and memoranda
Telephone conversation notes (handwritten or typed)
Meeting notes
Decision memoranda (e.g., denial of waiver request)
Where applicable, materials relating to determinations for
conformance with other Acts (i.e., Coastal Zone Management Act,
Clean Water Act, Fish and Wildlife Coordination Act, applicable
State and local laws and regulations).
Consent decrees
Federal Register notice to grant or deny a delisting petition
Reviews of Exposure Information Reports (EIR)
Draft permit (or notice of intent to deny or to terminate)
Statement of basis or fact sheet and supporting documents
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September 1988
Documentation of public participation process
Public participation plan, if applicable
Public notice(s)
Minimum of 45 days for public comment
Minimum of 30 days notice of public hearing(s)
Notarized proof of publication of public notice(s) from each
newspaper in which notice was placed and from each radio
station which broadcast the notice
Comments received during public comment period and public
hearing(s)
Tape or transcript of public hearing(s)
Summary of comments received
Response to comments received
Identification of draft permit provisions changed in the final
permit in response to comments
Explanation of basis of changes
Brief description and response to significant comments with
documents cited in response to comments (including new
materials supplied during the public comment period and/or new
materials added by the Permit Writer)
Final permit
Documentation of review and approval of the permit by Regional
Counsel
INCINERATOR PERMITS
Trial burn plan (should be in Part B)
Trial burn results
Review of trial burn results by the Permit Writer or documentation
that the Permit Writer reviewed and accepted reviews performed by
contractors or State Permit Writers
Correspondence between EPA and the State regarding establishment of
incineration permit conditions
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September
Documentation supporting permit conditions established by the State
(e.g., POHCs)
GROUND-WATER MONITORING REPORTS
Ground-water characterization report(s)
Site characterization report(s)
Comprehensive ground-water monitoring evaluation report or other
site inspection report(s)
HSWA CORRECTIVE ACTION
Solid waste management unit (SWMU) information request (yellow
tissue copy)
Applicant's SWMU response report
RCRA Facility Assessment (RFA) conducted by the Permit Writer or by
a contractor
Preliminary Review
Visual Site Inspection Report
Sampling Plan
Final RFA
Documentation that the Permit Writer reviewed and accepted a
contractor's RFA
RFI Work Plan with Permit Writer approval documents
Final RCRA Facility Investigation (RFI) Report with Permit Writer
approval documents
RCRA Section 3008(h) orders
CERCLA administrative orders
Documentation of CERCLA activities at the site
Copy of CERCLA file or
Review of periodic reports on on-going work
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September 1988
Corrective measures study plan and Permit Writer approval documents
Corrective measures study report and Permit Writer approval
documents
Periodic progress reports
VARIANCES /WAIVERS
[Note: For each variance or waiver granted or denied, the Administrative
Record must document that the Permit Writer reviewed and accepted or
rejected the permit applicant's demonstration, including any additional
items used in the decision.]
_ Demonstration that security requirements are not necessary [40 CFR
264.14(a)]
_ Demonstration that washout of existing surface impoundments , waste
piles, landfill, and land treatment units by a 100-year flood will
not cause adverse effects on human health or the environment [40 CFR
Demonstration that communications or emergency equipment is not
required [40 CFR 264.32]
Demonstration that aisle space is not required [40 CFR 264.35]
Demonstration that additional time is needed for closure activities
[40 CFR 264.113]
Demonstration that an adjusted level of liability coverage is
warranted [40 CFR 264. 147 (c) and (d) ]
Demonstration that surface impoundment single liner requirement is
not necessary [40 CFR 264.221(b)]
Demonstration that surface impoundment double liner/leachate
collection system is not necessary [40 CFR 264.221(d)]
Waiver from surface impoundment double liner/leachate collection
requirement for certain monofills [40 CFR 264. 221 (e)]
Demonstration that waste pile liner/leachate collection system is
not necessary [40 CFR 264.251(b)]
Demonstration that landfill multiple liner/leachate collection
system is not necessary [40 CFR 264.301(d)]
Waiver from landfill liner/leachate collection requirements for
certain monofills [40 CFR 264.301(e)]
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September 1983d
Exemption from all requirements for incinerators (except waste
analysis and closure) or some requirements because of the type of
hazardous waste handled [40 CFR 264.340(b) or (c)]
Demonstration there is good cause for shortening the new incinerator
shakedown phase to less than 720 hours or for granting an extension
beyond 720 hours [40 CFR 264.344(c)(1) and 270.62(a)]
Demonstration that shortening the post-closure care period will
still protect human health and the environment or that extending the
post-closure care period from 30 years is necessary to protect human
health and the environment [40 CFR 264.117(a)]
Demonstration that basis for exemptions from ground-water monitoring
requirements under 40 CFR 264.90(b) or 264.90(c) are satisfied
Demonstration that alternate concentration limits (ACLs) will not
pose a substantial present or potential hazard to human health or
the environment [40 CFR 264.94(b)]
Documentation for granting an extension from the effective date of
the land disposal ban [40 CFR 268.5]
Documentation for granting an exemption from the landfill disposal
ban [40 CFR 268.6]
MAJOR PERMIT MODIFICATIONS/REVOCATION AND REISSUANCE
Original permit
Draft revised permit
Statement of basis or fact sheet
New or updated permit application, if requested by EPA
Additional information requested by EPA
Correspondence
Permit application update call-in (yellow tissue copy)
Request for additional information (yellow tissue copy)
Other relevant correspondence
Documentation/explanation of basis of permit modification
Citation of appropriate provisions of 40 CFR 270.41
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September 1988
Permittee request for, or agreement to, revocation and
reissuance for reasons cited in 40 CFR 270.41(a)
Public notice
Minimum of 45 days for public comment
Minimum of 30 days notice for public hearing(s)
For modifications involving selection of remedies for corrective
action, all documents supporting the original permitting action
MINOR PERMIT MODIFICATIONS
Documentation of reasons for minor modification(s)
Documentation of Permittee's consent to minor modification(s)
Reviewer:
Date:
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PART 3
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RCRA PERMIT QUALITY PROTOCOL
PART 3. PERMIT CHECKLIST/CONDITIONS
Following is a checklist of permit conditions to facilitate completeness
reviews of Permits.
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I. GENERAL PERMIT CONDITIONS
Facility Name
ID No.
RCRA PERMIT CHECKLIST/CONDITIONS
Effect of Permit [55270.4 and
270.30(g)]
Permit Actions [55270. 30(b) and (f) and
270.
Severablllty [5124. 16(a)]
Definitions
Duties and Requirements
Duty to comply [5270. 30(a)]
Duty to reapply [55270. 30(b) and
270.10(h)]
Permit expiration [5270.51]
Need to halt or reduce activity not a
defense [5270. 30(c)]
Duty to mitigate [5270. 30(d)]
Proper operation and maintenance
(S270.30(e)]
Model Permit
Condition ID
I.A.
I.E.(1.2)
I.C.
I.D.
I.E.
I.E.I
I.E.2
I.E.3
I.E.A
I.E.5
I.E.6
Actual Permit
Condition ID
Comments
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Model Permit Actual Permit
Condition ID Condition ID Comments
Duty to provide information [§§270.30(h)
and 264.74(a)J I .E. 7
Inspection and entry ($270.30(1)] I. E.8(a.b.c.d)
Monitoring and records [$$270.30(j) and
264.74(b) I.E.9(a.b,c)
Reporting planned changes [$270.30(1)(1) ] I.E.10
Reporting anticipated noncompllance
[$270.30(1)(2)] I.E.11
Certification of construction or
modification [{270.30(1)(2)] I.E.12(a.b)
Transfer of permits [{{270.30(1)(3),
264.12(c)] I.E.13
Twenty-four hour reporting [$270.30(1)(6)] I.E.14(a.b.c)
Other noncompllance [$270.30(1)(10)] I.E.15
Other information [$270.30(1)(11) ] I.E.16
Signatory Requirement [5$270.11 and
270.30(k)] I.F.
Reports, Notifications, and Submissions
to the Regional Administrator I.G.
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Model Permit Actual Permit
Condition ID Condition ID Comments
Confidential Information [§270.12] I.H.
Documents to be Submitted Prior to
Operation [$$270.32 and 270*.33] I.I.
Documents to be Maintained at
Facility Site I. J
Waste analysis plan [5264.13(b)) I.J.I
Inspection schedule(s) [$264.15(b)] I.J.2
Personnel training documents/records
[$264.16(d)J I.J.3
Contingency plan [526*.53(a)] I. J . 4
Operating record [$264.73] I.J.5
Closure plan [$264.112(a)] I.J.6
Post-closure plan [$264.118(a)] I.J.7
Annually adjusted closure cost estimate/
post-closure cost estimate
[$$264.142(d) and 264.144(d)] I.J.8
Other documents I.J.9
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II. GENERAL FACILITY CONDITIONS
Design and Operation of Facility
[5264.31]
Required Notices [J264.12]
General Waste Analysis [5264.13]
Security [$264.14]
General Inspection Requirements
[S264.15]
Personnel Training [$264.16]
Facility Name
ID No.
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
II.A.
II.B.(1.2)
II.C.
II.D.
II.E.
II. F.
Special Provisions for Ignltablg.
Reactive, or Incompatible Waste [5264.17] II.C.
Location Standards [§264.18(a)]
Preparedness and Prevention
Required equipment [$264.32]
Testing and maintenance of equipment
[5264.33]
II.H.
II.I.
II.I.I
Actual Permit
Condition ID
Comments
II.I.2
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Model Permit Actual Permit
Condition ID Condition ID Comments
Access to communication or alarm system
[5264.34] II.I.3
Required aisle space [8264.35] II.I.it
Arrangements with local authorities
[5264.37] II.I.5
Contingency Plan II. J.
Implementation of plan [§264.51] II.J.1
Copies of plan [5264.53] II.J.2
Amendments to plan [§264.54] II.J.3
Emergency Coordinator [5264.55] II.J.A
Manifest System [$$264.71 and 264.72] U.K.
Recordkeeping and Reporting II.L.
Operating record [S264.73] II.L.I
Blennla-l report 85264.75] ILL.2
General Closure Requirements II.M.
Performance standard [$264.111] II.M.1
Amendment to closure plan [$264.112(c)] II.M.2
Notification of closure [$264.112(d)] II.M.3
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Model Permit Actual Permit
Condition ID Condition ID Comments
Time allowed for closure [5264.113] II.M.4
Disposal or decontamination of
equipment, structures, and soils
[$264.114] II.M.5
Certification of closure [$264.115] II.M.6
Survey plat [{264.116] II.M.7
General Post-Closure Requirements II.N.
Post-closure care period
[S264.117(a)(l)] II.N.I
Post-closure security [5264.117(b)] II.N.2
Amendment to post-closure plan
[5264.118(4)1 U.K.3
Post-closure notices [5264.119] II.N.4(a.b.c)
Certification of completion of post-
closure care [$264.120] II.N.5
Cost Estimate for Facility Closure [and
Post-Closure] [55264.142 and 264.144] II.0.(1,2.3.4)
Financial Assurance for Facility Closure
[and Post-Closure] ($5264.143 and 264.145] II.P.
Liability Requirements [5264.147] II.Q.
Incapacity of Owners or Operators.
Guarantors, or Financial Institutions
[5264.148] II.R.
3-6
-------
III. CONTAINERS
Facility Name
ID No.
RCRA PERMIT CHECKLIST/CONDITIONS
Module Highlights
Permitted and Prohibited
Waste Identification
Allowable wastes for storage
in containers
Prohibition from storing
wastes not identified in
Condition III.B.I
Model Permit
Condition ID
III.A.
III.B.
III.B.I
III.B.2
Actual Permit
Condition ID
Comments
Condition of Containers [J264.171] III.C.
Compatibility of Waste with Containers
[J264.172] III.D.
Management of Containers [S264.173] III.E.
Containment Systems [5264.1751 III.F.
Inspection Schedules and Procedures III.G.
[§264.174]
Recordkeeping [5264.731 III.H.
3-7
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Closure [§264.1781 III.I.
Special Container Provisions for
Ignitable or Reactive Wastes [$264.176] III.J.(1.2)
Special Container Provisions for
Incompatible Wastes ($264.177) III.K.(1.2.3)
Compliance Schedule III.L.
3-8
-------
JV. TANKS
Facility Name
ID No.
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Module Highlights
Permitted and Prohibited
Waste Indentification
IV.A.
IV.B.
Allowable wastes for storage
and/or treatment in each tank
Prohibition from storing or treating
wastes not identified in Condition
IV.B.I
IV.B.I
IV.B.2
Secondary Containment and Integrity
Asses sments
IV.C.
Existing tank system integrity assessment
[S264.191] IV.C.I
Design, construction, and operating plans
for tank systems maintaining a variance
from the requirements for secondary
containment [$264.193] IV.C.2
Design, construction, and operating plans
for secondary containment system
[§264.193
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Requirements for existing tank systems
pending Installation of secondary
containment [$264.193(1)] IV.C.4
a. Leak test for non-enterable underground
tanks IV.C.4(a)
b. Leak test for other than non-enterable
underground tanks IV.C.4(b)
c. Leak test for ancillary equipment IV.C.4(c)
d. Response to leaks or spills IV.C.4(d)
Operating Requirements IV.D.
Placing wastes In tanks that could
cause failure [1264.194(a)] IV.D.I
Prevention of spills and overflows
[J264.194(b)] IV.D.2
Response to Leaks and Spills
[J264.196(a-f)l IV.E.
Stop hazardous waste flow IV.E.1
Remove waste and accumulated precipitation IV.E.2
Contain visible releases IV.E.3
Close tank system or: IV.E.4
a. Remove waste and repair tank system IV.E.4(a)
3-10
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
b. Repair primary system IV.E.4(b)
c. Provide secondary containment for
underground components requiring repair IV.E.*(c)
d. Repair above-ground portions IV.E.4(d)
e. Provide secondary containment for
components not readily available for
visual Inspection IV.E.*(e)
f. New components must conform to
regulatory requirements IV.E.4(f)
Certification of major repairs IV.E.5
Inspection Schedules and Procedures IV.F.
Conduct Inspections according to the
approved schedule IV.F.1
Periodic Inspection of overfill controls
[$264.195(a>] IV.F.2
Dally Inspection requirements
[J264.195(b)] IV.F.3
1. Above-ground portions of the tank
system IV.F.3U)
2. Data gathered from monitoring and leak
detection equipment IV.F.3(b)
3-11
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
3. Construction materials and the area
immediately surrounding the externally
accessible portion of the tank systems
Including the secondary containment
system IV.F.3(c)
Cathodic protection system [$264.195(c) ] IV.F.4
Document compliance with the operating
record [J264.195(d)] IV.F.5
Recordkeeping and Reporting IV.G.
Report leak or spill within 24 hours
[$264.196(d)(l) or (2)] IV.G.I
Release report [$264.196(d)(3)] IV.0.2
(a,b,c,d,e)
Certification of major repairs
[$264.196(f)l IV.G.3
Certification for new tank systems
[$264.196(g>] IV.G.4
Tank integrity assessment [$264.191(a) ] IV.G.5
Leak tests and integrity tests
($264.193(1)] IV.G.6
Clean Closure and/or Closure
with Post-Closure Care [$264.197] IV.H.
3-12
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Clean closure (without post-closure
care requirements) [5264.197(a)] IV.H.I
Closure with waste in place (with
post-closure care requirements)
[J264.197(b) and (c)J IV.H.2
Special Tank Provisions for Ignitable
or Reactive Wastes IV.I.
Management plan [$264.198(a)] IV.I.I
Maintenance of protective distances
[J264.198(b)J IV.I.2
Special Tank Provisions for Incompatible
Wastes IV.J.
Required precautions [J264.199(a)] IV.J.I
Decontamination of tanks which previously
stored Incompatible wastes or materials
[$264.199(b)] IV.J.2
Compliance Schedule IV.K.
3-13
-------
Facility Name
ID No.
V. SURFACE IMPOUNDMENTS
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Module Highlights
V.A.
Permitted and Prohibited Waste
Identification
V.B.
Allowable wastes for storage,
treatment, or disposal In
surface impoundments
V.B.I
Prohibition from storing,
treating, or disposing wastes not
identified in Condition V.B.I
V.B.2
Design. Construction, and Operating
Requirements
V.C.
Liners and leachate collection
systems [1264.221(c)]
V.C.I
General design, construction and
operating practices [$264.221(d)]
V.C.2
Monofill design, construction and
operating practices [5264.221(e)]
V.C.3
Prevention of overtopping [$264.221(f)] V.C.
3-14
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Dike design, construction and
operating practices [{264.221(g)] V.C.5
Leak Control Procedures V.D.
Leak detection system monitoring V.D.I
Removal from service [{264.227(a)-(b)] V.D.2
Recertification of repaired surface
impoundments ({264.227(d)] V.D.3(a.b)
Closure of nonrepaired surface
Impoundments [{264.227(e)] V.D.4
Inspection Schedules and Procedures V.E.
Inspection schedule V.E.I
During construction [$264.226(a)] V. E. 2
Prior to start-up [{264.226(a)] V.E.3(a.b)
Prior to re-start [{264.226(c) ] V.E.4(a.b)
Recordkeeping and Reporting
[{264.227(b)(6)J V.F.
Closure and Post-Closure Care V.G.
Clean closure (without post-closure
care requirements) [{264 . 228(a)] V.G.I
Closure with waste in place (with post-
closure care requirements) (storage and
treatment impoundments)
[S264.228(b)-(c)J V.G.2
3-15
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Closure with waste in place (with post-
closure care requirements) (disposal
impoundments) [$264.228(b)] V.G.3
Surface Impoundment Retrofitting Plans
or Waiver Application Requirements V.H.
Retrofitting plans V.H.I
(a,b,c,d,e)
Waiver application plans V.H.2
Permit modification request V.H.3
Special Surface Impoundment Provisions
for Ignltable or Reactive Wastes
($264.229(b)J V.I.
Special Surface Impoundment Provisions
for Incompatible Wastes [$264.230] V.J.
Special Surface Impoundment Provisions
for Hazardous Wastes F020. F021. F022.
F023. F026 and F027 [$264.231] V.K.
Special Surface Impoundment
Provisions for Hazardous Wastes
Restricted from Surface Impoundment
Units [§$268.5 and 268.7] V.L.(1.2.3.4.
5,6,7,8)
Compliance Schedule V.M.
3-16
-------
Facility Name
ID No.
VI. WASTE PILES
Module Highlights
Permitted and Prohibited
Waste Identification
Allowable wastes for storage
or treatment In waste piles
Prohibition from storing or treating
wastes not Identified In Condition
VI.B.I
Design. Construction, and Operating
Requirements
Liners [$264.251(a)(1)]
Leachate control [$264.251(a)(2)]
Run-on control {$264.251(c)]
Run-off management [$264.251(d)]
Run-on/run-off collection [$264.251(e)]
Dust suppression [$264.251(f)]
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
VI.A.
VLB.
VI.B.I
VI.B.2
VI.C.
VI.C.I
VI.C.2
VI.C.3
VI.C.
VI.C.5
VI.C.6
Actual Permit
Condition ID
Comments
3-17
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Inspection Schedules and Procedures VI.D.
During and after construction
[5264.254(a)] VI.D.1
During operations and after storms
[5264.254(6)] VI.D.2
Recordkeeping [$264.73] VI.E.
Clean Closure and Post-Closure Care VI.F.
Clean closure (without post-closure
care requirements) [$264.258(a)] VI.F.1
Closure with waste in place (with
post-closure care requirements)
(5264.258(6) and (c)J VI.F.2
Groundwater. Surface Water, and
Subsurface Soil Monitoring Exemptions
[$J264.250(c) and 264.251(6)] VI.G.(1.2)
Special Waste Pile Provisions for
Ignltable or Reactive Waste
[$264.198(a)l VI.H.
Special Waste Pile Provisions for
Incompatible Wastes [§5264.257 and
264.17(b)] VI.I.(1.2.3)
Special Waste Pile Provisions for
Hazardous Waste F020. F021. F022.
F023, F026 and F027 [5264.259] VI.J.
3-18
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Special Waste Pile Provisions for
Hazardous Wastes Restricted from
Waste Pile Units [§§268.5, 268.7] VI.K.(1.2.3.
5,6,7)
Compliance Schedule VI.L.
3-19
-------
Facility Name
ID No.
VII(A). LAND TREATMENT OPERATIONS
Module Highlights
Permitted and Prohibited
Waste Identification
Allowable wastes for treatment in
the land treatment program
Prohibition from treating wastes
not identified in Condition
VII(A).B.I.
Treatment Program [$264.271(a)]
Design, Construction, and
Operating Requirements
Basic design requirements to enhance
waste degradation [J26A.273(a)]
Run-off minimization [1264.273(b)]
Run-on control [$264.273(c)]
Run-off management [$264.273(d)]
Run-on/run-off collection [5264.273(e)]
Dust suppression [$264.273(f)]
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
VII(A).A.
VIKA).B.
VIKA).B.I
VIKA).B.2
VIKA).C.
VIKA).D.
VIKA).D.I
VIKA) .D.2
VIKA).D.3
VIKA).D.4
VIKA).D.5
VIKA) .D.6
Actual Permit
Condition ID
Comments
3-20
-------
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Ur
ated Zone Sampling
and Monitoring [S264.278]
Inspection Schedules and
Procedures [S264.273(g) J
Periodic inspection of run-on/run-off
control
Closure procedures [$264.280]
Closure certification
Post-closure care procedures
Special Requirements for Food-Chain
Crop Protection [S264.276]
Food-chain protection in the
untreated surroundings
VIKA).E.(1.2.
3,4,5,6,7,8)
VII(A).F.
VIKA) .F.I
Periodic inspection of dust suppression
control VIKA) .F.2
Recordkeeping and Reporting [S264.279] VIKA) .G.
Closure and Post-Closure Care VIKA) .H.
VIKA) .H.Ka.
b,c,d,e,f,g,h)
VIKA).H.2
VIKA) .H.3
VIKA) .1.
VIKA) .I.Ka.b.
c,d,e)
Prevention of crop growth in the
treatment zone
Special Land Treatment Provisions
for Ignltable or Reactive Wastes
[§264.281]
VIKA) .1.2
VIKA) . J.
3-21
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Special Land Treatment Provisions for
Incompatible Wastes (S264.17(b)] VII(A).K.
Special Land Treatment Provisions
for Hazardous Wastes F020. F021, F022.
F023. F026 and F027 [$26'..283] VII(A) . L.
Special Land Treatment Provisions for
Hazardous Wastes Restricted from Land
Treatment Units [H268.5 and 268.7) VII(A).M.(1.2.
3,4,5)
Compliance Schedule VIKA) .N.
3-22
-------
Facility Name
ID No.
VII(B). LAND TREATMENT DEMONSTRATIONS
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Module Highlights
VIKB) .A.
Permitted and Prohibited
Waste Identification
VIKB) .B.
Allowable wastes for a land treatment
demonstration
VIKB) .B.I
Prohibition from treating wastes
not Identified In Condition
VIKB) .B.2
Duration of Demonstrations
VIKB) .C.
Land Treatment Demonstration
Requirements [$264.272]
VIKB) .D.
Demonstrations Test and Analytical
Procedures
VIKB) .E.
Reeordkeeplng and Reporting
VIKB) .F. (1,2.
3)
3-23
-------
Facility Name
ID No.
VIII. LANDFILLS
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Module Highlights
Permitted and Prohibited Waste
Identification
Allowable wastes for disposal In a
landfill or landfill cell
Prohibition from disposing wastes
not identified in Condition
VIII.B.I
Design. Construction, and Operating
Requirements
VIII.A.
Leachate collection tank management
VIII.B.
VIII.B.I
VIII.B.2
VIII.C.
Liners and leachate collection systems
[S264.301(c)] VIII.C.I
VIII.C.2
General design, construction and operating
practices [$264.301(d)J VIII.C.3
Monofill design, construction and
operating practices [5264.301(e)]
Run-on control [1264.301(f)]
Run-off management [5264.301(g)]
VIII.C.
VIII.C.S
VIII.C.6
3-24
-------
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Run-on/run-off collection
tank management [$264.301(h)]
Dust suppression [$264.301(1)]
Inspection Schedules and Procedures
During construction [§264.303(a))
Prior to start-up [S264.303(a)]
During operations and after storms
[$264.303(b)]
Cell Location Surveying [JJ264.73 and
264.309]
Closure and Post-Closure Care
Closure care [J264.310(a)]
Post-closure care [S264.310(b)]
Special Landfill Provisions for
Ignltable or Reactive Wastes [5264.312]
Special Landfill Provisions for
Incompatible Wastes [5S264.217(b)
and 264.17]
VIII.C.7
VIII.C.8
VIII.D.
VIII.D.I
VIII.D.2(a.b)
VIII.D.3
VIII.E.
VIII.F.
VIII.F.I
VIII.F.2
VIII.G.(1.2)
VIII.H.
3-25
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Special Landfill Provisions for Hazardous
Wastes F020. F021. F022. F023. F026. and
F027 [J264.317] VIII.I.
Special Landfill Provisions for Hazardous
Wastes Restricted from Landfill Units
[JS268.5 and 268.7] VIII.J.(1.2.3.
4,5,6,7)
Special Landfill Provisions for Liquid
Waste [J264.314] VIII.K.(1.2.3)
Volume Reduction Requirements for
Empty Containers (§264.315] VIII.L.
Provisions for the Containerized Landfill
Disposal of Lab Packs [$264.316] VIII.M.
Compliance Schedule VIII.N.
3-26
-------
IX(A). INCINERATION
Facility Name
ID No.
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Module Highlights
Identification Criteria for Permitted
and Prohibited Waste [1264.344(a)1
For commercial (off-site) incineration
IX(A).A.
IX(A).B.
For non-commercial (on-slte) incineration IX(A).B.2
Verification of waste composition IX(A).B.3
Construction. Instrumentation, and
Operational Performance Requirements
[JS264.343 and 264.345] IX(A).C.
Construction and maintenance per
approved plans and specifications
(new facilities) IX(A).C.I
Maintenance per approved plans and
specifications (existing facilities) IX(A).C.2
Instrumentation per approved plans
and specifications IX(A).C.3
POHC ORE requirement IX(A).C.4
Maximum HC1 allowable IX(A).C.5
3-27
-------
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
IX(A).C.10
Maximum particulate matter allowable IX(A).C.6
Maximum CO allowable IX(A).C.7
Maximum waste feed rate allowable IX(A).C.8
Minimum combustion temperature IX(A).C.9
Maximum combustion gas velocity
Maximum mass feed rates of toxic
metals
Minimum atomizatlon fluid pressure
Maximum burner turndown ratio
L
Minimum G ratio to the absorber
Minimum scrubber effluent pH
Minimum scrubber water nozzle
pressure IX(A).C.16
Minimum pressure drop allowable
across venturi scrubber IX(A).C.17
Minimum scrubber blowdown rate IX(A).C.18
Minimum kVA for electrostatic
preclpltator operation IX(A).C.19
Minimum kV for ionized wet scrubber IX(A).C.20
Minimum and maximum pressure drop
across the baghouse IX(A).C.21
IX(A)
IX(A)
IX(A)
IX(A)
.C.
.C,
.C.
.C.
.12
.13
.14
,15
3-28
-------
Model Permit
Condition ID
•Actual Permit
Condition ID
Comments
Fugitive emissions control IX(A).C.22
Compliance with operating conditions IX(A).C.23
Inspection Requirements IX(A).D.
Incinerator and associated equipment
[J264.347(b)J IX(A).D.I
Instrumentation IX(A).D.2
Periodic testing of emergency
equipment [I26A.347(c)] IX(A).D.3
Monitoring Requirements [5264.347(a)] IX(A).E
Listed or tabulated routine requirements IX(A).E.I
Additional special requirements IX(A).E.2
Waste Feed Cut-Off and Incinerator
Shut-Off Requirements
Listed or tabulated requirements for
automatic waste feed cut-off and
incinerator shut-off [5264.345(e) ]
IX(A).F
IX(A).F.I
Provisions for manual waste feed cut-off
and incinerator shut-off IX(A).F.2
Closure [$264.351]
Recordkeeping
IX(A).G.
IX(A).H
3-29
-------
Model Permit Actual Permit
Condition ID Condition ID
Comments
Monitoring and inspection data
[5264.347(d>]
IX(A).H.I
Waste feed shut-offs
IX(A).H.2
Compliance Schedule
IX(A).
3-30
-------
IX(B). SHORT-TERM TEST INCINERATION
Facility Name
ID No.
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
MODULE HIGHLIGHTS
SHAKEDOWN PHASE
Duration of Shakedown Phase
[|264.344(c)(l>]
Allowable Waste Feed
Instrumentation and Operational
Performance Requirements
[{$264.343 and 264.345]
Maximum CO allowable
Minimum combustion temperature
Maximum combustion gas velocity
Minimum atomization fluid pressure
Maximum burner turndown ratio
IX(B).A.
IX(B).B.
IX(B).B.I
IX(B).B.2
IX(B).B.3.
IX(B).B.3.a.
IX(B).B.3.b.
IX(B).B.3.C.
IX(B).B.3.d.
IX(B).B.3.e.
Minimum G ratio to the absorber
Minimum scrubber effluent pH
IX(B).B.3.f.
IX(B).B.3.g.
3-31
-------
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Minimum scrubber water nozzle
pressure IX(B).B.3.H.
Minimum pressure drop allowable
across venturi scrubber IX(B).B.3.i.
Minimum scrubber blowdown rate IX(B).B.3.1.
Minimum kVA for electrostatic
precipitator operation IX(B).B.3.k.
Minimum kV for ionized wet scrubber IX(B).B.3.1.
Minimum and maximum pressure drop
across the baghouse IX(B).B.3.m.
Fugitive emissions control IX(B).B.3.n.
Compliance with operating conditions IX(B).B.3.o.
Inspection Requirements IX(B).B.4.
Incinerator and associated equipment
t§264.347(b)] IX(B).B.4.a.
Instrumentation IX(B).B.4.b.
Periodic testing of emergency
equipment [§264.347(c)] IX(B).B.4.e.
Monitoring Requirements [§264.347(a)] IX(B).B.5.
Listed or tabulated routine requirements IX(B).B.5.a.
Additional special requirements IX(B).B.5.b.
3-.32
-------
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Waste Feed Cut-Off and Incinerator
Shut-Off Requirements IX(B).B.6.
Listed or tabulated requirements for
automatic waste feed cut-off and
incinerator shut-off [§264.345(e)] IX(B).B.6.a.
Provisions for manual waste feed cut-off
and incinerator shut-off IX(B).B.6.b.
Recordkeepini^
Monitoring and inspection data
[§264.347(d>]
Waste feed shut-offs
Compliance Schedule
TRIAL BPRH PHASE [J270.62(b)]
Conformity to Trial Burn Plan
Trial POHCs
Trial Burn Determinations
Trial Burn Data Submissions and
Certifications
POST-TRIAL BURH PHASE
Allowable Waste Feed
Instrumentation and Operational
Performance Requirements
[§$264.343 and 264.345]
IX(B).B.7.
IX(B).B.7.a.
IX(B).B.7.b.
IX(B).B.8.
IX(B).C.
IX(B).C.I
IX(B).C.2
IX(B).C.3
IX(B).C.4
IX(B).D.
IX(B).D.I
IX(B).D.2.
3-33
-------
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Maximum CO allowable IX(B).D.2.a.
Minimum combustion temperature IX(B).D.2.b.
Maximum combustion gas velocity IX(B).D.2.c.
Minimum atomizatlon fluid pressure IX(B).D.Z.d.
Maximum burner turndown ratio IX(B).D.2.e.
k
Minimum G ratio to the absorber IX(B).D.2.f.
Minimum scrubber effluent pH IX(B).D.2.g.
Minimum scrubber water nozzle
pressure IX(B).D.2.h.
Minimum pressure drop allowable
across venturi scrubber IX(B).D.2.i.
Minimum scrubber blowdown rate IX(B) .0 . 2 . .1 .
Minimum kVA for electrostatic
precipitator operation IX(B).D.2.k.
Minimum kV for ionized wet scrubber IX(B).D.2.1.
Minimum and maximum pressure drop
across the baghouse IX(B).D.2.m.
Fugitive emissions control IX(B).D.2.n.
Compliance with operating conditions IX(B).D.2.o.
Inspection Requirements IX(B).D.3.
3-34
-------
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Incinerator and associated equipment
[§264.347(b)l IX(B).D.3.a.
Instrumentation IX(B).D.3.b.
Periodic testing of emergency
equipment (§264.347(c)] IX(B).D.3.C.
Monitoring Requirements [J264.347(a)J IX(B).D.4.
Listed or tabulated routine requirements IX(B).D.4.a.
Additional special requirements IX(B).D.4.b.
Waste Feed Cut-Off and Incinerator
Shut-Off Requirements
Listed or tabulated requirements for
automatic waste feed cut-off and
incinerator shut-off
IX(B).D.5.
IX(B).D.S.a.
Provisions for manual waste feed cut-off
and Incinerator shut-off IX(B).D.S.b.
Recordkeeping
Monitoring and inspection data
Waste feed shut-offs
Compliance Schedule
REPORTING HOH-COMPLIAHCE DURING
THE TRIAL BURH
IX(B).D.6.
IX(B).D.6.3.
IX(B).D.6.b.
IX(B).D.7.
IX(B).E.
3-35
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Facility Name
ID No.
X. GROUND-WATER DETECTION MONITORING
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Module Highlights
X.A
Well Location. Installation and
Construction
X.B.
Monitoring well locations
(to Include proposed monitoring wells)
[§264.97(a) and (b)J
X.B.I
Description of monitoring wells
($264.97(a) and (c)]
X.B.2
Methodology for monitoring well
abandonment
X.B.3
Indicator Parameters and Monitoring
Constituents
X.C.
Indicator parameters and monitoring
constituents to be monitored
[S264.98(a>]
X.C.I
Plan for establishing ground-water
quality data (J264.97(g)]
X.C.2(a.b)
Sampling and Analysis Procedures
X.D.
3-36
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Techniques for sample collection
[55264.97(d)(l) and 264.97(e)] X.D.I
Sample preservation and shipment
[55264.97(d)(2) and 264.97(e)] X.D.2
Analytical procedures
[55264.97(d)(3) and 264.97(e)J X.D.3
Chain of custody [5264.97(d)(4)] X.D.4
Elevation of the Ground-Water Surface X.E.
Determination of ground-water surface
elevation [5264.97(f)] X.E.I
Report of monitoring well elevation X.E.2
Statistical Procedures X.F
Statistical procedure [$264.97(h)(1)] X.F.I
Alternate statistical procedure
[$264.97(h)(2)] X.F.2
Monitoring Program and Data Evaluation X.G.
Sampling procedures X.G.I
Sampling frequency [§264.98(d)] X.G.2
3-37
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Model Permit Actual Permit
Condition ID Condition ID Comments
Determination of ground-water flow rate
and direction [5264.98(e)J X.G.3
Statistical evaluation of sample analysis
[5264.98(g)) X.G.4
Time requirement for statistical
determination [$264.98(g)(2)] X.G.5
Reeordkeeping and Reporting X.H.
Recordkeeping of all ground-water
monitoring data [$264.73(b)(6)] X.H.I
Submlttal of background values X.H.2
Report schedule for analytical and
statistical results X.H.3
Reporting significant increases in
background levels for regulated units
($264.98(h) X.H.A
(a,b,c,d,e)
Reporting significant increases in
background levels for non-regulated
units ($264.98(1)] X.H.5(a.b.c.d)
Assurance of Compliance [8264.98(k)] X.I.
3-38
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Special Requirements if Significant
Increases Occur in Values for Parameters
or Constituents X.J.
Requirements if a significant increase
occurs [$264.98(h) and/or $264.98(1)] X.J.(1.2.3.4.5)
Request for Permit Modification
t$264.98(J)] X.K
3-39
-------
Facility Name
ID No.
XI. GROUND-WATER COMPLIANCE MONITORING
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Module Highlights
XI.A.
Well Location. Installation and
Construction
XI. B.
Monitoring well locations (to include
proposed monitoring wells)
[J264.99]
XI.B.I
Description of monitoring wells
[$264.99(b)J
XI.B.2
Methodology for monitoring well
abandonment
XI.B.3
Ground-Water Protection Standard
XI. C.
Hazardous constituents and concentration
limits to be monitored [55264.93 and
264.94] XI.C.I
Background concentrations established
during each sampling event
[8264.99(c)(l)l XI.C.2
Designation of monitoring wells
for compliance monitoring [$264.95]
XI.C.3
3-40
-------
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Length of the compliance period
[S264.96] XI.C.4
Sampling and Analysis Procedures XI.D.
Techniques for sample collection
[S$264.97(d)(l) and 264.97(e)] XI.D.I
Sample preservation and shipment
[$$264.97(d)(2) and 264.97(e)] XI.D.2
Analytical procedures
[$$264.97(d)(2) and 264.97(e)] XI.D.3
Chain of custody [5264.97(d)(4)] XI.D.4
Quarterly sampling [$264.99(d)] XI.D.5
Annual analysis of Appendix IX
constituents [$264.99(f)J XI.D.6
Elevation of the Ground-Water Surface XI.E.
Determination of ground-water
surface elevation [J264.97(f)J XI.E.I
Report of monitoring well elevation XI,E.2
Statistical Procedures
[55264.99(c)(2)(i) and (ii)] XI.F.
Monitoring Program and Data Evaluation XI.G.
Sampling procedures
Sampling frequency [$264.99(d)]
XI.G.I
XI.G.2
3-41
-------
Model Permit Actual Permit
Condition ID Condition ID Comments
Determination of ground-water
flow rate and direction [$264.99(e)] XI.G.3
Appendix IX sample analysis
[5264.99(f)] XI. G. It
Statistical evaluation of sample
analysis [$264.99(h)(1) and (2)] XI.G.5
Time requirements for statistical
determination [$264.99(h)(2)] XI.G.6
Recordkeeping and Reporting XI.H.
Recordkeeping of all ground-water
monitoring data [$264.73(b)(6)] XI.H.I
Report schedule for analytical
and statistical results [$264.99(h)(2)] XI.H.2
Reporting statistically significant
Increases [$264.99(i)(1)J XI.H.3
Reporting concentrations of Appendix IX
constituents not routinely monitored XI.H.4
Assurance of Compliance [S264.99(k)(1)] XI.I.
Special Requirements if the Ground-Water
Protection Standard is Exceeded XI.J.
Requirements if a significant
increase occurs ($264.99(1) and/or
264.99(J)] XI.J.(1.2.3.4)
Request for Permit Modification XI.K.
3-42
-------
Model Permit
Condition 10
Actual Permit
Condition ID
Comments
Establish a corrective action
program [$264.99(1)(2)]
Modify compliance monitoring
program [J264.99(k)l
XI.K.I
XI.K.2
3-43
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Facility Name
ID No.
XII(A). CORRECTIVE ACTION PROGRAM FOR REGULATED UNITS
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Module Highlights
XII(A).A.
Well Location. Installation
and Construction
XII(A).B.
Monitoring well locations
[S264.100(a)(3) and (d)]
XII(A) .B.I
Description of monitoring veils
[S264.100(d)]
XIKA) .B.2
Methodology for monitoring well
abandonment
XIKA) .B.3
Ground-Water Protection Standard
XIKA) .C.
Hazardous constituents and
concentration limits in the
facility ground-water protection
standard [J264.100(d)]
XIKA) .C.I
Designation of monitoring wells
for corrective action monitoring
[§5264.95 and 264.100(d)]
XIKA) .C.2
3-44
-------
Model Permit
Condition ID
Actual Permit
Condition ID
45
Comments
Hazardous constituents
to be monitored [1264.93] XII(A).C.3
Corrective Action Program XIKA).D.
Beginning date of corrective action
15264.100(c)J XII(A).D.I
Prevent constituents from exceeding
concentration limits [$264.100(b) ] XIKA).D.2
Remove or treat constituents exceeding
concentration limits [S264.100(«) ] XII(A).D.3
Continuation of corrective action
[J264.100(f)] XII(A).D.4
Sampling and Analysis Procedures XII(A).E.
Techniques for sample collection
[$264.97(d) and (e)] XII(A).E.l
Preservation and shipment of samples
(S264.97(d) and (e)] XIKA).E.2^
Analytical procedures
[5264.97(d) and (e)] XIKA) .E.3
Chain of custody [$264.97(d) and (e)] XIKA) .E.4
Ground-Water Surface Elevation XIKA).F.
Determination of the ground-water
surface elevation [5264.97(f)] XIKA) .F.I
3-45
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46
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Report elevation of monitoring well(s) XII(A).F.2
Statistical Procedures XIKA).G.
Monitoring Program and Data Evaluation
Sampling procedures
Sampling frequency [$264.100(d) ]
Sample analysis procedures
Determination of ground-water flow rate
[$264.98(e>]
Statistical comparison of hazardous
constituents with concentration limits
Recordkeeplng and Reporting
Recordkeeping of ground-water
monitoring data [J264 . 73(b)(6)]
Semi-annual report of corrective action
program effectiveness [J264.100(g)]
Report schedule for analytical and
statistical results (SJ264.99(f)
and (h)(2)]
Request for Permit Modification
[$264.100(h)l
XII(A).H.
XII(A).H.I
XII(A).H.2
XII(A).H.3
XIKA).H.4
XIKA).H.5
XIKA) .1.1
XIKA) .1.3
XIKA) .J.
3-46
-------
Facility Name
ID No.
RCRA PERMIT CHECKLIST/CONDITIONS
XII(B). CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS
Model Permit Actual Permit
Condition ID Condition ID Comments
[This Checklist Is currently being revised and will be distributed when redrafted.]
3-47
-------
Facility Name
ID No.
XIII. POST-CLOSURE CARE
RCRA PERMIT CHECKLIST/CONDITIONS
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Module Highlights
XIII.A.
Unit Identification
XIII.B.
Post-Closure Procedures and
Use of Property
XIII.C.
Post-Closure care time period (normally
30 yrs.) [S264.117(a)]
XIII.C.I
Ground-water monitoring requirements
[S264.117(a)(l)]
XIII.C.2
Surface impoundment requirements
[!S264.228(b)(l) and (3)]
XIII.C.3(a.b)
Land treatment requirements
[5264.280(c)1
XIII.C.4(a.b.
c,d,e,f,g)
Landfill requirements [$264.310(b))
XIII.C.5(a.b.
c,d,e)
Continuation of security procedures
[S264.117(b>]
XIII.C.6
Restriction on disturbing units
[(264.117(0)]
XIII.C.7
3-48
-------
Model Permit
Condition ID
Actual Permit
Condition ID
Comments
Implementation of Post-Closure Plan
(5S264.117(d) and 264.118(b)]
XIII.C.8
Inspections
XIII.D.
Notices and Certification
XIII.E.
Submission of record to local authority
and the Agency [S264.119(a)]
XIII.E.I
Notation on facility property deed
[S264.119(a)]
XIII.E.2(a.b)
Procedures for removing hazardous vaste
in the future [$264.119(c)J
XIII.E.3
Submission of certification following
post-closure care period [(264.120]
XIII.E.4
Financial Assurance
XIII.F.
Maintenance of financial assurance during
post-closure period [5264.145] XIII.F.I
Demonstration of financial assurance value
[S264.145(a)(10)] XIII.F.2
Submission of bills for reimbursement
tS264.145(a)(ll)]
XIII.F.3
Post-Closure Permit Modifications
XIII.G.
3-49
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PART 4
-------
RCRA PERMIT QUALITY PROTOCOL
PART 4. PERMIT QUALITY EVALUATION CRITERIA
Following is a compilation of selected permit conditions and a description of
how to evaluate their content in terms of completeness, technical soundness,
and enforceability. This is not a "cookbook." Instead, it merely identifies
the type of analyses that need to be done and includes references that describe
how to do the analyses. The references are listed by code. These codes are
described at the end of this Part.
-------
I. GENERAL PERMIT CONDITIONS
EVALUATION CRITERIA
Condition I . I. : Documents to be Submitted Prior to Operation
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
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 the documents
(40 CFR 270.33).
When appropriate, the permit must specify the
documents to be submitted prior to operation of
the facility or of specific units that demonstrate
compliance with RCRA. 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.
ENFORCEABILITY
The permit condition(s) must clearly state the
documents to be submitted, and must specify a date
for each submittal.
4-1
-------
II. GENERAL FACILITY CONDITIONS
EVALUATION CRITERIA
Condition II.E.: General Inspection Requirements
[General inspection schedule]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The general inspection
schedule attached 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
(40 CFR 264.15).
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
The schedule 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 "daily"
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
problems.
REFERENCES
FINDINGS/COMMENTS
4-2
-------
II. GENERAL FACILITY CONDITIONS
EVALUATION CRITERIA
Condition II.E.: General Inspection Requirements
[General inspection schedule (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
ENFORCEABILITY
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.
Condition II.E.: General Inspection Requirements
[For underground tank systems, until secondary containment in provided]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
For other than non-
enterable underground
tanks, where leak tests
will not be conducted,
the inspection schedule
attached to the permit
must specify the pro-
cedures to be followed
for periodically empty-
ing and Inspecting the
Interior of tanks [40
CFR 264.193 (i)).
The Inspection schedule for the 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 and
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.
REFERENCES
FINDINGS/COMMENTS
REFERENCES
PWGD-HU Tanks
pp. 8-7, 8-10
FINDINGS/COMMENTS
4-3
-------
II. GENERAL FACILITY CONDITIONS
EVALUATION CRITERIA
Condition II.E.: General Inspection Requirements
[For underground tank systems, until secondary containment in provided (cont'd)]
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
In addition, the procedure must address protection
of the personnel inspecting the tank interiors,
including testing of air quality, adequate lighting,
appropriate protective clothing, and standby
equipment and services.
ENFORCEABILITY
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
FINDINGS/COMMENTS
Condition II.E.: General Inspection Requirements
[For surface impoundments]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The Inspection schedule
attached to the permit
must describe the pro-
cedures for Inspecting
surface impoundments
In addition to the four items specified in section
26A.226(b), the Inspection schedule must include
procedures to inspect soil layers protecting
synthetic liners from sunlight, wind, and machinery
used to remove sludge from the impoundment.
REFERENCES
PAGM-GFS
FINDINGS/COMMENTS
-------
II. GENERAL FACILITY CONDITIONS
EVALUATION CRITERIA
Condition II.E.; General Inspection Requirements
(For surface Impoundments (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
overtopping controls,
content levels, leak
detection systems, and
dikes [40 CFR
264.226 (b)J.
REFERENCES
FINDINGS/COMMENTS
The Inspection schedule must Include a procedure PAGM
for Inspecting each of the Items In 40 CFR 264.226(b). pp. 5-42, 5-43
In particular, the procedure for thoroughly
Inspecting the impoundment dikes must be described.
It must include checking for 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
ENFORCEABILITY
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.
4-5
-------
Condition II.H.: Location Standards
II. GENERAL FACILITY CONDITIONS
EVALUATION CRITERIA
[Flood proofing descriptions/drawings]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
If the facility Is
located within a 100-
year floodplaln, the
permit must specify
flood protection or a
flood plan per 40 CFR
270.14(b)(11)(111) and
264.18(b). (The
criteria on this page
are for revlev of
flood protection.
The criteria for
flood plan review
follows.)
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 the Federal
Emergency Management Agency (FEMA), the Federal
Insurance Administration (FIA), a flood Insurance
Study (FIS) or from 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
hydrodynamlc 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.
PAGM-GFS
pp. 5-142
and 5-143
PWGM-CLAEAR
pp. 2-12 to 2-18
pp. 3-5 to 3-8
PWGM
pp. 4-5
In addition, the record must contain documentation
showing that the agency conducted a technical
review of the flood protection devices.
4-6
-------
Condition II.H.; Location Standards
II. GENERAL FACILITY CONDITIONS
EVALUATION CRITERIA
[Flood proofing descriptions/drawings (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
ENFORCEABILIIY
The permit must require certification by a pro-
fessional engineer that flood protection devices
are constructed as designed per 40 CFR 270 . 30(k)(2).
In addition, the permit must require that records
be maintained of all Inspections and repairs or
corrective actions for the life of the facility.
Condition II.H.: Location Standards
[Flood plan]
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
If the facility is
located within a 100-
year floodplaln, the
permit must specify
flood protection or a
flood plan per 40 CFR
270.14(b)(ll)(lv) and
264.18(b). The criteria
on this page are for
review of a flood plan.
The administrative record must contain the neces-
sary documentation supporting a facility flood •
plan per 40 CFR 270 .14 (b) { 11) ( iv) (c) . A flood
plan consists of formulated procedures to safely
remove hazardous wastes from a flood prone facility,
before flood waters can reach the facility, and ship
it to a facility eligible to receive hazardous waste
at a location that is not vulnerable to flood waters.
PAGM-GFS
pp. 5-142 & 5-143
PWGM-CLAEAR
pp. 2-12 to 2-18
pp. 3-5 to 3-8
4-7
-------
II. GENERAL FACILITY CONDITIONS
EVALUATION CRITERIA
Condition II.H.; Location Standards
[Flood plan (cont'd)]
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS REFERENCES
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 also describe
the equipment and personnel to be used to move1
hazardous wastes. The plan must also describe the
location che wastes will be moved to and demon-
strate that those facilities are eligible to
receive hazardous wastes.
ENFORCEABILITY
These conditions are enforceable through the
agency's enforcement inspection program.
Condition II.J.: Contingency Plan
[Unit-specific control procedures for tanks and surface impoundments]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
The contingency plan
attached to the permit
must contain specific
procedures for responding
to leaking tanks [40
The contingency plan must contain specific proce-
dures for responding to leaking tanks [40 CFR
264.196(a)-(f)) and surface impoundments failures
[40 CFR 264.227(a) and (b)J and must address the
requirements necessary to remedy a failure [40 CFR
FINDINGS/COMMENTS
FINDINGS/COMMENTS
4-8
-------
II. GENERAL FACILITY CONDITIONS
EVALUATION CRITERIA
Condition II.J.: Contingency Plan
[Unit-specific control procedures for tanks and surface Impoundments (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
CFR 264.194
-------
REFERENCES
II. GENERAL FACILITY CONDITIONS
EVALUATION CRITERIA
Condition II.J.: Contingency Plan
[Unit-specific control procedures for tanks and surface impoundments (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
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:
o Emptying the impoundment if the leak cannot be
stopped; and
o Notifications.
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.
PAGM
pp. 5-48 to 5-50
FINDINGS/COMMENTS
4-10
-------
II. GENERAL FACILITY CONDITIONS
EVALUATION CRITERIA
Condition II.J.: Contingency Plan
[Unit-specific control procedures for tanks and surface impoundments (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
ENFORCEABILITY
The permit will require the permittee to maintain
the Contingency Plan on-site and to implement its
procedures when necessary. The permittee is also
required to file a report with the Regional
Administrator when the Contingency Plan must be
implemented.
-------
III. CONTAINERS
EVALUATION CRITERIA
Condition III.F.: Construction and Maintenance of Containment Systems
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The plans and specifi-
cations attached to the
permit must demonstrate
compliance with the
requirements for a con-
tainment system as
required by 40 CFR 264.175.
They must specifically
describe and/or show via
design drawings:
The design information must specify the construc-
tion material for the base of the storage area
(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 properly
sealed. The design information for new storage
areas must specify that construction joints will
be sealed.
PUGD-Containers
pp. 4-14 to 4-16
o the base of liner
material
o containment system
capacity
o design features for
drainage of leaks
and spills
o prevention of
run-on
The containment system must have sufficient
capacity to contain 10 percent of the volume of
containers, or the volume of the largest con-
tainer, whichever is greater [40 CFR 264.175(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
documentation that the calculations were checked
during technical evaluation of the application.
If containers are not elevated on pallets or other
device, the design information must specify a sloped
base or other design features 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 attachment to the permit.
FWGD-Containers
pp. 4-12 to 4-15
4-12
-------
III. CONTAINERS
EVALUATION CRITERIA
Condition III.F.: Construction and Maintenance of Containment Systems (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
This generally vill include a procedure for deter-
mining if the accumulated liquid is hazardous.
The design plans and specifications must show that
the containment system is elevated above grade or
describe protection from run-on (by a wall or other
feature). If no protection from run-on is shown,
the containment system must have sufficient extra
capacity to also 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
24-hour, 25-year storm event must be provided.
ENFORCEABILITY
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 specifica-
tions, and that the certification be submitted to
the agency at the completion of construction.
FINDINGS/COMMENTS
PWGD-Containers
pp. 4-16 to 4-17
4-13
-------
III. CONTAINERS
EVALUATION CRITERIA
Condition III.K.; Special Provisions for Incompatible Wastes
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCESFINDINGS/COMMENTS
Where incompatible
wastes are handled, the
permit must Include
special design and
operating features to
prevent incompatible
materials from coming-
ling (see 40 CFR 264.177).
The administrative record must document that,
during technical evaluation of the permit appli-
cation, the permit writer either determined
waste incompatibilities or verified the appli-
cant's assessment of waste incompatibilities.
When determining if Incompatibilities exist, the
applicant must not only look at the hazardous
wastes themselves, but also must consider any
materials stored nearby. Each container area
must provide secondary containment for the
containers stored in that area.
PWDG-Containers
pp. 4-11 to 4-12
The most common method of meeting the requirements
of 40 CFR 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 to show the specific wastes to be placed in
each cell.
Where there is no design feature (e.g. wall, curb)
to separate areas containing incompatible wastes,
a permit condition specifying that containers
holding incompatible wastes be placed in
overpacked drums is an option to consider for the
permit.
4-14
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III. CONTAINERS
EVALUATION CRITERIA
Condition III.K.: Special Provisions for Incompatible Wastes (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
The permit also must contain a conditions specify-
ing that a hazardous waste cannot be placed in an
unwashed container previously holding an incom-
patible waste or material.
EHFORCEABILITY
These conditions are generally enforced through
certification of construction by a registered
engineer and continued inspection of the facility
by the agency.
4-15
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IV. TANKS
EVALUATION CRITERIA
Condition IV.C.3.: Design and Construction of the Secondary Containment System
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
FINDINGS/COMMENTS
The Permit must specify how
the secondary containment
system has been (or will be)
designed, installed, and
operated to prevent any
migration of waste or
accumulated liquid from the
tank system to the soil,
ground water, or surface
water at any time during
its use, in accordance
with 40 CFR 264.193(b)
and (c).
The types of secondary containment devices
considered acceptable are liners (external to
the tank), vaults, double-walled tanks, and
equivalent devices that are approved by the
Regional Administrator. Design parameters for
secondary containment systems are listed in
40 CFR 264.193(c). The secondary containment
systems must be:
o Lined and/or constructed of materials
compatible with the contained waste and
designed to withstand pressure gradients,
physical contact with any released waste,
climatic conditions, and daily operational
stresses (including hazards posed from nearby
vehicular traffic);
o Placed on a foundation which can support it, can
withstand any foreseeable pressure gradients,
and prevent failure due to settlement, compres-
sion, or uplift;
o Equipped with a leak-detection system that will
detect the presence of a release within 24 hours
(unless the Permittee has demonstrated that
existing detection technologies or site conditions
will not allow detection within 24 hours); and
STHWTS
Chapter 7
4-16
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IV. TANKS
EVALUATION CRITERIA
Condition IV.C.3.; Design and Construction of the Secondary Containment System (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
o Sloped or operated to drain and remove any accumu-
lated liquids resulting from spills, leaks, or
precipitation within 24 hours (unless the
Permittee has demonstrated that removal of the
liquids cannot be accomplished within 24 hours).
ENFORCEABILITY
The tank system inspection schedule in the Permit must
provide for inspection, at least once each operating
day, of the construction materials and the area
immediately surrounding the externally accessible
portion of the tank system.
Condition IV.D.2.: Controls and Practices to Prevent Spills
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
FINDINGS/COMMENTS
The Permit must specify what
controls and practices will
be used to prevent the spill
of hazardous wastes from the
tank system, in accordance
with 40 CFR 264.194(b).
Underground tanks can be equipped with overfill
prevention systems and/or transfer spill prevention
systems. Appropriate transfer practices must be
followed. The proper elements of an overfill pre-
vention system are:
o Sensors for detecting the liquid level in the
tank (i.e., float-activated, capacitance, thermal
conductivity, ultrasonic, optical, displacer,
hydrostatic head);
REFERENCES
STHWTS
Chapter 9
FINDINGS/COMMENTS
4-17
-------
IV. TANKS
EVALUATION CRITERIA
Condition IV.D.2.: Controls and Practices to Prevent Spills (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
o High-level alarms that activate when a tank
overfill Is Imminent:
o Automatic shut-off devices to prevent overfill
from occurring;
o Tying In the unloading process with the overfill
prevention system to prevent any unloading when
the system is non-operative; and
o Bypass prevention system to assure that the over-
fill prevention system cannot be overridden by an
operator.
The proper elements of a transfer spill prevention
system are:
o Couplings equipped with spring-loaded valves
which automatically block flow when hoses are
disconnected and
o Emergency shut-off valves.
Similarly, tanks located above ground, onground,
or inground can be equipped with overfill preven-
tion and transfer spill prevention systems.
Appropriate transfer practices must also be
followed. The proper elements of an overfill pre-
vention system are:
4-18
-------
IV. TANKS
EVALUATION CRITERIA
Condition IV.D.2.: Controls and Practices to Prevent Spills (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
o Sensors and gauges to indicate the liquid level
in the tank. Float-activated, dlsplacer, and
hydrostatic-head sensors are most commonly used.
Capacitance, thermal conductivity, ultrasonic
and optical sensors are also used;
o High-level alarms:
o Automatic shut-down controls or automatic flow
diversion controls to prevent overfilling;
o Provisions for emergency overflow to adjacent
tanks to collect overflowing materials; and
o Daily monitoring by a trained operator.
The proper elements of a transfer spill-prevention
system are:
o Transfer of hazardous waste from established
stations equipped with curbing, paving, and
catchment facilities;
o Couplings equipped with spring-loaded valves
which automatically block flow when hoses are
disconnected; and
o Use of redundant valves and instrumentation.
4-19
-------
IV. TANKS
EVALUATION CRITERIA
Condition IV.D.2.; Controls and Practices to Prevent Spills (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
ENFORCEABILITY
Gauge readings should be monitored and recorded
during inspections. The inspection schedule must
provide for inspection, at least once each operating
day, of the spill prevention equipment.
4-20
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Description]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
Except as noted, the
permit must contain a
description of a double
liner system to be in-
stalled at the site.
Included with the
description must be a
design drawing of the
system [40 CFR 264.221(c)).
Exceptions:
a) No liner system is required for existing
units (40 CFR 264.221), except that all sites must
be retrofitted with a double liner system by
November 8, 1988 or closed.
b) An exemption from the double liner system
requirements can be granted for alternative
designs.
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
least 3 feet thick of a 3-foot-thlck soil liner
directly beneath a second flexible membrane liner.
HSWA
Liner Mem
4-21
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.; Liner System [Description (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
Documentation would include drawings of the
areal 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
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.
FINDINGS/COMMENTS
4-22
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Description (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
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.
ENFORCEA8ILITY
The permit must include provisions for
certification as per 40 CFR 270.30(k)(2) and
inspection during construction as per 40 CFR
226(a).
Note: When enforceability 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.
4-23
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.; Design, Construction and Operating Requirements
Condition V.C.I.; Liner System [Flexible membrane liner material, thickness, and manufacturer]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
The permit must contain
flexible membrane liner
specifications. Each
surface impoundment
unit, except for exempt
units is required to
have two or more liners
[40 CFR 264.221(3)
and (c)].
At least one of the liners must 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 leachatei the bottom liner
must also include a 30-mll 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.
FINDINGS/COMMENTS
GDLS
PUGM
pp. 6-11 to 6-61
GDLS
pp. 2-8
p. 13
pp. 38-45
SW-846
NSF
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Flexible membrane liner material, thickness, and manufacturer (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
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
testing.
Finally, the administrative record must contain
documentation that all the calculations and data
dealing with 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.
ENFORCEABILITY
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).
4-25
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V. C . : Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Flexible membrane liner material, thickness, and manufacturer (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
FINDINGS/COMMENTS
Note: When enforceability 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.
Condition V.C.I.: Liner System [Flexible membrane liner bedding]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must Include
a description for the
bedding material used
both above and below the
flexible membrane liner
to protect it [40 CFR
264.221(a)l.
The material must 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 cases
documentation such as calculations, historical
data, or test data be provided that indicates
equivalent protection of the liner. If calcu-
lations or test data are provided, the admini-
istrative record must contain documentation that
the data have been technically reviewed and approved.
REFERENCES
GDLS
pp. 16-17
PWGM
pp. 6-11 to 6-31
FINDINGS/COMMENTS
4-26
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Flexible membrane liner bedding (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
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.
ENFORCEABILITY
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).
FINDINGS/COMMENTS
Note: When enforceabllity 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.
Condition V.C.I.: Liner System [Flexible membrane liner installation procedures, including seaming]
REGULATORY REQUIREMENT
The permit must Include
detailed flexible
membrane liner material
specifications and
installation procedures
[40 CFR 264.221].
TECHNICAL SOUNDNESS
Included within the specifications must be such
items as:
o liner manufacturer (optional),
REFERENCES
SW-870
pp. 298-305
pp. 345-373
pp. 403-414
FINDINGS/COMMENTS
4-27
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Flexible membrane liner installation procedures, including seaming (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
o liner brand name (optional),
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.
ENFORCEABILITY
The permit must include provisions for certifi-
cation as per 40 CFR 270.30(k)(2) and inspection
during construction per 40 CFR 264.226(a).
Note: When enforceability 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.
GDLS
pp. 38-45
4-28
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V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Exposure prevention]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must Include
provisions for protec-
tion of the flexible
membrane liner from
exposure [40 CFR 264.221]
Protection is usually provided by placing a cover
layer of soil or other material over the flexible
membrane liner.
If this is not done, or if the flexible membrane
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. In addition, it is likely
that the flexible membrane liner thickness will
have to exceed 30 mils.
ENFORCEABILITY
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 enforceability 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
PWGM
pp. 6-11 to 6-31
CQA
FINDINGS/COMMENTS
4-29
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Soil liner thickness and material specifications]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must contain
specifications for a
soil liner. Each sur-
face impoundment unit
except for exempt units
is required to have a
have a bottom soil liner
which is at least 3 feet
thick with a permea-
bility of lxlO~7 cm/see
or less [40 CFR 264.221(a)
and (c)]. (Note: If only
one flexible membrane liner
is present, then the soil
liner thickness must be
computed.)
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" cm/sec and the flexible
membrane liner must be placed directly on the soil
liner.
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 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 soil liner 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 completing the calculations,
it must be assumed (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 evalua-
tion has been technically reviewed and accepted.
GDLS
p. 17
pp. 45-48
SU-869
SW-84-001
SW-925
pp. 29-30
4-30
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Soil liner thickness and material specifications (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
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.
The administrative record must contain a check-
list, or other documentation, which indicates that
the design data have been technically reviewed and
were accepted.
4-31
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Soil liner thickness and material specifications (cont'd)}
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
ENFORCEABILITY
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 enforceability of a permit condition
is linked to activities conducted under the
facility's inspection plan to contingency plan,
the reviewer should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
4-32
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V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Soil liner construction specifications]
REGULATORY REQUIREMENT
The permit must include
detailed material and
construction specifica-
tions for placement of
the soil liner
[40 CFR 264.221(a)].
TECHNICAL SOUNDNESS
Items 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
necessary
o proper addition of water if necessary
o not constructed of frozed soil, along with
prevention of freezing or compacted material,
and
o seal-rolling of final lift for smooth surface.
ENFORCEABILITY
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
GDLS
pp. 18-20
FINDINGS/COMMENTS
4-33
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.; Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Soil liner construction specifications (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
Note: When enforceability 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.
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.; Liner System [Design specifications]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
Each surface Impoundment
unit, except for exempt
units is required
to have a leachate
detection zone located
beneath the top
flexible membrane liner
and above the bottom
liner [40 CFR 264.221(e)].
The design plans
attached to the permit
must contain specifi-
cations for a leachate
detection system.
The permit must contain the following for the.
leachate detection system:
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 27.
o A graded granular filter of filter fabric to
prevent clogging of the system is required.
o The granular material should have a permea-
bility of 1x10 cm/sec or greater and must
be at least 12 inches thick.
REFERENCES
FINDINGS/COMMENTS
REFERENCES
GDLS
pp. 4-11
pp. 31-44
PWGM
pp. 9-60 to 9-108
SW-869
FINDINGS/COMMENTS
4-34
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V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C. : Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Design specifications (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
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 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.
4-35
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V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Design specifications (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
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
placed 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
provided.
The 12-lnch-thick layer of granular material on a
2Z 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).
REFERENCES
FINDINGS/COMMENTS
4-36
-------
SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.; Liner System [Design specifications (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
The record must also contain documentation, such
as checklist or supporting calculations, indi-
cating that all engineering calculations and test
data have been technically reviewed and are
approved.
ENFORCEABILITY
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 enforceabillty 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
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.; Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Leachate detection system - material specifications]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
The permit must contain
detailed material speci-
fications for all
components of the
leachate detection
system [40 CFR 264.221].
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.
ENFORCEABILITY
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 enforceability of a permit condition
is linked to activities conducted under the
facility's inspection plan or contingency plan,
the reviever should check those plans to verify
that the required activities (and their frequen-
cies) are clearly defined.
FINDINGS/COMMENTS
GDLS
pp. 39-44
4-38
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.; Liner System [Leachate detection system - installation specifications]
REGULATORY REQUIREMENT
The permit must contain
detailed construction
specifications for con-
structing the leachate
detection system
[40 CFR 26*.22)
TECHNICAL SOUNDNESS
The construction specifications should address the
following procedures.
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
filters.
ENFORCEABILITY
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
GDLS
pp. 39-44
FINDINGS/COMMENTS
Note: When enforceability 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.
4-39
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V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Foundation preparation]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The liner 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 uplift (40 CFR
264.221(a)(2)].
The administrative record must contain geo-
technical data and engineering calculations which
describe the liner system foundation and verify
that is 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:
o test borings 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.
DDLS
pp. 39-44
FWGM
pp. 6-46 to 6-58
CQA
4-40
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.I.: Liner System [Foundation preparation (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The record also must contain detailed foundation
construction specifications and a construction
quality assurance procedure for preparation of the
foundation. The necessary items are site specific,
and 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.
ENFORCEABILITY
The permit must include provisions for certi-
fication as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.226(a).
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.4.: Prevention of Overtopping
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must specify
the design of hydraulic
features to prevent 1m-
The administrative record must contain an engi-
neering report and detailed plans providing the
necessary documentation to support the design of
REFERENCES
GDLS
pp. 39-44
FINDINGS/COMMENTS
REFERENCES
PAGM
pp. 5-24 to 5-27
FINDINGS/COMMENTS
4-41
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.4.: Prevention of Overtopping (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
poundment overtopping as
per 40 CFR 264.221(f).
The design may Incorporate
hydrauilc features,
such as channels, spill-
ways, pipes, pumps,
etc., to be operated
either manually or auto-
matically.
all hydraulic features to prevent overtopping.
Report and plan information should include the size
and capacity calculations of all hydraulic struc-
tures such as pumps, pipes, weirs, principal and
emergency 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 from 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
REFERENCES
PWGM
pp. 6-64 to 6-77
PAGM
p. 5-37 and
pp. 5-42 to 5-44
FINDINGS/COMMENTS
4-42
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C. : Design, Construction and Operating Requirements
Condition V.C.4.; Prevention of Overtopping (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
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-cff vsiuiaes 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
Uir.d Setup on Reservoir Embankments," or other
acceptable procedures. The administrative .recirii
must include documentation (e.g., calculations,
notes) that the surface impoundment is designed and
operated to prevent overtopping.
In addition, the record must show that a technical
review was conducted on the design of the
impoundment and all appurtenant structures.
ENFORCEABILITY
The permit must specify the monitoring and inspec-
tion plan to be followed during construction as
per 40 CFR 270.17(c) and include an inspection plan
4-43
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V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.; Design, Construction and Operating Requirements
Condition V.C.A.: Prevention of Overtopping (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
to be followed during impoundment operation, per
40 CFR 264.226(b). The operating 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 inspections, per
40 CFR 264.15(d).
Condition V.C.5.: Dike Design, Construction and Maintenance
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must demonstrate
the structural integrity of
all dikes in accordance
with 40 CFR 224.221(g).
The administrative record must contain an engi-
neering report and detailed plans supporting the
dike design, 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
design:
o foundation conditions
o embankment materials
o impoundment liner
o waste material
REFERENCES
FINDINGS/COMMENTS
REFERENCES
PWGM
pp. 6-78 to 6-85
PAGM
pp. 5-27 to 5-32
PWGM
pp. 6-133 to 6-134
PAGM
pp. 5-45 to 5-48
FINDINGS/COMMENTS
4-44
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
CondIt Ion V.C. : Design, Construction and Operating Requirements
CondltIon V.C.5.; Dike Design, Construction and Maintenance (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
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:
o design plans, technical specifications and
schedules
o results of field and laboratory Investiga-
tions of strength, compressibility, Atterberg
limits, etc., for foundation and dike
materials
o data on geologic, hydrogeologlc, and hydro-
logic conditions Including groundvater
levels, bedrock conditions, and seismic
setting
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"
REFERENCES
FINDINGS/COMMENTS
4-45
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Condition V.C.: Design, Construction and Operating Requirements
Condition V.C.5.: Dike Design, Construction and Maintenance (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
o erosion potential from rainfall, surface
water runoff, leakage through dikes, and
contact with wastes
o evaluation of liquificatlon tendencies
o evaluation of seismic effects
All references, analytical methods, computer
models, and field and laboratory test data must be
identified.
In addition, the record must show via calculations,
notes or other date that a technical review was
conducted on the dike design specifications.
ENFORCEABILITY
The permit must include a certification by a quali-
fied engineer which attests to the structural
Integrity of the dike as per 40 CFR 270.17(d).
4-46
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V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Conditions V.E.I. - 3.: Inspection Schedules and Procedures
[Inspection and quality assurance program]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must include
a detailed construction
quality assurance
program [40 CFR 264.221]
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
liner seams, and
o documentation procedures to be used.
ENFORCEABILITY
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).
REFERENCES
GLDS
pp. 38-45
SW-870
pp. 250-253
CQA
FINDINGS/COMMENTS
Note: When enforceabllity 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.
4-47
-------
V. SURFACE IMPOUNDMENTS
EVALUATION CRITERIA
Conditions V.E.I. - 3.: Inspection Schedules and Procedures
[Construction Inspection and monitoring program]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must contain
a construction quality
assurance plan for deter-
mining that the soil liner
has been constructed
per the plans and specifi-
cations [40 CFR 264.226].
Included must be:
o testing of soil materials 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.
ENFORCEABILITY
The permit must include provisions for certifi-
cation per 40 CFR 270.30(k)(2) and inspection
during construction per 40 CFR 264.226(a).
Note: When enforceabllity 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
COLS
pp. 38-44
CQA
FINDINGS/COMMENTS
4-48
-------
VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.l.; Liner system - description of liner system
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must contain
a description of a liner
system to be Installed
at the site. Included
with the description
must be design drawings
of the system
(40 CFR 264.251).
The permit must contain a description of the liner
system. The liner system must consist of the1
following:
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.
If exempt as an enclosed dry pile, the
administrative record must include documentation
(e.g., testing data, design plans, specifications)
verifying the following (40 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
wetting,
o the waste in the pile does not generate
leachate.
UPDLS
PWGM
pp. 7-9 to 7-51
4-49
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VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.l.: Liner system - description of Liner system (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
Exemptions from the Liner requirement, and the
required documentation are complex. The Permit
Writer should refer to the noted references or to
current Agency guidance and policies.
ENFORCEABILITY
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 specifications is
enforced through the agency's enforcement inspection
program.
Condition VI.C.l.; Liner system - synthetic liner material, thickness, and manufacturer
REGULATORY REQUIREMENT
Each waste pile unit,
except for exempt units
is required to
have a liner. The permit
must specify the liner
material, thickness and
manufacturer [40 CFR
264.251(a)(l)] .
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
If the liner is a synthetic liner, the permit must PWGM
indicate the brand name and manufacturer of the pp. 7-16 to 7-51
synthetic liner. In most cases more than one name
will be provided with a note that the final selection SU-846
will be made at the time of installation subject
to final approval of the RA. NSF
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.
WPDLS
4-50
-------
VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.l.; Liner system - synthetic liner material, thickness, and manufacturer (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
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.
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 consists 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.
4-51
-------
VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.l.: Liner system - synthetic liner material, thickness, and manufacturer (cont'd)
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
ENFORCEABILITY
The permit must include provisions for certification
as per 40 CFR 270.30(k)(2) and inspection during
construction as per 40 CFR 264.254(a).
Note: When enforceability 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 frequencies) are clearly
defined.
Condition VI.C.l.: Liner system - synthetic liner bedding
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must include
a description for the
bedding material used
both above and below the
synthetic liner to
protect it [40 CFR
264.251(a)(l)].
The material should be (SP) material or finer, as
suggested by the Unified Soil Classification (USGS).
Documentation should 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 documentation
such as calculations, historical data, or test data
must be provided that indicate equivalent protection
of the liner. If calculations or test data are
WPDLS
PWGM
pp. 7-16 to 7-51
4-52
-------
VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.l.: Liner system - synthetic liner bedding (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
provided, the administrative record must contain
documentation that the data have been technically
reviewed and approved.
EHFORCEABILITY
The permit must Include provisions for certification
as per 40 CFR 270.30(k)(2) and inspection during
construction as per 40 CFR 264.254(a).
Note: When enforceabillty 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.
Condition VI.C.l.: Liner system - synthetic liner installation procedures, Including seaming
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
The permit must Include Included within the specifications must be such SW-870
detailed synthetic liner items as: pp. 298-305
material specifications pp. 345-373
and installation o liner manufacturer, pp. 403-414
procedures [40 CFR o liner brand name,
264.251(a)(1)]. o liner thickness, PWGM
o liner chemical and physical properties, pp. 7-16 to 7-51
4-53
-------
VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.l.: Liner system - synthetic liner installation procedures, including seaming (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
FINDINGS/COMMENTS
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.
ENFORCEABILIIY
The permit must include provisions for certi-
fication as per 40 CFR 270.30(k)(2) and
inspection during construction as per 40 CFR
264.254(a) .
WPDLS
Note: When enforceability 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
frequencies) are clearly defined.
Condition VI.C.l.! Liner system - exposure prevention
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must include
provisions for protec-
tion of the synthetic
liner from exposure
Protection is usually provided by placing a cover
layer of soil or other material over the synthetic
liner.
PUGM
pp. 7-16 to 7-51
WPDLS
4-5*
-------
VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.l.: Liner system - exposure prevention (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
[40 CFR 264.251(a)].
If this is not done, or if the synthetic liner will
be exposed for long periods due to phased construe"
tion, then the record must contain test data demon-
strating 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.
ENFORCEABILITY
The permit must include provisions for certifi-
cation as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.254(a).
Condition VI.C.l.; Liner system - soil liner construction procedures
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must include
detailed material and
construction specifi-
cations for placement of
the soil liner
[40 CFR 264.2Sl(a)(1)].
Items 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,
REFERENCES
FINDINGS/COMMENTS
REFERENCES
PWGM
pp. 7-16 to 7-51
WPDLS
FINDINGS/COMMENTS
4-55
-------
VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.l.: Liner system - soil liner construction procedures (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
o requires the breaking up of soil clods if
necessary
o proper addition of water if necessary,
o not constructed of frozen soil along with
prevention of freezing of compacted material,
and
o seal-rolling of final lift for smooth surface.
ENFORCEABILITY
The permit must Include provisions for certifi-
cation as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.254(a).
Condition VI.C.1.: Liner system - liner system foundation preparation
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must specify
procedures for liner
foundation preparation.
The liner system must be
placed on a foundation
capable of supporting
the liner system and
resistant to forces
The administrative record must contain geo-
technlcal 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.
FINDINGS/COMMENTS
REFERENCES
PWGM
pp. 7-37 to 7-39
WPDLS
FINDINGS/COMMENTS
4-56
-------
VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.1.; Liner system - liner system foundation preparation (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
FINDINGS/COMMENTS
which could result In
liner failure due to
settlement, compression,
or uplift [40 CFR
Items normally provided In support of the liner
foundation design Include the following.
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!
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 site specific
and are discussed 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.
ENFORCEABILITY
The permit must Include provisions for certification
as per 40 CFR 270.30(k)(2) and Inspection during
construction as per 40 CFR 264.254.
4-57
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VI. WASTE PILES
EVALUATION "CRITERIA
Condition VI.C.2.: Leachate collection system - design description
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
Each waste pile unit,
except for exempt units
is required to have a
leachate collection
system placed above the
liner [40 CFR
264.251(a)(2)J .
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
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
permeability of 1x10 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
required.
PWGM
pp. 7-51 to 7-100
SW-869
GDLS
pp. 9-10
pp. 35-36
WPDLS
4-58
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VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.2.: Leachate collection system - design description (cont'd-)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
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.
o If a granular filter Is used, the record must
Include calculations which show compliance with
the requirements discussed on pages 7-81 through
7-96 of the reference.
o The record should contain documentation either
with test data or acceptable engineering analysis
of the permeability of the granular material.
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.
4-59
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VI. HASTE PILES
EVALUATION CRITERIA
Condition VI.C.2. : Leachate collection system - design description (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
The 12-inch-thick layer of granular material on a
2X 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 recommended 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, indicating
that all engineering calculations and test data have
been technically reviewed and are approved.
ENFORCEABILITY
The permit must include provisions for certification
as per 40 CFR 270.30(k)(2) and inspection during
construction as per 40 CFR 264.254(a).
Condition VI.C.2.: Leachate collection system - material specifications
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
FINDINGS/COMMENTS
The permit must contain
detailed material specifi-
cations for all components
of the leachate collection
Included must be such items as applicable:
o pipe specifications,
REFERENCES
PWGM
pp. 7-51 to 7-100
UFDLS
FINDINGS/COMMENTS
4-60
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VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.2.: Leachate collection system - material specifications (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
FINDINGS/COMMENTS
system [40 CFR
264.251(a)(2)].
o granular material gradations,
o pump specifications, and
o sump specifications.
ENFORCEABILITY
The permit must include provisions for certifi-
cation as per 40 CFR 270.30(k)(2) and inspec'tion
during construction as per 40 CFR 264.254(a).
Condition VI.C.2.: Leachate collection system - leachate head restriction
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must contain
a provision that the
maximum leachate in the
leachate collection
system cannot exceed one
foot [40 CFR 264.251(a)(2)].
The administrative record must contain verified PWGM
engineering calculations showing that leachate pp. 7-51 to 7-100
collection system has sufficient capacity to maintain
a leachate depth of less than or equal to one foot. WPDLS
A detailed discussion of the necessary calculations
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.
4-61
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VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.2.; Leachate collection system - leachate head restriction (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
ENFORCEABILITY
The permit must include provisions for certifi-
cation as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.254(a).
Condition VI.C.2.; Leachate collection system - installation procedures
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must contain
detailed construction
specifications for con-
structing the leachate
collection system [40
CFR 264.251(a)(2)].
Included must be such 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 -filters.
ENFORCEABILITY
The permit must include provisions for certification
as per 40 CFR 270.30(k)(2) and inspection during
construction as per 40 CFR 264.254(a).
REFERENCES
FINDINGS/COMMENTS
REFERENCES
PWGM
pp. 7-51 to 7-100
WPDLS
FIHDIHCS/COMMENTS
4-62
-------
VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.C.2.: Leachate collection system - inspection and quality assurance program during installation
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
FINDINGS/COMMENTS
The permit must include
a detailed construction
quality assurance
program [40 CFR
264.254
-------
VI. WASTE PILES
EVALUATION CRITERIA
Condition VI.D.2.: Liner system - construction inspection and monitoring program (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
ENFORCEABILITY
The permit must include provisions for certifi-
cation as per 40 CFR 270.30(k)(2) and inspection
during construction as per 40 CFR 264.254(a).
Condition VI.D.2.: Leachate collection system - inspection and monitoring procedures during Installation
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
FINDINGS/COMMENTS
FINDINGS/COMMENTS
The permit must contain
a construction quality
assurance plan to assure
that the leachate
collection system is
constructed in accor-
dance with the plans and
specifications (40 CFR
264.254).
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.
ENFORCEABILITY
The permit must include provisions for certification
as per 40 CFR 270.30(k)(2) and inspection during
construction as per 40 CFR 264.2S4(a).
PWGM
pp. 7-51 to 7-100
UPDLS
CQA
pp. 39 to 47
4-64
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).B.: Permitted and Prohibited Waste Identification
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must specify the
wastes that are to be applied
to the land treatment unit
140 CFR 264.271(a)(l)].
The permit must specify the
wastes that must be degraded,
transformed or Immobilized
[40 CFR 264.271(b)].
The wastes to be applied to
the land treatment must be
analyzed for the hazardous con-
stituents listed In Appendix VIII
for purposes of waste stream
verification.
The administrative record must contain
documentation of a technical review
performed by the permit writer Indi-
cating that the waste stream being
applied to the treatment unit con-
tains only the wastes described In
the permit.
HWLT pp.107-134
ENFORCEABILITY
The permit must Include a condition
requiring maintenance of records of the
wastes applied to the land treatment
unit per 40 CFR 264.73 and 264.279.
40 CFR 270.30 provides right of entry
to the facility for Inspection purposes.
4-65
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Condition VII(A).C.: Treatment Program
VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permittee may implement a
land treatment program that is
designed to ensure that hazardous
constituents placed In or on the
treatment zone are degraded, transformed
or Immobilized within the treatment zone
(40 CFR 26*.271).
The treatment program must:
- specify the wastes capable of
being treated in the unit based
on the land treatment demonstra-
tion;
- include a list of hazardous con-
stituents expected to be in or
derived from the wastes to be
land treated based on waste stream
analyses;
- include an unsaturated zone mon-
itoring provisions meeting the
requirements of 40 CFR 264.278; and
- include the vertical and horizontal
dimensions of the treatment zone as
as defined in the permit.
PAGM-HWLTSD
pp.7-44 to 7-46
The administrative record must contain
verification as to the technical soundness of
the components of the treatment program by
the permit writer. This information must
include a soil boring log and the results of
all soil sample analyses. The analyses must
verify that the depth of the treatment zone
does not exceed that defined in this permit
condition. Results of studies documenting the
depth of the seasonal high water table, including
boring logs and depth-to-water table measurements,
must also be Included. This information must show
4-66
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Condition VII(A).C.; Treatment Program (cont'd)
VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
that the maximum depth of the
treatment zone is located at
least three feet above the seasonal
high water table and no more than
five feet below the initial soil
surface.
ENFORCEABILITY
This condition is enforceable under
40 CFR 264.278, unsaturated zone
monitoring requirements.
Condition VII(A).D.: Design Construction and Operating Requirements
REGULATORY REQUIREMENT (Condition VII(A).D.l.) TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must specify that
the land treatment system will be
designed, constructed, operated and
maintained according to approved plans
and specifications included in the
permit (40 CFR 264.273(a)].
The permit must specify the rate
and method of application of haz-
ardous constituents, measures to
The administrative record must
contain documentation that the
selection of rate and method of
application, measures to control
soil pH, measures to enhance
mlcroblal or chemical reactions and
measures to control moisture content
of the treatment zone was based on the
results of the treatment demonstration.
HWLT
pp. 373-405
4-67
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).D.; Design Construction and Operating Requirements (cont'd)
REGULATORY REQUIREMENT (Condition VII(A).D.l.) TECHNICAL SOUNDNESS
REFERENCES
control soil pH, measures to enhance
tnicrobial or chemical reactions and
measures to control moisture content
Ln the treatment zone [40 CFR 264.273(a)
(1),(2) , (3 ) and (4)].
FINDINGS/COMMENTS
This information must include, for
all wastes to be placed in the'treat-
ment unit, specification of:
- Rate Limiting Constituent - that com-
pound or element which restricts the
amount of waste which can be applied
per year.
- Application LiroitinR Constituent -
that compound or element which
restricts the amount of waste which
can be applied per application.
- Capacity Limiting Constituent - 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.
In setting the loading rate, consider-
ation must have been given to the
following major classes of constituents
Ln the waste:
- Organic constituents in terms of their
potential for volatlzation, leaching,
run-off and degradation;
- Metals content of the waste considering
the leaching potential of the metals
based on the cation exchange capacity of
the soils;
4-68
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).D.: Design Construction and Operating Requirements (cont'd)
REGULATORY REQUIREMENT (Condition VII(A).0.1.) TECHNICAL SOUNDNESS
- Nitrogen and phosphorous content
of the wastei
- Soluble salts content of the
waste: and
- Water content of the waste.
In addition, this information must
contain a description and technical
verification of the following items
related to soil pH control:
- Sampling Protocol - a description
of the frequency, location and
procedures used to determine soil
pH.
- pH Control Calculations - the
method used to calculate chemical
amendments for pH control and the
range pH to be maintained.
- pH Control Method - the chemicals
to be used to control soil pH and
description of how they will be
applied to the treatment zone.
The documentation must also provide
support for the measures used to
enhance microbial and chemical
reactions. This information must
include a description and technical
verification of the following items:
REFERENCES
FINDINGS/COMMENTS
HWLT
pp. 465-468
PAGM
pp. 7-41
HWLT
p. 372
PAGM
pp. 7-14
4-69
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).D.; Design Construction and Operating Requirements (cont'd)
REGULATORY REQUIREMENT (Condition VII(A).C.1.) TECHNICAL SOUNDNESS REFERENCES
- Sampling Protocol - a description
of the frequency, location and
procedures used to determine
additions of soil necessary to
enhance microblal or chemical
react ions.
- Nutrients Additions - the method
used to calculate soil amendments
and specification of the C:N:P
ratio to be maintained.
- Soil Nutrient Control Methods -
the chemicals to be used to enhance
mlcrobial and chemical reactions
and description of how they will
be added to the treatment zone.
FINDINGS/COMMENTS
The administrative record roust
include documentation supporting
the measures to control.soil
moisture in the treatment zone.
This information must contain a
description of the methods used to
monitor soil moisture, the range of
soil moisture to be maintained and
the methods to be use'd to control
soil moisture.
PAGM
pp. 7-41
4-70
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).D.; Design Construction and Operating Requirements (cont'd)
REGULATORY REQUIREMENT (Condition VII(A).D.l.) TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
REGULATORY REQUIREMENT (Condition VII(A).D.2.)
The permit must specify that the
land treatment system be designed,
constructed, operated and maintained
to minimize run-off of hazardous
constituents from the treatment zone
during the active life of the unit
[40 CFR 264.273(b)].
ENFORCEABILITY
The use of the approved methods of
waste application, soil pH control
microbial and chemical reaction
enhancement can be enforced through
inspection under 40 CFR 270.30(1)(3).
The permit must include a condition
requiring maintenance of records of
waste application rates and dates
per 40 CFR 264.73 and 264.279.
Proper control of soil moisture Is
enforceable through inspection under
40 CFR 270.30(1)(4).
TECHNICAL SOUNDNESS
The permit and the administrative
record must contain plans and
specifications for run-off control
features. The administrative record
must also include a technical review
containing a verification of all cal-
culations and specifications used in
the design and construction of the
run-off control system.
PAGM
pp. 47-46 and 49-51
HWLT
pp.425-427
REFERENCES
FINDINGS/COMMENTS
4-71
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).D.: Design Construction and Operating Requirements (cont'd)
REGULATORY REQUIREMENT (Condition VII(A).D.2.) TECHNICAL SOUNDNESS
ENFORCEABILITY
Proper operation and maintenance of
of the run-off control system is
enforceable by agency inspection
under 40 CFR 270.30 (1)(3).
REGULATORY REQUIREMENT (Condition VII(A).D.3.)
The permit must specify that a
run-on control system be designed,
constructed, operated and main-
tained so as to prevent flow
onto the treatment zone during
peak discharge from at least.a
24-hour, 25-year storm
[40 CFR 264.273(c)J.
REFERENCES
FINDINGS/COMMENTS
TECHNICAL SOUNDNESS REFERENCES
The permit must contain plans and HWLT p. 425
specifications which demonstrate
that the run-on control system is
capable of preventing flow onto
the treatment zone during peak dis-
charge from at least a 24-hour,
25-year storm.
The administrative record must Include
a technical review which contains veri-
fication of all calculations and speci-
fications used in the design and con-
struction of the run-on control system.
ENFORCEABILITY
Proper operation and maintenance of the
run-on control system is enforceable
through Inspection under 40 CFR 264.273 (g)
and 270.30(i)(3).
FINDINGS/COMMENTS
4-72
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).D.: Design Construction and Operating Requirements (cont'd)
REGULATORY REQUIREMENT (Condition VII(A).D.4.) TECHNICAL SOUNDNESS
The permit must specify that a
run-off management system be
designed, constructed, operated
and maintained so as to collect
and control at least the water
volume resulting from a 24-hour,
25-year storm [40 CFR 264.273(d)].
The permit must contain plans
and specifications which demon-
strate how the run-off manage-
ment system will collect and
control at least the water volume
resulting from a 24-hour, 25-year
storm.
The administrative record must in-
clude a technical review which
verifies all calculations and speci-
fications used in the design and
construction of the run-off manage-
ment system.
ENFORCEABILITY
REFERENCES
HWLT
pp. 425-428
FINDINGS/COMMENTS
REGULATORY REQUIREMENT (Condition VII(A).D.5.)
The permit must specify that.
collection and holding facilities
( e.g., tanks or basins )
associated with run-on and run-off
control systems must be emptied or
Proper operation and maintenance of
the run-off management system is enforceable
through inspection under 40 CFR 264.273(g)
and 270.30(i)(3).
TECHNICAL SOUNDNESS
REFERENCES
HWLT pp.425-427
FINDINGS/COMMENTS
4-73
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).D.; Design Construction and Operating Requirements (cont'd)
REGULATORY REQUIREMENT (Condition VII(A).D.5.) TECHNICAL SOUNDNESS REFERENCES
otherwise managed expeditiously after
storms to maintain the design
capacity of the system [40 CFR
264.273(e)].
ENFORCEABILITY
Proper operation and maintenance of
the run-on and run-off collection and
and holding facilities is enforceable
through inspection under 40 CFR 264.273
(g) and 270.30 (i)(3).
FINDINGS/COMMENTS
REGULATORY REQUIREMENT (Condition VII(A).D.6.)
The permit must specify that
the treatment unit will be
managed so as to control wind
dispersal of particulate matter
[40 CFR 264.273(f)).
TECHNICAL SOUNDNESS
The administrative record must
contain a technical review of
the equipment and procedures used
to monitor wind dispersal of
particulate matter.
If the treatment zone will not
be managed to control wind dispersal,
the permit writer should include a
condition which prohibits placement
of dispersable particulate matter in
the treatment zone.
REFERENCES
HWLT pp.454-455
and 548
FINDINGS/COMMENTS
4-74
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).D.; Design Construction and Operating Requirements (cont'd)
REGULATORY REQUIREMENT (Condition VII(A).D.6.) TECHNICAL SOUNDNESS REFERENCES
ENFORCEABILITY
This permit condition is enforceable
through inspection under 40 CFR 264.273
(g) and 270.30(i)(3).
Condition VII(A).E.: Unsaturated Zone Sampling and Monitoring
REGULATORY REQUIREMENT (Oondltlons VII(A).E.1.-4.) TECHNICAL SOUNDNESS
FINDINGS/COMMENTS
The permit must specify that
the soil and soil-pore liquid
in the unsaturated zone between
the lower limit of the treatment
zone and the seasonal high water
table will be monitored to de-
termine if hazardous constit-
uents have migrated out of the
treatment zone. [40 CFR 264.278(a)]
The permit must specify that the
permittee install and operate an
unsaturated zone monitoring system
using soil cores and soil-pore
liquid monitoring using devices such
as lyslmeters. The system must
consist of a sufficient number of
sampling points at appropriate
locations and depths to yield
adequate samples [40 CFR 264.278(b)}.
The administrative record must
contain extensive documentation
relating to the unsaturated zone
monitoring program (plan). The
Information must specify and verify
by way of a technical review the
following items:
- Sampling locations - The locations of
soil-pore liquid samples and soil core
samples must be established randomly to
ensure representative placement of the
samples. Additional "hot-spots", such
as the toes of slopes, may also be
selected as sampling points.
- Sampling frequency - Sampling of soil
cores and soil-pore liquid must be
conducted according to the frequency
established in the permit. Soil-pore
REFERENCES
PGM/UZM-HWLT,
Chapters 2-4
HWLT
pp. 532-544
FINDINGS/COMMENTS
4-75
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).E.: Unsaturated Zone Sampling and Monitoring (cont'd)
REGULATORY REQUIREMENT (Conditions VII(A).E.1.-4.) TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permittee must establish a
background value for each hazard-
ous constituent to be monitored
under Part 264.271(b). The permit
will specify the values for each
constituent or specify the procedures
to be used to calculate the values.
(40 CFR 264.278(e)].
The permit must specify that soil moni-
toring and soil-pore monitoring will
be conducted immediately below the treat-
ment zone. The permit must also specify
the frequency and timing of the monitoring
[40 CFR 264.278(d)].
liquid sampling is most effective
following a precipitation event.
- Analytes of interest - The consti-
tuents to be monitored for are those
expected to be present in the hazar-
dous wastes Identified in Condition
VII(A).B.l. or principal hazardous
constituents (PHC). PHCs are hazar-
dous constituents contained in the
wastes to be applied to the units
which are the most difficult to treat.
The administrative record must
document that the basis for selecting
the frequency and timing of soil and
soil-pore monitoring was the
frequency, timing and rate of waste
application, and the soil permeability.
PGM-UZM/HWLT
Chapters 2-4
REGULATORY REQUIREMENT (Condition VII(A).E.5.)
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must specify the sampling and analy-
sis procedures to be used in the soil and soil-
pore monitoring under Part 264.278(a). [40
CFR 264.278(e)J
The administrative record must contain PGM-UZM/HWLT
a detailed description of the sampling Chapters 2-4
and analysis procedures to include (at
a minimum) sample collection, sample HWLT
preservation and shipment, analytical pp. 532-544
procedures and chain of custody control.
4-76
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).E.: Unsaturated Zone Sampling and Monitoring (cont'd)
REGULATORY REQUIREMENT (Condition VII(A).E.6.) TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permittee must determine whether there is
a statistically significant change over back-
ground values for each constituent monitored
under Fart 264.278(a) each time sampling under
Part 264.278(d) is conducted. In determining
whether the statistically significant increase
has occurred, the permittee must use the statis-
tical procedures specified in the permit. The
permittee must complete the statistical determin-
ation within a reasonable period of time after
completing the sampling. [40 CFR 264.278(f>]
REGULATORY REQUIREMENT (Condition VII(A).E.7.)
The permit must specify that if a statis-
tically significant change over background
values occurs, the permittee will notify
the Regional Administrator within seven
days In writing and will indicate which
constituents have shown the Increases. The
permit must also specify that in the event a
statistically significant increase occurs,
the permittee will, within ninety days, sub-
mit to the Regional Administrator a permit
modification to modify the facility operating
practices to maximize the success of degrada-
tion, transformation of immobilization pro-
cesses in the treatment zone. [ 40 CFR
264.278(g)]
The permit writer should consider the
complexity of the statistical proce-
dures and the availability of labora-
tory facilities to perform the analyses
in determining the time period for
completing the statistical evaluation.
TECHNICAL SOUNDNESS
The administrative record must contain
documentation of the technical review
conducted on the facility's evaluation
of its land treatment unit operating
practices, design and location in the
event significant contamination is
detected.
REFERENCES
HWLT
pp. 542-544
FINDINGS/COMMENTS
4-77
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VII(A). LAND TREATMENT OPERATIONS
EVALUATION CRITERIA
Condition VII(A).E.; Unsaturated Zone Sampling and Monitoring (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
ENFORCEABILITY
The requirements of Part 264.278
are enforceable through specific
permit conditions.
Condition VII(A).F.; Inspection Schedules and Procedures
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must specify that the permittee
will inspect the land treatment unit weekly,
after storms and In accordance with the in-
spection schedule included in the permit
for evidence of deterioration, malfunctions
or Improper operation of run-on and run-off
control systems and, if applicable, improper
functioning of wind dispersal control
measures. f40 CFR 264.273]
REFERENCES
FINDINGS/COMMENTS
While weekly and post-storm In-
spections are required, daily
inspections of all active por-
tions of the treatment unit are
highly desirable. These inspections
should include observations of
waste spreading and incorporation,
and freeboard apace of run-off
retention structures.
ENFORCEABILITY
Inspection requirements are enforceable
by incorporating an inspection schedule
into the permit, and under Part
270.30(i)(3).
REFERENCES
BWLT
p. 514
FINDINGS/COMMENTS
4-78
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VII(B). LAND TREATMENT DEMONSTRATIONS
EVALUATION CRITERIA
Condition VIKBi.D.: Land Treatment Demonstration Requirements
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must specify
the types of tests used
in the demonstration and
the analytical procedures
used [40 CFR 264.272(b)].
The permit must identify the specific laboratory
procedures in the subject demonstration. The
following items pertaining to laboratory treatment
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
simulated 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 wastes used in
the demonstration 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
protection during the laboratory demon-
stration. This includes such items as safety
equipment and emergency plans. In all cases,
the demonstration must show that hazardous
constituents in the waste can be transformed,
immobilized, or degraded.
REFERENCES
PGM-HWLTD
pp. 43-59
FINDINGS/COMMENTS
4-79
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VII(B). LAND TREATMENT DEMONSTRATIONS
EVALUATION CRITERIA
Condition VII(B).D.: Land Treatment Demonstration Requirements (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
ENFORCEABILITY
The conduct of laboratory demonstrations is
enforceable by agency inspection under 40 CFR
270.30(1), and through the recordkeeping
requirements of 40 CFR 270.30(j).
4-80
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Description of liner system]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must contain
specifications for a
double liner system
and a description of a
double liner system to be
installed at the site.
Included with the
description must be
design drawings of the
system [40 CFR
264.301U) and (c)] .
The permit must contain a description of the double HSWA
liner system. The double liner system should consist Liner Memo
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 and a
3-foot-thick compacted soil liner with a
permeability of no more than 1 x 10 cm/sec
directly beneath the second flexible membrane
liner.
Documentation would include drawings showing the
areal- extent of the liner system with a detailed
cross-sectional drawing of the liner system.
Exemptions from the double-liner requirements,
and the required documentation, are complex. The
Permit Writer should refer to the current Agency
guidance and policies. These exemptions are based on
site-specific design and/or operating procedures,
and will require extensive documentation along with
a detailed technical review. The administrative
4-81
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Description of liner system (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
record roust contain documentation of that reviev
and a notification of the approval of the exemption
by the RA. The permit fact sheet should
include a justification of the exemption. [No
exemptions are allowed in Alabama per 40 CFR
264.301(k)].
ENFORCEABILITY
The permit must contain design plans and specifi-
cations for the liner system. The permit also must
contain conditions requiring Inspection during
construction as per 40 CFR 264.303(a) and certifi-
cation as per 40 CFR 270.30(k)(2).
Note: When enforceability 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 frequencies) are clearly
defined.
4-82
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VIII. LANDFILLS
EVALUATION 'CRITERIA
Condition VIII.C.I.: Liner System
[Flexible membrane liner material, thickness, and manufacturer]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
Each landfill unit,
except for exempt units
is required to have two
or more liners
[40 CFR 26<>.301(a) and
(c)].
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 wi.ll 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; the bottom liner
must also include a 30-mll 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.
REFERENCES
PWGM
pp. 9-10 to 9-30
GDLS
pp. 2-8
p. 13
pp. 38-45
SU-846
NSF
FINDINGS/COMMENTS
4-83
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Flexible membrane liner material, thickness, and manufacturer (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
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
flexible membrane liner along with a comparison of
those loads against the strength of the flexible
membrane liner as determined by the Method 9090
testing.
Finally the administrative record must contain
documentation that all calculations and data associated
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.
ENFORCEABILITY
The permit must include provisions for certification
as per 40 CFR 270.30(k)(2) and inspection during
construction as per 40 CFR 264.303(a).
Note: When enforceability 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 frequencies) are
clearly defined.
4-84
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Flexible membrane liner bedding]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
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).
The material should be (SP) material or liner, as GDLS
classified by the Unified Soil Classification System. pp. 16-17
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 cal-
culations or test data are provided, the admini-
strative record must contain documentation that
the data have been technically reviewed and '
approved.
ENFORCEABILITY
The permit must Include provisions for certification
as per 40 CFR 270.30(k)(2) and inspection during
construction as per 40 CFR 264.303(a).
Note: When enforceability 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 frequencies) are
clearly defined.
PWGM
pp. 9-27
4-85
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Flexible membrane liner installation procedures, including seaming]
REGULATORY REQUIREMENT
The permit must include
detailed flexible
membrane liner material
specifications and
installation procedures
(40 CFR 264.301).
TECHNICAL SOUNDNESS
Included vithin the specifications must be such
items as:
o liner manufacturer (optional),
o liner brand name (optional),
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.
ENFORCEABILIIY
The permit must include provisions for certification
as per 40 CFR 270.30(k)(2) and inspection during
construction as per 40 CFR 264.303(a).
REFERENCES
SW-870
pp. 298-305
pp. 345-373
pp. 403-414
GDLS
pp. 38-45
FINDINGS/COMMENTS
4-86
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System (cont'd)
[Inspection and quality assurance program during installation]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must include
a plan providing for a
detailed construction
quality assurance
program (40 CFR
264.301) .
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
liner seams, and
o documentation procedures to be used.
ENFORCEABILITY
The permit must include provisions for certification
as per 40 CFR 270.30(k)(2) and inspection during
construction as per 40 CFR 264.303(a).
Condition VIII.C.I.: Liner System
[Exposure prevention]
REGULATORY REQUIREMENT
The permit must include
provisions for protection
of the flexible
TECHNICAL SOUNDNESS
Protection usually is provided by placing a cover
layer of soil or other material over the flexible
membrane liner.
REFERENCES
GLDS
pp. 38-45
SW-870
pp. 250-253
CQA
REFERENCES
FWGM
pp. 9-27 to 9-30
FINDINGS/COMMENTS
FINDINGS/COMMENTS
4-87
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Exposure prevention (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
membrane Liner from
exposure (40 CFR 264.301).
If this Is not done, or if the flexible membrane
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 that such data
have been technically reviewed and approved.
ENFORCEABILITY
The permit must include provisions for certification
as per 40 CFR 270.30(k)(2) and Inspection during
construction as per 40 CFR 264.303(a).
Condition VIII.C.l.i Liner System
[Soil liner thickness and material specifications]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
Each landfill unit
except for exempt units
is required to
have a bottom soil liner
which is at least 3 feet
thick with a permeability
of 1x10" cm/sec or
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 cm/sec or less and the
flexible membrane liner must be placed directly on
the soil liner.
REFERENCES
FINDINGS/COMMENTS
REFERENCES
GDLS
p. 17
pp. 45-48
SW-869
FINDINGS/COMMENTS
4-88
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.; Liner System
[Soil liner thickness and material specifications (cont'd)J
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
less [40 CFR 264.30(a)
and (c)]. (Note: If
only one flexible
membrane liner is
present, then the soil
liner thickness must be
computed.]
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 cm/sec or less 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 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 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.
The administrative record must contain documentation
that the soil liner is compatible with the leachate
expected to be generated at the facility.
REFERENCES
SW-84-001
SW-925
pp. 29-30
FINDINGS/COMMENTS
4-89
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.; Liner System
(Soil liner thickness and material specifications (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
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 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.
The administrative record must contain a check-
list, or other documentation, which indicates that
the design data has been technically reviewed and
was accepted.
ENFORCEABILITY
The permit must include provisions for certification
as per 40 CFR 270.30(k)(2) and inspection during
construction as per 40 CFR 264.303(a).
4-90
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Soil liner thickness and material specifications (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
Note: When enforceability 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 frequencies) are
clearly defined.
Condition VIII.C.I.; Liner System
[Soil liner construction procedures]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must include
detailed material and
construction specifica-
tions for placement of
the soil liner
(40 CFR 264.301).
Items 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
necessary,
o proper addition of water if necessary.
REFERENCES
GDLS
pp. 18-20
FINDINGS/COMMENTS
4-91
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Soil liner construction procedures (cont'd))
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
o not constructed of frozen soil along vith
prevention of freezing of compacted
material, and
o seal-rolling of final lift for smooth
surface.
ENFORCEABILITY
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).
Note: When enforceabllLty 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.
4-92
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Construction inspection and monitoring program]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must contain
a construction quality
assurance pian for deter-
mining that the soil
liner has been con-
structed as per the
plans and specifica-
tions (40 CFR 264.301
and 264.303).
The construction testing and monitoring program
specified in the permit must contain, at a
minimum:
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.
ENFORCEABILITY
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. 38-44
CQA
FINDINGS/COMMENTS
4-93
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Leachate collection/removal system - design description]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must contain
specifications for two
leachate collection
systems. Each landfill
unit, except for exempt
units, is required to
have two leachate
collection systems, one
placed above and one
below the top flexible
membrane liner (40 CFR
264.301).
The permit must contain the following for both
leachate collection systems:
o A description including drawings of the
operation and design of each system.
o Each portion of the systems must have a
minimum slope of 2X.
o A graded granular filter or filter fabric to
prevent clogging of the system should be
specified.
o The granular material should have a permeability
of 1x10 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.
GDLS
pp. 4-11
pp. 31-44
PWGM
pp. 9-60 to 9-108
SW-869
4-94
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Leachate collect Ion/removal system - design description (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
The administrative record should contain the
following for both leachate collection systems:
o Drawings showing the extent of the system,
pipe layouts, slopes, and typical cross-
sections .
o Data showing the chemical compatibility of
all components of the systems with the waste
and leachate.
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 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.
4-95
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Leachate collect ion/removal system - design description (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
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
interconnected.
o Calculations along with material properties
which must be provided show that all com-
ponents of the system have sufficient
strength to support the loads to which they
will be subjected.
The 12-Inch-thick layer of granular material on a
21 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 checklist of supporting calculations, Indi-
cating that all engineering calculations and test
data have been technically reviewed and are
approved.
4-96
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Leachate collection/removal system - design description (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
EHFORCEABILITY
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).
Condition VIII.C.l.-. Liner System
[Leachate collect ion/removal system - material specifications]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must contain
detailed material speci-
fications for all
components of the
leachate collection and
removal system
(40 CFR 264.301).
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.
REFERENCES
FINDINGS/COMMENTS
REFERENCES
CDLS
pp. 39-44
FINDINGS/COMMENTS
4-97
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Leachate collect ion/removal system - material specifications (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
ENFORCEABILITY
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).
Condition VIII.C.I.: Liner System
[Leachate collection/removal system - leachate head restriction]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit roust contain
a provision that the
maximum SP leachate in the
leachate collection
system cannot exceed one
foot (40 CFR 264.301) .
REFERENCES
FINDINGS/COMMENTS
The administrative 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
calculations is contained on pages 9-64 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.
REFERENCES
PUGM
pp. 9-64 to 9-71
FINDINGS/COMMENTS
4r98
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I. : Liner System
[Leachate collection/removal system - leachate head restriction (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
ENFORCEABILITY
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).
Condition VIII.C.I.: Liner System
[Leachate collection/removal system - installation procedures]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit must contain
detailed construction
specifications for con-
structing the leachate
collection and removal
systems (40 CFR)
264.301)
The Installation procedures specified in the
permit should address, at a minimum, the following
Items:
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
filters.
REFERENCES
REFERENCES
GDLS
pp. 39-44
FINDINGS/COMMENTS
FINDINGS/COMMENTS
4-99
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Leachate collect ion/removal system - Installation procedures (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
ENFORCEABILIIY
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).
Condition VIII.C.I.: Liner System
[Leachate collection/removal system - 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 removal
systems are constructed
in accordance with the
plans and specifica-
tions (40 CFR 264.301
and 264.303) .
TECHNICAL SOUNDNESS
The construction inspection and monitoring
procedures addressed in the permit should include:
o qualification of the inspectors,
o testing procedures,
o inspection during placement of the materials,
and
o documentation procedures.
ENFORCEABILITY
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).
4-100
REFERENCES
GDLS
pp. 38-44
CQA
FINDINGS/COMMENTS
FINDINGS/COMMENTS
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Liner system foundation preparation]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The liner 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
up uplift (40 CFR
264.301(a)).
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 analysis 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.
GDLS
pp. 39-44
PUGM
pp. 69-31 to 9-50
CQA
4-101
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.I.: Liner System
[Liner system foundation preparation (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
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 site
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.
EHFORCEABILITY
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).
Condition VIII.C.6.: Runoff Control System
[Design]
REGULATORY REQUIREMENT
The permit must describe
the runoff control
design as per 40 CFR
TECHNICAL SOUNDNESS
The administrative record must contain an engi-
neering report and drawings having the necessary
documentation supporting the design of the runoff
REFERENCES
FINDINGS/COMMENTS
REFERENCES
PWGM
pp. 9-127 to 9-134
FINDINGS/COMMENTS
4-102
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.6.: Runoff Control System
[Design (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
270.21(b)(3) and
264.301(g). The design
may incorporate features
such as channels, hold-
ing basins and tanks,
pipes, spillways,
ditches, ponds etc.
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 »11 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 both the runoff peak discharge and volume
resulting from a 25-year, 24-hour storm event.
Peak discharge and 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
PAGM
pp. 8-33 to 8-37
FINDINGS/COMMENTS
4-103
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.6.: Runoff Control System
[Construction procedures]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must specify
construction procedures
for the runoff control
system as per 40 CFR
270.21(b)(3) and
264.301(g>.
The administrative record must contain an
engineering report and dravings 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.
EHFORCEABILITY
. PWGM
pp. 9-127
PAGM
pp. 8-33
PWGM
pp. 9-147 to 9-177
and pp. 4-5
PAGM
pp. 8-44 to 8-48
CQA
The permit must specify the monitoring and inspec-
tion plan to be followed during construction as
per 40 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 40 CFR 270.30(1)(2).
Note: When enforceability 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.
-------
VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.C.6.; Runoff Control System
[Maintenance]
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must specify
a maintenance plan for
the runoff control
system as per 40 CFR
270.21(b)(3) and
264.301
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.K.: Liquids in Landfills
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
Bulk and containerized
liquid wastes can only
be placed in landfills
under certain very
controlled conditions
(40 CFR 264.314) .
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:
o no other method of disposal exists as out-
lined in 40 CFR 264.314(e)
o some liquids can be placed in the landfill if
for beneficial purposes (see guidance)
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.
EHFORCEABILITY
The permit must contain a provision for testing
wastes using the "Paint Filter Test" (Method 9095
as required by 40 CFR 270.30(j).
BLHW
PNHL
4-106
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.K.: Liquids in Landfills (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The permit also must contain a condition requiring
the owner/operator to maintain records of the
testing results in accordance with 40 CFR
270.30(j).
Condition VIII.F.: Closure and Post-Closure Care
[Final cover design]
REGULATORY REQUIREMENT
Each landfill unit must
be covered at closure
with a cover which mini-
mizes the migration of
liquid through the
cover, requires little
maintenance, promotes
drainage, minimizes
erosion, accommodates
settling and subsidence
and has a permeability
less than or equal to
the bottom liner (40 CFR
264.310).
TECHNICAL SOUNDNESS
The cover should consist of the following (from
bottom to top):
o a 2-fcot-thick soil layer having a permea-
bility of 1x10 cm/sec or less,
o a 20 mil or thicker flexible membrane liner,
o a 12-inch-thick drainage layer,
o a vegetation crop.
The slope of the final cover surface should be at
least 3X.
REFERENCES
FINDINGS/COMMENTS
REFERENCES
LDFC
pp. 23-33
PGWM
pp. 9-197 to 9-201
SW-867
CQA
pp. 47-54
FINDINGS/COMMENTS
4-107
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.F.: Closure and Post-Closure Care
[Final cover design (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
The detailed description and dravlngs of the cover
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.
4-108
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.F.: Closure and Post-Closure Care
[Final cover design (cont'd)]
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
Also Included must be detailed engineering cal-
culations addressing:
o erosion of thfe 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 and
o A demonstration that the permeability of the
cover Is equal to or less than that of the
landfill liner or subsoils.
4-109
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VIII. LANDFILLS
EVALUATION CRITERIA
Condition VIII.F.; Closure and Post-Closure Care
[Final cover design (cont'd)]
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
Documentation such as checklists or supporting
calculations must be Included In the record to
show that the engineering analyses provided by the
applicant have been technically reviewed and are
approved.
ENFORCEABILITY
The permit must include provisions for certifica-
tion of closure as per 40 CFR 264.115.
4-110
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IX(A). INCINERATION
EVALUATION CRITERIA
Condition IX(A).B.: Identification Criteria for Permitted and Prohibited Waste
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The hazardous waste
constituents specified
in the permit must be
those which were burned
successfully at least to
a 99.99 percent DRE
during the trial burn,
or constituents which
exhibit higher heats of
combustion [40 CFR
264.344(a)].
The types and quantities of hazardous waste con- GM-HWIP
stituents to be burned in the incineration system EH-HWI
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 than the PORCs 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 the wastes that a facility might be permitted to
burn. In this options, criteria are identified to
establish limitations on the physical and Chemical
characteristics 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 incinerator system. For example, if the
incinerator accepts both solid and liquid feeds,
limitations for each must be set in the permit based
on the trial burn results.
4-111
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IX(A). INCINERATION
EVALUATION CRITERIA
Condition IX(A).B.: Identification Criteria for Permitted and Prohibited Waste (cont'd)
REGULATORY REQUIREMENT
ENFORCEABILITY
REFERENCES
FINDINGS/COMMENTS
Quantitative limitations on waste feed must be set
forth in the permit. In addition, the waste
analysis provisions must specify a frequency for
verifying that the waste feed is within the physical
and chemical composition limits specified in the
permit. [40 CFR 264.341(b)]
Condition IX(A).C.: Construction, Instrumentation, and Operational Performance Requirements
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES
FINDINGS/COMMENTS
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 [40 CFR 264.343
and 264.345].
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,
HC1, and particulate standards. Examples are air
pollution control system operating conditions
(e.g., wet scrubber water reclrculating rate and
pH). The limits set forth in the permit must be
GM-HWIP
pp. 4-2 through
4-14
FR-86-119/ESD
4-112
-------
IX(A). INCINERATION
EVALUATION CRITERIA
Condition IX(A).C.t Construction, Instrumentation, and Operational Performance Requirements (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
based on the trial burn results, data in lieu
of a trial burn, or from the manufacturer's
specifications.
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.
ENFORCEABILITY
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 [40 CFR 264.343(d)]. If
the Permittee complies with the permit operating
conditions, but it is later shown that the perform-
ance standards are not being attained, the permit
may be modified or revoked and reissued.
4-113
REFERENCES
FINDINGS/COMMENTS
GM-HWIP
pp. 5-7
-------
IX(A). INCINERATION
EVALUATION CRITERIA
Condition IX(A).E.: Monitoring Requirements
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The permit must specify
a monitoring system for
each specified operating
condition (40 CFR 264.3*7).
Monitoring systems must be specified for each of
the operating conditions (e.g., combustion temper-
ature, waste feed rate, carbon monoxide concern-
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 temper-
ature, waste feed rate, combustion gas velocity
indicator and CO stack gas concentration roust be
recorded continuously.
ENFORCEABILITY
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).
Condition IX(A).F.; Waste Feed Cut-Off Requirements
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
A system must speci-
fied in the permit to
automatically cut off
waste feed to the
incinerator whenever the
operating conditions
deviate from the limits
The purpose of the automatic waste 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.
GW-HWIP
pp. 4-14 through
4-16 and 4-25
4-114
-------
IX(A). INCINERATION
EVALUATION CRITERIA
Condition IX(A).F.: Waste Feed Cut-Off Requirements (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
designated in permit
(40 CFR 264.345(e)) .
combustion temperature). A calibration frequency
and test frequency must be specified In the per-
mit. The regulations [40 CFR 264.347(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 sufficient.
ENFORCEABILITY
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.
4-115
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IX(B). SHORT-TERM TEST INCINERATION
EVALUATION CRITERIA
Condition IX(B).C.: Trial Burn Phase
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
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 40
CFR 264.344(c)(2) and
270.62.
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.
The permit must include the complete trial burn
plan as an attachment. The trial burn plan must
Include all of the Information required in 40 CFR
270.62(b)(2).
GM-HWIP
Chapter 2
FR-86-119/ESD
The permit must specify one or more proncipal
organic hazardous constituents (POHCs) for each
hazardous waste stream to be burned during the
trial burn. These POHCs 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 POHCs have been specified in the
permit. Since the Regional Administrator can
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 POHCs the Regional Administrator
specifies.
4-116
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IX(B). SHORT-TERM TEST INCINERATION
EVALUATION CRITERIA
Condition IX(B).C.; Trial Burn Phase (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
The permit must specify that the Permittee must
make the determinations required by 40 CFR
270.62(b)(6)(L)-(lx). 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 all the determinations required by
40 CFR 270.62(b)(6) vithin 90 days after the
completion of the trial burn.
ENFORCEABILITY
The trial burn plan provides protocols and
schedules which are incorporated into the permit.
All aspects of the trial burn plan thus are
enforceable.
4-117
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X. GROUND-WATER DETECTION MONITORING
EVALUATION CRITERIA
Condition X.B.: Well Location, Installation and Construction
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify
In detail the Individual
elements of the detection
monitoring system Including
the number, location,
sampling depths, and
design features of all
background and compliance
point wells. [40 CFR
264.97(a) and (c)J
The monitoring well system must first and foremost be consistent with FWGM-GWP
supporting Information In the Fart B Permit Application Identifying the pp. 15-82,
uppermost aquifer (as defined In 40 CFR S260.10) and the site specific
hydrogeology, Including the ground-water elevation, flow rates and directions.
It Is essential that the hydrologlc units beneath the site be accurately and TEGD
adequately described. The heterogeneous nature of the subsurface Chapters 1
necessitates that careful planning be used for the selection of well through 3
locations, well depths and the screen Intervals. In general, the complex
(or heterogeneous) hydrogeologic systems require greater Investigation and more GWMIM
monitoring wells.
The administrative record must Include all aspects of well design and
construction, criteria for well locations, etc. The TEGD reference should
be followed very closely in evaluating the permit application and writing
the Permit.
The information provided must adequately identify all potential release
pathways from the regulated units. This information, along with the type
of potential leakage associated with a regulated unit, are the critical
factors for the design of the monitoring well system.
Compliance point monitoring wells must be located at the hydraulically
downgradient limit of the waste management area.
4-118
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X. GROUND-WATER DETECTION MONITORING
EVALUATION CRITERIA
Condition X.B.: Well Location, Installation and Construction (cont'd)
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify
in detail the individual
elements of the detection
monitoring system including
the number, location,
sampling depths, and design
features of all background
and compliance point wells.
140 CFR 264.97(a) and (c)J
If a proposed location for a hazardous waste management facility is being C.I.V.H.
reviewed, or if a facility being permitted is thought to be in a hydrologically TEGD
sensitive area, the Criteria For Identifying Areas of Vulnerable Hydrogeology
Under the Resource Conservation and Recovery Act Guidance Manual and Appendices
should be consulted, as well as the TEGD.
ENFORCEABILITY
Assurance that th; monitoring well network is constructed and maintained
as specified in the Permit is obtained via Agency inspection of monitoring
facilities as per 40 CFR 270.30( 1)(4) .
Condition X.C. : Indicator Parameters and Monitoring Constituents
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
The Permit must specify
the indicator parameters
and/or monitoring consti-
tuents for which routine
monitoring is required under
the detection monitoring
program. [40 CFR 264.98(a)J
The Permit must specify
the indicator parameters
and/or constituents
REFERENCES
PWGM-GWP
pp. 190-192
pp. 199-200
FINDINGS/COMMENTS
The Indicator parameters and/or monitoring constituents specified in the
detection monitoring program to be monitored must be selected so as to be
consistent with the goal of detection monitoring to allow the earliest
possible indication of leakage from a regulated unit(s). As such, the
chosen parameters/constituents must be representative of the waste. In
addition, the parameters/constituents should be relatively mobile, stable,
and persistent in the subsurface environment.
The administrative record must contain results of waste characterization, in- PWGM-GWP
eluding analysis to identify both the hazardous and nonhazardous constituents pp. 190-192,
of the facility's waste. In addition, the record must identify any pp. 199-200.
4-119
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X. GROUND-WATER DETECTION MONITORING
EVALUATION CRITERIA
Condition X.C.: Indicator Parameters and Monitoring Constituents (cont'd)
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
for which routine constituents likely to form through chemical reaction.
monitoring is required under
the detection monitoring pro- The administrative record must identify those constituents which would be
gram. [40 CFR 264.98(a)] 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 ground water compared to levels
anticipated in the waste's leachate. If background levels are too high, it
may not be possible to correctly identify that ground-water contamination is
occurring.
There must be documentation (e.g., notes, testing data) in the administrative
record that the Permit Writer ensured consideration of all the above factors
supporting monitoring parameter/constituent selection, including presence in
the waste, mobility/persistence, and detectabillty.
ENFORCEABILITY
The Permit may specify reporting requirements for detection monitoring in
accordance with 40 CFR 26A.98(g), (h), and (1), and 40 CFR 270.31(c). The
Permit must specify recordkeeping provisions for detection monitoring in
accordance with 40 CFR 270.30(j). 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(1)(4).
4-120
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X. GROUND-WATER DETECTION MONITORING
EVALUATION CRITERIA
Condition X.D.: Sampling and Analysis Procedures
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify
the procedures and tech-
niques to be used for
ground-water sample col-
lection and analysis.
[40 CFR 264.97(d)J
The sampling procedures specified In the Permit must be consistent and PWGM-GWP
designed to ensure monitoring results that provide a reliable Indication pp. 83-109
of ground-water quality below the waste management area. Techniques to pp. 194-195
determine the presence of immiscibles, if the regulated units manage
wastes of this type, should be included. Procedures for evacuating
stagnant water from the well prior to sampling, determining
how much water to evacuate prior to sample collection and procedures for MGWSP
sample collection must be specified. Critical factors in obtaining
representative samples include:
o Use of inert materials in sampling equipment to ensure the samples
are not contaminated or altered by foreign materials.
TEGD
Chapter 4
Use of a sampling methodology which does not result in excessive
exposure to the atmosphere or other gases causing chemical alteration.
Specification of adequate procedures to prevent cross-contamination:
the procedures specified must be chosen to fit the nature of the sample
analysis to be performed.
The Permit must specify
the procedures and
techniques to be used
for ground-water
sample analysis.
[40 CFR 264.97(e)]
The analytical procedures submitted by the Permittee should describe TEGD
in detail the analytical procedures used to determine the concentrations of Chapter 4
constituents or parameters of interest. The procedures should specify which
analytical method per parameter or constituent will be used. The method
listed should be in SW-846 or an EPA-approved method preservation methods and
holdings times for each parameter/constituent should also be specified.
4-121
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X. GROUND-WATER DETECTION MONITORING
EVALUATION CRITERIA
Condition X.D.: Sampling and Analysis Procedures (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
ENFORCEABILITY
The Permic muse 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 reporting of monitoring results as per
40 CFR 270.30(k)(4) and inspection of monitoring activities as per 40 CFR
270.30(1)(3).
Condition X.E.: Elevation of the Ground-Water Surface
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
A determination of the
ground-water surface
elevation must be made
each time the ground
water is sampled.
[40 CFR 264.97(f)]
Recording the elevation of the ground-water surface is a critical factor TEGD
in the monitoring program. The. data is used to determine the amount of water Chapter
to be evacuated from the well prior to sample collection, to draw
potentiometric or water table maps and to ascertain if other factors are
influencing the water table such as tidal effects, seasonal variations
and off- or on-site well pumping. The Permittee should describe in the
application the device and procedure to be used for measuring the elevation
of the ground-water surface.
Condition X.F: Statistical Procedures
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify
procedures to determine
whether there has been a
statistically significant
The administrative record must demonstrate that the statistical procedures PWGM-GWP
specified in the Permit are suitable for comparing detection monitoring pp. 127-155,
parameter values to background levels. The basic statistical technique, pp. 192, 194
the Students' t-test, is specified in detail in the regulations under
4-122
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X. GROUND-WATER DETECTION MONITORING
EVALUATION CRITERIA
Condition X.F: Statistical Procedures (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
change over background
values established pur-
suant to 40 CFR 264.98(c),
for each parameter or con-
stituent monitored at the
compliance point.
[40 CFR 264.98(g)(l)]
40 CFR 264.97(h)(1)(1). (Note: 40 CFR 264, Subpart F regulations were TEGD
undergoing revisions at the time this document was prepared. The new Chapter 5
regulations will specify four performance standards that the statistical
methods and sampling procedures must meet. The Permit Writer has the option
of specifying the basic statistical technique or some other valid technique
which may be suitable depending on the data involved. Several alternative
procedures are available as outlined in the Agency guidance, such as the
Mann-Whitney U Test. Such alternative procedures are applicable only when
water quality data exhibits specific characteristics. In specifying the basic
Students' t-test or an alternative procedure, the Permit Writer must ensure
that the observed characteristics 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 (the background sample coefficient of variation is less
than 1.00). The administrative record must contain sufficient background data
from previous monitoring to allow such a determination.
The Permit must specify
procedures to determine
whether there has been a
statistically significant
change over background
values established pur-
suant to 40 CFR 264.98(c),
for each parameter or con-
stituent monitored at the
compliance point.
[40 CFR 264.98(g)(l)J
Alternatively, the Permit may specify a statistical procedure based on PWGM-GWP
probable characteristics for background data with the understanding that a pp. 127-155,
Permit modification may be necessary if subsequently obtained background pp. 192-194
data indicates this procedure is not suitable.
The administrative record must document that suitable statistical TEGD
procedures have been specified which achieve a reasonable balance between the Chapter 5
probability of falsely identifying a non-contaminating regulated unit and the
probability of failing to identify a contaminating regulated unit. The record
also must document that the specified procedure(s) are suitable in light of
background characteristics.
4-123
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X. GROUND-WATER DETECTION MONITORING
EVALUATION CRITERIA
Condition X.F: Statistical Procedures (cont'd)
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
ENFORCEABILITY
The Permit must specify reporting requirements for detection monitoring as
per 40 CFR 264.98(h)(1). and (1) and 40 CFR 270.31(c). The Permit must
Include provisions for certification of statistical results as per
40 CFR 270.30(k)(4).
Condition X.G.: Monitoring Program and Data Evaluation
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must require
that ground-water quality
be determined at each
monitoring well at the
compliance point at least
semi-annually.
[40 CFR 264.98(d)]
The Permit Writer must require sample collection at least seml-annuallyi PWGM-GWP
more frequent sampling can be required. Conditions which might merit more p. 195
frequent sampling are: a high ground-water flow rate; the regulated unit Is
near ground-water users or sensitive environments; or the wastes are highly
toxic.
The regulations do not state that ground-water sampling analytical results PWGM-GWP
and statistical evaluations be routinely submitted. The Permit Writer pp. 197-199
may elect to require submlttal of this data. If the data Is to be
routinely submitted, the Permittee must report ground-water quality data
In a form from which statistical determination can be made to ascertain
If a significant statistical Increase has occurred.
The Permit must require the
Permittee to determine the
ground-water flow rate and
direction annually
[40 CFR 264.98(e)]
The regulations do not specify that the annual determination of the ground- PWGM-GWP
water flow rate and direction be reported. However, the permit writer may pp. 25-31
require that the annual determination be reported and when It should be TEGD
reported. The Information enables the Permit Writer to ensure the
monitoring well system Is still adequate.
4-124
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X. GROUND-WATER DETECTION MONITORING
EVALUATION CRITERIA
Condition X.H.: Recordkeeping and Reporting
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permittee must maintain,
in the operating record,
monitoring, testing or
analytical data vere
required by Subpart F.
[40 CFR 264.73(b)(6)]
The Permit must specify
that significant changes
in the concentration of
monitoring constituents
be reported to the Regional
Administrator within 7
days. [40 CFR 264.98(h)(1)]
All data generated by hydrologlc investigations at a facility must be
maintained by the Permittee for three years after the data is generated.
The three year period may be extended by the request of the Director at any
time. The Permittee must maintain information from all ground-water
monitoring wells and associated ground-water surface elevations for
the active life of the facility, and for disposal facilities for the post-
closure period as well. [40 CFR 270.30(j)J
All statistically significant increases in monitoring parameters/constituents,
changes in hydraulic gradients or any data gathered by the Permittee which
may impact the effectiveness of the monitoring system or indicate a release
from a regulated unit, must be reported to the Regional Administrator.
ENFORCEABILITY
The Permit must specify reporting requirements for detection monitoring
as per 40 CFR 270.31(c). The Permit must specify recordkeeplng requirements
as per 40 CFR 270.30(j). The Permit must also include provisions for
certification of statistical results per 40 CFR 270.30(k)(4). The Permit may
specify reporting requirements for semi-annual, or more frequent, detection
monitoring results as per 40 CFR 264.98(h).
4-125
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XI. GROUND-WATER COMPLIANCE MONITORING
EVALUATION CRITERIA
Condition XI.B.; Well Location, Installation and Construction
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permittee must
Install a ground-water
monitoring system at
the compliance point
which compiles with
40 CFR 264.97(a)(2),
(b) and .
[40 CFR 264.99(b)]
For more detailed Information see X. Detection Monitoring, Condition X.B.
Compliance monitoring Is generally more vigorous than detection monitoring
and may require more detailed hydrogeologlc Investigations and the
Installation of additional monitoring wells.
Monitoring well abandonment may offer a pathway of contamination to deeper
ground water hydrologlc zones. It is Imperative that all monitoring wells
that are abandoned be sealed properly to avoid creating such a pathway.
TEGD
Chapters 1-3
PWGM-GWP
pp. 158-164
Condition XI.C.: Ground-Water Protection Standard
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify
the hazardous constituents
and their maximum con-
centration limits to be
monitored for under the
compliance monitoring
program. [40 CFR 264.92-94
and 264.99]
The Permittee may have been required to sample for Appendix IX 40 CFR 261
constituents in all monitoring wells If a statistically significant Increase
occurred in any monitoring well for any monitoring parameter or constituent
pursuant to 264.98(h)(2). Or, the Permittee may have been required to analyze
for hazardous waste or hazardous waste constituents present at the facility in
all monitoring wells pursuant to 40 CFR 265.93(d) if any statistically
significant Increase in any monitoring parameter or constituent was detected.
PWGM-GWP
pp. 166-168,
203-214
The Permit must specify
the hazardous constituents
and their concentration
limits to be monitored
under the compliance
Documentation must be provided by the Permittee showing that the monitoring PWGM-GWP
well network and sampling and analysis procedures used to determine the pp. 166-168,
presence and concentration of all Appendix IX constituents were adequate. The 203-214
Permit Writer must verify that the determination of the presence of all
Appendix IX constituents was sufficient.
4-126
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XI. GROUND-WATER COMPLIANCE MONITORING
EVALUATION CRITERIA
Condition XI.C.: Ground-Water Protection Standard (cont'd)
REGULATORY REQUIREMENT
monitoring program. [40 CFR
264.92-94 and 264.99]
TECHNICAL SOUNDNESS REFERENCES
The ground-water protection standard (GWPS) Is established by Identifying
all Appendix IX hazardous constituents present in the ground water and
specifying a concentration limit for each hazardous constituent identified.
The concentration limits are established by one or more of the following:
o Existing ground-water data;
o The 40 CFR 264.91, Table 1, maximum concentration limits list;
o Alternate concentration limits: and
o At facilities where there is a high temporal correlation between
upgradient and compliance point concent ratlon(s) of hazardous
constituents, the concentration limit may be established by
sampling upgradient wells each time ground water is sampled
at the compliance point.
The Permittee may request an alternate concentration limit (ACL) for any ACLG
hazardous constituent. To grant an ACL the Regional Administrator will
review material submitted by the Permittee pursuant to 40 CFR 264.94(b).
For detailed Information on ACLs, consult the Alternate Concentration
Limit Guidance (July, 1987).
In general, if a constituent Is not listed in 40 CFR 264.94, Table 1, PWGM-GWP
or the background concentration is above that allowed by Table 1, no pp. 166-168
degradation beyond background water quality becomes the standard.
The Agency's policy is to not allow any degradation of water quality
FINDINGS/COMMENTS
4-127
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XI. GROUND-WATER COMPLIANCE MONITORING
EVALUATION CRITERIA
Condition XI.C.: Ground-Water Protection Standard (cont'd)
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
unless it can be shown that no substantial adverse public health or
environmental effects can occur.
The Permit must specify the
hazardous constituents and
their concentration limits
to be monitored for under
the compliance monitoring
program. [40 CFR 264.92-
264.99)
Generally all Appendix IX constituents identified in the ground water must be
specified in the ground-water protection standard (GWPS) for that facility
and be included in the list of hazardous constituents to be routinely
monitored. The following exclusions/exemptions are possible pursuant to
Subpart F:
o The constituent(s) cannot reasonably be expected to be in or derived
from the waste contained in the facility. [40 CFR 264.93(a)]
PWGM-GWP
pp. 203-205
o The constituent cannot pose a substantial present or potential hazard
to human health of the environment. [40 CFR 264.93(b)]
An annual determination of all Appendix IX constituents in all monitoring
wells Is required by 40 CFR 264.99(f).
The Permit must specify
the compliance period
during which the ground-
water protection standard
applies. [40 CFR 264.96(b)]
The Permit Writer should specify the length of time in months or years, the
facility is expected to be active and include the closure period. The post-
closure period should be included for land disposal units that will not
clean close.
4-128
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XI. GROUND-WATER COMPLIANCE MONITORING
EVALUATION CRITERIA
Condition XI.P.: Sampling and Analysis Procedures
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify
the procedures and
techniques for sample
collection under the
compliance monitoring
program [40 CFR
264.97(d) and («)].
The specified procedures must be valid for the particular hazardous
constituents monitored In the compliance monitoring program. In addition,
sampling procedures must be specified for the annual Appendix IX sampling
to determine the presence of any additional hazardous constituents. Sampling
procedures established under Part 264 detection 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 X.
Detection Monitoring, Condition X.D for additional notes.)
PWGM-GWP
pp. 83-109,
211-213
ENFORCEABILITY
The Permit must Include provisions to require that sampling and measure-
ment during monitoring be representative as per 40 CFR 270.30(j)(1). The
Permit must also Include provisions for certification of monitoring results
as per 40 CFR 270.30(k)(4) and Inspection of monitoring activities as per
40 CFR 270.30(1X3) .
Condition XI.E.: Elevation of the Ground-Water Surface
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
A determination of the
ground-water surface
elevation must be made
each time the ground
water Is sampled.
[40 CFR 264.97 (f)]
Recording the elevation of the ground-water surface Is a critical factor
In the monitoring program. The data Is used to determine the amount of water
to be evacuated from the well prior to sample collection, to draw
potentlometrlc or water table maps and to ascertain If other factors are
Influencing the water table such as tidal effects, seasonal variations
and off- or on-slte well pumping. The Permittee should describe In the
application the device and procedure to be used for measuring the elevation
of the ground-water surface.
TEGD
Chapter 4
4-129
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XI. GROUND-WATER COMPLIANCE MONITORING
EVALUATION CRITERIA
Condition XI.F.: Statistical Procedures
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify
the statistical procedures
used to determine whether
a statistically significant
increase over concentration
limits has occurred for
each hazardous constituent
monitored at the compliance
point. [40 CFR 264.97(h)(1),
264.99]
The statistical procedure must be adequate to compare monitoring data with
the established concentration limits to identify violations of the facility's
ground-water 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 concentration limits). Revisions to the 40 CFR Subpart F
regulations will specify four performance standards that the statistical
methods and sampling procedures must meet.
Concentration limits based on background values require procedures to account
for sampling/analysis variability as well as spatial and seasonal variability
of background levels.
ENFORCEABILITY
The Permit must specify reporting requirements for compliance monitoring as
per 40 CFR 264.99(f) and (i), and 40 CFR 270.31(c). The Permit must
specify recordkeeping requirements as per 40 CFR 270.30(j). The Permit also
must include provisions for certification of statistical results as per
40 CFR 270.30(k)(4) .
PWGM-GWP
pp.127-154
Condition XI.G.; Monitoring Program and Data Evaluation
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must require
the determination of the
concentration of hazardous
constituents at least
The Permit Writer must require the monitoring wells be sampled for the
hazardous constituents present at the facility at least quarterly during
the compliance period. The Permit Writer may require more frequent
sampling (e.g., if there is a high ground-water flow rate, the
PWGM-GWP
pp. 211-213
4-130
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XI. GROUND-WATER COMPLIANCE MONITORING
EVALUATION CRITERIA
Condition XI.G.: Monitoring Program and Data Evaluation (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
quarterly. [40 CFR 264.99(d)] regulated unit is near ground-water users or sensitive environments,
or the wastes are highly toxic).
The Permit must require The Permit Writer must require that Appendix IX constituents be analyzed
sampling for all Appendix IX for annually in all monitoring wells, but may require more frequent analysis.
40 CFR 261 constituents.
[40 CFR 264.99(f)]
REFERENCES FINDINGS/COMMENTS
4-131
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XII(A). CORRECTIVE ACTION FOR REGULATED UNITS
EVALUATION CRITERIA
Condition XII(A).B.: Well Location, Installation and Operation
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify
a monitoring program as
effective as that required
for compliance monitoring.
(40 CFR 264.100(4)]
For detailed requirements of monitoring veil location, installation and
operation, see X. Detection Monitoring, Condition X.B.
Additional wells will generally be required for the adequate determination
of ground-water elevations extent of the contamination, or the impact
that corrective action is having on the quality of the ground water.
Initially, monitoring wells may not have to be constructed as if they
were to be used for compliance monitoring. Wells may be installed for the sole
purpose of monitoring gross contamination or sampled when drilling.
PWGM-GWP
pp. 15-81
255-260
TEGD
Chapters 1-4
Condition XII(A).C.: Ground-Water Protection Standard
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
The Permit must specify
concentration limits for
each hazardous constituent
Included in the ground-
water protection standard.
[40 CFR 264.100(a)(1)
and (2)]
The ground-water protection standard established for the compliance
monitoring program is also applicable under a Subpart F corrective action
program.
For additional information, see XI. Compliance Monitoring, Condition XI.C.
Ground-Water Protection Standard.
PWGM-GWP
pp. 164-187
The Permit must specify the
monitoring constituents
as part of the ground-
water monitoring
program which must be as
effective as the compliance
monitoring program.
[40 CFR 264.100(4)]
The list of monitoring parameters and constituents should be developed from PWGM-GWP
the Permittee's waste analysis plan, waste characterization, site hydro- pp. 164-187
geologic investigations, and the Appendix IX ground-water sample analyses.
At the Permit Writer's discretion, a lengthier list of monitoring parameters and
constituents at compliance point wells and a shorter list required for more ACLG
distal wells may initially be required.
4-132
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XII(A). CORRECTIVE ACTION FOR REGULATED UNITS
EVALUATION CRITERIA
Condition XII(A).C.: Ground-Water Protection Standard (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
ENFORCEABILITY
The Permit must establish a ground-water protection standard which specifies
concentration limits for each hazardous constituent to be monitored as per
40 CFR 264.94. The Permit must specify that whenever concentration limits are
exceeded at the compliance point, or in ground water between the compliance
point and the downgradlent facility boundary, the owner/operator must
institute a corrective action program under 40 CFR 264.100.
The Permit must specify reporting requirements as effective as those for
compliance monitoring under 40 CFR 264.99(f) and (i) and 40 CFR 270.31(c).
The Permit must specify recordkeeping provisions as per 40 CFR 270.30(J),
and certification of records as per 40 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).
Condition XII(A).D.; Corrective Action Program
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
The Permit shall state when Whenever the ground-water protection standard is exceeded, the owner or PWGM-GWP
corrective action must operator must develop and implement a corrective action program. pp. 220-262
begin. [40 CFR 264.100(c)] The length of time granted to a facility prior to enacting a corrective action
program may be dependent on the extent and type of contamination and the
measures required to bring the facility back into compliance.
4-133
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XII(A). CORRECTIVE ACTION FOR REGULATED UNITS
EVALUATION CRITERIA
Condition XII(A).D.; Corrective Action Program (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify the
specific measures to be
taken to remove or treat
In place any hazardous
constituents from the
ground water at the
compliance point. [40 CFR
264.100(b))
The Permit must specify the
specific measures to be
taken to remove or treat
In place any hazardous
constituents from the
ground water between the
compliance point and the
downgradient facility
property boundary.
The Permit Writer will need to carefully review the proposed corrective
action plan to ensure it can accomplish the removal, or treatment in place,
of hazardous constituents. A variety of methods are available for corrective
action and the Permit Writer should be concerned that any system proposed
meet the broad objectives of the corrective action program. The program
may include containment measure to prevent further contaminant migration.
Condition XII(A).E.; Sampling and Analysis Procedures
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify a
monitoring program as
effective as that required
for compliance monitoring.
[40 CFR 264.100(d)]
The requirements for ground-water monitoring at the compliance point must
be at least as effective as those required for compliance monitoring pursuant
to 40 CFR 264.97(d) and (e). Informational sampling may occur at some
facilities in areas of gross contamination which requires less sophisticated
sampling ancl analysis procedures. For more detailed information see
X. Detection Monitoring, Condition X.D and IX. Compliance Monitoring,
Condition XI.D.
PWGM-GWP
pp. 253-259
4-134
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XII(A). CORRECTIVE ACTION FOR REGULATED UNITS
EVALUATION CRITERIA
Condition XII(A).E.; Sampling and Analysis Procedures (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
For monitoring wells located beyond the point of compliance, less sophisticated
sampling procedures for key hazardous constituents may be specified for wells
known to be grossly contaminated. As concentrations approach concentration
limits, compliance point procedures must be applied.
ENFORCEABILITY
The Permit must include provisions to require that sampling and measurement
during monitoring be representative pursuant to 40 CFR 270 . 30(J)(1). The
Permit also must include provisions for certification of monitoring
results pursuant to 40 CFR 270.30(k)(4) and inspection of monitoring activities
pursuant to 40 CFR 270.30(1)(3 ) .
Condition XII(A).F.; Ground-Water Surface Elevation
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify a
monitoring program as
effective as that required
for compliance monitoring.
[40 CFR 264.100(d)]
To comply with the ground-water protection standard to determine if the
corrective action program is effective, it is essential that the ground-water
surface elevations be accurately measured at an adequate frequency. The
corrective action measures may radically alter the ground-water flow direction,
as may be indicated by the corrective action plan. It is important that the
Permit Writer is aware of all changes effecting the ground-water flow-rate and
direction.
PWGM-GWP
pp. 253-259
4-135
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XII(A). CORRECTIVE ACTION FOR REGULATED UNITS
EVALUATION CRITERIA
Condition XIKA) .0. : Statistical Procedures
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The Permit must specify
statistical procedures to
be followed in demon-
strating that corrective
action measures are effective
and in determining
compliance with the
ground-water protection
standard. [40 CFR
264.100(d)J
Statistical procedures to determine whether the facility has been brought
back into compliance may generally follow the guidance given under
XI. Compliance Monitoring Condition FI Statistical Procedure of this
protocol. (Until ground-water quality Improves to a concentration(s) 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 ground water. 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 deadline date for assessing the data to determine whether statistical
measures to establish effectiveness may be instituted.
ENFORCEABILITY
The Permit must specify reporting requirements for corrective action program
monitoring as per 40 CFR 264.99(f), 264.99(h)(2) and (i)(2), 264.100(g), and
40 CFR 270.31(c). The Permit must specify recordkeeplng requirements as per
40 CFR 270.30(j). The Permit also must Include provisions for certification
of statistical results as per 40 CFR 270.30(k)(4).
PWGM-GWP
pp. 127-155,
206-207, 260
4-136
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XII(B). CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS
EVALUATION CRITERIA
[This Part * is currently being revised and will be distributed when redrafted.]
4-137
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XIII. POST-CLOSURE CARE
EVALUATION CRITERIA
Condition XIII.C.2: Ground-Water Monitoring
REGULATORY REQUIREMENT
TECHNICAL SOUNDNESS
REFERENCES
FINDINGS/COMMENTS
The post-closure permit
must specify the monitoring
and reporting requirements
in accordance with the
requirements of AO CFR
Subparts F, K, L, M and
N [40 CFR 264.117(a)].
A post-closure permit may be issued to units which FWGM
were regulated under RCRA interim status or a RCRA TEGD
permit. For RCRA permitted units undergoing closure,
all monitoring is performed to comply with the
specifications in 40 CFR Subpart F. For RCRA interim
status units which close without permits, ground-water
monitoring activities during closure and post closure
must continue to comply with the 40 CFR 265 Subpart F
requirements. Upon Issuance of a post-closure permit
(either operating or post-closure) under 40 CFR 270.l(c),
the closed unit is regulated by 40 CFR 264 requirements
throughout the post-closure period. Interim status
facility closure and post-closure plans should be
reviewed for their compliance with the 40 CFR 264
Subpart F ground-water monitoring requirements. Review
of existing ground-water monitoring data is required
during closure activities to define appropriate post-
closure ground-water monitoring programs and to ensure
that closure design addresses all contaminant releases
during the expected post-closure care period for the
unit.
For information on 40 CFR Subpart F ground-water
monitoring requirements, see X. Detection Monitoring
and XI. Compliance Monitoring.
4-138
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XIII. POST-CLOSURE CARE
EVALUATION CRITERIA
Condition XIII.C.3.. 4., and/or 5.: Post-Closure Procedures
REGULATORY REQUIREMENT
The permittee shall comply
with the post-closure care
requirements for surface
impoundments, land treatment
units and/or landfills (unit
type, as appropriate)
[40 CFR 264.228(b)(1) and
(3); 40 CFR 264.280(c),
and/or 40 CFR 264.310(b)]
TECHNICAL SOUNDNESS
The specific requirements for post-closure care vary
by the type of unit. In establishing site-specific
permit conditions, the permit writer must carefully
review the permittee's proposed post-closure care
procedures to ensure that the permittee fully under-
stands his obligations for long-term care and that
the proposed procedures, as described in the post-
closure permit application, are sound and meet
acceptable practices.
REFERENCES
SW-867
SW-873
SILS
LDFC
LTCPC
FINDINGS/COMMENTS
One on the key elements for review is the proposed
inspection schedule. The long-term site inspection
schedule must ensure continued operation of equipment,
site access controls and closure controls. Inspec-
tions should cover the following items:
o security control devices:
o erosion damage;
o cover settlement, subsidence and displacement;
o vegetative cover condition;
o integrity of run-on and run-off control measures;
o cover drainage system functioning;
o leak detection system;
o leachate collection and removal system;
o gas venting system;
o well condition; and
o benchmark integrity.
4-139
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XIII. POST-CLOSURE CARE
EVALUATION CRITERIA
Condition XIII.C.3.. 4.. and/or 5.; Post-Closure Procedures (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
In addition to the inspection schedule, the
permittee must describe the specific procedures he
will use to assess long-term care and performance
o£ maintenance activities such as:
o repair of security control devices;
o erosion damage repair:
o correction of settlement, subsidence and
displacement;
o mowing, fertilization and other vegetative cover
maintenance;
o leachate removal system maintenance; and
o well replacement.
Examples of procedures that should be covered are:
o Prevent erosion damage - The permittee must in-
spect the facility to identify cover areas that
have eroded and replace the eroded material.
o Settlement and subsidence of caps - Caps are
subject to settlement and subsidence due to foun-
dation compression, waste compression, and settle-
ment due to dewaterlng. The permittee must survey
the cap elevations over time to monitor the extent
of settlement. The permittee must establish sur-
veying benchmarks at the site as reference points
in order to conduct these surveys.
4-140
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XIII. POST-CLOSURE CARE
EVALUATION CRITERIA
Condition XIII.C.3.. 4.. and/or 5.: Post-Closure Procedures (cont'd)
REGULATORY REQUIREMENT TECHNICAL SOUNDNESS REFERENCES FINDINGS/COMMENTS
o Maintenance of vegetative covers - Roots from the
vegetative cover must not penetrate the cover.
The permittee must assure that items (such as
heavy brush or trees) do not start growing on the
vegetative cover. These items must be removed
as soon as possible and an assessment made of
potential damage from their roots.
Note: This discussion may be expanded, pending the
availability of EPA guidances and/or policies
presenting specific procedures for post-closure
activities.
4-141
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LIST OF REFERENCES
ABBREVIATION
REFERENCE
General Facility
Conditions
PAGM-GFS
PAGM-CLAEAR
PAGM
Containers
PWGD-Containers
U.S. EPA. 1983. Permit Applicant's Guidance
Manual for the General Facility Standards of
Part 264.
U.S. EPA. 1984. Permit Writer's Guidance Manual
for Hazardous Waste Land Storage and Disposal
Facilities - Criteria for Location Acceptability
and Existing Applicable Regulations.
U.S. EPA. 1984. Permit Applicant's 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.
STHWT
Waste Piles
WPDLS
GSLS
Liner Systems
PWGM
U.S. EPA. 1986. Technical Resource Document:
Storage and Treatment of Hazardous
Wastes in Tank Systems. EPA/530-SW-86-044
U.S. EPA. 1982. Draft RCRA Guidance Document:
Waste Pile Design.
U.S. EPA. 1987. Draft Minimum Technology Guidance
on Single Liner Systems for Landfills, Surface
Impoundments, and Waste Piles. EPA/530-SW-85-0137.
U.S. EPA. 1983. Permit Writer's Guidance Manual
for Hazardous Waste Land Treatment, Storage, and
Disposal Facilities.
-1-
-------
LIST OF REFERENCES
ABBREVIATION
REFERENCE
Liner Systems (cont'd)
SW-846
NSF9
SW-870
SW-869
SW-84-001
SW-925
GDLS
Surface Impoundments
PWGM
PAGM
HSWA
Liner Memo
GDLS
U.S. EPA. 1986. Test Methods for Evaluating Solid
Waste - Physical and Chemical Methods. SW-846.
National Sanitation Foundation.
Flexible Membrane Liners.
1983. Standard 54:
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 Requirements
of HSWA of 1984, Respecting Liners and Leachate
Collection Systems.
U.S. EPA. 1987.. Draft Minimum Technology Guidance
on Double Liner Systems for Landfills and
Surface Impoundments--Design, Construction, and
Operation. EPA/530-SW-85-014.
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LIST OF REFERENCES
ABBREVIATION
REFERENCE
Surface Impoundments (cont'd)
SW-846
NSF
SW-870
SW-869
SW-84-001
SW-925
ISSIRV
CQA
GSLS
CLWMF
Landfills
HSWA
Liner Memo
U.S. EPA. 1986. Test Methods for Evaluating Solid
Waste - Physical and Chemical Methods. SW-846.
National Sanitation Foundation.
Flexible Membrane Liners.
1983. Standard 54:
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. 1986. Interim Status Surface Impoundments
Retrofitting Variances. Final.
U.S. EPA. 1986. Technical Guidance Document:
Construction Quality Assurance for Hazardous Waste
Land Disposal Facilities. EPA/530-SW-86-031.
U.S. EPA. 1987. Draft Minimum Technology Guidance on
Single Liner Systems for Landfills, Surface
Impoundments and Waste Piles. EPA/530-SW-85-013.
U.S. EPA. 1986. Draft Technical Resource Document
for Public Comment - Design, Construction and
Evaluation of Clay Liners for Waste Management
Facilities. March. EPA/530-SW-86-007.
Hazardous and Solid Waste Amendments of 1984.
McGraw, Jack. 1985. Draft Guidance Memorandum -
Implementation of Minimum Technology Requirements
of HSWA of 1984, Respecting Liners and Leachate
Collection Systems.
-3-
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LIST OF REFERENCES
ABBREVIATION
REFERENCE
Landfills (cont'd)
PWGM
GDLS
CQA
BLHW
SW-846
NSF
SW-870
SW-869
SW-84-001
SW-925
PAGM
LDFC
SW-867
U.S. EPA. 1983. Permit Writers' Guidance Manual
for Hazardous Waste Land Treatment, Storage, and
Disposal Facilities.
U.S. EPA. 1987. Draft Minimum Technology Guidance
on Double Liner Systems for Landfills and Surface
Impoundments--Design, Construction, and Operation.
U.S. EPA. 1986. Construction Quality Assurance for
Hazardous Waste Land Disposal Facilities.
EPA/530-SW-86-031.
U.S. EPA. 1986. Prohibition on the Disposal of
Bulk Liquid Hazardous Wastes in Landfills.
Statutory Interpretive Guidance. June 11.
EPA/530-SW-86-016.
U.S. EPA. 1986. Test Methods for Evaluating Solid
Waste - Physical and Chemical Methods. SW-846.
National Sanitation Foundation, 1983. Standard 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. Permit Applicants' Guidance
Manual for Hazardous Waste Land Treatment,
Storage, and Disposal. EPA/530-84-004.
U.S. EPA. 1982. Draft RCRA Guidance Document -
Landfill Design. Liner System and Final Cover.
U.S. EPA. 1982. Evaluating Cover Systems for
Solid and Hazardous Wastes. SW-867.
-4-
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LIST OF REFERENCES
ABBREVIATION
REFERENCE
Landfills (cont'd)
PNHL
CLWMF
Land Treatment
PGM-HWLTD
PGM/UZM-HWLT
U.S. EPA. 1986. Restrictions on the Placement of
Non-Hazardous Liquids in Hazardous Waste Landfills.
April 30.
U.S. EPA. 1986. Draft Technical Resource
Document for Public Comment - Design, Construction
and Evaluation of Clay Liners for Waste
Management Facilities. March. EPA/530-SW-86-007.
U.S. EPA. 1986. Permit Guidance Manual on
Hazardous Waste Land Treatment Demonstrations.
EPA/530-SW-86.
U.S. EPA. 1986. Permit Guidance Manual on
Unsaturated Zone Monitoring for Hazardous Waste
Land Treatment Units. EPA/530-SW-86-040
HWLT
PAGM
Incineration
GM-HWIP
EH-HWI
FR-86-119/ESD
Ground-Water Monitoring
PWGM-GWP
MGWSP
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. 1980. Engineering Handbook for
Hazardous Waste Incineration.
U.S. EPA. 1987. Guidance on Trial Burn Reporting
and Setting Permit Conditions (Draft Final)
U.S. EPA. 1983. Permit Writers' Guidance Manual
for Part 264, Subpart F Ground-water Protection.
U.S. EPA. 1981. Manual of Ground-water Quality
Sampling Procedures.
-5-
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LIST OF REFERENCES
ABBREVIATION
REFERENCE
Ground-Water Monitoring (cont'd)
ACLG
TEGD
GWMIM
CIVH
Post-Closure Care
SW-867
SW-873
SILS
LDFC
LTCPC
U.S. EPA. 1985. Alternate Concentration Limit
Guidance Based on §264.94(b) Criteria. Part I.
Information Required in ACL Demonstrations.
U.S. EPA. 1986. RCRA Groundwater Monitoring
Technical Enforcement Guidance Document.
U.S. EPA. 1987. RCRA Groundwater Monitoring
Operation and Maintenance Inspections
Guidance Manual.
Criteria For Identifying Areas of Vulnerable
Hydrogeology Under RCRA Guidance Manual and
Appendices.
U.S. EPA. 1982. Evaluating Cover Systems for
Solid and Hazardous Wastes.
U.S. EPA. 1982. Closure of Hazardous Waste
Surface Impoundments.
U.S. EPA. 1982. Draft RCRA Guidance Document:
Surface Impoundment Liner Systems, Final Cover
and Freeboard Control.
U.S. EPA. 1982. Draft RCRA Guidance Document:
Landfill Design - Liner Systems and Final Cover
U.S. EPA. 1987. Part 265 Land Treatment Closure/
Post-Closure Guidance. OSWER Directive No.
9476.00-9
-6-
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APPENDIX A
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APPENDIX A
CHECKLIST FOR RCRA RESEARCH,
DEVELOPMENT AND DEMONSTRATION PERMITS
-------
Fac iI Ity Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS»
Provided
(Y/N) or NA Location Comments
I STANDARD CONDITIONS
A Effect of Permit |§§270.1, 270.30(g)J
B Permit Actions l§270.30(f))
C SeverablIity (§121.16(8)]
D Duties and Requirements
D-1 Duty to comply [§270.30(a)J
D-? Duty to reopply I§§270.30(b), 270.10(h))
D-3 Permit expiration (§270.51)
D-t» Need to halt or reduce activity not a
defense (§270.30(c))
D-5 Duty to mitigate (§270.30(d)]
D-6 Proper operation and maintenance
[§270.30(e)|
D-7 Duty to provide Information |§§270.30(h),
261.71(a)J
D-8 Inspection and entry (§270.30(1))
D-9 Monitoring and records (§§270.30(J),
270.30(I
D-10 Reporting planned changes (§270.30(I)(1))
D-11 Certification of construction or modification
(§270.30(I)(2)(I)J
D-12 Anticipated noncompllance (§270.30(I )(2))
D-13 Transfer of permits (§§270.30( I )(3), 270.10)
YoteT Under the provisions of 10 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, tVie 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
10 CFR Parts 270 and 261. Those permit conditions may be evaluated using Sections I through IV of the Permit Quality
Protocol.
A-l
-------
FacI Ii ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Provided
(Y/N) or NA Location Comments
0-1U Compliance schedules (§270.30(I )(5) ]
D-15 Twenty-four hour reporting [§§270.30( I )(6),
261.56(d) and (J)J
D-16 Manifest discrepancy reports and unmanirested
waste reports [§270.30(I)(7) and (8)]
D-17 Biennial report {§270.30(I)(9)]
D-18 Other noncompllance |§270.30(I)(10)I
D-19 Other information (§270.30( I )(11) ]
E Signatory Requirements (§5270.11,
27u.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 |§261.13(b) ]
H-2 Personnel training documents/records
[§26i».16(d)|
H-3 Contingency plan [26U.53(a)l
H-U Closure plan/post-closure plan [ §26'4.112(a))
H-5 Closure cost estimate/post-closure cost
estimate [§264.1U2(d)]
H-6 Operating record [§264.73]
H-7 Inspection schedule(s) [§261.15(b) ],
H-8 Other documents
A-2
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Tnci11ty 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 Jaclllty [§261.31]
B Required Notices (§261.12)
C General Waste Analysis (§261.13)
C-1 Parameters to be analyzed for In each waste
C-2 Analytical methods | §261. 13(b)(2) ]
C-3 Methods to sample wastes | §261. 13(b)( 3) )
C-1 Frequency of analysis | §261. 13(b)(1) ]
C-5 Wastes from off-site [ §261. 13(a )(1) and (b)(5)]
C-6 Waste characterization requirements for
specific types of treatment and disposal
(§261.13(b)(6))
D Security (§261.111
D-1 Description of barrier and means to control
entry (or 21-hour surve! I lance system)
D-2 Description of warning signs [§261.11(c)J
E General Inspection Requirements*
11261.15)
E-1 Inspection schedule l§261.15(b)J
E-2 Items to be Inspected [ §261. 15( b)( 1 ) ]
E-3 Type of problems for which each item is
inspected | §261. 15( b ) ( 3 ) 1
E-1 Inspection frequency ( §261. 15(b)(1) ]
F Personnel Training (§261.16)
F-1 Program director ( §261. 16(a )(2) J
F-2 Training program contents ( §261. 16( a )( 3 ) 1
A-3
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FaciI Ity Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Provided
(Y/N) or NA Location Comments
F-3 Frequency of training (§26l|.16(b) and (c)J
G General Requirements for Iqnitable.
Reactive, or Incompatible Waste I §264.17]
G-1 Ignltable or reactive [§264.17(a)J
G-2 Incompatible* [§264.17(b) ]
H Location Standards (§§261.18, 270.14(b)(11) ]
H-1 Seismic considerations (§264.18(a)]
H-2 Flood proofing description/drawings [ §26*4.18( b) ]
H-3 Flood plan |§261.18(b))
I Preparedness and Prevention
1-1 Required equipment [§264.32)
1-2 Testing and maintenance or equipment
[§264.33J
1-3 Access to communications or alarm system
[§264.34]
1-4 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
J-4b coordination agreements [§264.52(c)J
J-4c emergency coordinators (§§264.52(d ), 264.55]
J-4d emergency equipment [§264.52(e)J
A-A
-------
FnciIi ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Provided
(Y/N) or NA Location Comments
J-le evacuation plan | §26i|.52( f))
J-5 Emergency procedures (§261.56]
J-5a notification |§261.56(a)J
J-5b identification of hazardous materials
(§261.56(b)I
J-5c assessment of hazards [ §261.56(c) ]
J-5d notification In event of threat to human
health or the environment (§261.56(d))
J-5e prevention of recurrence or spread of fires,
explosions, or releases (§261.56(e)]
J-5f monitoring following cessation of operations
(§261.56(f)]
J-5g storage and treatment of released materials
(§261.56(g)]
J-5h Incompatible wastes |§261.56(h)(1))
J-51 post-emergency equipment maintenance
(§261.56(h)(2))
J-5J notification and reports (§261.56(1) and (J))
J-6 Unit-specific control procedures
K Manifest System [§§261.71, 261.72)
L RecordkeepIng and Reporting
L-1 Operating record (§261.73]
L-2 Availability of records (§261.71]
L-3 Biennial report (§261.75]
L-1 Unmanlfested waste report (§261.76]
A-5
-------
Tad I i ty Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENT AND DEMONSTRATION PERMITS*
Provided
(Y/N) or NA Location Comments
M General Closure Requirements*
M-1 Requirement Tor written plan [§264.112(a))
M-2 Content of closure plan (§264.112(b)]
M-2a description of final closure |§26U.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)J
M-5 Removal of wastes and decontamination or
dismantling of equipment (§264.112(e)]
M-6 Certification of closure (§264.1151
N Cost Estimate for Facility Closure
rS§264.142)
0 Financial Assurance for Facility Closure
01)264.143, 264.145)
P LlablIIty Requirements (§264.147)
Q Incapacity of Owners or Operators.
Guarantors, or Financial Institutions
IT264.148J
*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 tflose units.
A-6
-------
Ffici I I 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 Dow
B Design and ConstructLon or Process Units
B-1 Design plans and specifications
B-1a process units
B-1b pollution control equipment
B-2 Materials of construction
B-3 Construction procedures and specifications
(for new uni ts)
B-l» Construction monitoring and inspection
C Ope rat Ions
C-1 Wastes
C-la allowable types and quantities of wastes
C-1b waste feed rates
C-lc sources of wastes (where applicable)
C-1d specific prohibitions or exclusions
C-2 Operating I inil ts
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-i* Operating controls
A-7
-------
TaciI Ity Name
ID No.
CHECKLIST FOR RCRA RESEARCH. DEVELOPMENI_AND DEMONSTRATION PERMITS*
Provided
(Y/N) or NA Location Comments
C-Ua monitoring and Instrumentation
C-t|b 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
instrumentation
C-6c analytical methods (where appropriate)
C-6d required form of data
C-6e statistical procedures (where appropriate)
C-6f recordkeeplng requirements (related to
process efficiency)
C-6g reporting requirements (related to
process efficiency)
A-8
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