GCA-TR-83-48-G
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Research Triangle Park
North Carolina 27711
EPA Project Officer
Jon R. Perry
U.S. Environmental Protection Agency
Land Disposal Branch
Office of Solid Waste
401 M Street, SW
Washington, D.C. 20460
Contract No. 68-02-3168
Assignment No. 95-(3)
PERMIT APPLICANT'S GUIDANCE
MANUAL FOR THE GENERAL FACILITY
STANDARDS OF 40 CFR 264
Draft Final Report
June 21, 1983
Prepared by
Stephen V. Capone
Charles W. Young
Nancy H. Krusell
John P. Patinskas
Arlene W. Levin
Barbara J. Bosy
GCA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts
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CONTENTS
Section Page
1.0 INTRODUCTION 1-1
L.I Purpose 1-1
1.2 Provisions of the Manual 1-1
1.3 Organization of the Manual 1-2
1.4 Other Guidance Manuals 1-3
1.5 Procedures for Updating and Revising 1-3
2.0 THE LAM 2-1
2.1 Introduction 2-1
2.2 The Federal Register 2-4
2.3 The Code of Federal Regulations 2-8
2.4 Availability of Copies 2-10
3.0 THE PERMITTING PROCESS 3-1
3.1 Introduction 3-1
3.2 The Permit Application and the Permit 3-2
3.3 Where to Submit Applications 3-2
3.4 Confidentiality 3-2
3.5 Appeals 3-6
4.0 OVERVIEW OF PARTS 270 AND 264 AND USEFUL INFORMATION SOURCES 4-1
4.1 Introduction 4-1
4.2 Overview of Parts 270 and 264 4-1
4.3 Information Sources 4-2
4.3.1 Documents/Reports 4-2
4.3.2 Regional EPA Offices and State Offices 4-5
4.4 References 4-5
i
5.0 GUIDANCE FOR PERMIT APPLICATION PREPARATION 5-1
5.1 Facility Description 5-3
5.1.1 Regulatory Citations 5-3
5.1.2 Guidance to Achieve the Standards 5-3
5.1.3 List of Major Points 5-3
5.2 Chemical and Physical Analyses of Hazardous Waste 5-4
5.2.1 Regulatory Citations 5-4
5.2.2 Guidance to Achieve the Part 264 Standards 5-4
5.2.3 List of Major Points 5-7
5.3 Waste Analysis Plans 5-8
5.3.1 Regulatory Citations 5-8
5.3.2 Guidance to Achieve the Part 264 Standards 5-9
11
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27308
CONTENTS (continued)
Section
Page
5.4
5.5
5.6
5.7
5.8
5.9
5.10
5.11
5.12
5.3.3 Guidance for Preparation of Waste Analysis Plans
for All Facilities
5.3.4 Guidance for Preparation of Waste Analysis Plans
for Offsite Facilities
5.3.5 Guidance on Preparing Waste Analysis Plans for
Specific Facility Types
Waste Analysis Plan Examples
List of Major Points
References
6
7
5.3
5.3
5.3.8
Security
5.4.1 Regulatory Citations
5.4.2 Guidance to Achieve the Part 264 Standards
5.4.3 List of Major Points
Inspections
5.5.1 Regulatory Citations
5.5.2 Guidance to Achieve the Part 264 Standards
5.5.3 List of Major Points
5.5.4 References
Preparedness and Prevention
5.6.1 Regulatory Citations
5.6.2 Guidance to Achieve the Part 264 Standards
5.6.3 List of Major Points
Contingency Plan and Emergency Procedures
5.7.1 Regulatory Citations
5.7.2 Guidance to Achieve the Part 264 Standards
5.7.3 List of Major Points
General Hazard Prevention
5.8.1 Regulatory Citations
5.8.2 Guidance to Achieve the Part 264 Standards
5.8.3 List of Major Points
Prevention of Ignition or Reaction of Wastes
5.9.1 Regulatory Citations
5.9.2 Guidance to Achieve the Part 264 Standards
5.9.3 List of Major Points
Traffic
5.10.1 Regulatory Citations
5.10.2 Guidance to Achieve the Standards
5.10.3 List of Major Points
Location Information
5.11.1 Regulatory Citations
5.11.2 Guidance to Achieve the Part 264 Standards
5.11.3 References
Personnel Training
5.12.1 Regulatory Citations
5.12.2 Guidance to Achieve the Part 264 Standards
5.12.3 List of Major Points
5-11
5-19
5-30
5-40
5-58
5-65
5-66
5-66
5-67
5-75
5-76
5-76
5-77
5-98
5-98
5-99
5-99
5-101
5-109
5-110
5-110
5-113
5-126
5-127
5-127
5-127
5-129
5-130
5-130
5-131
5-136
5-138
5-138
5-138
5-140
5-141
5-141
5-143
5-164
5-165
5-165
5-166
5-171
111
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CONTENTS (continued)
Section
Page
5.13 Topographic Map Requirements 5-173
5.13.1 Regulatory Citations 5-173
5.13.2 Obtaining Topographic Maps 5-174
5.13.3 Topographic Map Features 5-175
5.13.4 Obtaining Climatological Information 5-178
5.13.5 Flood Plain Area Maps 5-179
5.13.6 Other Required Information 5-180
5.13.7 List of Major Points 5-180
5.14 Manifest System, Recordkeeping, and Reporting 5-181
5.14.1 Regulatory Citations 5-181
5.14.2 Guidance to Achieve the Part 264 Standards 5-185
5.14.3 List of Major Points 5-187
6.0 COMPLETENESS CHECKLIST 6_!
Appendices
A FEDERAL AND STAGE AGENCY ADDRESSES AND TELEPHONE NUMBERS A-l
B SYNOPSIS OF TECHNICAL REPORTS B-!
C ADDRESSES OF GEOLOGICAL AGENCIES C-l
D AERIAL PHOTOGRAPHS D^
E AERIAL RECONNAISSANCE FLIGHT PLANNING E-l
F QUALITY ASSURANCE/QUALITY CONTROL F-l
IV
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FIGURES
Number Page
3-1 Flow diagram of the EPA's RCRA permitting process 3-3
5-1 Example waste characterization scheme 5-28
5-2 Sequence of procedure sets designed by Acurex 5-32
5-3 Seismic standard requirements 5-145
5-4 Floodplain location requirements 5-154
5-5 Site located on 100-year floodplain 5-157
5-6 Sample USGS map order form 5-176
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TABLES
Number Page
2-1 The RCRA Table of Contents 2-2
2-2 Example Federal Register Notice 2-5
2-3 Parts of Title 40 of the CFR Regarding Permitting and
Hazardous Waste Handling and Disposal 2-9
3-1 EPA Regional Hazardous Waste Program Offices 3-4
5-1 Sections of Parts 270 and 264 Addressed in This Manual 5-2
5-2 Example Waste Characterization Data for a Waste Received at
an Offsite Solvent Recovery Plant 5-6
5-3 Sampling Equipment for Particular Waste Types 5-17
5-4 Sampling Requirements to Adequately Characterize Waste
Movements 5-24
5-5 Reactivity Group Definitions 5-29
5-6 Procedure Sets for Classifying Hazardous Wastes by Reactivity
Group Number 5-31
5-7 Objectives of the Waste Analysis Plan Based on General and
Specific Regulations 5-33
5-8 Summary of Specific Requirements for Waste Analysis Noted in
Subparts I Through N 5-39
5-9 Disposition of Major Classes of Wastes Received Onsite 5-42
5-10 Analytical Parameters Selected for Given Waste Classifications 5-43
5-11 Summary of Waste Survey Analysis 5-46
5-12 Definition of Sample Types for Analysis of Fingerprint
Parameters 5-50
5-13 Results of Initial Analysis of Pharmaceutical Waste 5-51
5-14 Criteria for a Determination of Exemption 5-74
5-15 Equipment, Structures, Areas to be Considered for Inclusion
in an Inspection Schedule 5-79
VI
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TABLES (continued)
Number Page
5-16 Example Raw Material Inspection Form 5-89
5-17 Example Items for Surface Impoundment Inspection Plan 5-90
5-18 Example List of Items for an Inspection Plan for an Operating
Surface Impoundment 5-92
5-19 Example List of Items for an Inspection Plan for an Operating
Waste Pile 5-95
5-20 Sample Table of Contents for a Contingency Plan 5-116
5-21 Emergency Coordinators List 5-119
5-22 Emergency Evacuation Procedures 5-121
5-23 Appendix VI Political Jurisdictions 5-146
vn
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ACKNOWLEDGMENTS
The authors express their appreciation to several key people at the EPA
Office of Solid Waste who provided valuable guidance and assistance in the
preparation of this report. They include the Project Officer, Mr. Jon Perry;
our technical contact, Ms. Melissa Friedland; and Mr. Arthur Day. Others who
provided assistance are Tony Baney, Dan Derkics, David Friedman, Terry Grogan,
Myles Morse, and Florence Richardson. We would also like to acknowledge the
useful assistance and information provided to us by Messrs. Dick Boynton and
Rich Cavagnero of EPA, Region 1. Others at GCA who assisted in preparation of
this document include Messrs. Brian Hobbs, Michael Kravitt, Patrick Ford,
Douglas Seely, and the staff of our Technical Publications Department.
viii
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1.0 INTRODUCTION
1.1 PURPOSE
This manual is intended for use by owners and operators of existing and
new land based hazardous waste management facilities who are required to
submit Part B of their permit applications to illustrate compliance with the
land disposal standards of 40 CFR 264.* If you are currently operating an
existing facility under interim status (40 CFR 265), you will have submitted
Part A of your application. Owners and operators of new facilities must
submit Parts A and B together.
The Part 264 standards have been adopted under the Resource Conservation
and Recovery Act, became effective on January 26, 1983, and will be used by
the EPA to issue permits to facilities that treat, store, or dispose of
hazardous waste. The standards identify general requirements that all
hazardous waste management facilities must meet and specific requirements
applicable to specific types of facilities.Q~T\iis manual presents guidance on
methods that you should use in preparing your Part B permit application to
demonstrate compliance with the general requirements of 40 CFR 264jlisted in
Subparts A through E of that Part. Depending on facility type, these
standards may be supported in different ways. ^Therefore, this manual also
presents guidance on supporting the general standards as a function of
specific facility type.
1.2 PROVISIONS OF THE MANUAL
The information which you are required to submit in the Part B permit
application to demonstrate compliance with the land disposal standards^is
stipulated in 40 CFR 270 which establishes the requirements of the EPA's
permit program for hazardous waste management facilities. The general
information requirements which you must address are contained in §270.14(b) of
that Part. The information required under that section includes:
(1) general facility description
(2) chemical and physical analysis of hazardous wastes to be handled
(3) waste analysis plan
(4) security procedures
(5) inspection plans
*If you are unfamiliar with RCRA and associated regulations and/or conventions
used for referencing them, it is suggested that you refer to Sections 2.0 and
3.0 of this manual for a full explanation.
1-1
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(6) plans for preparedness and prevention
(7) contingency plans
(8) procedures and equipment to prevent or mitigate hazards
(9) precautions taken to prevent ignition or reaction of wastes
(10) planned traffic patterns
(11) facility location information
(12) training programs
(13) facility closure plans
(14) facility deed documentation
(15) closure cost estimates and financial assurances
(16) post-closure cost estimates and financial assurances
(17) insurance policies
(18) coverage by State financial mechanisms
(19) topographic map for the facility and environs.
In this manual, guidance is provided to illustrate means of addressing
the first 12 information requirements as well as the 19th, topographic map
information. Each of the 13 information requirements is addressed
individually. For each one, the information presented includes the applicable
regulatory citations, guidance on achieving the information requirements and
referenced standards, examples of suitable application information, and major
points to address in preparing your application. Guidance on the manifest
requirements noted in Subpart E of Part 264 is also provided.
Although the guidance noted above is the main intent of this manual,
introductory and background information is also included to provide better
understanding of the regulations and the permitting process. Several
appendices which augment the information in the main text are also included.
If you prepare your application in conformance with the guidance presented
here on the general information requirements, it will, at a minimum, expedite
agency review of your application, and should markedly improve the likelihood
of being granted a permit.
1.3 ORGANIZATION OF THE MANUAL
Introductory Sections 2.0 and 3.0 explain the Resource Conservation and
Recovery Act (RCRA), regulations implemented under RCRA, format and use of the
Federal Register, and the RCRA permitting process employed by EPA. In
Section 4.0, we discuss useful sources of information that will assist you in
1-2
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preparing your application and provide an overview of the requirements of
40 CFR Parts 264, 265, and 270. If you are unfamiliar with any of the noted
topics, these sections are essential reading before proceeding to the guidance
presented in Section 5.0.
As noted, you should use the guidance on procedures and methods in
Section 5.0 to prepare those parts of your Fart B application which support
the information requirements of §270.14(b), paragraphs (1) through (12) and
(19). Each information requirement is addressed separately in a subsection of
Section 5.0.
Six appendices are included at the end of the manual to provide
supplementary information such as names and addresses of state and federal
regulatory agencies, and locations where you can request pertinent
documentation, reports, and maps. Other appendix information of a more
technical nature is also included.
1.4 OTHER GUIDANCE MANUALS
Several other guidance manuals exist or are in preparation and will be of
use to you in preparing your overall Part B permit application. These include
RCRA guidance manuals published with the Part 264 standards in July 1982; a
series of Technical Resource Documents which have been prepared over the last
5 years, and other guidance manuals specific to preparing permit applications
in support of the land disposal regulations and specific subparts of those
regulations. Section 4.0 and Appendices A and B provide a list of pertinent
documents, locations where they can be reviewed or purchased, and a synopsis
of each document. It is recommended that you become familiar with the
available literature, because in total, this body of information will be of
great assistance in preparing a permit application.
1.5 PROCEDURES FOR UPDATING AND REVISING THIS MANUAL
This manual is published in loose leaf format to allow for future
updating or revision. When you receive your copy, your name will be kept on
file and the Agency will notify you of the availability of new or amended
pages for incorporation into the manual.
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2.0 THE LAW
2.1 INTRODUCTION
In 1976, the Resource Conservation and Recovery Act was passed by the
Congress to regulate the handling and disposal of hazardous waste. That act,
widely known by the acronym RCRA, mandated the development of regulations
governing the actions of owners or operators who generate, transport, treat,
store, or dispose of solid wastes. Although most readers of this guidance
manual will be aware of RCRA because of the extensive regulations developed
under its authority governing hazardous waste, the Act, in fact, addresses all
solid wastes.
The Congress passed a second Act which addresses the problems associated
with the handling and disposal of solid wastes, especially hazardous wastes.
The "Comprehensive Environmental Response, Compensation, and Liability Act of
1980" (CERCLA) is the Act that established the "Superfund" (called the
Hazardous Substance Response Trust Fund in the Act). This Act, in general,
addresses the release, or imminent release, of hazardous substances to the
environment and the established mechanisms for responding to those releases
and assessing liabilities. As such, Superfund is not applicable to permitting
of hazardous waste management facilities.
The complete texts of RCRA and its associated amendments are too long for
inclusion in this document. The end of this section includes information on
where interested parties may obtain copies of the Act and other related laws
and regulations. Additionally, regulatory citations are included in
Section 5.0 to help define the permit application information requirements.
RCRA, as amended by the Quiet Communities Act of 1978, the Used Oil
Recycling Act of 1980, and the Solid Waste Disposal Act Amendments of 1980,
is, itself, an amendment of Title II of the Solid Waste Disposal Act. The
beginning of the Act and its Table of Contents are shown in Table 2-1.
As Table 2-1 shows, RCRA consists of eight parts, called Subtitles,
identified as A through H. Each Subtitle contains parts called Sections which
are numbered consecutively within each Subtitle. Table 2-1 is actually a
reproduction of Section 1001 of Subtitle A of the Act.
"Subtitle C—Hazardous Waste Management" incorporates 13 sections which
serve as the basis for the development of the hazardous waste regulations
which have been promulgated by the EPA. Subtitle C states what the EPA must
do to govern hazardous waste handling and disposal and provides the EPA with
the authority to carry out the provisions of the Act. Specifically, the
various Sections of Subtitle C of RCRA state that "the Administrator* . . .
shall promulgate regulations . . ." Thus, the Legislative Branch passed a Law
*Defined in Section 1004 of Subtitle A of RCRA as "the Administrator of the
Environmental Protection Agency."
2-1
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TABLE 2-1. THE RCRA TABLE OF CONTENTS
RESOURCE CONSERVATION AND RECOVERY ACT OF 1976,
As Amended by Che Quiet Communities Ace of 1978, the Used Oil Recycling Act
of 1980 and Che Solid Waste Disposal Act Amendments of 1980
An Act
Short Title
Section 1. This Act may be cited as the "Resource Conservation and Recovery
Act of 1976"
AMENDMENT OF SOLID WASTE DISPOSAL ACT
Section 2. The Solid Waste Disposal Act (42 U.S.C. 3251 and following) is
amended to read as follows:
T11LE II - SOLID WASTE DISPOSAL
"Subtitle A—General Provisions
"Short Title and Table of Contents
"Sec. 1001. This title (hereinafter in this title referred to as 'this
Act1), together with the following table of contents, may be cited as the
'Solid Waste Disposal Act':
"Subtitle A—General Provisions
"Sac. 1001. Short title and table of contents.
"Sec. 1002. Congressional findings.
"Sec. 1003. Objectives.
"Sec. 1006. Definitions.
"Sec. 1005. Governmental cooperation.
"Sec. 1006. Application of Act and integration with other Acts.
"Sec. 1007. Financial disclosure.
"Sec. 1008. Solid waste management information and guidelines.
"Subtitle--0ffice of Solid Waste, Authorities of the Administrator
"Sec. 2001. Office of Solid Waste and Interagency Coordinating Committee.
"Sec. 2002. Authorities of Administrator.
"Sec. 2003. Resource recovery and conservation panels.
"Sec. 2006. Grants for discarded tire disposal.
"Sec. 2005. Labeling of certain oil.
"Sec. 2006. Annual report.
"Sec. 2007. General authorization.
"Subtitle C—Hazardous Waste Management
"Sec. 3001. Identification and listing of hazardous waste.
"Sec. 3002. Standards applicable to generators of hazardous waste.
"Sec. 3003. Standards applicable to transporters of hazardous waste.
"Sec. 3004. Standards applicable to owners and operators of hazardous waste
treatment, storage, and diaposal facilities.
"Sec. 3005. Permits for treatment, storage, or diaposal of hazardous waste.
"Sec. 3006. Authorized State hazardous waste programs.
"Sec. 3007. Inspections.
"Sec. 3008. Federal enforcement.
"Sec. 3009. Retention of State authority.
"Sec. 3010. Effective date.
"Sec. 3011. Authorization of assistance to States.
"Sec. 3012. Restrictions on recycled oil.
"Sec. 3013. Monitoring, anslysis, and testing.
(continued)
2-2
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TABLE 2-1 (continued)
"Sulit 11 If II--SIBIP in Ki-H'iinnl hnliil WHP.II- Pimm
"Sec. 4001. Objectives ul subtitle.
"Sec. 4002. Federal guidelines tor plans.
"Sec. 4003. Minimum requirements for approval of plans.
"Sec. 6004. Criteria for sanitary landfills, sanitary landfills required
for all disposal.
"Sec. 4005. Upgrading of open dumps.
"Sec. 4006. Procedure for development and implementation of Stare plan.
"Sec. 4007. Approval of State plan. Federal assistance.
"Sec. 4008. Federal assistance.
"Subtitle E—Outies of the Secretary of Coumeree in Resource and Recovery
"Sec. 5001. Functions.
"Sec. S002. Development of specifications for secondary materials.
"Sec. 5003. Development of markets for recovered materials.
"Sec. 5004. Technology promotion.
"Sec. 3005. Nondiecrimination requirement.
"Sec. 5006. Authorization of applications.
"Subtitle F—Federal Responsibilities
"Sec. 6001. Application of Federal, State, and local law to Federal
facilities.
"Sac. 6002. Federal procurement.
"Sec. 6003. Cooperation with Environmental Protection Agency.
"Sec. 6004. Applicability of solid waste disposal guidelines to executive
agencies.
"Subtitle G--rliscellaneous Provisions
"Sec. 7001. Employee protection.
"Sec. 7002. Citizen suits.
"Sec. 7003. Imminent hazard.
"Sec. 7004. Petition for regulations, public participation.
"Sec. 7005. Separability.
"Sec. 7006. Judicial review.
"Sec. 7007. Grants or contracts for training projects.
"Sec. 7008. Payments.
"Sec. 7009. Labor standards
"Subtitle ({--Research, Development, Demonstration, and Information
"Sec. 8001. Research, demonstrations, training, and other activities.
"Sec. 8002. Special studies, plans or research, development, and
demonstrations.
"Sec. 8003. Coordination, collection, and dissemination of information.
"Sec. 8004. Full scale demonstration facilities.
"Sec. BOOS. Special study and demonstration projects on recovery of useful
energy and materials.
"Sec. 8006. Grants for recovery systems and improved solid waste disposal
facilities.
"Sec. 8007. Authorization of appropriations.
2-3
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to
SfuTaTfons? BUD8equently incorporating them into the Code of FederaT
2.2 THE FEDERAL REGISTER
Branch implements the intentions of Laws passed by the
K" developing —J -*••--
".Publi8hed ev«y Business day by the Federal
.
- descriptions of the
RCRA th8 °f/mplementin8 the Congress' intentions as contained in
-
n th. Feder.! Reei.te,. the EPA announce,
* °'° °£ "icei on" VU a Noti« °
s:
the Federal "d.d"criPtio? of a11 th« types of Notices that EPA published in
engthv Ind ***"*** rel"lv« to the hazardous waste regulations is much too
lengthy and complex to serve any purpose in this document. The EPA began
publishing notices regarding the hazardous waste regulations in 1978 «d
0nt8 "8ulation8 Continue to appear regularly in the
*
readers » °f NOti"8 that "e U™7° *>* of mostaue to
U* ' Rules' and *•«*•«". to
»
Rues Jh. «TU*H '" "T" RuU8' Final Rules' and *•«*•«". t
Rules. The format and purpose of these Notice types are discussed here.
iy.' sr.^ CSLI-VS^ISTS.
, by . (2) 1. the pre.«ble, .nd by . (3) is the text of the .ctull «u.
2-4
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M72
TABLE 2-2. EXAMPLE FEDERAL REGISTER NOTICE
_Foderal Register / Vol. 48. No. 27 / Tuesday. February B. 1983 / Proposed Rules
•NVMONIMNI AC PROTECTION
40 ONI tarfe 182,121 and 264
(•WMLMW-t)
regulatory docket number ai "Section
112.8—Duration of Permits"
The public docket for this proposed
rule Is located in Room S-289C. U.S.
Environmental Protection Agency. 401 M
Street. SW. Washington. D.C.. and is
available for viewing from MO a.m. to
4:00 p.m. Monday through Friday
excluding holidays.
d Operators of Nenrdoue
f Environmental Protection
Agency.
^ •cream Proposed rule.
Amy Mills. Office of Solid Waste (WH-
563). U.S. Environmental Protection
Agency. Weshlngton. D.C 20460. or ceD
(202) 382-4785. or the RCRA Hodine at
(800) 424-9348 or (202) 382-3000.
TMYI
i On February 26.1080 and
May 19.1980. the Environmental
Protection Agency (EPA) published
ragttlsttons which estobliehed a system
to manage hazardous waste. Those
regulations provide the! permits issued
by EPA (end Stoles with suthorisation to
issue permits under the Resource
Conserverlon and Reeovery Act (RCRAJ
for haserdous waste treatment storage
ead disposal neftittos will be effective
foe fixed term aot to exceed 10yeers.
I During the find term. EPA .and /_
autaorfiotf Slates lave Emlted (2
opportanittoi for reopening e permit to
niake chaages I* permit oondltlons.
EPA to today proposing to amend the
regulations to provide that RCRA
and the period of poateasene
Under this
EPA airfldpatss (Hat pMteemn of
human hoalth aad the environment
would norbe effected by this section.
EPA eleo eenmetes that this action
would result in a savings to the
fogatated oommunlty of epproxlmetery
IBM million tf EPA promufestes this
rule ead If Stales with suthorisation to
laeue RCRA permits elect to Issue those
ptmna effective for the designed
operating life of eeoh fedllly plus the
poet-closure period
MTC8: EPA will accept public
commeata on the proposed amendment
until April 11.1983.
AMMMU: Comments should be
eddreessd to the Docket Clerk, Office of
Solid Wests (WH-682). VS.
Bnvironmental Protection Agency.
Washington. D.C 20480.
Communications should Identify the
I. Background
On February 26.1980 and May N.
1980. EPA promulgated "tt"*-"—t
pursuant to the Solid Waste Dispeeel
Act. es emended by the Resource
Conservation and Recovery Act of 199*
(RCRA). es amended. 42 U.S.C. 8901 el
sao. The regulations establish e sfsjtom
to manage hazardous waste, end Include
provisions under which EPA Issnee
.[.permits to owners or operators of
^facilities that treat store or diapooo of
>i haiardous waaU(40CFR Part 128.45 PR
83418).' Section 122.9 of those
reguMone umialn that permit* toseed
to nanrdoui waste management
facilitiee will be effectivefor e fixed
term of 10 yean or less. At the end of
each permit temvthe permittee aaust
•fprj air and reeeive a new pertdt ff he
pans to coattnae hie operation The
purpose) of this foquirement is to assure
eAEOgee toeegnlBlons or eveilaHe
technology are Integrated Into usudto -
one periodic basis.
Tito May~n rule, eleo contain»o
provWon walok-gtves EPA the
opportunfry to revise permit conditions
daring fh»8m of the permit (| SC2.15).
Pot most of the allowable causes far
permit modifications. EPA may asflUto e
change with or without the consent of
the permittee (| I22.15(e) (1). (2),BB*(8)
and 122.15(b]). However, in an atkmpt
to provide permittees with greater
certainty during the, terms of their
permits, the May 19 regulations Bmitod
the cause for permit modifications
resulting from changes to EPA
regulations to instances when
•TIM ROM pnnllilnf raqulmamu •»
eoaliliwd In BPA't cattolldttod pwmli
oHflMUy pramul(il«l oo fcUy n. 1SSO
InWCnPwum-lM •nwniquUaonBn*
bMn ooallnuoaly rappl«BaMd tnd tmmtit Th»
•ml tmportwil unmdamti oocumd on taauiry
111SS1. whn EPA proaralvitad pmiitUB
ratuUtton (or tlanf nd bvsMml fadOih* fas
PR entk oo iraMiy a. tan. wkoa EPA
proau||oi«d pnrallllnt rafnUHaai far toalBOMon
|4S PR rSBS): ud July IS. 1SS1. vhn EPA
pronwlBitad pmlttni nfuUllon for Und
bdllUo* (4T PR 1104)
modification Is requested by the
permittee (J 122 l6(a)(3))
EPA has re-examined the maximum
10-year permit term and its implications
for both the regulated community and
the Agency. The subject erase In recent
negotiations in a lawsuit involving the
consolidated permit regulations (NRDC
v SPA. No. 80-1807 end consolidated
cases. D.C. dr.. filed June 2.1980).'The
petitioners in that case claimthat the
current regulations unreasonably require
EPA to repeatedly review an entire
facility's operation every 10 years or
leee. and reopen end re-evaluate aD of
the fasues which were resolved when
the? Initial permit wee Issued. Some
nwilUies era designed to operate 30
yeers or more: thus, under the currant
regulations en entire facility may be re-
eweluqted three or more times during Its
operating life. Theae extensive re-
evaluations would proceed regardless of
whether there hed been eny substantive
eJsuges in the fedllty's design or
operation, or In the regulations on which
It* Initial permit had been baaed.
The petitioners further claim that
sepeattng the permit eppUcaUon process
•wry 10 yean or less can lose a
•ejolRoant burden to the regulated
eeanmunlty. Pint, then can be a
substantial monetary burden aeeodeted
with the extensive paperwork Involved
In epplying for a permit Second, the 10-
year permit presents disadvantages to
fte hdaty owner who may plan to
oporato kr more then 10 yeers but can
only obtain approval for his facility for
•years el e tune.
BPA agreee that the curent llmi] to
peonit duration can pose certain
•BBdvaatagee to the regulated
OBmmonlty. The Agency also finds that
•er procedures for issuing permits. I.e..
Bsjriewing each permit epplication.
p«sparing a draft permit, providing en
opportunity for public hearing, and
preparing a final permit can be very
SBBt-consuming and resource-Intensive
ferine Agency. Under the current
•BjeJattou. EPA would neve to repeet
•sese procedures at teest once every 10
•ease for each fadllty.
EPA wtahes to evoid the unnecessary
expiration and relsauanee of permits et
alMtrary intervals of 10 years or less
aad the attendent costs and paperwork
hardens. At the same time, the Agency
believes II must melntein some oversight
ef the operation of e fadllty during the
tent) of its permit. Therefore. EPA is
today proposing en approach which
r •xpbnaiion of Iht praecdunl
I ol *• NRDC t SPA rait. MO Ik* prunbb
MBScal uwndnwnu tt SBCPR Pirn 112
•ad let ta DM April a. isai r«dml Roglok* |47 PS.
IISSS)
2-5
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5878
TABLE 2-2 (continued)
Federal Register / Vol. 48. No. 27 / Tuesday. February B. 1983 / Proposed Rules
years or less. The Agency believes that
this Is not the type of regulation revision
that Congress had In mind when It
provided a delay between the
promulgation and the effective date of
revisions to regulations. Therefore, the
Agency plans to make these
amendments effective Immediately If
and when they ere promulgated In final
form, but requests comments on whether
such action would cause hardship for
the regulated community or otherwise
be Inappropriate.
Compliance With Executive Order 12281
Under Executive Order 12281. EPA
must Judge whether a regulation Is
"major" and therefore subject to the
requirement of e Regulatory Impact
Analysis. This proposed regulation Is
not major because It will not result in an
effect on the economy of 9100 million or
more, nor will It result In an increase In
costs or prices to industry. Then would
be no adverse Impact on the ability of
UA-beaed enterprises to compete with
foreign based enterprises In domestic or
export eurkets. Because this
amendment Is not a major regulation, no
Regulatory Impeet Analysis Is being
conducted.
Tbeee esMndments ware submitted to
the OHJce of Management and Budget
for review as required by Executive
Order 12291. Any comments from OMB
to BPA aad any response to those
comments era available for viewing at
the Oflloe of Solid Waste docket. Room
B-268C, U4. BJ>.A.. 401M St. SW.
Washington, D.C. 20460.
i Tack Force OB Regulatory
Regulatory Flexibility Act
Under the Regulatory Flexibility Ai.t. S
U.S.C. 601 at seq.. Federal agencies must
prepare a regulatory flexibility analysis
for all proposed rules to assess their
Impact on small entitles No regulatory
flexibility analysis (inquired, however.
where the head of the agency certifies
that the rule will not have a significant
economic impact on a substantial
number of small entities.
The economic impact of this
regulation would be to reduce the costs
of complying with EPA's hazardous
waste management regulations for
owners snd operators of hazardous
waste management facilities (including
those which era small entities)
Accordingly. I hereby certify, pursuant
to B U.S.C. eOl(b), that this proposed rule
would not have a significant economic
Impact on a substantial number of small
entitles.
List of Subjects
40 CFR Port 122
Administrative practice and
procedure. Air pollution control.
Confidential business Information.
Hazardous materials. Reporting and
recordkeeping requirements. Waste
treatment and disposal. Water pollution
control. Water supply.
40 CFR Port 123
Confidential business information.
Hazardous materials. Indian lands.
Intergovernmental relations.' Penalties, ^
Reporting and recordkeeping
requirements, Waste treatment and
disposal. Water pollution control. Water
supply.
40 CFR Port 264 e
USC 1Z51 el ieq. Clean Air Act 42 U S C
1857 el arq
2 Section 122 9 is amended by
fpvmng paragraphs (b) and (e) to read
as follows.
1122.9 Duration of permits.
,„,„„,„„, and disposal
Deled' January 26.1983
AaaeM-Conucb,
Admimttrator
The President's Task Force on
Regulatory Relief designated the
ConsolidatedI Permit Regulation. (40 O Harardou8 malena|§. |n8urance.
CFR Parts 122-124) for review by EPA. Z packaging and container,. Reporting
TMspropoe^ei^rtsibejoalsorthe ™ Jind r/cordkeeping requirements. u
Teak force by reducing burden on the A s^^y mea.urei. Surety bond.. Waste"! • «*•«
regulated communlty.Thls proposal also ,„.,„/„, and di.nosal T "•«••"•"
fulfills BPA's obligations In the
settlement of Industry litigation on the
Consolidated Permit Regulations. In
addition to settling the litigation, the
Agency also plans to:
• Propose other aubstantlve changes
to further streamline the Agency's
permitting process, and
• Deconsolldate the regulations to
make them more-aaslly usable by the
(b) RCRA. Except as provided in
paragraph (e) of this section and
1122.30. RCRA permits shall be
effective for the fixed term of the
designed operating life of the facility (in
the case of an new facility) or the
remainder of the designed operating life
of the facility (In the case of an existing
facility). For land disposal facilities, the
term of RCRA permits shell include the
post-closure care period or compliance
period, whichever is longer. In addition
to the designed operating life of the
facility The designed operating life of
the facility is the period of time.
estimated by the owner or operator and
approved by EPA. for which the facility
is designed to operate, and during which
operation is expected to continue The
estimate should reflect consideration of
the construction materials of the facility.
the volume and type of waste the facility
expects to handle, and the processes the
facility will employ.
(e) The Regional Administrator mey
Issue any NPDES. UIC or 404 permit for
a duration that Is less than the full
allowable term under this section, for
RCRA permits only, the Regional
Administrator may issue e permit for a
duration that Is less than the full
allowable term under this section only
when the permit applicant so requests
3 Section 122.15 is amended In
paragraph (a)(3) by revising the
introductory text and paragraph
(a)(3)(i)(A) and adding paragraph
(a)(7)(ix) to read as follows-
It is proposed that Title 40 of the Code
of Federal Regulations be amended as
follows.
_
public. 3
As a result of deconsolldatlon. then will
be some reorganization of the
regulations. Thus, this proposed
amendment may be finalised In a
different format and location than It
appears In the currant regulations and
the settlement agreement
PART 122— EPA ADMINISTERED
.PERMIT PROGRAMS: THE
IAZARDOU8 WASTE PERMIT
'PROGRAM
1. The authority citation for Part 122
reads as follows:
Authority: Resource Conservation and
Recovery Act. a. amended. (RCRA). 42 U S C
6901 el M« .: Sate Drinking Water ACL 42
U.8.C. SOOf el MQ.: Clem Water Act. S3
(.«)••'
(3) New Regulations. The standards or
regulations on which the permit was
based have been changed by
promulgation of new or amended
standards or regulations or by judicial
decision sfter the permit was issued
I Permits for RCRA facilities and UIC
vClass 11 or III wells may be modified
during their terms for this cause without
following the conditions of paragraphs
(a)(3)(i) and (II) of this section. All other
permits may be modified for this cause
only es follows.
(i) For promulgation of emended
standards or regulations, when:
(A) The permit condition requested 10
be modified was based on a
2-6
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The heading of the Notice supplies some identifying and descriptive
information. As shown in Table 2-2, this particular notice has been published
by the EPA, the regulations affected by the Notice are identified (40 CFR
Parts 122, 123, and 264) and a descriptive title of the programs addressed is
provided (Hazardous Waste-Management System; the Hazardous Waste . . .).
Importantly, the type of Notice is identified; in this case, "Action:
Proposed Rule". The type of Notice can always be identified by the phrase
next to "Action:" in the heading. Other phrases typically used are:
Final Rule
Interim Final Rule
Proposed Amendments
Amendments to Final Rule
Interim Final Amendments
Any phrase used in the heading of a Notice that contains the words Rule or
Amendment and does not include the word Proposed, means that the Notice is
promulgating a new, or changed, regulation. This is important since all
persons affected by the regulation in the Notice will have a finite time
period to comply with that regulation and that time period often begins on the
date the Notice is published in the Federal Register. Proposed Rules and
Amendments are published to inform the public of their content and these types
of Notices usually establish a time period during which the public is invited
to comment on the Proposed Rules and Amendments.
The preamble of the Notice contains a significant amount of information.
It begins with a summary of the action being taken. It will also contain
dates, addresses, and contacts for additional information. The major portion
of the preamble contains information explaining the purpose and intent of the
regulations, why they are written as they are, who or what they are intended
to affect, and other information used in support of and as a basis for the
regulations. The preamble is always written in "non-regulatory" language and,
most importantly, although it explains the intent of the regulatory language,
nothing in the preamble carries the force of the law.
As shown in Table 2-2, the preamble will always conclude with the date
and name of a high-ranking EPA official. The preamble is then followed by the
text of the actual regulations as either proposed or promulgated. This part
of the Notice is very important because it contains the regulations as they
will read when they become effective after promulgation as a final rule. When
promulgated they become part of the Code of Federal Regulations (CFR) and
carry the full force of the law.
A discussion of the organization and format of the CFR follows. However,
at this point a description of the organization of the Federal Register will
assist those who wish to locate any specific Notices pertaining to hazardous
waste which have been or will be published.
As mentioned earlier in this discussion, the Federal Register is
published every business day, except Federal holidays, throughout the year.
All of these daily documents are part of a single "Volume" of the Federal
2-7
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Register for a specific calendar year. For example, all of the daily issues
of the Federal Register published during 1983 are part of the "Volume 48 of
the Federal Register"." Volume 47 of the Federal Register is comprised of all
daily issues of 1982 and so on.
Each volume of the Federal Register is consecutively page numbered and
each daily issue receives a consecutive number. This numbering system is most
easily explained by reference to the example page from the Federal Register in
Table 2-2. Across the top of that reproduced page is the following heading:
"5872 Federal Register/Vol. 48, No. 27/Tuesday, February 8, 1983 Proposed Rules."
That heading indicates that the daily issue of the Federal Register from which
that page was copied was published on Tuesday, February 8, 1983; it is the
27th daily issue published in 1983; it is part of Volume 48 (the 1983 volume);
it is from the Proposed Rules section of that day's issue; and it is page
5872. The accepted notation for identifying this page for reference purposes
is 48FR5872. However, since that notation does not identify which daily issue
that page is contained in, the date is often included, i. e., 48FR5872
(2/8/83). The use of this notation is exemplified in footnote 1 at the bottom
of the center column in the example Federal Register page.
2.3 THE CODE OF FEDERAL REGULATIONS
The Code of Federal Regulations, often denoted by the acronym CFR, is the
compilation of all regulations in effect in the United States. The full text
of every regulation promulgated by all Federal government agencies is included
in the CFR.
The regulations are grouped under "Titles" in the CFR and each Title is
divided into "Chapters". The hazardous waste regulations can be found in
"Title 40-Protection of Environment, Chapter I-Environmental Protection
Agency". Title 40 is generally identified or annotated as "40 CFR".
Each Chapter of Title 40 is divided into numerous "Parts". Each Part is
further divided into "Subparts". The Subparts are comprised of "Sections" and
each Section consists of numerous "paragraphs".
"Parts" of 40 CFR are always identified by the word Part followed by a
number in Arabic numerals i.e., Part 260. The Parts of a Chapter of a Title
are numbered consecutively within the Chapter. Parts are also identified by
the notation 40 CFR 260. That notation means "Part 260 of Title 40 of the
Code of Federal Regulations." A list of the Parts in Chapter I of Title 40
which deal with hazardous waste are listed in Table 2-3.
Each Part is divided into Subparts. Subparts are identified by the word
Subpart followed by an upper case alphabetic character, i.e., Subpart A. The
first Subpart of a Part is always "A", the second "B", and so on. There can
be as many Subparts as necessary in a Part to properly organize and present
informaton.
2-8
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TABLE 2-3. PARTS OF TITLE 40 OF THE CFR REGARDING PERMITTING AND HAZARDOUS
WASTE HANDLING AND DISPOSAL
Part
Title
Notation
260
261
262
263
264
265
266
267
270
271
124
Hazardous Waste Management 40CFR260
System: General
Identification and Listing of 40CFR261
Hazardous Waste
Standards Applicable to Generation 40CFR262
of Hazardous Waste
Standards Applicable to 40CFR263
Transporters of Hazardous Waste
Standards for Owners and Operators 40CFR264
of Hazardous Waste Treatment,
Storage, and Disposal Facilities
Interim Status Standards for Owners 40CFR265
and Operators of Hazardous Waste
Treatment, Storage, and Disposal
Facilities
Reserved 40CFR266
Interim Standards for Owners and 40CFR267
and Operators of New Hazardous
Waste Land Disposal Facilities
EPA Administered Permit Programs: 40CFR270
The Hazardous Waste Permit Program
Requirements for Authorization of 40CFR271
State Hazardous Waste Programs
Procedures for Decisionmaking 40CFR124
2-9
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Each Subpart ie comprised of Sections which are designated by the symbol
"§" followed by a number in Arabic numerals, i.e., §260.135. The number which
follows the Section symbol always has a decimal point. The Arabic numerals to
the left of the decimal point always identify the Part that the Section is
included in and the Arabic numberals to the right of the decimal are a
consecutive series within each Part. For example, §264.15 is the fifteenth
Section of Part 264 and §264.198 is the one-hundred and ninety-eighth Section
of Part 264.
The numbering of Sections within a Part has no correlation to the Subpart
in which the Section may appear. For example, §261.30 is the thirtieth
Section of Part 261 and appears in Subpart D of Part 261, but §264.30 is the
thirtieth Section of Part 264 and it appears in Subpart C of Part 264. As
noted above, Sections are numbered consecutively within each Part, beginning,
for example, with §260.1 (the first Section of Part 260), and proceeding to as
high as §260.999.
Within each Section, each and every paragraph is identified by alphabetic
or numeric characters in outline format. The outline format used is:
(a) lower case alphabetic
(1) Arabic numerals
(i) lower case Roman numerals
(A) upper case alphabetic
(1) italic Arabic numerals
The outline format is started from the beginning in each Section. The term
"Subparagraph" is not used. The designation §260.11(a)(2)(iv) is called
paragraph (a)(2)(iv) of Section 260.11. The parentheses are always used in
paragraph designation.
In addition to Subparts, a Part may have one or more Appendices. These
Appendices are identified by either upper case alphabetic characters or upper
case Roman numerals and a title. All Appendices of the Parts listed in
Table 3 use upper case Roman numerals, i.e., Appendix I - Representative
Sampling Methods (the first Appendix of Part 261). There is no formalized or
required organizational format for Appendices of a Part. They are organized
internally as best suits the material each contains.
2.4 AVAILABILITY OF COPIES
Applicants may find it useful to refer to copies of the Act (RCRA), the
Federal Register (FR), and the Code of Federal Regulations (CFR). These
documents are available to the public and readers of this manual are
encouraged to obtain them.
One should start by calling the RCRA Hotline in Washington, DC. Guidance
is offered as to which documents may be appropriate and which are currently
available. Appendix A lists the Hotline number.
2-10
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Copies of the RCRA might be obtained free of charge through the Regional
EPA offices. Appendix A lists the addresses and telephone numbers of the
branch of each Regional office which may be able to provide a copy of the
Act. As the authority for RCRA has been delegated to each state, the
availability of these copies has become increasingly limited.
State agencies may be another source where copies of RCRA may be obtained
free of charge. The addresses and telephone numbers of the appropriate agency
in each state is given in Appendix A.
Copies of the Act, the Federal Register, and the Code of Federal
Regulations may be purchased from the closest Governmental Printing Office
(GPO) bookstore. A list of these has been provided in Appendix A. The GPO
bookstores are the only available source of the FR and CFR to the public.
Should these documents be unavailable through the closest bookstore, they may
be ordered through the Superintendent of Documents office in Washington, DC.
In addition to the sources given in Appendix A, there are a variety of
locations where copies of these documents may be available. The Regional EPA
library should have all documents pertinent to RCRA and many University and
Public libraries also have copies of these documents. Many large companies
subscribe to the Federal Register and might make copies available to smaller
businesses in their area. The current (1983) subscription cost for 1-year of
the Federal Register is $300. Subscriptions are available from the GPO in
Washington, D.C.
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3.0 THE PERMITTING PROCESS
3.1 INTRODUCTION
There are two Parts of Title 40 of the Code of Federal Regulations that
contain information on the RCRA permitting process. Part 270 contains
information on what an applicant and the EPA must do regarding a permit. That
Part contains basic permitting requirements for EPA-administered RCRA
programs, such as application requirements, standard permit conditions, and
monitoring and reporting requirements. Part 124 establishes the
decisionmaking procedures for EPA issuance of RCRA permits. That Part also
establishes the procedures for administrative appeals of EPA permit decisions.
This section of the manual presents a simplified description of the major
steps that must be taken by both an applicant and the EPA during the RCRA
permitting procedure. It also identifies those Parts of Title 40 that are
of importance to an owner or operator seeking a RCRA permit.
The overall RCRA permitting process can be summarized into the following
steps:
Step 1. The owner or operator of a hazardous waste management facility
completes Parts A and B of a RCRA permit application and
submits the application to the appropriate EPA office.
Step 2. The EPA reviews the application for completeness. If
incomplete, the EPA sends a list of deficiencies, in writing,
to the applicant. If complete, the applicant is so informed in
writing.
Step 3. When necessary, the applicant prepares and submits the
additional information requested.
Step 4. If not done in Step 2, the EPA reviews original and additional
submittals and notifies the applicant in writing of the
completeness of the application. The date that the EPA makes
this notification is the effective date of the application.
Step 5. The EPA reviews the application and either prepares a draft
permit or issues a notice of intent to deny the application.
In either case, the EPA simultaneously prepares and issues a
statement of basis or a fact sheet.
Step 6. The EPA sends copies of the documents in Step 5 to the
applicant and others, and simultaneously makes a public notice
that they have been.prepared. The public notice will provide
45 days for public (or applicant) comment.
3-1
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Step 7. If at the time of public notice, or at any time during the 45
day comment period, anyone, including the EPA, requests a
public hearing, one will be scheduled and announced a minumum
of 30 days before the scheduled date.
Step 8. The EPA prepares and issues a final permit decision.
These eight steps are a simplified description. The overall process is
presented in more detail in Figure 3-1 and a full description of the steps
which EPA must take after receiving a complete RCRA permit application is
contained TrTJJubpart A of Part 124 in §§124.3 through 124.21.
3.2 THE PERMIT APPLICATION AND THE PERMIT
The RCRA permit application consists of two parts; a Part A, which is a
form requiring completion, and a Part B, which is not a form. This manual is
designed to assist applicants in preparing the informational submittal which
is the Part B of an application for a RCRA permit.
Part 270 of Title 40 of the CFR provides the informational requirements
necessary for a complete RCRA permit application (Part A and Part B). All of
the Sections of Subpart B of Part 270 should be read and understood by any
owner or operator who is applying for a RCRA permit for the first time.
The actual permit will consist of written approval of the contents of the
complete permit application. It will require the applicant to adhere to all
statements made in the application and will also include conditions which must
be complied with in addition to the application statements. Applicants
interested in the types of conditions that may be contained in a permit are
referred to §270.30-"Conditions applicable to all permits" and
§270.32-"Establi8hing permit conditions."
3.3 WHERE TO SUBMIT APPLICATIONS
Table 3-1 lists the mailing addresses and the telephone numbers of the
EPA offices in each of the ten EPA Regions where permit applications should be
submitted. Personnel in these offices should be contacted with any questions
that may arise during preparation of a permit application.
Many states have their own hazardous waste permitting program. Their
programs may be in addition to or in lieu of the EPA RCRA program. State
program offices are listed in Appendix A. Any applicant who is unsure of
which agency an application should be submitted to should contact the Regional
EPA office (Table 3-1) for clarification.
3.4 CONFIDENTIALITY
An applicant may find it necessary, or may be required, to include
confidential information in an application. All applicants are referred to
§270.12-"Confidentiality of information" in Subpart B of Part 270. Of
particular note are the items in §270.12(b) which cannot be claimed as
confidential.
3-2
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REQUEST
FOR RCRA
PART 8 FROM
EXISTING
FACILITY
IF OMISSIONS
OR DEFICIENCIES
ARE NOTED, ISSUE
NOTICE OF
DEFICIENCY
EPA RECEIVES
AND LOGS IN
. PART B
COMPLETENESS
CHECK
TECHNICAL
EVALUATION
PREPARATION
OF DRAFT
PERMIT
STATEMENT OF
BASIS OR
FACT SHEET
ADMINISTRATIVE
RECORD
PUBLIC NOTICE
OF DRAFT
PERMIT, COMMENT
PERIOD, AND
HEARING
PUBLIC
COMMENTS;
REQUESTS
FOR PUBLIC
HEARING
NEW STATEMENT OF BASIS; FACT SHEET; OR DRAFT PERMIT
ISSUANC
OF FINAL
PERMIT DEC.:
RESPONSE TO
COMMENTS
ADMINISTRATIVE
RECORD
PUBLIC
NOTICE OF
HEARING.
EXTENSION OF
COMMENT
PERIOD
Figure 3-1. Flow diagram of the EPA's RCRA permitting process.
CLOSE OF
COMMENT
PERIOD
(UNLESS
HEARING TO
BE HELD)
DtCISIO
ON REQUEST
FOR HEARING
-------
TABLE 3-1. EPA REGIONAL HAZARDOUS WASTE PROGRAM OFFICES
Region I:
Region II:
Region III:
Region IV:
Region V:
Region VI:
OFFICE OF THE DIRECTOR
State Waste Programs Branch
Waste Management Division
John F. Kennedy Federal Building
Boston, MA 02203
(617) 223-6883
OFFICE OF THE DIRECTOR
Solid Waste Branch
Air and Waste Management Division
26 Federal Plaza
New York, NY 10007
(212) 264-0505
OFFICE OF THE DIRECTOR
Waste Management Branch/RCRA Permit Section
Air and Waste Management Division
Curtis Building, 6th and Walnut Streets
Philadelphia, PA 19106
(212) 597-9118
OFFICE OF THE DIRECTOR
Residuals Management Branch/Waste Engineering Section
Air and Waste Management Division
345 Courtland Street NE
Atlanta, GA 30308
(404) 881-3433
OFFICE OF THE DIRECTOR
Waste Management Branch
Waste Management Division
Federal Building
230 South Dearborn
Chicago, IL 60604
(312) 886-7579
OFFICE OF THE DIRECTOR
Hazardous Materials Branch
Air and Waste Management Division
First International Building
1201 Elm Street
Dallas, TX 75270
(214) 729-2645
(continued)
3-4
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TABLE 3-1 (continued)
Region VII: OFFICE OF THE DIRECTOR
Waste Management Branch
Air and Waste Management Division
1735 Baltimore Street
Kansas City, MO 64108
(816) 758-6536
Region VIII: OFFICE OF THE DIRECTOR
Waste Management Branch
Air and Waste Management Division
Suite 900, 1860 Lincoln Street
Denver, CO 80203
(303) 837-6238
Region IX: OFFICE OF THE DIRECTOR
Programs Branch
Toxics and Waste Management Division
215 Fremont Street
San Francisco, CA 94105
(415) 974-7411/974-8391
Region X: OFFICE OF THE DIRECTOR
RCRA Branch
Air and Waste Management Division
1200 6th Avenue
Seattle, WA 98101
(206) 399-2782
3-5
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To assert a claim, the provisions of 40 CFK 2 require that the applicant
must attach a cover sheet to the information, or stamp or type a notice on
each page of the information, or otherwise identify the confidential portions
of the application. Words such as "trade secret", "confidential business
information", "proprietary", or "company confidential" should be used. The
notice should also state whether the applicant desires confidential treatment
only until a certain date or a certain event.
Whenever possible, the applicant should separate the information
contained in the application into confidential and nonconfidential units and
submit them under separate cover letters. Claiming confidentiality for a
large portion of the information in the permit application and failing to
separate the application into confidential and nonconfidential units may
result in significant delays in processing the permit application because the
EPA lacks the in-house resources for expeditiously isolating the confidential
information from the nonconfidential items.
If it becomes necessary to send confidential information through the
mail, the applicant should consider the following precautions in addition to
those in $270.12.
I. Place the material in a sealed envelope or container and
conspicuously mark that envelope or container as containing
confidential information.
2. Place the sealed, marked envelope or container inside an outer
envelope or container which is properly addressed but not marked as
confidential and seal this outer envelope or container.
3. Mail (or otherwise ship) the material with return receipt (or
equivalent) requested.
The EPA is not liable for release of information which an applicant has
submitted, but failed to identify as confidential. Additional information on
the EPA1s handling of confidential information can be found in Part 2 of
Title 40 of the CFR.
3.5 APPEALS
It is possible to appeal the contents of a final RCRA permit. The
procedure for petitioning the EPA to review any condition of a permit decision
is contained in §124.19-"Appeal of RCRA, UIC, and PSD permits." In addition,
the EPA can decide on its own initiative to review a final permit. In either
case, a petition or decision to review a final permit must be made within 30
days after a RCRA final permit decision has been made under §124.15.
3-6
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4.0 OVERVIEW OF PARTS 270 AND 264 AND USEFUL INFORMATION SOURCES
4.1 INTRODUCTION
This section provides an overview of Parts 270 and 264 and discusses
sources of information that may be useful to the permit applicant. An
overview of Parts 270 and 264 is presented because this manual does not
provide guidance on all of the information you must develop, compile and
submit in Part B of your permit application. The overview identifies what
requirements are discussed here and discusses how these relate to other
requirements in the regulations. Sources of additional information are
provided to identify where you can get answers to specific questions which may
arise during application preparation.
The guidance provided later in Section 5.0 is intended to provide you
with a discussion and examples of the information content and detail that the
Agency expects in your Part B submittal. There is no specific format for
Part B, but in some cases, example formats are presented for your
consideration. The majority of the discussion has been developed based on
research of referenced documents and reports, familiarity with the preamble
discussions presented in Federal Register promulgations of these regulations,
and extensive discussions with EPA personnel.
4.2 OVERVIEW OF PARTS 270 AND 264
On April 1, 1983, the EPA established, by publication in the Federal
Register, Part 270 of Title 40 of the Code of Federal Regulations. That new
Part (see 48FR14146, 4/1/83) is titled "EPA Administered Permit Programs: The
Hazardous Waste Permit Program". That Part was established to gather all the
requirements applicable to RCRA permits into one location in the CFR.
Information now contained in Part 270 was scattered throughout Part 122. The
April 1, 1983 Federal Register contains a cross-reference index of RCRA
related sections in Part 122 that correspond to the new Part 270 sections at
48FR14152.
The regulations in Part 270 present the basic EPA permitting requirements
for a RCRA permit. Permit application requirements, standard permit
conditions, and monitoring and reporting requirements are all presented in
Part 270. Subpart B of Part 270 is titled "Permit Application". The sections
in that Subpart identify all the items of information that must be submitted
with a permit application. Section 5.0 of this manual focuses on the general
information requirements that must be contained in Part B of a permit
application. These requirements are contained in §270.14. Additional
facility-type specific information requirements are contained in §§270.15
through 270.21.
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In addition to the requirements in Part 270, separate technical
permitting regulations are stipulated in Part 264. The Part 264 regulations
establish minimum Federal standards which define the acceptable management of
hazardous waste. The text of Part 270 refers the reader to the sections of
Part 264 which contain the standards that a permit applicant must demonstrate
compliance with by submittal of information in Part B of a permit
application. Section 5.0 of this manual addresses 14 of the required
informational items identified in Part 270, identifies the corresponding
standards in Part 264, and provides guidance on how to obtain, prepare, and
present information required by part 270 that will demonstrate to the EPA that
the facility complies with the Part 264 standards.
4.3 INFORMATION SOURCES
4.3.1 Document s/Report s
(a) RCRA Technical Guidance Documents
Each Regional office of the EPA should have available in their
library a series of guidance documents which are directly related to
the Part 264 regulations governing land based storage, treatment,
and disposal facilities. Currently, there are four Technical
Guidance Documents available:
(1) "Surface Impoundments - Liner Systems, Final Cover, and
Freeboard Control".
(2) "Waste Pile Design - Liner Systems".
(3) "Land Treatment Units".
(4) "Landfill Design - Liner Systems and Final Cover"
These volumes may be ordered from the Government Printing Office,
through a local GPO bookstore, or from the Superintendent of
Documents Office listed in Appendix A.
The purpose of the Technical Guidance Documents is to present
details of design concepts that the EPA believes will satisfy the
Part 264 standards (for surface impoundments, waste piles, land
treatment units, and landfills). A few contain examples of various
unit designs, and as more information is acquired, more models will
be included. In all likelihood, a facility meeting these design
requirements should qualify for a draft permit.1
Appendix B contains a synopsis of each of the Technical
Guidance Documents.
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(b) Technical Resource Documents (TRDs)
Eight Technical Resource Documents have been developed (as of
May 1983) to assist the regulated community and the permitting
authorities. In contrast to the Technical Guidance Documents, the
TRDs are not directly related to the Part 264 regulations. The
current Technical Resource Documents are:
(1) "Evaluating Cover Systems for Solid and Hazardous Waste"
(SW-867); GPO Stock f; 055-000-00228-2.
(2) "Hydrologic Simulation on Solid Waste Disposal"
(SW-868); GPO Stock #; 055-000-00225-8.
(3) "Landfill and Surface Impoundment Performance Evaluation"
(SW-869); GPO Stock #; 055-000-00233-9.
(4) "Lining of Waste Impoundments and Disposal Facilities"
(SW-870); GPO Stock f; 055-000-00231-2.
(5) "Management of Hazardous Waste Leachate"
(SW-871); GPO Stock #; 055-000-00224-0.
(6) "Guide to the Disposal of Chemically Stablilized and
Solidified Waste"
(SW-872); GPO Stock #; 055-000-00226-6.
(7) "Closure of Hazardous Waste Surface Impoundments"
(SW-873); GPO Stock #; 055-000-00227-4.
(8) "Hazardous Waste Land Treatment"
(SW-874); GPO Stock #; 055-000-00232-1.
These documents are intended to serve as a resource for the
applicant and present the most current state-of-the-art in
technologies and methods for evaluating the performance of a
disposal facility design. A synopsis of each of the TRDs is
presented in Appendix B.
The EPA plans to update these documents to reflect the latest
information, and also plans to introduce several new documents
dealing with related topics including:
(9) "Evaluation of Closure and Post-Closure Care Plans for
Hazardous Waste Landfills".
(10) "Soil Properties, Classification, and Hydraulic
Conductivity Testing".
(11) "Solid Waste Leaching Procedure Manual".2
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(c) Other Guidance Manuals
There exist several other publications which deal with topics
specific to land disposal. These are also available from the GPO in
the locations given in Appendix A. The other available guidance
manuals are:
(1) "Test Methods for Evaluating Solid Wastes" (SW-846)
(2) "A Method for Determing the Compatibility of Hazardous
Wastes" (EPA-600/2-80-076)
(3) "Handbook for Remedial Action at Waste Disposal Sites"
(EPA-625/6-82-006)
(4) "Permit Writer's Guidance Manual for Subpart F" (Prepared
by GeoTrans; currently in draft form)
(5) "Ground-Water Monitoring for Owners and Operators of
Interim Status Facilities" (SW-963)
(6) "Financial Assurance for Closure and Post-Closure Care:
Requirements for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities - A Guidance
Manual" (SW-955)
(7) "Liability Coverage: Requirements for Owners or Operators
of Hazardous Waste treatment, Storage, and Disposal
Facilities - A Guidance Manual" (SW-961)
(8) RCRA Personnel Training Guidance Manual September 1980
(Updated version available May 1983)
(9) Regional Guidance Manual for Selected Interim Status
Requirements - September 22, 1980
(10) Draft Guidance for Subpart G of the Interim Status
Standards - October 6, 1981
(11) Draft Guidance for Subpart H of the Interim Status
Standards, August 29, 1980
(12) Guidance Manual for Evaluating Permit Applications for the
Operation of Hazardous Waste Incineration Units
(13) Guidance Manual for the Closure of Hazardous Waste Surface
Impoundments - May 1980
(14) Guidance Document for Subpart F—Ground Water Protection
(15) Guidance Document for Evaluation and Monitoring of Toxic
Air Emissions from Land Disposal Facilities
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(16) RCRA Inspection Manual3
Appendix B also presents a synopsis of some of these documents,
4.3.2 Regional EPA Offices and State Offices
Permit applicants may purchase or study library copies of any of the
Technical Resource Documents or the other guidance manuals described in the
preceding section. Information regarding these documents, as well as any
matter of technical guidance in the RCRA permitting process, is readily
available at the EPA Regional offices and the state waste management program
offices which are listed in Appendix A, and users of this manual are
encouraged to contact them.
4.4 REFERENCES
1. Draft Report: Permit Applicants Guidance Manual for Landfills,
Surface Impoundments, Land Treatment and Waste Piles. Prepared by
the U.S. EPA. p. 32.
2. Ibid, p. 34.
3. Ibid, pp. 37-39.
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5.0 GUIDANCE FOR PERMIT APPLICATION PREPARATION
This manual is specifically intended to assist permit applicants in
addressing the general requirements for a Part B RCRA permit application.
Those requirements are all found in §270.14 of Subpart B of Part 270. The
permit application information requirements Ln §270.14 identify the specific
Part 264 technical requirements with which an applicant's facility must
comply. That compliance must be demonstrated by the information submitted in
the Part B application. Table 5-1 shows the Part 270 requirements for which
guidance is supplied in this manual and identifies corresponding Part 264
standards for which guidance is also supplied. In addition to the Part 270
requirements identified in Table 5-1, this manual provides guidance relative
to the Part 264, Subpart E manifest system, recordkeeping, and reporting
requirements. Additional recordkeeping and reporting requirements can be
found in §§270.30(j), (1), and 270.31.
In this section of the manual, each of the identified Part 270
requirements is separately addressed. The discussion of each of the
requirements includes the wording of the specific regulatory citations, an
explanation of the intent of the requirement, and guidance and examples of how
applicants can demonstrate compliance with permitting and technical
requirements in their RCRA Part B permit applications.
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TABLE 5-1. SECTIONS OF PARTS 270 AND 264 ADDRESSED IN THIS MANUAL
Part 270 Sections
Corresponding Part 264 Sections
§270.14(b)(l) Facility Description
§270.14(b)(2) Waste Analysis
§270.14(b)(3) Waste Analysis Plan
§270.14(b)(4) Security
§270.14(b)(5) Inspection Schedule
S270.l4(b)(6) Preparedness and
Prevention
§270.14(b)(7) Contingency Plan
§270.14(b)(8) Prevention Equipment
§270.14(b)(9) Ignition/Reaction
Precautions
§270.14(b)(10) Traffic Control
§270.14(b)(ll) Location Information
§270.14(b)(12) Personnel Training
§270.14(b)(19) Topographic Map
None
None specific
§264.13
§264.14
§§264.1S(b), 264.174, 264,194,
264,226, 264.254, 264.273, 264.303,
264.273(g)
Part 264, Subpart C, §§264.30
through 264.37
Part 264, Subpart D, §§264.50 through
264.56, §264.227 and §264.255
None specific
§264.17
None specific
§264.18
§264.16
None
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5.1 FACILITY DESCRIPTION
5.1.1 Regulatory Citations
A description of the facility must be included with Part B of the permit
application, as specified in:
"§270.14(b)(D A general description of the facility."
Part 264 of the regulations does not specify any regulatory standards
with which the facility description must comply.
5.1.2 Guidance to Achieve the Standards
The requirement that a general description of the facility be included in
the permit application is straightforward and requires little explanation.
The intent is to provide enough information to identify the type and size of
facilities for which a permit is being sought. The description can be brief
and general. The following is a list of information items which should be
considered for mention in the facility description:
• Type of facility (onsite, offsite; storage, treatment, disposal)
• New or existing
• Size (acres, number of units)
• Location
• Name of company
• Name of owner
• Activities conducted
• Wastes types and quantities stored, treated, and/or disposed of
5.1.3 List of Major Points
1. Has a general description of the facility for which a permit is
sought been provided?
2. Have the items noted above been addressed?
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5.2 CHEMICAL AND PHYSICAL ANALYSES OF HAZARDOUS WASTE
5-2.1 Regulatory Citationa
analyses of the "«.tdous wes.e to
be inciu
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event, it may be appropriate for you to read all of Section 5.3 before you
formulate your response to the information requirements of §270.14(b)(2) in
your permit application.
The Part 270 information requirements specify that the submitted
hazardous waste analyses must contain the information required to properly
treat, store, or dispose of the waste. Thus, analytical parameters must be
selected based on waste type, facility type, and management procedure. If a
relatively homogeneous waste is stored onsite in tanks, the parameters listed
to characterize the waste will be much less comprehensive than that associated
with an offsite treatment facility accepting hazardous inorganic sludges for
treatment to render the wastes nonhazardous.
In the first case, the owner/operator would select analytical parameters
such as ignitability and reactivity to illustrate that he can safety store the
waste and to expedite agreements with an offsite facility that accepts the
waste for further storage, treatment, or disposal. The owner/operator would
also be concerned with waste/tank compatibility and waste/waste compatibility
and would present analytical or other waste characterization data to assure
that compatibility exists.
In the case of the offsite treatment facility, the owner/operator would
be concerned with characterizing the waste to the extent necessary to
adequately treat the waste so that it is no longer hazardous. Possibly the
inorganic waste of concern is a metal plating sludge which demonstrates the EP
toxicity characteristic because of high chromium concentration. An applicable
treatment process might consist of hydroxide precipitation of chromium,
followed by sludge drying and solidification using a cement or pozzolan based
stabilization process. The waste characteristics of concern would probably
include chromium, other heavy metals, and cyanide (used in alkaline plating
baths), which could interfere with reagents used throughout the treatment and
stabilization system.
Regardless of facility type and waste, to fulfill the information
requirements of §270.14(b)(2), you should present waste characterization data
in tabular form for each waste handled or to be handled at your facility. An
example is noted in Table 5-2.
The specific information requirements call for a list of hazardous wastes
to be submitted in Part B applications for landfills, surface impoundments,
and waste piles. The specific information requirements for land treatment?
facilities require a listing of wastes to accompany plans for a treatment
demonstration. To fulfill the waste listing requirements for these types of
facilities, you should indicate the following general information:
• Name of the waste
• EPA hazardous waste ID number (if assigned), and
• Location where the waste will be stored, treated, or disposed of at
the facility.
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TABLE 5-2. EXAMPLE WASTE CHARACTERIZATION DATA FOR A WASTE
RECEIVED AT AN OFFSITE SOLVENT RECOVERY PLANT
Waste No. 346A (EPA ID F002): 1,1,1-trichloroethane from
degreasing of cutting tools
Characteristics
Concentration
Comment s
1,1,1-trichloroethane
Priority pollutant metals
Chromium
Copper
Lead
Nickel
Silver
Viscosity
Flash point
Specific gravity
83 + 5%
210 ± 30 mg/1
650 +. 80
40 +. 10
800 + 100
25+5
0.85 cp
65°C
0.96
More than 40% required to be
recoverable
Metal sludge is centrifuged
and landfilled
Measured to assure pumpability
Measured for safety in handling
Measured to assess separability
of phases
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If you are also submitting a new or revised Part A application, you are
reminded that additional waste analysis information is required in the Part A
application to meet the requirements of §270.13. A Part A application must be
submitted along with Part B if the facility is new or if the facility is
existing and the wastes have changed since the first Part A submittal. The
Part A application must include:
• Specification of the hazardous wastes to be stored, treated, or
disposed of
• the quantity of wastes to be stored, treated, or disposed of
annually at the facility, and
• a general description of processes to be used for such wastes.
5.2.3 List of Major Points
1. If you are submitting a new or revised Part A application, does it
include a list of wastes; quantities to be stored, treated, or
disposed of on an annual basis; and a general description of the
processes used for such wastes?
2. If a new or revised Part A application is being submitted, does all
waste related information correspond precisely with waste
information presented in the Part B application?
3. In the Part B application, have you identified all hazardous wastes
to be handled and any applicable EPA ID numbers?
A. Most importantly, have you denoted the waste characteristics which
must be known to adequately store, treat, or dispose of the wastes
at the facility?
5. Have you noted the locations where each waste will be handled at
your facility?
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5.3 WASTE ANALYSIS PLANS
5.3.1 Regulatory Citations
The information required in the permit application for waste analysis
plans is specified under §270.14(b)(3) as follows:
"A copy of the waste analysis plan required by §264.13(b) and, if
applicable §264.13(c)."
The standards specified in §264.13 are applicable to all facilities that
treat, store, or dispose of hazardous wastes, and are reprinted below:
"264.13 General waste analysis.
(a)(l) Before an owner or operator treats, stores, or disposes
of any hazardous waste, he must obtain a detailed chemical and
physical analysis of a representative sample of the waste. At a
minimum, this analysis must contain all the information which must
be known to treat, store, or dispose of the waste in accordance with
the requirements of this Part or with the conditions of a permit
issued under Part 122, Subparts A and B, and Part 124 of this
Chapter.
(2) The analysis may include data developed under Part 261 of
this Chapter, and existing published or documented data on the
hazardous waste or on hazardous waste generated from similar
processes.
(3) The analysis must be repeated as necessary to ensure that
it is accurate and up to date. At a minimum, the analysis must be
repeated;
(i) When the owner or operator is notified, or has reason to
believe, that the process or operation generating the hazardous
waste has changed; and
(ii) For offsite facilities, when the results of the
inspection required in paragraph (a)(4) of this Section indicate
that the hazardous waste received at the facility does not match the
waste designated on the accompanying manifest or shipping paper.
(4) The owner or operator of an offsite facility must inspect
and, if necessary, analyze each hazardous waste movement received at
the facility to determine whether it matches the identity of the
waste specified on the accompanying manifest or shipping paper.
(b) The owner or operator must develop and follow a written
waste analysis plan which describes the procedures which he will
carry out to comply with paragraph (a) of this Section. He must
keep this plan at the facility. At a minimum, the plan must specify:
(1) The parameters for which each hazardous waste will be
analyzed and the rationale for the selection of these parameters
(i.e., how analysis for these parameters will provide sufficient
information on the waste's properties to comply with paragraph (a)
of this Section;
(2) The test methods which will be used to test for these
parameters;
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(3) The sampling method which will be used to obtain a
representative sample of the waste to be analyzed. A representative
sample may be obtained using either:
(i) One of the sampling methods described in Appendix I of
Part 261 of this Chapter; or
(ii) An equivalent sampling method.
(4) The frequency with which the initial analysis of the waste
will be reviewed or repeated to ensure that the analysis is accurate
and up to date; and
(5) For offsite facilities, the waste analyses that hazardous
waste generators have agreed to supply.
(6) Where applicable, the methods which will be used to meet
the additional waste analysis requirements for specific waste
management methods as specified in §264.17 and 264.341.
(c) For offsite facilities, the waste analysis plan required in
paragraph (b) of this Section must also specify the procedures which
will be used to inspect and, if necessary, analyze each movement of
hazardous waste received at the facility to ensure that it matches
the identify of the waste designated on the accompanying manifest or
shipping paper. At a minimum, the plan must describe:
(1) The procedures which will be used to determine the identity
of each movement of waste managed at the facility; and
(2) The sampling method which will be used to obtain a
representative sample of the waste to be identified, if the
identification method includes sampling.
5.3.2 Guidance to Achieve the Part 264 Standards
In response to public comment, the standards of §264.13 were stated in
somewhat general terms to be comprehensive enough to account for the variety
of conditions and waste analysis requirements which arise from site to
site.1 The requirements for waste analysis that each owner/operator will
have to meet will be specified in the facility permit after administrative and
technical review of the permit application. -The scope of the waste analysis
plan is expected to differ significantly from site to site, so that the
ownen operator must successfully demonstrate through his proposed procedures
that the intent of the §264.13 waste analysis requirements are met and that
the specific requirements for his facility type (Subparts I through N) are
also supported. Waste characterization or waste analysis is implicitly
required in those Subparts to comply with waste related standards for these
different types of treatment, storage, and disposal facilities. In essence,
the objective of the waste analysis plan is to assure successful treatment,
storage, or disposal of wastes at the facility through recognition and
implementation of specific waste analysis procedures selected based on waste
type, facility type, and waste management procedures.
In providing the information to meet this permitting requirement, the
applicant should rigorously consider what he is doing with the waste at his
facility to formulate an appropriate plan of sampling and analysis. The
applicant should view this plan as essential to successful and safe operation
of the facility, as opposed to a regulatory requirement to generate analytical
5-9
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data for simple recordkeeping purposes. A well designed comprehensive waste
analysis plan will help the owner/operator prevent adverse incidents and the
expense of associated cleanup or litigation.
An acceptable waste analysis plan must encompass the following aspects
for all facilities:
• Procedures and methods for characterizing wastes to assure that they
can be successfully treated, stored, or disposed of.
• Methods of collecting representative samples.
• Procedures for recharacterizing wastes on a routine and as-needed
basis.
• Quality assurance/quality control for waste sampling and analysis in
all phases.
• Procedures and methods for characterizing incompatible, ignitable,
and reactive wastes, as well as methods to show that such wastes
have been rendered compatible, nonignitable, or nonreactive.
Additionally, the waste analysis plan must incorporate procedures and
methods to support waste characterization requirements associated with
specific onsite and offsite facility types (containers, tanks, waste piles,
surface impoundments, land treatment facilities, and landfills) and specific
waste management procedures (treatment, storage, or disposal). Some of these
added requirements for offsite facilities include:
• Methods of characterizing each movement of waste received.
• Methods of documenting consistency of waste received with the
accompanying manifest.
• Procedures for resampling, reanalyzing, or rejecting received wastes.
Additional procedures that must be represented for yet other types of
facilities include:
• Methods of characterizing existing wastes in waste receiving
facilities to assure compatibility with incoming waste.
• Methods of characterizing wastes to assure compatibility with
equipment surfaces, facility liners, and leachate collection system
materials.
• Methods of determining that storage facilities and equipment are
decontaminated at closure.
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• Methods to determine the presence of liquids or free liquids.
• Methods of determining whether collected leaks, spills, run-off, or
leachate are hazardous or nonhazardous.
The remainder of this section presents guidance on achieving the general
standards for waste analysis specified in §264.13 and for achieving the
facility specific standards (Subparts I through N) which implicitly require
waste characterization or waste analysis. Examples are provided in
Section 5.3.6 to illustrate the type of information that an owner/operator
should incorporate in his waste analysis plan.
5.3.3 Guidance for Preparation of Waste Analysis Plans for All Facilities
Waste analysis requirements will differ depending on the type of
facility, type of waste, and specific waste management practices. However,
certain aspects of the general waste analysis requirements are common to all
facilities and waste types.
5.3.3.1 Characterization of Wastes to be Treated, Stored, or Disposed Of—
Wastes must be characterized to ascertain that they can be successfully
treated, stored, or disposed of. This characterization can be based on
historical or available scientific data, or analysis of representative waste
samples. Except for simple cases, it is expected that both types of
documentation will be necessary.
Analytical parameters must be selected based on waste type, facility
type, and management procedure. If a relatively homogeneous waste is stored
onsite in tanks, the list of parameters selected for analysis will be much
less comprehensive than that associated with an offsite treatment facility
accepting hazardous inorganic sludges to be rendered nonhazardous. In the
first case, the owner/operator would select analytical parameters such as
ignitability and reactivity to allow for safe storage and to expedite
agreements with an offsite facility that would later accept the waste for
further storage, treatment, or disposal. In this case, the owner/operator
would also be concerned with waste/tank compatibility and wasta*waste
compatibility and would select analytical parameters to assure that
compatibility exists.
In the second case, in addition to recognizing issues of waste
compatibility and safety in handling, the owner/operator of the offsite
treatment facility would be concerned with characterizing the waste to the
extent necessary to adequately treat the waste so that it is no longer
hazardous. Suppose that the inorganic waste of concern is generated by
production of titanium oxide pigment and demonstrates the EP toxicity
characteristic because of high concentrations of heavy metals. Such a waste
might also be contaminated with cyanide. An applicable treatment process
might consist of chemical oxidation of cyanide followed by hydroxide
precipitation of heavy metals. Ultimately, the resulting sludge might be
dried and solidified or otherwise stabilized. In this instance, the
owner/operator's waste analysis plan should specify analytical parameters for
5-11
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the waste feed, treated stabilized waste product, and intermediate streams in
the treatment process. The waste feed analytical parameters might include pH,
cyanide, a variety of specific heavy metals, total solids, and others to
assure proper treatment. Other constituents that are incorporated in the
waste which could interfere with reagents used throughout the treatment and
stabilization system might also be designated for analysis. The stabilized
product could conceivably be subjected to the EP toxicity test and leachate
analyzed for heavy metals and metal cyanides to document that the stabilized
waste is no longer hazardous.
Other examples are provided in later sections. The point to be made here
is that there is no universal set of parameters to be analyzed for. The
parameters selected will be strongly site and waste specific. Therefore, the
applicant must carefully evaluate and present a rationale for selection of
waste analysis parameters in all cases.
5.3.3.2 Procedures for Collecting Representative Samples—
Regardless of the purpose of the analysis, the applicant must demonstrate
his procedures for collecting representative samples for analysis. These
procedures will depend on the nature of the waste, its variability over time,
and the waste generating process. Samples are representative if they allow
for accurate and precise quantification of the average characteristics of the
waste. An accurate sample is one which will provide a measured value close to
the true value. A precise sample is one which will provide a measured value
close to the measured value of other replicate samples. In-depth discussion
of representative sampling procedures is provided in SW-846—Test Methods for
Evaluating Solid Wastes.2 The applicant should obtain a copy of this
document (see Appendix A for locations where it is available) because of its
comprehensive treatment of waste sampling and analysis and because much of the
discussion and guidance in this document is based on its contents. In
addition to SW-846, other reference sources of value in understanding
representative sample collection procedures for hazardous waste include:
• Ford, P. J. , P. J. Turina, and D. E. Seely. Characterization of
Hazardous Waste Sites - A Methods Manual. Volume II - Available
Sampling Methods. Prepared for Lockheed Engineering and Management
Services under EPA Contract No. 68-03-3050. Environmental
Monitoring Systems Laboratory, Office of Research and Development,
U.S. Environmental Protection Agency. March 1983.3
• U.S. Environmental Protection Agency. Samplers and Sampling
Procedures for Hazardous Waste Streams. U.S. EPA Municipal
Environmental Research Laboratory. Cincinnati, Ohio.
EPA-600/e-80-Ol8.4
Further, 40 CFR 261 Appendix I lists certain ASTM standard methods for
collecting representative samples, as follows:
"Extremely viscous liquid—ASTM Standard D140-70, Crushed or
powdered material—ASTM Standard D346-75, Soil or rock-like
material—ASTM Standard D420-69, Soil-like material—ASTM Standard
D1452-65
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Fly ash-like material—ASTM Standard D2234-76 (ASTM Standards
are available from ASTM, 1916 Race St., Philadelphia, PA 19103).
Containerized liquid wastes—'COLIWASA1 described in [SW-846].
Liquid waste in pits, ponds, lagoons, and similar reservoirs—
'Pond Sampler1 described in [SW-846]."
5.3.3.2.1 Statistical Concepts Used in Collecting Representative
Samples—Statistical techniques must be used to collect accurate and precise
samples. Your waste analysis plan should be clear and specific with regard to
this issue because statistical sampling techniques are not always simple to
implement in spite of the fact that they are fairly clear to understand.
Sampling accuracy is usually achieved by some form of random sampling.
This is particularly true for sampling of heterogeneous wastes. In random
sampling, every unit in the population has a theoretically equal chance of
being sampled and measured. Consequently, statistics generated (mean,
standard deviation) by analyzing the sample are accurate estimators of the
true population parameters, i.e., the sample is representative of the
population. One method of selecting a random sample is to divide the
population by an imaginary grid, assign a series of consecutive numbers to the
units of the grid, and select the numbers (units) to be sampled through the
use of a random numbers table. Note that a haphazardly selected sample is not
a suitable substitute for a randomly selected sample. Samples collected in
other than a random fashion may be skewed because of sampling bias; for
instance by the collection of the most easily accessible samples.
Sampling precision is most commonly achieved by taking an appropriate
number of samples from the population. Sampling precision can be increased by
maximizing the physical size (weight or volume) of the samples. Increasing
the number or size of samples taken from a population, in addition to
increasing sampling precision, has the secondary effect of increasing sampling
accuracy.
More complex stratified random sampling is appropriate if a waste is
known to be randomly heterogeneous in terms of its chemical properties and/or
nonrandom chemical heterogeneity is known to exist from batch to batch. In
such cases, the population should be stratified during sampling to isolate the
known sources of nonrandom chemical heterogeneity. After stratification,
which may occur over space and/or time, the units in each stratum are
numerically identified, and a simple random sample is taken from each
stratum. The advantage of stratified random sampling over simple random
sampling is that, for a given number of samples and a given sample size, the
former technique often results in a more precise estimate of chemical
properties of a waste than the latter technique. However, greater precision
is likely to be realized only if a waste exhibits substantial nonrandom
chemical heterogeneity and stratification efficiently "divides" the waste into
strata that exhibit maximum between-strata variability and minimum
within-strata variability. If that does not occur, stratified random sampling
can lead to analytical results that are less precise than those which result
from simple random sampling. Therefore, it is reasonable to select stratified
random sampling over simple random sampling only if the distribution of
5-13
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chemical contaminants in a waste is sufficiently known to allow an intelligent
identification of strata and at least two or three samples can be collected in
each stratum.
Another type of probability sampling is systematic random sampling, in
which the first unit to be collected from a population is randomly selected,
but all subsequent units are taken at fixed space or time intervals. An
example of systematic random sampling is the sampling of a movement of drums
received at an offsite facility wherein the first drum sampled is selected on
a random basis and every fourth drum is sampled thereafter. The advantages of
systematic random sampling over simple random sampling and stratified random
sampling are the ease in which samples are identified and collected. One
disadvantage of systematic random sampling is the inaccuracy that may result
if trends or cycles in waste variability are not recognized and they coincide
with the sampling routine.
The foregoing statistical sampling techniques are contrasted with
authoritative sampling, in which an individual who has knowledge of the solid
waste to be sampled selects a sampling scheme using his own judgement. The
validity of data gathered is completely dependent on the knowledge of the
sampler and although valid data can sometimes be obtained, authoritative
sampling is not recommended for characterization of most wastes.
To summarize, if little or no information is available concerning the
distribution of chemical contaminants of a waste, simple random sampling is
the most appropriate sampling strategy. As more information is accumulated
for the wastes and contaminants of concern, consideration can be given to
stratified random sampling, systematic random sampling, and, perhaps,
authoritative sampling.
Test Methods for Evaluating Solid Waste (SW-846) provides much more
detail on representative sampling procedures and sampling strategies.
Hypothetical examples are provided to illustrate statistical procedures used
in designing sampling strategies.
5.3.3.2.2 Grab and Composite Samples?,3—^ grab sample is defined as a
discrete aliquot representative of a specific location at a given point in
time. The sample is collected in its entirety at one point in the sample
medium. The representativeness of such samples is defined by the nature of
the materials being sampled. In general, as sources vary over time and
distance, the representativeness of grab samples will decrease.
Composite samples are nondiscrete samples composed of more than one
specific aliquot collected at various sampling locations and/or different
points in time. Analysis of this type of sample produces an average value and
in certain instances is a viable alternative to analyzing a number of
individual grab samples and calculating an average value. It should be noted,
however, that compositing can mask low concentrations of constituents that may
exist in samples taken at specific locations or times.
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For sampling situations involving hazardous wastes, grab sampling
techniques are generally preferred because grab sampling minimizes the amount
of time sampling personnel must be in contact with the wastes, reduces risks
associated with compositing unknowns, and eliminates chemical changes that
might occur due to compositing. Compositing, however, may be used for
hazardous samples under certain conditions. For example, compositing of
hazardous waste is often performed (after compatibility tests have been
completed) to determine an average value over a number of different locations
such as a group of drums. This procedure provides data that can be useful by
providing an average concentration within a number of units, can help keep
analytical costs down, and can provide information useful to the
owner/operator.
Some valuable insight on composite sampling is provided in a study
prepared for EPA Region I by A. T. Kearney, Inc.5 The report points out the
disadvantages of composite samples by first noting the natural heterogeneity
of hazardous wastes and then by reference to measurement of waste
ignitability, corrosivity, reactivity, and EP-toxicity. With respect to
ignitability, it is noted that otherwise ignitable wastes such as waste ether
or acetone may be rendered nonignitable if mixed (i.e., composited) with a
sufficient quantity of aqueous waste. Corrosive wastes are generally either
strongly caustic or acidic. Clearly, compositing diverse, otherwise corrosive
wastes may result in a neutral, noncorrosive composite waste, analysis of
which will not indicate the corrosive wastes which may exist in the waste
population. Additionally, compositing of reactive hazardous wastes must be
avoided to prevent generation of toxic gases or fumes. Further, if several
dissimilar wastes are composited, dilution effects may result in a waste
sample which does not exhibit EP-toxicity, despite the possibility that
individual samples and associated wastes may be EP-toxic. In summary,
complicating factors which must be considered in compositing samples include
neutralization upon compositing, precipitation of hazardous constituents,
reactions or explosions, waste dilution, and other phenomena.
Although analysis of discrete or grab samples is superior to composite
samples in assuring measurement of representative characteristics and accurate
waste characteristics, the disadvantages of cost and time must be considered
in selecting sampling procedures.
5.3.3.2.3 Multiple Samples3—The concept of multiple samples is
applicable to both grab and composite samples. It is recommended that
multiple samples be collected whenever possible. They are essential for
quality control, assist in reducing costs associated with resampling as a
result of container breakage, errors in the analytical procedure, and data
confirmation. Multiple samples include duplicates, blanks, split samples, or
spiked samples.
Duplicate samples are identical samples collected at the same time in the
same way, and contained, preserved, and transported in the same manner. These
samples are often used to verify the sampling precision. Sample blanks are
samples of deionized/distilled water, rinsed collection devices or containers,
sampling media (e.g., aorbent), etc. that are handled in the same manner as
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Che sample and subsequently analyzed Co identify possible sources of
conCaminacion during collection, preservation, handling, or transport. Split
samples are those collected in duplicate fashion for the purpose of separate
analysis. Spiked samples are duplicate samples that have a known amount of a
substance of interest added to them. These samples are used to corroborate
the accuracy of the analytical technique and could be used as an indicator of
sample quality change during shipment to the laboratory.
5.3.3.2.4 Applicable Hazardous Waste Sampling Equipment—Sampling of
various types of hazardous wastes requires a variety of sampling equipment.
Although much of the applicable sampling equipment is commercially available,
some may have to be custom made for a given sampling routine. Table 5-3, from
SW-846, provides a summary of sampling equipment which may be used for
different classifications of waste.
5.3.3.3 Quality Assurance/Quality Control—
As noted in SW-846, Section Ten (incorporated here in Appendix F):
"Quality assurance (QA) is a system for ensuring that all
information, data, and resulting decisions compiled under a specific
task are technically sound, statistically valid, and properly
documented. Quality control is the mechanism through which quality
assurance achieves its goals. Quality control programs define the
frequency and methods of checks, audits, and reviews necessary to
identify problems and dictate corrective action, thus verifying
product quality.
The facility's implemented QA/QC program will determine the accuracy,
precision, and overall integrity of Che sampling and analysis program. An
incomplete, unsound, or poorly planned QA/QC program will be judged deficient
during review of your permit application. Therefore, if an outside laboratory
is contracted, the applicant should carefully review their current QA/QC
program. Similarly, the applicant should review and augment his own QA/QC
procedures, if the owner/operator plans to conduct all necessary sampling and
analyses with his own resources.
As noted in SW-846, an acceptable QA/QC plan will denote:
"1. The intended use(s) for the data, and the necessary level of
precision and accuracy of the data for these intended uses.
"2. A representative sampling plan that includes provisions for:
selecting appropriate sampling locations, depths, etc.
- providing a statistically sufficient number of sampling sites.
measuring all necessary ancillary data.
- determining which media are to be sampled (e.g., solid, liquid,
sludge).
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TABLE 5-3. SAMPLING EQUIPMENT FOR PARTICULAR WASTE TYPES
Source: Reference 2 (SW-846).
Waste location
Waste type
Free flowing
liquids and
slurries
Sludges
Moist
powders
or granules
Dry powders
or granules
Sand or packed
powders and
granules
Large
grained
solids
Sacks
Drum and bags
Coliwasa N/A
Trier N/A
Trier Trier
Thief Thief
Auger Auger
Large Large
Trier Trier
Open bed
truck
N/A
Trier
Trier
Thief
Auger
Large
Trier
Closed
bed truck
Coliwasa
Trier
Trier
Thief
Auger
Large
Trier
or container
Storage
tanks
or bins
Weighted
bottle
Trier
Trier
Thief
a
Large
Trier
Waste
piles
N/A
a
Trier
Thief
a
Large
Trier
Ponds,
lagoons,
& pits
Dipper
a
Trier
Thief
a
Large
Trier
Conveyor
belt Pipe
N/A Dipper
Shovel Dipper
Shovel Dipper
Dipper Dipper
Trier Dipper
*This type of sampling situation can present significant logistical sampling problems. Therefore
sampling equipment must be specifically selected or designed based on site and waste conditions.
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determining which parameters are to be measured (and where).
selecting appropriate sample containers.
selecting the frequency of sampling and length of sampling
period.
selecting the types of sample (e.g., composites vs. grabs) to
be collected.
sample preservation procedures.
chain-of-custody.
"3. An analytical plan that includes:
chain-of-custody procedures.
appropriate sample preparation methods.
appropriate analytical methods.
appropriate calibration and analytical procedures.
procedures for data handling, review and reporting.
"4. Planning for the inclusion of proper and sufficient QA/QC
activities, including the use of QC samples throughout all phases of
sampling and analysis to ensure that the level of quality of the
data will meet the requirements of the intended use(s) of the data."
Further more detailed guidance is provided in Section 10 of SW-846 as reported
here in Appendix F.
5.3.3.A Procedures for Recharacterizing Wastes—
The applicant should develop a scheme for recharacterizing wastes during
facility operation on a routine basis and on an as-needed basis. Waste
characteristics will vary depending on the nature of the waste generating
process. For instance, the process may operate using different feedstocks at
different times of the year (e.g. petroleum distillation bottoms) and may
incorporate different downstream processing components or additives as a
consequence of the change in feedstock. Thus, the applicant should actively
account for these routine changes in the generated waste by incorporating
intermittent reanalysis of the waste into his waste analysis plan.
In addition, the owner/operator should develop a plan to reanalyze wastes
on a contingent basis if he suspects that the waste characteristics have
changed. Such contingent reanalysis might be signaled as a result of visual
inspection during handling, as a result of measured changes in waste
treatability, or as a result of incidents during handling such as fume
generation. Additionally, wastes should be reanalyzed if a generator notifies
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the owner*operator that the waste generating process has changed or if he
knows of a specific change in the waste. The applicant's waste analysis plan
must propose criteria and schedules for reanalysis and must specify the
parameters to be analyzed during recharacterization of the waste in each
instance,
5.3.4 Guidance for Preparation of Waste Analysis Plans for Offsite Facilities
This subgroup of facilities is addressed next because requirements for
waste analysis plans for offsite facilities are incorporated in the general
waste analysis requirements of §264.13. Offsite facilities are those storage,
treatment, and disposal facilities which accept waste from remote generator
locations after waste transport. Offsite facilities are required to:
• document the waste analysis data that generators have agreed to
supply;
• specify procedures to characterize each movement of waste received;
and
• specify procedures that will be used to assure consistency between
the waste and manifest.
5.3.4.1 Waste Analysis Data Provided by Generators—
It is the owner/operator's responsibility to characterize wastes to be
received at his facility. Although the generator can not be forced to provide
waste analysis data, the owner/operator can request it. Additionally, the
owner/operator can not be prevented from charging the waste generator for the
full cost of handling his waste which would include the cost of analyzing the
waste. The most prudent waste generators will provide accurate analytical
data in recognition of this fact and frequently as a result of having
previously generated this information for purposes of safely storing the
wastes onsite prior to transport to the offsite facility.
In formulating and implementing the waste analysis plan for an offsite
facility, the preliminary work and agreements between the owner/operator and
generator will be the key to success. The owner/operator should consider the
nature of a potential customer's waste, the variability of that waste, the
chance that other waste components could be inadvertently or otherwise mixed
in the expected waste, and the chance of errors during shipment of the waste
from the generator's plant. To guard against the adversities associated with
errors or intentional changes in the waste, the owner/operator should do the
following during early negotiations with waste generators:
• request representative waste samples for testing;
• request as much data as exists on the waste stream, including
expected quantities, processes generating the waste, waste
classification, specific waste characteristics, known health or
environmental effects of the waste, and known hazards in handling or
disposing of the wastes;
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• ask the generator how he proposes to assure that the waste shipped
will be as specified in the original contract; and
• visit the generating facility to gain first hand knowledge of the
waste generating process, other waste materials onsite which could
potentially be mixed with the contracted waste, and the chances for
error in waste shipment.
It is recommended that requests for waste data from the generator be
formalized by use of a standard and detailed questionnaire developed by the
owner/operator. Additionally, if the owner/operator proposes to use such a
questionnaire, its incorporation in this part of the application will expedite
the permit review process. If the owner/operator has not yet produced such a
form, he should consider requesting the following types of information,
subject to the type of storage, treatment, or disposal that he proposes.
• Generator name, address, and company representative;
• waste name, industry or EPA hazardous waste number, and process
generating waste;
• waste characteristics, such as:
pH
physical state
liquids or solids content
specific gravity
flash point
• specific waste components, such as:
specific organic compounds
specific inorganic compounds
heavy metals
The form might also request the generator to provide a general ranking of
the waste in terms of its reactivity or ignitability. Additionally, if the
generator knows of specific wastes that are incompatible with the candidate
waste, he should be asked to list them. In essence, the generator should be
requested to provide any information possible to promote successful handling
of the candidate waste.
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5.3.4.2 Generator Audits—
Waste characterization is of utmost importance to successful operation of
an offsite facility. In addition to requesting waste information or
representative samples for analysis from the generator, it is recommended that
the facility owner/operator conduct an "audit" of the waste generator's
facility. A generator audit is possibly one of the most thorough and rigorous
methods of obtaining knowledge of the candidate waste and its potential
variability. The audit should be formulated to allow the owner/operator to
inspect the waste generating process and plant and to independently assess
potential variability of the waste stream and chances for errors or
inconsistencies in shipment. The owner/operator should consider the results
of the audit in defining the stringency of contracts (i.e., allowable
tolerances for given waste characteristics) or other formal agreements made
with the generator. Although the scope of the audit will depend on the waste
generating process and offsite facility design and operation, we present below
a list of applicable information which should be retrieved during an audit:
• Characterization of the waste generating process, including
types and quantities (batch or rate) of raw materials,
catalysts, and reagents
processing information such as operating parameters and
schedules
contingency operating plans and possible use of other hazardous
materials or materials which render other hazardous components
in the waste product
routine variations in process operation
• Characterization of the waste
average rate of production and variability of rate
storage time onsite before shipment
controlled or uncontrolled changes to waste during storage
method of waste shipment and provisions for access to samples
upon receipt at offsite facility
all known waste characterization data or sources of data
previous history of waste handling and any remarkable incidents
• Characterization of other influencing factors at the plant
other sources of waste which could be intentionally or
accidently mixed with the intended waste product
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adequacy of procedures currently used to manage other wastes
generated onsite
practices currently implemented to avoid cross-contamination
As part of the audit, representative samples should be collected and
analyzed. For best results, replicate samples should also be collected and
the number of replicates should be determined based on expected waste
variability.
5.3.4.3 Agreements Between Owner/Operator and Generator—
Once the question of waste variability has been answered by means of the
generator audit, sample analysis, or by acquisition of historical or published
data, the affects of such variability on offsite facility operation must be
evaluated. The magnitude of these impacts will depend on the constituents
which vary, the range of variability, and the design and operation of the
facility. The range of potential effects to be considered will expand with
the complexity of the facility.
Tolerance limits should be specified for measured waste components that
may adversely affect plant operation. These parameters or suitable indicator
parameters should then be considered for analysis upon receipt of each
movement of waste from that particular generator. Agreements made between the
generator and owner/operator should specify allowable tolerances for accepting
the transported waste. Additionally, the agreement should specify the steps
to be taken when the results of waste characterization at receipt indicate
waste characteristics outside allowable tolerances. For instance, procedures
for resampling the waste, reanalyzing, contacting the generator, or rejecting
waste shipments should be specified in the agreement and in the waste analysis
plan.
5.3.4.A Characterization of Each Movement of Waste—
Each movement of waste received at your facility must be characterized to
determine consistency between the manifest information and the waste movement;
to assure that the waste you receive from a particular generator is the waste
that you expect to receive, and to assure that you detect restricted wastes.
In the first case, inconsistencies between waste and manifest information may
arise because of accidental or intentional mixups. Since a waste movement
could contain a significant amount of waste units (e.g., a flat bed truck
carrying drums), the question arises as to the proportion of the waste which
should be somehow screened to determine consistency of waste and manifest
information.
Wastes are typically nonhomogeneous. Additionally, waste streams at a
given generator location may be inadvertantly or intentionally mixed, thus
causing further uncertainty in waste characteristics. Therefore, each
movement of waste must also be somehow characterized to verify that it
possesses the characteristics that the waste from that particular generator is
expected to possess. Therefore, the concept of "fingerprint analyses" is
introduced in this section.
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You may have decided to restrict certain wastes or waste constituents
from your facility. In all likelihood, those which may have been selected for
restriction typically exist is small concentrations or may be easily masked by
mixing in other wastes. We provide some guidance here to help plan for
screening to detect restricted wastes.
5.3.4.A.I Screening to Determine Consistency of Waste and Manifest
Information—One of the most important aspects of waste analysis at offsite
facilities is the need to characterize each movement of waste to assure that
the information provided on the waste manifest correctly identifies the
waste. The questions of most concern are the amount of sampling which must be
done and the inspections or analyses which should be conducted to assure that
these goals are achieved for each waste movement.
The previously noted report by A. T. Kearney5 provides perspective on
this issue. They report the results of a telephone survey conducted by
Mittelhauser Corporation to characterize sampling procedures used by
treatment, storage, and disposal facilities. A summary of the responses
received from 10 sites is discussed below.
Each facility sampled every shipment of waste received, and in fact, the
majority of facilities sampled every drum and bulk shipment received. One
site samples 1 to 5 or more drums from each shipment depending on the total
number of drums. Another site whose policy was to sample only 10 percent of
incoming waste indicated that 100 percent of the waste would be sampled
starting in 1983. The purpose noted was to provide more safety in handling
and assure successful treatment in new treatment processes.
The facilities noted that analytical parameters selected are heavily
dependent on the type of waste and the available waste treatment process.
Some representative parameters included TOC, pH, heavy metals, and solids
concentration. To assess consistency between waste and manifest you should
consider visually inspecting the wastes for physical state, phase separation,
texture, color, and odor. Applicable analytical procedures that may be
informative include pH and specific gravity.
The A. T. Kearney report5 provides further perspective on the
advantages of sampling 100 percent of the wastes in question. Clearly, any
time less than 100 percent of all wastes are sampled (for instance, less than
all of the drums in a single waste movement), there is a finite probability
that the unsampled waste is different than expected, different from manifest
documentation, and/or different from the sampled wastes. In the context of
drum sampling at offsite facilities, the report provides tabulated statistics
to determine the number of drums which must be sampled to estimate p, the
proportion correct (i.e., consistent with the manifest), with a confidence
level of A percent and an error bound of B percent assuming that an estimate
of the actual number correct, C, is known based on historical information.
The statistics ignore waste lot size and are reproduced here in Table 5-4 for
the conditions of 95 percent correct and 99 percent correct. These
percentages correct are selected for the purposes of discussion only.
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TABLE 5-4. SAMPLING REQUIREMENTS TO ADEQUATELY CHARACTERIZE WASTE MOVEMENTS
Source: Reference 5.
Required Sample Size When
Proportion Correct (C) • 95%
A
(Confidence
Level)
95%
96%
97%
98%
99%
10%
18
20
22
26
31
B
9%
22
25
28
32
39
(Bound
8%
28
31
35
40
49
on Error)
7%
37
41
46
53
64
6%
51
56
62
72
87
5%
73
80
89
103
126
Required Sample Size When
Proportion Correct (C) = 99%
A
(Confidence
Level)
95%
96%
97%
98%
99%
B (Bound on Error)
10%
4
4
5
5
7
9%
5
5
6
7
8
8%
6
6
7
8
10
7%
8
8
9
11
13
6%
11
12
13
15
18
5%
15
17
19
22
26
4%
24
26
29
34
41
3%
42
46
52
60
73
2%
95
104
116
134
164
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The data presented in the table serve to illustrate the degree of
certainty sacrificed if a decision is made to sample and analyze less than
all discrete units of waste in a waste movement. Consider the statistics
presented in Table 5-4 for the required sample size when the proportion
correct is known to equal 99 percent. If the owner/operator were to sample
24 drums in the waste movement and find that all tested in conformance with
the manifest, he would then have 95 percent contidence that no more than
4 percent (the bound on error) of the drums in the movement were inconsistent
with the manifest. If 1 of the 24 tested drums proved inconsistent with the
manifest, the proportion incorrect could then be as high as 8.2 percent, i.e.,
[100 percent - percentage correct (23/24 x 100) + bound on error (4 percent)].
In the case where 95 percent of the units are historically correct, the error
bounds for the noted conditions would be even greater, between 8 to 9 percent.
To determine if abbreviated sampling or screening schemes are acceptable, the
owner/operator must show proof that such increased levels of error will not
jeopardize adequate or safe operation of his facility. If such an abbreviated
scheme is proposed, it should be fully documented and supported in the permit
application.
5.3.4.4.2 Selection and Measurement of "Fingerprint Parameters"—To
determine that the wastes received are the expected wastes it is useful to
select "fingerprint parameters" based on the initial waste characterization
for analysis after receipt of waste. We refer to these parameters as
"fingerprint parameters" because we envision that they will be selected from
the more comprehensive population of analytical parameters originally tested
for, would be fairly simple to test during facility operation and receipt of
waste, and testing of them would provide confidence that the waste is the
expected waste, meets all necessary specifications, and the waste can be
adequately stored, treated, or disposed of. Fingerprint parameters should be
selected based on their unique ability to identify a waste, their variability
as noted during initial analysis, the affect of that variability on your
operation, and ease of detection.
Sameness will be assessed based on expected variability, as well as waste
handling tolerances of the offsite facility, that is, the range of constituent
concentrations for a given waste that a facility can accept. This allowable
range of concentrations will be determined based on the nature of the waste.
For instance, an inordinately high level of an otherwise acceptable
constituent may make the waste reactive or otherwise incompatible with wastes
disposed of in a given landfill cell. Alternatively, if the pH of the waste
is greatly different than agreed upon (in a facility-generator agreement or
contract), the waste may be incompatible with storage tank materials or
surface impoundment liners. A given movement of semisolid waste found to
contain free liquids may be unacceptable for receipt at a landfill which does
not operate with a liner and leachate collection system.
Each movement of waste must be characterized to the extent necessary to
assure that wastes received are consistent with conditions and characteristics
specified under agreements with the waste generator. Attainment of this goal
rests on:
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• Accurate and precise characterization of wastes before acceptance
and receipt;
• Accurate knowledge of the range of variability of characteristics of
a given waste;
• Sound knowledge of the impact of waste characteristic variability on
facility operation; and,
• Establishment of workable agreements between waste generator and
owner/operator.
To meet these needs, the applicant should implement a strategy to select
and analyze "fingerprint parameters" in representative waste samples collected
from waste movements during facility operation. In Subsection 5.3.6.1.8, we
provide a detailed example of the selection of fingerprint parameters for
testing of a pharmaceutical waste received at an offsite landfill. The
rationale for selecting the parameters is presented and is based on the
initial waste characterization, the waste management technique, and ease of
analyzing for the selected parameters.
5.3.4.4.3 Screening for Restricted Wastes—Proposed procedures for
screening for restricted wastes are an important aspect of your waste analysis
plan. Apart from the issue of health hazard that may be induced in the event
of an incident; for success in operation, you should consider the adverse
affect that restricted wastes might have on given operations at your plant.
For instance, if you operate a biological treatment plant you would restrict
highly toxic constituents that would upset the process, or you would handle
such constituents in another manner. The selection of restricted components
will depend on the capabilities and limitations of operations at your
facility, the existence or likelihood of highly toxic or other undesirable
wastes in your market area; and other factors such as public concern or
comment. In general, as the variety of wastes accepted and the number of
waste sources increase, the concern over and control of restricted wastes must
also increase accordingly. In developing a plan for screening of restricted
waste, you should consider the statistics noted in subsection 5.3.4.4.1. If
there is a waste constituent highly likely to be generated in your market area
and if your operation would be highly sensitive to unknowingly receiving that
waste component, then it would be prudent to institute a screening procedure
for that component which includes sampling of all discrete waste units
received in waste movements which have any likelihood of containing that waste
component. To determine the cost-effectiveness of instituting the complete
screen, you might balance the cost of sampling and analysis versus revenue
lost if an incident were to occur at your facility or if you were to restrict
receipt of all waste from a generator whose waste might be contaminated with
the unwanted constituent. The estimated cost of sampling and analysis should
consider whether there is an applicable simple indicator parameter for the
restricted constituent or whether the specific constituent must be detected.
You should also consider whether sample compositing would mask detection of
the constituent, thus requiring collection and analysis of grab samples.
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5.3.4.5 Waste Analysis Requirements for Ignitable, Reactive,
or Incompatible Wastes—
As noted in $264.13, the applicant is required to demonstrate waste
analysis methods he will use in showing compliance with §264.17, General
requirements for ignitable, reactive, or incompatible wastes. Waste analysis
procedures for determining waste ignitability are fairly straight forward.
SW-84&2 describes two methods for measuring waste ignitability, both of
which measure the flash point of the tested waste. Method 1010 uses the
Pensky-Martens closed cup tester to determine flash point for fuel oils, lube
oils, suspensions of solids, liquids that tend to form a surface film under
test conditions, and other liquids. Method 1020 uses the Setaflash® Closed
Tester to determine the flash point of paints, enamels, lacquers, varnishes,
and related products. Although it is important for the applicant to note the
exact procedure he will use to test flash point as a function of the waste
type; moreover, he must present a logical plan for testing the ignitability of
generated wastes, or wastes received, to assure that no adverse reactions will
occur in handling ignitable wastes. If ignitable wastes will be accepted and
rendered non-ignitable, the applicant's plan must be capable of documenting
that treated wastes are, in fact, non-ignitable. The plan must also account
for specific requirements for ignitable wastes which are noted in Subparts I
through N of Part 264. These requirements are discussed further in remaining
subsections.
The applicant's planning for analysis of reactive or otherwise
incompatible wastes must be well conceived because of the enormity of waste
combinations which may be reactive. Some of the best guidance currently
available on testing of waste compatibility are test plans and procedures
which have been developed to manage and handle potentially incompatible or
reactive wastes removed from CERCLA sites. One such scheme, shown in
Figure 5-1,6 was implemented by GCA at an uncontrolled hazardous waste site
to characterize unknown wastes and could be used for segregating otherwise
reactive or incompatible wastes.
Although this scheme, or some modification of it, may be applicable to
RCRA facilities, its primary purpose is to assure safety when dealing with
unknown wastes. A complex facility which handles a variety of wastes and
stores or treats these wastes in common locations may require more definitive
procedures for waste compatibility or reactivity testing. Such a scheme is
currently under development by Acurex in support of the EPA's Municipal
Environmental Research Laboratory.? Test procedures and a test kit are
being developed to classify waste materials into reactivity groups (RGNs).
These reactivity groups are as specified by Hatayama, et al., in
EPA-600/2-80-076, A Method for Determining the Compatibility of Hazardous
Wastes.® Once a waste is classified by its Reactivity Group Number, the
matrix provided in EPA-600/2-80-076 can be used to identify compatible and
incompatible waste combinations. The currently defined reactivity groups are
shown in Table 5-5. The compatibility chart is not shown here, one reason
being that it is currently under revision. Copies of the updated report will
be available from NTIS, the National Technical Information Service in
Springfield, Virginia.
5-27
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Figure 5-1. Example waste characterization scheme.
Source: Reference 6.
5-28
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TABLE 5-5. REACTIVITY GROUP DEFINITIONS
Source: Reference 8.
Reactivity
Group No. Reactivity Group Name
1 Acids, mineral, nonoxidizing
2 Acids, mineral, oxidizing
3 Acids, organic
4 Alcohols and glycols
5 Aldehydes
6 Amides
7 Amines, aliphatic and aromatic
8 Azo compounds, diazo compounds, and hydrazines
9 Carbamates
10 Caustics
11 Cyanides
12 Dithiocarbomates
13 Esters
14 Ethers
15 Fluorides, inorganic
16 Hydrocarbons, aromatic
17 Halogenated organics
18 Isocyanates
19 Ketones
20 Mercaptans and other organic sulfides
21 Metals, alkali and alkaline earth, elemental and alloys
22 Metals, other elemental and alloys in the form of powders,
vapors, or sponges
23 Metals, other elemental and alloys as sheets, rods, moldings,
drops, etc.
24 Metals and metal compounds, toxic
25 Nitrides
26 Nitriles
27 Nitro compounds
28 Hydrocarbons, aliphatic, unsaturated
29 Hydrocarbons, aliphatic, saturated
30 Peroxides and hydroperoxides, organic
31 Phenols and cresols
32 Organophosphates, phosphothioates, phosphodithioates
33 Sulfides, inorganic
34 Epoxides
101 Combustible and flammable materials, miscellaneous
102 Explosives
103 Polymerizable compounds
104 Oxidizing agents, strong
105 Reducing agents, strong
106 Water and mixtures containing water
107 Water reactive substances
5-29
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In addition to determining the reactivity characteristics noted in the
scheme shown in Figure 5-1, the test procedure recommended by Acurex will
define specific waste classes and allow for complete categorization of wastes
according to chemical functionality. Any or all of these procedures can be
employed, depending upon the discretion of the analyst and the completeness of
information required.
The test procedures are organized into six series of tests, each included
to provide specific information about the waste material. In several cases,
results obtained at a specific stage in the testing sequence can sufficiently
define the chemical characteristics of the waste material so that the need for
further testing is eliminated. Each of the six procedure sets is summarized
with a flow diagram which provides an overview of procedures involved in that
particular procedure set. The six procedure sets are summarized in Table 5-6.
The full sequence of implementing these procedure sets to identify
specific waste classifications is summarized in Figure 5-2. The Acurex
manual? provides analogous diagrams for each procedure set along with
descriptions and directions for implementing specific test procedures.
5.3.5 Guidance on Preparing Waste Analysis Plans for Specific Facility Types
This subsection provides guidance on preparing waste analysis plans
suitable for specific facility types and suitable to address the specific
waste analysis requirements of regulations specified in Part 264, Subparts I
(Containers), J (Tanks), K (Surface Impoundments), L (Waste Piles), M (Land
Treatment), and N (Landfills). Examples are presented in Section 5.3.6 to
illustrate the level of detail that the applicant is expected to provide in
his waste analysis plan. Although presented for specific facilities, the
discussions and examples cover the general requirements specified in §264.13
for all facilities and for offsite facilities.
Table 5-7 summarizes the waste analysis requirements for §264.13 and
identifies the objectives that the waste analysis plan must fulfill to assure
support of the facility specific standards (Subparts I to N). These specific
standards implicitly require some type of waste characterization to identify
incompatible, reactive, or ignitable wastes; determine that wastes are
compatible with facility equipment liners, and surfaces; determine that
storage facilities are decontaminated at closure; and to fulfill several other
specific objectives noted in the table. To illustrate the commonality and
overlap of these specific facility standards and to indicate where
similarities in waste analysis plans will exist for different facility types,
we have summarized the noted regulations in Table 5-8.
An abundance of facility specific scenarios exist and cannot all be
specifically addressed by examples. However, review of the examples presented
here should assist in preparing waste analysis plans for other types of
facilities not specifically addressed.
3-30
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TABLE 5-6. PROCEDURE SETS FOR CLASSIFYING HAZARDOUS WASTES BY
REACTIVITY GROUP NUMBER
Source: Reference 7.
Procedure
Sec
Title
pH and Redox Tests
Solution-Reactivity and
Special Functionality Tests
Flame Test
Sodium Fusion and
Ferrox Tests
Organic Functionality Tests
Information Obtained
Acidity, basicity, oxidizing and
reducing potential
Identification of sulfides and
cyanides, reactivity and solubility
in acids and solvents, reactivity
with water, presence of water
Combustibility, classification as
organic or inorganic, identification
of explosives
Identification of oxygen, nitrogen,
phosphorous, sulfur, and halogen in
organic waste materials
Presence of specific organic
functional groups
Inorganic Functionality Tests Presence of elemental metals, heavy
metal compounds, and inorganic
fluorides
5-31
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T
u>
10
SLURRY. SLUDGE
PROCEDURE SET I
VISUAL
EXAMINATION
PROCEDURE
SET 1
PROCEDURE SET 2
i
PROCEDURE SET 3
LIQI
FILTER
no \
SOLID
PROCtOURE SET 2
1
PROCrOURE SET 3
PROCEDURE SET 4
PROCEDURE SET 5
o
en
o
START
STOP
CONTINUE
PROCEDURE
RESULT
Figure 5-2. Sequence of procedure sets designed by Acurex.
Source: Reference 7. '
-------
TABLE 5-7. OBJECTIVES OF THE WASTE ANALYSIS PLAN BASED ON GENERAL AND
SPECIFIC REGULATIONS
Part 264 Citation
Objectives of the Waste Analysis Plan
General Waste Analysis
§264.13
Subpart I - Containers
§264.172
§264.175
S264.176
§264.177
Characterize the waste to assure that,
after receipt, the waste can and will
be successfully treated, stored, or
disposed of.
For offsite facilities, demonstrate
procedures to characterize each waste
movement, and to check for consistency
between the waste and the waste manifest.
Assure that wastes are recharacterized
on a routine basis, and on an as-needed
basis if a change in waste character-
istics is suspected.
Document methods of characterizing incom-
patible, ignitable, or reactive wastes.
Document procedures to assure compatibil-
ity between the waste and the container.
Characterize leaks, spills, or accumula-
ted precipitation in containment systems.
Document that wastes do not contain
free liquids and, therefore, containment
systems may not be necessary.
Identify containers holding ignitable or
reactive wastes so that they can be
located at least 15 meters (50 feet) from
the property line.
Identify incompatible wastes so that they
will not be placed in the same container
unless the provisions of §264.17(b) are
complied with.
(continued)
5-33
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TABLE 5-7 (continued)
Part 264 Citation
Objectives of the Waste Analysis Plan
1264.177
S264.178
Subpart J - Tanks
§264.192
S264.197
§264.198
§264.199
Subpart K - Surface Impoundments
§264.221
Assure that containers to be used to
store different wastes are adequately
washed of previously held incompatible
wastes.
Demonstrate decontamination of containers
and related equipment at closure.
Document procedures to assure compati-
bility between the waste and the tank.
Demonstrate that all hazardous wastes and
hazardous waste residue are removed from
tanks and related equipment at closure.
Demonstrate that ignitable or reactive
wastes are no longer ignitable or
reactive if placed in a tank and that
§264.17(b) is complied with.
Identify ignitable and reactive wastes to
be stored in covered tanks in compliance
with NEPA buffer zone requirements.
Identify incompatible wastes so that they
will not be placed in the same tank
unless the provisions of §264.17(b) are
complied with.
Assure that tanks to be used to store
different wastes are adequately washed
of previously held incompatible wastes.
Assure compatibility of wastes and
leachates with liner materials.
(continued)
5-34
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TABLE 5-7 (continued)
Part 264 Citation
Objectives of the Waste Analysis Plan
S264.228
§264.229
§264.230
Subpart L - Waste Piles
§264.250
§264.251
§264.256
§264.257
Demonstrate removal or decontamination
of waste residues and any contaminated
components, soil, or other equipment at
closure.
Demonstrate the absence of free liquids
if wastes are solidified at closure
Document whether waste residues or
contaminated materials are left in place
at closure to determine if the post
closure care requirements of §§264.117-
264.120 apply.
Demonstrate that ignitable or reactive
wastes are no longer ignitable or reac-
tive if placed in a surface impoundment
and that §264.17(b) is complied with.
Identify incompatible wastes so that they
will not be placed in the same surface
impoundment unless the provisions of
§264.17(b) are complied with.
Identify the presence of liquids or free
liquids and determine if leachate can be
generated through decomposition or other
reactions if any exemption from §264.251
is sought under §264.250(c).
Assure compatibility of wastes and
leachate with the liner and leachate
collection system materials.
Demonstrate that ignitable or reactive
wastes are no longer ignitable or reac-
tive if placed in a surface impoundment
and that §264.17(b) is complied with.
Document that incompatible wastes and
materials are not placed in the same pile
unless §264.17(b) is complied with.
(continued)
3-35
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TABLE 5-7 (continued)
Part 264 Citation
§264.257
S264.258
Subpart M - Land Treatment
§264.272
§264.273
§264.276
Objectives of the Waste Analysis Plan
Determine if wastes and materials in
one pile are incompatible with those of
another pile or other containment facil-
ity so that suitable physical separation
can be implemented.
Assure that bases to be used to store
wastes are decontaminated of previously
stored incompatible wastes.
Demonstrate removal or decontamination
of waste residues and any contaminated
components, soil, or other equipment at
closure.
Document whether waste residues or
contaminated materials are left in place
at closure to determine if the post
closure care requirements of §264.310
apply.
As part of the treatment demonstration,
characterize the wastes including the
presence of constituents listed in
Appendix VIII of Part 261.
Characterize the waste to assure proper
control of soil pH, enhancement of
microbial or chemical reactions, and
control of moisture content in the
treatment zone.
For facilities proposing growth of food
chain crops, identify Part 261,
Appendix VIII constituents reasonably
expected to be in or derived from wastes.
Similarly, document the presence and
concentration of cadmium in the waste
and the pH of the waste and soil mixture.
(continued)
5-36
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TABLE 5-7 (continued)
Part 264 Citation
Objectives of the Waste Analysis Plan
S264.281
§264.282
Subpart N - Landfills
$264.301
§264.312
§264.313
S264.314
Demonstrate that ignitable or reactive
wastes are no longer ignitable or reac-
tive after incorporation into the soil.
Assure that incompatible wastes are not
placed in or on the same treatment zone
unless §264.17(b) is complied with.
Assure compatibility of wastes and
leachates with the liner and leachate
collection system materials.
Demonstrate that ignitable or reactive
wastes are no longer ignitable or reac-
tive if placed in a landfill and that
§264.17(b) is complied with.
Determine if wastes in containers are
ignitable.' If containers holding igni-
table wastes are disposed of, determine
that the disposal cells do not and will
not contain wastes that generate heat
sufficient to ignite the containerized
ignitable waste.
Assure that incompatible wastes are not
placed in the same landfill cell unless
§264.17(b) is complied with.
Determine whether wastes are liquids or
contain free liquids.
Determine that liquid wastes or wastes
containing free liquids no longer contain
free liquids if disposed of in a cell
without a leachate collection and removal
system.
(continued)
5-37
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TABLE 5-7 (continued)
Part 264 Citation Objectives of the Waste Analysis Plan
§264.314 (cont.) • Determine that containers which once held
free liquids can be placed in a landfill
cell by demonstrating that free standing
liquids have been removed, that they have
been mixed with absorbent or solidified,
or that they have been otherwise elimin-
ated.
§264.315 « Determine that containers, other than
small ones such as ampules, are at least
90 percent full before disposal.
§264.316 • Demonstrate that wastes in lab packs are
compatible with the inside containers of
the lab pack.
• Determine the liquid contents of the
wastes or inside containers so that a
sufficient quantity of absorbent material
can be placed in the lab pack.
• Demonstrate that the contained waste and
absorbent material are compatible.
• Demonstrate that incompatible wastes are
not placed in the same outside container.
• Determine whether wastes in lab packs are
ignitable or reactive and if so, whether
they are cyanide or sulfide bearing
wastes.
5-38
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TABLE 5-8. SUMMARY OF SPECIFIC REQUIREMENTS FOR WASTE ANALYSIS NOTED IN SUBPARTS I THROUGH N
Containers
Tanka
Surface
impoundments
Waste piles
Land
treatment
Landfills
Compatibility
Waste and facility .aterials
tla.te and wasted) in same location
Waste and waate(s) not in sane location, but in proximity
Haste and previously used unwashed receptacles
204.172
2O4.177
264.177
264.192
264.199
264.199
264.221
264.230
264.251
264.237
264.257
264.257
2o4.: -'•'
264.278
264.276
264. JL 5
rtft.Jlft
-------
5.3.6 Waste Analysis Plan Examples
Example*} are provided here to indicate the type of information permit
applicants should provide as well as the level of detail necessary to
interpret the adequacy of their proposed plans. The examples provided are for
a hypothetical offsite landfill unit (part of a larger TSD facility), and an
onsite container storage facility.
5.3.6.1 Example: New Offsite Landfill—
It is expected that a high percentage of Part B applicants will be
persuing permits for new offsite landfill units. Therefore, we have
incorporated the following example to illustrate the associated waste analysis
plan application information requirements. This example mirrors the level of
detail required to support the general facility standards for waste analysis
included in §264.13. The landfill unit considered in the example is part of a
new offsite treatment, storage, and disposal facility.
The example provided is not meant to be an entire waste analysis plan.
Components for which we provide examples include:
• Waste parameters to be characterized and rationale for selection
• Rationale for selection of additional parameters for specific waste
streams
• Procedures for recharacterizing wastes
• Procedures for characterizing each waste movement, including:
screening of all wastes for consistency with manifest and
associated sampling methods
procedures for documenting that the received waste is the
expected waste (fingerprint analyses and associated sampling
methods)
procedures for screening restricted wastes and associated
sampling methods
• Procedures for accepting or rejecting waste movements
Other important components of a waste analysis plan for this facility that are
not specified here include:
• Specific Quality Assurance/Quality Control Procedures
• Procedures for Characterizing Ignitable, Reactive, and Incompatible
Wastes
• Procedures for Demonstrating Compatibility of Wastes and Leachates
with Landfill Liners
5-40
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5.3.6.1.1 Waste Parameters to be Characterized and Rationale for
Selection—The XYZ Landfill is planned for location in East St. Louis,
Missouri. We expect a broad gamut of wastes; solid, sludge, and bulk liquids;
inorganic, and organic in nature. As noted in our facility description, our
landfill units will be used for disposal of solids and semi-solids as they are
received at the site as well as residuals which are generated by our onsite
waste treatment processes.
Disposition of wastes to different units at our facility will depend
primarily on generic waste classification as noted in Table 5-9. Most wastes
will undergo treatment of some type before landfilling. However, solids and
aqueous wastes with less than 40 percent water content will be directly
landfilled.
[Note: The applicant should include a detailed diagram to illustrate all
operations at the facility and the relationship of other units with the
landfill cell.]
Waste parameters we will analyze for will depend on the classification of
the waste, disposition at our facility, and the specific industry generating
the waste. Parameters that we have selected based on the first two factors
are presented in Table 5-10. The rationale for selection of these parameters
is discussed below. Additional parameters will be selected based on specific
waste types. Discussion of selection of parameters for specific wastes also
follows.
The parameters noted in Table 5-10 have been selected on the following
basis:
• pH, alkalinity, and acidity—These parameters will be tested in
aqueous wastes, and sludges and slurries to determine the amount of
neutralizing agent required for treatment and the applicability of
recovering acids or basis. These parameters will be measured in 1:1
water mixtures for solid wastes to determine compatibility of wastes
and leachates with the PVC membrane liners to be used in our
landfill cells. Additionally, solid wastes with appropriate
characteristics might also be used as reagents in portions of our
treatment system. Significant changes in the pH, alkalinity, or
acidity of aqueous wastes and sludges or slurries will influence
treatability, cost of treatment, and types of residuals remaining
after treatment.
• Specific anions and cations—These parameters will be characterized
in aqueous wastes, slurries, sludge, or inorganic solid samples to
account for major constituents or type of acid/base/salts present.
Cyanide and Sulfide will be measured at the ppm level because of
possible reactivity during storage or treatment. Changes in levels
of specific anions and cations will affect treatment and disposal
options.
5-41
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TABLE 5-9. DISPOSITION OF MAJOR CLASSES OF WASTES RECEIVED ONSITE
Waste classification
Disposition
Storage tanks
for testing and
further processing
Physical/chemical
treatment
Incineration
Landfill
X
ro
Aqueous
>40% water
[acidic, alkaline,
and metallic]
<40% water
Organic Liquids
flammables
combustibles
solvents/degreasers
Sludges and Slurries
organic
inorganic
Solids
X [sludge to landfill]
X [residue to landfill]
X [residue to landfill]
X [ash to landfill]
X [ash to landfill]
X [residue to landfill]
organic
inorganic
X
X
-------
TABLE 5-10. ANALYTICAL PARAMETERS SELECTED FOR GIVEN WASTE CLASSIFICATIONS
Waste classification
Parameters
PH
Acidity /alkalinity
Anions/cations
Heavy metals
Solids/volatile solids
Water or liquid content
Free liquids
Viscosity
Specific gravity
Flashpoint
Reactivity group
TOX/TOC
Selected organics
Ash
Higher heating value
Aqueous
X
X
X
X
X
X
X
X
X
X
X
X
Organic
liquids
X
X
X
X
X
X
X
X
X
Sludges and
slurries
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Solids
X
X
X
X
X
X
X
X
X
X
3-43
-------
Heavy metals—Heavy metals such as chromium, zinc, copper, lead, and
others will be measured in aqueous and organic liquids to ppm levels
to determine treatability using hydroxide precipitation. Sludge
from this treatment will be landfilled.
Solids and volatile solids—Type and concentration of solids are
important for aqueous and slurry/sludge samples to determine
treatability (i.e., incineration, biological, or phase separation)
and pumping/handling characteristics. Significant changes in solid
concentrations will affect treatment efficiency and may reflect a
change in the waste chemical composition.
Water content—Water concentration will be measured to determine
whether wastes will be treated (>40 percent water) or directly
landfilled (<40 percent water).
Free liquids—Free liquids will be measured in drummed wastes to
determine handling procedures we should expect to implement if the
wastes are accepted. If free liquids are present, we will decant
and treat the liquids, or add absorbent to the containers holding
free liquids so that they are no longer in evidence.
Viscosity—Viscosity values will help determine the method of waste
handling, blending, and storage. Highly viscous wastes may require
heating or special pumps for transfers. Changes in viscosity may
affect handling and storage requirements or may indicate a change in
other waste characteristics.
Specific gravity—Specific gravity is selected because significant
changes are strongly indicative of changes in waste characteristics.
Specific gravity is important in determining settleability or
buoyancy of wastes in suspension, as well as treatability in other
process units.
Flash point—Flash point will be measured to determine waste
ignitability and, thus, necessary waste handling practices. Bulk
ignitable solids will be rendered non-ignitable before landfilling.
Ignitable wastes in containers will be landfilled in comformance
with the container disposal standards of §§264.312-264.316.
[Although incinerators are not specifically addressed in this
manual, ignitable organic wastes will be incinerated at this
hypothetical site and ash will be landfilled.]
Reactivity group—At full operation, we expect to receive a wide
variety of wastes at our facility. Therefore, as a determinant of
waste acceptability (i.e., to assure that incompatible wastes are
not mixed) we will classify each candidate waste by reactivity group
(see Hatayama, et al., EPA-600/2-80-076). Some of the reactivity
groupings can be identified as a result of the parameters already
selected for analysis such as pH and flash point. Thereafter,
however, other specific procedures must be implemented to classify a
5-44
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waste into one of the current 41 reactivity groups. We will follow
the test protocols currently recommended by Acurex7 to determine
waste reactivity groupings.
• TOX. TOC—Wastes which are predominantly inorganic in nature will be
tested for total organic halogen and total organic carbon content as
an additional waste identification method. Changes in the organic
content of inorganic waste may signal changes in the waste and may
influence waste treatability.
• Selected organics—We will test all wastes which are potentially
contaminated with PCBs or dioxins for PCBs and dioxin to determine
if the wastes should be accepted or rejected. Other specific
organics will be selected for analysis based on the waste under
consideration, existing knowledge of the waste, information provided
by the generator, and information gained during our visit and
inspection of the generating facility. Chlorinated and halogenated
solvents or degreasers must be carefully screened to assure
compatibility with our biological treatment process.
5.3.6.1.2 Rationale for Selection of Additional Parameters for
Characterization of Specific Waste Streams—To assure that our waste analysis
plan is comprehensive enough to assure successful handling of all wastes, we
must select parameters for analysis based on specific waste types. We have
attempted to determine the specific waste categories and types that we may
encounter by reviewing and compiling existing industry/waste statistical data
for the East St. Louis market area. We have reviewed results of surveys
conducted by the East St. Louis Waste Commission (ESWC) and the State of
Missouri Hazardous Waste Board (MHWB). The results of our review are
presented in matrix form in Table 5-11, illustrating waste types and
associated industrial generators by 2-digit SIC code.
Analytical parameters will be selected for specific wastes as a means of
identifying each waste by setting specification limits or tolerances on waste
components. For instance, trichloroethylene sludge from an electrical
machinery manufacturer (SIC Code 34) will be tested for those parameters noted
earlier in Table 5-11, as well as for metallic species which are used in the
manufacturing process. These constituents will then be considered for use in
identifying the waste based on their intrinsic variability, concentration,
ease of detection, and impact on sludge treatability.
[Note: The applicant should identify test parameters for all specific
wastes and the rationale for their selection if he currently knows or has
foreknowledge of the identity of specific candidate wastes. A tabular
format is suggested to provide a concise presentation.]
5.3.6.1.3 Procedures for Recharacterizing Wastes—We routinely
recharacterize generator's wastes that we receive at least one to three times
per quarter on a quarterly basis. Wastes which are delivered less frequently
than once every 3 months are recharacterized upon receipt. Any time we
recharacterize a waste we analyze all parameters originally analyzed during
the initial waste characterization.
i-45
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TABLE 5-11. SUMMARY OF WASTE SURVEY ANALYSIS
Haste categories and types
Explosives
Flannables
Acetone
Hethylethyl Ketone (KEK)
Isopropyl Alcohol
Toluene
Xylene
Paint Solvent & Thinner
Stoddard Solvent
Mixed Solvents & Oils
Solvents
Kerosene
Turpentine
Varnish
Solvents & Solidified Paint
Printers Ink
Paint Filters
Combustibles
Oils
Oils Nixed with Halogenated Solvents
Grease & Oils
Paint Sludge
Oil Sludge
Solidified Paint
Solidified Phenolic Compounds
Ink Residue
Halogenated Solvents 4 Pegreasers
Freon
Hethylene Chloride
Trichloroethylene
Trichloroethylene Sludge
Chlorinated Hydrocarbons and Other
Synthetic Organics
Herbicides
Pesticides
Two Digit SIC Code
Haste classification 20 24 26 27 28 30 33 34
X
Organic liquids
and sludges
X XX
X XX
X X
X X
XX X
X XX
X
X XXX X
X
XX X
X X
X
Organic liquids
sludges, and solids
XXXXXXXX
X X
X X X X X X X
XXX
XXX X
X
X X X X X
X
Organic liquids
and sludges
X XX
X
Organic liquids
X
X
35
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
36
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
39
X
X
X
X
X
X
(continued)
-------
TABLE 5-11 (continued)
Haste categories and types
Cyanides t Isocyanates
SodiuB Cyanide 6 Sludge
Acidic Hastes
Chronic Acid
Hydrof louric Acid
Hydrochloric Acid
Nitric Acid
Su If uric Acid
Acetic Acid
Ferric Chloride
Ammonia Persulfate
Solder Stripper
Acids
Alkaline Hastes
Spent Caustic
Alkaline Etchant
Spent Ammonia
Detergents
Two Digit SIC Code
Waste classification 20 24 26 27 28 30 33 34 33 36 39
Inorganic liquids
and sludges
X X X X
Aqueous Inorganic
X X
X X X X
X
X
X
X
X
X
X
XX XXX
Aqueous Inorganic
X X X X X X X
X X
X
X
Metallic & Inorganic Compounds
Mercury
Heavy Metal Solution
Electro less Copper
Heavy Metal Sludge
Lead Compounds
Chromate Compounds
Zinc Compounds
Aluminum
Phosphorous Compounds
Sulfur Compounds
Aqueous Inorganic &
Inorganic Sludges &
Solids
X
X
X
X
X
X
-------
We also recharacterize wastes on a contingent basis if we are informed by
the generator that his production process has changed or if he indicates a
known change in the waste. If we are notified that the production process has
changed, we conduct a new generator audit and reevaluate our original listing
of analytical parameters for the waste. We then conduct applicable analyses,
decide whether to continue to accept the waste and define new fingerprint
parameters and tolerance bands, if necessary.
If the generator informs us of a known change in his waste, we will
conduct a new generator audit depending on the nature of the change. In any
event, we repeat all analyses which were conducted to initially characterize
the waste and test for any new parameters which would reflect the known change
in the waste. We then reevaluate the acceptability of the waste and the list
of fingerprint parameters and established tolerance bands.
If any abnormality occurs at our facility during waste handling, such as
fume generation or equipment deterioration or other incidents, we will
recharacterize any waste or wastes which are suspected to have caused the
incident.
5.3.6.1.4 Procedures for Characterizing Each Waste Movement—Our
objectives in characterizing each waste movement are to document consistency
between the waste and manifest, assure that the waste we receive from a
generator is the waste we expect to receive, and to screen out restricted
wastes. Although we require all generators to notify us of changes in wastes
and although we fully reanalyze all wastes on the basis noted above, we will
implement a variety of screening tests applicable to all wastes, and specific
tests dependent on waste type, on a routine basis to assure fulfillment of
these objectives.
5.3.6.1.5 Waste Screening Procedures—To screen wastes and assure
consistency between a waste movement and the accompanying manifest, we will
count all discrete units in the movement or weigh the entire movement,
depending on the type of containment used and the waste description on the
manifest. We will then visually inspect and test all discrete units of waste
in each waste movement. We will inspect all waste units for physical state,
texture, visible liquids, and odor. We will test all waste units by
collecting grab samples and analyzing them for pH and specific gravity. Each
waste unit of a waste movement means the following:
• all drums or containers on a truck
• all accessible ports on a tank truck
• all compartments of a truck carrying bulk solids or sludges
We will collect representative samples from all types of waste containers upon
delivery using the following sampling equipment:
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Waste type Sampling equipment
Liquids and slurries COLIWASA
Sludges Trier
Loose powders or granules Thief
Packed powders or granules Auger
Large grained solids Large Trier
5.3.6.1.6 Fingerprint Analyses and Sampling Methods—We will select
indicator or fingerprint parameters for specific wastes pending the results of
the initial waste analysis. Fingerprint parameters will be selected based on
their perceived ability to provide rapid and reliable evidence that the waste
received is the same as the waste expected within defined tolerance limits.
As a matter of course, any time we have not received a specific generator's
waste for more than 3 months, we will repeat the initial full analysis on a
representative sample taken from the waste movement.
Sample types that we will collect for analyzing fingerprint parameters
will be waste specific depending on the sampling technique that was used to
initially characterize the waste and on the form of waste shipment.
Table 5-12 presents our general approach to defining sample types depending on
waste classification and type of waste containment used in shipping.
Depending on the specific waste and generator, we may vary this procedure, but
generally only to implement more stringent procedures.
To further illustrate our proposed procedures and rationale for selecting
fingerprint or indicator parameters, we present the following discussion.
[Note: We have selected one example waste below and present narrative
discussion to provide a clear indication of the information required in
applications. The applicant should provide enough examples to cover the
full range of wastes expected to be received. Furthermore, if a
multitude of different wastes are accepted, you should rely on tabulated
data and accompanying discussion to present a comprehensive plan for
checking all waste movements.]
We have contacted one generator who produces pharmaceutical intermediates.
Information which he supplied to us indicated that his waste contained a high
concentration of methylene chloride and other components such as heavy metals
(zinc, iron), sodium sulfates and p-dichlorophenol. We subsequently obtained
four replicate representative samples during our visit to his facility. The
parameters we selected for analysis and the quantitative results are shown in
Table 5-13. These samples were collected over a period of 2 weeks during
normal plant operation. Clearly, the waste characteristics are relatively
constant and any wide variation in any of the parameters upon further testing
will be indicative of a change in the waste. Therefore, we will select
fingerprint parameters from the list in Table 5-13 on the basis of speed and
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TABLE 5-12. DEFINITION OF SAMPLE TYPES FOR ANALYSIS OF FINGERPRINT PARAMETERS
Waste classification
Drums
Types of containment used for waste movement
Large containers Open bed trucks
Closed or tank trucks
Liquids
Slurries or sludges
Solids
VJt
Ul
o
Crabs from 3 levels are
taken from 10Z of drums,
and are composited into 3
total samples for analysis
Crabs from at least 2
levels are taken from IOZ
of drums, and are com-
posited into a minimum of
4 samples for analysis
Crabs are taken from one
of three different levels
in IOZ of drums. At least
3 samples are composited
from grab samples taken at
equal levels in different
drums
COLIUASA samples are taken Not applicable
from 25Z of the containers
and are analyzed
As for drums containing
slurries and sludges
As for drums containing
solids
The truck is divided into
a 5 x 10 grid and a random
sampling procedure is used
to collect 5 samples for
analysis
As for open bed trucks
carrying slurries or
sludges
COLIWASA samples are
taken fron 3 sampling
ports for analysis
A trier is used to
collect 2 replicate
samples from 3 sampling
ports. The pairs are
composited for analysis
As for closed or tank
trucks carrying slurries
or sludges
-------
TABLE 5-13. RESULTS OF INITIAL ANALYSIS OF PHARMACEUTICAL WASTE8
N
Analytical
Parameters
pH
Alkalinity
Sodium
Sulfate
Zinc
Iron
Total Solids
Water Content
Viscosity
Specific Gravity
Flash Point
Reactivity Group No.
TOC
Replicate Sample Number
1
7.9
116
12,500
23,000
1.2
2.7
31,500
98.5%
0.95cp
1.09
185°C
106
2,900
2
8.3
125
12,700
18,500
2.0
2.7
34,000
96.1%
0.97cp
1.06
198°C
106
2,950
3
8.1
130
12,100
18,500
1.9
4.0
32,100
98.0%
0.97cp
1.05
197°C
106
3,650
4
7.9
118
13,000
18,600
1.7
1.8
32,600
97.4%
0.95cp
1.08
213°C
106
3,050
aResults are reported in mg/1 except as noted.
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eaae of measurement, as influenced by the selected waste handling method.
Based on the waste analysis, we will treat this waste in our
physical/chemical/biological treatment system which incorporates solids
sedimentation, activated sludge, and polishing using granular activated
carbon. Considering all factors, we have designated the following parameters
for fingerprinting this waste:
Fingerprint Parameters Concentration Tolerances
pH 8 + 0.8
Specific gravity 1.07 ^ 0.06
Total solids 32,000 + 6,500 mg/1
TOC 3,000 +_ 1,000 mg/1
Zinc <2.5 mg/1
In addition to being easy to measure, these parameters were designated as
fingerprint parameters for the following reasons:
• pH
avoid handling strong acids or bases, associated neutralization
costs, and possible corrosion or reactivity problems
• specific gravity
assure efficient settling upon treatment
reliable indicator of waste change
• total solids
avoid treatment process upsets
• TOC
acts as indicator for methylene chloride, p-dichlorophenol, and
other water soluble organics
• Zinc
avoid high zinc concentrations which could be toxic to
biological mass in activated sludge process
5.3.6.1.7 Procedures for Screening Restricted Wastes—We do not accept
explosives, radioactive wastes, or wastes contaminated with PCBs or dioxin.
We screen all waste movements for such constituents. If wastes from a
particular generator do not exhibit these characteristics either historically
or based on the initial waste characterization, we implement the following
waste screening procedures:
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• Explosives—Three random samples from a bulk waste movement or three
composite samples from random sampling of 25 percent of the discrete
units in a waste movement are each tested for flash point and
flammability.
• Radioactivity—A Geiger Counter is used to count each discrete waste
unit in a waste movement. We walk around the full circumference of
bulk waste movements with the detector to determine the presence of
radioactive material.
• Dioxin and PCBs—Two random grab samples are taken from the waste
movement and dioxin or PCBs are detected using GC/MS.
If historical information or initial waste characterization indicates
that wastes may be contaminated with any restricted components, we implement
the following waste screening procedures:
• Explosives—Five random samples from a bulk waste movement or grab
samples from all discrete units of the movement are tested for
flashpoint and flammability.
• Radioactivity—A Geiger Counter is used to count each discrete unit
in a waste movement. For bulk waste movements, we collect five
random grab samples for counting after an initial pass around the
circumference of the waste carrier.
• Dixoins and PCBs—For waste oils and other waste types that may be
contaminated, we collect 12 random samples and composite them into
4 samples for detection of dioxin and PCBs using GC/MS.
5.3.6.1.8 Procedures for Accepting or Rejecting Waste Movements—We will
reject wastes for the following reasons in the noted order of priority:
(1) the waste movement and/or included waste units are found to be
inconsistent with the manifest information
(2) the waste movement is a restricted waste or includes waste units
that are restricted
(3) fingerprint analyses indicate off-specification conditions.
In support of (1), we first visually inspect the waste and conduct analyses
for pH and specific gravity. If visual inspection or analysis indicate no
discrepancies we proceed to check each waste for restricted wastes. If
discrepancies seem apparent based on visual inspection, we postpone a decision
to reject until after the wastes are screened for restricted components and/or
fingerprint analyses are conducted.
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As noted earlier we do not accept any explosive or radioactive wastes, or
any wastes contaminated with dioxin or PCBs. If any screening test results
are positive for these components, the wastes are immediately considered for
rejection. General procedures we implement to reject a waste are noted under
the discussion below for fingerprint analyses.
Our last waste acceptance test procedure is testing for fingerprint
parameters. To illustrate our overall plan for selecting fingerprint
parameters, collecting samples, conducting analyses and, ultimately, accepting
or rejecting the wastes based on the fingerprint analyses, we continue the
example for the pharmaceutical waste initiated earlier.
[Note: In your application, you should include several examples to
indicate procedures for a representative cross-section of waste types.]
After selecting the fingerprint parameters (pH, specific gravity, solids,
TOO, and zinc) for the pharmaceutical waste, we negotiated a contract with the
generator which, among other things, set out requirements for information to
be noted on the manifest accompanying his waste. We have requested the
generator to identify his waste as "aqueous pharmaceutical waste—Control
No. AP974", to note the concentration tolerances for the selected five
fingerprint parameters, and to specify the color (aqueous-turbid) and odor
(solvent-methylene chloride) of the waste. On a routine basis, we ask all
generators to note on the manifest any hazards in visually inspecting wastes.
While one laboratory technician visually inspects the waste, a copy of the
manifest will be taken to our onsite laboratory to assist in locating the
generator file and all necessary information for conducting the fingerprint
analyses. While visually inspecting the waste, collecting representative
samples, and analyzing collected samples, the transport vehicle is located in
a designated waste holding area until all fingerprint parameters have been
analyzed and the acceptability of the waste shipment is determined.
Waste AP974 is delivered in tank trucks. To collect a representative
sample we use a Coliwasa sampler to collect three samples along three vertical
transects located at the three roof hatches on the tank truck. Two of these
samples are analyzed for the noted fingerprint parameters and the third is
held for confirmatory testing if necessary. If tested components are within
specified tolerances for both samples, the waste is accepted. If any
components are outside allowable tolerance bands, further analytical testing
is required. If only one of the tested samples shows a deviation, an aliquot
of that sample is tested along with the third sample previously held aside.
If both samples are within tolerance bands, the waste is accepted; otherwise
the shipment is rejected and the generator is contacted to resolve the problem.
If during original testing of the first two of three collected samples,
both tested samples indicate analytical results outside the specified
tolerance bands for the fingerprint parameters, the waste shipment is rejected
and the generator is contacted.
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Once a generator is contacted for resolution of such a problem, we advise
him that his waste has been rejected because of determination of
off-specification conditions based on analysis of two or more representative
samples of his waste. We will resample and reanalyze the waste only if
discussions with the generator present strong evidence that the waste has not
changed and that errors in shipment are unlikely. Only then will we accept
the possibility that the originally collected samples were not representative
or that laboratory analyses may have been in error. The shift supervisor will
then consult with the laboratory director on the advisability of resampling
and reanalyzing the waste as opposed to simply rejecting the shipment.
5.3.6.2 Example—Existing Onsite Containers—
This example is provided to illustrate certain components of a waste
analysis plan for an existing onsite facility which stores wastes in
containers. It is less comprehensive that the first example partly because
waste analysis plans for onsite facilities will generally be more
straightforward and concise than for offsite facilities. This is envisioned
because onsite facilities will typically handle one waste type which they have
experience handling and whose characteristics they know fairly well. In the
following example, we have highlighted components of the waste analysis plan
which support the specific facility standards of Subpart I, Use and Management
of Containers. The example is intended to illustrate how related standards
would be supported in waste analysis plans for other facility types. The
components addressed in the example include:
• Waste Characteristics to be Quantified and Rationale for Selection
• Procedures for Recharacterizing the Waste
• Procedures for Characterizing Collected Leaks, Spills, and Runoff
• Procedures for Assuring Compatibility of Wastes with Container
Materials and Equipment
• Procedures for Assuring Compatibility of Wastes with Water Residues
in Previously Used Unwashed Containers
• Procedures for Documenting Waste Ignitability
• Procedures for Assuring Container and Equipment Decontamination at
Closure
Other components that would be required in an actual waste analysis plan for
such a facility include overall quality assurance procedures and specific
sampling and analytical methods.
5.3.6.2.1 Waste Characteristics to be Quantified and Rationale for
Selection—The ABC Company in Akron, Ohio is a chrome leather tanning
operation. Our plant conducts "through the blue tanning" wherein we process
raw and cured hides into the blue tanned state but do not conduct retanning or
wet finishing. We store solid wastes (more than 90 percent solids) generated
5-55
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in the process in eight butyl rubber lined portable containers that are picked
up and transported to an offsite landfill once every 6 months. The solid
wastes are a mixture of chrome trimmings, shavings, and buffing dust. The
wastes result from manual trimming, shaving, and sanding of chrome tanned
hides and contain high concentrations of chromium and lead. Results of EP
toxicity testing have indicated the following concentrations of chromium and
lead:
chromium 35 ^ 6 mg/1
lead 17 T 10 mg/1
[Note: In an actual plan of this type, the applicant should incorporate
a diagram to illustrate the waste generating process and its
interrelationship with the waste storage containers.]
For the past 18 months we have been shipping these waste containers to the DEF
landfill in West Akron. As part of our agreement with the disposal facility
and to check the consistency of the waste stream (higher concentrations of
chromium and lead are indicative of process upsets, use of excessive chromium,
or still other problems which represent economic loss), we collect and analyze
two replicate samples from each container once per month and one week before
shipment. The samples are analyzed in our fully equipped laboratory
(constructed and operated to assure proper operation of our wastewater
treatment plant) using the extraction procedure and the leachate is analyzed
using atomic absorption spectrometry for chromium and lead.
We test an aliquot of each raw solid sample to determine percent solids
content and we use the paint filter method (47FR8311) to determine the
presence of free liquids. The DEF landfill will not accept wastes containing
free liquids nor waste solids with a moisture content more than 10 percent.
We maintain all analytical data in our operating record and report the
latest analytical results on the manifest form accompanying each waste
shipment to DEF.
5.3.6.2.2 Procedures for Recharacterizing the Waste—As noted, we
analyze replicate samples from each waste container once per month and one
week before shipment. On a daily basis, we visually check the containers to
assess separation of the solid and liquid phase which, based on past
experience, indicates a liquid content of greater than 10 percent. If we find
this condition, we mix sand with the waste to assure the absence of free
liquids upon delivery to the DEF landfill. We also reanalyze the waste on a
contingent basis if we notice any fumes or haze in the vicinity of the
containers or if we perceive uncharacteristic odors during our daily
inspection.
5.3.6.2.3 Procedures for Characterizing Collected Leaks, Spills, and
Runoff—The container area is diked and the container lids are closed except
when wastes are added. We generally experience no leaks, spills, or runoff.
However, if and when we do, we will collect three representative samples of
resulting liquids as soon as we can gain safe access after the event. We will
test the samples for chromium, lead, pH, TOO, and total solids. If acceptable,
5-56
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the waste liquid will be pumped to our onsite wastewater treatment facility
for treatment. If unacceptable, we will notify Haz Clean in West Akron, a
local spill control company.
[Note: In an actual plan of this type, it would be appropriate to fully
describe the treatment process, its permit status, and note the tolerance
bands for the noted constituents to determine their acceptability for
treatment.]
5'3'6-2.4 Procedures for Assuring Compatibility of Wastes with Container
Materials and Equipment—We store and transport our solid waste (more than
90 percent solids) in containers lined with butyl rubber. Butyl rubber is
used because of its strong resistance to abrasion and to acids and bases. It
is chemically compatible with the solid wastes produced, i.e., no ignition, no
corrosion, and no reactions ensue from normal handling procedures employed at
ABC Company.
As further proof of waste/liner compatibility, we are submitting herewith
raw test data from conducting EPA Test Method 9090 on two specimens of the
butyl rubber over a 4-month period. The specimens were suspended in tubs
containing waste leachate generated used the extraction procedure. Before and
after immersion we tested these samples for tear strength and resistance,
puncture resistance, other tensile properties, and hardness. You will note
from the raw test data that the only significant difference noted after the
4-month period was the butyl rubber hardness. However, we have tested butyl
rubber in the presence of rainwater with a pH of 4.8 (close to the EP pH) and
have noted the same changes in hardness. Since we typically keep the
container lids closed, we are confident that the container liners are fully
compatible with the contained wastes.
(Note: In an actual plan of this type, raw test data should be provided
along with a diagram of the test apparatus, and a description of the test
procedures.]
On a weekly basis, we visually inspect the container lining. A check is
made for holes, pock marks, creases, abrasion or other signs of deterioration.
Containers which have defects are relined or discarded. On a quarterly basis,
tests are conducted to determine the presence of other metallic compounds. We
use the extraction procedure to generate a leachate and analyze the leachate
for priority pollutant metals using ICAP.
5.3.6.2.5 Procedures for Assuring Compatibility of Wastes with Waste
Residues in Previously Used Unwashed Containers—When the containers are
returned from the DEF landfill, we visually inspect them to assure that no
residuals are visible and that the interior container surfaces are completely
dry. As part of our agreement with DEF, any containers found to contain
residual material are returned to the landfill, cleaned and rinsed, and
returned to us within 24 hours, all at DEF's expense. Each container has an
index number associated with it; thus, the previous constituents are known and
control is exercised over unauthorized use of the containers. Since our
process generates a fairly consistent solid waste, incompatibility is
generally not a consideration.
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5.3.6.2.6 Procedures for Documenting Waste Ignitability—Baaed upon
historical information, operating experience, and data, we are confident that
? K?" ?"., 3t the ABC ComPany are n°t ignitable under the guidelines
established under 40 CFR 261.21(a). On a quarterly basis, however? flash
SiniV'lV"? 1Y°nduCted as a Precautionary measure. One representative
sample is taken from each container for flashpoint testing.
5*3*6-2'7 Procedures for Documenting Waste Reactivity—During our
quarterly testing, in addition to measuring waste flash point, we also test
for water reactivity and the presence of cyanides or free cyanides. We
conduct these tests to determine the likelihood of toxic fume generation in
the event of accidental contact of water with the stored wastes.
5.3.6.2.8 Procedures for Assuring Container and Equipment
Decontamination at Closure-At eiM»r»" »- M;ii M-ir.^.-Lr1rt, of container
rinse water to determine that the containers are decontaminated. Two samples
representative of rinsings from each container will be subjected to EP
toxicity testing to measure the concentration of chromium and lead. If the
results are below the EP toxicity limit of 5 mg/1 for each metal, we will
consider the containers decontaminated and suitable for disposal or other
uses. If the EP toxicity limits are not supported we will follow one of two
alternative procedures. In all likelihood we will ship the containers to DEF
or another licensed hazardous waste landfill for crushing and disposal.
Otherwise, we will fully rinse the containers clean, collect the rinse water
in the container dike area, and analyze the collected liquid as if it were a
leak or spill. If the analytical results are within required tolerance
limits, we will treat the collected rinse water in our wastewater treatment
tacility.
[Note: In an actual plan, these tolerance limits would be specified.]
5.3.7 List of Major Points
This subsection acts as a summary and will be useful to you in assuring
cHLk°rhiet5ne88 °f TUr 8ubmittial- Xt can be «*ed to help plan, prepare, and
check the adequacy of your submitted waste analysis plan. The listings are
organized according to the following topics:
• General
• Offsite Facilities
• Onsite Facilities
• Containers
• Tanks
• Surface Impoundments
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• Waste Piles
• Land Treatment
• Landfills
5.3.7.1 General—
Your submitted waste analysis plan should explain the following factors
and procedures, regardless of your facility type, to demonstrate compliance
with the general standards of §264.13:
• Procedures and methods to gain or develop all information necessary
to treat, store, or dispose of the waste.
• Plan for and frequency of repeating initial waste analyses
on a routine basis, and
on a contingent basis when the waste generating process
changes, when the waste changes, or when the waste is suspected
to have changed based on visual inspection or other routine
testing.
• Parameters analyzed for in each waste.
• Rationale for selecting waste analysis parameters.
• Analytical test methods used.
• Representative sampling methods including number of samples; grabs,
composites; timing of sample collection, and related information.
• Waste analysis results and information provided by generators (for
onsite facilities, the waste analysis information you provide in
your application will fulfill this requirement).
• Procedures and methods for characterizing waste ignitability,
reactivity, or incompatibility.
• Methods of quality assurance and quality control including
consideration of the following factors, certain of which may be
applicable in specific instances only:
QA Organization and Responsibilities
Representative Sampling Procedures
Chain of Custody Procedures and Documentation
Instrument Calibration Procedures
5-39
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Analytical Procedures
Data Analysis, Validation, Reporting, and Recording Procedures
Internal QC Checks
Performance and System Audits
- Preventitive Maintenance Procedures and Schedules
Specific Procedures to Routinely Assess Precision, Accuracy,
Completeness, Compatibility, and Representativeness
Corrective Action
It is recommended that you include:
• schematic diagrams whenever possible,
• summary charts, tables, and figures whenever possible.
5.3.7.2 Offsite Facilities—
Your submittal must demonstrate procedures and methods covering the
following waste analysis factors and components:
• Initial Waste Characterization
- submit information provided by the generator including
completed questionaires
provide blank questionnaires if your facility is new and you
have not yet received such information
define generator visit, audit, inspection, or other survey
procedures and examples of existing results
note whether generator or your personnel collect the samples
indicate selected waste analysis parameters and rationale for
selection
identify and describe representative sampling methods
specify analytical test methods for each waste and measured
component
identify the laboratory that conducts the analyses
note procedures and frequency of reanalyzing wastes, on a
routine basis and on a contingent basis
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identify procedures and agreements for receiving prior notice
from generators of changes in the waste generating process or
in other procedures which would or could change the nature of
the waste
identify procedures and methods for determining the
compatibility or availability of the generator's waste with
your storage, treatment, or disposal facility, including:
methods to show compatibility with other wastes
methods to show compatibility with equipment surfaces
methods to show compatibility with liners and leachate
collection systems, and
method to show waste treatability if the treated waste is
considered non-hazardous after treatment
note procedures for specifying allowable ranges on waste
constituent concentrations
waste general procedures for rejecting wastes with components
outside of the established tolerance levels or for rejecting
otherwise restricted wastes
describe all quality assurance and quality control procedures
Screening of Incoming Waste Movements
indicate procedures for documenting that selected tolerance
bands are supported
specify analytical parameters and rationale for selection
describe nonanalytical waste characterization procedures such
as visual inspections
indicate procedures for determining consistency between waste
and manifest
indicate procedures for identifying restricted wastes
indicate procedures for identifying discrepancies in the number
of drums or in the weight or volume of bulk waste movements
fully define representative sampling procedures including
identification of samples taken in grab or composite fashion;
the number of samples taken; use of random sampling or sampling
of all discrete waste units
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• Evaluation of Waste Movements and Associated Analytical Results
- identify sampling, analytical, and decision team personnel
- define criteria and circumstances for waste acceptance,
rejection, or reevaluation
define documentation and recording procedures
define procedures implemented during and after decision to
reject a waste
document waste unloading procedures after waste acceptance
5.3.7.3 Onsite Facilities—
• Initial Waste Characterization
describe waste production processes including raw materials,
end products, and other intermittent sources of waste
identify historical or published information on the waste
identify waste parameters for analysis and rationale for
selection
identify any tolerances or other restrictions on waste
constituents
procedures and methods for characterizing ignitable, reactive,
or incompatible wastes
representative sampling methods, including identification of
samples taken in grab or composite fashion; the number of
samples taken, use of random sampling or sampling of all
discrete waste units
analytical procedures
indicate procedures and frequency of reanalyzing wastes on a
routine basis and a contingent basis
identify procedures for waste handling if waste analyses
indicate conditions outside of established tolerance bands or
the presence of restricted constituents or wastes
describe all quality assurance and quality control procedures
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5.3.7.4 Containers—
Waste analysis plans for storage of containers must address the
additional specific requirements listed below:
• procedures to assure and document compatibility of waste and
container
• procedures to characterize accumulations in containment systems
• procedures to detect free liquids
• procedures to characterize ignitable, reactive, and incompatible
wastes
• procedures to determine if containers previously held and are
contaminated with wastes not compatible with present wastes
• procedures to demonstrate decontamination at closure
5.3.7.5 Tanks—
• procedures to assure and document compatibility of waste and tank
• procedures to characterize ignitable, reactive, and incompatible
wastes
• procedures to document that tanks have been sufficiently washed of
previously held wastes if new wastes would be incompatible with
residual wastes
• procedures to demonstrate decontamination at closure
5.3.7.6 Surface Impoundments—
• procedures to assure and document compatibility of wastes and
leachates with liner materials
• procedures to characterize ignitable, reactive, and incompatible
wastes
• procedures to demonstrate decontamination at closure, residual
contamination at closure, or the absence of free liquids if wastes
are solidified at closure
5.3.7.7 Waste Piles—
• procedures to detect the presence of liquids or free liquids
• procedures to assure and document compatibility of wastes and
leachates with liner and leachate collection system materials
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procedures to characterize ignitable, reactive, and incompatible
wastes
procedures to demonstrate that bases have been decontaminated of
previously stored wastes which would be incompatible with new wastes
procedures to demonstrate decontamination at closure or residual
contamination at closure
5.3.7.8 Land Treatment—
o procedures to characterize wastes and Appendix VIII constituents as
part of the treatment demonstration
• procedures to characterize waste to allow for control of soil, pH,
enhancement of soil/waste reactions, and control of soil moisture
• procedures to identify Appendix VIII constituents in or derived from
wastes for facilities growing food chain crops
• procedures to quantify cadmium concentration in waste and the pH of
the waste/soil mixture
• procedures to characterize ignitable, reactive, and incompatible
wastes
5.3.7.9 Landfills—
• procedures to assure and document compatibility of wastes and
leachates with liner and leachate collection system materials
• procedures to characterize ignitable, reactive, and incompatible
wastes
• procedures to detect the presence of liquids or free liquids in
wastes or free standing liquids in waste containers
• procedures to demonstrate that wastes in lab packs are compatible
with inside containers
• procedures to assure and document compatibility of containerized
wastes and added absorbents
• procedures to determine whether waste in lab packs are sulfide and
cyanide bearing wastes
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5.3.8 References
1. U.S. Environmental Protection Agency. Background Document for 40 CFR
Parts 264 and 265, Subpart B—General Facility Standards.
Section 264.13—General Waste Analysis and Section 265.13—Interim Status
Standards for General Waste Analysis. U.S. EPA Office of Solid Waste,
January 12, 1981.
2. U.S. Environmental Protection Agency. Test Methods for Evaluating Solid
Waste. Physical/Chemical Methods. SW-846. Second Edition. July 1982.
3. Ford, P. J. , P. J. Turina, and D. E. Seely. Characterization of
Hazardous Waste Sites—A Methods Manual. Volume II—Available Sampling
Methods. Prepared for Lockheed Engineering and Management Services under
EPA Contract No. 68-03-3050. Environmental Monitoring Systems
Laboratory, Office of Research and Development, U.S. Environmental
Protection Agency. March 1983.
4. U.S. Environmental Protection Agency. Samplers and Sampling Procedures
for Hazardous Waste Streams. U.S. EPA Municipal Environmental Research
Laboratory. Cincinnnati, Ohio. EPA-600/2-80-018.
5. A. T. Kearney, Inc. Final Report under Contract No. 68-01-6515, Work
Assignment R01-007. Prepared for the U.S. Environmental Protection
Agency. December 1982.
6. Correspondence from GCA Corporation, GCA/Technology Division to U.S. EPA
Region II, Office of Hazardous Waste Response. November 17, 1981.
7. Wolbach, C. D., U. Spannagel, and R. Whitney. Field Scheme for
Determination of Waste Reactivity Groups. Prepared by Acurex Corporation
for the U.S. Environmental Protection Agency. Presented in the
Proceedings of the Ninth Annual Research Symposium—Land Disposal,
Incineration, and Treatment of Hazardous Waste. Fort Mitchell,
Kentucky. May 1983.
8. Hatayama, H. K., et al. A Method for Determining the Compatibility of
Hazardous Wastes. Prepared for the U.S. Environmental Protection Agency,
Municipal Environmental Research Laboratory by the California Department
of Health Services. EPA-600/2-80-076, April 1980. (Currently under
review and revision by the American Society of Testing and Materials.)
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5.4 SECURITY
5.4.1 Regulatory Citations
Information on security must be included in Part B of the permit
application, as specified in:
"§270.14(b)(4) A description of the security procedures and
equipment required by §264.14, or a justification demonstrating the
reasons for requesting a waiver of this requirement."
The regulatory requirements regarding security are contained in §264.14.
They are:
"§264.14 Security.
(a) The owner or operator must prevent the unknowing entry,
and minimize the possibility for the unauthorized entry, of persons
or livestock onto the active portion of his facility, unless he can
demonstrate to the Regional Administrator that:
(1) Physical contact with the waste, structures, or equipment
within the active portion of the facility will not injure unknowing
or unauthorized persons or livestock which may enter the active
portion of a facility; and
(2) Disturbance of the waste or equipment, by the unknowing
or unauthorized entry of persons or livestock onto the active
portion of a facility, will not cause a violation of the
requirements of this Part.
(b) Unless the owner or operator has made a successful
demonstration under paragraphs (a)(l) and (a)(2) of this Section, a
facility must have:
(1) A 24-hour surveillance system (e.g., television monitoring
or surveillance by guards or facility personnel) which continuously
monitors and controls entry onto the active portion of the facility;
or
(2)(i) An artificial or natural barrier (e.g., a fence in good
repair or a fence combined with a cliff), which completely surrounds
the active portion of the facility; and
(ii) A means to control entry, at all times, through the gates
or other entrances to the active portion of the facility (e.g., an
attendant, television monitors, locked entrance, or controlled
roadway access to the facility).
(c) Unless the owner or operator has made a successful
demonstration under paragraphs (a)(l) and (a)(2) of this Section, a
sign with the legend, "Danger—Unauthorized Personnel Keep Out,"
must be posted at each entrance to the active portion of a facility,
and at other locations, in sufficient numbers to be seen from any
approach to this active portion. The legend must be written in
English and in any other language predominant in the area
surrounding the facility (e.g., facilities in counties bordering the
Canadian province of Quebec must post signs in French; facilities in
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counties bordering Mexico must post signs in Spanish), and must be
legible from a distance of at least 25 feet. Existing signs with a
legend other than "Danger—Unauthorized Personnel Keep Out" may be
used if the legend on the sign indicates that only authorized
personnel are allowed to enter the active portion, and that entry
onto the active portion can be dangerous."
5.4.2 Guidance to Achieve the Part 264 Standards
5.4.2.1 General—
The intent of the §264.14 requirements is to keep unauthorized people and
livestock out of the active portion of the facility. In order to comply with
the requirements of §264.14, you must:
• Prevent unknowing entry of persons or livestock to active portions
of the facility.
• Minimize unauthorized entry of persons or livestock to active
portions of the facility.
In order to qualify as adequate, the security measures described in your
application must include:
• A 24-hour surveillance system and signs around the active portion of
the facility, or
• Artificial or natural barriers with controlled access points and
signs around the active portion of the facility.
However, you may request a waiver of these requirements if you can make a
demonstration in Part B of your permit application that unknowing or
unauthorized persons or livestock would not injure themselves or cause a
violation of your permit upon entering the active portion of the facility (see
5264.14(a)(l) and (2)). Additional information on exemptions or waivers is
presented later in this discussion.
5.4.2.2 Surveillance System or Barrier and Controlled Access—
As indicated in §264.14(b), the security procedures and equipment must
provide a means for controlling entry to the active portion of the facility.
The intent is that there should be a finite number of entrances into the
facility and that attempted or inadvertent entry to the facility at points
other than the identified, controlled entrances will be physically hindered
or, at least, immediately identified.
If some type of 24-hour surveillance system is or will be utilized to
monitor and control entry to the active portion of the facility, the permit
application should describe it in detail. All related structures and
equipment should be indicated on a plot plan. All facets of the system,
including personnel, procedures, structures, and equipment used should be
described, and if possible, demonstrated on the plot plan.
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Example:
"Security at this Company is maintained by a staff of trained
security guards, who primarily monitor entrv and exit from the active
portion of the facility and provide security measures within the plant
premises. The only authorized entry point is at the east end of the
facility. Personnel and vehicle entry at that point are controlled by
gates operated by remote control from the guard house. The guardhouse is
occupied by two armed guards 24 hours a day, 7 days a week, except during
plant shutdowns for holidays, at which time the gate remains locked and
only one guard is on duty. Guards normally work an 8-hour shift with a
crew of six guards per day. There is a six-foot high chain-link fence
along the entire eastern side of the facility. There are no physical
barriers on the north, south and west sides of the facility. Once each
hour a guard walks the entire facility perimeter and makes a walkthrough
of the facility. The security facilities and the guard's patrol route
are shown on plot plan xyz." OK
*nH l8 U8Cd t0 contro1 entry. the height, type of material
and any locking devices should be presented in the permit application. The
procedures and equipment used to control entry must be presented in your
application, and, if appropriate, a description of any natural barriers should
oe provided.
Examples :
A 7-foot high, chain-link fence with two lockable gates is
constructed around the container storage area to restrict
unauthorized entry and to prevent drums from being washed downstream
in the event of a minor flood. (See plot plan xyz).
• Means to Control Entry. Entry to the facility is controlled by two
armed guards stationed at the main entrance gate. Employees are
required to show identification cards when reporting for work, and
visitors and contractors entering the plant must sign a log sheet
and obtain visitor passes. (See plot plan xyz).
* Use of Natural Barrier. The hazardous waste facility is located
entirely within xyz's operating facility. The facility is enclosed
by a fence and the Michigan River with limited access provided by
24-hour guarded gates. (See plot plan xyz).
Although §270.14(b) mentions specific equipment and procedures that must
be part of security at a facility, the intent of §270.14(b)(4) is that all
procedures and equipment which contribute to facility security should b~
described.
Example:
"In addition to the general security provisions of fencing, gates,
and guards, several other features contribute to the safety and security
of the facility. Ample lighting is provided throughout the site, and
guards and operators are equipped with hand-held, two-way radios to
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report upset conditions immediately. In addition to the two-way portable
radios carried by guards and operators, a base station for the public
address system is located in the plant manager's office. An internal
telephone system (with phones in most plant areas) is provided. The same
telephone system is used for communication outside the plant."
It is important to note that the requirements of §264.14(b) are satisfied
if the active portion is located within a facility or plant which itself has a
surveillance system, or a barrier and a means to control entry, which complies
with the requirements of §264.14(b). Thus, a separate security system around
only the active'portion may not be required. However, the requirements for
signs around the active portion, as discussed below, would still be applicable.
5.4.2.3 Signs--
Regardless of the methods employed to limit entry to the active portion
of the facility, the owner or operator must post signs in accordance with the
requirements of S264.14(c). There are four requirements for any signs. They
are:
• A legend which makes it plain that unauthorized persons are in
danger and are not allowed into the active portion of the facility.
• Legibility from a distance of at least 25 feet.
• Visibility from any approach to the active portion of the facility.
• Legend in English and in any other language predominant in the area
surrounding the facility.
In §264.14(c), the legend "Danger-Unauthorized Personnel Keep Out" is
suggested. However, any legend that makes it clear that danger exists and
entry authorization is required is acceptable. A sign with a symbol alone is
not sufficient, a written legend is also necessary.
The legibility of any sign will depend on the viewing conditions and the
size and shape of the letters. A reputable industrial safety sign
manufacturer is likely to be your best source of information on the legibility
of a particular sign or legend at 25 feet. The American National Standards
Institute's standard ANSI Z35.1 "Specifications for Industrial Accident
Prevention Signs" may also be of assistance. The sign colors, dimensions, and
the height of the letters on the proposed signs should be identified in the
application. If the stroke-to-width ratio of the letters is available it
should be considered for inclusion in the application.
The signs should be placed at all entries to the active portion of the
facility. In addition, they should be placed at intervals around the
perimeter of the active portion such that they are visible from all angles of
approach. The spacing and location of the signs should be stated in the
permit application.
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The need to include the legend on Che sign in a language other than
English will depend on the predominance of another language in the area of the
facility. The posting of two signs in different languages close together is
acceptable, provided that they both meet the legibility and visibility
criteria. Facilities in counties bordering Quebec Province are required to
choose French as the second language and those bordering Mexico must choose
Spanish. In some areas, it may be necessary to post signs in English and more
than one other language.
Example:
"The signs to be posted will bear the legend 'Danger - Unauthorized
Personnel Keep Out1. They are diamond-shaped and measure 10 inches on
each side. The letters will be two inches high and will be red on a
reflective white background. The manufacturer estimates they are legible
in daylight at distances to 50 feet. Identical signs bearing the same
legend in French will be posted next to each English sign. The signs
will be posted at each vehicle and personnel access point and attached to
the facility perimeter fencing at corners and at 75-foot intervals (see
plot plan xyz)."
5.A.2.4 Exemptions/Waivers—
The provisions of §264.14(a) provide that you may request an exemption/
waiver from the security provisions in §264.14(b) and (c). If you believe a
waiver of any of the requirements of §264.14 is appropriate, you must
demonstrate that unknowing or unauthorized persons or livestock would not
injure themselves or cause a RCRA violation upon entering the active portion
of your facility. Both these points may be demonstrated by showing that tho
nature and duration of the hazard potential from the hazardous waste onsite
does not warrant the required security procedure or equipment. In addition,
if you can show that your facility provides certain features, such as cover
materials or containers, that would prevent contact with equipment or
structures, certain security procedures and equipment might not be needed.
Finally, a waiver justification could show that safety or operating practices
related to equipment and structures would eliminate the potential for an
intruder to cause a spill, mix incompatible wastes, ignite ignitable or
reactive waste, damage containment or monitoring systems, etc. The
circumstances under which a waiver will be granted are limited.
The following are two examples of facility scenarios where a waiver of
security has been requested.
Example 1:
The permit applicant has stated that the landfill does not have a
security system and has requested a waiver from that requirement. The
following reasons have been provided as justification in support of the
request;
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Landfill is in a remote, relatively unpopulated region.
Six inches of cover material is applied daily.
Wastes are toxic as determined by the extraction procedure (EP)
of Appendix II, 40 CFR 261, with greater than 100 times the
drinking water standard of chromium.
Precautions have been taken at the facility to protect
equipment and structures from unauthorized operation or
tampering.
^ EPA W°Uld jUdge this demonstration to be
«ui tm fe facility is located in a remote area' the
potential still exists for a person or animal to gain access to the
^ni -I iP°r °n °f C*e facility- Such unauthorized entry may be
unlikely to result in injury, since chromium is not usually toxic on
mat rial """'T ' ^ P°tentUl ""^ f°r the Disturbance oTco'ver
for vioU^r8"^^8 10 a.hazard' ™- "<>"" indicate the potential
Reai™! AH " ° * 6 Perm1'' ^ facilifcy ""I* be required by the
dep8th of c^er "t0r '" ln9taU ^^ 'ecurit* « -"ease
Example 2:
seoarltP P"mit aPPlicant »••• ^ated that the waste pile does not have a
wnoll !nH H * 8y8tem> °nly thC 8ecurity Astern for the plant as a
rquested a waiv« f"™ ^he requirement for a security
• Waste pile is located onsite at a chemical manufacturing
complex. 6
• Waste pile is covered by a secured tarpaulin.
• Physical analysis shows that waste dries to a consolidated
concrete-like mass. '
• Precautions have been taken at the facility to protect
equipment and structures from unauthorized operation or
tampering.
In this case, it is likely that EPA would judge the
Pnt™Ta*J;0n t0 be ade<«uate- Although unknowing or unauthorized
with the Wa8te P* hSS n0t been.Prevented, physical contact
intruder. Further, due to the consistency of the waste^it'is0
unlikely that tampering with the tarpaulin covering the material
will result in violation of standards.
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TABLE 5-14. CRITERIA FOR A DETERMINATION OF EXEMPTION
Category
Determination of Hazard
to Intruder
Determination of Risk of
Violating Other Standards
Favorable Factors
for Exemption
Physical contact with waste will
not result in injury
An intruder could not cauae a spill
An intruder could not mix incompatible
wastes nor ignite ignitable or
reactive wastes
An intruder could not damage contain-
ment or monitoring equipment in a
manner chat would cause a violation
General inaccessabilicy of waatea
relating Co management strategy
(e.g., deep burial, covered tank)
Vehicles and structures are pro-
tected from unauthorized operation
or tampering
Principal Tools for
Determination
Review of chemical and physical
analyses of waste sample
Identification of hazard properties
of waste baaed on available literature
Determination of length of time waste
is hazardous
Review of permit application for con-
ditions such as: waste consists of
a solidified and relatively immovable
mass, or waste containers are securely
sealed and valves are protected from
tampering
Review of permit application for condi-
tions such as: the absence of these
types of waatea at the facility, or
ignitable or reactive wastes are
covered in a manner that would prevent
contact with ignited materials such aa
matches or cigarettes
Review of permit application for con-
ditions such as: inaccessability of
structures to intruders, protection
of monitoring equipment by locked
housing
Review of permit application to de-
termine the preaence of natural and
man-made barriers
Review of permit application for
safety practicea, such as locking
of vehicle ignitions or storage of
vehicles in locked garages
Areas of Judgement
Evaluation of class of Hazard
and degradation
Determination that intruder actions
would not result in a violation
Evaluation of the probable effec-
tiveness of barriers in preventing
physical contact with wastes
Determination that contact with
equipment or structures would not
result in intruder injury or vio-
lation of standards
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5.4.2.5 Post-Closure Security—
Subpart G of Part 264 contains security requirements at disposal
facilities during the post-closure period in §264.117(b). All applicants
should read those requirements to determine if they are applicable to their
facility. Post-closure security requirements should be addressed in the
post-closure plan required by §264.118.
5.4.3 List of Major Points
1. Which option under §264.14(b)(l) or (2) will be used?
(a) Where is the gate or barrier with means to control entry? How
is barrier situated in relation to the active portion of the
facility? Provide plans.
(b) If 24-hour surveillance is used, describe in detail. Provide
plans.
2. Where are the Danger Signs posted - in what language, are they
described? (§264.14(c))
3. Will any other security procedures be used e.g., lights, dogs, etc.
(§270.14(b)(4))
4. If applying for a waiver, was a case made to demonstrate compliance
with §264.14(a)(l) and (2)?
Additional background discussion on the security requirements of §264.14
is available in the preamble on security in the May 19, 1980 Federal Register
at page 33180.
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5.5 INSPECTIONS
5.5.1 Regulatory Citations
Information on inspection schedules must be included in Part B of the
permit application, as specified in:
"§270.14(b)(5) A copy of the general inspection schedule
required by §264.15(b); include where applicable; as part of the
inspection schedule, specific requirements in §§264.174, 264.194,
264.226, 264.254, 264.273, 264.303, and 264.347."
The regulatory requirements regarding inspections are contained in
S264.15(b) and, depending on the type of facility, additional requirements are
in the sections of the regulations noted at the end of §270.14(b)(5).
Although §270.14(b) references only paragraph (b) of §264.15, the entire
§264.15, General Inspection Requirements, is presented below, since the
requirements of all four paragraphs, (a) through (d), will have to be
addressed in your inspection plan. The §264.15 regulatory requirements are:
1264.15 General inspection requirements.
(a) The owner or operator must inspect his facility for
malfunctions and deterioration, operator errors, and discharges
which may be causing—or may lead to—(1) release of hazardous waste
constituents to the environment or (2) a threat to human health.
The owner or operator must conduct these inspections often enough to
identify problems in time to correct them before they harm human
health or the environment.
(b)(l) The owner or operator must develop and follow a written
schedule for inspecting monitoring equiment, safety and emergency
equipment, security devices, and operating and structural equipment
(such as dikes and sump pumps) that are important to preventing,
detecting, or responding to environmental or human health hazards.
(2) He must keep this schedule at the facility.
(3) The schedule must identify the types of problems (e.g.,
malfunctions or deterioration) which are to be looked for during the
inspection (e.g., inoperative sump pump, leaking fitting, eroding
dike, etc.).
(4) The frequency of inspection may vary for the items on the
schedule. However, it should be based on the rate of possible
deterioration of the equipment and the probability of an
environmental or human health incident if the deterioration or
malfunction of any operator error goes undetected between
inspections. Areas subject to spills, such as loading and unloading
areas, must be inspected daily when in use. At a minimum, the
inspection schedule must include the terms and frequencies called
for in §§264.174, 264.194, 264.226, 264.253, 264.254, 264.303, and
264.347, where applicable.
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(c) The owner or operator must remedy any deterioration or
malfunction of equipment or structures which the inspection reveals
on a schedule which ensures that the problem does not lead to an
environmental or human health hazard. Where a hazard is imminent or
has already occurred, remedial action must be taken immediately.
(d) The owner or operator must record inspections in an
inspection log or summary. He must keep these records for at least
three years from the date of inspection. At a minimum, these
records must include the date and time of the inspection, the name
of the inspector, a notation of the observations made, and the date
and nature of any repairs or other remedial actions.
The EPA will evaluate your inspection schedule along with the rest of
your inspection plan and your entire Part B submittal to insure that it
adequately protects human health and the environment. As part of that review,
EPA may request modification or amendment to the inspection schedule, as may
be necessary.
5-5.2 Guidance to Achieve the Part 264 Standards
5.5.2.1 General—
The intent of the §264.15 requirements and the facility-type specific
requirements on inspections is to insure that all owners and operators have
identified key pieces of equipment and areas of their operations where
scheduled inspection will minimize equipment failure which could lead to
endangerment of public health or the environment. By requiring the
development and submittal of an inspection schedule, the Agency intends to
insure that all hazardous waste facilities are closely monitored by their
owners and operators so that they will continue to function as designed
throughout the active lives and, when applicable, the post-closure periods.
In order to comply with the requirements of §26A.15(b) you must;
• Have and follow a written inspection schedule.
• Keep the schedule at your facility.
In order to qualify as an adequate inspection schedule your submittal
must;
• Identify the specific equipment to be inspected.
• Identify how each item will be inspected.
• Contain a justifiable frequency for inspecting each item.
• Contain a schedule for additional inspections required by the
regulations depending on the type of facility you are operating.
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The additional inspection requirements for specific types of facilities
can be found in the sections listed at the end of §264.15(b)(4). They are;
1264.174 - Inspection of Containers
1264.194 - Inspections of Tanks
1264.226 - Inspections of Surface Impoundments
§264.253 - Inspections of Waste Pile Liners
S264.254 - Inspections of Waste Piles
$264.303 - Inspections of Landfills
Although not specifically called out in §264.15(b)(4), there are
additional inspection requirements for Land Treatment facilities. Those
requirements are specified under §264.273, Design and Operating Requirements,
in paragraph (g) of that section. If you are requesting a permit for a land
treatment facility you must address the requirements of S264.273(g) in your
inspection plan. Additional inspection requirements for incineration
facilities are contained in §264.347. However, the Agency plans to discuss
those requirements in detail in a separate document.
Possibly the easiest and most straightforward way to satisfy the
inspection schedule requirements is to develop an inspection plan in total in
the form that it will be implemented and include it with your permit
application submittal. In this way you will not only comply with the
requirements of §270.14(b)(5), but you will also demonstrate compliance with
all of the §264.15 requirements.
Developing a Schedule—The first step in developing a schedule is
identification of all equipment, devices, and structures that will be
inspected. Identification can be organized either by equipment type (safety
equipment, security devices, monitoring equipment) or by facility operating
area (receiving area, treatment area, office area) or both. If you are
grouping strictly by types of equipment, remember that areas of the facility
that have no equipment, such as roadways or other traffic areas, must be
inspected. Table 5-15 is a list of equipment and operating areas that will
typically be a part of any hazardous waste management facility. Use that list
as a starting point and add equipment, devices, structures, and areas specific
to your facility. The list is by no means exhaustive. It is intended to
guide your thinking of the types of equipment or areas that should be
identified and provide examples of the detail desired in your submittal.
Further, the listing of items under topical headings in the table is not meant
to define the item. You should organize your presentation in the most lucid
manner that is representative of your facility.
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TABLE 5-15. EQUIPMENT, STRUCTURES, AREAS TO BE CONSIDERED FOR INCLUSION
IN AN INSPECTION SCHEDULE
Safety Equipment
Emergency Shower/Eyewash
Face Shields
Protective Glasses
Disposable Respirators
First Aid/Equipment Supplies
Protective Clothing
Gas Masks
Chemical Respirators
Signs
Monitoring Equipment
Liquid Level Transmitters
Conservation Vents
Leak Detection System
Fire Detection System
Ground Water Monitoring System
Liquid Meters
Mobile Equipment
Tires/Tracks
Brakes
Hydraulics
Trailer Hitches
Lights-Running/Emergency
Horns/Sirens
Engine Conditions
Structures
Dikes
Berms
Ramps
Lifts (Elevators)
Tank Supports
Bases/Foundst ions
Roofs
Walls
Emergency Equipment
Fire Blankets
Fire Extinguishers
Fire Alarm System
Generators
Emergency Lights
Portable Pumps/Hoses
Fire Fighting Wagon/Hoses
Self-Contained Breathing Apparatus
Absorbents
Containment Booms
Security Equipment
Fences-Facility/Area
Signs
Gates
Lighting
Locks
Areas
Loading Area
Unloading Area
Storage Area
Main Roadways
Gate Areas
Periphery
Communication Equipment
Telephones
Radios
Intercoms
Public Address System
TV Monitoring System
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The detail with which you identify equipment to be inspected is very
important. For example, suppose you have a pump mounted on a trailer that
will be used to transfer hazardous liquids in the event of an emergency. The
statement "check mobile emergency pump" is likely to be judged inadequate.
However, if you list specific parts of the apparatus that should be checked
under that heading, then you are providing the detail expected. An example of
the necessary detail is presented below:
Check mobile emergency pump
hitch operable
tire inflation (between and Ib)
inlet/outlet pump connections clean/operable
hose connections clean/operable
5-10 ft lengths of inlet hose on trailer
5-10 ft lengths of outlet hose on trailer
hose condition
motor to pump shaft connections
Additionally, if the pump is gasoline-powered; then checks of spark-plug
condition and fuel tank level would be listed. For electric-powered, power
cord condition and cord connector condition checks would be indicated, and
so on. Other items which should be considered for inclusion in an inspection
plan for all types of pumps include;1
• pump pad condition
• anchor bolt tightness
• pump/motor shaft alignment
• bearing temperatures
• electrical conduit integrity
• bearing oil reservoir level
• vibration/noise
• seals/packing integrity
• primary liquid availability
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The above examples of items that should be considered for pump
inspections are indicative of the level of detail that you should provide in
an inspection plan for any equipment, device, or structure. In essence, the
level of detail required in the inspection -varies depending on the role of the
equipment or area inspected. Emergency equipment, such as the example pump
discussed above, should be thoroughly inspected to insure that it will perform
its contingency action and, thus, prevent dangerous conditions. The detail
required in inspection of noncontingency equipment will in many cases be as
stringent, but generally not as detailed.
Inspection Procedures—Once you have identified all the equipment,
structures, or areas to be checked during the inspections, the next step is to
document how each item on the list is checked or inspected. Simply using
words like "check" or "observe" is inadequate. Rather, use phrases such as
'check for by " or "observe for signs of ". Using
the mobile emergency pump as an example, the applicant should indicate in the
inspection procedures;
• Check tires for proper inflation by using a tire pressure gauge and
record the reading for each tire.
• Observe hose connections for signs of rust, corrosion, or dirt
buildup that might prevent a tight connection.
Many structures or areas will not lend themselves to a quantitative
measurement which is otherwise possible for a piece of mechanical equipment.
In these cases, the inspection procedures should indicate a visual inspection,
as a minimum, but be certain that the procedures state "what to look for" and,
as specifically as possible, "where to look." Examples are;
• "Walk along the top of the dike. Look for erosion rivelets or
slides on the slopes on either side. Look for signs of settling and
unevenness along the top edge. Look for signs of liquids (puddles,
dampness) on the sloping sides of the dike and especially along the
flat surfaces at the bottom of the dike slope for a distance
of ft away from the bottom of the dike slope."
• "Walk along the roadway from the main gate to . Look at the
roadway surface for signs of subsidence, bumps, holes, cracks or
other signs of damage. Look for signs of spillage from vehicles,
especially around turns and corners. Observe both edges of the
roadway for materials that may have fallen from vehicles and
collected there."
Inspection Frequencies—The next step in preparing an adequate inspection
plan is determining a justifiable frequency for conducting the inspections of
each item. The regulation (§264.15(b)(4)) states that the frequency "should
be based on the rate of possible deterioration ... and the probability of an
... incident if the deterioration or ... operator error goes undetected
between inspections." As will be discussed later, some of the facility-
specific regulations set daily, weekly, or other periodic requirements for
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inspecting certain components of the facility. In general, equipment,
structures, or areas that are subjected to daily or continual use or stress
should be inspected more frequently than backup or emergency components.
Items inspected less frequently should be subjected to more rigorous
inspection. However, if the failure of equipment used continuously would pose
a hazardous situation of any kind, the inspection should be rigorous, as well
as frequent.
For example, a mobile emergency pump might receive a thorough inspection
in an inactive mode once per month, while active pumps might be visually
inspected once per day. Where an emergency pump might be tested in operation
on a quarterly or semiannual basis to insure proper suction and discharge
pressures and a nonleaking condition, active pumps might be so tested on a
weekly basis.
Continual or frequent successful use of an area or equipment item does
not substitute for inspection. For example, although plant communcations
equipment may be used at the facility for paging or indicating work-breaks,
that system should be inspected on a scheduled basis, if it will be used to
signal emergency situations.
5.5.2.2 Inspections of Containers—
The owner or operator of any facility that stores containers of hazardous
waste must, in addition to the inspection requirements of §264.15, comply with
the inspection requirements of §264.174, which are;
"§264.174 Inspections.
At least weekly, the owner or operator must inspect areas where
containers are stored, looking for leaking containers and for
deterioration of containers and the containment system caused by
corrosion or other factors."
These requirements are straightforward. They state that you must inspect the
containers and their associated containment system every week. The regulation
states what must be looked at (containers and containment system), the
frequency (weekly), and, generally, what to look for (leaks and
deterioration). You must, therefore, address these three concerns in your
inspection plan, but you must also provide additional details specific to your
facility. You should indicate the locations where the inspector will check
for leaks and deterioration; whether the inspection will be visual,
quantitative, or both; decision criteria for determining deterioration, and
follow-up action in the event of such leakage or deterioration.
For example;
"Look at the concrete pad, check for cracks in the surface or curbs,
flaking, chips or gouges and areas of wear. Check for liquid in the sump
at the northeast corner of the pad."
Examples of the types of containers for which inspection procedures
should be provided are drums, barrels, pails, railroad tank cars, tank
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coniidpr:/1^ °-h^ P°rtable containers. Examples of items that should be
considered for inclusion in an inspection plan for containers include checks
• tightness of lids
• leaks in flanges
• high liquid level/overflow
• leaks in plug seals
• evidence of corrosion
8f8^°Uld b* infpected before and d«i«8 waste addition and storage.
of inspection items before waste addition include:
• wheels properly braked/chocked
• drain valves closed tight
• inside walls/compartment dividers free of corrosion
• overfilling controls operative
containers located so as to minimize potential for external puncture
<° "Ceive and 8tore wastes at your facility, tank cars, tank
il» , , a
fir rhl K p°rtabl* containers should be periodically inspected, not only
for the above items, but also to the same extent as a stationary tank.
imn.rM T", f°V0ine Cype8 of containers will typically consist of an
impermeable pad made of a material such as concrete. These pads should be
included in the inspection plan. Procedures for inspecting them for chips,
are reco^A^'f86"-"! d
-------
Finally the provisions of H264.15(c) and 264.171 require certain
slu=!-^fu=?ss.- "
5.5.2.3 Inspections of Tanks —
22 5
"S264.194 Inspections.
(a) The owner or operator must inspect;
systems a£ehfillin8 ""'"I e"uiPraent «••••• w«'e feed cut-off
ensure that JH"" "^T^ " I6a8t °nce "Ch °Perating day to
ensure that it is in good working order;
•..»„., Datfi 88th®red f"m monitoring equipment (e.g., pressure and
temperature gauges) where present, at least once each operatinTday
to ensure that the tank is being operated according to its Design *
(3) For uncovered tanks, the level of waste in the tank at
ea8'™ t0 en8U" Compliance with '
f°n8truction materials of the above-ground portions of
0 detect corr°8ion °r
r« H !5^Thu a"a iomediately surrounding the tank, at least weekly
v*± , ? °US 8lgn8 °f leakage (e'8" wet 8Pot» or dead Y>
vegetation^ .
«nrf ,-n °f the insPection schedule required in §264.15(b)
10'0
n .
Section10^'0 ^ SP6CifiC «<'ui«ment«' of paragraph (a) of
nron ! ' °^er " °Perator must develop a schedule and
procedure for assessing the condition of the tank. The schedule and
erosifon wh"Uh f^!""' tO detCCt Cr3Ck8' leaks> corrosion or
llll S^I" w"'y -° °raCk8 " leak8' Or wal1 Binning to less
I tank ? 'Vf"688 re
-------
The provisions of §264.19A(b) require you to develop a schedule and
procedure that will provide a detailed inspection of the integrity of the
tank. This requirement is in addition to the more cursory weekly tank
inspection required by §264.194(a) and is indicative of the need for a
thorough inspection of the tank walls and seams using appropriate
instrumentation or gauges.
Storage tanks are similar to containers with respect to the items that
should be included in an inspection plan. Thorough inspection for evidence of
corrosion, which may lead to leaking, is particularly important. In addition,
the inspection plan should provide that tanks will periodically be emptied and
the interior walls and seams inspected for signs of deterioration. A detailed
description of this procedure is important. The description should address
where the waste will be placed when the tank is emptied, identify the type of
equipment that will be used to conduct the inspection of the tank interior,
and explain the inspection that will be conducted to insure that the tank is
ready to be returned to service.
Pressure/vacuum vents, vent seals, roof drains, inlet/outlet connections,
and seals are additional items that should be considered for inclusion in the
inspection plan. Examples include;
• Determination of pressure/vacuum vent set-point
• Seating of vent seals
• Check for/remove foreign materials in roof drains
• Check inlets/outlets for blocking/corrosion
• Check seals on:
manholes
gauge hatches
inlet/outlet nozzles or flanges
weather shields
level gauges
Overfilling control systems will typically consist of some type of liquid
level monitoring device with an output signal that is used to close an inlet
valve, open a by-pass valve, or sound an alarm. In some cases, however, the
overfilling control equipment may simply be a hook gauge, tape-and-plumb bob,
or manometer which is periodically visually checked. The regulation requires
daily inspection of these control systems to insure their proper operation.
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The liquid level monitoring devices which provide a visual indication of
liquid level can usually be visually inspected to insure that their mechanical
parts are not binding or "hung-up". However, inspection checks of manometers
may also include confirmation that the unit is level, checks for blockage
leaks and good seal connections on fluid lines, and confirmation of sufficient
level in fluid wells. Periodic flushing of manometer fluid lines should also
be considered for inclusion in the inspection schedule if warranted by service
conditions.
The following are example items that could be included in inspections of
float actuated liquid level sensing devices;
• check float for bouyancy/liquid infiltration
• check lever arm and interconnecting rods for integrity and freedom
of movement.
Inspections of electronic level sensing units could include checking of
wiring condition, probe position and condition, and condition of seals.2
Periodic calibration and checks in accordance with manufacturer's
recommendations should also be indicated in the inspection plan.
In cases where the liquid level sensor, regardless of type, provides a
signal for valve control or alarm activation, the entire system must be
inspected on a daily basis. The inspection plan should provide a detailed
description of how this will be done and what items will be inspected. A
clear description of how a false high liquid level indication will be input to
the level sensor so that system operation can be confirmed is important.
Other items that should be confirmed during the inspection include;
• system activated at proper preset level
• valves operated properly
• visual and audible alarms functioned properly
• there were no leaks in the system
The provisions of §264.15(c) require you to remedy any leak, crack, or
wall thinning in violation of §264.191, or equipment malfunction in violation
of §264.192, which you may discover as a result of your inspections. In
addition, the provisions of §264.194(b) may require personnel to enter tanks
during inspection. The Occupational Safety and Health Administration
requirements relating to entry of tanks for inspection can be found at 29 CFR
5.5.2.4 Inspection of Surface Impoundments —
Any owner or operator of a facility that uses a surface impoundment to
treat, store, or dispose of hazardous waste must, in addition to the
inspection requirements of §264.15, comply with the inspection requirements of
§264.226, which are;
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"§264.226 Monitoring and inspection.
(a) During construction and installation, liners (except in
the case of existing portions of surface impoundments exempt from
I264.221(a)) and cover systems (e.g., membranes, sheets, or
coatings) must be inspected for uniformity, damage, and
imperfections (e.g., holes, cracks, thin spots, or foreign
materials). Immediately after construction or installation:
(1) Synthetic liners and covers must be inspected to ensure
tight seams and joints and the absence of tears, punctures, or
blisters; and
(2) Soil-based and admixed liners and covers must be inspected
for imperfections including lenses, cracks, channels, root holes, or
other structural non-uniformities that may cause an increase in the
permeability of the liner or cover.
(b) While a surface impoundment is in operation, it must be
inspected weekly and after storms to detect evidence of any of the
following:
(1) Deterioration, malfunctions, or improper operation of
overtopping control systems;
(2) Sudden drops in the level of the impoundment's contents; and
(3) The presence of liquids in leak detection systems, where
installed to comply with §264.222; and
(4) Severe erosion or other signs of deterioration in dikes or
other containment devices.
(c) Prior to the issuance of a permit, and after any extended
period of time (at least six months) during which the impoundment
was not in service, the owner or operator must obtain a
certification from a qualified engineer that the impoundment's dike,'
including that portion of any dike which provides freeboard, has
structural integrity. The certification must establish, in
particular, that the dike:
(1) Will withstand the stress of the pressure exerted by the
types and amounts of wastes to be placed in the impoundment; and
(2) Will not fail due to scouring or piping, without dependence
on any liner system included in the surface impoundment
construction."
The provisions of §264.226 require inspections at two distinct times;
during and immediately after construction (paragraph(a)), and weekly during
operation (paragraph (b)). In addition, paragraph (c) requires that a
qualified engineer certify the unit's integrity before a permit will be issued
or at any time that the impoundment has been out of service for 6 months or
more.
The intent of paragraph (a) is to insure that both the materials and the
construction of a surface impoundment comply with the plans which have served
as a basis for granting a permit. Although the material suppliers and
construction contractors will employ quality assurance procedures and tests,
you must include provisions in your inspection plan for overseeing and
reviewing the contractor or supplier procedures. The personnel you identify
to conduct these inspections should represent only the owner's or operator's
interests. The inspection procedures should include a statement of when,
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during construction, the inspections will be conducted and should provide for
inspector approval before construction is allowed to continue, it may be
necessary to identify multiple inspectors to insure that qualified personnel
are conducting the inspections during the various construction phases.
Paragraph (a) of §264.226 specifically mentions liners and cover
systems. However, any inspection plans submitted to comply with §264.226(a)
should provide for inspection of materials and construction of all the various
components of the surface impoundment. The following paragraphs offer
examples of items that should be inspected during and immediately after
construction.
Raw materials—All materials that will be used to construct the surface
ind°«1itment,.8hOUld b! in8Pected "P°n receipt at the site. These include soils
and aggregates, synthetic liner materials, pipes or trench materials, and any
other materials that are purchased or delivered to the site. The material
I™61*6? ! u6 C°mPared to the Dipping papers. Shipping papers should be
compared to purchase orders and to the original plan specifications. Any
tests that may be conducted on the materials, in addition to visual
inspection, should be described. The inspection procedures should identify
damaged shipping containers or wrappings. If only samples of a shipment will
be inspected, justification of the representativeness of this procedure should
be provided. If materials are to be stored, the storage area should be
inspected before and during use, and all stored materials should be
periodically inspected. Table 5-16 is an example inspection form which
illustrates the type of information and level of detail that would constitute
an adequate inspection plan.
Construction equipment and procedures—The inspection plan should provide
tor observation of surface impoundment construction. The equipment used and
procedures of operation should be observed. As construction proceeds, the
inspector should periodically check key dimensions of the impoundment (e.g.,
height and thickness of berme and dikes) as a check on the contractor's
surveyor.
Post-construction inspections—Liner and cover systems are typically
constructed of multiple layers. The inspection procedures should indicate
that each of these layers will be inspected before any overlying layers are
placed. The installation contractor should be conducting quantitative tests
to confirm that the constructed layers meet design specifications. It is not
necessary for the inspector to independently conduct these tests. However
the inspector should observe them being conducted and review the results in
detail.
The portion of the inspection plan developed to comply with §264.226(a)
should address the following topics; what will be inspected, when will it be
inspected, what will be looked for, how will it be inspected, and what
criteria establish failure and require corrective action. Table 5-17 is a
summary list of example items that should be considered for inclusion in an
inspection plan to satisfy §264.226(a). The items in the table are neither
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TABLE 5-16. EXAMPLE RAW MATERIAL INSPECTION FORM
Name/Type Screened and washed sand
Quantity Received 100 cu yards
Received In 10 Truckoads
of 10 cu yards
each
Shipping Papers: X compared to material received
X compared to purchase order
X compared to plans specifications
Amount of Material Visually Inspected All
Samples Taken 3-from first, fifth, and last truckloads-all grab
Sample Analysis Performed Sieve on all three
Analysis Results
_X Sent to Storage in rear-equipment shed No. 5
Sent to Site for Installation
Visual Inspection Results
Date Location
4/8/83 Yard
Comments
Inspection at receipt-looked OK
4/15/83 Storage Erosion losses noted-sand bagged circumference
of pile
4/23/83 Site Moved from storage-installed, looked OK—last
load from each pile hand-raked
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TABLE 5-17. EXAMPLE ITEMS FOR SURFACE IMPOUNDKENT INSPECTION PLAN
What to inspect
When to inspect
What to look for
How to inspect
\o
o
Raw materials
At receipt
In storage
At installation
Construction procedures During construction
Finished components
At completion
Shipping damage
Off-spec items
Deterioration
Contamination
Deterioration
Contaminat ion
Handling damage
Proper placement
Proper equipment
Proper execution
Lenses, holes, cracks, etc.
Permeability
Seam integrity
Dimensions
Repairs
Visual
Visual/grab samples
Visual
Visual
Visual
Visual/testing
Visual
Visual/check plans
Visual
Review with installer
Visual checks
Visual
Perform/review tests
Perform/review tests
Measurements
Visual/testing
-------
all inclusive nor detailed. Your inspection plan should indicate what type of
deterioration to look for, where to visually inspect the material, what
samples to take, and what tests to perform or review. For example;
• "As the liner material is being unfolded, check for 'blocking' by
looking for places where delamination has occurred, check for cracks
by looking at places where the material was folded," or
• "After the sand has been spread, and rough graded, but before final
compaction or grading walk across it in a 'zig-zag1 fashion looking
for off-size or foreign materials."
Paragraph(b) of §264.226 identifies four things that must be inspected
weekly and after storms; overtopping control systems, liquid level, leak
detectiotTsystem (if present), and dikes and other containment devices. These
inspections need to be conducted when the surface impoundment is in operation,
or any time that it contains waste. The requirement for inspection after
storms is in addition to the weekly inspection requirement.
The need to conduct inspections during a storm of extended duration will
depend on the location and design of the surface impoundment. The permit
applicant should consider how to address the need for inspections during a
storm when preparing the inspection plan. Table 5-18 is a list which
illustrates the type of information and level of detail which an adequate
inspection plan would generate.
In some cases, a synthetic liner will be protected by a layer of soil
from potential damage due to sunlight or wind. This protective soil layer
should be included in the inspection plan.
If mechanical equipment is used to remove sludge from the bottom of the
impoundment, checks of its operation and condition should be included to
insure that the liner is not being damaged. When sludge removal equipment is
used in a synthetically lined impoundment, a layer of protective soil is
usually installed. This protective soil liner should be included in the
inspection plan to insure that its depth over the liner is maintained.
Paragraph (c) of §264.226 requires that the structural integrity of the
surface impoundment dike be certified by a qualified engineer. For a surface
impoundment operating under interim status, part of the certification process
should be a site inspection of the dike. For a new unit, the certification
will be based on a review of the final design and specifications. If a
surface impoundment is not in service for any extended period (at least
6 months), then certification is required before it can resume operation. In
any of these cases, the permit applicant should consider including, as part of
the certification, any calculations conducted to establish that the dike
complies with §264.226(c)(l) and (2).
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TABLE 5-18. EXAMPLE LIST OF ITEMS FOR AN INSPECTION PLAN FOR
AN OPERATING SURFACE IMPOUNDMENT
Inspector Name
Weekly/After Storm Inspection
Time of Inspection
Date of Inspection
Liquid Level Indicator/Controller Check
Inlet Flow Valve Check
High Level Alarm Check
By-pass System Check
Liquid Level Check/Record
Leak Detection/Containment System Check
Evidence of liquid
Pump operation
Component integrity
Dike/Containment System Check
Subsidence/erosion/corrosion
Leaks
Dampness
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5.5.2.5 Inspections of Waste Piles—
Any owner or operator of a facility that stores or treats hazardous waste
in piles must, in addition to the inspection requirements of §264.15, comply
with the inspection requirements of §264.254. If the pile qualifies for
exemption from the Part 264, Subpart F requirements, then the owner or
operator must also comply with the inspection requirements of §264.253(a)(3).
The inspection requirements for all waste piles are;
"§264.254 Monitoring and inspection.
(a) During construction or installation, liners (except in the
case of existing portions of piles exempt from §264.251(a)) and
cover systems (e.g., membranes, sheets, or coatings) must be
inspected for uniformity, damage, and imperfections (e.g., holes,
cracks, thin spots, or foreign materials). Immediately after
construction or installation:
(1) Synthetic liners and covers must be inspected to ensure
tight seams and joints and the absence of tears, punctures, or
blisters; and
(2) Soil-based and admixed liners and covers must be inspected
for imperfections including lenses, cracks, channels, root holes, or
other structural non-uniformities that may cause an increase in the
permeability of the liner or cover.
(b) While a waste pile is in operation, it must be inspected
weekly and after storms to detect evidence of any of the following:
(I) Deterioration, malfunctions, or improper operation of
run-on and run-off control systems;
(2) The presence of liquids in leak detection systems, where
installed to comply with §264.252; '
(3) Proper functioning of wind dispersal control systems,
where present; and
(4) The presence of leachate in and proper functioning of
leachate collection and removal systems, where present."
Additionally, for waste piles which qualify for exemption from the Part 264,
Subpart F requirements for ground water protection, the inspection
requirements are;
"§264.253(a)(3) The wastes in the pile must be removed
periodically, and the liner must be inspected for deterioration,
cracks, or other conditions that may result in leaks. The frequency
of inspection will be specified in the inspection plan required in
§264.15 and must be based on the potential for the liner (base) to
crack or otherwise deteriorate under the conditions of operation
(e.g., waste type, rainfall, loading rates, and subsurface
stability)."
The provisions of §264.254 require inspections at two distinct times,
which are; during and immediately after construction (paragraph(a)), and
weekly during operation (paragraph (b)). In addition, §264.253 requires that
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owners or operators of piles which qualify for exemption from Part 264,
Subpart F must periodically remove the wastes from the pile and conduct an
inspection of the pile liner.
The intent of paragraph (a) of §264.254 is to insure that both the
materials and the construction of a waste pile comply with the plans which
have served as a basis for granting a permit. Although the material suppliers
and construction contractors will employ quality assurance procedures and
tests, you must include provisions in your inspection plan for overseeing and
reviewing the contractor or supplier procedures. The personnel you identify
to conduct these inspections should represent only the owner's or operator's
interests. The inspection procedures should include a statement of when,
during construction, the inspections will be conducted and should provide for
inspector approval before construction is allowed to continue. It may be
necessary to identify multiple inspectors to insure that qualified personnel
are conducting the inspections during the various construction phases.
Paragraph (a) of §264.254 specifically mentions liners and cover
systems. However, any inspection plans submitted to comply with §264.254(a)
should provide for inspection of materials and construction of all the various
components of the waste pile. The applicant should refer to the discussion of
inspection of surface impoundments for guidance on inspection plans for raw
materials, construction equipment and procedures, and post-construction
inspections.
The portion of the inspection plan developed to comply with §264.254(a)
should address the following topics; what will be inspected, when will it be
inspected, what will be looked for, how will it be inspected, and what
criteria establish failure and require corrective action. See Table 5-17 in
the preceding discussion on surface impoundments for examples of items to
include in an inspection plan.
Paragraph(b) of §264.254 identifies four things that must be inspected
weekly and after storms; run-on and run-off control systems, liquids in the
leak detection system (if present), wind dispersal control system (if
present), leachate collection and removal systems (if present). These
inspections only need to be conducted when the waste pile is in operation, or
any time that it contains waste. The requirement for inspection after storms
is in addition to the weekly inspection requirement.
The need to conduct inspections during a storm of extended duration will
depend on the location and design of the waste pile. The permit applicant
should consider how to address the need for inspections during a storm when
preparing the inspection plan. Table 5-19 is a list which illustrates the
type of information and level of detail which an adequate inspection plan
would generate.
The inspection requirements of §264.253(a)(3) must be compiled with only
if the waste pile is exempted from the ground water protection requirements of
Part 264, Subpart F by meeting the requirements of §264.253(a)(l), (2), (4)
and (5). The inspection plan, in these instances, should indicate how the
wastes will be removed from the pile, where they will be placed during liner
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TABLE 5-19. EXAMPLE LIST OF ITEMS FOR AN INSPECTION PLAN FOR
AN OPERATING WASTE PILE
Inspector Name
Weekly/After Stonn Inspection
Time of Inspection
Run-on Control System Checks
Checked for integrity
Checked for clogging/blockage
Mechanical parts checked for proper operation
Run-off Control System Checks
Checked for integrity
Checked for clogging/blockage
Run-off collection system capacity confirmed
- Mechanical parts checked for proper operation
Leak Detection/Containment System Checks
Evidence of liquid
Pump operation
Component integrity
Leachate Collection/Removal System Checks
Flow checks
Pump operation
Component integrity
Wind Dispersal Control System Checks
Damage/integrity
Effectiveness
Waste accumulation
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inflPected« and how the wastes will be placed
5.5.2.6 Inspections of Landfills—
t" Z 3S3? -
the inspection requirements of §264.303, which are;
"§264.303 Monitoring and inspection.
r.oa DYring construction or installation, liners (except in the
case of existing portions of landfills exempt from §264 301 (a)) and
in^Tr8 ^f" ?emb"ne8' 8heet8' or Ratings) must bi ' **'
inspected for uniformity, damage, and imperfections (e.g., holes
cracks, thin spots, or foreign materials). Immediately after
"mediately after
s, in spots, or foreign materials). Immediately after
construction or installation: "mediately after
H.hi.(l) Synth"fc.line« and covers must be inspected to ensure
bHstersrand J°int9 *"* ^ ab86nCe °f te"8 • Pictures, or
(2) Soil-based and admixed liners and covers must be inspected
for imperfections including lenses, cracks, channels, root hofes or
other structural non-uniformities that may cause an increase in the
permeability of the liner or cover. increase in the
(b) While a landfill is in operation, it must be insoected
weekly and after storms to detect evidence of anjof the following.
(1) Deterioration, malfunctions, or improper operation of
run-on and run-off control systems- operation ot
present? ^d0^ functionin* of wind dispersal control systems, where
leacht* "^fP^fence of leachate in and proper functioning of
leachate collection and removal systems, where present."
He Pr°vi?ions of §264.303 require inspections at two distinct times
are; during and immediately after construction (paragraph^)) and
provide for inspector approval before construction is allowed to continue it
oer± n""8ar^ " identify -Itipl. inspectors to insure that quSiSS"
phasfs "e C
-------
Paragraph (a) of §264.303 specifically mentions liners and cover
systems. However, any inspection plans submitted to comply with §264.303(a)
should provide for inspection of materials and construction of all the various
components of the landfill. The applicant should refer to the discussion of
inspection of surface impoundments for guidance on inspection plans for raw
materials, construction equipment and procedures, and post-construction
inspections.
The portion of the inspection plan developed to comply with §264.226(a)
should address the following topics; what will be inspected, when will it be
inspected, what will be looked for, how will it be inspected, and what
criteria establish failure and require corrective action. See Table 4 in the
preceding discussion of surface impoundments for a list of example inspection
items.
Paragraph (b) of 264.303 identifies four things that must be inspected
weekly and after storms; run-on and run-off control systems, leak detection
systems (if present), wind dispersal control systems (if present), and
leachate collection and removal systems (if present). These inspections only
need to be conducted when the landfill is in operation, or any time that it
contains waste. The requirement for inspection after storms is in addition to
the weekly inspection requirement.
The need to conduct inspections during a storm of extended duration will
depend on the location and design of the landfill. The permit applicant
should consider how to address the need for inspections during a storm when
preparing the inspection plan. See Table 6 in the preceding discussion of
waste piles for illustration of the type and detail of information that an
adequate inspection plan would generate.
5.5.2.6 Inspections of Land Treatment Facilities—
Any owner or operator of a facility that treats or disposes of hazardous
wastes in land treatment units must, in addition to the inspection
requirements of $264.15, comply with the inspection requirements of
S264.273(g), which are;
"§264.273(g)
The owner or operator must inspect the unit weekly and after
storms to detect evidence of:
(1) Deterioration, malfunctions, or improper operation of run-on
and run-off control systems; and .
(2) Improper functioning of wind dispersal control measures."
The requirements of §264.273(g) are straightforward in requiring weekly
and after storm inspection of run-on, run-off, and wind dispersal control
systems. Run-on and run-off controls which consist of diversion dikes/berms
and open channels or trenches are key to preventing the uncontrolled spread of
waste outside the actual land treatment facility.
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.i contro1 ' -
run-off control s«tem.^ri?-i,? ' r"n"m' c°""°l •ystems. However,
a
aass
for accumulated materials originating from the land treatment unit
5.5.3 List of Major Points
8tructu«8 that wiH be inspected
iiedinH-f-' s« and "ructures
ified in detail for inspection?
3. Is the frequency of inspection for each' item clearly indicated?
"ci- -eluded in the
5. 5. A References
r °Peration *"* Maintenance of Air
Control Equipment, Technomic , Westport, Connecticut. 1975
2' •
i Inc.,
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5.6 PREPAREDNESS AND PREVENTION
5.6.1 Regulatory Citations
Information on preparedness and prevention must be included in Part B of
the permit application, as specified in:
"§270.14(b)(6) A justification of any request for waiver(s) of the
preparedness and prevention requirements of Part 264, Subpart C."
The regulatory requirements regarding preparedness and prevention are
contained in Subpart C of Part 264. They are:
"Part 264 - Subpart C - Preparedness and Prevention
§264.30 Applicability.
The regulations in this Subpart apply to owners and operators
of all hazardous waste facilities, except as §264.4 provides
otherwise.
§264.31 Design and operation of facility.
Facilities must be designed, constructed, maintained, and
operated to minimize the possibility of a fire, explosion, or any
unplanned sudden or non-sudden release of haz'ardous waste or
hazardous waste constituents to air, soil, or surface water which
could threaten human health or the environment.
"§264.32 Required equipment.
All facilities must be equipped with the following, unless it
can be demonstrated to the Regional Administrator that none of the
hazards posed by waste handled at the facility could require a
particular kind of equipment specified below:
(a) An internal communications or alarm system capable of
providing immediate emergency instruction (voice or signal) to
facility personnel;
(b) A device, such as a telephone (immediately available at the
scene of operations) or a hand-held two-way radio, capable of
summoning emergency assistance from local police departments, fire
departments, or State or local emergency response teams;
(c) Portable fire extinguishers, fire control equipment
(including special extinguishing equipment, such as that using foam,
inert gas, or dry chemicals), spill control equipment, and
decontamination equipment; and
(d) Water at adequate volume and pressure to supply water hose
streams, or foam producing equipment, or automatic sprinklers, or
water' spray systems.
§264.33 Testing and maintenance of equipment.
All facility communications or alarm systems, fire protection
equipment, spill control equipment, and decontamination equipment,
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» — <• «••<•
§264.34 Access to communications or alarm system.
iu
§264.35 Required aisle space.
§264.36 Special handling for ignitable or reactive waste.*
§264.37 Arrangements with local authorities.
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(4) Arrangements to familiarize local hospitals with the
properties of hazardous waste handled at the facility and the types
of injuries or illnesses which could result from fires, explosions,
or releases at the facility.
(b) Where State or local authorities decline to enter into such
arrangements, the owner or operator must document the refusal in the
operating record."
Requests and justifications for waivers of any of the Part 264 -
Subpart C requirements must be made in Part B of the permit application. The
inherent hazards associated with the treatment, storage, and disposal of
hazardous waste reduce the possible scenarios where valid justification for
waivers could be demonstrated. Thus, the guidance provided will be for owners
or operators of hazardous waste facilities attempting to achieve compliance
with the Part 264 standards.
5.6.2 Guidance to Achieve the Part 264 Standards
5.6.2.1 General—
The intent of Subpart C of Part 264 is to insure that each permit
applicant provides a complete description of the preparedness and prevention
measures which have been or will be implemented at the HWM facility to
minimize the possibility of a fire, explosion, or any unplanned sudden or
non-sudden release of hazardous waste or hazardous waste constituents to air,
soil, or surface water which could threaten human health or the environment.
Subpart C sets requirements on:
• Facility design and operation in §264.31,
• Equipment available in §264.32,
• Equipment testing and maintenance in §264.33,
• Communications or alarm systems in §264.34,
• Aisle space in §264.35, and
• Arrangements with local authorities in §264.37.
Much of the information necessary to demonstrate compliance with the
requirements of Subpart C will be developed and contained in detail in other
portions of Part B of the permit application. In these cases, a brief
description should be incorporated in the discussion of Preparedness and
Prevention and the location of the specific details should be referenced.
Additionally, the Subpart C requirements are closely tied to the
Contingency Plan required by Subpart D of Part 264. The Contingency Plan is
described in the next section of this manual. Whereas Subpart C requires a
description and documentation that efforts have been taken to prevent and be
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'
artT^ °J Unpl««"ence, the Contingency Plan
0"'11" l1 «" « an
5264.30-264.37]
^
the
four KrcKMS?.^' [i264-321- ?"» ««"l«io« specifically identifies
di»u».d in ?h« Ur -r""? V'y.'l-il-"" "hUh «ust be identified .nd
aucu»M in the permit application. You should also be aware that th.
"" "
™* 10C"i0° °« the -»— nication nd a an.
properly .. "" ""P'""' i- «- Contingency
ha«« Internal Conmunication or Alarm System [§264.32(a)l . The facility muit
K«r!!ctJrB1Stl0n-0r alarm 8y8tem Capable °f "r°vid^ Agency y "
5-102
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Example:
"The operations building is equipped with 15 wall-mounted switches
tied into an electric bell alarm system. Ten switches are located in
production areas, adjacent to each of 10 work stations, and five are
located in storage areas. The switches are clearly marked for rapid
identification. Workmen are instructed to keep the surrounding areas
free of obstructions. In addition, remote sensors which detect
combustible gas, low oxygen levels and sprinkler system flow are tied
into the alarm. Activation of any individual switch or remote sensor
will sound all bell alarms and lights in the system.
Two work crews, consisting of four men each, are involved in outside
landfill ing and treatment operations. Each crew foreman carries a
hand-held two-way radio which can be used to contact the operations room
in the event of an emergency. Members of the crews maintain visual and
voice contact with each other at all times.
There is an internal phone system which connects the operations room
to all areas of the operations building. There is a phone (part of this
system) located at the landfill and at the treatment area.
A complete description of the alarm system showing switch, sensor,
and alarm bell locations and system specifications can be found on page _
of the Contingency Plan (Attachment _ of this application). An equally ~~
detailed description of the phone system begins on page of the
Contingency Plan." ~~
External Communication System [264.32(b)]. Should an emergency
situation arise, the HWM facility will need some means of summoning
assistance from local police departments, fire departments, and State and
local emergency response teams. Both a telephone and a hand-held two-way
radio are acceptable communication devices. Such devices must be
immediately available at the scene of operations.
Example:
"The facility is equipped with an intercom system to provide
internal emergency communications. Any emergency will be brought to the
attention of the chief engineer stationed at the operations control
room. He will quickly evaluates the situation and places any necessary
calls to police departments, fire departments and/or emergency response
teams from one of the outside phones located in the control room. If the
control room is affected by the emergency situation, a telephone at the
front gate will be used to summon assistance.
Details on the specifications, locations, and operation of the
intercom system are located on page _ of the Contingency Plan. The
locations of all outside phones are shown on the emergency equipment
location plan which follows page _ in the Contingency Plan."
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Emergency Equipment [§264.32(c)l. Provide a description of any equipment
to be used in the event of an emergency situation. Emergency equipment must
include portable fire extinguishers, fire control equipment (including any
special extinquishing equipment such as foams, inert gas, or dry chemicals),
spill control equipment (e.g. pumps, absorbents, vacuum cleaners, etc.) and
decontamination equipment (e.g. pumping or vacuum equipment). You should
provide a description of the number and type of each piece of emergency
equipment and its location and function relative to process operations.
Example for Fire Control Equipment: (Considering a facility which
employs several physical/chemical processes for treating liquid hazardous
wastes.)
"Several treatment processes are carried out in a large single floor
building. To provide rapid response to fires, wall-mounted, hand-held
fire extinguishers are centrally located at each of six operations.
Three additional extinguishers are provided in a storage area. Because
the primary danger of fire is from flammable liquids, carbon dioxide
extinguishers are used. An automatic sprinkler system runs throughout
the building. The sprinkler system is of the foam-water type; providing
an initial discharge of water. The sprinkler heads are designed to open
at between 250 and 286°F and are spaced 10 feet apart, each head covering
an area of 100 square feet.
The outside yard storage area contains four fire hydrants, spaced
100 feet apart and 125 feet of 2 1/2 inch fire hose are stored on racks
next to each hydrant."
Example for Spill Control:
"The facility has several above ground tanks used to store and/or
treat hazardous wastes. To control spills, each tank is completely
surrounded by a dike constructed of compacted clay soil. The dikes are
of sufficient height to contain the entire contents of the tanks. The
facility has three identical trailer-mounted portable pumps powered by
10-HP gasoline engines. Each pump can transfer GPM at 20 ft. TDH.
The facility maintains sufficient empty tank capacity to transfer the
contents of the largest tank onsite."
Example for Decontamination Equipment:
"The facility owns a 10,000 gallon tank truck which has been fitted
with a vacuum unit that is capable of cleaning up solid or liquid
materials. The tank truck also has fittings compatible with the hoses
used on the trailer-mounted emergency pumps. A separate vacuum unit,
mounted on a special fork-lift compatible skid, is stored in the same
shed as the emergency fire equipment. By agreement, an additional 10,000
gallon tank truck is available from the County Fire Department."
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Water Supply for Fire Fighting Equipment [264.32(d)l. The owner or
operator must show that sufficient water will be available for emergency use.
In addition to providing water for sprinklers, the supply should be adequate
for hydrants and hose streams. Identify any secondary water supplies such as
gravity tanks, suction tanks, private reservoirs, rivers, ponds, etc., which
can be used in case of emergency.
Example:
"A public water supply serves as the primary source of emergency
water. The system has a rated delivery capacity of 1,500 gpm at
40 psig. This supply is supplemented by two 100,000 gallon gravity water
tanks capable of delivering 1,500 gpm at 60 psig. The maximum water
requirement under worst case conditions is estimated to be 2,000 gpm."
You are reminded that the required equipment identified in §264.32
must be described in more detail in the Contingency Plan which is
presented in the next section of this manual. The intent of the
regulations is to insure that you have given serious thought to the
unplanned or emergency situations that might occur at your facility and
have made plans to handle these situations in ways which minimize threats
to human health and the environment.
Testing and Maintenance of Equipment [§264.33]. Your facility's
communication and/or alarm systems, fire protection equipment, spill control
equipment, and decontamination equipment must be periodically inspected and
tested to insure proper operation during an emergency. The inspection
procedure must conform to guidelines provided in Section 264.15. The
applicant should prepare an inspection schedule detailing testing and
maintenance procedures. The frequency of scheduled testing and maintenance
will vary depending on the role and reliability of the individual pieces of
equipment. Most emergency equipment requires a relatively frequent and
thorough inspection to insure that it will adequately perform its contingency
function so as to prevent dangerous conditions. See Section , Inspections,
for a detailed discussion of inspection testing and maintenance requirements.
The intent of §264.33 is to insure that you have included a^l your
emergency equipment in the Inspection Plan and Schedule that you are required,
by §264.15, to prepare and submit with Part B of the permit application.
Satisfactory compliance with §264.33 can be achieved by thoroughly referencing
where the emergency equipment inspection and maintenance procedures can be
found in the Inspection Plan and Schedule.
Example:
"All the equipment required by §264.32 will be inspected, tested,
and maintained as required by §264.33. A complete list of the emergency
equipment can be found beginning on page _ of the Contingency Plan
(Attachment to this application). Inspections, tests, and maintenance
are contained in the Inspection Plan and Schedule that is Attachment to
this application. The following table identifies the equipment and the
pages in the Inspection Plan where testing and maintenance are described.
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Equipment Location in Inspection Plan
Internal Communications pp. 14 and 42
Alarm Systems pp. 24 through 28
Fire Control Equipment pp. 15 through 23
Spill Control Equipment pp. 29 through 35
Decontamination Equipment pp. 35 through 41
Emergency Water Supply System pp. 12 and 13
Access to Communications or Alarm System [§264.34(a)]. The applicant
must demonstrate that immediate access to a communications or alarm system is
available to all personnel involved in hazardous waste handling operations.
Access can either be direct or through visual or voice contact with another
employee.
Example:
"Fifteen wall-mounted switches, wired into an alarm system, are
located throughout building A which houses several hazardous waste
processing operations. The switches are centrally located to the various
work stations providing immediate access to all employees inside the
building. Personnel involved in outside treatment and landfill
operations work in two crews of four workmen. The foreman of each crew
carries a hand-held two-way radio which can be used to contact the
control room should an emergency arise."
Access to Emergency Services [§264.34(b)]. If there is ever a situation
where only one employee is on the premises while the facility is in operation,
that person must have immediate access to an outside communications device
such as a telephone or a hand-held two-way radio with which emergency help can
be summoned. When the facility is not operating, but attended by a single
individual, you should still consider the issue of access to outside
communications.
Required Aisle Space [§264.35]. The applicant must show that sufficient
aisle space will be maintained to provide unobstructed movement of emergency
equipment. In providing information on aisle space, it would be helpful to
include floor plans indicating the special distribution of aisles relative to
process operations and building entries.
Example:
"Aisles within the operations building provide access to storage
areas and each process operation. The aisle width is maintained at _
inches to allow passage of two fork trucks. Aisle boundaries are ~
clearly marked with four inch wide orange lines. Workmen are instructed
to keep aisles clear of obstructions at all times."
Arrangements with Local Authorities [§264.37(a)]. The permit applicant
is required to attempt to make arrangements with appropriate local agencies in
an effort to coordinate responses to emergency situations. Any arrangements
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Chat are made must be described in detail in the Contingency Plan. If you are
applying for a permit for either an existing or new facility you must make
these arrangements and submit them in your Contingency Plan with your permit
application. As part of the "arrangements to familiarize" that are required
by S264.37(a)(l), you should consider touring the local authorities through
your facility. This, of course, may not be possible for you to do prior to
submitting a permit application for a new facility. However, an application
for a new facility must, at a minimum, indicate that agreements have been
reached and that you have supplied the authorities with some information. It
may also be to your advantage to indicate in your permit application that you
will supplement that information and provide the opportunity for onsite visits
after the facility is constructed.
Arrangements with Emergency Services [§264.37(a)(1)1. Provide police,
fire and emergency response teams with a layout of the facility. Identify
types of hazardous wastes handled, places where workers are normally working,
facility entrances, roads inside the facility and possible evacuation routes.
Detailed site maps and floor plans showing water supplies, process operations,
access routes, etc. would be helpful. Indicate any special hazardous
situations which might be encountered (e.g. explosions, toxic fumes, reactive
chemicals) and discuss any special equipment needed to protect personnel (e.g.
protective clothing, respirators). It would also be a good idea to have fire
department officials visit the plant to inspect fire protection capabilities
onsite. If a fire department inspection is required as part of your local
building permit, you should mention that fact in your application.
Example:
"Meetings were held between management, personnel and local fire,
police and emergency response officials. Detailed site maps and building
floor plans were provided for each agency. They have been given lists of
wastes being treated, and information detailing hazardous characteristics
of the wastes involved. Fire department officials have visited the site
and have observed site access routes, the locations of highrisk areas,
and have inspected fire protection capabilities including sprinkler
systems and primary and secondary water supplies. In addition, the fire
department has conducted training exercises using an ignitable oily
sludge waste. The fire department has also provided training for an
emergency squad comprised of five plant personnel. Their role will be to
begin emergency operations immediately, preparing for the arrival of the
local fire department and to guide the fire fighting effort because of
their intimate knowledge of plant operations. They are also responsible
for rescue operations and evacuation of injured or threatened personnel."
Agreements Designating Primary Emergency Authority [§267.37(a)(D].
Local police and fire departments often have reciprocating emergency response
agreements with departments within the same region. Where such agreements
exist, the site owner or operator must attempt to designate specific fire and
police departments as primary emergency authorities. Site owners or operators
must attempt to obtain agreements with other departments to provide support to
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the primary emergency authority. Such agreements should be obtained in
writing and photocopies should be included in the Contingency Plan submitted
with the permit application.
Example:
"Five towns around the facility have fire departments operating
under cooperative assistance agreements. The are: Grey, Acton, Athol,
Paris, and Middleton. Only the Grey and Paris departments have agreed to
assist our fire department (Middleton) in an emergency response to our
facility. We have met with the Chiefs of those three departments and it
has been agreed that the Middleton Chief will be responsible for calling
out the Paris and Grey departments, in that order, as needed. The
Middleton Chief has been designated the primary fire equipment
authority. He will be with the Emergency Coordinator in the Emergency
Response Center and will direct his equipment, through his Lieutenant,
and the other equipment, through their respective Chiefs onsite, from
that point."
Agreements with Emergency Response Teams [§264.37(a)(3)l . The owner or
operator should attempt to make arrangements to the appropriate state
emergency response team, emergency response contractor and/or equipment
suppliers. These arrangements must also be included in the Contingency Plan
but should be described in the same detail as the above example in the
application.
Arrangements with Local Hospitals [§264.37(a)(4)l. The owner or operator
should furnish local hospital officials with information on the properties and
types of hazardous waste handled at the facility In addition, the types of
injuries or illnesses that could result from fires, explosions or releases of
those hazardous materials should be thoroughly presented to the hospital.
With this information, the hospital can develop a procedure for addressing any
special type of injuries which may occur during an emergency. Include a
detailed discussion of hospital arrangements in the Contingency Plan.
Example:
"Pesticide residues stored at the facility would produce harmful
emissions in the event of a fire. The hospital has been informed that
inhalation of these emissions could result in poisoning symptoms. The
hospital has a contingency plan calling for decontamination and treatment
of potential victims. The decontamination procedure consists of removing
the victims clothing and sealing it in plastic bags. The individuals are
then bathed and issued clean hospital gowns. Blood tests and chest
x-rays are then administered to detect any signs of poisoning."
Failure to Reach Agreements [S264.37]. If state or local authorities
decline to enter into arrangements, the owner or operator must document the
refusal in the operating record. You should identify all agencies with which
agreements could not be reached and identify their reasons for declining to
enter into agreements.
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5.6.3 List of Major Points
1. Have the facets of facility design, construction, maintenance, and
operation which contribute to preparedness and prevention been
highlighted and discussed? Have the places in the permit
application where details can be found been adequately referenced?
2. Have each of the four required equipment groups been discussed and
references made to the locations of more detailed information in the
Contingency Plan?
3. Has a statement been made regarding emergency equipment testing and
maintenance? Has the Inspection Plan and Schedule been referenced?
4. Has it been shown that all employees have immediate access to
communications and alarms? Has access to emergency services during
single employee occupancy been addressed?
5. Is there a discussion of aisle space adequacy, documented by plot
plans or other drawings?
6. Have attempts at arrangements with local authorities been
documented? Are successful agreements described and their location
in the Contingency Plan referenced? Have failed agreement attempts
been noted? Have fire, police, emergency response, and hospitals
all been addressed?
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5.7 CONTINGENCY PLAN AND EMERGENCY PROCEDURES
5-7-l Regulatory Citations
r ;ir-P^;D. A£.T t^eS^;:^-^
tne contingency plan, specific requireuents in S264.227 and 264.255.
"Subpart D— Contingency Plan and Emergency Procedures
§264.50 Applicability.
of -nhK reg"lation9 in this Subpart apply to owners and operators
otheriise °U8 *"" facilities' ««P' •• §264.1 provides
§264.51 Purpose and implementation of contingency plan.
facility Ea^P°T^'°r °pera'or must have a contingency plan for his
to human 'h^>, C0ntl"8ency plan must be designed to minimize hazards
unolpn H 1? " the environm*nt f"m fires, explosions, or any
unplanned sudden or non-sudden release of hazardous waste or
hazardous waste constituents to air, soil, or surface water.
Cb) The provisions of the plan must be carried out immediately
11 fi"' exPlosio". °r release of hazardous waste"
human health or
§264.52 Content of contingency plan.
(a) The contingency plan must describe the actions
ke " C°"ply With §26A'51 and 264'56 in resP°e to
h«rrf ' or.anv unplanned sudden or non-sudden release of
facility! W88te C°n8tituents to air« s°il« or surface water at the
(b) If the owner or operator has already prepared a Spill
;i- aru Countermeasures (SPCC) Plan in accordance
other th" C^Pter' or Part 1510 of Chapter V, or some
other emergency or contingency plan, he need only lend that PUn to
incorporate hazardous waste management provisions that are
sufficient to comply with the requirements of this Part.
The plan must describe arrangements agreed to by local
dePartments' hospitals, contractors, and
teams to
"J"..11" name8' •"'«•"•, and phone numbers
t "-"''e- '-"--» ff^Tsra-.
Where more than one person is listed, one must be named as primary
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emergency coordinator and others must be listed in the order in
which they will assume responsibility as alternates. For new
facilities, this information must be supplied to the Regional
Administrator at the time of certification, rather than at the time
of permit application.
(e) The plan must include a list of all emergency equipment
at the facility (such as fire extinguishing systems, spill control
equipment, communications and alarm systems (internal and external),
and decontamination equipment), where this equipment is required.
This list must be kept up to date. In addition, the plan must
include the location and a physical description of each item on the
list, and a brief outline of its capabilities.
(f) The plan must include an evacuation plan for facility
personnel where there is a possibility that evacuation could be
necessary. This plan must describe signal(s) to be used to begin
evacuation, evacuation routes, and alternate evacuation routes (in
cases where the primary routes could be blocked by releases of
hazardous waste or fires).
$264.53 Copies of contingency plan.
A copy of the contingency plan and all revisions to the plan
must be:
(a) Maintained at the facility; and
(b) Submitted to all local police departments; fire departments,
hospitals, and State and local emergency response teams that may be
called upon to provide emergency services.
§264.54 Amendment of contingency plan.
The contingency plan must be reviewed, and immediately amended,
if necessary, whenever;
(a) The facility permit is revised;
(b) The plan fails in an emergency;
(c) The facility changes—in its design, construction,
operation, maintenance, or other circumstances—in a way that
materially increases the potential for fires, explosions, or
releases of hazardous waste or hazardous waste constituents, or
changes the response necessary in an emergency;
(d) The list of emergency coordinators changes; or
(e) The list of emergency equipment changes.
$264.55 Emergency coordinator.
At all times, there must be at least once employee either on
the facility premises or on call (i.e., available to respond to an
emergency by reaching the facility within a short period of time)
with the responsibility for coordinating all emergency response
measures. This emergency coordinator must be thoroughly familiar
with all aspects of the facility's contingency plan, all operations
and activities at the facility, the location and characteristics of
waste handled, the location of all records within the facility, and
the facility layout. In addition, this person must have the
authority to commit the resources needed to carry out the
contingency plan.
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$264.56 Emergency procedures.
(a) Whenever there is an imminent or actual emergency situation,
the emergency coordinator (or his designee when the emergency
coordinator is on call) must immediately:
(1) Activate internal facility alarms or communication systems,
where applicable, to notify all facility personnel; and
(2) Notify appropriate State or local agencies with designated
response roles if their help is needed.
(b) Whenever there is a release, fire, or explosion, the
emergency coordinator must immediately identify the character, exact
source, amount, and areal extent of any released materials. He may
do this by observation or review of facility records or manifests,
and, if necessary, by chemical analysis.
(c) Concurrently, the emergency coordinator must assess possible
hazards to human health or the environment that may result from the
release, fire, or explosion. This assessment must consider both
direct and indirect effects of the release, fire, or explosion
(e.g., the effects of any toxic, irritating, or asphyxiating gases
that are generated, or the effects of any hazardous surface water
run-off from water or chemical agents used to control fire and
heat-induced explosions).
(d) If the emergency coordinator determines that the facility
has had a release, fire, or explosion which could threaten human
health, or the environment, outside the facility, he must report his
findings as follows:
(1) If his assessment indicates that evacuation of local areas
may be advisable, he must immediately notify appropriate local
authorities. He must be available to help appropriate officials
decide whether local areas should be evacuated; and
(2) He must immediately notify either the government official
designated as the on-scene coordinator for that geographical area,
(in the applicable regional contingency plan under Part 1510 of this
Title) or the National Response Center (using their 24-hour toll
free number 800/424-8802). The report must include:
(i) Name and telephone number of reporter;
(ii) Name and address of facility;
(iii) Time and type of incident (e.g., release, fire);
(iv) Name and quantity of material(s) involved, to the extent
known;
(v) The extent of injuries, if any; and
(vi) The possible hazards to human health; or the environment,
outside the facility.
(e) During an emergency, the emergency coordinator must take
all reasonable measures necessary to ensure that fires, explosions,
and releases do not occur, recur, or spread to other hazardous waste
at the facility. These measures must include, where applicable,
stopping processes and operations, collecting and containing
released waste, and removing or isolating containers.
(f) If the facility stops operations in response to a fire,
explosion, or release, the emergency coordinator must monitor for
leaks, pressure buildup, gas generation, or ruptures in valves,
pipes, or other equipment, whenever this is appropriate.
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(g) Immediately after an emergency, the emergency coordinator
must provide for treating, storing, or disposing of recovered waste,
contaminated soil or surface water, or any other material that
results from a release, fire, or explosion at the facility.
(h) The emergency coordinator must ensure that, in the affected
area(s) of the facility;
(1) No waste that may be incompatible with the released
material is treated, stored, or disposed of until cleanup procedures
are completed; and
(2) All emergency equipment listed in the contingency plan is
cleaned and fit for its intended use before operations are resumed.
(i) The owner or operator must notify the Regional
Administrator, and appropriate State and local authorities, that the
facility is in compliance with paragraph (h) of this Section before
operations are resumed in the affected area(s) of the facility.
(j) The owner or operator must note in the operating record the
time, date, and details of any incident that requires implementing
the contingency plan. Within 15 days after the incident, he must
submit a written report on the incident to the Regional
Administrator. The report must include:
(1) Name, address, and telephone number of the owner or
operator;
(2) Name, address, and telephone number of the facility;
(3) Date, time and type of incident (e.g., fire, explosion);
(4) Name and quantity of material(s) involved;
(5) The extent of injuries, if any;
(6) An assessment of actual or potential hazards to human
health or the environment, where this is applicable; and
(7) Estimated quantity and disposition of recovered material
that resulted from the incident."
5.7.2 Guidance to Achieve the Part 264 Standards
5.7.2.1 General—
The intent of Subpart D of Part 264 is to insure that all permit
applicants have developed and formalized a Contingency Plan for their
facilities that will be immediately implemented in the event of a fire,
explosion, or other unplanned occurrence that has or could present a hazard to
human health or release hazardous waste to the environment.
Subpart D sets requirements on:
• The purpose and implementation of the contingency plan in §264.51,
• Content of the contingency plan in §264.52,
• Copies of the contingency plan in §264.53,
• Amendments of the contingency plan in §264.54,
• Emergency coordinator in §264.55, and
• Emergency procedures in §264.56.
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The most effective method for an applicant to demonstrate compliance with the
requirements of Subpart D is to develop a formal Contingency Plan and submit
that plan as part of Part B of the permit application. The Contingency Plan
should be a document written for use by facility personnel in the event of the
occurrence of an emergency or unplanned event. In addition to submitting your
actual Contingency Plan document, your permit application should include a
discussion which identifies where, in the Contingency Plan, the requirements
of Subpart D are addressed. This discussion will allow agency personnel who
review your application to quickly confirm that your Contingency Plan is
adequate.
There are no provisions for a waiver or exemption from the requirement
for a Contingency Plan. All owners and operators must develop a Contingency
Plan and submit it with Part B of their permit applications. However, the
preparedness and prevention requirements set forth in Subpart C of Part 264
are closely tied to the Contingency Plan requirements. Subpart C requirements
were discussed in the preceding section of this manual. Thus, although a
specific facility may be exempted from certain preparedness and prevention
requirements in Subpart C, all facilities must have a Contingency Plan that
addresses applicable requirements of Subpart C and all requirements of
Subpart D of Part 264. After review and modification or approval, your
Contingency Plan will become a condition of your permit.
Owners and operators of surface impoundments must also provide, in their
Contingency Plan, procedures that address how compliance with the requirements
of §264.227(b) will be achieved. At this time (May 1983), there are no other
facility-type specific Contingency Plan requirements. However, the EPA may
well add these requirements to Subparts I through 0 of Part 264 in the
future. Owners and operators of facilities should contact the government
agency to which they will submit their permit application to determine if
there are any facility specific Contingency Plan requirements in effect at the
time they are preparing Part B of their application.
5.7.2.2 Contingency Plan and Emergency Procedures [40 CFR 270.14(b)(7) and
§264.50-264.56]--
Applicability [§264.50]. All permit applicants must provide a copy of
their Contingency Plan unless they have been exempted as specified in §264.1
Purpose and Implementation of Contingency Plan [§264.51]. The
contingency plan for your facility must be designed to minimize hazards to
human health or the environment from fires, explosions, or any unplanned
sudden or nonsudden release of hazardous waste or hazardous waste constituents
to air, soil, or surface water. Your Contingency Plan must demonstrate that
specified emergency procedures will be implemented immediately whenever a
hazard at the facility occurs.
Content of Contingency Plan [§264.52]. Your contingency plan must
describe the actions that facility personnel will take to comply with and
implement the plan (§264.51) including emergency procedures (§264.56). If you
have already prepared a Spill Prevention, Control, and Countermeasures (SPCC)
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Plan or other emergency or Contingency Plan for your facility, amendments to
-hould1^ **l ^Ifi11-tu8 reuate
Coordinated Emergency Services (§264.52(c))— A coordinated emergency
d"epa"rtmen?ianhraUB- *? a"an*ed and a8reed to by local police departments, fire
«d SrSS'f "F J'§ C0ntractora« State and local emergency response teams,
and the HWM facility's owner or operator, pursuant to §264.37. You should
obtain written agreements whenever possible. See the discussion in the
?!!!!!«? !ecti™°? th" manual m Sut>P«t C-Preparedness and Prevention
vno
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TABLE 5-20. SAMPLE TABLE OF CONTENTS FOR A CONTINGENCY PLAN
1. Purpose
2. Scope
3. Responsibilities
4. Organization and Duties
5. Coordinated Emergency Services
6. Training
7. Routine Surveillance to Detect Potential Hazards
8. Emergency Procedures
A. Fire
B. Explosion
C. Hazardous Waste Release
9. Evacuation Plans
10. Recordkeeping and Incident Reports
Appendix A—List of Emergency Coordinators, names, addresses
and phone numbers
Appendix B—List of Emergency Equipment
Appendix B—Incident Reports
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In your Contingency Plan, the Coordinated Emergency Services section
should be written to instruct facility personnel on "how to" obtain and
coordinate those services. An example of how that section of your plan might
be presented is given below:
"This section of the Contingency Plan identifies available off-plant
Emergency Services. Written agreements with these off-plant groups are at the
end of this section. These services are to be requested only by the In-Plant
Emergency Coordinator.
• Call the Middleton Fire Department, Telephone No. 774-9191
• Notify the Plant Fire Coordinator to meet fire equipment at the West
Gate with mobile radio.
• Plant Fire Coordinator will send ranking responding officer to
Emergency Control Center.
• Plant Fire Coordinator will stay with fire equipment.
• The ranking responding fire department officer will direct equipment
from Control Center until replaced by the Middleton Fire Chief on
his arrival.
• All Plant Fire Team Leaders will report to ranking fire department
officer at fire site on his arrival.
• Fire department personnel will not enter process buildings or tank
pits. They will provide equipment, support, and rescue services to
Plant Fire Teams."
Your plant-specific Contingency Plan will, of course, be organized and
worded as is best suited to your facility. However, the point of the above
example is that the Coordinated Emergency Services part of the Plan, and all
other parts, should be presented as instructions to your personnel. The
Contingency Plan should be specific regarding what to do, who to notify, and
in the case of off-plant assistance, what those groups will and will not do
during the emergency.
List of Emergency Coordinators (§264.52(d))—A list of names, addresses,
and phone numbers (office and home) of all persons qualified to act as
emergency coordinators (see §264.55) in the order in which they will assume
responsibility must be included. The choice of emergency coordinator and
alternates is extremely important. Since §264.55 requires that the emergency
coordinator "must have the authority to commit the resources needed to carry
out the contingency plan," it is strongly suggested that you consider
personnel from facility management positions for the required list.
Additional guidance on choosing emergency coordinators is provided in this
section of the manual in the discussion of §264.55.
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The provisions of §264.52(d) require only that the list of emergency
coordinators be included in the Contingency Plan. However, from an
operational standpoint, copies of this list should probably be posted in
various parts of the facility such as control rooms and guardhouses.
Note that this list of emergency coordinators does not have to be
submitted with your application for new facilities. In these cases, the list
f£iH*! 1?S? ^ 8ny time bef°re y°U begin °Pe"tio"s at the completed
tacility. Although you may not be able to supply names and associated details
Sb!??2riCy C°"diratora for a new facility at the time of application
when ™ ' H°" consider identifying the personnel by position title
when you submit your application.
Table 5-21 is an example of a format that could be used for the emereencv
coordinators list. Ideally, there would be one person from the list at the *
fhllH K (°"Slte) at ^ *iven time' Alternatively, the primary coordinator
should be the most senior member of the staff closest to the facility. In
addition to a list such as this, it is recommended that you identify the
onsite emergency coordinator for those periods (nights, weekends, vacations)
when the primary emergency coordinator is not onsite.
. List of Emergency Equipment (§264.52(e))—You must list all emergency
thTlo^ti™ ^ hfacili1ty that.".^PHcable to facility operations, "include
the location, a physical description, and the capabilities of each item
listed. As specified in §264.32, the list must include the following:
• Internal communication or alarm system
• External communication system
• Fire extinguishing systems (including primary and secondary water
supplies)
• Spill control equipment
In addition to listing the emergency equipment, the Contingency Plan must
include a physical description of each item on the list, provide its location
Sid'iv" * °Utlr! °* lt8 CflPabilitie8- Remember that this list will be
used by your personnel during an emergency. The format chosen for the list
should, therefore, allow identification of any needed equipment and its
location in the easiest possible manner. It is suggested that a plot plan
showing the locations of the equipment also be included in the Contingency
fm Evacuation Plan (§264.52(f))-An evacuation plan for the safe egress of
facility personnel must be developed. Recognizable signals to commence an
evacuation routes, alternate evacuation routes (in case primary exit routes
Jo «c«± f * "}ea868 of haz«d°"3 waste or fires), and safe assembly areas
to account for all evacuated personnel should be noted in the plan. Maps
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TABLE 5-21. EMERGENCY COORDINATORS LIST
CONTACT III ORDER LISTED (SEE NOTE 1)
Date:
Supersedes all lists dated:
and earlier.
Name & hone address
Telephones
Work Home
PRIMARY
ALTERNATES
John Cregson
15 Park Dr.
Acton
Bill Johnson
180 Boston St.
Middleton
—
X 500
X 503
Page: 76
(555)690-4673
(555)919-5623
6
Mon.-Fri.
Sat.
Mon.-Fri.
Sun.
— — — — — — — — _
08:00 a.m. -05:00 p
09:00 a.m. -Noon
08:00 a.m. -05: 00 p.
Noon-05:00 p.m.
Contents
J. G. must be notified
of all emergency
situations.
See Note 2.
B. J. must be called
in for all emergency
situations.
See Note 1.
Sam Houston
17 Sycamore St.
Grey
Steve Sforza
1919 Columbia Ave.
Athol
Dave McNulty
63 Bourne Dr.
Niddleton
X 520 (555)523-5772
! /bo
X 534 (555)734-7872
Page: 773
X 557 (555)774-6051
Page: 771
Mon.-Fri. 04:30 p.m.-01:00 a.m.
Tues.-Sat. 12:30 a.m.-08:30 a.m.
Rotating
• Guardhouse will know
if McNulty is on-site.
NOTE 1: On nights (2nd and 3rd shifts) and weekends contact Coordinator
Johnson.
on-site first - then contact B.
NOTE 2: Alternative home phone for Cregson is (617)224-9139 on weekends.
-------
clearly delineating evacuation routes, fire fighting equipment, alarms and
assembly areas should be prepared. In addition, the applicant should note the
presence of employee training sessions, fire drills, and the placement of
evacuation maps posted at the facility.
Table 5-22 is an example of an Evacuation Plan format and content. The
Evacuation Plan is extremely important to insure that employees are safely
removed from danger and are not inhibiting plant and outside emergency
personnel from effectively dealing with the emergency. The plan in Table 5-22
is only an example. You will have to develop an Evacuation Plan specific to
the needs of your facility and it must be included in your Contingency Plan
document.
Copies of Contingency Plan [§264.53]. The applicant must submit a copy
of the Contingency Plan to the EPA Regional Administrator with Part B of the
permit application. In addition, copies of your Contingency Plan and all
revisions to the plan must be:
(a) maintained at the facility; and
(b) submitted to all local police departments, fire departments,
hospitals, and State and local emergency response teams that may
provide emergency services to the facility.
It is suggested that numbering the individual copies of the Contingency Plan
and keeping a log of where each copy is located will assist in updating the
Plan when necessary. Regardless, your permit application should state how
many copies of your Contingency Plan exist and to whom the copies were given.
Your application should also state how many copies are retained at your
facility and, as specifically as possible, where they are located.
Amendment of Contingency Plan [§264.54]. The Contingency Plan must be
reviewed and immediately amended, if necessary, whenever:
(a) The facility permit is revised;
(b) The plan fails in an emergency;
(c) The facility design, construction, operation, maintenance, or other
circumstances change to increase the potential for fires,
explosions, or releases of hazardous waste or hazardous waste
constituents, or changes the response necessary in an emergency;
(d) The list of emergency coordinators changes; or
(e) The list of emergency equipment changes.
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TABLE 5-22. EMERGENCY EVACUATION PROCEDURES
PURPOSE: Plan for safe evacuation in the event of an emergency.
RESPONSIBILITIES:
1. The Emergency Coordinator is responsible for implementing the evacuation
procedure.
2. Each Area Monitor is responsible for directing employees and visitors in
his/her section to the proper exit and their assigned safe area outside
(see assignments).
PROCEDURE:
1. The Emergency Coordinator will notify supervisors and Area Monitors if an
evacuation may be necessary.
2. The Emergency Coordinator will assess the conditions and order an
evacuation or other actions required.
3. When an evacuation is announced stop work. The Area Monitors will direct
employees in their areas to the closest available exit.
4. All employees must leave the facility and report to the designated
assembly area. Do not run. Do not linger in entrance ways or driveways,
stay together in your assigned safe area.
5. Each employee must report to his/her Area Monitor once outside the
building.
6. Each Area Monitor must report to the Emergency Coordinator when his/her
employees have cleared the facility.
7. The Emergency Coordinator will notify the Area Monitors when it is safe
to re-enter the facility.
8. Stay outside the facility until notified by the Area Monitors to
re-enter.
EVACUATION ROUTES, EXIT ASSIGNMENTS:
1. The attached floor diagrams (see Figure 7A) of Company X show each
section of the office area and facility and the best route for each
section to use when evacuating the building. Fire alarms and fire
extinguishers are also noted on the diagrams.
2. The designated assembly areas for each section of the facility are shown
in Figure 7A.
(continued)
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TABLE 5-22 (continued)
EMERGENCY PRECAUTIONS:
1. Keep calm, Chink, avoid panic and confusion.
2. Know all exit locations: Be sure you know the safest and quickest way
out of all buildings.
3. Do not lock office doors when vacating the facility. The Emergency
Coordinator and emergency support personnel must have visual access to
all areas to ensure that the facility is clear of personnel.
4. Do not delay evacuation of the facility for any reason.
5. Do not assist in fire control unless properly trained and qualified.
6. Do not use voice paging system. The paging system must be left open for
issuing plantwide instructions.
7. When evacuating the facility WALK to the nearest safe exit. Report to
the safe areas away from the buildings and wait for instructions.
8. Keep out of the way, stay clear of the facility, and DO NOT interfere
with emergency operations.
9. DO NOT reenter the facility until instructed to do so.
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The requirements of this section (§264.54) are intended for owners or
operators of facilities that have previously prepared and submitted a
Contingency Plan with Part B of their permit application. Amendments would be
required only after EPA approval of the initial Contingency Plan and if one or
more of the aforementioned conditions exist at the applicant's facility.
Because the Contingency Plan will be a condition to your facility permit, any
amendments to it will be judged a modification to the facility permit.
However, changes to the lists of emergency coordinators or emergency equipment
constitute minor modifications to the permit.
Because of the importance of this document during emergency situations,
you should consider identifying a specific person, by name or title, who would
be responsible for all revisions to all copies, on a periodic basis and on an
"as needed" basis. Your permit application should clearly indicate how the
copies of your Contingency Plan will be amended when the need arises. You
should place special emphasis on how offsite copies of the plan will be
amended and, especially, how you will be assured that amendments are
incorporated into those copies.
Emergency Coordinator [§264.55]. The applicant should select at least
one employee who is either on the facility premises during peak operational
periods (preferred) or available to respond to an emergency by reaching the
facility within a short period of time. This employee should be designated
the primary emergency coordinator. The emergency coordinator is responsible
for coordinating all emergency response measures, and being thoroughly
familiar with:
(a) the facility's contingency plan,
(b) all operations and activities at the facility,
(c) the location and characteristics of waste handled,
(d) the location of all records within the facility, and
(e) the physical layout of the facility.
The selected emergency coordinator should have the authority to expend
funds and recruit employees to implement the Contingency Plan. The
owner/operator should also select alternative employees to act as emergency
coordinators if for some reason the designated emergency coordinator is
unavailable.
Your selection of the proper primary emergency coordinator and
alternatives is extremely important to successful implementation of your
Contingency Plan, when and if it needs to be implemented in an emergency. The
agency reviewing your application will pay particular attention to the
qualifications of the persons named in your Contingency Plan. You should
therefore include in your application a brief biographical sketch of the
background and experience of the named personnel with your justification for
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appointing them as emergency coordinators. Your application should also
^^^or^r - in - ™™ ^ -
"" 5 ""' y°-r —'««"* coordinator have the
..
is present at the .=v.*n.,.y itoni 0;uu i
operating hours) and resides within 30 miles of the
coDi^rthl'1^ Jf8t of emergency coordinators is contained in all
copies of the Contingency Plan. In addition, it is posted next to the
OUtSlde nhonpo in a11 throp rnnt-ynl »«. j • ^ ^"ol-ca ne*c CO tne
ait cnree control rooms and in the two Guardhouses.
«hi rs s
responsible for notifying the emergency coordinator. If the Shift
Supervisor is not in the control room at the time the emergency oc
"nnoti?vP%rHat°r " "Ch C°ntro1 r°°m h" bee
to notify the emergency coordinator.
. Bill Johnson, who is the Chief Plant Engineer, and resides
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4 miles from the plant. The onsite coordinator will implement his duties
and transfer them to Mr. Johnson on his arrival. When Mr. Johnson cannot
be called in. Mr. Gregson will be called in."
Emergency Procedures [§264.56). The applicant must discuss emergency
procedures in the Contingency Plan in his application. The emergency
procedures required to comply with §264.56 are explicitly outlined in the
standard. The responsibility for implementing the procedures are divided
between the emergency coordinator and the owner or operator of the facility.
The eight (8) emergency procedures implemented by the emergency coordinator
when a fire, explosion or hazardous waste release occurs are:
(a) Active facility alarms and notify appropriate State or local
agencies;
(b) Identify the character, exact source, amount, and areal extent of
any released material;
(c) Assess possible direct and indirect hazards to human health or the
environment that may result from the release, fire, or explosion;
(d) Determine if evacuation of local areas is required, and immediately
notify either the government official designated as on-scene
coordinator or the National Response Center;
(e) Insure that fires, explosions, and releases do not occur, recur, or
spread to other hazardous waste at the facility;
(f) Monitor for leaks, pressure buildup, gas generation, or ruptures in
valves, pipes, or other equipment if facility operations cease;
(g) Provide treatment, storage, and disposal of any material that
results from a release, fire, or explosion immediately after an
emergency; and
(h) Insure that no waste incompatible with the released material is
processed until cleanup procedures are completed and all emergency
equipment listed in the Contingency Plan is cleaned and fit for its
intended use.
The two (2) emergency procedures implemented by the owner or op.erator of
the facility are:
(a) Notify the EPA Regional Administrator and State and local
authorities that the facility is in compliance with §264.56(h)
before operations commence; and
(b) Record the time, date, and details of any incident that requires
implementing the Contingency Plan and submit a written report on the
incident to the EPA Regional Administrator within 15 days of the
incident.
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Your Contingency Plan must contain specific instructions for the
emergency coordinator to follow and implement. The contents of §264.56
indicate what the emergency coordinator must do and your Contingency Plan
should be specific as to how those items will be accomplished by listing
specific steps that the coordinator will take. You should include a
discussion of these steps in your permit application that will identify what
instructions in the Contingency Plan emergency procedures are intended to
address the eight specific items in 8264.56(a) through (h). However, because
Contingency Plan must be facility specific, it is likely that additional
procedures will be necessary.
The steps which the owner or operator must take after the emergency is
over are presented in §264.56(i) and (j). The Contingency Plan should
indicate how the owners or operators will confirm that the facility is in
compliance with 5264.56(h).
The Contingency Plan should also include specific instruction on how to
prepare the report required by §264.56(j). Your discussion of the owner's and
operator's responsibility in your permit application should identify the
specific places in the Contingency Plan where procedures designed to comply
with §264.56(i) and (j) are located.
Contingency Plan Requirements for Surface Impoundments (§264.227).
Subpart K of Part 264 contains requirements for surface impoundments. In
particular, §264.227 presents criteria for when a surface impoundment must be
removed from service in §264.227(a) and what must be done to remove it from
service in §264.227(b). Section 264.227(c) then requires that procedures for
complying with the requirements of §264.227(b) must be specified in the
Contingency Plan.
5.7.3 List of Major Points
1. Does your company have a Contingency Plan? Can another plan be
amended to comply with Subpart D?
2. Describe in detail the emergency procedures and evacuation plan of
your facility.
3. Identify all key personnel and equipment required to implement the
plan.
Additional background discussion on the Contingency Plan can be found in
the preamble on Subpart D in the May 19, 1980 Federal Register at page 33183.
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5.8 GENERAL HAZARD PREVENTION
5.8.1 Regulatory Citations
Information on hazard prevention must be submitted with Part B of the
permit application, as required by:
"270.14(b)(8) A description of procedures, structures, or
equipment used at the facility to:
(i) Prevent hazards in unloading operations (for example,
ramps, special forklifts);
(ii) Prevent run-off from hazardous waste handling areas to
other areas of the facility or environment, or to prevent flooding
(for example, berms, dikes, trenches);
(iii) Prevent contamination of water supplies;
(iv) Mitigate effects of equipment failure and power outages;
and
(v) Prevent undue exposure of personnel to hazardous waste (for
example, protective clothing)."
The §270.14(b)(8) regulatory requirements do not identify specific
Part 264 standards with which the application information must prove
compliance. However, the five informational items identified in §270.14(b)(8)
are clearly stated and are likely to be addressed by information developed for
and included in the Part B application for other purposes.
5.8.2 Guidance to Achieve the Part 264 Standards
The requirements of §270.14(b)(8) do not identify any specific Part 264
standards. However, the intent of requiring a description of procedures,
structures, or equipment used in hazard prevention is to draw the applicant's
attention to the five potential sources of hazards which are listed in
§270.14(b)(8).
It is likely that another part of your application may already identify
procedures, structures, or equipment applicable to the five items in
§270.14(b)(8). In those cases, you can either repeat or reference those
discussions to demonstrate compliance with §270.14(b)(8). Specifically, the
requirements of §270.14(b)(8)(i)(iv), and (v) may well be addressed in your
discussion of preparedness and prevention or your Contingency Plan (see
Sections 5.6 and 5.7 of this manual). Likewise, the run-off requirement of
§270.14(b)(8)(ii) will be addressed in your response to your facility's
specific design standards in Part 264 and flooding will be addressed in your
analysis of facility location required by §270.14(b)(ll) (see Section 5.11 of
this manual). The requirements of §270.14(b)(8)(ii) will be addressed in your
discussion of compliance with Subpart F of Part 264. The specific request for
information identified by §270.14(b)(8) should also serve as a check that you
have addressed these issues adequately in other portions of your Part B permit
application.
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When identifying and discussing procedures, structures, or equipment used
at your facility to prevent hazards in unloading operations, you should also
present information regarding loading operations if applicable. In order to
be thoroughly responsive to §270.14(b)(8)(i), your discussion should indicate
that you have identified the potential hazards that exist or could result
during loading and unloading and have taken positive steps to minimize or
eliminate the likelihood of their occurrence.
Your facility's run-off controls, flooding potential, and flood control
measures are likely to have been presented in your permit application under
the discussions to demonstrate compliance with facility design and location
standards. However, in your response to §270.14(b)(8)(ii), you should also
consider demonstrating that drainage in and around your facility is sufficient
to handle short duration, high intensity storm events. Even if your facility
is not in a 100-year floodplain, surface drainage during short duration, high
intensity storms could result in flooding because of the topography around
your facility. You should consider addressing this issue in your permit
application. At a minimum, your discussion to address §270.14(b)(8)(ii)
should reference the locations in your application where the details of your
run-off and flood prevention procedures, structures, or equipment are
presented.
The overall intent of the Part 264 standards, and especially Subpart F of
Part 264, is the protection of ground water and surface water. Your response
to §270.14(b)(8)(iii) should be used to summarize the key features of your
facility's procedures, structures, or equipment that are intended to prevent
contamination of water supplies. Your discussion should direct an application
reviewer to the parts of your application where details are presented.
Any procedures, structures, or equipment that are used to mitigate the
effects of a power outage or equipment failure should be addressed in detail
in your Contingency Plan (see Section 5.7 of this manual). Thus, your
response to §270.14(b)(8)(iv) could be a summary which also references the
portions of your application and Contingency Plan where details are
presented. You need only address equipment failures and power outages to the
extent that their occurrence has the potential to cause a violation of your
permit or a release of hazardous waste. However, you should address equipment
failures over which you have no control, either because they result from acts
of nature or because the equipment is maintained by a supplier.
When you prepare a response to §270.14(b)(8)(v), you should address both
routine and emergency procedures, structures, or equipment that will be
employed to protect personnel from undue exposure to hazardous waste. Your
Contingency Plan should address emergencies and can be referenced for
compliance with the §270.14(b)(8)(v) requirement. However, routine personnel
protection must also be discussed. Subpart I—Personal Protective Equipment
of the Occupational Safety and Health Standards in 29 CFR 1910 should be used
as guidance when addressing §270.14(b)(8)(v). The amount of training that
personnel will receive in protection procedures, structures, or equipment
should be indicated in your application. Passive personnel protection items
should also be identified.
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5.8.3 List of Major Points
1. Have each of the five hazard prevention areas been discussed in the
application?
2. Have other locations in the application where details can be found
been properly referenced?
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5.9 PREVENTION OF IGNITION OR REACTION OF WASTES
5.9.1 Regulatory Citation
Information on precautions employed to prevent accidental waste ignition
or reaction must be submitted with Part B of the permit application, as
specified in:
"§270.14(b)(9) A description of precautions to prevent
accidental ignition or reaction of ignitable, reactive, or
incompatible wastes as required to demonstrate compliance with
§264.17 including documentation demonstrating compliance with
§264.17(c)."
The regulatory requirements regarding the precautions required are
contained in §264.17. They are:
"§264.17 General requirements for ignitable, reactive, or
incompatible wastes.
(a) The owner or operator must take precautions to prevent
accidental ignition or reaction of ignitable or reactive waste.
This waste must be separated and protected from sources of ignition
or reaction including but not limited to: open flames, smoking,
cutting and welding, hot surfaces, frictional heat, sparks (static,
electrical, or mechanical), spontaneous ignition (e.g., from
heat-producing chemical reactions), and radiant heat. While
ignitable or reactive waste is being handled, the owner or operator
must confine smoking and open flame to specially designated
locations. "No Smoking" signs must be conspicuously placed wherever
there is a hazard from ignitable or reactive waste.
(b) Where specifically required by other Sections of this Part,
the owner or operator of a facility that treats, stores, or disposes
ignitable or reactive waste, or mixes incompatible waste or
incompatible wastes and other materials, must take precautions to
prevent reactions which:
(1) Generate extreme heat or pressure fire or explosions, or
violent reactions;
(2) Produce uncontrolled toxic mists, fumes, dusts, or gases in
sufficient quantites to threaten human health or the environment;
(3) Produce uncontrolled flammable fumes or gases in sufficient
quantities to pose a risk of fire or explosions;
(4) Damage the structural integrity of the device or facility;
(5) Through other like means threaten human health or the
environment.
(c) When required to comply with paragraphs (a) or (b) of this
Section, the owner or operator must document that compliance. This
documentation may be based on references to published scientific or
engineering literature, data from trial tests (e.g., bench scale or
pilot scale tests), waste analyses (as specified in §264.13), or the
results of the treatment of similar wastes by similar treatment
processes and under similar operating conditions.
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In addition to the "general" requirements contained in §264.17, there are
facility-type specific information requirements in Part 270 and associated
specific standards in Part 264. The following list identifies where these
specific requirements can be located.
Specific
information
Facility Type requirements Specific standards
Containers §270.15(c) and (d) §264.176, §264.177
Tanks §270.16(f) §264.198, §264.199
Surface Impoundments §270.17(h) and (i) §264.299, §264.230
Waste Piles §270.18(g) and (h) §264.256, §264.257
Land Treatment §270.20(g) and (h) §264.281, §264.282
Landfills §270.21(f) and (g) §264.312, §264.313
5.9.2 Guidance to Achieve the Part 264 Standards
5.9.2.1 General—
The intent of the precautionary requirements is to reduce the potential
for accidental ignition or reaction of ignitable and/or reactive wastes, or
the mixing of incompatible wastes by insuring that facility personnel are
thoroughly familiar with the prevailing dangers, and more significantly that
the design of the facility and the devices utilized for treating, storing, and
transporting wastes account for these dangers.
Ignitability is exhibited by a solid waste if it has any of the four
properties listed in §261.21(a). More specifically, §261.21(a)(l) addresses
liquids, §261,21(a)(2) addresses nonliquids, §261.21(a)(3) addresses
compressed gases, and §261.21(a)(4) addresses oxidizers. The provisions of
§261.21(a)(l) identify three ASTM standard methods that can be used to
determine ignitability. They are:
• ASTM Standard D-93-79
• ASTM Standard D-93-80
• ASTM Standard D-3278-781
These methods are also described along with test methods for gases and
oxidizers in Section 2.1.1 of "Test Methods for Evaluating of Solid Waste,
Physical/Chemical Methods" (July 1982) Second Edition (SW-846).2 (Addresses
of Government Printing Office Book Stores and EPA Regional Libraries are
provided in Appendix A.)
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Reactivity is exhibited by a solid waste if it has any of the eight
properties listed in §261.23(a). These properties are based largely upon the
definitions employed by the National Fire Prevention Association. Detailed
information on identification and testing of reactive wastes is presented in
Section 2.1.3 of SW-846 and in Section 5.3 of this manual.
The owner or operator of a facility which handles ignitable or reactive
wastes, or which mixes incompatible wastes, or wastes and materials which are
incompatible must take precautions against reactions which:
(1) Generate extreme heat or pressure, fire or explosions, or violent
reactions;
(2) Produce uncontrolled toxic mists, fumes, dusts, gases in sufficient
quantities to threaten human health or the environment;
(3) Produce uncontrolled flammable fumes or gases which, in sufficient
quantities, pose a risk of fire or explosion;
(4) Damage the structural integrity of the device or facility;
(5) Through other means threaten human health or the environment.
The precautions taken to prevent these reactions would generally
encompass:
• Identification of ignitable, reactive, and incompatible wastes
• Identification of the ways that incompatible wastes are combined
• Identification of the sources of ignition and reaction (as indicated
in §264.17(a))
• Analysis of the storage devices used, and their placement in the
facility, should the wastes be stored as they are
• Analysis of methods of treatment which would render wastes
unreactive or nonignitable, and subsequent testing to insure that
the wastes are no longer ignitable or reactive.
5.9.2.2 Precautions (S264.17 and 270.14(b)(9))--
Identification of Ignitable, Reactive, and Incompatible Wastes—In
Part 261, Subpart D, hazardous wastes are listed. Ignitable wastes are
identified by an "(I)" and reactive wastes are identified by an "(R)".
However, these listings will not provide all the information you will need to
identify ignitable, reactive, or otherwise incompatible wastes. It is
recommended that you review Section 5.3, Waste Analysis Plans, to determine
applicable procedures for characterizing these wastes.
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Because many types of hazardous waste are extremely reactive, the
compatibility of hazardous wastes to be combined must be thoroughly evaluated
in order that the aforementioned reactions be prevented. The applicant must
identify the methods which he will employ for estimating the potential
consequences of mixing different classes of waste.
Identification of the Ways Incompatible Wastes are Combined—The primary
cause of combining incompatible wastes is insufficient or inaccurate
information about a waste or wastes. Regardless of the efforts to adequately
characterize wastes via the waste analysis plan, properties of some wastes may
change with time and temperature, thereby producing more or different
hazardous components.
A second cause of accidents is the indiscriminate handling of waste,
which might encompass the following:
• Containers which are supposedly empty, but may contain incompatible
residual wastes.
• Haulers may "top off" their load on the way to the disposal site.
• Rough handling could cause container rupture or leakage that might
result in comingling of otherwise segregated incompatible wastes.
• Indiscriminate disposal of containerized incompatible wastes in the
same cell could result in incompatible waste mixing, once the
containers corrode and leak.
5.9.2.3 Sources of Ignition or Reaction (§264.17(a))—
The regulations list several sources of ignition or reaction from which
the ignitable or reactive wastes must be separated and protected including but
not limited to:
• Open flames,
• Smoking,
• Cutting and welding,
• Hot surfaces,
• Frictional heat,
• Sparks (static, electrical, or mechanical),
• Spontaneous ignition (e.g., from heat-producing chemical reactions),
and
• Radiant heat.
While many of these are self-explanatory, there are three sources which bear.
further comment.
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Special precautions must be taken against smoking by personnel in
facilities handling ignitable or reactive wastes. While the wastes are being
handled, smoking must be confined to specially designated areas. Warnings
against smoking should be clearly displayed to all occupants of the facility.
"No Smoking" signs should be placed conspicuously in areas where hazards exist
from smoking or open flames.
The facility owner and operator must take care as well in the equipment
used in the handling of these wastes. Tools and machinery which are used in
handling ignitable or reactive wastes should be constructed of nonsparking
materials. For example, when placing containers of waste in a landfill, it is
recommended that a tractor barrel grappler be employed. Such equipment allows
the operator to accurately place the containers in a landfill, while greatly
minimizing the risks of damage to the container or ignition or reaction due to
spark-producing equipment.
The ignitable or reactive wastes, particularly the ignitable wastes,
should be segregated from other wastes which may generate radiant heat or
cause spontaneous ignition. For example, ignitable wastes will have to be
segregated from other wastes which may be subject to microbial degradation or
wastes which may be subject to exothermic reaction with water.
Storage Devices—Containers, Tanks, Waste Piles—If the owner or operator
of the hazardous waste management facility chooses to store or dispose of
wastes which are ignitable or reactive, special precautions must be taken in
the selection of the devices employed. Wastes which are reactive or ignitable
may not be placed in a landfill untreated. Ignitable or reactive wastes
stored in containers should not be placed near a waste pile, container, tank,
or surface impoundment which contains a waste or wastes which are
incompatible, unless separated and protected by means of a dike, berm, wall,
or other structure. The container must be in good condition (e.g., no
apparent rusting or structural defects). The permit reviewer may require that
all containers meet the container requirements of the Department of
Transportation Regulations.
For storage of ignitable, reactive, or incompatible waste in tanks, it is
necessary that the buffer zone requirements in the National Fire Prevention
Association's publication "Flammable and Combustible Code—1977" in Tables 2-1
and 2-63 be complied with. Wastes must not be placed in unwashed tanks
which previously held incompatible wastes or materials.
An ignitable or reactive waste may only be placed in a waste pile if the
addition of that waste to an existing pile results in the waste or mixture no
longer meeting the definition of ignitable or reactive waste as specified in
§261.21 and §261.23, respectively.
Treatment Methods—A number of methods are available to treat, render, or
mix wastes so that they are no longer ignitable or reactive. Several
treatment processes which previously were only used in the organic or
inorganic chemical industry are being considered for broader applications in
the treatment of hazardous wastes.
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The rendering of ignitable or reactive compounds nonignitable or
unreactive may be accomplished by diluting the waste with other compatible
material. There are several disadvantages to doing this, however. Hazardous
reactions may result if the materials being mixed are incompatible. Dilution
of liquids is also undesirable because of added liquids involved. For
example, disposal of diluted wastes in a landfill would result in greater
leachate generation. If the quantities of wastes are relatively small,
dilution may be the most economical precautionary measure.
Incineration may be considered as a method to render reactive or
ignitable wastes nonreactive or nonignitable. Ignitable hazardous wastes,
containing solvents and other organic materials are easily incinerated.
Incineration reduces waste volume and may also reduce the potential for ground
water contamination from the ash compared to that associated with disposing of
the parent waste. On the other hand, compliance with air emissions standards
requires emissions evaluation.
After treatment processes are complete, the owner/operator must conduct
testing, or document by some other means, that the waste is no longer
ignitable or reactive. If testing is employed, specification of the testing
procedure must be provided. Available methods to test for ignitability are
set forth in §261.21. Two test methods are acceptable for determining the
flashpoint: Pensky-Martens Closed Cup Tester using the test method specified
in ASTM Standard D-93-79 or D-93-80, or 'a Steaflash Closed Cup Tester, using
the test method specified in ASTM Standard D-3278-78. To test for reactivity,
the applicant should base the demonstration on tests for: water reactivity,
flashpoint/flammability, oxidation/reduction potential, pH, and the presence
of cyanide or sulfide. The testing procedures should conform with the ASTM
Standards and test methods incorporated in SW-846. As stated in §264.17(c),
documentation of compliance may be based upon references to published
scientific or engineering literature, data from trial tests, waste analyses,
or the results of the treatment of similar wastes by similar treatment
processes and under similar operating conditions.
5.9.2.4 Documentation (§264.17(c))—
Documentation of the precautions taken by the owner or operator of a
hazardous waste management facility handling ignitable or reactive wastes to
prevent accidental ignition or reaction is required in the permit
application. The documentation will involve a complete description of the
precautions taken, and how they serve to comply with the §264.17 regulations.
The permit application may be judged to be deficient if the required
documentation is not submitted or is judged to be inadequate.
Specifically, you should list the ignitable and/or reactive or the
incompatible wastes to be handled, stored, or disposed of at the facility. If
methods other than those referenced in the regulations have been employed to
determine ignitability or reactivity (which have been approved by the
Administrator), they must be detailed. The methods employed for estimating
the potential consequences of mixing different wastes should be documented.
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The sources of ignition and reaction present in the facility should be
identified and described. The precautions for prevention of sparking should
be described, as well as the other measures employed to separate and protect
the wastes from open flames, smoking, cutting and welding, hot surfaces,
frictional heat, and spontaneous ignition (e.g., from heat-producing chemical
reactions and radiant heat). Describe how smoking and open flames are
confined to specifically designated locations when ignitable and/or reactive
wastes are being handled, and how "No Smoking" signs are conspicuously placed
wherever there is a hazard from such wastes.
Sketches, drawings, or data should be provided to demonstrate how
containers of ignitable or reactive waste are to be located. Description of
the container systems employed should be included, especially noting
compliance with relevant standards (e.g., the National Fire Prevention
Association's buffer zone requirements for tanks). If no treatment methods
are employed, describe how the ignitable, reactive, or incompatible wastes are
to be separated and protected. State which containment systems are to be
employed for emergency usage.
If the wastes are to be treated, the treatment procedure used must be
fully documented. Fundamentally, one must show how the method will ensure
that the wastes no longer fulfill the requirements for classification as
ignitable or reactive hazardous wastes. The testing methods employed should
also be fully documented.
As you will note from the above description of the documentation
necesary, much of the information or data necessary to document that the
proper precautions have been taken will be included in your application for
other reasons. In these cases, you should reference the location of these
materials in your application under your discussion to demonstrate compliance
with the requirements of §270.14(b)(9). When you reference material in this
manner, make certain that the referenced material does, in fact, describe the
precautions taken to show compliance with §264.17 or include a brief
discussion to "tie together" the referenced materials.
5.9.3 List of Major Points
1. Have you listed the ignitable, reactive, and incompatible wastes to
be handled at your facility?
2. Have you documented the potential consequences of mixing of wastes?
3. Have you taken precautions to separate and protect ignitable or
reactive wastes from sources of ignition or reaction located in your
facility?
4. Have you designated special areas at your facility to which smoking
and open flames must be confined, and placed "No Smoking" signs in
all other locations?
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5. Have you taken all necessary precautions in the selection and
placement of containers and other storage devices?
6. Have you documented the methods employed to treat the ignitable or
reactive wastes, and the methods employed to test the wastes
following treatment?
7. Have you fully documented compliance with all pertinent sections of
the regulations?
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5.10 TRAFFIC
5.10.1 Regulatory Citations
Information related to traffic movement must be submitted with Part B of
the permit application, as specified in:
"§270.14(b)(10) Traffic pattern, estimated volume (number,
types of vehicles) and control (for example, show turns across
traffic lanes, and stacking lanes (if appropriate); describe access
road surfacing and load bearing capacity; show traffic control
signals).
Part 264 of the regulations does not specify any regulatory standards
with which traffic movement must comply.
5.10.2 Guidance to Achieve the Standards
5.10.2.1 General—
The intent of requiring submittal of the traffic related information
delineated in §270.14(b)(10) with the permit application is to insure that
movement of hazardous waste, and simply traffic movement, will be conducted
safely to minimize the risk of accidents. The traffic related information
required is only for that area inside and immediately surrounding the
hazardous waste management facility.
As noted above, there are no "standards" in Part 264 with which traffic
related items must comply. However, the overriding concern is safety. As an
applicant, you should be concerned that the movement of hazardous waste into,
out of, and within your facility will be conducted in a manner that minimizes
accident potential. Additionally, general traffic movement should not be such
that hazardous waste stored or disposed of at your facility will be
disturbed. In order to present traffic related items most effectively in your
permit application, it is suggested that both a discussion and a drawing be
provided.
5.10.2.2 Traffic Patterns and Estimated Volumes—
You should provide a thorough description of both the pattern of general
traffic and the pattern of traffic moving hazardous waste within your
facility. A description of traffic on roadways traveled by the public which
intersect with access roadways to your facility should also be provided. The
following items should be considered for inclusion in your discussion of
traffic patterns and volumes;
• routes traveled
• distances traveled
• number of vehicles
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• types of vehicles
• waste movement sampling and unloading locations
• amount of pedestrian traffic
If traffic volumes vary with the time of day, or if routes will be varied,
these variations should be identified. The following examples are intended to
provide insight into how information on traffic patterns and volumes should be
presented in your permit application. The first is an example presentation
for an offsite landfill. The second is an example for an industrial facility
which operates an onsite surface impoundment and a landfill.
Example 1:
"Plot plan xyz shows the roadways in and around our facility.
Access gates are off Pine St. on the south side and off Lowell St. on the
north side. At both gates, their is a 150-foot distance from the street
to the gatehouse where all entering vehicles must stop. That area, plus
the adjacent aprons shown, provide enough room for up to four
tractor-trailer rigs to pull completely off the public roadway at each
gate while waiting to be processed through the gates.
Pine St. is a two-lane road with a posted 40 MPH speed limit.
It is moderately busy with passenger vehicles during the morning and
evening rush hours but is only lightly traveled in off-peak hours. It is
not a major connector, a short-cut, nor a school bus route.
Lowell St. is a four lane, divided surface artery with a posted speed
limit of 45 MPH. It is heavily traveled during the morning and evening
rush hours by passenger vehicles and trucks and moderately traveled
during all the other daylight hours during which our facility operates.
Lowell St. is not a school bus route.
Both entrances to our facility are equally used. Over the past year,
an average of 45 trucks entered our facility per day. The majority of
these (40) are ten-wheel flat-bed or open dump trucks. The remainder are
20 and 40 foot trailers. Occasionally, waste is brought to our site in
pick-up trucks. During the period from March to May, an additional seven
trucks per day (4 dump and 3 flat-bed) above average entered our facility
during cleanup of the Reeseville Farm site.
As shown on plot plan xyz, vehicles entering our site travel the
perimeter roads to the active portion of the landfill. Empty vehicles
all use roadway A and turn left or right at intersection B toward their
desired exit gate. Both the perimeter and exit roadways are clearly
marked as one-way."
Example 2:
"Plot plan xyz shows the roadways within our facility. The landfill
is labeled A and the surface impoundment is labeled B.
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Hazardous wastes destined for the landfill are collected from the
loading docks labeled 1 through 6. As shown in the plot plan, the
collection truck (a ten-wheel flat-bed) uses one of the indicated routes
from the loading docks to the west perimeter road and then to the
landfill. Collections are scheduled for once per week on Wednesday and
it typically requires three trips to complete the collections.
Hazardous wastes entering the surface impoundment are delivered
directly by pipelines as described on page of this application. As
shown on the plot plan, there is a plant roadway along the east side of
the impoundment. A guardrail has been installed along that roadway at
the impoundment.
Roadways in the plant are traveled by various company trucks,
forklifts, and electric carts. All noncompany vehicles are restricted to
the roadways marked on the plot plan. The hazardous waste collection
truck routes do not follow or intersect the noncompany vehicle routes.
The plant speed limit is posted at 10 MPH. The hazardous waste
collection truck is painted yellow and is equipped with a revolving amber
light on the cab roof. All plant employees have been informed of the
description and purpose of this truck. Plant traffic safety rules have
established that this truck has the right-of-way at all times."
The plot plan and description of traffic in your application should also
indicate traffic control signs and signals. If you have established special
procedures for controlling vehicles containing hazardous wastes you should
describe those procedures in your application.
You are also required to provide a description of roadway surfaces and
load bearing capacity. The intent here is to insure that the roadways are
appropriate for the type and number of vehicles which will be using them.
Further, if the road surface is such that it will require periodic
maintenance, you should consider describing the frequency and type of
maintenance that will be undertaken to insure that the roadway will remain
safe for vehicular traffic. The reviewing agency may also be concerned with
the amount of dust that will be generated by vehicular traffic in and around
your facility.
5.10.3 List of Major Points
1. Have vehicle routes been clearly indicated?
2. Has a description of the number and types of vehicles been provided?
3. Have traffic control signs, signals, and procedures been identified?
4. Has the adequacy of roadway surfaces and load bearing capacity for
expected traffic been clearly demonstrated?
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5.11 LOCATION INFORMATION
5.11.1 Regulatory Citations
Information on the location of the facility must be submitted with Part B
of the permit application, as specified in:
"§270.14(b)(ll) Facility location information.
(i) In order to determine the applicability of the seismic
standard [§264.18(a)l the owner or operator of a new facility must
identify the political jurisdiction (e.g., county, township, or
election district) in which the facility is proposed to be located.
(ii) If the facility is proposed to be located in an area
listed in Appendix VI of Part 264, the owner or operator shall
demonstrate compliance with the seismic standard. This
demonstration may be made using either published geologic data or
data obtained from field investigations carried out by the
applicant. The information provided must be of such quality to be
acceptable to geologists experienced in identifying and evaluating
seismic activity. The information submitted must show that either:
(A) No faults which have had displacement in Holocene time are
present, or no lineations which suggest the presence of a fault
(which have displacement in Holocene time) within 3,000 feet of a
facility are present, based on data from:
(1) Published geologic studies,
(2) Aerial reconnaissance of the area within a five-mile radius
from the facility.
(3) An analysis of aerial photographs covering a 3,000 foot
radius of the facility, and
(4) If needed to clarify the above data, a reconnaissance based
on walking portions of the area within 3,000 feet of the facility, or
(B) If faults (to include lineations) which have had
displacement in Holocene time are present within 3,000 feet of a
facility, no faults pass with 200 feet of the portions of the
facility where treatment, storage, or disposal of hazardous waste
will be conducted, based on data from a comprehensive geologic
analysis of the site. Unless a site analysis is otherwise
conclusive concerning the absence of faults within 200 feet of such
portions of the facility data shall be obtained from a subsurface
exploration (trenching) of the area within a distance no less than
200 feet from portions of the facility where treatment, storage, or
disposal of hazardous waste will be conducted. Such trenching shall
be performed in a direction that is perpendicular to known faults
(which have had displacement in Holocene time) passing within
3,000 feet of the portions of the facility where treatment, storage,
or disposal of hazardous waste will be conducted. Such
investigation shall document with supporting maps and other
analyses, the location of faults found.
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(ill) Owners and operators of all facilities shall provide an
identification of whether the facility is located within a 100-year
floodplain. This identification must indicate the source of data
for such determination and include a copy of the relevant Federal
Insurance Administration (FIA) flood map, if used, or Ihe
calculations and maps used where an FIA map is not available.
Information shall also be provided identifying the 100-year flood
level and any other special flooding factors (e.g., wave action)
which must be considered in designing, constructing, operating, or
maintaining the facility to withstand washout from a 100-year flood.
(iv) Owners and operators of facilities located in the 100-year
floodplain must provide the following information:
(A) Engineering analysis to indicate the various hydrodynamic
and hydrostatic forces expected to result at the site as consequence
of a 100-year flood.
(B) Structural or other engineering studies showing the design
of operational units (e.g., tanks, incinerators) and flood
protection devices (e.g., floodwalls, dikes) at the facility and how
these will prevent washout.
(C) If applicable, and in lieu of paragraphs (b)(11)(iv)(A)
and (B) above, a detailed description of procedures to be followed
to remove hazardous waste to safety before the facility is flooded,
including:
(1) Timing of such movement relative to flood levels,
including estimated time to move the waste, to show that such
movement can be completed before floodwaters reach the facility.
(2) A description of the location(s) to which the waste will
be moved and demonstration that those facilities will be eligible to
receive hazardous waste in accordance with the regulations under
Parts 270, 271, 124, and 264 through 266 of this Chapter.
(3) The planned procedures, equipment, and personnel to be
used and the means to ensure that such resources will be available
in time for use.
(4) The potential for accidental discharges of the waste
during movement.
(v) Existing facilities NOT in compliance with §264.18(b)
shall provide a plan showing how the facility will be brought into
compliance and a schedule for compliance."
The regulatory requirements for facility location are contained in
$264.18. They are:
"§264.18 Location standards.
(a) Seismic considerations. (1) Portions of new facilities
where treatment, storage, or disposal of hazardous waste will be
conducted must not be located within 61 meters (200 feet) of a fault
which has had displacement in Holocene time.
(2) As used in paragraph (a)(l) of this Section:
(i) "Fault" means a fracture along which rocks on one side have
been displaced with respect to those on the other side.
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(ii) "Displacement" means the relative movement of any two
sides of a fault measured in any direction.
(iii) "Holocene" means the most recent epoch of the Quarternary
period, extending from the end of the Pleistocene to the present.
(b) Floodplains. (1) A facility located in a 100-year
floodplain must be designed, constructed, operated, and maintained
to prevent washout of any hazardous waste by a 100-year flood,
unless the owner or operator can demonstrate to the Regional
Administrator's satisfaction that:
(i) Procedures are in effect which will cause the waste to be
removed safely, before flood waters can reach the facility, to a
location where the wastes will not be vulnerable to flood waters; or
(ii) For existing surface impoundments, waste piles, land
treatment units, and landfills, no adverse effects on human health
or the environment will result if washout occurs, considering:
(A) The volume and physical and chemical characteristics of
the waste in the facility;
(B) The concentration of hazardous constituents that would
potentially affect surface waters as a result of washout;
(C) The impact of such concentrations on the current or
potential uses of and water quality standards established for the
affected surface waters; and
(D) The impact of hazardous constituents on the sediments of
affected surface waters or the soils of the 100-year floodplain that
could result from washout.
(2) As used in paragraph (b)(l) of this Section:
(i) "100-year floodplain" means any land area which is subject
to a one percent or greater chance of flooding in any given year
from any source.
(ii) "Washout" means the movement of hazardous waste from the
active portion of the facility as a result of flooding.
(iii) "100-year flood" means a flood that has a one percent
chance of being equalled or exceeded in any given year."
The regulations address two issues relative to a facility's location;
seismic considerations and floodplains. The guidance provided in the
following part of this section of the manual is organized under these two
topical headings.
5.H.2 Guidance to Achieve the Part 264 Standards
5.11.2.1 Seismic Considerations—
Purpose—The intent of the regulation requiring consideration of seismic
activity when locating a facility is to protect these facilities from the
deformation and displacement of the earth's surface when an earthquake occurs
and to prevent the release of hazardous waste that could result from damage to
the facilities. At present (May 1983), the seismic standard applies only to
the location of new hazardous waste facilities. Existing facilities do not
have to comply with the seismic standard in §264.18(a). However, applicants
seeking a permit for an existing facility are advised to contact the
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permitting authority (see Appendix A) to determine if any seismic standards
are applicable at the time they are preparing Part B of their permit
application. A flow diagram (Figure 5-3) is provided to summarize the
location information requirements to meet the seismic standard of §264.18(a).
For new facilities the political jurisdiction (e.g., county, township, or
election district) in which the facility is proposed to be located must be
identified and compared to the list of such jurisdictions provided in
Appendix VI to Part 264 (Table 5-23). If the location is NOT listed in
Appendix VI, no further information is required to demonstrate compliance with
S264.18(a) (all other locations are assumed to be in compliance). If the
location IS listed in Appendix VI, the applicant must demonstrate compliance
with the seismic standard specified in §264.l8(a).
Examples:
"The proposed facility is to be located in Tacoma, Washington, which
lies in Pierce County. Appendix VI lists Pierce County and, therefore,
we have demonstrated compliance with §264.18(a) is in Section _ of this
application."
"The proposed facility is to be located in Massachusetts.
Appendix VI does not list Massachusetts and, therefore, we have provided
no further information to demonstrate compliance with §264.18(a)."
The information which must be submitted by facilities that will locate in
areas listed in Appendix VI of Part 264 to demonstrate compliance with
S264.18(a) is identified in §270.14(b)(ll)(ii). One of two compliance
showings must be made, §270.14(b)(ll)(ii)(A) addresses facilities which can be
shown NOT to be located within 3,000 feet of a fault displaced in Holocene
time and §270.14(b)(11)(ii)(B) covers facilities where such a fault is found
within 3,000 feet of the facility.
In either case, the applicant must demonstrate compliance with the
Seismic standard by using either:
• published geologic data, or
• data obtained from field investigations conducted or sponsored by
the applicant.
Published geologic data includes any existing data which may be available
to the applicant. Field investigations would entail original work performed
by the applicant or representatives. Holocene time is the geologic epoch
which represents approximately the last 11,000 years, although in some parts
of the U.S., the limits of the Holocene may range from 10,000 to 15,000 years
ago. Where deposits or landforms of known Holocene age are offset or
displaced by faults, movement along the fault is established to have occurred
within Holocene time.1
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S-nlll MOI US or rtciiirT
c) wumu or «m«i »>oios COVIIIM J ODD rt
MOIUS or nciiiiT
01 *CCOHMIK«W[ USCD Oil ilTI UUKKC lOW
yiim« 3.000 ri jr r«cuir» ir uttoto ra
ClARirv ABOVE DATA
rAinii (mciuomc LINMTIO«, WHICX HAVI DAD oiir-iAccntm m HOLOCINI
HUE All f«ti[«T HI THIN J.OOO n Or * fACIHK 8UT 00 NOI PASS WITHIN
100 ri or THI POITIOHS or i« r«miT HHIU TKAIKCIIT iioiAU on
DISPOSAL Or HWAUOUS WASTES will >[ UMUCIED
•UED OH
COMPIIEHTirSIVE UOIOCIC AMKSIS Or TIC
Sill KMICH IS CO»tlUSIVC OXCEmnK
A>SCKE or rtu.TS HI THI ii no n or
SUCH POUT i ens or THE r«tmn
ir DATA r«OH SUCH AH MALI*IS IS IHCOKIUSKE
IH IMS AREA. OAIA SHALL >E OIIAmlt f«6» iut-
SOUrACE EHUD" AT I OH (TDCHCHim) Or THE *«£.
WITHIN A DISTANCE HO LISS THAU 200 H run
SUCH POUTIOIIS Or A FACILITY KEHCHINC SHALL
BE PEKFOUxlO IH A DIIECTIOII THAT IS PE*PE«-
DICULAA TO Wan rAULTS (DISPLACEnEMT III
HOLOCEHE TIHE) fASSINC WITHIN ) 000 H Or
THE PO«TIO«S Or THE fACIUTY DISCUSSED THIS
IHVESTICATIOH WILL OOCLHEM LOCATION Or Am
rAULTS FOUND WITH SUPrOITINC NAPS AHD OlKEI
ANALYSIS
Figure 5-3. Seismic standard requirements.
-------
TABLE 5-23. APPENDIX VI POLITICAL JURISDICTIONS
Political Jurisdictions in Which Compliance
With S264.18(a) Must Be Demonstrated
Alaska
Aleutian Islands
Anchorage
Bethel
Bristol Bay
Cordova-Valdez
Fairbanks-Fort Yukon
Juneau
Kenai-Cook Inlet
Ketchikan Prince of Wales
Cochise
Graham
Kodiak '
Lynn Canal-Icy Straits
Palmer-Wasilla-Talkeena
Seward
Sitka
Wade Hampton
Wrangeli Petersburg
Yukon-Kuskokwim
Archuleta
ConeJOB
Hintdale
Hawaii
Arizona
California
All
Colorado
Greenlee
Yuma
Hawaii
Mineral
Rio Grande
Saguache
Idaho
Bannock
Bear Lake
Bingham
Bonneville
Caribou
Cassia
Clark
Be aver he ad
Broadwater
Flathead
Cillatin
Granite
Jefferson
Lake
Lewis and Clark
Madison
Meagher
Missoula
Montana
Franklin
Fremont
Jefferson
Madison
Oneida
Power
Teton
Cascade
Deer Lodge
Park
Powell
Sanders
Silver Bow
Stillwater
Sweet Graas
Teton
Wheat land
(continued)
5-146
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TABLE 5-23 (continued)
New Mexico
Bernalillo
Catron
Crane
Hidalgo
lot Alamos
Rio Arriba
Sandoval
Beaver
Box Elder
Cache
Carbon
Davis
Duchesne
Emery
Carfie Id
Iron
Juab
Millard
Morgan
Che Ian
Clallam
Clark
Covlitt
Douglas
Ferry
Grant
Grays Harbor
Jefferson
King
Ki(s«P
Kictitas
Lewis
Fremont
Lincoln
Park
Sublette
Utah
Santa Fe
Sierra
Socorro
Taos
Tor ranee
Valencia
Piute
Rich
Salt Lake
Sanpete
Sevier
Summit
Tooele
Utah
Wasatch
Washington
Wayne
Weber
Washington
Wyoming
Mason
Okanogan
Pacific
Pierce
San Juan Islands
Skagit
Skamania
Snohomish
Thurston
Wahkiakum
Whatcom
Yakima
Teton
Uinta
Yellowstone National Park
5-147
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Although specific procedures for conducting appropriate field
investigations are not provided in the regulations, all permitting decisions
(waivers, monitoring programs) are based on such data. The applicant's
objective in such an investigation is to obtain the information necessary to
allow the permit writer to evaluate with confidence that the site is not
within 3,000 feet of a fault. Information presented by the applicant must be
of a quality acceptable to geologists experienced in identifying and
evaluating seismic activity.
In the case of §270.14(b)(11)(ii)(A), an applicant must show that no
faults (or lineations suggesting faults) which have had displacement in
Holocene time are present within 3,000 feet of the facility. The applicant
should base this decision on some or all of the following data sources:
• published geologic studies
• walking reconnaissance of the area (3,000 feet)
• aerial reconnaissance of the area (5-mile radius)
• analysis of aerial photos (3,000 foot radius).
Published geologic studies are available through both federal and state
agencies (the U.S. Geological Society, State Geological Survey Offices, the
U.S. Soil Conservation Service, etc.). A listing of the addresses of some of
these agencies is included in Appendix C of this manual. In addition, the
Nuclear Regulatory Commission thoroughly researches the geology around
proposed nuclear sites, thus they might be a source of information. Since a
variety of site related data are required to fulfill permit application
requirements (topography, soils, bedrock and surficial geology, ground water,
surface water, etc.) it is recommended that all available information be
thoroughly researched. Publications, maps, and computerized data bases are
all useful. In some cases, additional information such as ground-penetrating
radar or seismic refraction surveys may also be available. Local agencies and
professional literature should also be consulted. Any deficiencies in data
should be noted. The data should be reviewed and summarized by a qualified
geologist who is familiar with local conditions.
If local conditions are relatively unknown, a walking reconnaissance is
recommended. This walking tour would ideally be designed to tie in other
parameters necessary to complete the application. For example, snapshots
could be obtained, sketches of the area could be drawn for use in compiling
the site map, seismic study areas and flood control measures could be
considered, soil samples could be procured, etc. The people participating in
the site tour should include those whose expert opinions will be used in
evaluating the site; i.e., a geologist, engineer, aerial photograph
interpreter, etc.
If existing aerial photographs are available, they may be used as an
additional source of information. Virtually, all of the U.S. has been
5-148
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photographed in recent years for various federal agencies and a map has been
compiled indicating areas photographed.2 This map is available free of
charge from the:
U.S. Geologic Survey
Washington, D.C. 20242
The map shows all areas of the U.S., by county, which have been photographed
by Federal agencies. Names and addresses of the agencies holding the
negatives for photographs are printed on the back of the map. Stereographic
coverage should be requested. Other potential sources of aerial photos are
listed in Appendix D of this manual. Aerial photos will vary in quality with
season of flight, film type, photo scale, cloud cover, and other factors. You
should determine what photos are available for the site area and procure them
if they would aid in determining the presence of faults.
Air photo interpretation requires experience. Diagnostic features
include terrain position, color tones, topography, drainage and erosional
features, and vegetative cover. Scale should be 1:20,000 for geologic
interpretation of surface materials, in some instances deep, underground
conditions can also be predicted given sharp photography. Onsight follow-up
to aerial interpretations (walking reconnaissance) is recommended to validate
results. Features such as sink holes, which must be investigated as part of
foundation analysis, can also be noted using aerials.
If available photos, having been reviewed by one experienced in aerial
photo interpretation techniques, show conclusively that no faults are present,
the applicant should submit those photos to meet the requirements of
§270.14(b)(ll)(ii)(A). If instead, there is doubt as to their clarity in
indicating lineations or faults for some reason (quality of photo, time of
year, etc.) or if they do not adequately cover the area in question (within a
5-mile radius and covering a 3,000 foot radius about the facility) the
applicant might consider an aerial reconnaissance flight. Information for
planning such a flight is presented as Appendix E to this manual.
Example:
"No faults having had displacement in Holocene time are present at
our site which is located in Long Beach, California. We consulted the
regional USGS Office for ground-penetrating radar or seismic refraction
surveys in the area and procured a ground-penetrating radar survey which
ran inside the site boundary. Topographic and geologic (surficial and
bedrock) maps were obtained. Holocene fault maps of the area were also
procured, as they have been compiled under the California Geologic
Hazards Act. The maps were searched for faults, including fault traces,
fault planes, faults which did not have surface expression, main faults,
branch faults, and secondary faults. Aerial photographs were obtained
from the Soil Conservation Service which covered a 5-mile radius of the
area, and the area within a 3,000 foot radius was analyzed by our
geologist, who is also skilled in interpretation of aerial photographs.
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In reviewing the aerial photos, the interpreter searched for
indicators of faults, such as alignments of .stream segments and small
drainage courses. As most high-angle faults are expressed on photographs
as straight or gently curving lines (this characteristic is probably the
most important clue that a fault may exist), all linear features were
examined care fully. 3 xn one area, a shadow had been cast on the
photos. This area was walked by our experienced geologist, our
engineers, and others who had a part in site evaluation. No evidence of
lineations or faults having displacement during Holocene time was found."
If your analysis of the four data sources indicates that there are no
faults within 3,000 feet of the proposed facility, then you must document that
fact in your permit application and you will have shown compliance with the
seismic standard in §264.18(a). It may not be necessary to submit copies of
all the supporting data. The agency may simply accept the signed statements
of the geologist, photo interpreter, etc. In any case, you should include a
detailed list of all the materials you reviewed and investigated to support
your statement on the absence of faults.
In the event that your investigation does identify a fault within
3,000 feet of your facility, the information you submit must make the showing
indicated in §270.14(b)(11)(ii)(B).
The objective is to provide EPA with suitable information to show that no
faults (or lineations) pass within 200 feet of the portions of the facility
where treatment, storage, or disposal of hazardous waste will be conducted.
This should be based on data from a comprehensive geologic analysis of the
site. This analysis can serve many purposes in that other sections of the
application require similiar data. A comprehensive geologic analysis would
use any or all of the following tools:
• surface geophysical surveying
• drilling and logging of boreholes
• other methods
Seismic Surveys can be used to show where faults or lineations run and to
estimate elevations and thickness of hydrogeologic units. For the analysis
required, ground-penetrating radar and possibly seismic refraction methods
could be utilized. Less definitive seismic tools for fault-detection include
microgravimetry and magnetic surveys. Reflection seismograph surveys may show
faults by a zone of no reflection but provide no definite basis for
determining direction of fault placement; a gravity survey complementary to
this can locate the corresponding fault indications and show direction of
displacement. Drilling and borehole logging can improve estimates of contact
elevations. To verify seismic data, some sort of digging is often required,
such as logging or trenching (subsurface exploration).
5-150
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Aspects of seismic surveys are explained in the following references:**
• For general field investigations including geologic mapping, and
evaluations of borings and trenches - Earth Manual, U.S. Dept. of
Interior, U.S. Government Printing Office, Washington, D.C. 1974;
• For surface geophysical methods - Zohdy et al., "Application of
Surface Geophysics to Groundwater Investigations," U.S. Geological
Survey Techniques of Water Resources Investigations Book 2,
Chapter D.I, 1974; Roux "Electrical Resistivity Evaluations at Solid
Waste Disposal Facilities" U.S. EPA SW-729, 1978; Telford et al.,
Applied Geophysics, Cambridge University Press, Cambridge, 1977;
Dobrin, Introduction to Geophysical Prospecting, McGraw-Hill, Inc.,
New York, 1976; L. L. Nettleton, Monograph Series No. 1, Elementary
Gravity and Magnetics for Geologists and Seismologists, 1971;
Paul M. Tucker and Howard J. Yorston, Monograph Series No. 2,
Pitfalls in Seismic Interpreation, 1973;
• For borehole geophysical methods - Keys and MacCary, "Application of
Borehole Geophysics to Water Resources Investigations; U.S.
Geological Survey Techniques of Water Resources Investigations,
Book 2, Chapter El, 1971.
The Earth Manual, Zohdy et al. (1974), and Keys and MacCary (1971) are
available through the U.S. Government Printing Office (see Appendix A).
If the comprehensive geologic analysis does not provide conclusive
evidence that faults are absent within 200 feet of the portions of the
facility, where treatment, storage, or disposal of hazardous waste will be
conducted, the regulations require the applicant to perform subsurface
exploration (trenching) of the area within a distance no less than 200 feet
from such portions of the facility. This trenching must be performed in a
direction that is perpendicular to known faults (which have had displacement
in Holocene time) passing within 3,000 feet of such portions of the facility.
Supporting maps and other analyses must document the location of any faults
found and these must be submitted as part of the permit application.
Excavations such as this, to more accurately define shallow subsurface
conditions, may also be tied in to permit requirements such as a liner
foundation analysis (if a liner is to be used) or other test pits and trenches.
Example 1:
"We conducted a geologic analysis to augment information from aerial
photographs which had indicated a lineation approximately 1,000 feet from
the proposed facility location. This was followed by an onsite
reconnaissance of the area for clarification. The walking tour indicated
that, in fact, more information would be necessary to determine if the
fault intersected the proposed facility area. Using ground penetrating
radar, the fault was shown to lie outside of a 200 foot radius of the
facility. Maps and data from the survey along with our geologist's
interpretation are included with this submittal."
5-151
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Example 2:
"In carrying out the geologic analysis of this site, two faults were
investigated. One, termed the main fault as it showed greatest
displacement, length and continuity, was located approximately 1,500 feet
from the site. Diverging from this fault and extending well beyond the
main fault was a branch fault which ran to a point only 180 feet from one
portion of the facility as designed. It was decided that a trenching
operation was necessary to further define the extent of the branch fault,
and a back hoe was used to trench perpendicular to the fault in this
area. Based on the results of this trenching, we re-designed the
facility to locate storage tank F at a distance of 400 feet from the
branch fault. We are submitting the following with this application:
detailed engineering drawings of the trenches; surficial and bedrock
geology maps of the site compiled by a local geologist; and a seismic
analysis of the site using ground-penetrating radar."
List of Major Points
1. Under what political jurisdiction does the proposed location fall?
2. Is this county, township, etc. listed in Appendix VI?
3. Is published geologic data available for this site? What other data
can be obtained from the sources used?
4. If published data is not available or inadequate, what type of field
investigations are needed to secure adequate information? Can these
be tied into the other requirements within this application?
5. Is a site walking reconnaissance of the site necessary to clarify
the seismic data? Who should participate in such a tour? What
other data can be collected during the tour?
6. Do aerial photographs exist for the area, and if so, were they taken
(at the correct season of the year, on a useful type of film, from a
low enough altitude, such that they show the entire site area etc.)
such that they are useful in interpretation of faults (lineations)?
If not, is an aerial reconnaissance flight a viable option?
7. Who will interpret the photos, once obtained?
8. If the aerials show faults to be present within 3,000 feet of the
site, can a comprehensive geologic analysis of the site provide
ample evidence to indicate that no fault or lineation displaced in
Holocene time runs within a 200 foot radius of the portions of the
site where hazardous waste will be treated, stored, or disposed of?
9. What data will be submitted to support this application?
5-152
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10. If this information cannot show conclusively that no fault is
present within this 200 foot radius and therefore trenching is
necessary to provide more evidence, what trenching data (maps
analyses, etc.) can be used to show that faults are not present in
the 200 foot range?
11. Has a geologist familiar with the local situation been involved in
this investigation? Would the data be acceptable to geologists
experienced in identifying and evaluating seismic activity?
nro. w di8c?88i°n on the seismic considerations can be found in the
preamble to the regulations located at 46 FR 2810 in the January 12, 1981
issue of the Federal Register. Applicants should also consult the EPA
"
w^!r?Und,DOCUmect "Stand«d* Applicable to Owners and Operators of Hazardous
waste Treatment, Storage, and Disposal Facilities under RCRA, Subtitle C,
ffn^n ~? General Facility Standards for Location of Facilities
(40 CFR 264, Subpart B, Section 264.18)." U.S. EPA, December 30, 1980.
5.11.2.2 Floodplains —
Purpose— The intent of the regulation is to prevent the release of
hazardous wastes from a facility during a flood. In general, the EPA feels
that waste management facilities should not be located where a flood may
occur. However, in some circumstances, it may be necessary to locate a new
waste management facility in a floodplain and, in fact, some existing
facilities are so located. Thus, the informational and regulatory
requirements of I270.l4(b)(ll)(ii) ,(iv) , (v) and §264. 18(b) have been
established to minimize the potential for hazardous waste release in the event
of a flood; they apply to both new and existing facilities. Existing
sEowi^lhn "^ " ^Pjiance with the floodplain standard must provide a plan
showing how they will be brought into compliance and a compliance schedule.
figure 5-a is a flow diagram which summarizes the floodplain information
required to meet the standard in §264.18(b).
The standards in §264.18(b)(l) specify the design, construction,
and operating requirements for facilities located in a 100-year floodplain.
Definitions are provided in §264. 18(b)(2) that should be noted including:
• 100 year floodplain: any land area which is subject to a 1 percent
or greater chance of flooding in any given year from any source.
• 100 year flood; a flood that has a 1 percent chance of being
equaled or exceeded in any given year.
• Flood prone is defined here as any land area susceptible to being
inundated by water from any source.5
The first step in showing compliance is documentation of whether the
facility is located within a 100-year floodplain. Relevant information that
must be provided in the application should include:
• the source of data used for this determination.
5-153
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OMER/DPEMTONS OF »u FACILITIES
HILL PROVIDE AN IDENTIFICATION or
WHETHER THI FACILITY IS LOCATCD
WITHIN * IOO-TEAR FIOOOPLAIN
»> INDICATE SOURCE or DM* FOR SUCH
DETERMINATION
b) INCLUDE * COPT OF IHI RELEVANT FEDERAL
INSURANCE ADHINISTRAIION (Fl») FLOOD
BAP. IF USED OR THE CUMULATIONS «O
HAPS USED WHERE A FIA HAP IS «OI
AVAILABLE *
cl INCLUDE INFORMATION IDCmiFTIIIC THE
100-YEAR FLOOD LEVEL AMI *»V OTHER
SPECIAL FLOODmC FACTORS (e g . WAVE
ACTION) WHICH DUST 1C CONSIDERED IN
DESIGNING. CONSTRUCTING. OPERATING.
OR MAINTAINING THE FACILITY TO WITH-
STAND WASHOUT FROH A 100-fEAR FLOOD
OVNEI/OPOATOIIS OF FACILITIES LOCATCD
WITHIN THE 100-VEJM FLOODPLAIN HUST
PROVIDE ADDITIONAL INFORMATION
HUST
«) SUBHII AN [NCINCERING WALTS IS TO INDICATE
THE VARIOUS HYOROOYNAHIC AND HTBROSTAI1C
FORCES CIPECTEO TO RESULT AT THE SITE AS A
CONSEQUENCE OF A I DO-TEAR FLOOD
b) PIOVIDE STRUCTURAL OH OTHCH CWINCOINC
STUDIES SHOWING IHE DESIGN OF OPERATIONAL
UNITS (e g . TANKS. WASTE PILES) AND
FLOOD PROTECTION DEVICES (e g . FLOODWALIS
DIKES) AT THE FACILITY AND HOW |piESC WILL
PREVENT WASHOUT
EUSTING FACILITIES NOT IN COBPIIWIC WIIH
irfl iB!b) IFLOOOPLAINS) HOST PROVIDE A PLAN
SMOWIW HOW IRE FACILITT WILL BE IROUCHT INTO
COHPUANCE ANO A SCHEDULE FOP. COMPLIANCE
OR
If APPLICABLE
c) IN LIEU OF j) and b). PROVIDE A DETAILED
DESCRIPTION OF PROCEDURES 13 U FOLLOWED
TO RCNOVE HAZARDOUS WASTE TO SAFETY BEFORE
IHE FACILITY IS FLOODED INCLUDING
d) TIH.NG OF SUCH HOVEHENT RELATIVE (n
TO FLOOD LEVELS. INCLUDING ESTI-
MATED TINE TO HOVE THE WASTE. 10
10 SHOW THAT IBIS HOVCnEHT CAN BE
COH'LETEO BEFORE FLOODWATERS REACH
THE FACILITY
|l<
11) DESCRIPTION OF LOCATION(S) TO
WHICH THE WASTE WILL BE MOVED
AND DC10NS1RATION THAT THOSE
FAC'LITIES WILL BE ELIGIBLE TO
RECEIVE HAZARDOUS WASTE IN ACCORD-
ANCE WITH REGS UNDER PARTS 122-124
AHO 264-2M OF RCRA
THE PLANNED PROCEDURES iquiP«E<-
AND PERSONNEL 10 BE USED AND THt
HEANS TO ENSURE THAT SUCH RISOUCES
WILL Ot AVAILABLE >« TIKI 10* 1.41
THE POTENTIAL FOR ACCIDEHUi
DISCHARGES OF THE WASTE DURIHG
NOVEHENT
•WHERE FIA NAPS ARE AVAILABLE THEY WILL NORMALLY INDICATE WHETHER A FACILITY IS LOCATED WITHIN OR OUTSIDE Or THE 100-YEAR FLOOOPUIN. WHERE
7S fli ^.craErw^'luruALLY AREis OF THE FLOOOPLAIN «200' IN WIDTH]. THESE AREAS HUST BE CONSIDERED ANO A DETERMINATION HADE AS TO
WHETHER THEY ARE IN THE 100-YEAR FLOODPLAIN WHERE FIA NAPS ARE NOT AVAILABLE. EQUIVALENT NAPPING TECHNIQUES HUST BE USED BT THE OWNER/
OPERATOR TO DETERMINE WHETHER THE FACILITY IS WJTHIN THE 100-YEAR FLOOOPLAIN. AND IF SO LOCATED. WHAT THE 100-YEAR FLOOD ELEVATION WOULD BE
Figure 5-4. Floodplain location requirements.
-------
• an original or clear copy of the relevant Federal Insurance
Administration (FIA) flood map or calculations and maps used where
an FIA map is not available.
• clear identification of the 100-year flood level and any other
special flooding factors (e.g. wave action) which must be considered
in designing, constructing, operating or maintaining the facility to
withstand washout from a 100-year flood.
As a part of the National Flood Insurance Program (NFIP), Flood Hazard
Boundary Maps (FHBM) have been prepared for virtually all 20,238 communities
that have been identified as "flood prone".1 The FHMB delineates the
boundaries of the 100-year floodplain, but elevations are not provided.
Nearly 90 percent of the Federal Emergency Management Agency (FEMA) maps are
FHBMs. In addition, some of the communities that have been accepted into the
NFIP have Flood Insurance Rate Maps (FIRM) which delineate the 100-year
floodplain and also provide flood elevations.1 Where these maps are
available, the determination as to location on a 100-year floodplain is
straight-forward. Such maps are most often included as part of a brief Flood
Insurance Study for a particular political jurisdiction along a waterway. The
U.S. Department of Housing and Urban Development, Federal Insurance
Administration which publishes such studies, includes a fold-out map
delineating 100-year flood boundaries for various river reaches in the area
covered. Examples provided in this section refer to such a map and a
representative drawing of one may be found in Figure 5-5 which appears later.
In addition, parameters such as hydraulic analyses used to determine the flood
level, community description, and principal flood problems and flood
protection measures are provided in such flood insurance studies.
If a 100-year flood level is not available from another source, it can be
determined using a FHBM. A qualified hydrologist will be able to make such a
determination in less than a day's work or FIA may be contacted to assist in
determining the 100-year flood elevation at a particular location.1 FIA,
however, does not usually map floodplains that are less than 200 feet wide;
therefore, it is unlikely that mapped information exists for such areas.
Where FIA omits an area due to this 200 foot exclusion, the owner or operator
will have to make a determination as to the extent of the 100-year floodplain.
FIA mapping procedures or equivalent mapping techniques should be used to make
this determination, and to determine what the 100-year flood elevation would
be.1 You should note that floodplains less than 200 feet wide are
frequently subject to local zoning ordinances and easements.
Other sources of floodplain maps and additional information may also be
consulted, such as the U.S. Geological Survey, the U.S. Army Corps of
Engineers, the U.S. Soil Conservation Service, and the Office of Coastal Zone
Management. The Army Corps of Engineers has issued technical manuals on
desien and construction techniques and methods for ascertaining the proper
levels of structural integrity for flood protection devices such as dikes,
covers, and flood walls. For example, the general manual entitled Flood-
Proofing Regulations" will be of use to the applicant (EP 1165-2-314,
June 1972). There is also an Engineering Manual by the Army Corps of
5-155
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Engineers (EM 1110-2-1913) for design and construction of levees (1978). The
Department of the Array also published "Wall Design: Floodwalls" in 1948 which
was due to be revised by 1981. The U.S. Bureau of Reclamation published a
manual for design of small dams in 1973. In,addition, the Nuclear Regulatory
Commission has thoroughly researched the manner in which one protects elements
of a nuclear facility from the hazards of flooding. Those techniques could
also be applied in hazardous waste facility protection.1
Example 1: Flood Insurance Study Available
"The facility is proposed to be located in the Borough of Trainer,
Pennsylvania, near Marcus Hook Creek, which is a tributary to the
Delaware River. Facility plans call for use of land near the Smith
Street area, as shown in Figure 5-5. The'Flood Insurance Study for
Trainer Borough has been obtained through the Federal Emergency
Management Agency (FEMA), Region III, Philadelphia, PA, and is submitted
as part of this application. The location of the facility is within the
100-year floodplain as indicated on the map provided by FEMA (see
Figure 5-5). That map is included in this application. The flood
elevation is approximately 12.25 feet msl (provided on map). Special
flooding factors applicable in this area were researched; wave action is
not deemed to be a significant problem on the creek. Potential sources
which could influence flooding, located upstream of the site, are
enumerated and plans for dealing with flooding are included in this
application."
Example 2: Site Near Water Body—No Flood Insurance StudyAvaliable Use
Hydrologist and Computer Modeling
"The proposed facility will be built near a water body for which no
Federal Flood Insurance Study has been carried out. A map of the area is
included in this submittal showing the potential 100-year flood elevation
as determined by a hydrologist. Water surface elevation for the 100-year
flood was computed using the U.S. Army Corps of Engineers HEC-2 step-back
water computer program (U.S. Army Corps of Engineers, Hydrologic
Engineering Center, October 1973, HEC-2 Water Surface Profile Users
Manual 723-02A, Davis, CA).6 The map included in this submittal
delineates the 100-year flood elevation predicted by the model as well as
the proposed facility location and indicates that the facility will not
be located in this floodplain."
Example 3: Site Near Small Creek—No FIA Study Available—Request Aid
"The site location is near a small creek which is excluded from FIA
maps due to the fact that the floodplain is less than 200 feet in width.
We requested aid from the FIA to help designate the 100-year floodplain
and associated elevation for this area. The resultant map is part of
this application and indicates that the site is not within the 100-year
floodplain boundary."
5-156
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FLOODWAY
PROPOSED
SITE
D
100 YR.
'FLOOD BOUNDARY
500 YR.
FLOOD BOUNDARY
0 200 400 tttt
Figure 5-5. Site located on 100-year floodplaln.
Source: Reference 6.
5-157
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Example 4: Site Near Water Body—No FIA Study Available—Obtain
Gaging Records
"Records from a nearby gaging station were obtained from the USGS
covering the past 50 years. Combining these flood records with
climatological data from the National Weather Service an elevation for a
100-year flood was determined. Drum storage onsite was designed such
that it was located at the highest point onsite, 25 feet above the
estimated 100-year flood evaluation."
If the preceding investigation reveals that your facility is not in the
100-year floodplain, submittal of the documentation is compliance. If,
however, your facility is located in the 100-year floodplain, then the
regulations require that a facility in a 100-year floodplain be designed,
conatructed, operated and maintained to prevent washout, unless you can
demonstrate that if washout occurs, no adverse effects on human health or the
environment will result. To demonstrate this, regulations stipulate that you
must either:
• Provide for the safe removal of waste (to a non-vulnerable location,
as specified) before the flood waters reach the site, OR,
• Owners of existing surface impoundments, waste piles, land treatment
units, and landfills may choose to demonstrate that no adverse human
health effects or environmental effects will result if washout
occurs based on:
the volume and physical and chemical characteristics of the
waste in the facility;
the concentration of hazardous constituents that would
potentially affect surface waters as a result of washout;
the impact of such concentrations on the current or potential
uses of the affected surface waters, including demonstration of
compliance with established water quality standards; and
the impact of hazardous constituents on the sediment °*
affected surface waters or the soils of the 100-year floodplain
that could result from washout.
All applicants who do not make a "no adverse affects" showing must
provide information regarding either the procedures that will be relied upon
to insure flood protection or the methods that will be used to remove wastes
to Safety in the event of flooding. Flood protection refers to any method
which prevents flood waters from reaching the facility or active P^ions
.""tCral <££ U;;;«ve«eo. For example, elevating . tank ,uch that flood
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waters in a 100-year flood would be likely to make contact with the tank's
support structure, but not overtop the tank itself, or use of impermeable
walls for structures, or proper anchoring of containers. Flood protection
measures may also be needed at a flood proofed facility if waste will be
exposed at the 100-year flood level (i.e., an uncovered tank).1 Any permit
applicant who decides to demonstrate that a facility is protected against
hazardous waste release if flooded must provide both an engineering analysis
that indicates the various hydrodynamic and hydrostatic forces expected at the
site as a consequence of a 100-year flood, and structural or other engineering
studies showing the design of operational units (e.g., tanks) and flood
protection devices (e.g., floodwalls, dikes) at the facility and how these
will prevent washout.
Alternatively, any applicant seeking a permit for a facility that is
located in a 100-year floodplain has the option of removing waste from a flood
prone area in the event of flooding. In these cases, the applicants should
describe a justifiable plan which details the procedures to be followed to
remove hazardous waste to safety before the facility is flooded. The
information which is required is presented in §270.14(b)(11)(C) and includes:
• An indication of the timing of waste movement relative to flood
levels, including estimated time to move all the waste. You must
show that such movement can be completed before floodwaters reach
the facility.
• A description of the location(s) to which the waste will be moved.
You must demonstrate that this facility is either permitted by EPA
under 40 CFR Part 264, authorized to manage hazardous waste by a
state with a hazardous waste management program authorized under
Part 123 of 40 CFR or in interim status under Part 265 of 40 CFR.
• An explanation of the planned procedures, equipment, and personnel
to be used and the means you will employ to ensure that such
resources will be available in time for use.
• A determination and description of the potential for accidental
discharges of the waste during movement.
Requirements pertaining to other Federal laws (the Wild and Scenic Rivers
Act, the National Historic Preservation Act, the Endangered Species Act, the
Coastal Zone Management Act, the Fish and Wildlife Coordination Act, and other
Executive Orders) which affect the location and permitting of facilities may
be found in §122.12. EPA also has a manual for Special Environmental Area
(SEA) requirements for hazardous waste facility permits that provides details
relative to these laws. Applicants are encouraged to consider the
requirements of these other laws when planning a facility location to prevent
possible permit delays.
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Example 1: Proposed Land Treatment Facility—Flood Protection
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Forklift trucks will be used to transport the barrels from their present
location to a concrete platform,* built 6 feet above the 100-year flood level
on a hill onsite (approximately 500 feet away from Building D). Drums will be
placed, at a maximum, two drums high, using the pallets for support. In most
circumstances, however, we will be storing significantly fewer than 400 drums
and stacking will not be necessary. Waste removal procedures are keyed to the
river stages, such that, when the river approaches the 100-year flood stage,
the contingency plan for drum relocation is initiated. Using four forklifts
and a flat-bed truck we estimate that 400 drums can be moved in 3 hours and
assure completion before floodwaters reach the facility.
The potential for accidental discharge of the waste during movement has
been evaluated (damaging drums with the forklift, spilling drums, etc.) and
necessary precautions are included as an attachment. Personnel who will be
involved are trained and available at all times onsite. Methods to prevent
any discharge are included in the application, including: health and safety
precautions, drum removal stipulations, a mock demonstration of removal,
personnel qualifications, and flat-bed truck and forklift maintenance."
Example 4: Existing Waste Pile
"Almost half of the facility property is located within the 100-year
floodplain and is subject to floods 1-5 feet in depth. The long-term
solution offered is to move the waste pile to higher ground; plans for
such are attached. However, if a flood occurs prior to this, the
following steps will be followed:
1. We will consult with the nearest National Weather Service station or
the Array Corps of Engineers for a projected time and elevation of
flood crest.
2. If this crest will result in less than 1 foot of water in the waste
pile area, sandbags will be used to dike the area to a level of
1 foot over the projected level of water.
3. If the crest will be greater than 1 foot, the waste will be removed
in a similiar manner to that described in "Managerial Solutions" of
this section. The waste pile will take approximately 6 hours to
remove; a sandbag dike will protect the site during this time."
*Note: The applicant should recognize that the location to which the wastes
will be moved must be a RCRA Interim Status Facility or a RCRA Permitted
Facility.
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Example 5: New Landfill
"A permanent flood water protection dike will be constructed around
three aides of the active landfill cells. A temporary flood water
protection dike is to be constructed along the fourth side of the active
landfill cells, to be moved as the landfill cells are expanded. When the
maximum landfill cell size is reached, a permanent flood water protection
dike will be constructed. The flood water protection dike will be
constructed to a minimum elevation of thirteen feet above mean sea level,
thus providing a factor of safety of 2 feet above the 100-year flood
elevation. Additionally, side slopes will not exceed three horizontal to
one vertical and will be protected from erosion due to incident rainfall,
rainfall runoff, or flooding. Attachments showing all engineering plans
are included."
Example 6: Existing Landfill
"The landfill site is located on a 100-year floodplain. The volume
and physical and chemical characteristics of the waste in the facility
are reported as attachments to this application, as well as
concentrations of hazardous constituents that could affect surface waters
in a washout. Impacts of these constituents on users, water quality
standards and sediments was evaluated by a toxicologist and are reported
in the application. The facility is shown to be in compliance with
existing standards."
Existing facilities that are located on a 100-year floodplain but do not
have a flood plan or are not designed to withstand washout are not in
compliance with the floodplain regulations in §264.18(b). These applicants
are required by §270.14(b)(ll)(v) to provide a plan indicating how and when
the facility will be brought into compliance. A schedule supporting these
assertions must be included.
Example:
"The facility was built in 1976. It is located on the 100-year
floodplain and no flood protection or flood proofing measures exist;
therefore, it is currently NOT in compliance with the regulations in
S264.18(b). Under the interim RCRA permit for this facility, a
compliance schedule was adopted which allows a one year time period
during which levees will be built to bring the facility into compliance.
Engineering plans of levee development are included in this application;
they show the design of the operational units of the facility. Various
hydrodynamic and hydrostatic forces expected during a 100-year flood are
reported and features to protect the facility from damage due to such are
enumerated."
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Liet of Major Points
1. Is the area in question adjacent to any streams or rivers?
2. Are FIA flood hazard boundary maps/insurance studies available for
the area in question? Are Flood Insurance Rate Maps available?
3. If not, are floodplain maps available from USGS or the Army Corps of
Engineers or local planning agencies?
4. If the site is on a small floodplain area ( 200 feet wide), will the
FIA help determine the 100-year flood elevation and areas affected?
Can FIA techniques be used to calculate the elevation in-house?
5. What other tools can be used to indicate that the site is or is not
located on a 100-year floodplain?
6. What special flooding factors should be considered in designing,
constructing, operating, and maintaining the facility to withstand
washout from a 100-year flood?
7. What hydrostatic and hydrodynamic forces are expected to result at
the site as a consequence of a 100-year flood?
8. What type of control measure is warranted at the site: flood
protection or flood proofing?
9. How are such units designed to show that washout will be prevented?
10. Is it practical to remove the waste to a safe location at the onset
of flood conditions? How will such notification be assured? How
will the removal take place? What equipment will be used? How is
availability documented? How quickly can removal occur? What will
be involved in the procedure, who will be responsible for what
action, etc.? Where will the waste be moved to? Is this place
eligible to receive hazardous waste in accordance with the
regulations? What means are available to insure that the resources
for such removal will be available in time for use? What is the
potential for accidental discharge of waste to the environment
during movement?
11. What are the volumes and physical and chemical characteristics of
the waste?
12. What is the concentration of hazardous constituents that could
affect surface waters during washout and what impact does this have
on potential users of these waters and applicable water quality
standards?
13. What is the impact on the sediments of these potentially affected
surface waters or soils of the 100-year floodplain if there is a
washout?
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14. Is the facility in compliance with §264.18(b) (The Floodplain
standards) i.e., is it designed, constructed, operated, and
maintained to prevent washout of any hazardous waste during a
100-year flood?
15. If not, can it be demonstrated instead that the waste will be safely
removed to a non-vulnerable location in case of flood?
16. If none of the above, can it be demonstrated that no adverse effects
on human health or the environment will ensue due to washout (from a
100-year flood) from the facility? Consider volume and physical and
chemical characteristics of the waste; concentration of wastes which
could affect surface waters in a washout; impact on users, water
quality standards, impact on soils, etc.
Additional discussion on the floodplain requirements can be found in the
preambles to the regulations at 46 FR 2813 and 47 FR 32290 in the
January 12, 1981 and July 26, 1982 Federal Registers, respectively. Also,
applicants should review the EPA Standard for Location of Facilities described
at the end of the seismic analysis Section, 5.11.2.1.
5.11.3 References
1. General Facility Standard for Location of Facilities (40 CFR 264,
Subpart B, Section 264.18). Background Document. U.S. Environmental
Protection Agency. December 30, 1980.
2. Avery, T. Eugene. Interpretation of Aerial Photographs. 2nd
Edition. Burgess Publishing Company, Minneapolis, MN, 1968.
3. Ray, Richard G. Aerial Photographs in Geologic Interpretation and
Mapping. Geological Survey Professional Paper 373; U.S. Government
Printing Office, Washington, DC., 1960, p. 21.
4. Draft Permit Writers Manual for Subpart F.
5. U.S. Federal Emergency Agency, Federal Insurance Administration.
"National Flood Insurance Program." §1909.1 Definitions. Federal
Register. Vol. 41, No. 207. Tuesday, October 26, 1976.
6. U.S. Department of Housing and Urban Development, Federal Insurance
Administration. Flood Insurance Study. Borough of Trainer, PA,
Delaware County, September 1977.
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5.12 PERSONNEL TRAINING
5.12.1 Regulatory Citations
Information on employee training must be submitted with Part B of the
permit application, as specified in:
"§270.14(b)(12) An outline of both the introductory and
continuing training programs by owners or operators to prepare
persons to operate or maintain the HWM facility in a safe manner as
required to demonstrate compliance with §264.16. A brief
demonstration of how training will be designed to meet actual job
tasks in accordance with requirements in §264.16(a)(13)."
The regulatory requirements regarding employee training are contained in
5264.16. They are:
"§264.16 Personnel Training
(a)(l) Facility personnel must successfully complete a program
of classroom instruction or on-the-job training that teaches them to
perform their duties in a way that ensures the facility's compliance
with the requirements of this Part. The owner or operator must
ensure that this program includes all the elements described in the
document required under paragraph (d)(3) of this Section.
(2) This program must be directed by a person trained in
hazardous waste management procedures and must include instruction
which teaches facility personnel hazardous waste management
procedures (including contingency plan implementation) relevant to
the positions in which they are employed.
(3) At a minimum, the training program must be designed to
ensure that facility personnel are able to respond effectively to
emergencies by familiarizing them with emergency procedures,
emergency equipment, and emergency systems, including, where
applicable:
(i) Procedures for using, inspecting, repairing, and replacing
facility emergency and monitoring equipment;
(ii) Key parameters for automatic waste feed cut-off systems;
(iii) Communications or alarm systems;
(iv) Response to fires or explosions;
(v) Response to ground water contamination incidents; and
(vi) Shutdown of operations.
(b) Facility personnel must successfully complete the program
required in paragraph (a) of this Section within six months after
the effective date of these regulations or six months after the date
of their employment or assignment to a facility or to a new position
at a facility, whichever is later. Employees hired after the
effective date of these regulations must not work in unsupervised
positions until they have completed the training requirements of
paragraph (a) of this Section.
(c) Facility personnel must take part in an annual review of
the initial training required in paragraph (a) of this Section.
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(d) The owner or operator must maintain the following documents
and records at the facility;
(1) The job title for each position at the facility related to
hazardous waste management, and the name of the employee filing each
job;
(2) A written job description for each position listed under
paragraph (d)(l) of this Section. This description may be
consistent in its degree of specificity with descriptions of other
similar positions in the same company location or bargaining unit,
but must include the requisite skill, education, or other
qualifications, and duties of employees assigned to each position;
(3) A written description of the type and amount of both
introductory and continuing training that will be given to each
person filling a position listed under paragraph (d)(l) of this
Section;
(4) Records that document that the training or job experience
required under paragraphs (a), (b), and (c) of this Section has been
given to, and completed by, facility personnel.
(e) Training records on current personnel must be kept until
closure of the facility; training records on former employees must
be kept for at least three years from the date the employee last
worked at the facility. Personnel training records may accompany
personnel transferred within the same company."
5.12.2 Guidance to Achieve the Part 264 Standards
5.12.2.1 General—
The intent of the personnel training requirements is to reduce the
potential for mistakes which might threaten human health or the environment by
insuring that facility personnel working in jobs where they handle hazardous
waste will be thoroughly familiar with their duties and responsibilities.
Further, the intent of the training requirements is not only to train
personnel in the mechanics of their job function. Rather, and especially in
the areas of safety and emergency response, employees should be made cognizant
of why they must perform certain tasks in a prescribed manner. Providing
employees with a thorough explanation of why certain operations are performed
as they are, and not in a seemingly easier fashion, should reduce the use of
"short-cut" procedures that may be dangerous to plant personnel or the
surrounding population.
*
An outline of the training program for each of the job positions at your
facility must be submitted with your Part B application. It should list the
areas of concern which will be covered in both the initial training program
and in the annual review program.
The point that you should make in your outline is that your programs will
prepare your employees to operate and maintain the hazardous waste facility in
a safe manner (as required to demonstrate compliance with §264.16).
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You must also include a brief description of how your training programs
will be designed to relate specifically to individual job tasks in
familiarizing your employees with emergency procedures, emergency equipment,
and emergency systems at your facility.
The requirements of §264.16 are that:
• Facility personnel must successfully complete a training program
which ensures the facility's compliance with the requirements of
this Part (§264.16(a)(1)).
• The training program must be directed by a person trained in
hazardous waste management procedures (§264.16(a)(2)).
• The training program must be designed to ensure at a minimum that
facility personnel are able to respond with familiarity during an
emergency situation (§264.16(a)(3)).
• Facility personnel must successfully complete the program within six
months of their assignment to a facility (§264.16(b)).
• Facility personnel must take part in an annual review of the
training program (§264.16(c)).
• The owner/operator must maintain documentation at the facility
(§264.16(d)).
• Training records on-current personnel must be kept until closure of
the facility (§264.16(e)).
"Facility Personnel," is defined in §260.10, as: "All persons who work
at, or oversee the operations of a hazardous waste facility, and whose actions
or failure to act may result in noncompliance with the requirements of
Parts 264 or 265 of this Chapter." In other words, all personnel (supervisors
and nonsupervisory personnel) who are actively engaged in the operation of the
facility require the type of training which is described in this section of
the manual.
The EPA is preparing a training manual which will describe the type of
instruction which the Agency believes is appropriate for the various functions
carried out at hazardous waste management facilities. It will provide general
guidance on how to comply with the §264.16 training standards.
5.12.2.2 Responsibility of Facility Personnel §264.16(a)(l)~
Under the guidelines of the regulation, all personnel associated with the
handling of hazardous wastes are required to "successfully" complete a program
of classroom instruction or on-the-job training that teaches them to perform
their duties in a way that ensures the facility's compliance with the
requirements of this part.
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A certification program is not included in the training requirements.
This means that facility personnel and instructors will not be required to
receive a formal certificate stating that they have successfully completed
their particular training programs in hazardous waste management.
Additionally, there is no minimum hourly requirement. Due to variability in
waste types, management processes, and employee functions at hazardous waste
facilities, it was not possible to specify rigid training courses in the
regulations.
It is required that the training programs be specific to the various
positions performed at your facility. Training should be structured so that
it Parallels as realistically as possible the actual job in order that the
real world activities are approximated as much as possible. Any training
program must also take into account the educational level of the class.
Training may be acquired in any one of three ways: a formal training
program (which refers to a training program offered outside of the facility
such as the National Hazardous Materials Training Course offered by the Toxic
Substances Control Laboratory of Vanderbilt University), in-house training
programs, or on-the-job training programs. A combination of these three is
also feasible. The decision lies with the owners and operators of the
facility to determine which option is the most beneficial to operation of
their facility.
It is not necessary for all facility personnel to be trained by attending
a formal program. One approach would be to send only your supervisory
personnel to formal, off-site training programs. In this way, they can
acquire the appropriate training skills and then relay those skills to the
remaining facility personnel by conducting more focused, on-the-job training
866s ions•
Choosing on-the-job or in-house training program options, as opposed to a
formal training program, allows for more flexibility in your training
programs. They can be designed to closely fit the individual needs of the
employees job requirements. A formal training program will be more general
than a set of training programs designed for each of the positions at your
facility, and thus may not cover all of the various job positions in the level
of detail which is required by the regulation.
All facility personnel, regardless of their position, must be
familiarized with your facility's contingency plan so they will all be able to
respond effectively in an emergency situation (i.e., an evacuation due to the
volatilization of spilled toxic wastes). In this case, the majority of
employees will be responsible for vacating the premises in a predetermined
manner, while other facility personnel (those who have been properly trained)
will have higher levels of responsibility. Some may be responsible for
containing the spill, informing local officials (i.e., police and firemen), or
bringing out fire-fighting equipment.
5.12.2.3 Program Instructors §264.16(a)(2) —
The training program must be instructed by persons who are trained in
hazardous waste management procedures and can familiarize facility personnel
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with those same management procedures. Facility personnel are only
responsible for learning those procedures which are relevant to the positions
in which they are employed.
Program instructors, especially those conducting formal programs, should
preferably be experts in the field of hazardous waste management, since
answers to questions that could arise during the class may require a
background of considerable experience and expertise. For performance type
training programs (on-the-job training), the instructor should be a supervisor
who is skilled in the current methods of facility operation. Supervisors are
recommended since they are the ones who must ultimately make the determination
of whether or not the trainees have mastered the skills necessary to perform
the tasks called for in their job descriptions.
5.12.2.4 Response to Emergencies §264.16(a)(3)—
At a minimum, your training program must familiarize facility personnel
with emergency procedures, emergency equipment, and emergency systems which
are applicable to their positions. Emergency response procedures which should
be taught to selected facility personnel, as required by the regulations, are:
• Procedures for using, inspecting, repairing, and replacing facility
emergency and monitoring equipment,
• key parameters for automatic waste feed cut-off systems,
• communications or alarm systems,
• response to fires or explosions,
• response to ground water contamination incidents, and
• shutdown of operations.
Additionally, employees who are in charge of managing wastes must have
certain knowledge which will help them perform their jobs adequately. For
example, their training program might include the following instructions;
• the chemical characteristics of the wastes which they are assigned
to manage (i.e. , reactivity and incompatibility with other types of
wastes),
• knowledge of what to do in the event of a spill or leak,
• the types of protective equipment (such as respirators or self
contained breathing equipment) or clothing to be worn,
• proper operation of trucks, forklifts, or any other machinery to be
used in waste disposal,
• knowledge of basic first aid, and
• who to inform in the event of an emergency (such as the foreman).
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It is your responsibility to define the scope of the training programs.
The training programs should assure the Agency that your employees have or
will have acquired the necessary training and management skills needed to
perform their jobs in a competent manner that will protect human health and
the environment. Thus, the more detailed the training program documentation,
the more apparent it will be to the Agency that your facility is providing its
personnel with proper training.
5.12.2.5 Time Requirements S264.16(b)~
To comply with the §264.16 regulations, the training program must be
successfully completed by facility personnel at existing facilities within
6 months after the effective date of the regulations. Thus, you have
12 months from the promulgation date of the regulations (July 26, 1983) to
make sure that your personnel have received their proper training.
New employees who are hired after the effective date of the regulations
must not work in unsupervised positions requiring them to handle hazardous
wastes until they have completed their training programs. New employees may
handle hazardous wastes but only under the supervision of trained employees.
It is beneficial to your facility to meet this requirement, as it will help
avoid accidents and may help to keep insurance premiums at a minimum.
5.12.2.6 Annual Review §264.16(c)—
The emergency procedures taught in the original training program must be
reviewed on an annual basis to keep personnel up to date with any changes,
such as the characteristics of new wastes managed at your facility. With new
and more sophisticated technologies being developed for hazardous waste,
management facilities may have to periodically change certain procedures to
remain current with these new technologies.
Also, due to changes in facility processes or emergency equipment, or
with the types of wastes being accepted at your facility, your facility's
contingency plan may need to be modified. Therefore, the contingency plan
should also be included in the annual review process.
5.12.2.7 Recordkeeping §264.16(d)&(e)~
Records must be kept at your facility for examination by the Regional
Administrator upon request. Maintenance of facility personnel training
records acts as a certification program. The following must be included on
your records:
(1) A job title for each position at your facility that is related to
hazardous waste management (i.e., excluding clerical or janitorial
positions) and the names of the employees filling those positions,
(2) a job description for each of those positions, and
(3) a description of the type and amount of introductory and continuing
training that will be given to each employee.
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The job description (for each position) must include:
• skill, education, or other qualifications needed by employees to
fill each position at your facility,
• duties of employees assigned to each position.
It should not be too difficult to comply with the first or second
recordkeeping requirements, since many facilities may have this information
already in a written format. If not, job titles and job descriptions must be
defined for each position.
The third recordkeeping requirement relates directly to the training
program. For each job description, you must include the type of training to
be given and the length of the program. For instance, if you are sending
employees to a formal training program you must keep a written document
stating the types of hazardous waste management practices being taught and the
length of time involved.
Similarly, if you have designed your own training programs to be
conducted in-house or on-the-job, you must keep a detailed written account of
the material to be presented for each position. You must also include the
techniques to be used and a schedule to be followed by the instructors. The
training records must also contain the type and amount of training that will
be given to fulfill the annual review requirement.
The records must be documented to prove that the proper training has been
given to, and completed by facility personnel. Therefore, you must keep a
record of the dates on which employees received their initial training and
schedule the annual review.
The training records for current personnel must be kept on file at your
facility until your facility closes. The training records of former employees
must be kept for at least 3 years from their last date of employment at your
facility. If a person is transferred within the same company, their training
records remain the same.
The training records are needed by the Agency in order to judge whether
facility personnel have to appropriate skills called for by their job
descriptions and their specific duties in handling hazardous wastes. Thus,
the more detail used in your training records, the more apparent it will be
that your personnel are receiving the appropriate training.
5.12.3 List of Major Points
1. Has an outline of the training programs been included in the
application?
2. Have both the original and annual training programs been addressed
in the outline?
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• Has &
been included? *S°n trained in
6.
7.
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5.13 TOPOGRAPHIC MAP REQUIREMENTS
In fulfilling requirements set forth for Part B of the RCRA application,
one of the first steps is to make or obtain a topographic map covering the
area in question. Not only can this map serve as a base upon which
information detailed in this section should be placed (legal boundaries,
etc.); it also provides some of the required parameters intrinsically, for
instance, USGS maps show contours, scale, date, etc. The requirements of
§270.14(b)(l9) are delineated here in conjunction with recommended methods for
meeting these requirements. An example of a topographic map for a site is
included to assist in the presentation.
5.13.1 Regulatory Citations
Part B of the permit application must incorporate a topographic map and
associated information to meet the requirements of §260.14(b)(19), which are:
"270.14(b)(19) A topographic map showing a distance of
1000 feet around the facility at a scale of 2.5 centimeters (1 inch)
equal to not more than 61.0 meters (200 feet). Contours must be
shown on the map. The contour interval must be sufficient to
clearly show the pattern of surface water flow in the vicinity of
and from each operational unit of the facility. For example,
contours with an interval of 1.5 meters (5 feet), if relief is
greater than 6.1 meters (20 feet), or an interval of 0.6 meters
(2 feet), if relief is less than 6.1 meters (20 feet). Owners and
operators of HWM facilities located in mountainous areas should use
large contour intervals to adequately show topographic profiles of
facilities. The map shall clearly show the following:
(i) Map scale and date.
(ii) 100-year floodplain area.
(iii) Surface waters including intermittent streams.
(iv) Surrounding land uses (residential, commercial,
agricultural, recreational).
(v) A wind rose (i.e., prevailing wind-speed and direction).
(vi) Orientation of the map (north arrow).
(vii) Legal boundaries of the HWM facility site.
(viii) Access control (fences, gates).
(ix) Injection and withdrawal wells both onsite and offsite.
(x) Buildings; treatment; storage, or disposal operations; or
other structures (recreation areas, runoff control systems, access
and internal roads, storm, sanitary, and process sewerage systems,
loading and unloading areas, fire control facilities, etc.).
(xi) Barriers for drainage or flood control.
(xii) Location of operational units within the HWM facility
site, where hazardous waste is (or will be) treated, stored, or
disposed (include equipment cleanup areas).
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Additional information which must be noted on the topographic map is
specified in the requirements of §270.14(c)(3), as follows:
"On the topographic map required under paragraph (b)(19) of this
section, a delineation of the waste management area, the property
boundary, the proposed "point of compliance" as defined under
1264.95, the proposed location of ground water monitoring wells as
required under §264.97, and, to the extent possible, the information
required in paragraph (c)(2) of this section.", that being ...
"(2) Identification of the uppermost aquifer and aquifers
hydraulically interconnected beneath the facility property,
including ground water flow direction and rate, and the basis for
such identification (i.e., the information obtained from
hydrogeologic investigations of the facility area)."
5.13.2 Obtaining Topographic Maps
The regulations require that the topographic map submitted in Part B of
the application include: 2 feet or 5 feet contour intervals. USGS maps
(7.5 minute quadrangles) generally incorporate 10 feet contour intervals so
that the applicant may generally have to produce a map for his site. Some
USGS maps for flat regions are at 5 feet intervals but will still likely be
insufficient due to the range of elevation (little) incurred in such an area
(with flat areas, the intent is to provide 2 feet contour intervals; with
steep, 5 feet). For this reason, several methods which are applicable in
producing or obtaining the necessary topo maps are discussed here. They
include:
• obtaining a map from local town offices,
• onsite surveying to gather exact elevation information and present
it in map form,
• the use of a photogrammetric company to Ely the site and develop a
map with a specified contour interval,
• the use of a USGS map, where it will allow the permit applicant to
meet the qualifications required.
Often, local town offices, such as the Building Department or Board of
Assessors, have compiled large scale maps which might be helpful in meeting
the topographic map requirements. Such a map could be used as a base map if
the contour intervals are 2 or 5 feet.
If no suitable topographic mapping of the proposed site location exists,
it may be necessary to measure and plot land elevations by conducting a stadia
survey. This technique will provide the information necessary for plotting
any desired contour interval.
Another method which the applicant might choose to meet the topographic
map requirements entails the use of a photogrammetric survey company to fly
the site and produce the map required. Such companies are available
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throughout the U.S. Their abilities include planning and scheduling the
flight to collect data for the map, performing the flight, analyzing the
results, and compiling a final topographic map. in addition, the applicant
could request that this company take the aerial photos needed for fault
location or other geologic information, thus fulfilling several requirements
at once. M
USGS topographic maps are referred to as quadrangle maps. They cover
four-sided areas indexed by geographical latitude and longitude. Quadrangle
size is given in minutes or degrees; most often a 7.5 minute quadrangle will
be desired for RCRA permitting.
The first step in obtaining a topographic map of the site area is to
determine which map(s) are appropriate, i.e. what are the names of the
specific quadrangles covering this area. This may be accomplished in any of
several ways.
1. The USGS may be contacted in Arlington, VA for areas east of the
Mississippi River; Denver, Co. for areas west of the
Mississippi River. They would provide the name over the phone or
send out an index map for the state in question. The permit
applicant could then locate the area on the index map and obtain the
narae(s) of needed quandrangle(s) in this manner.
2. Index map sets may be available from a local college or University.
These could be consulted to determine which quadrangle is desired.
3. Local town offices may be aware of which quadrangle covers their
area (town engineer, planners, etc.).
4. Other nearby institutions or firms that deal with land holdings or
have extensive properties in the area are likely to have USGS
quadrangles for the area.
5. If a geologist is used in any seismic interpretations, this person
could easily obtain the quadrangle in question.
6. Maps may be purchased over-the-counter from local USGS offices, map
distributers, and other suppliers.
A sample order form is included here as Figure 5-6. RCRA requires a
topographic map showing a distance of 1000 feet around the facility. This
requirement will determine how many quadrangles are necessary to include and
order.
5.13.3 Topographic Map Features
The USGS will provide, free on request, a one-page sheet which shows the
topographic map symbols normally found on their maps. These features should
also be noted on maps formed through photogrammetry, compiled by surveying, or
obtained through town offices. Several of these symbols are described below.
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MflUlUaonbrtoi
EASTERN DISTRIBUTION BRANCH
U.S. GEOLOGICAL SURVEY
ISM SOUTH CAM STREET
ARLINGTON. VIRGINIA 33203
MAP ORDER BLANK
DATE:
office uae
00 NOT WRITE
IN THIS SPACE
FROMi NOD*
Street Addnu
Clrr
Suta.
Zip Cod* ,
LIST MAPS ALPHABETICALLY BT MAP NAMES IN STATE CROUPS
Indeiee ad alphabetised order formi ratable lor ill SUM
Quality
Map Not* and SUM OR Map Strict and Number
Seal.
•
Unit Price
PREPAYMENT REQUIRED iu»uune. p.r.bi. to v*. c«>Jo^«i Su~.r [ £??££ ] Toul
Toul Price
for PROMPT. ACCURATE SHIPMENT PLEASE FILL IN THE FOLLOWING LABEL
Placae PRINT or TYHLWRI'I'L
EASTERN DISTRIBUTION BR
UJ. GEOLOGICAL SURVEY
1300 SOUTH BADS STREET
ARLINGTON. VIRGINIA 33309
TO,
Street Addrw
CII7.
State
Zip Code
Figure 5-6. Sample USGS map order form.
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5.13.3.1 Contours—
Contours are imaginary lines following the ground surface at a constant
elevation above or below sea level. Contour lines are normally shown in brown
on USGS topographic maps. USGS maps vary in contour interval; they are either
5 feet, 10 feet, or 20 feet, depending on the relief involved. The contour
interval is reported beneath the scale at the bottom of the map or may be
determined by simple inspection of the map. Contour intervals depend on
ground slope and map scale. Small contour intervals are used for flat areas;
larger contour intervals for mountainous terrain.
The Part 270 regulations require contour intervals of 5 feet with relief
of more than 20 feet; and intervals of 2 feet with relief less than 20 feet.
Relief is the total change in elevation over the area of concern. The site in
question could be mapped using a USGS 5 feet contour map if relief is more
than 20 feet within the site area. Otherwise, USGS maps would not provide
sufficient detail. Regardless of the mapping system used, major contour
intervals should be clearly noted with the applicable land elevation.
5.13.3.2 Scale--
The scale shows the relationship between distance on a map and the
corresponding distance on the ground. The scale of USGS topo maps is provided
at the bottom of the map in the form of a numerical ratio and graphically
using bar scales marked in feet, miles, and kilometers. For example, the
numerical ratio 1:24,000 indicates 1 inch on the map equals 24,000 inches on
the earth; or 1 cm on the map equals 24,000 cm on the earth, etc. Any map
used should clearly indicate scale. The scale must be no smaller than
1 inch • 200 feet (1:2400) to meet RCRA topographic map requirements.
However, for larger HWM facilities, the EPA will allow the use of other scales
on a case-by-case basis.
5.13.3.3 Date—
.The date on which the map was compiled (year of photos used, etc.) should
be inserted on the map where new maps or town maps are used. USGS quadrangles
provide a date (year) in which aerial photographs were taken (from which the
map was compiled) on the bottom left hand corner of the map. In addition, the
date of any field check is provided. The most recent revisions to the map are
normally added in purple, along with the year of any aerial photographs.
Dates are also included in the bottom right hand corner of the map, under the
quadrangle name. USGS attempts to update their maps every five years.
5.13.3,4 Surface Waters-
Surface waters, including intermittent streams, must be shown on the
topographic map supplied in the application. For USGS topographic maps, USGS
symbols should be consulted in determining the various types of surface waters
shown. Perennial streams are normally shown as solid blue lines whose
thickness relates to stream flow (size). Intermittent streams are usually
shown as solid blue lines interrupted by dots at frequent intervals and no
exaggeration of width. These surface water types may be contrasted with
ephemeral streams which consist of a dry channel throughout most of the year,
bearing water only during and after rainfall. Ephemeral streams need not be
shown on the topo site map.
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?!Ernichrp? 8iould also depict ponds and iakes- ™* USGS
(usually blue), dams, large rapids, marshes, waterfalls, etc
5.13.3.5 Land Forms/ Land Use —
Geography Program
Land Information and Analysis Office
USGS - MS 710
Reston, VA 22092
5.13.3.6 Map Orientation—
'4 Obtaining Climatolo^ical Information (Wind Rose)
Wind rose information is available through:
National Climatic Center
Department of Commerce
Federal Building
Ashville, North Carolina 28801
(704) 258-2850
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5.13.5 Flood Plain Area Maps
An indication of the 100-year floodplain area must be included on the
topographic map submitted with your application, as required in
S270.14(b)(l9)(ii). Additional information which you must submit on flooding
is presented in Section 5.11 of this manual.
As a part of the National Flood Insurance Program (NFIP), Flood Hazard
Boundary Maps (FHBM) have been prepared for virtually all (20,238) communities
that have been identified as "flood prone". The FHMB delineates the boundaries
of the 100-year flood plain, although they do not provide elevations. Nearly
90 percent of the Federal Emergency Management Agency (FEMA) maps are of this
type. In addition, some of the communities that have been accepted into the
NFIP have Flood Insurance Rate Maps (FIRM) which delineate the 100-year flood
plain and also provide flood elevations. Where these maps are available,
determination of the 100 year flood plain is straight-forward. Such maps are
most often included as part of a brief Flood Insurance Study for a particular
political jurisdiction along a waterway. The U.S. Department of Housing and
Urban Development, Federal Insurance Administration which publishes such
studies, includes a fold-out map delineating 100-year flood boundaries for
various river reaches in the area covered. An original or clear copy of this
map (or another suitable map) should be included in the permit for all cases
in which sites are located near a river. Hydraulic analyses used to determine
the flood level, community description, and principal flood problems and flood
protection measures are also provided in the flood insurance studies and
should be included in the application.
If a 100-year flood level is not available from another source, the
applicant may have to determine the level using a Flood Hazard Boundary Map.
The applicant should use a qualified hydrologist for such determinations or
may contact the FIA to assist in determining the 100-year flood elevation at
the location in question.
FIA does not usually map flood plains that are less than 200 feet wide.
In such situations, the applicant will have to make a determination of the
extent of the 100-year floodplain. FIA mapping procedures should be used to
make this determination, or the applicant can assume it is 200 feet to be
conservative The applicant might also consult the U.S. Geological Survey (may
have detailed flood-hazard maps of area) the U.S. Army Corps of Engineers, the
U.S. Soil Conservation Service, the Office of Coastal Zone Management, or
others for floodplain information. All data sources should be noted in the
application. In addition, any special flooding factors (e.g. wave action)
which might be considered in designing, constructing, operating, or
maintaining a facility to withstand washout from a 100-year flood should be
included on the map.
5.13.5.1 Site Boundary Maps—
The applicant should include the boundaries of the site land. An
official plot plan from town offices should be obtained and included as part
of this information.
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5.13.6 Other Required Information
Information which should be delineated on the topographic map includes:
• Access control (fences, gates),
• Buildings, treatment, storage, or disposal operation areas and other
structures nearby or onsite,
• Barriers for drainage or flood control,
• Operational HWM facility unit locations.
5.13.6.1 Well Locations—
The applicant should designate existing and proposed onsite and offsite
wells on the submitted topographic map. Well depth and elevation should be
reported for comparison with the submitted cross-section and/or well logs.
Cross-section locations should be clearly delineated on the map.
5.13.6.2 Access Control—
Fences and gates are required for security purposes (see Section 5.4) at
all hazardous waste management sites. These structures should be indicated on
the topographic map submitted.
5.13.6.3 Buildings and Other Structures Nearby or Onsite—
Each existing or proposed building located in the site area should be
depicted on the topo map. This will enable the applicant to provide the
reviewer with an idea of site operations, transportation routes onsite and
offsite, proximity of units to surface waters, relationship to elevation and
geology, etc.
5.13.6.4 Barriers for Drainage or Flood Control—
The applicant should show drainage or flood control measures on the
topographic map where appropriate.
5.13.6.5 Operational Unit Locations—
The topographic map submitted by the applicant should also include the
location of all existing and proposed operational units. Other facility
design features such as run-on/run-off control systems and wind dispersal
control systems should be shown.
5.13.7 List of Major Points
1. Has a topographic map been provided in the application?
2. Does the map have the required scale and contour intervals?
3. Does the map show the area within 1000 feet of the facility?
4. Does the map clearly show the items identified in §270.14(b)(19)(i)
through (xii)?
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5.14 MANIFEST SYSTEM, RECORDKEEPING, AND REPORTING
5.14.1 Regulatory Citations
Subpart E—Manifest System, Recordkeeping, and Reporting, of Part 264, is
not specifically identified in the Part 270 permit information requirements.
Although permit applicants are not required to submit material to demonstrate
compliance with Subpart E with their permit applications, failure to comply
with the Subpart E requirements is a violation of any permit that may be
issued.
The owners and operators of existing and interim status facilities should
be especially cognizant of the Subpart E requirements for two reasons. First,
they should already be complying with these requirements as required by
Subpart E of the interim status regulations in Part 265. Second, the review
of a Part B permit application by the permitting authority is very likely to
include a thorough site inspection of the applicant's facility. During that
inspection, the applicant can expect to be asked to show that his manifesting,
recordkeeping, and reporting procedures do comply with the Part 264, Subpart E
requirements. Applicants who cannot demonstrate a thorough knowledge of those
requirements, or whose procedures are identified as not complying with the
requirements during the inspection, could delay or jeopardize the approval of
their permit application.
Subpart E of Part 264 is reproduced below.
"Subpart E—Manifest System, Recordkeeping, and Reporting
§264.70 Applicability.
The regulations in this Subpart apply to owners and operators
of both on-site and off-site facilities, except as §264.1 provides
otherwise. Sections 264.71, 264.72, and 264.76 do not apply to
owners and operators of on-site facilities that do not receive any
hazardous waste from off-site sources.
§264.71 Use of manifest system.
(a) If a facility receives hazardous waste accompanied by a
manifest, the owner or operator or his agent, must:
(1) Sign and date each copy of the manifest to certify that
the hazardous waste covered by the manifest was received;
(2) Note any significant discrepancies in the manifest (as
defined in §264.72(a)) on each copy of the manifest;
(3) Immediately give the transporter at least one copy of the
signed manifest;
(4) Within 30 days after the delivery, send a copy of the
manifest to the generator; and
(5) Retain at the facility a copy of each manifest for at
least three years from the date of delivery.
(b) If the facility receives, from a rail or water (bulk
shipment) transporter, hazardous waste which is accompanied by a
shipping paper containing all the information required on the
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manifest (excluding the EPA identification numbers, generator's
certification, and signatures), the owner or operator, or his agent
must:
(1) Sign and date each copy of the manifest or shipping paper
(if the manifest has not been received) to certify that the
hazardous waste covered by the manifest or shipping paper was
received;
(2) Note any significant discrepancies (as defined in
§264.72(a)) in the manifest or shipping paper (if the manifest has
not been received) on each copy of the manifest or shipping paper.
(3) Immediately give the rail or water (bulk shipment)
transporter at least one copy of the manifest or shipping paper (if
the manifest has not been received);
(4) Within 30 days after the delivery, send a copy of^the
signed and dated manifest to the generator; however, if the'manifest
has not been received within 30 days after delivery, the owner or
operator, or his agent, must send a copy of the shipping paper
signed and dated to the generator; and
(5) Retain at the facility a copy of the manifest and shipping
paper (if signed in lieu of the manifest at the time of delivery)
for at least three years from the date of delivery.
(c) Whenever a shipment of hazardous waste is initiated from a
facility, the owner or operator of that facility must comply with
the requirements of Part 262 of this chapter.
§264.72 Manifest discrepancies.
(a) Manifest discrepancies are differences between the
quantity or type of hazardous waste designated on the manifest or
shipping paper, and the quantity or type of hazardous waste a
facility actually receives. Significant discrepancies in quantity
are: (1) For bulk waste, variations greater than 10 percent in
weight, and (2) for batch waste, any variation in piece count, such
as a discrepancy of one drum in a truckload. Significant
discrepancies in type are obvious differences which can be
discovered by inspection or waste analysis, such as waste solvent
substituted for waste acid, or toxic constituents not reported on
the manifest or shipping paper.
(b) Upon discovering a significant discrepancy, the owner or
operator must attempt to reconcile the discrepancy with the waste
generator or transporter (e.g., with telephone conversations). If
the discrepancy is not resolved within 15 days after receiving the
waste, the owner or operator must immediately submit to the Regional
Administrator a letter describing the discrepancy and attempts to
reconcile it, and a copy of the manifest or shipping paper at issue.
§264.73 Operating record.
(a) The owner or operator must keep a written operating record
at his facility.
(b) The following information must be recorded as it becomes
available, and maintained in the operating record until closure of
the facility:
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(1) A description and the quantity of each hazardous waste
received, and the method(s) and date(s) of its treatment, storage,
or disposal at the facility as required by Appendix I;
(2) The location of each hazardous waste within the facility
and the quantity at each location. For disposal facilities, the
location and quantity of each hazardous waste must be recorded on a
map or diagram of each cell or disposal area. For all facilities,
this information must include cross-references to specific manifest
document numbers, if the waste was accompanied by a manifest;
(3) Records and results of waste analyses performed as
specified in §§264.13, 264.17, and 264.341;
(4) Summary reports and details of all incidents that require
implementing the contingency plan as specified in §264.56(j);
(5) Records and results of inspections as required by
§264.15(d) (except these data need be kept only three years);
(6) Monitoring, testing, or analytical data where required by
Subpart F and §§264.226, 264.253, 264.254, 264.276, 264.278,
264.280, 264.303, 264.309, and 264.347;
(7) For off-site facilities, notices to generators as
specified in §264.12(b); and
(8) All closure cost estimates under §264.142, and, for
disposal facilities, all post-closure cost estimates under §264.144.
§264.74 Availability, retention, and disposition of records.
(a) All records, including plans, required under this Part
must be furnished upon request, and made available at all reasonable
times for inspection, by any officer, employee, or represenative of
EPA who is duly designated by the Administrator.
(b) The retention period for all records required under this
Part is extended automatically during the course of any unresolved
enforcement action regarding the facility or as requested by the
Administrator.
(c) A copy of records of waste disposal locations and
quantities under §264.73(b)(2) must be submitted to the Regional
Administrator and local land authority upon closure of the facility.
§264.75 Biennial report.
The owner or operator must prepare and submit a single copy of
a biennial report to the Regional Administrator by March 1 of each
even numbered year. The biennial report must be submitted on EPA
form 8700-13B. The report must cover facility activities during the
previous calendar year and must include:
(a) The EPA identification number, name, and address of the
facility;
(b) The calendar year covered by the report;
(c) For off-site facilities, the EPA identification number of
each hazardous waste generator from which the facility received a
hazardous waste during the year; for imported shipments, the report
must give the name and address of the foreign generator;
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(d) A description and the quantity of each hazardous waste the
facility received during the year. For off-site facilities, this
information must be listed by EPA identification number of each
generator;
(e) The method of treatment, storage, or disposal for each
hazardous waste;
(f) [Reserved]
(g) The most recent closure cost estimate under §264.142, and,
for disposal facilities, the most recent post-closure cost estimate
under §264.144; and
(h) The certification signed by the owner or operator of the
facility or his authorized representative.
§264.76 Unmanifested waste report.
If a facility accepts for treatment, storage, or disposal any
hazardous waste from an off-site source without an accompanying
manifest, or without an accompanying shipping paper as described in
§263.20(e)(2) of this Chapter, and if the waste is not excluded from
the manifest requirement by §261.5 of this Chapter, then the owner
or operator must prepare and submit a single copy of a report to the
Regional Administrator within fifteen days after receiving the
waste. The unmanifested waste report must be submitted on EPA form
8700-13B. Such report must be designated 'Unmanifested Waste
Report* and include the following information:
(a) The EPA identification number, name, and address of the
facility;
(b) The date the facility received the waste;
(c) The EPA identification number, name, and address of the
generator and the transporter, if available;
(d) A description and the quantity of each unmanifested
hazardous waste the facility received;
(e) The method of treatment, storage, or disposal for each
hazardous waste;
(f) The certification signed by the owner or operator of the
facility or his authorized representative; and
(g) A brief explanation of why the waste was unmanifested, if
known.
§264.77 Additional reports.
In addition to submitting the biennial reports and unmanifested
waste reports described in §§264.75 and 264.76, the owner or
operator must also report to the Regional Administrator:
(a) Releases, fires, and explosions as specified in §264.56(j);
(b) Facility closures specified in §264.115; and
(c) As otherwise required by Subparts F and K-N.
§264.78-264.89 [Reserved]
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5.14.2 Guidance to Achieve the Part 264 Standards
The purpose of Subpart E of Part 264 is to establish specific handling
procedures for records of waste movement. The requirements in Subpart E are
the heart of the "cradle-to-grave" tracking system that the EPA has
established for movements of hazardous wastes.
The applicability statement in §264.70 indicates that the regulations
apply to all owners and operators of hazardous waste treatment, storage, and
disposal facilities. However, the regulations make a distinction between
facilities used to treat, store, or dispose of wastes generated on the same
property (onsite facilities) and facilities used to treat, store, or dispose
of wastes that were not generated on the facility property (offsite
facilities). Specifically, owners and operators of onsite facilities are not
required to utilize a manifest system if they do not receive any hazardous
waste from offsite sources. However, they are still required to comply with
the manifest system standards contained in Subpart B of Part 262 if they ship
hazardous waste off of their property. The owners and operators of all
facilities, regardless of whether they are onsite or offsite facilities, must
comply with the requirements of §§264.73, 264.74, 264.75, and 264.77.
The requirements for manifest handling with which owners or operators of
hazardous waste treatment, storage, or disposal facilities must comply are
contained in §264.71. Two handling procedures are identified, one for
manifests which accompany hazardous wastes received, and one for shipping
papers accompanying hazardous wastes received from rail or water (bulk
shipment) transporters. The procedures for handling either manifests or
shipping papers are identical. They are:
1. Sign to certify receipt of the waste,
2. Note, on the document, discrepancies between the document and the
wastes received,
3. Immediately give a signed copy to the person delivering the waste,
4. Send a signed copy to the generator within 30 days, and
5. Keep a signed copy on file for 3 years from date of receipt.
Waste analyses do not have to be performed immediately upon receipt to
identify discrepancies. The discrepancies that should be noted on the
manifest or shipping papers are obvious ones that can be immediately
determined by counting or measuring the waste received and comparing the
manifest or shipping papers with labels on the waste.
A description of what a discrepancy is and the actions that must be taken
when a discrepancy is identified either on receipt or during later waste
analyses are presented in §264.72. The description of discrepancies in
quantity presented in §264.72(a) identifies any difference in piece count for
batch waste and greater than a 10 percent difference in quantity for bulk
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wastes as significant discrepancies. However, the receiver of bulk wastes
should use judgment regarding whether or not to adhere to the 10 percent
requirement based on the size of the bulk shipment received. Any difference
between the amount of the bulk shipment stated on the manifest or shipping
papers and the amount actually received should be noted on the documents at
the time of receipt. The receiver should then decide whether or not to take
the actions identified in §264.72(b) based on the quantity of difference and
not the percent of difference for bulk shipments.
In $264.72(b), receivers of hazardous waste are required to attempt to
reconcile significant discrepancies with the generator or transporter within
15 days of receiving a waste. If your permit requires you to analyze incoming
waste, you must still attempt to reconcile differences within the "15 days
from receipt" limit. It is therefore to your advantage to perform any
required analyses as soon as possible after receipt to avoid the reporting
requirement if analysis identifies a discrepancy.
If identified discrepancies in type or quantities of waste received
cannot be reconciled within-15 days of receipt, the receiver must immediately
notify the Regional Administrator. The notification must include a letter
describing the discrepancy and attempts to reconcile it, and include copies of
the subject manifests or shipping papers.
Owners and operators of hazardous waste treatment, storage, or disposal
facilities are required by §264.73(a) to keep a written operating record.
Eight items of information which must be recorded in the operating record are
identified in §264.73(b). They are:
1. Records on wastes received and treated, stored, or disposed;
2. Records on locations of wastes within the facility,
3. Waste analyses results,
4. Records of contingency plan implementation,
5. Inspection records,
6. Ground water monitoring, testing, or analytical data,
7. Notices of permit acquisition and waste acceptance to generators,
8. Closure and post-closure estimates.
All of the information that is required to be entered into the operating
record must be retained until the facility is closed, except for inspection
records which need be kept for only 3 years from the date of inspection.
Appendix I of Part 264, referenced in §264.73(b)(l), contains
recordkeeping instructions for a portion of the operating record.
Specifically, it identifies how to record the information required by
S264.73(b)(l).
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The requirements of §264.74 place stipulations on handling of all records
relative to Part 264. Specifically, they require that you must allow
authorized Agency personnel to inspect the records, that you must retain
records for longer than required by the regulations if you are involved in
enforcement actions or are requested to retain them by the Agency, and that
you must submit copies of the records required by §264.73(b)(2) to the local
land authority and EPA when you close the facility.
Section 264.75 requires that you submit a biennial report of your
activities on a form prescribed by the EPA. The form is identified as EPA
form 8700-13B and copies are available from the EPA offices identified in
Appendix A of this manual. The information which must be supplied in a
biennial report is identified in §264.75(a) through (h). The EPA established
the biennial reporting requirement on January 28, 1983. The first biennial
report is due on March 1, 1984. Note that submission of the first biennial
report is due on that date even if you have not received a permit by that
time. Owners and operators of facilities who have not received permits should
refer to the biennial reporting requirements in Subpart E, §265.75 of
Part 265. Additional information on the biennial report can be found in the
January 28, 1983, Federal Register at page 3977.
The requirements of §264.76 establish procedures which must be followed
if hazardous wastes are received without an accompanying manifest or shipping
paper. Those requirements indicate that an "Unmanifested Waste Report" must
be submitted to the EPA within 15 days of receiving the waste. The EPA has
identified the same form (EPA form 8700-13B) as used for the biennial report
as the form to be used for an Unmanifested Waste Report. The informational
items which must be included on that report form are identified in §264.76(a)
through (g). Additional information on this type of report can be found in
the January 28, 1983, Federal Register at page 3981.
The last section of Subpart E in Part 264, §264.77, identifies additional
reports that must be made to the EPA. They include reports of hazardous waste
releases, fires, explosions, closures, or any other reports that may be
required in Subparts F and K through N of Part 264. Owners and operators of
hazardous waste treatment, storage, or disposal facilities should review those
Subparts to determine if they contain any reporting requirements applicable to
their operations.
5.14.3 List of Major Points
Subpart E of Part 264 does not require the submission of any information
with the Part B permit application. However, the following are questions that
each applicant should bear in mind during preparation and submission of the
Part B:
1. Are you familiar with and do you understand the requirements set
forth in §§264.70 through 264.77?
5-187
-------
2. Have you compared your existing procedures for manifest handling,
recordkeeping, and reporting to the Subpart E requirements and
corrected or instituted procedures that comply with Subpart E
requirements when those procedures were lacking?
3. Are your personnel who are handling manifests or performing
recordkeeping or reporting familiar with the Subpart E
requirements? Have they been trained in the procedures you have
instituted to comply with Subpart E?
4. Have you checked Subparts F and K through N of Part 264 to make sure
that any recordkeeping or reporting necessary in addition to
Subpart E is being conducted?
5. Have you checked Subparts E, F, and K through N of Part 265 to
insure that past activities have complied with any manifest system,
recordkeeping, or reporting requirements contained in those Subparts?
6. If your facility is inspected during the permit application review
process, do you know where the various records are kept so that they
can be promptly located for the inspector's review?
5-188
-------
6.0 COMPLETENESS CHECKLIST
This section contains a checklist of items which must be included in a
RCRA permit application. The checklist separately covers Part A and B for a
land storage, treatment, and disposal permit application.
The checklist is forty-one (41) pages long and addresses more permit
application requirements than are discussed in this manual. However, items
related to the topics presented in this manual (the general information
requirements of 1270.14(b)) can be found on pages 3 through 14 and 21 of the
checklist.
Use of this checklist is not a regulatory requirement. However, its use,
or use of any similar type document, is strongly recommended. By completing
and submitting this type of document, you will have developed both a summary
and a table of contents for your permit application. It will also assist the
reviewing agency and enable a more expeditious review of your application.
Its use will assist you in confirming that you are submitting a complete
application.
Each required information item is briefly stated. Regulatory citations
are provided which enable quick location of the full text of the regulation
that contains each required item (if no citation is indicated next to a
specific item, the last citation indicated above the item contains the
requirement).
Space is provided so that you can indicate whether the item is included
in your application or did not apply. Space is also provided so that you can
record the page number or other indication of where the item can be found in
your application.
The required items are generally listed in the sequence that they are
presented in S§270.13, 270.14, 270.17, 270.18, 270.20, and 270.21 of the
regulations except where presentation of information from a later section is
specifically requested. The one exception is that the additional information
requested in §270.14(c) is listed at the end of the checklist beginning on
page 35.
6-1
-------
Page 1 of 41
EPA I.D. Ho.
Part 270
Part 264
Subject Requirement
Location
Not in
Provided Applicable Application
nt*
270.10(d>
and 270.13
270.13(g)
270.13(g)
270.13U)
270.L3(c)
270.13(a)
270.13(b)
270.13(b)
270.13(b)
270.13(b)
270.13(h)d)
270.13d)
270.13(1)
270.13(h)(2)
270.13(e)
270.13(d)
Part A Requirements
Statement that facility is new or existing
Statement that application is first or revised
Description of business conducted
SIC Codes
Description of activities requiring permit
Facility: Name
Hailing Address
Location
Latitude and Longitude
Scale drawing (existing facility only)
Sufficient detail
Topographic Hap
Sufficient detail
Other map
Sufficient detail
Photographs (existing facilities only)
Sufficient detail
Owner. Name
Address
Telephone
Operator Name
Address
Telephone
-------
Page 2 of
270.13(l)
270.11(d)
270.11(a)
Identification of facility ownership status
and status as Federal, State, private,
public, or other entity
Statement that facility is or is not on
Indian lands
Listing of all peraits and construction
approvals received/applied for
List of 40 CFR 261 wastes and annual aoounts
to be handled
Description of all processes to be used to
handle wastes and design capacity of each
process
Part A Certification and Signatories
Certification paragraph
Appropriate signatory
-------
Page 3 of 41
EM 1.0. Bo.
Part 270
Part 2M
Subject Requirement
Location
Hat in
Provided Applicable Application
oti
270.14
270.14(b)(l)
270.14(b)(2) 264.13(a)
270.14(b)(3)
264.13(b)
270.14(b)(4)
264.13(b)(6)
and
264.17(c)
264.13(c)
264.l4(a)
Part B General Information Requirements
General description of the facility
Ctaeaiical and phyaical analysis of hazardous
wastes to be handled
Waste analysis plan
Analysis parameters with rationale
Test methods for analysing parameters
- Procedure for collecting representative
samples
Frequency of analyses
List and description of waste analyses to
be generator supplied
Waste analysis procedures for ignitable,
reactive, incompatible wastes
- Procedures to determine identity of
each waste movement
~ Procedures for collecting represen-
tative samples
Security description for active portion of
facility
Security procedurea waiver justification
Unknowing/unauthorized contact with
waste not harmful
Unknowing/unauthorized disturbance of
waste or equipment cannot cause
violation of Part 264
-------
Page 4 of 41
EPA 1.0. Ho.
Part 270 Part 264
Subject Requirement
Location
Hot
Provided Applicable Application
270.14(b)(4) 264.14(b)
264.14(c)
270.14(b>(5)
264.1S(b)(l)
264.1S(b)(2)
and
265.15(d)
264.15(b)U)
2 64.1Mb) (3)
264.15(b)(4)
264.15
-------
Page i of 41
EPA 1.0. Mo.
Part 270
Part 264 Subject Requirement
Location
Hot in
Provided Applicable Application
Cmmstots
270.U(b)(S) 264.1S(a>
and and
270.17(d) 264.226
270.14(b)(5> 264.15(a)
and and
270.18(e) 264.254
Inspections weekly and after storms
for
Operation of overtopping controls
Sudden drop in impoundment liquid
level
Presence of liquid in leak detec-
tion system
Integrity of dikes/contaimaent
devices
Statement from qualified engineer
that structural integrity of
dikes will be certified upon
construction completion
Qualified engineer's certifi-
cation of dike integrity for
Stress
Piping/scouring
Specific Inspection Requirements for Waste
Piles
Description of procedures for
Inspection of liners/covers during
and immediately after installation
Inspections weekly and after storms
for
Operation of run-on/run-off
controls
Liquids in leak detection system
Proper functioning of wind
dispersal controls
Leachate in and proper operation
of leachate collection/removal
system
-------
Page 6 of 41
EM I.D. Bo.
Part 270
Part 264
Subject Requirement
Provided
Not
Applicable
Location
in
Application
270.l4(b)(5) 2M.15(a)
and and
270.20(c)(S) 264.273(g)
270.14(b)(5) 264.1SU)
and and
270.21(d) 264.303
270.14(b)(6) Part 264
Subpart C
264.32(a)
264.34(a)
264.32(b)
264.34(b)
Specific Inspection Requirement! for Land
Treatment Units
Description of procedures for units inspec-
tions weekly and after storms for
Operation of run-on/run-off controls
Function of wind dispersal controls
Specific Inspection Requirements for Landfills
Description of procedures for
Inspection of liners/covers during
and mediately after installation
Inspections weekly and after storms
for
Operation of run-on/run-off
controls
Liquids in leak detection system
Proper functioning of wind
dispersal controls
Leachate in and proper operation
of leachste collection/removal
system
Preparedness and Prevention Documentation
Uaiver(s) request and justification
Description of internal conmunications/
alarm system(s)
Documentation of personnel access to
internal communication/alarm system(s)
Description of external communications/
alarm syatem(s)
Documentation of personnel access to
external coonunications/alarm system(s)
-------
Page 7 of 41
EPA l.D. No.
Part 270
Part 264 Subject Requirement
Provided
•ot
Applicable
Location
in
Application
270.l4(b)(6) 264.32(c)
2M.32(d)
264.33
264.35
264.37 (also
264.S2(c»
264.37(>)(2)
270.14(b)(7) Part 264
SubparC D
264.31 and
264.52(a)
264.32U)
— Deacription of fire control/
extinguishing, spill control, and
decontamination equipment
- Documentation of adequate vater volume and
pressure for above equipment
Documentation of equipment testing/
maintenance schedule and procedures
Documentation of adequate isle space
Documentation and descriptions of
arrangements or attempts at arrangements
with;
Police department(s)
Fire departmentd)
Hospitals
Local emergency response teams
State emergency response teams
Emergency response contractors
~ Equipment suppliers
Documentation of agreements designating
primary emergency authority
Contingency Plan Documentation
Criteria for implementation of
contingency plan
Emergency Coordinators Identification
Names
Addresses
-------
Page 8 of 41
EM I.D. No.
Part 170 Part 264
Subject Requirement
Location
Hot in
Provided Applicable Application
270.14(b>(7)
264.55
264.52(e)
264.52U)
264.53
264.54
Have/Work Phonea
Documentation of Qualification*
Documentation of Authority
Description oC notification
procedure
Emergency equipment list
Documentation of equipment location
Physical description of equipment
Statement of equipment capabilities
Evacuation Plan
Criteria for implementation
Description of signal(s) to implement
Description of primary and alternate
routes
Contingency Plan Copy Location
Description of location of facility's
copy of plan
Number of duplicate copies distributed
and their location
Contingency Plan Amendment
Identification of person responsible
and authorized to change/amend plan
Description of procedure to change/
amend facility copy of plan
Description of procedure to insure
update of all copies of plan
-------
Page 9 of 41
EM I.D. Bo.
Part 110
Part 26* Object »equire«nt
Pro.lded
Location
AppUc.tio,
Co-ent.
270.U(b)(7) 264. 56
270.U(b)(7) 264.227
and
270.17U)
- Detailed Emergency Procedures
Procedure for facility perionnel
notification
Procedure for state/local agency
notification
procedure for identification of
character, source, amount, and
a real extent of released Materials
Procedure for assessment of
environment /hunan health hazards
Identification of On-Scene Coordinator
for geographic area
Description of specific responses and
control procedures for
Fire
Explosion
Spill
Description of process shutdown and
monitoring procedures
Description of cleanup procedures and
associated material treating, storing,
disposal procedures
Description of emergency equipment
cleaning and refitting procedures
Description of procedures to insure
incompatible waste segregation during
cleanup
Specific Contingency Plan Requirements for
Surface Impoundments
Procedure for stopping waste addition to
impoundment
-------
Page 10 of 41
EPA I.D. lo.
Part 270
Part 264
Subject Bequirenent
Provided
264.227
Procedure for containing leakage
Procedure to prevent catastrophic failure
Procedure for emptying impoundment
Procedure for recertifying and reactivating
impoundment
Procedure for closing impoundment
IHote: There are no 1122.25 requirement, which parallel Part 264, Subpart K.
However, the applicant should be familiar with the following sections
of the regulations since the requirements in them will be enforceable
under any permit received.
Part 264, Subpart E, {264.70 through 1264.77
Part 270. Subpart C, 1270.30(j) and 1270.30(1)
The applicant should be prepared to respond to inquiries by the permit
application reviewers regarding these requirements)
270.14(b)(B)
Hot
Applicable
270.14(b)(9) 264.17
Preventive Procedures, Structures, and Equipment
Documentation, including descriptions of
equipment/procedures to
Prevent hasarda during unloading operations
Prevent run-off and flooding
Prevent water supply contamination
Mitigate equipment failure and power outages
Prevent undue personnel exposure to wastes
Prevention of Accidental Ignition or Reaction
Documentation
Description of separation and protection
of ignitable, reactive, incompatible wastes
Description of ignitable, reactive,
incompatible wastes handling procedures
Description of number, location, and type
of warning/prohibition signs
-------
Page II of 41
EPA 1.0. No.
Part 270
Part 2M Subject Requirement
Location
•ot in
Provided Applicable Application
nti
270.14(b)(9) 264.l7(b)
and 270.17(h)
and 270.17U)
264.229
264.230
270.14(b)(9) 264.17(6)
and 270.18(g)
and 270.18(h>
264.256
264.257
270.14(b)(9) 264.17(b)
and 270.20(g)
and 270.20(h)
264.281
Documentation that procedures are adequate
to prevent accidental ignitions or reactions
Description of number, location, and type
of varning/prohibition signs
Documentation that procedures are adequate
to prevent accidental ignitions or reactions
Specific Ignitable/Reactive Waste Requirements
for Surface Impoundments
Procedures that render waste non re active
or uonignitable
- Procedures for preventing reactions
Procedures for protecting wastes
"Emergency use only" documentation
Incompatible waste segregation or
protection procedures
Specific Ignitable/Reactive Waste Requirements
for Waste Piles
Procedures that render waste nonreactive
or nonignitable
Procedures for preventing reactions
Procedures for protecting wastes
Incompatible waste segregation or protection
procedures
Specific Ignitable/Reactive Waste Requirements
for Land Treatment Facilities
Documentation that application to soil
renders waste nonreactive/nonignitable
and preventa reactions
Procedures for protecting wastes
-------
Page 12 of 41
EPA 1.0. Ho.
Part 270
Part 264 Subject Requirement
264.282
270.14(b)(9) 264.17(6)
and 270.21(1)
and 270.21(g)
264.312
264.313
264.316
(c)-(e)
270.14(b)(10)
270.14(b)Ul)
270.14
-------
Page 13 of 41
EPA I.D. Ho.
Location
Not in
Part 270 Part 264 Subject Requirement Provided Applicable Application
Demonstration that fault* with
displacement in Holoceoe lime are •ore
than 3000 feet from facility
264.18(a) - Demonstration that no faults pass within 200
feet of sites where T/S/D to be conducted
270.14(b)(ll) 264.18(b) - Documentation of facility location
(iii)-(iv) relative to 100-year flood plain level
or nave action flooding
Documentation that facility can withstand
the 100-year flood without washout of
hazardous waste by:
Analysis of hydrodynanic/hydrostatic
forces resulting at site from 100-year
flood, and
Presentation of operating units and flood
protection devices design and how they
will prevent washout, or
Plan for removal of waste before washout
including.
Timing of removal relative to flood
levels
Estimated time to remove all waste
location to which waste will be moved
and proof of compliance with Parts 122
through 124 and 266 through 267 oC
this Chapter
Detailed description of personnel,
equipment, and procedures for waste
removal sufficient to insure
availability in time for use
Analysis of potential for discharge
during waste movement
-------
Page 14 of 41
EPA I.D. No.
Part 270 Part 264
Subject Requirement
Provided
Hot
Applicable
Location
in
Application
270.14(b>
270.14(b)(12) 264.16
270.14(b)(13) 264.112
264.114
254.113
A plan documenting how and on what time
schedule the facility will comply with
1264.18(b) if not in compliance
(existing facilities only).
Personnel Training Program Documentation
Outline of introductory and continuing
personnel training programs
Identification and qualifications of program
instructor
Brief description of how training program
meets actual job tasks
Description of procedures to insure all
appropriate personnel receive appropriate
training and receive annual training
review
Description of records to be kept, their
location, and procedures to insure they
are retained for proper length of time
Closure Plan Documentation
Description of partial and final closure
procedures
Description of maximum unclosed portion
during facility life
Estimate of maximum waste inventory in
storage/treatment during facility life
Equipment decontamination procedure
Estimated year of closure
Description of closure schedule including
Total time to close
-------
Page IS of 41
EPA I.D. Bo.
P«rt 270
Part 264
Subject Requirement
Provided
Hot
Applicable
Local ion
in
Application
270.14(b)(13> 254.113
270.14(b) 264.112 and
(13) and 264.228(a)
270.17(g)
Traekable intervening closure
activities
Locationd) and number of copies of
closure plan
Identification of person responsible for
storage and updating of facility copy of
closure plan
Procedure for updating all other copies of
closure plan
Specific Closure Plan Requirements for
Surface Impoundments
Procedures for removal and/or decontamina-
tion of all wastes and materials/equipment
associated with the impoundment, or
Detailed plans and engineering reports
describing
Elimination of free liquids
Stabilization of remaining wastes
Design of final cover demonstrating
Liquid migration minimization
Function with minimum maintenance
Drainage promotion
Erosion/abrasion minimization
Settling/subsidence accomodation
Permeability less than liner or
subsoils
-------
Page 16 of 41
KPA l.D. Ho.
Part 270
Part 264
Subject Requi
Provided
Location
Not in
Applicable application
270. U(b)
(13) and
270.18U)
270.14(b)
(13) and
270.20U)
270.14(b)
(13) and
270.21(e)
264.112
264.2S8(a)
264.2S8(b)
264.112
264.280(a)
264.112 and
264.310(a)
Specific Closure Plan Requirements for Waste
Piles
Procedure for removal and/or decontamination
of all wastes and materials/equipment
associated with the waste pile
Procedure for closing in conformance with
landfill closing requirements
Specific Closure Plan Requirements for Land
Treatment Facilities
Procedures to maximize degradation of waste
in treatment zone
Procedures to minimize waste run-off
- Run-off system maintenance procedures
Wind dispersal control procedures
Procedures for compliance with food-chain
crop growth
Procedures for unsaturated zone monitoring
Description of vegetative cover
Procedures for establishing vegetative cover
Specific Closure Plan Requirements for
Landfills
Detailed plans and an engineering report
which describes the final cover components
in detail
Documentation that the final cover will
Provide long-term minimization of
migration of liquids through closed
landfill
-------
Page 11 of 41
EPA I.D. Ho.
P«rt 270
Part 264
Subject Requirement
Hoc
Provided Applicable
Location
in
Application
ots
270.U(b)
(13)
264.117 and
264.118
270.14(b) 264.118 and
(13) and 264.228(b)
270.17(g)
Function with minimum maintenance
Pronote drainage and minimise
eroalon/abrasion
Settle/subside without losing
integrity
Be lesa pemeable than bottom liners
or subsoils
Post-Closure Plan Documentation
Description of ground water monitoring
Activities and frequencies
Description of maintenance activities and
frequencies for,
Pinal containment structures
Facility monitoring equipment
Location(s) and number of copies of post-
closure plan
Identification and location (address and
phone number) of person responsible for
storage and updating of facility copy of
post-closure plan prior to closure
Identification and location (address and
phone number) of person responsible for
storage and updating facility copy of
post-closure plan during post-closure
period
Procedure for updating all other copies of
post-closure plan
Specific Post-Closure Plan Requirements for
Surface Impoundments
Procedures for maintenance and repair of
final cover
-------
Page 18 of «l
EPA I.D. No.
Part 270
Part 264
Subject Requi
Provided
Not
Applicable
location
10
Application
270.1Mb)
(13) and
270.18(1)
270.l4(b>
(13) and
270.20(0
270.14(b)
(13) and
270.2l(e)
Procedures for maintenance and nooitoring
of leak detection system
Procedures for maintenance and monitoring
of ground water monitoring system
Procedures for compliance with Subpart F
Procedures for preventing run-on/run-off
final cover damage
264.118 and - Specific Post-Closure Plan Requirements for
264.2*8(b) Haste Pilea
- Procedures for post-closure care that meet
the requirements for landfills
264.118 and - Specific Post-Closure Plan Requirements for
264.280(c) Land Treatment Facilities
Procedures to enhance degradation of wastes
in treatment zone
Procedure for maintaining vegetative cover
Procedure for maintaining run-on controls
Procedure for maintaining run-off controls
Procedures for wind dispersal control
Procedures to insure compliance with food-
chain crop prohibitions
Procedures for unsaturated zone monitoring
264.118 and - Specific Post-Closure Plan Requirements for
264.310(b) Landfills
Procedures for maintenance and repair of
final cover
Monitoring and maintenance procedures for
leak detection system
-------
Page 19 of 41
EPA I.D. No.
Part 270
Part 264
Subject Requirement
Location
Hot in
Provided Applicable application
270.l4(b)
(14)
270. 14(b)
(IS)
264.310U)
266.120
264.119
264.142
264.143 and
264.146
264.151U)
264.1Sl(b)
2 64.151 (c>
264.151(d)
264.1Sl(e)
264.1S1({)
and (h)
Procedure for leachate collection/removal
system operation
Procedures to Maintain and monitor ground
water monitoring system
Procedures for compliance with Subpart F
Procedures for preventing final cap erosion
due to run-on and run-off
Procedures for protection and maintenance
of benchmarks
Procedures to be undertaken if liquid is
found in leak detection system
Documentation of Notice on Deed (existing
facilities only)
Statement that land used to manage wastes
Statement of restricted use per 1284.U7(c)
Documentation of type, location, and
quantity of wastes filed with local
authority and EPA Regional Administrator
Closure Cost Estimate
Documentation of a financial assurance
mechanism for closure that is*
Closure trust fund
Surety bond guaranteeing payment
Surety bond guaranteeing performance
Closure letter of credit
Closure insurance
Financial test and corporate guarantee
-------
Page 20 of 4
EPA I.D. Ho.
Part 270
Part 264 Subject Requirement
Provided
Bot
Applicable
Location
in
Application
270.14(6)
(16)
270.14(b)
(17)
264.144
264.14S and
264.146
264.lSl(a)
264.151
-------
Page 21 of 41
EPA l.D. Ho.
Part 270
Part 264
Subject Requirement
Provided
Location
Mot in
Applicable Application
270.14(b) 264.149
(18)
264.150
270.14(b)
(19)
Documentation of a State Required Financial
Mechanism for Closure, Post-Closure, or
Liability including
EPA l.D. number
Facility name
Facility address
~ Amounts of liability coverage or funds
assured
Documentation of State Assumed Responsibility
for Closure Post-Closure or Liability including
Letter from State describing State's
responsibilities
Facility EPA l.D. number
Facility name
Facility address
Amounts of liability coverage or funds
assured
Topographic map showing a distance of 1000
feet around facility at a scale of not more
than 1 inch equals 200 feet that clearly shows
Contours
Proper contour intervals
Hap scale and date
100-year flood plain area
Surface waters and intermittent streams
Surrounding land uses
-------
Page 22 of 4
EPA I.D. No.
Part 270
Part 264
Subject Requirement:
Provided
Hot
Applicable
location
in
Application
270.1Mb)
(19)
270.17
270.17(a)
270.17(b)
264.221
270.17(b)(i) 264.221(a)
264.221(a)(l)
Wind rose
North orientation
Legal boundaries of facility site
Access control
Injection and withdrawal wells onsite and
offsite
Buildings and recreation areas
Runoff control systems
Access and internal roads
Storm, sanitary, and process sewerage
systems
Loading and unloading areas
Fire control facilities
Barriers for drainage or flood control
Location of past or present operational
units and equipment cleanup areas
Specific Part B Information Requirements for Surface
Impoundments
List of hazardous wastes placed or
to be placed in impoundment
Detailed plans and an engineering report
describing
Liner system construction (new only)
Material of construction
Chemical properties
-------
Page 23 of 41
EPA l.D. Ho.
Part 270
Part 264 Subject Requirement
Location
Nut in
Provided Applicable Application
270.17(b)(l)
264.221(a)(2)
264.22l(a)(3>
264.221(a)(l)
264.22Kb)
270.17(b)(2) 264.22l(c)
Physical strength
Thickness
Foundation design/integrity
Area covered
Liner aysten integrity against (new
only)
Internal and external pressure
gradients
Contact with waste/leachate
Climatic conditions
Installation stresses
Daily operational stresses
Liner system exemption including
Nature and quantity of wastes
Alternative design and operation
Impoundment location description
Hydrogeologic setting
Attenuative capacity of
materials between impoundment
and groundwater and surface
water
Documentation of no migration to
ground/surface waters at any
future time
Procedures/equipment to prevent
overtopping from
Normal operation
-------
Page 24 of -»l
EPA I.D. No.
Part 270
Part 264
Subject Requirement
Provided
Not
Applicaole
Location
in
Application
270.17(b)(2) 264.221(c)
270.17(b>(3> 264.221(d>
270.l7(c) 264.222(a)
270.18
270.18(a)
270.18(b) 264.2SO(c)
Abnormal operation
Overfilling
Wind/wave action
Rainfall
Run-on
- Equipment malfunctions
Human error
Structural integrity of dikes
Documentation for Part 264, Subpart F
exemption including,
Impoundment and liner location above
seasonal highwater table
Two liners meeting 1264. 221(a)
requirements
Leak detection system between liners
Specific Part B Information Requirements for
Waste Piles
List of hazardous wastes placed or to be
placed in each waste pile
Documentation of general exemption from
1264.251 and Part 264, Subpart F, including,
Waste pile protection from precipitation
Procedures for insuring liquids are
not placed in pile
Description of run-on controls
-------
Page 25 of M
EPA I.D. Ho.
Part 270
Part 2M Subject Requi
Provided
Not
Applicable
Location
io
Application
270.l8(c) 2M.251(a)
270.18(c)(l) 2M.2Sl(a)(l)
264.221(a)
264.251(a)(2>
Description of mod dispersal controls
other than wetting
Decomposition/reactions do not cause
leachate generation
Detailed plans and an engineering report
describing.
Liner system construction (new only)
Material of construction
Chemical properties
- Physical strength
Thickness
Foundation design/integrity
Area covered
Liner system integrity against (new
only)
Internal and external pressure
gradients
Contact with waste/leachate
Climatic conditions
Installation stresses
Daily operational stresses
Leachate collection and removal system
to maintain less than one foot of
leachate on liner including.
Materials of construction
-------
Page 26 of 41
EPA I.D. Ho.
Part 270
Part 264
Subject Requirement
Provided
Not
Applicable
Location
ID
Application
270.18(c)(l>
264.25Kb)
270.1BUH2) 264.251(c>
270.18(c)(3) 264.251(d)
270.18(c)U) 264.231(e>
270.l8(c)(5) 2M.251U)
270.18(d) 264.252(a)
Chemical resistance to waste/
leachate
Strength sufficient to prevent
collapse
Provisions to prevent clogging
Liner systen/leachate system exemption
including.
Nature and quantity of wastes
Alternative design and operation
Pile location description
Hydrogeologic setting
Attenuative capacity of
materials between pile,
ground and surface waters
Documentation of no migration to
ground/surface waters at any
future time
System for control of run-on from
peak discharge of a 25-year storm
System for control of run-off water
volume of a 24-hour, 23-year storm
Procedures to manage collection and
holding facilities associated with
run-on and run-off control systems
Wind dispersal control procedures
Documentation for Part 264, Subpart F
exemption including.
Pile and liners above seasonal high
water table
-------
Page 27 of il
EPA I.D. Mo.
Part 270 Part 264
Subject Requirement
Location
Not in
Provided Applicable Application
ols
270.18(d)
264.253(b)
270.l8(f)
270.20
270.20(a)
Two liners meeting requirements of
i264.2Sl(a)(l>
Leak detection system between liners
Leachate system meeting »264.251(a)(2)
requirements
Documentation for Part 264, Subpart F
exemption including,
Pile and liners above seasonal high
water table
Liner meets 1264.2Sl(a)(l) requirements
Soil characteristics/depths
Leachate system meets 1264.2Sl(a)(2)
requirements
Schedule/procedures for liner
inspection by waste removal
Sufficient liner strength/thickness
to allow periodic removal/replacement
of wastes
Description of treatment carried out in
or on the pile including,
Details of treatment process
Equipment used
Nature and quality of residuals
Specific Part B Information Requirements for
Land Treatment Facilities
Description of treatment demonstration
plans by
264.272(6)
Field test
-------
Page 28 of 41
EPA I.D. Mo.
Part 270
Pare 2M
Subject Requirement
Provided
Hot
Applicable
Location
in
Application
270.20U)
2M.272(c)
Laboratory analysis
Available data
Operating data (existing units only)
Subnittal for laboratory analyses or field
test demonstration permit including,
Documentation of accurate simulation
Wastes and hazardous constituents
descriptions (Part 261, Appendix
VIII)
Climatologic information
Topographical data
Operating practices
Type of test to be conducted
Test materials and methods
Expected completion time
Statement on appropriateness of
demonstration
~ Statement on human health and environ-
ment protection considering.
Characteristics of wastes to be
tested
Operating and monitoring during
tests
Duration of test
Volume of waste used in test
-------
Page 29 of 41
EPA 1.0. No.
Part 270
Part 264 Subject Requirement
Hot
Provided Applicable
Location
in
Application
270.20(b)
264.27l(a>
270.2(Xb)(2) 264.273(a)
(i)
270.20(b)(3) 264.278
(a)-(f)
Potential for hazardous waste
migration to ground/surface waters
(field tests only)
Description of land treatment program
Wastes to be land treated
Design measures to maximize treatment
including.
Rate and method of waste
application
Soil pH control measures
Nicrobial/chemical reaction
enhancements
Treatment zone moisture control
measures
Unsaturated zone monitoring proce-
dures including,
List of and rational for selecting
compounds to be monitored
- Monitoring equipment, procedures,
frequency
Procedures for selecting sampling
locations
Sample collection procedures
- Sample preservation/shipment
procedures
Sample chain of custody control
- Sample analysis procedures
-------
Pa«e 30 of 41
EPA I.D. No.
Part 270
Part 264
Subject Requirement
Provided
Not
Applicable
Locat ion
in
Application
CooMots
270.20(b)U)
Background value determination
procedures
Statistical methods description
List of hazardous constituents
expected to be in, or derived from,
wastes to be land treated
270.20(b)(5) 264.271(c)
270.20(c) 264.273
(b)-(f)
270.20(d) 264.276(a)
The proposed vertical and horizon-
tal dimensions of the treatment cone
with maximum depth of
No more than 5 feet from the
initial soil surface
More than 3 feet above the
seasonal high water table
Description of land treatment unit
design
Procedures/equipment to prevent
run-on from peak discharge of 23-year
storm
Procedures/equipment to collect and
control the run-off water volume from
a 24-hour, 25-year storo
Procedures/equipment to minimize
run-off from treatment zone during
active life
Run-on and run-off collection and
control systems management plan
Procedures/equipment for wind disper-
sal control
Documentation of request for growth of
food-chain crops on treatment zone not
receiving cadmium in wastes
-------
Page 11 of 41
EM 1.0. No.
Part 270
Part 264
Subjecc Requirement
Provided
Not
Applicable
location
tn
Application
270.20(d)
264.276U)
Statement that demonstration of no risk to
hunan health will be conducted by,
Field tescs
Greenhouse studies
Available data
Operating data (existing only)
Demonstration program description,
including
Soil pH
Cation exchange capacity of soil
Specific wastes to be applied
Waste application rates
Waste application methods
Identification of demonstration crops
Planting and growth procedures
Characteristics of crop
Sample selection criteria
Sample collection procedure
Sample size
Analyses methods
Statistical data evaluation
procedures
Identification of comparison crops
Characteristics of crop
-------
Page 32 of 41
EPA I.D. No.
Part 270
Part 264
Subject Requirement
Provided
Not
Applicable
Location
in
Application
270.20(d>
264.276
270.21
270.21(a)
Planting and growth procedures
Conditions of growth
Sample selection criteria
Sample collection procedures
Sample size
Analyses methods
Statistical data evaluation
procedures
Request for a permit to conduct demon-
stration program
Documentation of request for growth of
food-chain crops on treatment zone if
wastes contain cadmium
Cadmium concentration in waste
Soil pH
- Annual application of cadmium in
kilograms per hectane
Soil cation exchange capacity
Identification of animal feeds to be
grown
Plan to prevent animal feed ingest ion
by humans
Docunentat ion of notice on deed
Specific Part B Information Requirements for
Landfills
List of hazardous wastes to be placed in
each landfill cell
-------
Page 33 of 41
EPA I.D. No.
Part 270 Part 264 Subject Requirement
270.21(b) 264.301(a)
270.21(b)(I) 274.301(a)(l)
Provided
Not
Applicable
Local ioo
in
Application
Coonentc
264.301(a)(2)
Liner system construction (new only)
Material of construction
Chemical properties
Physical strength
Thickness
Foundation design/integrity
Area covered
Liner system integrity against (new
only)
Internal and external pressure
gradients
Contact with waste/leachate
Climatic conditions
Daily operational stresses
Leachate collection and removal systen
to maintain less than one foot of
leachate on liner including,
Materials of construction
Chemical resistance to waste/
leachate
Sufficient strength to prevent
collapse
-------
Page M of 41
EPA I.D. No.
Part 270
Part 264
Subject Requirement
Provided
Location
Hot in
Applicable Application
Comments
270.21(b)(l)
264. 301(b)
270.21(b)(2) 274.301(c>
270.21(b)(3) 274.301(d)
270.2l(b)(4) 274.301(e)
270.21(b)(5) 274. 301 (O
270.21(c) 264.302(a)
Provisions to prevent clogging
Liner system/leachate system exemption
including.
Nature and quantity of wastes
Alternative design and operation
Landfill location description
Hydrogeologic setting
Attenuative capacity of
materials between landfill
and ground and surface waters
Documentation of no migration to
ground/surface waters at any
future time
System for control of run-on from
peak discharge of a 25-year storm
System for control of run-off water
volume from a 24-hour, 25-year storm
Procedures to manage collection and
holding facilities associated with
run-on and run-off control systems
Wind dispersal control procedures
Documentation for Part 264, Subpart F
exemption including,
Landfill and liners above seasonal
high water table
Two liners meeting requirements of
I264.30l(a)(l)
-------
Page 35 ot «1
tPA l.D. ho.
Part 270
Part 264
Subject Requirement
Provided
Location
Not in
Applicable Application
Coooents
270.2Kb) 264.314
270.21(i) 264.315
270.14(c) Part 264
Subpart F
270.l4(c)(l)
270.14(c)(2)
270.14(c)(3)
and
270.14(b)(19)
264.9S(b)
264.95U)
270.14(c)(4)
Leak detection system between liners
Leachate system meeting $264.301(a)(2)
requirements
Documentation of procedures/equipment (or
landfilling liquid wastes
Documentation of procedures/equipment for
landfilling containers
Part B Protection of Ground Water Information Require-
ments for Surface Impoundments, Waste Piles, Land
Treatment Units, and Landfills
Interim status period ground-water monitoring
data summary
Identification of uppermost and hydraulically
interconnected aquifers under facility including.
Water flow rate and direction
Bases for identification
Topographic map
Delineation of property boundary
Delineation of waste management area
Delineation of proposed pome of
compliance
Ground-water monitoring well locations
Location of aquifers
Descriptions of existing contamination
Delineation of plume extent
-------
Page 36 of 41
EPA l.D. Ho.
Part 270
Part 266
Subject Requireaent
Provided
Not
Applicable
location
in
Application
nts
270.14(c)(S) 264.97
2M.97(a)
2M.97(c)
264.97(d)
264.97(e)
264.97U)
270.14(c>(6) 264.91(a)(4)
and 264.98
Appendix VIII constituents concentrations
Concentrations throughout plume
- Maxima concentrations in plune
Detailed plans and an engineering report of
Ground Water Monitoring Program
Descripton of welts
Number of wells
Locations
Depths
Assurance of unaffected background
water measurement
Assurance of compliance point ground
water measurement
Casing description
Description of sampling/analysis procedures
Sample collection methods
Sample preservation/shipment
Analytical procedures
Chain of custody control
Documentation of proper/adequate analytical
procedures
Procedure for determination of ground
water elevation with each sample
Description of Detection Monitoring Program
including,
-------
Page 37 of 41
EPA I.D. Ho.
Part 270
Part 264 Subject Requirement
Location
Not in
Provided Applicable Application
270.l4(c)(6) 264.93 and
U) 264.98(a>
270.14(c)(6) 264.98UH4)
(111) and
264.98(c)(l)
264.98UM3)
264.97(g)(l)
264.97(g)(3)
264.97(g)(4)
270.14(c)<6) 264.98(b)
(ii)
270.14(c)<6) 264.98(d)
(iv)
last of indicator parameters, waste
constituents, reaction products to be
monitored for, including
Type, quantities, concentrations
expected in wastes
Mobility, stability, persistence in
unsaturated zone
Detectability in ground-water
Background ground-water concen-
tration values and coefficients
of variation established by
Use o£ an appropriate ground
water monitoring system, and
Quarterly sampling of upgradient
wells for one year, or
Quarterly sampling of other wells
for one year, and
Data from a minimus of one sample/
well and minimum of four samples
per quarter, or
Presentation of procedures to
calculate such values
Description of an appropriate
ground-water monitoring system to be
installed at the compliance point
Procedures for collecting semi-
annual ground-water samples at the
compliance point during
Active life
Closure period
-------
Page 33 of 41
EPA I.D. No.
Part 270
Pare 2M
Subject Requirement
Provided
Not
Applicable
Location
in
Application
Cooaents
264.98(e)
2M.98(f> &
264.97(d)«(e)
2M.98(g)
270.16(c)(6) 264.98(h)
264.98(h)(l)
2M.98(h)(2)
264.98(h)(3)
264.98(h)(4J
Post-closure period
Procedure for annual detemination of
uppermost aquifer flow rate and
d irect ion
Documentation of sample collection
and analysis procedures
Procedure for determining a statisti-
cally significant increase for any
monitored parameter or constituent by
Comparing compliance point data
to background value data using
the procedures in f264.97(h)( 1)
or (2), and
Providing an estimate of the time
period after sampling completion
necessary to obtain results
Procedure to be implemented if a
statistically significant increase in
any constituent or parameter is
identified at any compliance point
monitoring well, including
Written notification to Regional
Administrator
Sample collection and analysis
methods for all Appendix VIII
constituents at all monitoring
wells
Method for establishing Appendix
VIII constituent background values
Preparation of an application for
permit modification to establish
compliance monitoring
-------
Page 39 of 61
EPA I.D. No.
Part 270
Part 264 Subject Requirement
Location
*« in
Provided Applicable Application
270.14(c)(7) 264.91(a)(l)
and 264.99
2M.99(b)
264.96
264.99(d)
264.99(c)(3)
264.97(g)
Oeacription of Compliance Monitoring Prog ran
including '
List of wastes previously handled at
facility
Characterization of contaminated ground-
water
Hazardous constituents identified
Hazardous constituents concentrations
Description of compliance monitoring
system at the compliance point
List of hazardous constituents to be
compliance monitored
Proposed compliance period
Procedure for collecting quarterly samples
at compliance point during compliance
period
Procedures for establishing background
concentration values for constituents that
are based on
Use of an appropriate ground-water
monitoring system, and
Data that is available prior to permit
issuance
Data that accounta for measurement
errors in sampling and analysis
Data that accounts for seasonal ground-
water quality fluctuations
Data from a minimum of one sample per
well and a minimum of four samples
from monitoring system, each time
ayatem la sampled
-------
Page 40 of 41
EPA 1.0. No.
Part 270
Part 264
Subject Requirement
Provided
location
Mot in
Applicable Application
270.14(c)(7) 264.92 and
(iv) 264.99(c)
264.99(e)
264.99(0
264.99(g)
264.99(h)
264.99(1)
264.99(i)(l)
264.99(i)(2)
Proposed concentration Units (or consti-
tuents with justification based on
I264.94(a)(l) and 1264.97(g)
I264.94(a)(2)
1264.94(6) and I264.99(c)(l)
Procedure for annual determination of
uppermost aquifer flow rate and direction
Procedures for annual testing of all
compliance point wells for Appendix VIII
constituents
Documentation of all sampling and analysis
procedures
Procedures for determining a statistically
significant increase for any monitored
constituent by
Comparing compliance point data to the
concentration limit using the procedure
in I264.97(h)(2)
Providing an estimate of the time
period after sampling completion
necessary to obtain results
Procedures to be implemented if the
ground-water protection standard is
exceeded at any compliance point moni-
toring well, including
Written notification to Regional
Administrator
Preparation of an application for
permit modification to establish a
corrective action program, including
-------
Page 41 of 41
SPA I.D. No.
Pert 270
Part 264 Subject Requirement
270.L4(c><7> 264.99(0(2)
<•> di)
270.14(c)(8) 264.9l(a)(2) -
and 264.100
Provided
Not
Applicable
Location
in
Application
270.14(c)(8)
(i)
2M.100(a)(l)
270.14(c)(8) 264.100(a)(2)
(ii)
270.14(c)(8) 264.100(b)
(in)
2M.100(c)
270.14(c)(8) 264.100(d)
(iv)
264.91(a)(3)
and
264.100(e)
264.100(g)
Part
270. H(d)
270.11(a)
Details of program to cooply
with ground-water protection
standard
Details of ground-water
monitoring to demonstrate
effectiveness of progran
Description of Corrective Action Program
including
Characterization of contaminated
ground-water
Identified hazardous constituents
Concentrations of hazardous
constituents
Concentration limit for each hazardous
constituent
Detailed plan and an engineering report
describing the corrective actions to be
taken at the compliance point
Time period necessary to implement correc-
tive action program
Description of ground-water monitoring
program that will be sufficient to assess
the adequacy of corrective action
Description of the corrective action to
be taken for constituents in ground-water
between compliance point and downgradient
facility boundary
Procedure and content for semi-annually
submitting written reports to the Regional
Administrator on program effectiveness
B Certification and Signatories
Certification paragraph
Appropriate signatory
Comments
-------
APPENDIX A
FEDERAL AND STATE AGENCY
ADDRESSES AND TELEPHONE NUMBERS
A.I RCRA HOTLINE
A.2 GOVERNMENT PRINTING OFFICE (GPO)
A.3 EPA REGIONAL OFFICES
A.U STATE AGENCIES
A.5 GPO BOOKSTORE LOCATIONS
A-l
-------
A.I RCRA HOTLINE: (800) 424-9346
Hours: Monday - Friday
8:00 a.m. - 4:30 p.m. EST or EDT
A.2 MAILING ADDRESS: Superintendant of Documents
Governmental Printing Office
Washington, D.C. 20402
Telephone: (202) 783-3238
Ordering Procedure:
• Payment in advance is required for shipment of regulations. Do not
send currency (bills and coins) or postage stamps.
• Make checks or money orders payable to the Superintendant of
Documents.
• If first-class mailing is desired, contact GPO at the above
telephone number - it costs more.
• To order any document, obtain a Governmental Printing Office order
form #1981-0-346-379/1307. These are available through any GPO
bookstore or by contacting the Superintendant's office.
• Type or print: Office/Home Telephone Number
Visa or MasterCard Number (if applicable)
Deposit Account Number (if applicable)
Date of Order
Order Number (if any)
Complete Name and Address
Stock Number
Quantity
Unit of Issue
Title
Price
Payment Enclosed
Shipping Address (if different from other)
• For information on publications, or for placing a Deposit Account or
Visa or MasterCard order, call the above telephone number.
• Mail completed form to the above address.
A-2
-------
A.3 REGIONAL EPA OFFICE BRANCHES WHO ADMINISTER THE RCRA
Region I:
Region II:
Region III:
Region IV:
Region V:
Region VI:
Region VII:
Region VIII:
State Waste Programs Branch
Waste Management Division
John F. Kennedy Federal Building
Boston, MA 02203
(617) 223-6883
Solid Waste Branch
Air and Waste Management Division
26 Federal Plaza
New York, NY 10007
(212) 264-0505
Waste Management Branch/RCRA Permit Section
Air and Waste Management Division
Curtis Building, 6th and Walnut Streets
Philadelphia, PA 19106
(215) 597-9118
Residuals Management Branch
Air and Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA 30308
(404) 881-3443
Waste Management Branch
Waste Management Division
Federal Building, 230 South Dearborn
Chicago, IL 60604
(312) 886-7579
Hazardous Materials Branch
Air and Waste Management Division
First International Building, 1201 Elm Street
Dallas, TX 73270
(214) 729-2645
Waste Management Branch
Air and Waste Management Division
1753 Baltimore Street
Kansas City, MO 64108
(816) 758-6536
Waste Management Branch
Air and Waste Management Division
Suite 900, 1860 Lincoln Street
Denver, CO 80203
(303) 837-6238
A-3
-------
Region IX: Programs Branch
Toxics and Waste Management Division
215 Fremont Street
San Francisco, CA
(415) 974-7411/974-8391
Region X: RCRA Branch
Air and Waste Management Division
1200 6th Avenue
Seattle, WA 98101
(206) 399-2782
A.4 STATE AGENCIES DEALING WITH HAZARDOUS WASTES
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Environmental Health Administration
Solid and Hazardous Waste Division
328 State Office Building
Montgomery, AL 36130
(205) 834-1303
Department of Environmental Conservation
Environmental Quality Management Section
Solid Waste Management Section
Pouch 0
Juneau, Alaska 99811
(907) 465-2667
Department of Health Services
Division of Environmental Health Services
Bureau of Waste Management
1740 West Adams
Phoenix, AZ 85007
(602) 255-1170
Department of Pollution Control and Ecology
Solid Waste Division
P.O. Box 9583
Little Rock, Arkansas 72219
(916) 562-7444
Solid Waste Management Board
1020 9th Street, Suite 300
Sacramento, CA 95841
(916) 322-3330
Department of Health
Office of Health and Environmental Protection
4210 East llth Avenue
Denver, CO 80220
(303) 320-8333
A-4
-------
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Department of Environmental Protection
Division of Environmental Quality
Solid Waste Management Unit
State Office Building
165 Capitol Avenue
Harford, CN 06115
(203) 566-5847
Department of Natural Resources and Environmental Control
Division of Environmental Control
Solid Waste/Hazardous Waste Section
Edward Tatnall Building
P.O. Box 1401
Dover, Delaware 19901
(302) 736-4781
Department of Environmental Services
Solid Waste Management Administration/
Hazardous Waste Division
500 Overlook Avenue, S.W.
Washington, D.C. 20032
(202) 767-8176/767-8422
Department of Environmental Regulation
Division of Environmental Programs
2600 Blairstone Road
Tallahassee, FL 32301
(904) 487-1855
Department of Natural Resources
Environmental Protection Division
Land Protection Branch
270 Washington Street, S.W.
Atlanta, GA 30334
(404) 650-2833
Department of Health
Environmental Protection and Health Services Division
P.O. Box 3378
1250 Punchbowl Street
Honolulu, HI 96801
(808) 548-4139
Department of Health and Welfare
Division of Environment
Statehouse
Boise, Idaho 83720
(208) 334-4059
A-5
-------
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Environmental Protection Agency
Land Pollution Control Division
2200 Churchill Road
Springfield, IL 62706
(217) 782-6760
Environmental Management Board
P.O. Box 1964
1330 Michigan Street
Indianapolis, IN 46206
(317) 633-0170
Department of Environmental Quality
Air and Land Quality Division
Henry A. Wallace Building
900 East Grand Avenue
Des Moines, Iowa 50319
(515) 281-5851
Department of Health and Environment
Solid Waste Management Division
740 Forbes Building
Topeka, KS 66620
(913) 862-9360
Bureau of Environmental Protection
Waste Management Division
Fort Boone Plaza
18 Re illy Road
Frankfort, Kentucky 40601
(502) 564-6716
Department of Natural Resources
Solid Waste/Hazardous Waste Division
P.O. Box 44066
Baton Rouge, Louisiana 70804
(504) 342-1216/342-1227
Department of Environmental Protection
Solid Waste/Hazardous Materials Division
State House, Station 17
Augusta, ME 04333
(207) 289-2111/289-2251
Department of Health and Mental Hygiene
Waste Management Division
201 West Preston Street
Baltimore, Maryland 21201
(301) 383-3123
A-6
-------
Massachusetts Executive Office of Environmental Affairs
Department of Environmental Quality Engineering
Solid and Hazardous Waste Division
One Winter Street
Boston, MA 02108
(617) 292-5589
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
Bureau of Environmental Protection
Hazardous Waste Management Office
P.O. Box 30038
Lansing, Michigan 48909
(517) 373-8114
Health Department
Environmental Health Division
717 Delaware Street SE
Minneapolis, Minnesota 55440
(612) 296-5320
Department of Natural Resources
Bureau of Pollution Control
P.O. Box 10385
Jackson, MS 39209
(601) 961-5202
Department of Natural Resources
Division Of Environmental Quality
Solid Waste Management Program
P.O. Box 1368
Missouri Boulevard
Jefferson City, Missouri 65102
(314) 751-3241
Department of Health and Environmental Sciences
Environmental Sciences Division
Solid Waste Management Bureau
Cogswell Building
Helena, Montana 59620
(406) 449-2821
Department of Environmental Control
P.O. Box 94877
State Office Building
Lincoln, Nebraska 68509
(402) 471-2186
Department of Conservation and National Resources
Division of Environmental Protection
201 South Fall Street, Capitol Complex
Carson City, Nevada 89710
(702) 885-4670
A-7
-------
New Jersey
New Mexico
New Hampshire Department of Health and Welfare
Bureau of Solid Waste Management/
Hazardous Waste Management
Hazen Drive
Concord, NH 03301
(603) 271-4586/271-4608
Department of Environmental Protection
Solid Waste Division/Hazardous Waste Bureau
CN 402
Trenton, NJ 08625
(609) 292-9120/292-9877
Health and Environmental Department
Environmental Improvement Division
P.O. Box 968
Santa Fe, NM 87503
(505) 827-5271
Department of Environmental Conservation
Solid Waste Management Division/
Bureau of Hazardous Waste
50 Wolf Road
Albany, NY 12233
(518) 457-5861/457-3254
North Carolina Department of Human Resources
Division of Health Services
Solid and Hazardous Waste Management Branch
P.O. Box 2091
225 North McDowell Street
Raleigh, North Carolina 27602
(919) 733-2178
New York
North Dakota
Ohio
Oklahoma
Health Department
Environmental and Waste Management Research Division
1200 Missouri Avenue
Bismarck, North Dakota 58505
(701) 224-2382
Environmental Protection Agency
Office of Land Pollution Control
P.O. Box 1049
361 East Broad Street
Columbus, Ohio 43216
(614) 466-8934
Health Department
Environmental Health Services
Industrial and Solid Waste Service
1000 NE 10th Street
Oklahoma City, OK 75152
(405) 271-5338
A-8
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Oregon
Pennsylvania
Department of Environmental Quality
Solid Waste Division
522 SW 5th Street
Portland, OR 97204
(503) 229-5336
Department of Environmental Resources
Office of Environmental Protection
Bureau of Solid Waste Management
Fulton Building, P.O. Box 2063
Harrisburg, PA 17120
(717) 787-9870
Department of Environmental Management
Division of Land Resources
75 Davis Street
Providence, RI 02908
(401) 277-6820
South Carolina Board of Health and Environmental Control
Bureau of Solid and Hazardous Waste
2600 Bull Street
Columbia, SC 29201
(803) 758-5544
Rhode Island
South Dakota
Tennessee
Texas
Utah
Department of Water and Natural Resources
Environmental Health Division
Joe FOBS Building
Pierre, SD 57501
(605) 773-3329
Department of Public Health
Bureau of Environmental Health Services
Solid Waste Management Division
Cordell Hull Building
Nashville, TN 37129
(615) 741-3424
Department of Health
Bureau of Solid Waste
(512) 458-7271
Department of Health
Division of Environmental Health
Bureau of Solid Waste Management
150 North Temple Street
P.O. Box 2500
Salt Lake City, UT 84110
(801) 533-4145
A-9
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Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Environmental Conservation Agency
Air and Solid Waste Division
State Office Building
Montpelier, VT 05602
(802) 828-3395
Department of Health
Division of Solid and Hazardous Waste Management
109 Governor Street
Richmond, VA 23219
(804) 786-5271
Department of Ecology
Solid Waste Management Division/Hazardous Waste Section
P.O. Box 829
Olympia, WA 98501
(206) 459-6273/459-6301
Department of Health
Office of Environmental Health
1800 Washington Street East
Charleston, WV 26505
(304) 348-2987
Department of Natural Resources
Bureau of Solid Waste Management
101 South Webster Street
Madison, Wisconsin 53707
(609) 266-1327
Environmental Quality
Solid Waste Management Program
401 West 19th Street
Cheyenne, Wyoming 82002
(307) 777-7753
A. 5 GOVERNMENT PRINTING OFFICE BOOKSTORE LOCATIONS
Region I
Region II
Region III
Boston, MA
John F. Kennedy Federal Building
Sudbury Street
(617) 223-6071
New York, NY
20 Federal Plaza
(212) 264-3825
Philadelphia, PA
Federal Office Building
600 Arch Street
(215) 597-0677
A-10
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Region IV
Region V
Pittsburgh, PA
Federal Building
1000 Liberty Avenue
(412) 644-2721
Washington, DC area:
Main Bookstore
710 N Capital St.
(202) 275-2091
Commercial Department
14th and E Streets NW
(202) 377-3527
HHS
330 Independence Ave. SW
(202) 472-7478
ICA
1776 Pennsylvania Ave. NW
(202) 724-9928
Laurel Bookstore
8660 Cherry Lane
Laurel, MD
(301) 953-7974
Pentagon Building
Main Concourse
(703) 557-1821
State Department
21st and C Streets NW
(202) 632-1437
Atlanta, GA
Federal Building
275 Peachtree Street NE
(404) 221-6947
Birmingham, AB
9220-B Parkway East
Roebuck Shopping City
(205) 254-1056
Jacksonville, FL
Federal Building
400 W. Bay Street
(904) 791-3801
Chicago, IL
Everett McKinley Dirksen Building
219 S. Dearborn Street
(312) 353-5133
A-ll
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Cleveland, OH
Federal Office Building
1240 E. 9th Street
(216) 522-4922
Columbus, OH
Federal Office Building
200 N. High Street
(614) 469-6956
Detroit, MI
Patrick V. McNamara Federal Building
477 Michigan Avenue
(313) 226-7816
Milwaukee, WI
Federal Building
519 E. Wisconsin Avenue
(414) 291-1304
Region VI Dallas, TX
Federal Building—U.S. Courthouse
1100 Commerce Street
(214) 729-0076
Houston, TX
45 College Center
9319 Gulf Freeway
(713) 226-5453
Region VII
Region VIII
Kansas City, MO
Federal Office Building
601 E. 12th Street
(816) 374-2160
Denver, CO
Federal Building
1961 Stout Street
(303) 837-3904
Pueblo, CO
720 N. Main Majestic Building
(303) 544-3142
Region IX San Francisco, CA
Federal Office Building
450 Golden Gate Avenue
(415) 556-0643
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Los Angeles, CA
ARCO Plaza
505 S. Flower Street
(213) 688-5841
Region X Seattle, WA
Federal Office Building
915 Second Avenue
(206) 442-4270
A-13
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APPENDIX B
SYNOPSIS OF TECHNICAL REPORTS
B.I SYNOPSIS OF TECHNICAL GUIDANCE DOCUMENTS
B.2 SYNOPSIS OF TECHNICAL RESOURCE DOCUMENTS
B.3 SYNOPSIS OF OTHER GUIDANCE MANUALS
B-l
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B.I SYNOPSIS OF TECHNICAL GUIDANCE DOCUMENTS
(1) Surface Impoundments Liner Systems, Final Cover, and Freeboard
Control discusses design specifications for the principal components
of surface impoundments (i.e., liner systems, monitoring methods,
overtopping controls, and closure caps). Appendices are included
that provide laboratory and field testing protocols for obtaining
necessary data elements.
(2) Waste Pile Design - Liner Systems describes liner designs that
provide an essentially impermeable waste pile base of sufficient
strength to allow periodic removal of all wastes in order to
physically inspect the base liner. Details such as suitable liner
materials, liner thickness, and leachate processing are discussed.
Appendices with useful test procedures are included.
(3) Land Treatment Units identifies specific designs and various
operating procedures to: maximize waste treatment; control water
run-on/run-off and wind dispersal; monitor for waste constituent
escape; close facility; and maintain the site after closure.
Methods to demonstrate waste treatability in soil are provided along
with appendices containing testing protocols.
(4) Landfill Design - Liner Systems and Final Cover presents various
liner specifications, leachate processing methods, and final cover
designs that would give satisfactory performance in a given
environmental setting. Appendices containing relevant testing
procedures are included.
B.2 SYNOPSIS OF TECHNICAL RESOURCE DOCUMENTS
(1) Evaluating Cover Systems for Solid and Hazardous Waste (SW-867)
presents a procedure for evaluating final cover engineering plans
proposed for solid and hazardous waste land disposal facilities.
All aspects of cover design are addressed in sufficient detail to
allow a complete evaluation of the entire cover system.
(2) Hydrologic Simulation on Solid Waste Disposal Sites (SW-868)
describes the use of a computer-based model for simulating the
percolation of water through cover material at a solid waste
disposal site. This model is a tool for evaluating present cover
materials, and the design of new landfill covers. Previous computer
experience by the program user is not necessary.
(3) Landfill and Surface Impoundment Performance Evaluation (SW-869)
provides techniques for determining the adequacy of design features
such as liners, drain layers, slope, and position of drains in
controlling liquid waste escape from surface impoundments and
landfills into the environment.
B-2
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Lining of Waste Impoundment and Disposal Facilities (SW-870)
discusses performance evaluation, selection, installation, and
maintenance of specific liner and cover materials for certain
containment situations based upon the latest technology. It
includes a description of several industrial waste streams, and
indicates several testing procedures for evaluating the waste/liner
interaction.
(5) Management of Hazardous Waste Leachate (SW-871) presents options for
controlling, treating, and disposing of hazardous waste leachates
generated by surface impoundments and landfills. Discussion
includes factors that influence leachate generation, data on
leachate characteristics, alternative technologies for processing
leachates, and data on treatment costs and byproducts. A systematic
approach is provided for selecting an appropriate leachate
management method.
(6> Guide to the Disposal of Chemically Stabilized and Solidified Waste
(SW-872) describes current treatment technology, and design of
long-term storage and disposal systems using
stabilization/solidification of wastes. In includes data on the
properties of treated wastes, and a listing of major technology
suppliers with a summary of each process. Sufficient information is
provided to determine relative cost/effectiveness of
stabilization/solidification for a particular waste and disposal
system.
O) Closure of Hazardous Waste Surface Impoundments (SW-873) discusses
the important details to consider in evaluating closure and
post-closure plans for hazardous waste surface impoundments.
Methodologies are presented for site specific assessments.
(8) Hazardous Waste Land Treatment (SW-874) describes current technology
and provides methods for evaluating the design and performance of
hazardous waste land treatment facilities. All aspects of land
treatment are discussed from initial site selection through final
closure.
FUTURE TECHNICAL RESOURCE DOCUMENTS
(9) Evaluation of Closure and Post-Closure Care Plans for Hazardous
Waste Landfills presents an overview of the current state-of-the-art
technologies for closing landfill facilities. (Due in early 1983.)
(10) Soil Properties, Classification, and Hydraulic Conductivity Testing
is a compilation of available laboratory and field testing methods
for the measurement of hydraulic conductivity of soils along with
background information on relevant soil properties and
classification systems. (Due in early 1983.) However, the RCRA
Technical Guidance Documents present the official EPA test methods
for hydraulic conductivity determinations.
(11) Solid Waste Leaching Procedure Manual provides laboratory batch
procedures for extracting a leachate sample from solid waste that is
similar to the composition of leachate from the waste under field
conditions. (Due in early 1983.)
B-3
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B.3 SYNOPSIS OF OTHER GUIDANCE MANUALS
(1) Test Methods for Evaluating Solid Wastes (SW-846) provides
standardized laboratory procedures for determining whether a waste
is hazardous as defined in Section 3001 of the Resource Conservation
and Reocvery Act (PL94-580), and for obtaining data to satisfy the
requirement of 40 CFR Part 261, Identification and Listing of
Hazardous Waste. These methods will generate data of acceptable
quality to support waste evaluation and listing/delisting
petitions. Included are protocols for collecting representative
waste samples, determining pH, flash point, leachability,
reactivity, corrosivity, ignitability, mobility of toxic
constituents, and general composition of the waste. These
procedures are current state-of-the-art techniques and will be
periodically updated and expanded as new information is developed.
(2) A Method for Determining the Compatibility of Hazardous Wastes
(EPA-600/2-80-076) presents a procedure for determining the
compatibility of combinations of two wastes or waste streams. The
manual includes a chart of 41 reactivity groups. Wastes to be
combined are first subjected to the analysis procedure for
identification and classification into a reactive group. The chart
is used to predict the compatibility of the classified wastes on
mixing.
(3) Handbook for Remedial Action at Waste Disposal Sites
(EPA-625/6-82-006) describes available remedial action technologies
and how they may be applied for the clean-up of hazardous waste
disposal sites. A general approach to selecting an appropriate
clean-up technique for a specific site is provided.
(4) Permit Writer's Guidance Manual for Subpart F(being drafted)
provides a comprehensive examination of items covering ground-water
protection requirements for permit writers to examine when reviewing
Part B applications.
(5) Ground-Water Monitoring Guidance for Owners and Operators of Interim
Status Facilities (SW-963) provides guidance for facilities in
compliance with the Interim Status requirements.
(6) Financial Assurance for Closure and Post-Closure Care; Requirements
for Owners and Operators of Hazardous Waste Treatment, Storage, and
Disposal Facilities - A Guidance Manual (SW-955) describes the
responsibilities of the regulated community in fulfilling the
financial assurance requirements of the regulations. Tasks that
must be performed by the Regional Office, and possible contingencies
that may arise are discussed. A checklist of required information
and sample application forms are provided.
B-4
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<7) Liability Coverage: Requirements for Owners or Operator* of
Hazardous Waste Treatment. Storage, and Disposal F«eiiiH.~- A
Guidance Manual QSW-961) describes the responsibilities of the
regulated community in providing liability coverage for facilities
and discusses the role of the Regional Office. Included are a
checklist of required information and sample application forms.
FUTURE RESOURCE MANUALS
°n technical resource manuals in the following
numerical simulation techniques for design of soil liners for
storage impoundments and waste piles
further information on the compatibility of soil liners and
hazardous wastes
characteristics of hazardous waste streams
avail"b"ity of these manuals will be announced in the Federal
' and m future editions of this Manual.
B-5
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APPENDIX C
ADDRESSES OF GEOLOGICAL AGENCIES
Geological agencies are located throughout the United States, in the form
of Federal agencies (U.S. Geological Survey), state geological surveys, and
district branches of USGS. The Federal USGS offices fall within the U.S.
Department of the Interior. This Appendix provides direction to the reader on
the Federal level only. This is due to several factors, the most important
being that the Federal USGS can provide up-to-date state and district office
addresses and telephone numbers. Thus, the two distribution offices of the
USGS (east and west) are listed here along with the 10 Public Inquiries
Offices (PIO's) spread throughout the country. Both can provide services and
maps; specific functions are noted in this Appendix.
The two distribution offices of the Federal U.S. Geological Survey are
for areas east of the Mississippi River, including Minnesota, Puerto Rico, and
the Virgin Islands:
• Eastern Distribution Branch
U.S. Geological Survey
1200 South Eads Street
Arlington, Virginia 22202
and for areas west of the Mississippi River, including Alaska, Hawaii,
Louisiana, Guam, and American Samoa:
• Western Distribution Branch
U.S. Geological Survey
Box 25286 Denver Federal Center
Denver, Colorado 80225
These offices can provide indexes which list all published maps and include
order blanks, prices, and detailed ordering instructions. They also list
addresses of local map reference libraries, local map dealers, and Federal map
distribution centers. You should use these addresses for obtaining
topographic and other maps through the mail.
Public inquiries offices of the USGS are provided in Table C-l. These
offices can also provide index maps and sell topographic maps over the
counter. They can ship geologic maps through the mail for nearby states.
C-l
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TABLE C-l. PUBLIC INQUIRIES OFFICES OF THE U.S. GEOLOGICAL SURVEY4
Anchorage, Alaska
Los Angeles, California1*
Menlo Park, California
San Francisco, Coliforniac
Denver, Colorado
Washington, District of
Columbia
Dallas,
Sail Lnkr City, Ut.ili
Ki-ston,
Spokane,
Rm. 108 Skyline Bldg.
508 2nd Avenue
Anchorage, AK 99501
Km. 7638 Federal Bldg.
300 No. Los Angeles St.
Los Angeles, CA 90012
Bldg. 3, MS 33
345 Middlefield Kd.
Mcnlo Park, CA 94025
Rm. 504 Custom House
555 Battery Street
San Francisco, CA 94111
Km. 169 Federal Bldg.
1961 Stout Street
Denver, CO 80294
Km. 1028 GSA Bldg.
19th & F Sts. NW
Washington, DC 20244
Rm. l-C-45 Federal Htdg.
1100 Commerce Street
Dallas, TX 75242
Km. 8105 Federal Bldg.
125 S. State St.
Salt Lake Cily, UT 841J8
Rm. l-C-402 National Center
STOP 503
12201 Sunrise Valley Dr.
Keston, VA 22092
Rm. 678 U.C. Courthouse
W. 920 Riverside Avenue
Spokane, WA 99201
(907) 277-0577
(213) 688-2850
(415) 323-8111
(415) -556-5627
(303) 837-4169
(202) 343-8073
(214) 767-0198
(801) 524-5652
(702) 860-6167
(509) 456-2524
8Any of these offices handle most states; you should generally contact the
one nearest you, especially in the case of geologic maps. These offices
center on bibliographic research projects. They will provide indexes of USGS
quadrangles, by statr, free* of charge. They can also mail geologic maps and
brochures, although in some cases they cannot ship topographic maps (this
requires mailing tubes). They all sell topographic maps over-the-counter.
For shipment of topographic maps, the reader should consult the two addresses
provided fit the beginning of this Appendix.
''Handles geologic maps of California, Alaska, Hawaii, Arizona, Nevada,
Washington, and Oregon.
cFocus on Idaho Geologic maps as well
Source: Geologic Survey Professional Paper 950, "Nature to be Commanded,"
1978, p. 92.
C-2
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The geological surveys can provide a variety of maps (topographic,
geologic, seismic, etc.) depending on the location. They can also provide
other data which may be useful such as books and reports or information such
as seismic-refraction data. An excerpt of several reports listed in a recent
USGS "New Publications of the Geological Survey" (October 1982) is included as
Table C-2. These publications are issued monthly.
In addition, geologic data may be available through private sources for
some locations. For example, the geology or earth science departments of
universities may have geologic data for the area.
You might also consult the local telephone director to check for other
branch offices of the USGS which might be located near your site or changes in
telephone number or location from those listed here.
C-3
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TABLE C-2. EXAMPLES OF AVAILABLE USGS DOCUMENTS a
OF 81-0459. Seismic-re fraction data taken in southwest NEW MEXICO and
southeast ARIZONA, by L. H. Jaksha, A. Garcia, and E. E. Tilgner. 19 p.
(NC, Da, M, T, SF, LA, U; USGS, Seventh Floor, 505 Marquette, NW. (P.O.
Box 26659), Albuquerque, NM 87125; New Mexico Bur. Mines and Mineral
Resources, Campus Station, Socorro, NM 87801; Arizona Bur. Geol. and
Mineral Tech., 845 North Park Ave., Tuscon, AZ 85719). Microfiche
$3.50; paper copy $2.25.
OF 82-0837. Map showing geophysical tracklines, south-central Monterey Bay,
CALIFORNIA (summer 1981), by G. W. Hill and J. L. Chin. 1 over-size
sheet, scale 1:24,000 (1 inch = 2,000 feet). (NC, Da, M.) Microfiche
$1; paper copy $2.50.
OF 82-0832. Interpretation of an aeromagnetic survey of parts of Shannon,
Carter, Oregon, and Ripley Counties in southeastern MISSOURI, by Allan
Spector, with introduction by Gerda Abrams. 20 p., 1 over-size sheet,
scale 1:62,500 (1 inch B 1 mile). (NC, Da, M; Missouri Dept. Natural
Resources, Div. Geol. and Land Survey (P.O. Box 250), Rolla, MO 65401.)
Microfiche $4; paper copy $5.25.
OF 82-0655. Geological map of the Alenaio-Waipahoehoe Stream area, South Hilo
District, HAWAII, by J. M. Buchanan-Banks and J. P. Lockwood. 1
over-size sheet, scale 1:24,000 (1 inch = 2,000 feet). (NC, Da, M, SF,
LA.) Microfiche $1; paper copy $1.75.
OF 82-0195. Bibliography of Alaskan geologic maps by 1:250,000 quadrangle,
compiled by J. F. Morrone. 70 p. (NC, Da, M, A, S, SF, LA; USGS,
Room 207, O'Neill Bldg., Univ. Alaska (P.O. Box 80586), Fairbanks, AK
99708; Alaska Div. Geol. and Geophys. Surveys, 3001 Porcupine Dr.,
Anchorage, AK 99501; and University Ave. (P.O. Box 80007), Fairbanks,
AK 99708.) Microfiche $3.50; paper copy $9.
OF 82-0462. Geochemical and geostatistical evaluation, Arkansas Canyon
planning unit. Fremont and Custer Counties, COLORADO, by E. F. Weiland.
115 p., 31 over-size sheets. (NC, Da, M, Db, U.) Microfiche $19; paper
copy $127.25.
OF 82-0488. Catalog of earthquakes in southern ALASKA, April-June 1978, by
C. D. Stephens, M. C. Astrue, J. R. Pelton, K. A. Fogleman, R. A. Page,
J. C. Lahr, M. A. Allan, and S. M. Helton. 37 p. (NC, Da, M, A, S, SF,
LA; USGS, Room 207, O'Neill Bldg., Univ. Alaska (P.O. Box 80586),
Fairbanks, AK 99708; Alaska Div. Geol. and Geophys. Surveys, 3001
Porcupine Dr., Anchorage, AK 99501; and University Ave. (P.O. Box
80007), Fairbanks, AK 99708.) Microfiche $3.50; paper copy $4.75.
(continued)
C-4
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TABLE C-2 (continued)
OF 82-0579. Quaternary fault map of the Basin and Range and Rio Grande rift
provinces, Western United States, by J. K. Nakata, C. H. Uentworth, and
M. N. Machette. 2 over-size sheets, scale 1:2,500,000 (1 inch - about
40 miles). (NC, Da, M, Db, U, SF, LA, T, S; USGS, Seventh Floor,
505 Marquette, NW. (P.O. Box 26659), Albuquerque, NM 87125; Montana
Bur. Mines and Geol., Montana Coll. Mineral Sci. and Tech., Butte, MT
59701; Nevada Bur. Mines and Geol., Univ. Nevada, Reno, NV 89557;
Oregon Dept. Geol. and Mineral Industries, Room 1069, State Office Bldg.,
1400 SW. Fifth Ave., Portland, OR 97201; Wyoming Geol. Survey, Univ.
Wyoming (P.O. Box 3008, Univ. Station), Laramie, WY 82071). Microfiche
$1; paper copy $7.
OF 82-0644. Subsurface information from eight wells drilled at the IDAHO
National Engineering Laboratory, by F. J. Goldstein and W. D. Weight.
34 p. (NC; USGS WRD, Idaho National Engineering Laboratory, CF-690,
Room 164, Idaho Falls, ID 83401; Public Document Room, DOE's Idaho
Operations Office, 550 Second St., Idaho Falls, ID 83401.) Microfiche
$3.50; paper copy $4.25.
OF 82-0689. Data on subsurface storage of liquid waste near Pensacola,
FLORIDA, 1963-1980, by R. W. Hull and J. B. Martin. 186 p. (NC, Wb;
USGS, WRD, 325 John Knox Rd. , Suite F-240, Tallahassee, FL 32303; USGS,
WRD, 325 John Knox Rd., Suite L-103, Tallahassee, FL 32303.) Microfiche
$3.50; paper copy $24.
OF 82-0876. Inventory of drilling activities of the U.S. Geological Survey
in the United States during fiscal year 1980, compiled by M. J. Reed,
Robert Mallis, and J. D. Bliss. 19 p. (NC, Da, M.) Microfiche $3.50,
paper copy $2.25.
OF 82-0877. A description of colored gravity and terrain maps for the United
States and adjacent Canada east of 104°, by R. W. Simpson,
T. G. Hildenbrand, R. H. Godson, and M. F. Kane. 18 p. (NC, Da, M.)
Microfiche $3.50; paper copy $2.25. Standard 2" by 2" color slides of
these maps are available through the U.S. Geologic Survey Photo Library,
Mail Stop 914, Box 25046, Denver Federal Ctr., Denver, CO 80225.
Telephone (303) 234-4004.
aSource: "New Publications of the Geological Survey," U.S. Dept. of
Interior, List 891—Oct. 1982. p. 10 and 11.
C-5
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APPENDIX D
AERIAL PHOTOGRAPHS
SOURCES OF AERIAL PHOTOGRAPHS
Federal Level
There are several Federal agencies which handle aerial photographs. The
first source that you may want to contact is:
• NCIC Headquarters
U.S. Geological Survey
507 National Center
Reston, VA 22092
(703) 860-6045
The NCIC will send out a printout of all the agencies (Federal, state,
commercial) which have photographs available for the area in question.
Thereafter, individual agencies such as the following five can be
contacted:
• Aerial Photography Field Office
ASCS-USDA
P.O. Box 30010
Salt Lake City, Utah 84130
801-524-5856
This agency has all ASCS photos, all Forest Service photos, and many others
(some USGS, National High Altitude Photos (Nhap), etc.). Besides providing
photos through the mail, the ASCS serves as a public reference facility. Any
maps they have can be used by the public by visiting their facility. Aerial
photos available through ASCS go back historically to 1944; their archives BO
into the 1930's.
• EROS Data Center
U.S. Geological Survey
Sioux Falls, South Dakota 57198
(605) 594-6511 X151 for cartographic unit
EROS has Landsat and U-2 photos, mainly black and white at 1:80,000 scale,
flown at the same time as the color photos for Landsat. They do computer
searches to retrieve listings of all available photos.
D-l
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• Soil Conservation Service
USDA-SCS
P.O. Box 6567
Fort Worth, TX 76115
(817) 334-5292
The SCS has consolidated its branches into this one office. SCS supplies
mostly low-altitude photos.
• National Archives
841 South Pickett Street
Alexandria, VA 22304
(703) 756-6700
The National Archives should be contacted for archival photographs. All of
these agencies will require some identification of site location by the
applicant. This may be in the form of a copy of a town engineer's map; a
Department of Transportation (DOT) map; a description of the township, range
and section; a hand-drawn map of the site and its location in regard to a
nearby town; a copy of the portion of a USGS quadrangle that shows the site;
the latitude/longitude coordinates of the site area, etc. In all cases, the
exact site location should be marked out and the topographic quadrangle used
noted. Any details that will help the agency provide aerial coverage of the
area in question should be included. Each agency also has forms available for
requesting photographs.
If the site is near the U.S.-Canada border, it may also be useful to
contact:
• The National Air Photo Library
Surveys and Mapping Branch
Department of Energy, Mines, and Resources
615 Booth Street
Ottawa, Ontario K1A OE9
Interstate Level
Table D-l provides a listing of interstate agencies which are likely to
have aerial coverage for their representative areas.
State Level
Numerous state agencies are likely to maintain aerial photographs on
file. If the sources previously outlined are too remote or do not have the
information you are looking for, you may be able to obtain photos from state
pollution control agencies, health departments, water resources departments,
and state highway departments as well.
Private Companies
A wide selection of photographic negatives are held by private aerial
survey companies and most often can be ordered directly from these sources.
D-2
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TABLE D-l. INTERSTATE AGENCIES WHICH ARE LIKELY TO HAVE
AERIAL PHOTOGRAPHY COVERAGE
Bi-State Agency
Bi-State Development Agency
915 Olive Street
St. Louis, MO
Delaware River
Interstate Commission on the Delaware River Basin
Suburban State Building
Philadelphia, PA
New England
New England Interstate Water Pollution Control Commission
73 Tremont Street
Boston, MA
Klamath River Compact Commission
Klamath River Compact Commission
P.O. Box 388
Sacramento, CA
New York/New Jersey/Connecticut
Interstate Sanitation Commission
10 Columbus Circle
New York, NY
Ohio River
Ohio River Valley Water Sanitation Commission (ORSANCO)
414 Walnut Street
Cincinnati, OH
Interstate Commission on the Potomac River Basin
203 Tranportation Building
Washington, D.C.
D-3
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Names and addresses of leading photogrammetric companies may be found in
current issues of "Photogrammetric Engineering", the Journal of the American
Society of Photogrammetry, or through local telephone listings. Photo indexes
and costs can usually be obtained by direct inquiry to the appropriate agency.
TYPES OF AERIAL PHOTOGRAPHS NEEDED FOR ANALYSIS
Air photo analysis is best done using a multistage approach; i.e., one
looks first at high-altitude photography and works down to a lower level. For
this reason, Landsat imagry (EROS) is important as it provides a large scale
and an analyst can identify lineaments. One could then use smaller scale U-2
photographs for the same area (1:125,000 scale) at which point the analyst can
eliminate the man-made features such as power-lines, old tree cuts, etc.
Finally, low-altitude photos such as those produced by the Soil Conservation
Service at 1:20,000 scale could be used.
It is desirable to use photos which are multiseasonal; winter is usually
best as this provides a low sun angle and minimal leaf color. To increase the
sensitivity of analysis, many variations can be considered, such as side lap,
seasonal difference, use of stereoscopy, etc.
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APPENDIX E
AERIAL RECONNAISSANCE FLIGHT PLANNING
To prepare for an aerial reconnaissance flight, the aid of a person
experienced in aerial photography will be required. Some guidelines on flight
planning are presented in Table E-l. Aerial reconnaissance of an area entails
planning the flight (height, season, number of flight lines, etc.) and
checking to be sure these specifications are followed. When photos are
delivered for a project, one reviews properties such as excessive crab, tilt,
scale differential and photo quality. The applicant should refer to the U.S.
Forest Service (USFS) Lake States Station Paper 96 which details procedures
and reasons for making such checks. After the flight, post-flight
interpretation of photos is performed.
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TABLE E-l. CONSIDERATIONS IN AERIAL RECONNAISSANCE FLIGHT PLANNING
Specifications and Equipment Considerations
• Average forward overlap8
• Desired photo scale
• Focal length
• Flight ground speed
• Intervalometerb
• Film format
Computations
• Flying height above terrain and height above mean sea level
• Direction and number of flight lines
• Adjusted distance between flight lines
• Adjusted percent of side lap or end lapc
• Map distance between flight lines
• Unadjusted distance between exposures on each line
• Time between exposures
• Map distance between exposures on each line
a
• Number of exposures on each line
• The amount of film required (feet and number of rolls)
aOverlap is the amount that one photograph overlaps the area covered by the
other, customarily expressed as a percentage.
t>A timing device for automatically operating the shutter of a camera at any
predetermined interval.
cSide lap is the overlap between photographs in adjacent parallel flights;
end lap is the overlap between photos in the same flight.
Source: Eugene T. Avery. Interpretation of Aerial Photographs. 2nd Edition,
Burgess Publishing Company, Minneapolis, MN, 1968.
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APPENDIX F
QUALITY ASSURANCE/QUALITY CONTROL
(Reprinted from Section Ten of
Test Methods for Evaluating Solid Waste,
SU-846. U.S. EPA, 1982)
"Section 10.1 defines Quality Control (QC) and Quality Assurance (QA).
Section 10.2 discusses how QC/QA procedures can be used to ensure achievement
of program goals. The various QC/QA aspects of sampling are discussed In
Section 10.1.3 while Section 10.1.4 discusses and lists appropriate laboratory
QC/QA activities. Section 10.1.5 discusses the criteria with which acceptable
data must comply and methods of data evaluation.
10.1 Introduction
Quality assurance (QA) 1s a system for ensuring that all information,
data, and resulting decisions compiled under a specific task are technically
sound, statistically valid, and properly documented. Quality control is the
mechanism through which quality assurance achieves its goals.Quality
control programs define the frequency and methods of checks, audits, and
reviews necessary to identify problems and dictate corrective action, thus
verifying product quality.
The soundness of an organization's QC/QA program has a direct bearing on
the integrity of its sampling and laboratory work. Results of sampling or
analysis conducted without adequate quality control and assurance may be
deemed unacceptable for RCRA evaluation purposes. The following section
discusses some minimum standards for QC/QA programs. Generators who are
choosing contractors to perform sampling or analytical work should make their
choice only after evaluating the contractor's QC/QA program against the
procedures presented in these sections. Likewise, contractors that currently
sample and/or analyze solid wastes should similarly evaluate their QC/QA
programs.
10.2 Program Design
The Initial step for any sampling or analytical work should be to
strictly define the program goals. Once the goals have been defined, a
program must be designed that will meet these program goals. QC and QA
measures will be the mechanisms used to monitor the program and to ensure
that all data generated are suitable for their intended use. A knowledgeable
person who is not directly involved in the sampling or analysis must be
assigned the responsibility of ensuring that the QC/QA measures are properly
employed.
As a minimum, a proper QC/QA program would include the following:
1. The intended use(s) for the data, and the necessary level of
precision and accuracy of the data for these Intended uses.
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"2. A representative sampling plan that includes provisions for:
- selecting appropriate sampling locations, depths, etc.
- providing a statistically sufficient number of sampling sites.
- measuring all necessary ancillary data.
- determining climatic flow or other conditions under which
sampling should be conducted.
- determining which media are to be sampled (e.g., wastewater,
sediment, effluent, soil).
- determining which parameters are to be measured (and where).
- selecting appropriate sample containers.
- selecting the frequency of sampling and length of sampling
period.
- selecting the types of sample (e.g., composites vs. grabs) to be
collected.
- sample preservation.
- chain-of-custody.
3. An analytical plan that includes:
- chain-of-custody procedures.
- appropriate sample preparation methods.
- appropriate analytical methods.
- appropriate calibration and analytical procedures.
- data handling, review and reporting.
4. Planning for the inclusion of proper and sufficient QC/QA activities,
Including the use of QC samples throughout all phases of the study
to ensure that the level of quality of the data will meet the
requirements of the intended use(s) of the data.
All program details should be put in writing and assignments made to
appropriate personnel.
If the above procedures are followed (i.e., an appropriate program is
designed, tasks are assigned to knowledgeable personnel, and sufficient QC/QA
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"steps are employed), the program should meet and possibly surpass Its goals
1n most cases; at worst the failure to meet the program goals will be detected
and the usefulness of any data will be quantified.
10.3 Sampling
The quality of a sampling program has a direct bearing on the legal,
physical, and chemical integrity of the samples. If the representativeness
of the samples cannot be verified due to inadequate attention to sampling
procedures, then the usefulness of the analytical data will be limited,
regardless of the refinement of the analytical program. It is imperative,
therefore, that no analytical program be conducted without an adequate
sampling plan which does or will document the degree of representativeness
of the parameters of interest.
10.3.1 Design of a Sampling Plan
Section One of this manual discusses the considerations involved in
designing a representative sampling plan. For each specific project, a
sampling plan should be designed prior to commencement of sampling. If the
plan addresses the considerations discussed in Section One, then the resulting
samples should be representative of the waste of interest and therefore
suitable for evaluation of the waste according to RCRA criteria.
10.3.2 Sample Collection
A variety of different sampling devices are used in sampling depending
on the type of sample (solid, liquid, multiphased), the type of sample
container, and the sampling location. Section One and portions of Section
Three of this manual describe different devices that are available. The
appropriate sampling device must be selected and its use supervised by a
person thoroughly familiar with both the sampling and analytical requirements.
This familiarity 1s essential since (1) certain sampling devices are made of
materials that may contaminate samples, (2) cross contamination of samples
can occur if the sampling device is not cleaned properly, (3) routine sampling
methods may not.be applicable when the waste is to be analyzed for a different
parameter (e.g., volatile organic compounds), and (3) the method of employing
the sampling devices may affect the Integrity of the sample.
10.3.3 Sample Preservation
Some form of preservation 1s usually required for all samples. The type of
sample preservation required will vary depending on the sample type and the
parameter to be measured. Therefore, more than one container of the same
waste may be necessary 1f the waste is to be analyzed for more than one
parameter type.
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"The analytical methods Included in this manual refer to the optimum
means of preservation. Since the chemical make-up of certain samples can
alter the effectiveness of preservation measures, all sample analyses should
be performed as soon as possible after sampling and before any recommended
holding time has expired.
10.3.4 Chain of Custody
Although chain-of-custody procedures may not be required in all cases,
they often are an essential part of sampling/analytical schemes-since these
procedures can document the history of samples. Chain of custody establishes
the documentation and control necessary to identify and trace a sample from
sample collection to final analysis. Such documentation includes labeling to
prevent mix-up, container seals to detect unauthorized tampering with
contents of the sample containers, secure custody, and the necessary records
to support potential litigation."
A sample is considered to be under a person's custody if (1) it is in the
person's physical possession, (2) in view of the person, (3) secured by
that person so that no one can tamper with the sample, or (4) secured by that
person 1n an area that is restricted to authorized personnel.
Refer to Section One for details of how to implement chain-of-custody
procedures.
10.4 Analysis
An analytical program defines standard operating procedures to be used
1n waste analysis, appropriate QC/QA procedures, means for detecting out-of-
control situations, and remedial actions. A separate analytical program
should be developed for each different waste to be analyzed. The program
should be thoroughly specified before sampling is begun, since the analytical
procedures to be used may affect the choice of sampling devices and procedures.
The program should select methods that will provide data at the level of
accuracy and precision that will be required by users of the data for decision-
making purposes under RCRA. Once the appropriate method(s) have been selected
it is imperative that the accuracy and precision of all analytical data be
thoroughly documented by means of a well-designed QC/QA program.
Laboratory QC/QA activities normally include:
1. Use of EPA-acceptable sample preparation and analytical methods.
2. Calibration of laboratory instruments to within acceptable limits
according to EPA or manufacturer's specifications before, after,
and during (as acceptable) use. Reference standards must be used
when necessary.
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"3. Periodic inspection, maintenance, and servicing (as necessary) of
all laboratory instruments and equipment.
4. The use of reference standards and QC samples (e.g., checks,
spikes, laboratory blanks, duplicates, splits) as necessary to
determine the accuracy and precision of procedures, instruments,
and operators.
5. The use of adequate statistical procedures (e.g., QC charts) to
monitor the precision and accuracy of the data and to establish
acceptable limits.
6. A continuous review of results to identify and correct problems
within'the measurement system (e.g., instrumentation problems,
inadequate operator training, inaccurate measurement methodologies).
7. Documenting the performance of systems and operators.
8. Regular participation in external laboratory evaluations (including
the EPA Performance Audit Program) to determine the accuracy and
overall performance of the laboratory. This should include performance
evaluation and interlaboratory comparison studies, and formal
field unit/laboratory evaluations and inspections.
9. Use of acceptable sample identification and, as necessary, formal
chain-of-custody procedures in the laboratory.
10. Maintenance and storage of complete records, charts, and logs of
all pertinent laboratory calibration, analytical, and QC activities
and data.
11. Ensuring all data outputs are presented in their prescribed format.
Specific Quality Control measures for each method can be found by
referring to the individual analytical methods included in this manual.
10.5 Data Handling
The quality of all data must be assessed before the data are used.
Assessment should focus on five basic points.
1. Accuracy - Can the data's accuracy be determined, and is it
acceptable for the planned use? QC/QA procedures will be designed
to measure the accuracy of all analytical data.
2. Precision - Can the data's precision be determined, and is it
acceptable for the planned use? QC/QA should demonstrate the
reproducibility of the measurement process.
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"3. Completeness - Are a sufficient amount of data available for the
planned use? QC/QA shall Identify the quantity of data needed to
meet the program goals.
4. Representatlveness - How well do the data represent actual
conditions at the sampling location, considering the original
study design, sampling methods, analytical methods, etc., which
were used?
5. Comparability - How comparable are data with respect to several
factors, Including:
- consistency of reporting units?
- standardized siting, sampling, and methods of analysis?
- standardized data format?
All these factors must be considered when designing a study, and QC/QA
procedures must specify a reviewing process for all data.
Statistical procedures applicable to data evaluation Include:
1. Central tendency and dispersion
- Arithmetic mean
- Range
- Standard deviation
- Relative standard deviation
- Pooled standard deviation
- Geometric mean
2. Measures of variability
- Accuracy
- Bias
- Precision; within laboratory and between laboratories
3. Significance test
- u-test
- t-test
- F-test
- Chi-square test
Specific data handling precautions are noted in the individual methods
described in this manual."
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