A GUIDE FOR PREPARING
RCRA PERMIT APPLICATIONS
FOR EXISTING STORAGE FACILITIES
U.S. ENVIRONMENTAL PROTECTION AGENCY
1982
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A GUIDE ?OR PREPARING RC3A
STORAGE PERMIT APPLICATIONS
This preliminary guidance document is intended to
assist the owner or operators of hazardous wast a
storage facilities in developing XCHA Part 3 Perait
Applications. It is being distributed to prospective
permit applicants and others for their review, comment
and use. 'EPA is interested in receiving comments on
the usefulness of the guide and suggestions as to how
it may be improved. It was developed by a contractor
in concert with EPA permit writers in Region I and
Headquarters but has not yet been reviewed by appli-
cants or other persons outside the Agency.
This guide was prepared by •
A. T. Kearney, Inc.
P.O. Box 1405
699 Prince Street
Alexandria, Virginia 22313
and by
PEDCo Environmental, Inc.
11499 Chester Road
Cincinnati, Ohio 45246
USEPA West Duin-niiy
Headquarters Repository
1301 Constitution Avenue NW.
Room 3340 - Mailcode 3404T
Washington, DC 20004
U.S. ENVIRONMENTAL PROTECTION AGENCY
1982
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DISCLAIMER
This Industry Guidance Document has been developed to
assist hazardous waste storage facilities in preparing Part 3 of
the RCSA Permit Application. It is intended that permit appli-
cants will use the document as a guide to prepare their own
applications is a format and level of detail acceptable to the
u'.S. Environmental Protection Agency. The model permit appli-
cation contained in the document was developed for a typical
representative storage facility. Therefore, some sections of
the model may not be applicable to all facilities. The U.S. EPA
urges applicants to contact their EPA Regional Office to discuss
the applicability of this guide to their facility and other
facility-specific requirements.
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PREFACE
The purpose of this guide is to assist hazardous waste
management facilities in the preparation of their RCRA Permit
Applications. Its intent is to provide sufficient information
and detail to enable a facility to submit an application;
however, in some situations certain regulations may not apply to
every facility. When this is the case, the applicable regional
office of the U.S. Environmental Protection Agency should be
contacted to arrange a preapplication meeting to discuss RCRA
permit application needs that are not covered or understood.
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CONTENTS
List of Figures vi
List of Tables ix
Preface iii
PART 1 GUIDANCE MATERIAL 1
Section I INTRODUCTION 1
Section II ADMINISTRATIVE PROCEDURES IN THE PERMITTING
PROCESS 4
Coordination with States 4
Submitting RCRA Part B Permit Applications 6
Claims of Confidentiality 7
EPA's Review of Part B Applications ... 9
Draft RCRA Permits and Permit Denials . . 10
Public Notice, Comments, Informal Public
Hearings, Panel Hearings 11
Final Permits 12
Appeal to the Regional Administrator ... 12
Section III INSTRUCTIONS FOR PREPARATION OF A RCRA PERMIT
APPLICATION 14
RCRA Permit Application Format 14
Suggested Permit Application Format ... 15
Detailed Instructions and Content
Requirements 21
PART 2 MODEL RCRA PERMIT APPLICATION 90
A - Part A Application 91
B - Facility Description 100
C - waste Characteristics 118
D - Process Information 135
E - Ground Water Monitoring Systems . . . 161
F - Procedures to Prevent Hazards .... 162
G - Contingency Plan 181
H - Personnel Training 222
I - Closure Plan, Post-Closure Plan and
Financial Requirements 236
J - Other Federal Laws 254
Certification 255
References 256
IV
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CONTENTS (continued)
Page
Appendix A GENERAL INFORMATION AND HAZARDOUS CHARACTER-
ISTICS OF WASTES 261
Appendix B INSPECTION LOG SHEETS 256
Appendix C TRUST AGREEMENT 278
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FIGURES
Page
1 Flow Diagram of the RCRA Permitting Process 5
2 A Topographical Map of TanJcopile Finishing
Company and Surrounding Area 98
3 Facility Photograph, June 2, 1980 99
4 Facility Hap of Tankopile Finishing Company 102
5 Facility Hap With 5-Foot Contour Intervals of
Elevation (feet HSL) 103
6 Facility Hap Showing 100-Year Floodplain 104
7 Surrounding Land Use ' 106
8 Wind Rose 107
9 Federal Insurance Administration (FIA) 100-Year
Floodplain Map 111
10 Traffic Flow 116
11 Laboratory Analysis Results - 1,1, 1-Trictiloro-
e thane 122
12 Laboratory Analysis Results for Pickle Liquor 123
13 Laboratory Analysis Results for Vinyl Acetate
Sludge 124
14 Laboratory Analysis Results for Vinyl Chloride
Sludge 125
15 Laboratory Analysis Results for Pickle Liquor
Sludge 126
16 Laboratory Analysis Results for Metal Grindings 127
17 Laboratory Analysis Results for Metal Hydroxide
Sludge '128
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FIGURES (continued)
Number
18
19
20
21
22
23
24
25
26
27
. 28
29
30
31
32
33
34
35
36
3-1
B-2
3-3
Plan View of Container Storage Area
Cross-Sectional View of Container Storage Area
Waste Storage Tanks
Process Flow Diagram
Piping and Instrumentation Diagram for Hazardous
Waste Storage in Tanks
Containment System Section
Containment System 'Flan
Log Sheet
Overview of Emergency Plan of Action
Emergency* Plan of Action
Rally Points in the Event of Fire or Explosion
Interceptor Trench
Interceptor Trench (Cross-Section)
Location of Emergency Equipment
Sample Reporting Form for Emergency Events
Organization Chart for Tankopile's HWM
Facility
Outline of Hazardous Waste Training Manual
Level of Training for Hazardous Waste Personnel
Anticipated Closure Schedule
Monitoring Equipment Inspection Log Sheet
Safety and Emergency Equipment Inspection Log
Sheet
Security Devices Inspection Log Sheet
Page
137
138
143
147
149
152
153
164
187
188
191
201
203
210
220
223
228
232
247
267
268
270
Vll
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FIGURES (continued)
Number Page
B-4 Operating and Structural Equipment Inspection
Log Sheet 271
B-5 Container Storage Area Inspection Log Sheet 272
B-6 Tank Storage Area and Ancillary Equipment
Inspection Log Sheet 274
B-7 External Tank Inspection Log Sheet 275
B-8 Internal Tank Inspection Log Sheet 276
B-9 Waste Pile Area Inspection Log Sheet 277
Vlll
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TABLES
Number Page
1 Implicit Price Deflators 1972 Weights, for
Gross National Product 70
2 Waste Pile Construction Schedule 114
3 Wastes, Associated Hazards, and Basis for
Hazard Designation 120
4 Parameters and Rationale for Their Section 129
5 Parameters and Test Methods 130
6 Methods Use to Sample Hazardous wastes 132
7 Frequency of Analysis 134
8 Physical Characteristics of Storage Tanks 144
9 Properties of Chlorinated Polyethylene (CFE)
Oil-Resistant Liner 157
10 Inspection Schedule • 167
11 Emergency Coordinators 183
12 Emergency Contacts 134
13 Materials and Equipment for Spill Containment
and Cleanup 212
14 Closure Cost Estimate 249
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PART 1 GUIDANCE MATERIAL
SECTION I
INTRODUCTION
Under Subtitle C of the Resource Conservation and Recovery
Act of 1976 (RCRA), the U.S. Environmental Protection Agency
(EPA) established regulations to insure the protection of human
health and the environment through the proper management of
hazardous wastes. These regulations require certain facilities
that treat, store, or dispose of hazardous wastes to submit RCRA
permit applications to EPA. These applications should contain
sufficient information to assure that the management practices
at those facilities will provide adequate levels of protection.
This Guide has been written specifically for owners and
operators of storage and treatment facilities that have hazardous
wastes in tanks, containers, or piles. It provides detailed
technical instructions covering the required content of the RCRA
permit applications and explains the administrative procedures
that the EPA will use in the RCRA permitting program.
The intent of this Guide is to minimize the effort and time
required of industry to apply for and obtain RCRA permits. The
detailed explanations provided in this Guide will help to pre-
vent Applicants from developing and presenting more information
than needed to evaluate the applications. The suggested appli-
cation format is presented as a guide for organizing submissions.
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The information presented concerning EPA's administrative
and confidentiality procedures in the RCRA permitting program is
intended to assist applicants in an understanding of Agency
requirements. Ultimately, this Guide should serve to improve
communications and cooperation between industry and the EPA in
the RCRA permitting program and increase the effectiveness and
timeliness with which EPA carries out its regulatory responsi-
bilities.
The second section of this Guide describes the administrative
procedures that will be followed in the RCRA permitting program.
It includes discussions of how applications will be requested,
the two-stage process that EPA will use for reviewing applica-
tions, public participation procedures, permit issuance pro-
cedures, and the timing of these events. This section also
describes the procedures that should be followed in requesting
protection from public disclosure of confidential business
information. It provides details of the types of information
that will receive confidential treatment by EPA and how the
legitimacy of confidentiality claims will be determined.
The third section of the Guide presents an accepted format
for structuring a RCRA permit application and provides detailed
explanations of the information that must be included in the
application.
Part 2 of this document presents an example of a complete
RCRA permit application for a hypothetical storage facility.
Tins example provides a model on which actual applications can
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be based. It is structured to assist RCRA permit applicants in
determining the appropriate level of detail and the proper
presentation of that material. Applicants should be aware,
however, that the level of detail will also be related to the
size and complexity of the facility.
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SECTION II
ADMINISTRATIVE PROCEDURES IN THE PERMITTING PROCESS
This section outlines the activities entailed in applying
for and obtaining a RCRA permit for a hazardous waste management
(HWM) facility (Figure 1). An understanding of these procedures
will allow applicants to deal effectively with EPA in the permit-
ting program.
Most facilities that treat, store, or dispose of hazardous
waste must obtain a RCRA permit. The application for this
permit consists of two parts, Part A and Part B. Certain facili-
ties (i.e., those in existence before November 19, 1980) have
been required to submit Part A. These facilities have been
granted an "interim status" that allows them to'continue to
operate until final administrative action is taken on their
permit. To obtain a RCRA permit, however, these facilities must
submit Part B applications. The EPA Regional Administrators
have the authority to request owners and operators of existing
HWM storage and treatment facilities to submit Part B of their
RCRA permit application, but any facility may submit the Part B
application voluntarily.
Coordination with States
An applicant for a RCRA permit should be aware that the EPA
and the states share responsibilities for the administration of
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Figure 1. Flow diagram of the RCRA permitting process.
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the RCRA permit program. Each state's role in the permitting
process varies according to the status of its authorization to
administer the hazardous waste permit program. Applicants
should familiarize themselves with the state's permitting
process and be aware that EPA permit writers will be communi-
cating with the states at appropriate stages in the permit
process.
Submitting RCRA Part B
Permit Applications
The EPA Regional Office may request submission of Fart B of
the RCRA permit application from an existing facility, or a
facility may voluntarily submit Part B. The letter of request
will generally include a list of the items in Part B that are
applicable to the permit applicant's facility type, a copy of
the Part 264 and Part 122.25 regulations, notice of the appli-
cant's right to claim confidentiality, notice of the right to
question the EPA Regional staff about application requirements
and the names and phone numbers of the appropriate contacts,
information on the number of copies required and where the
applicant is to submit them, and a recommendation that the
applicant contact the appropriate state authority.
An existing facility that has been requested to submit Part
B of the RCRA permit application is allowed at least 6 months to
gather, organize, and send the required data to EPA. During
this time, the facility can contact the EPA Regional Office for
clarification or assistance. Depending on the depth and com-
plexity of the issues, the EPA or the applicant may find it
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useful to schedule a conference. Such a meeting can facilitate
the permitting process by identifying problems early and enabling
the applicant to resolve them.
Claims of Confidentiality
At the time of submittal, applicants for a RCRA permit may
assert a claim of business confidentiality for proprietary
information included in their application. General EPA regula-
tions governing claims of confidentiality are found in Title 40
of the Code of Federal Regulations (40 CFR), Part 2. Specific
provisions for claims of confidentiality submitted with permit
applications are found in 40 CFR 122.19.
In these regulations, "business information" means "... any
information which pertains to the interest of any business,
which was developed or acquired by that business, and which is
possessed by EPA in recorded form." "Commercial information"
refers to processes, operations, style of work, ,or apparatus.
"Financial information" refers to the identity, confidential
statistical data, amount of source of any income, profits,
losses, or expenditures of the applicant.
An applicant may claim that business information is entitled
to confidential treatment for "reasons of business confidentiality."
This includes trade secrets and commercial or financial information,
that, if released, would be likely to cause substantial harm to
the competitive position of the applicant.
Claims of confidentiality must be asserted when the permit
application is submitted. If no claim is asserted at that time,
the EPA may make the information available to the public without
further notice to the applicant.
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To assert a claim, 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 appli-
cant desires confidential treatment only until a certain date or
a certain event.
Prior to releasing any information for which a claim of
confidentiality has been made, the Agency will give the applicant
an opportunity to substantiate its claim and will then determine
whether the information warrants confidential treatment.
Applicants should limit their requests for confidential
treatment to such material that if released, is likely to cause
substantial harm to the.competitive position of their respective
companies. Claims of confidentiality should not be asserted for
information that is reasonably obtainable without the applicant's
consent (for example, standard engineering designs). It is
important not to claim confidentiality for the entire permit
application, as such claims will significantly delay the permit-
ting process.
Whenever possible, the applicant should separate the informa-
tion contained in the application into confidential and nonconfiden-
tial 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
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confidential and nonconfidential units may result in significant
delays in processing the permit application because the EPA
lacks the in-house resources for expeditiously separating out
the information entitled to confidential treatment.
EPA's Review of
Part B Applications
When the EPA Regional Office receives a RCRA permit applica-
tion, it reviews the application for administrative and technical
completeness. The administrative review involves a check of the
timeliness of the submittal, general data items, correct signa-
tures, and certification of relevant technical data by registered
professional engineers.
If the application is incomplete, the EPA requests the
missing information through a "Notice-of Deficiency" (NOD)
letter. This letter details the information needed to complete
the application and specifies the date for submission of these
data. When the EPA has received all the necessary information,
they will notify the applicant in writing that the application
is complete.
The EPA then performs a technical review of the application
to determine whether the facility under review has satisfied the
requirements of the standards promulgated under Title 40 of the
Code of Federal Regulations (40 CFR), Part 264, and should be
granted a RCRA permit. A site inspection may be conducted
during the RCBA permit application review process to verify the
information contained in the application.
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The Agency may choose to use state officials or a contractor
to provide technical expertise and assist in the technical
review of a permit application or to conduct onsite visits to
verify information pertinent to the issuance or denial of a RCRA
permit.
Draft RCRA Permits and Permit Denials
Upon completion of the technical review, the EPA Regional
Administrator tentatively decides whether to issue or deny a
RCRA permit. If the tentative decision is to issue the permit,
the EPA regional staff prepares a draft permit for public review.
The draft RCRA permit specifies all the limitations, require-
ments, and conditions to be placed on the facility. The Regional
Office also prepares a "fact sheet" or "statement of basis,"
which explains in simple language the reason for each condition
included in the draft permit.
When writing a RCRA permit, the EPA may specify a schedule
for compliance rather than requiring the facility to be in full
compliance at the time of permit issuance. A compliance schedule
allows the facility to operate while it is upgrading its opera-
tions to meet all the regulatory requirements. Such a compliance
schedule is used only when it is clear that temporary noncompliance
will have no unacceptable effects on human health or the environment.
In its decision regarding a schedule for compliance, the Agency
also considers such factors as availability of any materials
required to upgrade the facility, construction time, and the
time required to contract for such services.
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A permit may be denied if it is determined that an applicant
cannot meet the requirements of the standards set forth in 40
CFR 264, that activities at the facility will endanger human
health or the environment, or that an applicant either has not
fully disclosed all relevant facts in the application or during
the RCRA permit issuance process or has misrepresented any
relevant facts at any time.
If the Regional Administrator tentatively decides to deny a
RCSA permit, a notice of intent to deny a permit is prepared.
This notice is considered a type of draft permit and follows the
same procedures as any draft permit. These procedures include
preparation of a statement of basis or fact sheet containing
reasons supporting the tentative decision to deny the permit,
public notice of the denial, acceptance of comments, a possible
hearing, preparation of a final decision, and possible receipt
of a request for appeal.
Public Notice, Comments, Informal
Public Hearings, Panel Hearings
All draft RCSA permits are subject to public notice, public
comments, and public hearing (if the Regional Administrator
finds a significant degree of public interest). Public notice
provides interested persons a minimum of 45 days to comment on
the draft permit.
If written opposition to the Agency's intent to issue a
permit and a request for a hearing are received during the
comment period, a public hearing will be held. Notification of
the hearing is issued at least 30 days prior to the scheduled
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date, and the public comment period is extended until the close
of the public hearing.
The EPA Regional Office also has the option of conducting
more formal "panel hearings" when the issuance of a draft RCRA
permit is complicated enough to justify such a proceeding.
Also, any person may request a panel hearing. The panel hearing
enables the EPA to obtain facts on objectionable aspects of the
draft permit and to receive evidence to support suggested alter-
native permit conditions and to aid in the preparation of a
final decision on a permit.
Final Permits
After the close of the public comment period (which includes
the public hearing period or any panel hearing), the Regional
Office either prepares and issues a final RCRA permit or denies
the permit application. In either case, the applicant and
interested parties will receive public notice, which includes
information regarding appeal procedures. Unless a later date is
specified, uncontested terms and conditions of the draft RCRA
permit become effective 30 days after the date of the public
notice. At the time the final RCRA permit is issued, the Regional
Office also issues a response to any significant public comments
received and indicates any provisions of the draft permit that
have been changed and the reasons for the changes. The response
to comments becomes part of the administrative record.
Appeal to the Regional Administrator
Persons who submitted comments on the draft RCRA permit or
participated in any public hearing are allowed 30 days after the
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final permit decision to file a notice of appeal and a petition
for review with the Regional Administrator. The Regional Admin-
istrator then grants or denies the petition within a reasonable
time. If the Administrator decides to conduct a review, the
parties are given the opportunity to file briefs in support of
their positions, within the 30-day period, the Administrator
also may decide to review the decision to grant or deny a hearing
on his/her own motion. The Administrator then notifies the
parties and sets up a briefing schedule. On review, the Admin-
istrator has several options regarding the final decision. It
may be summarily affirmed without opinion, modified, set aside,
or remanded for further proceedings. This petition for review
by the Administrator is a prerequisite for judicial review of
the Administrator's final decision.
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SECTION III
INSTRUCTIONS FOR PREPARATION OF A
RCRA PERMIT APPLICATION
This section attempts to simplify preparation of a RCRA
permit application by describing in detail the information
required. It also includes a suggested permit application
format. The information presented is based on RCRA regulations
dealing with Part B permit requirements (40 CFR 122.25) and the
technical standards in 40 CFR 264. Using the suggested format
and meeting the detailed requirements should enable the applicant
to complete the RCBA permit application in a timely and cost-
effective manner. When submitting an application, the applicant
should be sure that the document is presented in a manner that
will allow for major and minor revisions during the subsequent
review by EPA (e.g., a three-ring binder).
RCRA Permit Application Format
The suggested permit application format presented in the
following pages includes all information required for a permit
application. Most sections of the application must be completed
by all facilities, but a few sections do not apply to certain
facilities. For example, existing facilities need not address
the seismic standards in Section B - Facility Description. The
applicability of such sections is indicated in the narrative
that follows the outline.
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The format and explanations presented in this section are
supplemented by a model RCRA permit application for a hypotheti-
cal plant, which appears as Part 2 to this document. This
model carefully follows the outline and provides a practical
illustration of how to approach the RCBA permit application
process.
Suggested Permit Application Format
A. Part A Application
B. Facility Description
B-l General description [40 CFR Section 122.2S(a)(l)]
B-2 Topographic map [40 CFR Section 122.25(a)(19)]
3-3 Location information [40 CFR Sections 122.25(a)(11),
and 264.18]
3-3a Seismic standard (reserved)
B-3b Floodplain standard
B-3b(l) Demonstration of compliance
B-3b(l)(a) Flood proofing and flood protection
measures
B-3b(l)(b) Flood plain
B-3b(2) Plan for future'compliance
B-4 Traffic patterns [40 CFR Sections 122.25(a)(10)]
C. Waste Characteristics
C-l Chemical and physical analyses [40 CFR Sections 122.25(a)
(2) and 264.13U))]
C-2 Waste analysis plan [40 CFR Sections 122.25(a)(13) and
264.13(b) and (c)]
C-2a Parameters and rationale
C-2b Test methods
C-2c Sampling methods
C-2d Frequency of analyses ...
C-2e Additional requirements for waste generated offsite
D. Process Information
D-l Containers [40 CFR Sections 122.25(b) (1), 264.171,
264.172, 264.173, 264.175 and 264.176]
D-la Containers with free liquids
D-la(l) Description of containers
D-la(2) Container management practices
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Suggested Permit Acnlication Format (continued)
D-la(3) Secondary containment system design and
operation
D-la(3)(a) Requirement for base to contain
liquids
D-la(3)(b) Containment system drainage
D-la(3)(c) Containment system capacity
D-la(3)(d) Control of run-on
D-la(4) Removal of liquids from containment system
D-lb Containers without free liquids
D-lb(l) Test for free liquids
D-lb(2) Description of containers
D-lb(3) Container management practices
D-lb(4) Container storage area drainage
D-2 Tanks [40 CFR Sections 122.25(b)(2), 264.191, 264.192]
D-2a Description of tanks
D-2b Tank corrosion and erosion
D-2c Tank management practices
D-3 Wastes piles [40 CFR Sections 122.25(b)(4), 264.250,
264.251, 264.252, 264.253]
D-3a Waste piles with free liquids
D-3a,(l) Control of wind dispersal
D-3a(2) Control of run-on
D-3a(3-) Collection of leachate and runoff
D-3 a(4) Foundation
D-3a(5) Waste pile base
D-3a(5)(a) Containment system design
D-3a(5)(b) Leachate detection, collection, and
removal system
D-3a(6) Vegetation and rodent control
D-3a(7) Equipment and procedures for waste pile
movement
D-3b Waste piles without free liquids
D-3b(l) Test for free liquids
D-3b(2) Control of wind dispersal
D-3b(3) Protection from precipitation and run-on
D-3b(4) Demonstration that no free liquids are
placed on pile
D-4 Surface impoundments
D-5 Incinerators
£. Ground Water Monitoring Systems (Reserved)
F. Procedures to Prevent Hazards
F-l Security [40 CFR Sections 122.25(a)(4) and 264.14]
F-la Security procedures and equipment
F-la(l) 24-hour surveillance system
F-la(2) Barrier and means to control entry
F-la(2)(a) Barrier
F-la(2)(b) Means to control entry
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Suogested Permit Application Format (continued)
F-la(3) Warning signs
F-lb Waiver
F-lb(l) Injury to intruder
F-lb(2) Violation by intruder
F-2 Inspection schedule [40 CFR Sections 122.(a) (5), 264.15,
264.33, 264.174, 264.194, 264.254, 264.255]
F-2a General inspection requirements
F-2a(l) Types of problems
F-2a(2) Frequency of inspection
F-2b Specific process inspection requirements
F-2b(l) Container inspection
F-2b(2) Tank inspection
F-2b(2)(a) Construction materials
F-2b(2)(b) Surrounding area
F-2b(2)(c) Overfilling control equipment
F-2b(2)(d) Monitoring data
F-2b(2)(e) Level of waste
F-2b(2)(f) Tank condition assessment
F-2b(2)(g) Tank interior inspection
F-2b(3) Waste pile inspection
F-2b(3)(a) Liner systems
F-2b(3)(b) Manufactured liner materials
F-2b(3)(c) Containment system
F-2c Remedial action
F-2d Inspection log
F-3 waiver of preparedness and prevention requirements [40
CFR Sections 122.25(a)(6), 264.32, and 264.35]
F-3a Equipment requirements
F-3a(l) Internal communications
F-3a(2) External communications
F-3a(3) Emergency equipment
F-3a(4) Water for fire control
F-3b Aisle space requirement
F-4 Preventive procedures, structures, and equipment [40 CFR
Section 122.25(a)(8)]
F-4a Loading/unloading operations
F-4b Runoff
F-4c Water supplies
F-4d Equipment and power failure
F-4e Personnel .protection equipment
F-5 Prevention of reaction of ignitable, reactive, or
incompatible wastes [40 CFR Sections 122.25(a)(9),
122.2S(b)(l)(iii), 122.25(b)(2)(vi), 122.25(b)(4)
(1)(C)(4), 122.25(b)(4)(il)(b)(l),-264.17, 264.21,
264.23, 264.176, 264.177, 264.198, 264.199, 264.256,
264.257]
F-5a Precautions to prevent ignition or reaction of
ignitable or reactive wastes
F-5b General precautions for handling ignitable or
reactive wastes or accidently mixing incompatible
wastes
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Suggested Permit Application Format (continued)
F-5c Management of ignitable or reactive wastes in
containers
F-5d Management of incompatible wastes in containers
F-5e Management of ignitable or reactive wastes in
tanks
F-5f Management of incompatible wastes in tanks
F-5g Management of ignitable or reactive wastes in
waste piles
F-5h Management of incompatible wastes in waste piles
G. Contingency Plan
G-l General information [40 CFR Section 122.25(a)(7)]
G-2 Emergency coordinators [40 CFR Sections 122.25(a)(7),
264.52(d)/ and 264.55]
G-3 Implementation of the contingency plan [40 CFR Sections
122.25(a)(7), 264.51(b)]
G-4 Emergency response procedures [40 CFR Sections 122.25(a)
(7), 264.52(a), 264.56, 264.171, 264.194{c), 264.255,
and 264.258]
G-4a Notification
G-4b Identification of hazardous materials
G-4c Assessment
G-4d control procedures
G-4e Prevention of recurrence or spread of fires,
explosions, or releases
G-4f Storage and treatment of released material
G-4g Incompatible wastes
G-4h Post-emergency equipment maintenance
G-4i Container spills and leakage
G-4j Tank spills and leakage
G~4k Waste piles
G-4k(l) Indication of waste pile containment system
failure
G-4k(2) Elements of a containment system evaluation
and repair plan
G-4k(3) Criteria and procedures for removal of waste
pile from service in the case of positive
failure of the containment system
G-4k(4) Restoration of a waste pile to service
G-4k(5) Course of action after waste pile is removed
from service
G-5 Emergency equipment [40 CFR Sections 122.25(a)(7) and
264.52(e)]
G-6 Coordination agreements [40 CFR Sections 122.25(a) (7),
264.52(c) and 264.37]
G-7 Evacuation plan [40 CFR Sections 122.25(a)(7), 264.52(f)]
G-8 Required reports [40 CFR Sections 122.25(a)(7), 264.S6(d),
264.56(i), and 264.73(b)(4)]
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Suoaested Permit Acolication Format (continued)
H. Personnel Training
H-l Outline-of training program [40 CFR Sections 122.25(a) (12 )
and 264.16]
H-la Job titles and duties
H-lb Training content, frequency, and techniques
H-lc Training director
H-ld Relevance of training to job position
H-le Training for emergency response
H-le(l) Procedures for using, inspecting, repairing,
and replacing facility's emergency and
monitoring equipment
H-le(2) Key parameters for automatic waste feed
cutoff systems
H-le(3) Communications on alarm systems
H-le{4) Response to fires
H-le(5) Response to groundwater contamination
incidents
H-le(6) Shutdown of operations
H-2 Implementation of training program [40 CFR Sections
122.2S(a)(12) and 264.16]
I. Closure Flans, Post-Closure Plans and Financial Requirements
1-1 Closure plans [40 CFR Sections 122.25(a)(13), 264.111,
264.112, 264.113, 264.178, 264.197, and 264.258
I-la Closure performance standard
I-lb Partial closure
I-lc Maximum waste inventory
I-ld Disposal or decontamination of equipment
I-ld(l) Closure of containers
I-ld(2) Closure of tanks
I-ld(3) Closure of waste piles
I-le Schedule for closure
I-If Extensions for closure time
1-2 Post-closure plans*
1-3 Motice in deed and notice to local land authority*
1-4 Closure cost estimate [40 CFR Sections 122.2S(a)(15)
and 264.142]
1-5 Financial assurance mechanism for closure [40 CFR
Sections 122.25(a)(l), 264.143, and 264.151]
I-5a Closure trust fund
I-5b Surety bond
I-5c Closure letter of credit
I-5d Closure insurance
I-5e Financial test
I-5f Combinations
These items apply only to disposal facilities.
19
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Suggested Permit Application Format (continued)
I-5f(l) Multiple financial mechanisms
I-5f(2) Use of financial mechanism for multiple
facilities
I-5g Proof of financial coverage by an equivalent state
financial mechanism
1-6 Post-closure cost estimate*
1-7 Financial assurance mechanism for post-closure*
1-8 Liability requirements [40 CFR Sections 122.25(a)(17),
264.147, and 264.151]
I-8a Sudden insurance
I-8b Non-sudden insurance**
I-8c Financial test for liability insurance
I-3d Variance procedures
I-de Adjustment procedures
1-9 State mechanisms
I-9a Use of state-required mechanisms [40 CFR Sections
122.25(a)(18), 264.149, and 264.150]
I-9b State assumption of responsibility
J. Other Federal Laws [40 CFR Sections 122.12 and 122.25(a)(20)
K. Certification [40 CFR Sections 122..6(a) and (d)]
* These items apply only to disposal facilities.
** Required for surface impoundments, landfills, or land treatment
facilities.
20
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Detailed Instructions and Content Requirements
The detailed instructions provided herein encompass the
content requirements of each permit section identified in the
suggested RCRA Permit Application Format and cites the Federal
regulation from which they were developed.
Sources of information applicants may use to prepare por-
tions of the permit application are identified by reference
numbers in parentheses at the end of each section.
Certain technical data submitted in the permit application
must be certified by a registered professional engineer; these
include design drawings and specifications and engineering
studies.
A. PART A APPLICATION [CFR Sections 122.4(d) and 122.24]
Submit a revised Part A application if corrections to your
original submission are necessary because of changes at
your facility, inaccuracies in your submission, or changes
»
in the RCRA regulations. Unless a revised Part A application
is received, your original submittal will be used for
review purposes.
B. FACILITY DESCRIPTION
B-l General Description [40 CFR Section 122.25(a)(1)]
Provide a general description of the hazardous waste manage-
ment facility in sufficient detail to familiarize the
reviewer with its overall operation. Include the facility
name, contact, mailing address, and location. Briefly
21
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describe the nature of the business (e.g., products or
services offered). Provide a company brochure if one is
available. Offsite facilities should identify the types of
industries serviced. Onsite facilities should briefly
describe the process(es) involved in the generation of
hazardous waste (Reference 1).
B-2 Topographic Map [40 CFR Section 122.25(a)(19) ]
Submit a topographic map with a scale in which 1 inch
equals no more than 200 feet and with contour intervals
that are sufficient to clearly show the pattern of surface
water flow in the vicinity of the hazardous waste units.
The map must cover an area extending 1000 feet beyond the
facility property line. The map(s) oust show the scale,
date, 100-year floodplain area, surface waters (including
intermittent streams) and direction of their flow, surround-
ing land uses, a wind rose, wind speed and direction, map
orientation, legal property line boundaries of the facility,
access control, injection and withdrawal wells, buildings,
structures, the location of each intake and discharge
structure, sewers, loading and unloading areas, fire control,
flood control or drainage barriers, and location of hazard-
ous waste operations units. More than one map may be used
to indicate the items listed above. On- a case-by-case
basis the Agency may accept maps with contour intervals or
scales other than those specified in the regulations.
Consult your EPA or state agency for further guidance.
22
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The Part B topographic map will differ from the map
submitted with the Part A of the application in area of
coverage and level of detail (References 2, 3, 4, 5, 6, 7,
8).
B-3 Location Information
3-3a Seismic Standard [40 CFR Section 264.18(a) and 122.25(a)(11)
(i) and (ii)]
Existing facilities are not required to comply with the
seismic standards.
B-3b Floodplain Standard [40 CFR Sections 122.25(a) (11)(ill)
and 264.13(b)]
Provide documentation identifying whether the facility is
located within a 100-year floodplain. The Federal Insur-
ance Administration, through the National Flood Insurance
Program,* is the prime supplier of floodplain maps. Other
Federal agencies (e.g., the U.S. Army Corps of Engineers,
the Soil Conservation Services, and the U.S. Geological
Survey) supply maps or information that will help you
determine the boundaries of the 100-year floodplain. If
FIA maps are not available, equivalent mapping techniques
must be used. Facilities located within the 100-year
floodplain must identify the 100-year flood level and any
other special flooding factors (e.g., wave action) that
must be considered to prevent washout (References 9, 10, 3,
4, 5, 7, 8, 11)!
National Flood Insurance Program, P.O. Box 34294, Bethesda,
Maryland 20034.
23
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B-3b(l) Demonstration of Compliance [40 CFR Section 122.25(a)(11)
(iv)]
If your facility is located within the 100-year floodplain,
describe how.the facility is designed, constructed, oper-
ated, and maintained to prevent washout of any hazardous
waste in the event of a flood by either of the following
methods.
B-3b(l)(a) Flood Proofing and Flood Protection Measures [40 CFR
Section 122.25(a)(ll) iv (A) and (B)]
Provide structural or other engineering studies showing the
design of the tanks, containers, or waste piles and the
flood-proofing and protection devices (i.e., freeboard,
fencing, diversion structures) at the facility and how they
will prevent washout. The study should include an analysis
of the structural integrity of the waste units and/or the
flood protection devices to withstand the various hydro-
dynamic and hydrostatic forces expected as a result of a
100-year flood (References 10, 12, 13, 14, 15, 16, 17, 18,
19, 20, 21, 22, 23, 24, 25).
B-3b(l)(b) Flood Plan [40 CFR Section 122.25(a)(ll)(iv)(C)]
Describe the procedures for removing hazardous waste to
safety before the facility becomes flooded. Include the
timing of such movement related to flood levels (including
estimated time to move the waste) to show that it can be
completed before floodwaters reach the facility; a des-
cription of the location(s) to which the waste will be
moved and proof of the eligibility of these locations to
24
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receive hazardous wastes (i.e., RCRA Interim Status Facili-
ties or RCBA Permitted Facilities); the planned procedures,
equipment, and personnel to be used and the means of ensuring
that these resources will be available when needed; and tne
potential for accidental discharges of the wastes during .
movement .
B-3b(2) Plan for Future Compliance (40 CFR Section 122.25(a)
If your facility is not in compliance with the floodplain
regulation, provide a plan showing how and when it will be
brought into compliance. (Existing facilities located in
the 100-year floodplain that do not have a flood plan or
are not designed to withstand a washout are not in compli-
,1
ance with the floodplain regulations . )
B-4 Traffic Patterns [40 CFR Section 122.25(a) (10) ]
Describe the means of transporting hazardous waste material
on your facility's property; include traffic pattern,
traffic control, and estimated volume. List the weight of
trucks transporting hazardous waste (state the maximum
weight of fully loaded trucks), the load bearing capacity
of the roads, and the road surfacing.
For facilities receiving hazardous waste from off site, also
describe the movement of the waste material to the facility
from the point where it leaves the nearest major highway.
°rovide a diagram indicating traffic route, traffic controls,
and land use (commercial or residential streets) (Reference
26).
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C. WASTE CHARACTERISTICS
C-l Chemical and Physical Analyses [40 CFR Sections 122.25(a)
(2) and 264.13(a) J
Provide the following information on each hazardous waste
stored or treated at the facility: (1) general descrip-
tion; (2) hazardous characteristics (corrosive, toxic,
ignitable, reactive); (3) basis for hazardous designation.
(For a listed waste, identify the EPA hazardous waste
number; for an ignitable waste, specify the flash point;
for a reactive waste identify under what conditions the
waste reacts; for a corrosive waste, identify pfi; for an EP
toxic waste, identify the E? toxic constituents and their
concentrations.)
Include a copy of the laboratory report(s) detailing chemi-
cal and physical analyses of representative samples of the
hazardous waste, and give the date these analyses were
performed. The analyses may include existing published or
documented data on the hazardous waste or on hazadous
wastes generated from a similar process. Offsite facili-
ties may submit information supplied by the generator
(References 27, 28, 29, 30).
C-2 Waste Analysis Plan (40 CFR Sections 122.25(a)(3) and
264.13(b) and (c)J
Provide a copy of the waste analysis plan indicating how
the facility will ensure that analysis of hazardous waste
is accurate and up to date (i.e., that includes any changes
26
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in the process that generated the hazardous waste) (Refer-
ences 1, 3, 28, 45). The plan should include a description
of how the waste analyses will be performed; a list of the
parameters chosen for analysis and an explanation of the
rationale for their selection; a description of the test
methods used to test for the chosen parameters;11' a list of
the sampling methods used to obtain a representative sample
of each waste;* a description of the frequency at which the
analyses will be repeated; and for facilities handling
waste generated offsite, a description of the procedures
used to inspect and/or analyze wastes generated offsite
(including procedures to determine their identity and the
sampling methods used).
D. PROCESS INFORMATION
0-1 Containers
D-la Containers with Free Liquids
D-la(l) Description of Containers [40 CFR Sections 264.171 and
264.172]
Describe the facility's primary containment devices for
hazardous waste storage. The description should include
types, dimensions (including usable volume), and liner
specifications, and whether the containers are new, reused.
Refer to methods in EPA S.W. 846, Test Methods for Evaluating
Solid Wastes, Physical/Chemical Methods or 40 CFR Part 261,
Appendix I, II, and III where applicable.
27
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recycled, or reconditioned. Include container manufac-
turer's specifications, if available. Types of containers
can include, but are not restricted to, metal drums, fiber
drums, barrels, Jcegs, bags, multiwall paper, polyethylene
(PE) film, small bags, pouches, folding boxes, corrugated
cartons, bulk boxes, carboys, plastic drums, bottles, cans,
pails, and wrap materials. Indicate container markings (in
the form of labels, placards, tags, or stencils). Document
the compatibility of the waste(s) with the storage container(s)
in use at the facility. This documentation can consist of
references to published scientific or industrial engi-
neering literature, data from trial tests (e.g., bench-scale
or pilot-scale tests), waste analyses, or the results of
the storage or treatment of similar wastes under comparable
operating conditions, when information on experience with
similar wastes and materials (structural materials and
linings) is not available, corrosion tests are highly
recommended. Only wastes that significantly accelerate
corrosion or deterioration (as opposed to normal expected
container corrosion) are considered incompatible with the
containment material.
D-la(2) Container Management Practices [40 CFR Section 264.173]
Describe what container management practices are used to
ensure that containers holding hazardous waste are always
closed during storage (except when adding or removing
waste). Provide assurance that containers are not opened,
handled, or stored in a manner that may rupture the container
28
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or cause it to leak. Include a detailed exhibit (facility
drawing) and discussion of the container storage area. The
facility drawing must show the layout of the container
arrangement for both outdoor and indoor locations. Specify
the maximum number of containers in the storage area, the
type and volume of containers to be stored, separation and
aisle spacing distances, and the location of various waste
types. Clearly show the storage locations of incompatible,
reactive, and ignitable wastes. Also indicate possible
ignition sources of the facility (e.g., open flames). If
containers are stacked, indicate the maximum number of
containers and the height of the containers. Also, distin-
guish between the location of container storage areas and
container staging areas by clearly defining the design,
function, and operation of the staging areas. On the
facility drawing of outdoor storage areas, indicate loca-
tions that typically receive full sunlight. Describe the
machinery, equipment, and procedures used to move containers
containing hazardous waste to and within storage locations.
Indicate the frequency with which storage containers con-
taining hazardous waste are opened to add or remove waste
during the container's useful storage life at the facility.
If a system of tracking the age of drums and other con-
tainers is included in the container storage management
practices, state whether the dates are actually marked on
the drums and other containers or placed on the schematic
of the container storage area.
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D-la(3) Secondary Containment System Design and Opera-
tion [40 Cm Sections 122.25(b)(l) and 264.175(b)]
Describe the design and operation of the secondary contain-
ment system in the container storage area. The description
should clearly demonstrate the system's adequacy to hold
spills, leaks, and precipitation until detection and removal.
Include a drawing of the secondary containment system
design; show the dimensions of the containment system,
location of the storage area containers on the base/liner,
leachate collection system, slope characteristics, base
grading, height of auxiliary structures (curbs, dikes,
berms, ditches, trenches), and the location of the sump or
collection area.
D-la(3)(a) Requirement for Base or Liner to Contain Liquids
[40 CFR Section 264.175(b)(1)]
Demonstrate that the containers of free liquids are located
on a base free of cracks or gaps and sufficiently imper-
vious to contain leaks, spills, and accumulated preci-
pitation until the collected material is detected and
removed. Include the base or liner characteristics and
specifications for all concrete, asphaltic, and membrane
linings. Indicate the construction material used for the
base or liner, provide liner/base manufacturer's specifica-
tions and information, and include engineering data used as
the basis for construction of the base. This information
should be sufficient to verify that the base material and
thickness are adequate to support the weight of the containers
Document that the types of waste stored are compatible with
the liner or base to be used.
30
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D-la(3)(b) Containment System Drainage [40 CFR Sections 122.25(b)
(l)(l)(3) and*264.175(b)(2)]
If the containers are stored in direct contact with the
base, state how the base is sloped or how the containment
system is otherwise designed and operated to drain and
remove liquids resulting from leaks, spills, or precipita-
tion. Included in the various designs that comply with
this requirement are drains that lead into a sump under the
base, a sloped base that directs liquids into a sump, or a
system by which accumulated liquids are pumped out of the
containment area shortly after being detected. If the
containers are elevated or otherwise protected from contact
with accumulated.liquids (i.e., a roof over the drain
area), you only need to describe the storage practice used
to accomplish this protection (i.e., how containers are
stacked on pallets, plywood sheets, and/or racks).
D-la(3)(c) Containment System Capacity [40 CFR Sections 122.25(b)
. (l)(i)(C) and 264.17S(b)(3)]
Document that the containment system has sufficient capac-
ity to contain 10 percent of the volume of all the containers
or the volume of the largest container, whichever is greater.
Describe how the containment system has fared during extreme
precipitation events.
D-la(3)(d) Control of Run-On [40 CFR Sections 122.25(b)(1)(i)(D)
and 264.175(b)(4)]
Describe how run-on into the containment system is pre-
vented, unless the collection system has sufficient capac-
ity in excess of that required in the previous "Containment
31
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System Capacity" discussion [D-la(3)(c)J to contain any
run-on that might enter the system. Describe the role of
containment system auxiliary structures and other engi-
neering land-grading designs in preventing run-on into the
containment system, and in promoting drainage away from the
containment area (e.g., drain tiles installed at the out-
side perimeter of the containment curb to drain any col-
lected water to the sewer system).
D-la(4) Removal of Liquids from Containment System [40 CFR Sec-
tions 122.2S(b)(l)(i)(E) and 264.175(b)(5) ]
Describe how spilled or leaked waste and accumulated preci-
pitation will be removed from the collection area or sump
in as timely a manner as is necessary to prevent overflow
of the collection system. Include sump pump design and
operating capabilities, piping specifications, and dia-
grams-. Describe the management procedures for accumulated
liquids and the ultimate fate of such liquids removed from
the containment system.
D-lb Containers Without Free Liquids
D-lb(l) Test for Free Liquids [40 CFR Section 122. 25 (b)
Describe the test procedures and results or provide other
doc'.ja'sntation or information to show that the containerised
wastes do not contain free liquids.
A proposed test protocol for free liquids is provided on
page 8311 of the February 25, 1982, Federal Register. The
protocol calls for a representative sample of the waste
32
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from a container to be filtered and the filtrate to be
collected in a beaker or cylinder. If free liquid passes
through the filter, then the waste is considered to hold
free liquids.
D-lb(2) Description of containers [40 CFR Sections
264.171 and 264.172]
Provide a description similar to the one used for free
liquid containers, D-la(l).
D-lb(3) Container Management Practices [40 CFR Section 264.173]
Provide a description of container management practices
similar to the one used for free liquid containers, D-la(2).
D-lb(4) Container Storage Area Drainage [40 CFR Sections
122.2S(b)(l)(ii)(B) and 264.175(c)]
Provide a description of the container storage area drain-
age similar to the one used for free liquid containers,
D-la(3)(b).
D-2 Tanks
D-2a Description of Tanks [40 CFR Sections 122.25(b) (2)
and 264.191
Describe all facility storage, overflow, and processing
tanks used for hazardous waste management. The description
should include the number and types of tanks, the type of
waste they contain, and whether the tanks are covered. In-
clude manufacturer's literature or other engineering infor-
mation, if available. Tank design specifications should
include specific data on dimensions (height, diameter,
33
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measured uniform shell thickness), capacity, and the mate-
rial and method of construction. Include design operating
temperature and pressure information. State that the tanks
are designed in accordance with the design standard codes
of the American Petroleum Institute (API), the American
Society of Mechanical Engineers (ASME), Underwriters'
Laboratories, the American Concrete Institute standard, or
some other standard design code. Provide the applicable
standard code section and year. Indicate the specific
gravity of the liquid in the tanks and the maximum height
of the liquid level in the tank(s) during storage.
Provide detailed engineering drawings for each tank con-
taining a hazardous waste. Give specifications for the
foundation, structural support, seams, and pressure controls
to demonstrate that the tanks will not collapse or rupture.
D-2b Tank Corrosion and Erosion [40 CFR Sections 122.25(b) (2)(n)
• and 264.192(a)]
Describe the lining and coating materials (if any) used to
protect tank construction materials from corrosion or
erosion. Demonstrate the compatibility of the hazardous
waste with the tank construction and the lining and coating
materials. This documentation can consist of references to
published scientific or industrial engineering literature,
data from trial tests (e.g., bench-scale or pilot-scale
tests), waste analyses, or the results of the storage or
treatment of similar wastes under comparable operating
conditions. When information on experience with similar
34
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wastes and materials (structural materials and linings) is
not available, corrosion tests are highly recommended.
Provide information on the type of gaskets in use and their
material of construction. Describe how the shell thickness
will be maintained when the tank is built or converted to
store hazardous waste. . Provide information on the rate of
tank corrosion or erosion actually detected by measurement.
Include information about any treatment reagents used in
all of the facility tanks.
D-2c Tank Management Practices [40 CFR Sections 122.25(b)(2)(iv),
122.25(b)(2)(v) and 264.192(b)]
Describe tank operating practices and control devices to
prevent overfilling and overtopping. For covered tanks,
submit engineering process flow diagrams indicating the
location, numbers, and types of pressure and overfilling
controls and feed systems. For uncovered tanks, submit
engineering process flow diagrams indicating the location
and operational practices of the safety cutoffs or bypass
systems and the amount of freeboard. Describe what moni-
toring will be done to ensure that each tank is operated
according to design. Describe the procedures used to
measure the following process variables: temperature of
waste, pressure, flow level, and specific gravity; indicate
how frequently these measurements are taken. The process
flow diagram should show the flow direction of liquid or
vapor within the facility and (if available) flow rates.
The flow diagram must -indicate any waste streams in the
35
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flow process that vent directly to the atmosphere or dis-
charge directly to the municipal wastewater treatment
system.
Provide a piping and instrumentation diagram (P&ID) that
shows instruments such as valves, level and pressure con-
trols, and temperature and pressure indicators that are
used to control and monitor the operation of the tanks.
Provide a plot plan of the facility with each piece of
equipment (drawn to scale), and locate each piece of equip-
ment in relation to the entire facility. Include the
location of tank diking and drainage systems for tanks,
space requirements between equipment, and receiving areas
for wastes.
D-3 Waste Piles
D-3a waste Piles with Free Liquids [40 CFR section
'122.2S(b)(4)(i)]
D-3a(l) Control of Wind Dispersal [40 CFR Sections 122.25(b)(4)
(i)(A), 264.251(a) and 264.2S2(a)]
For each waste pile, describe the technique(s) for control-
ling wind dispersal. Include such considerations as waste
pile siting; pile slope design and compaction; the use of
water sprays, dust suppressants other than water, and
stabilizers; windbreaks; and enclosures (if they are used
as waste pile management techniques for control of wind
dispersal). If the waste pile is situated in a totally
enclosed building, describe the dust evacuation method.
36
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D-3a(2) Control of ' Sun-on [40 CFS Sections 122.25(b)(4)(3) (1)
and 264.252(b)]
Describe measures for preventing water from flowing into
the pile. Discuss the diversion of run-on by describing
the location and construction of such structures as benns,
dikes, walls, curbs, trenches, or other manmade or natural
barriers in the waste pile area.
D-3a(3) Collection of Leachate and Runoff [40 CFR Sections
122.25(b)(4)(B)(2), 122.2S(b)(4)(i)(C)(2), 264.2Sl(b),
264.252(b) and 264.253U) (1) ]
Describe the waste pile leachate and runoff collection and
control system. Show how accumulated leachate and precipi-
tation will be removed from the collection area or sump as
necessary to prevent overflow of the leachate collection
system. Include sump pump design and operating capabili-
ties, piping specifications, and diagrams. Indicate the
leachate management procedures and the ultimate fate of
accumulated liquids removed from the containment system.
D-3a(4) Foundation [40 CFR Sections 122.25(b) (4)(B) (3 ) and
264.253(b)(2)j
Provide engineering data to demonstrate that the foundation
is capable of holding the weight of the base or liner, the
pile, and any equipment to be used. Also describe the
foundation construction material (i.e., soil, concrete, or
asphalt). (Refer to the Model Permit Application, Section
D on Waste Piles - Foundation, for a specific example.)
D-3a(5) Waste Pile Base
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D-3a(5)(a) Containment System Design [40 CFR Sections 122.25(b)
(4)(B)(4), 264.253(a), 264.253(b), and 264.253(d)
Present containment system engineering plan drawings de-
picting all control systems and structures associated with
the waste pile. Provide information to demonstrate that
the waste pile will be located on a base that is free of
cracks or gaps and sufficiently impervious to contain
leachate and accumulated precipitation until the collected
material is detected and removed. Include the base or
liner characteristics and manufacturers' specifications for
all concrete, asphaltic, and membrane liners. Document
that the types of waste to be stored in the pile will be
compatible with the liner or base. Discuss which wastes
will be contained and how these .will be combined. State
the estimated life of the hazardous waste pile and show
that the containment system will have a containment life
equal to or greater than the life of the pile.
D-3a(5)(b) Leachate Detection, Collection and Removal System
[40 CFR Sections 122.25
-------
D-3a(6) Vegetation and Rodent Control [40 CFR Sections 122. 25 (b)
(4)(i)(C)(l) and 264.253(c)]
Describe precautions taken to protect the waste pile base
or liner and its components from plant growth that might
puncture it and cause a failure. Indicate any precautions
provided to prevent puncture by rodents or other ground-
burrowing animals .
D-3a(7) Equipment and Procedures for Waste Pile Movement [40 CFR
Sections 122.2S(b) (4) (i)(C) (3 ) ]
Describe all the facility equipment and operational pro-
cedures used to add waste to the pile or to remove waste
from the pile, or to expose the liner surface for cleaning.
D-3b Waste Piles Without Free Liquids [40 CFR section 122. 25 (b)
D-3b(l) Test for Free Liquids [40 CFR Section 122. 25 (b) (4)
Provide test procedures and results or other documentation
or information to show that the piled wastes do not contain
free liquids . . Also show that the wastes will not generate
leachate by decomposition or other reactions during the
time they are managed in the waste pile.
D-3b(2) Control of Wind Dispersal [40 CJR sections I22.25(b)(4)
(ii)(C) and 264.250(b)(4)]
Provide descriptions similar to those for controlling wind
dispersal for waste piles having free liquids, D-3a(l).
D-3b(3) Protection from Precipitation and Run-on [40 CFR Sec-
tions 122.25(b)(4)(ii)(B), 264.250(b){2) ] , and
264.2SO(b)(3)
Describe how the pile is protected from precipitation and
run-on by a structure or cover so that neither runoff nor
39
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leachate is generated. Include a detailed description of
the structure. Also describe how the pile is protected
from surface water run-on.
D-3b(4) Demonstration That No Free Liquids Are Placed on Pile
[40 CFR Sections 122.2S(b)(4)(ii)(D)(2) and 264.2SO(b)
(1)]
Describe procedures to insure that liquids or materials
containing free liquids are not placed on the pile; i.e.,
by performing a waste analysis test for free liquids [see
D-lb(l)] or testing the waste upon receipt at the facility
and handling it appropriately before placement on the pile
(Reference 31). '
D-4 Surface Impoundments , [40 CFR Sections 122.2S(b)(3) and
264.220-264.223J
This section has been reserved until this document is
expanded to address existing facilities that treat or store
hazardous wastes in surface impoundments.
D-5 Incinerators [40 CFR Sections 122.25(b)(5) and 264.340-
264.351]
This section has been reserved until this document is
expanded to include requirements for existing incinerators.
S. GROUNDWATER MONITORING [40 CFR Section 265.90-265.94]
This section has been reserved until this document is
expanded to include information on land disposal facil-
ities .
40
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F. PROCEDURES TO PREVENT HAZARDS
F-l Security
Describe the security procedures and equipment identified
below, or provide a request and substantiation for a waiver
of any of these requirements.
F-la Security Procedures and Equipment [40 CFR Sections 122.25
(a)(4) and 264.14]
The permit applicant has the option of fulfilling the
requirements of either F-la(l) or F-la(2).
F-la(l) 24-hour Surveillance System [40 CFR Section 264.14{b)(1)]
Describe the system used to monitor and control entry to
the active portion of the facility. If possible, all
related structures and equipment should be indicated on a
plot plan. If a 24-hour surveillance system is used, de-
scribe all facets of the system, including personnel, pro-
cedures, structures, and equipment used (Reference 32).
F-la(2) Barrier and Means to Control Entry [40 CFR Section 264.14
(b)(2)(i) and (ii)]
If a fence or wall is used to control entry, indicate
height, type of material, and locking devices of the
barrier. Describe how entry is controlled at all times
(Reference 32).
F-la(3) Warning Signs [40 CFR Section 264.14{c)]
Indicate the location of required warning signs. If the
facility is in an area where any language other than
English is commonly used, indicate the language and include
the legend of posted signs. Indicate that warning signs
are legible from at least 25 feet.
41
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F-Lb Waiver [40 CFR Section 264.14(a)]
If you belive 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 them-
selves or cause a RCSA violation upon entering the active
portion of a facility. Both these points may be demon-
strated by showing that the 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 the waste or potentially
hazardous 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 (Reference 28).
?-2 Inspection Schedule [40 CFR Sections 122.25(a) (5), 264.15]
Provide a copy of the general inspection schedule (see
Table 3 of the Model Permit Application in Part 2 of this
document). The inspection schedule should be broken down
into general inspection requirements and specific process
42
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inspection requirements, as shown. For both general and
specific inspection requirements, reference in the schedule
any inspection procedures or frequencies the manufacturer
has recommended for any equipment or structures. In addi-
tion, state that the inspection schedule will be kept at
the facility.
F-2a General Inspection Requirements [40 CFR Sections 264.15(a)
and (b) and 264.33]
The inspection schedule should indicate the safety, emer-
gency, and security devices and monitoring, operating, and
structural equipment to be inspected. Examples of the this
equipment are flow and liquid level monitors, leachate
monitors, hazardous gas detectors, respirators, alarm and
communication systems, emergency power and lighting, fire
protection and control equipment, smoke detectors, first
aid equipment, decontamination equipment, surveillance
systems, barriers surrounding the facility, locking devices,
fire and explosion barriers, ventilation equipment, and
spill detection, control, and collection equipment. The
inspection plan must include areas inside and outside
buildings where hazardous waste is handled (References 33,
34, 35, 32, 36).
F-2a(l) Types of Problems [40 CFR Section 264.15(b) (3 ) ]
The schedule must identify the types of problems that are
to be looked for during the inspection (e.g., malfunctions,
deteriorations, inoperative sump pumps, leaking fittings,
and eroding dikes).
43
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F-2a(2) Frequency of Inspection [40 CFR Section 264.15(b)(4)]
The schedule must identify the frequency of inspection for
the items on the schedule. The frequency may vary; 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, malfunction, or
any operator error should go undetected between inspections.
Areas sub]ect to spills (e.g., loading and unloading areas)
must be inspected daily when in use.
F-2b Specific Process Inspection Requirements
F-2(b)(l) Container Inspection [40 CIH Section 264.174]
Describe in detail how at least weekly inspections are
performed in areas where containers are stored. Describe
procedures and elaborate on methods used to detect leaking
containers. Indicate how the inspection includes careful
status checks for the deterioration of containers and the
containment system as a result of corrosion or other fac-
tors.
F-2(b)(2) Tank Inspection [40 CFR Sections 264.194(a) and (b)]
Describe in detail how each of the tanks and its related
facility components are inspected on a scheduled weekly or
daily basis, as required. Provide a list of equipment and
parts to be inspected. Describe how the tank construction
materials of the above-ground external portions of the tank
are inspected weekly (while the tank remains in service) to
detect corrosion or erosion and leaking of fixtures and
seams. Discuss how the area immediately surrounding the
44
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tank is inspected weekly to detect obvious signs of leakage.
Specify how tank overfill control equipment, such as waste
feed cutoff systems and bypass systems, are inspected daily
to ensure good working order. Describe the daily inspection
procedures undertaken to ensure that the tank is being
operated according to its design (by types of data gathered
from tank monitoring equipment). For uncovered tanks,
describe how the level of waste is measured daily to ensure
maintenance of sufficient freeboard to prevent overtopping
by wave or wind action or by precipitation.
Elaborate on the schedule, and document the methods used
for comprehensive inspection of the tank interior to detect
cracks, leaks, corrosion, or erosion that may lead to wall
thinning to less than sufficient shell strength. Discuss
established procedures for emptying the tank to allow entry
and inspection of the interior. The frequency of these
inspection assessments must be based on the tank's material
of construction, the type of corrosion or erosion protection
used, the rate of corrosion or erosion observed during
previous inspections, and the characteristics of the waste
being treated or stored (References 37, 38, 39, 40, 41).
F-2(b)(3) Waste Pile Inspection [40 CFR Sections 254.254U)
and 264.255]
Describe how liner systems were inspected for uniformity,
damage, and imperfections during the construction or instal-
lation of the waste pile base, and how manufactured liner
materials are inspected to ensure tight seams and joints
45
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and the absence of tears and blisters. Describe how the
containment system is inspected whenever there is any
indication of possible failure (Reference 42).
F-2c Remedial Action [40 CFR Sections 264.15(c) 264.194(c) and
264.255]
Describe procedures for ensuring that any deterioration or
malfunction of equipment or structures revealed by the
inspection will be remedied on a schedule that prevents an
environmental or human- health hazard. Procedures identi-
fied in the contingency plan that describe remedial actions
to be taken in the event of potential hazard can be refer-
enced in this section.
F-2d Inspection Log [40 CFR Section 264.15(d)]
Provide a copy of the inspection log. (Example is provided
in Supplement 1-B of the Model Permit Application in Part 2
of this document.) At a minimum, these records oust include
the date and time of the inspection, the name of the inspec-
tor, a notation of the observations made, and the date and
nature of any repairs or other remedial actions.
F-3 Waiver of Preparedness and Prevention Requirements [40 CFR
Sections 122.25(a)(6), 264.32, and 264.35]
If you wish to request a waiver for preparedness and pre-
vention requirements, you must provide the following:
F-3a Equipment Requirements [40 CFR Section 264.32]
Justification showing that none of the hazards posed by
waste handled at the facility could require the following
specified equipment: internal and external communications
46
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equipment, spill- and fire-control equipment, decontamina-
tion equipment, and water at adequate volume and pressure
for fire control (References 28, 33, 35, 36, 43).
F-3b Aisle Space Requirement [40 CFR Section 264.35]
Justification showing that aisle space is not needed for
unobstructed movement of emergency personnel and equipment.
F-4 Preventive Procedures, structures, and Equipment [40 CFR Sec
tion 122.25(a)(3) J
Applicable procedures, structures, and equipment addressed
in other sections may be repeated or referenced to demon-
strate compliance with any of the following requirements:
F-4a Unloading Operations [40 CFR Section 122.25(a) (8 ) (i) ]
Describe the procedures, structures, and equipment that
will be used to prevent hazards in unloading hazardous
waste ( Reference 28 ) .
F-4b Runoff [40 CFR Section 122. 25 (a) (8) (ii ) ]
Describe the procedures, structures, and equipment that
will be used to prevent runoff from hazardous waste han-
dling areas to other areas of the facility or to prevent
flooding (References 44, 45).
F-4c Water Supplies [40 CFR Section 122. 25( a) (8 ) ( ill ) ]
Describe the procedures, structures, and equipment that
will be used to prevent contamination of water supplies.
F-4d Equipment and Power Failure [40 CFR Section 122. 25 (a) (8)
Describe procedures and equipment for mitigating the ef-
fects of equipment failure and power outages, such as waste
feed shu toff systems or emergency lighting.
47
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F-4e Personnel Protection Equipment [40 CFR Section 122.25(a)
Describe procedures, structures, and equipment for prevent-
ing undue exposure of personnel to hazardous waste, such as
ventilation equipment or protective clothing. If the
facility must meet any applicable OSHA requirements, state
them (References 34, 46).
F-5 Prevention of Ignition or Reaction of Iqni table, Reactive, or
Incompatible Wastes
F-5a Precautions to Prevent Ignition or Reaction of Ignitable or
Reactive Waste [40 CFR Sections 122.25(a)(9) and 264.17(a)]
List each of the ignitable and reactive wastes to be stored
at the facility. Describe the precautions for preventing
sparking of ignitable or reactive wastes handled on site.
Describe how the wastes are separated and protected from
sources of ignition or reaction, such as open flames,
smoking, cutting 'and welding, hot surfaces, frictional
heat, sparks (static, electrical, or mechanical), 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 or reactive- wastes are being handled, and
how "No Smoking" signs are conspicuously placed wherever
there is a hazard from such wastes (References 7, 25).
F-5b General Precautions for Handling Ignitable or Reactive
Waste or to Prevent Accidentally Mixing Incompatible Waste
[40 CFR Sections 122.2S(a) (9) , 264.17(b)]
Describe onsite precautions taken for handling ignitable or
reactive wastes and measures taken to prevent the mixing of
48
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incompatible wastes or the mixing of other materials and
wastes that are incompatible. Reactions that must be pre-
vented are those that (1) generate extreme heat, pressure,
fire, explosions, or violent reactions; (2) produce uncon-
trolled flammable fumes, dusts, or gases in sufficient
quantities to threaten human health or the environment; (3)
produce uncontrolled flammable fumes or gases in sufficient
guantities to pose a risk of fire or explosions; (4) damage
*
the structural integrity of the device or facility; (5)
through other like means may threaten human health or the
environment (References 47, 48).
F-5c Management of Ignitable or Reactive Wastes in Containers
[40 CFR Sections 122.25(b)(l)(iii) and 264.176]
Use sketches, drawings, or data to demonstrate how con-
tainers of ignitable or reactive waste are located at least
IS meters (50 feet) from the site property line (Reference
33).
?-5d Incompatible Wastes in Containers (40 CFR Sections 122.25(b)
(l)(iii), and 264.177]
Describe the specific controls and/or practices utilized to
ensure that incompatible wastes or wastes and other materials
that are incompatible are not placed in the same container
unless precautions are taken to prevent the reactions
described in section F-5b - General Precautions for Handling
lonitable or Reactive Waste or to Prevent Accidentally Mixing
Incompatible waste. Include any documentation of compliance
sased on references to published scientific or engineering
literature, data from trial tests, waste analyses, or the
49
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results of the treatment of similar wastes by a comparable
treatment process and under similar operating conditions.
Discuss how storage containers holding a hazardous waste
incompatible with any other waste or materials that are
stored nearby in other containers, piles, open tanks, or
surface impoundments are separated or protected from the
other materials by means of a dike, berm, wall, or other
structure. Include a drawing to show separation of incom-
patible wastes (Reference 49).
F-5e Management of Ignitable or Reactive Wastes in Tanks [40 CFR
Sections 122.2S(b)(2)(vi) and 264.198]
Provide specific information of how ignitable or reactive
wastes destined for tank storage are treated, rendered, or
mixed before, or immediately after placement in the tank.
Indicate the general precautions that are taken for handing
either ignitable or reactive waste when such wastes are
destined for tank storage or how these wastes are stored or
treated to protect them against any materials or conditions .
that may cause their reaction or ignition. State if the
tank is reserved solely for use in emergencies. Demonstrate
compliance with the National Fire Protection Association's
buffer zone requirements contained in Tables 2-1 and 2-6 of
the "Flammable and Combustible Code - 1977" for covered
tanks used for the treating or storing of reactive or
ignitable wastes (Reference 33).
50
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?-5f Management of Incompatible Wastes in Tanks [40 cm Sections
122.2S(b)(2)(vi) and 264.199(b}]
Describe operating procedures to insure tiiat a hazardous
waste will not be placed in an unwashed tank that previ-
ously held an incompatible waste or material unless precau-
tions are taken to prevent the reactions described in
Section F-Sb • General Precautions for Handling Ignitable
or Reactive Waste or to Prevent Accidentally Mixing Incom-
patible Wastes (Reference 33).
F-5g Management of Ignitable or Reactive Wastes in Waste Piles
[40 CTR Sections 122.25(b)(4)(ii)(0)(l), 261.21, 261.23,
264.17(b), 264.256]
Describe operating procedures to insure tnat an ignitable
or reactive waste is placed in a pile only if the addition
,'
of tnat waste to an existing pile results in the waste or
mixture no longer meeting the definition of ignitable or
reactive waste. The waste pile must be shown to comply
with Section F-5b - General Precautions for Handling Ig-
aitable or Reactive Waste or to Prevent Accidentally Mix-
ing Incompatible Wastes. Alternatively, describe the
preventive measures that are taken to protect the waste
from conditions that might cause it to ignite or react.
F-5h Management of Incompatible Wastes in Waste Piles [40 CFR
Sections 122.25(b)(4)(i)(C)(4), 122.25(b)(4)(ii)(D)(1),
264.17(b) and 264.2S7]
Describe operating procedures ensuring that incompatible
wastes are placed in the same pile only when in compliance
51
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with section F-5b - General Precautions for Handling Ignit-
able or Reactive Waste or to Prevent Accidentally Mixing
Incompatible Waste. Describe precautions for adequate
buffer or protection of incompatible waste piles from other
wastes or material stored at the facility. If the bases
are to be reused for hazardous waste, describe how any
bases on which incompatible wastes or materials previously
had been piled are sufficiently decontaminated to ensure
compliance with section F-5b - General Precautions for
Handling Iqnitable or Reactive waste to Prevent Accidental-
ly Mixing Incompatible Wastes.
G. CONTINCraCT PLAN [40 CFR Sections 122.2S(a)(7) and
264-50-264.56J
The contingency plan should describe the actions to be
taken by facility personnel in response to fires, explo-
sions, or the release of hazardous waste. The following
sections outline the requirements for describing these
actions and other regulatory requirements. If a Spill
Prevention, Control, and Countermeasures (SFCC) Plan (in
accordance with 4C CFR Part 122 or Part 151) or some other
contingency plan has already been prepared, the plan need
only be amended to incorporate hazardous waste management
provisions that are sufficient to comply with the require-
ments of this part. Demonstrate that the contingency plan
will be reviewed and amended under any of the following
conditions: whenever the facility permit is revised, if
the plan should fail in an emergency, if the facility's
52
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operations should change in a way that would altar the con-
tingency plan, or if the list of emergency coordinators or
emergency equipment should change.
G-l General Information
Give the name and location of the facility and the oper-
ator's name. Include a site plan and description of facil-
ity operations.
G-2 Emergency Coordinators [40 CFR Sections 264.52(d) and
264.S5J
Give name, address, office and home phone numbers of pri-
mary and alternate emergency coordinators, and a statement
of authorization for them to commit necessary resources to
implement the contingency plan. If more than one person is
listed as Emergency Coordinator, one must be named as
primary Emergency Coordinator and others listed in the
order in which they will assume responsibility.
G-3 Implementation of the Contingency Plan [40 CFR Section
254.51(b)J
State criteria for implementation of the contingency plan
for any potential emergency.
G-4 Emergency Response Procedures
G-4a Notification [40 CFR Section 264.56(a)]
State methodology for immediate notification of facility
personnel and required state and local agencies in the
event of an emergency (Reference 50).
53
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G-4b Identification of Hazardous Wastes [40 CFR Section 264.56
(b)]
Describe procedures for identification of hazardous mate-
rials involved in the emergency (Reference 50).
G-4c Assessment [40 CFR Sections 2S4.56(c) and (d)]
State the policy for assessment of possible hazards to the
environment and human health and the need for evacuation of
residents and notification of authorities. Authority
notification should include the appropriate local authori-
ties and the government on-scene coordinator for that area
or the National Response Center (use their 24-hour toll
free number 300/424-6802) (References 28, 50, 51, 52, 53).
G-4d Control Procedures [40 CFR Section 264.52(a)]
Describe the specific control procedures to be taken in the
event of a fire, explosion, or hazardous waste release.
The contingency plan should examine potential emergency
situations and outline planned responses (Reference 31, 50,
53).
G-4e Prevention of Recurrence or Spread of Fires, Explosions, or
Releases [40 CFR Section 264.56(e)]
Describe the necessary steps to be taken to ensure that
fires, explosions, or hazardous waste releases do act
occur, recur, or spread to other hazardous wastes at the
facility. This should include stopping processes and
operations, isolating the materials involved in the emer-
gency, and containing and collecting any wastes that have
54
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been released. I.i addition, if ~e facility stops cpera-
-icns u: response to an emergency, the emergency cccr-
1- •» a f •
,atcr aust acmtcr for leaxs, pressure buildup. gas
generation. cr ruptures in valves, pipes, or otner
, wcersver aopropriaua (Refsrsscss 50, 33).
G-4f Storage and Traataent of Xeiaased' Material [*0 C7R Sec-^isn
254.56(g)]
Discuss cravisions for t^reataenr, storage, or disposal cf
any malarial tiiat results from a release, firs, or ax?lo-
sian at the facility.
G-4g Incompatible Wastes [40 C7S- Section 264.56 ( i) (1) ]
Discuss provisions for preventing incoapatiile wastes from
being treated, stored, or disposed of in the affected areas
before cleanup procedures have been completed.
G-4h Post- Emergency Equipment Maintenance [40 CT3. Section 264. 55
Describe procedures for ensuring that all emergency equip-
ment Listed in the. contingency plan is clean and fit for
its intended use before operations are resumed.
G-4i Container Spills and LeaJcage [40 cm Section 254.171]
Describe the ..procedures for response to container spills or
leakage, including remedial procedures and timing for
expeditious removal of -spilled waste and repair or raplace-
aent of the container ( s ). Describe the availability of
aacninery, equipment, and personnel to be used as cleanup
resources .and how they will be utilised. Discuss the
procedures for repair cr disposal of the damaged containers,
the management of spilled cr leaked waste, and tne decon-
tamination process during incident mitigation.
-------
-4 : "a-r-ie Spills and laaxace -;4C CTr. Section 2S4.134(c)*. •
Describe lie procedures far response to tank spills or
leakage, including remedial procedures and tiaing for
expeditious removal of leaked or spilled waste and repair
or removal of tne -ank. Au a air^jum, address die fclls'-
of i^ci
a Overfilling of tanks
3 Ruprura of tanks
0 Leaks in tanks, pipes, valves and fittings
9 Leaks in containment dikes
Water flow from diked area tnrougn open dike
9 Leaks from pump seals and maintenance
" t«v«l instrtinent failure that allows tank over-
filling
a Piping damage from collision with mobile equip-
ment
0 Spills from tank bottom cleanout and sludge
disposal
0 Spills from pipe and tank changes
Describe the availability of machinery, equipment, and
personnel ta be used as cleanup resources and how zhey will
be utilized. Discuss the management of spilled or Leaked
waste and the decontamination process during incident aiti-
gation (Sefersnces 33, 53).
G-4k Waste Piles
G-4k(l) Indication of Waste Pile Containment System Failures
[40 CTS. Section 2S4.2S5(a)j
Describe the aechanism by which indications of possible
failure of the waste pile containment system will rss-ult -j:
inspection of that system in accordance witn the provisions
of a containment system evaluation and repair plan. Indi-
cations of possible failure of the containment system ;
56
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include appearance of liquid in the leaciiate" detection
system, erosion of the base, evidence of leakage or po-
tential of leakage in the base, and the apparent or poten-
tial deterioration of liner(s) (based on observation or
test samples of liner materials).
G-4Jc(2) Elements of a Containment System Evaluation and Repair
Plan [40 CFR Section 264.255(d) (2) ]
Provide a containment system evaluation and repair plan
that describes testing and monitoring techniques and pro-
cedures to be followed to evaluate the integrity of the
containment system in the event of a possible failure.
Include a schedule of actions to be taken in the event of a
possible failure and a description of the repair techniques
to be used in the event of leakage due to containment
system failure or deterioration that does not require the
removal of the waste pile from service.
G-4k(3) Criteria and Procedures for Removal of Waste Pile from
Service in Case of Positive Failure of the Containment
System [40 CFR Sections 264. 255 (b) and (c) and 264.255
Show that provision is made for the waste pile to be removed
from service whenever there is a positive indication of a
failure of the containment system. Describe a procedure
for removal of the waste pile from service, and give details
of the cleanup resources to be implemented and how they
will be utilized.
G-4k(4) Restoration of a waste Pile to Service [40 CFR Section
264.255(e)]
Describe the conditions under which a waste pile that has
been removed from service will be restored to service.
57
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Show that a qualified engineer will certify that the con-
tainment system meets the design specifications approved in
the RCRA permit.
G-4Jc(5) Course of Action After Waste Pile is Removed From
Service (40 CFR Sections 264.255(f) and 264.253]
Describe what happens to a waste pile containment system
that is no longer in use and will not be used in the future.
Show that you either are meeting or will meet closure
requirements for this system (Reference 54).
G-5 Emergency Eguipment [40 CFR Section 264.52{e)]
Give the location, description, and capabilities of all
emergency equipment available. If possible, indicate the
location of emergency equipment on a site plan or plant
layout. Such equipment includes, but is not be limited to,
fire extinguishing equipment, spill-control equipment,
alarm systems, communication systems, decontamination
equipment, and personal protection equipment (References
28, 34, 35, 36, 50).
G-6 Coordination Agreements [40 CFR Sections 264.52(c) and
264.37]
Describe any coordination agreements with local agencies,
contractors, or hospitals involved in emergency response
that have been made or refused pursuant to Section 264.37.
The contingency plan must list these organizations, detail
what information (facility layout, waste properties, etc.)
has been made available to them, describe potential situa-
tions that could necessitate such assistance, and outline
58
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the lines of authority that will be followed in each situa-
tion.
G-7 Evacuation Plan [40 CFR Section 264.52(f)]
Provide a detailed description of the evacuation plan.
including planned and alternate evacuation routes (if
necessary) and the signals for beginning an evacuation.
G-8 Required Reports [40 CFR Section 264.56(d), 264.56(1)
and 264.73(b)(4)J
Discuss provisions for submission of written reports of
emergency incidents within 15 days of occurrence and the
maintenance of records identifying the time, date, and
details of any emergency incident.
H. PERSONNEL TRAINING
3-1 Outline of Tra-»"-'"o: Program [40 CFR Sections 122.25(a)(12)
and 264.16]
Provide an outline of both the introductory and continuing
training programs used to prepare persons to operate or
maintain the facility in a safe manner. Describe briefly
how training will be designed to meet actual job tasks.
Supervised on-the-job training may be used to comply with
requirements in this section (Reference 55).
H-la Job Titles and Duties [40 CFR Sections 264.16(d)(l) and (2)]
Indicate the name, job title, duties, and job description
of each employee filling a position related to hazardous
waste management at the facility.
59
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H-lb Training Content, Schedules, and Techniques [40 CFH
Sections 264.16(c) and 264.16(d)(3)]
Describe the content, frequency, and techniques used in
both introductory and continuing training, including an
annual review of the initial training for each employee.
You must present and discuss the following points: person-
nel safety training; release prevention and response;
decontamination procedures for personnel, equipment, and
tools; facility operation and maintenance; high-hazard
operations; maintenance of required facility documentation;
hazards associated with each waste; and applicable RCSA and
state hazardous waste regulations (Reference 55).
H-lc Training Director [40 CTR Section 264.16(a)(2)]
Show that the program is directed by a person trained in
hazardous waste management. Specify the training direc-
tor's experience and qualifications.
H-ld Relevance of Training to Job Position [40 CFR Section
264.16(a)(l)]
Show that the program includes instruction on hazardous
waste management procedures (including contingency plan
implementation) relevant to the positions held by per-
sonnel .
H-le Training for Emergency Response [40 CFR Section 264.16(a)
(3)]
Show that the program is designed to ensure that facility
personnel are able to respond effectively to emergencies by
familiarizing them with the following: contingency plan
and emergency procedures, including inspecting, repairing,
60
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and replacing facility emergency and monitoring equipment;
key parameters for automatic waste feed cutoff systems;
communication and alarm systems; response to fires, explo-
sions, or releases; responses to groundwater contamination
incidents; shutdown of operations and evacuation (Refer-
ences 34,. 55).
H-2 Implementation of Training Program [40 CFR Sections
264.16(d)(4) and 254.16(t>)J
For existing facilities, indicate that training has been
given to and successfully completed by facility personnel
within 6 months after the date of their employment or
assignment to a facility, or to a new position at a facil-
ity, whichever is later. Employees hired after the effec-
tive date of these regulations must not work in unsupervised
positions until they have completed the training require-
ments. Explain the methodology used by the facility to
verify that employees have successfully completed training.
Records documenting that facility personnel have completed
the required training must be maintained. Indicate that
training records on current personnel must be kept until
closure of the facility, and records for former employees
must be kept for 3 years after they leave.
I. CLOSURE PLANS, POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
[40 CFR Sections 122.25(a)(13) and 264.110-120J
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1-1 Closure Plans [40 CFR Sections 264.112 and 122.2S(a)(13)]
A written closure plan must be submitted with the permit
application. The closure plan must identify the steps
necessary for complete or partial closure of the facility
at any point during its intended operating life and for
complete closure of the facility at the end of its intended
operating life. If changes in the operating plans or
facility design affect the closure plan or if there is a
change in the expected year of closure, the closure plan
must be amended. For example, changes in any of the
following should result in a modification of the closure
plan: facility size/capacity; types and quantities of
wastes on site at maximum closure inventory; schedule for
partial and final closure; and schedules for periodic
maintenance and inspection activities. Changes in tech-
nical considerations also can result in closure plan modi-
fication; for example, the application of new technology or
changes in monitoring requirements, operating contingencies,
land-use patterns around the facility, and the response of
Regional Administrators to petitions by owners/operators.
A copy of the approved plan and all revisions to the plan
must be kept on site until the certification of closure
completeness has been submitted and accepted by the EPA.
The owner or operator must notify the Regional Administrator
at least 180 days prior to the date closure is expected to
begin. Upon completion of the closure, it is necessary to
62
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submit to the Regional Administrator a certification by
either the owner or operator and an independent registered
professional engineer that the facility has been closed in
accordance with the specifications in the approved closure
plan.
A permit modification may be required for a closure plan
amendment. The elements in the sections that follow should
be included in the closure plan (References 54, 56).
la Closure Performance Standard [40 CFR Section 264.111]
Describe how the facility will be closed in a manner that
minimizes toe need for further maintenance and controls;
minimizes or eliminates threats to human health and the
environment; and avoids post-closure escape of hazardous
waste, hazardous waste constituents, leachate, contaminated
rainfall, or waste decomposition products to ground or
surface waters or to the atmosphere.
-U) partial and Final Closure Activities [40 CFR Section
264.122(a)(l)J
Describe any plans for partial closure and the circumstances
under which the facility will undergo partial closure.
Partial closure applies when a portion of the hazardous
waste facility is to be closed at any time during the
operating life of the facility (e.g., removal of a tank or
waste pile from service or capping of portions of a landfill
as they are filled). The procedures you will follow for
partial or complete closure of the facility at any point
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during its intended operating life, and for complete
closure of the facility at the end of its intended oper-
ating life. Identify the date of final closure. Identify
the maximum extent of the hazardous waste facility that
will remain open during the life of the facility (Refer-
ences 54, 56 ) .
I-lc Maximum Waste Inventory [40 CFR Section 264.112(a)(2) ]
Describe the maximum inventory of wastes in storage and
treatment at any time during the life of the facility.
Actual amounts of waste should be. indicated in the appro-
priate units for each type of facility (References 54, 56).
I-Id Inventory Removal. Disposal, or Decontamination gf Equipment
[40 CFR Section 264.112(a) (3 ) J
Describe the steps needed to decontaminate facility equip-
ment during final closure, the labor force you intend to
use to perform decontamination (in-house or outside con-
tractor), and your criteria for determining contamination.
Name each piece of eguipment and/or structures (e.g., waste
feed systems, bypass systems, drainage systems, conveyors,
transport containers, piping, pumps, valves, heat exchangers,
compressors, discharge confinement structures such as
diJces) and procedures for cleaning (e.g., steam-cleaning,
hydroblasting). Describe the amounts of contaminated soil
to be disposed of on and off the site, and describe the
criteria used"to determine the amount of contaminated soil.
Describe the method for processing, treating, or disposing
of residues from decontamination (including decontaminant
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solutions, wastewater, and liquid wastes). Describe the
testing program to be used to determine if decontamination
has been effective for each piece of equipment and/or
structure and surrounding soils (e.g., laboratory procedures,
kits, mechanical, electrical, or visual methods). Describe
the method of transport to the disposal site (e.g., truck,
rail, water), the distance of transport to the disposal
site, and the final disposal method (e.g., facility type
such as a secure landfill) (Reference 57).
I-ld(l) Closure of Containers [40 CFR Section 264.178]
Describe in detail how, at closure, all hazardous wastes
and hazardous waste residues will be removed from the
container storage area, and how containers and the contain-
ment system will be removed or decontaminated. Describe
safety precautions and procedures to protect the labor
force during the operation. Show how the effectiveness of
decontamination will be determined. Also describe the fate
of all removed hazardous waste and waste residues and how
containers, containment linings, contaminated solids, and
decontamination washes will be handled and disposed of.
Provide an estimate of the maximum inventory of waste
stored in containers at any time during the life of the
facility.
I-ld(2) Closure of Tanks [40 CFR Section 264.197]
Describe in detail how, at closure, all hazardous wastes,
hazardous waste residues, and flammable or toxic vapors
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will be removed from tanks, associated piping, discharge
control equipment, and the discharge confinement structure.
Describe how all components will be decontaminated. Describe
preparation steps before testing and cleaning (after the
waste has been removed from the tanks) such as ventilation
and gas testing, assurances for safe entry and exit, and
safety protection for the cleaning crews. Also describe
the fate of all hazardous wastes and hazardous waste resi-
dues removed from the tanks and associated structures and
how decontamination washes and contaminated soil will be
handled and disposed of. Describe any waste processing or
treatment methods, if required, prior to transport or
disposal (e.g., neutralization, stabilization, solidifica-
tion). Describe the volume of waste that will be processed
or treated and the volume of waste that will result from
such processing/treatment (Reference 58).
Provide an estimate of the maximum inventory of wastes in
storage tanks and in tank treatment at any time during the
life of the facility.
I-l(d)(3) Closure of Waste Piles [40 CFR Section 264.253]
Describe in detail how, at waste pile closure, all haz-
ardous waste and hazardous waste residues will be removed
and how any component of the containment system containing
or contaminated with hazardous wastes or hazardous waste
residues will be removed or decontaminated. Also describe
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the fata of all hazardous wastes and waste residues removed
from the pile and associated structural containment compo-
nents, and how linings, contaminated soils, and decon-
tamination washes will be handled and disposed of.
Provide an estimate of the maximum inventory of wastes
stored in piles at any time during the life of the facil-
ity.
I-le Schedule for Closure [40 CFR Section 264.112(a)(4)]
Provide an estimate of the expected year of closure. The
closure schedule must include the total time required to
close the facility and a milestone schedule depicting the
time required for intervening closure activities. This
will allow tracking of the progress of closure. Include
provisions in the plan for scheduling several periodic
inspections during the closure period.
The milestone schedule should show that all hazardous
wastes will be treated, removed from the site, or disposed
of on the site within 90 days of receipt of the final
volume of waste and that all closure activities will be
completed within 180 days from receipt of the final volume
of waste.
I-If Extensions for Closure Time [40 CFR Sections 264.113(b)
(264.113(a)]
In the event a longer period of closure time is needed than
that specified in 40 CFR 264.113(a) and (b), you must
67
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demonstrate one of the following: the activities will
necessarily take longer than 130 days to complete; the
facility has the capacity to receive additional wastes; a
person other than the owner or operator will recommence
operation of the site; or closure of the facility would be
incompatible with continued operation of the site. You
must also demonstrate that all steps have been and will
continue to be taken to prevent threats to human health and
the environment from the unclosed but inactive facility.
1-2 Post-Closure Plans
These requirements apply only to disposal facilities that
are not addressed in this manual.
1-3 notice in Deed and Notice to Local Land Authority
These requirements apply only to disposal facilities that
are not addressed in this manual.
1-4 closure Cost Estimate [40 CFR Sections 122.25(a)(15)
264.142)
Provide a written, dated estimate, in current dollars, of
the cost of closing the facility in accordance with the
closure plan. The closure cost estimate must equal the
cost of closure at the point in the facility's operating
life when the extent and manner of its operation would make
closure the most expensive, as indicated by its closure
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plan. Adjust the closure cost estimate for inflation
within 30 days after each anniversary of the date on which
the first closure cost estimate was prepared.
Revise closure cost estimates annually to adjust for infla-
tion by using a factor derived from the annual Implicit
Price Deflator for Gross National Product, as published by
the Department of Commerce in the Survey of Current Business.
An illustration of the calculation is shown in the following
hypothetical example, which uses the price deflators given
in Table 1 adopted from the Survey of Current Business.
(See next page).
Previous year cost estimate = $50,000
Previous year deflator = $177.36
Current year deflator = $193.71
After rounding off to the nearest whole number, the infla-
tion factor is computed as 194/177 = 1.096. The current
year cost is then:
1.096 X $50,000 = $54,800
The closure cost estimate must also be revised whenever a
change in the closure plan increases the cost of closure
and the revised estimate must be adjusted for inflation in
the previously described manner.
The owner or operator is required to keep the following
items at the facility throughout the operating life of the
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IABLE 1. IMPLICIT PRICE DEFLATORS
19/2 WE IGUIS, FOR GROSS NATIONAL PRODUCT*
Implicit price deflators, 1972 = 100
Seasonally adjusted
Gross national product
Personal consumption expenditures
Durable goods
Nondurable goods
Services
Gross private domestic
investment
Fixed investment
Nonresidential
Structures
Producers' durable
equipment
Residential
Nonfarm structures
Farm structures
Producers' durable
equipment
Cbanye in business inventories
Net exports' of goods and services
Exports
Imports
1900
177.36
178.9
156.0
160.6
178.1
194.2
166. B
224.7
170.2
218.6
221.7
219.9
1981
193.71
193.7
166.4
202.4
195.2
209.2
202.5
246.3
182.4
233.3
236.8
235.5
1980
IV
183.81
184.9
160.5
195.2
184.3
199.9
192.4
233.3
174.5
223.3
226.3
.224.2 '
I
188. 14
188.5
162.3
199.2
188.4
203.1
195.0
236.2
176.8
228.7
231.8
229.6
1981
II
191.06
191.5
165.4
200.4
192.2
208.4
201.4
244.1
182.0
231.8
235.0
233.4
III
195.61
195.7
168.3
203.7
197.6
210.9
204.5
249.2
184.0
235.4
239.1
237.6
IV
200. 10
199.3
170.1
206.2
202.3
214.7
208.6
255.3
186.7
238.8
242.9
241.2
1UU2
V
201.00
201.8
171.9
207.2
206.3
215.5
209.3
2SU.4
1U6.2
242.0
246. 1
24b.3
149.4 159.4 152.4 155.2 158.0 161.5 163.1 166.1
211.0
290.1
229.0
295.5
219.9
296.4
226.1
303.1
228.0
301.2
229.8
209. 8
232.2
288.5
233.6
209 3
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1ABLE 1 (continued)
Implicit price deflators, 1972 = 100
. Seasonally adjusted
1980 1981 1980 1981 1982
IV I II HI IV V
Government purchases of
goods and services 184.4 202.7 192.8 196.4 199.5 204.2 210.6 212.3
Federal 183.9 206.4 197.4 199.4 201.9 206.6 217.2 216.2
National defense 185.6 208.8 196.8 201.2 204.2 208.3 220.8 223.1
Nondefense 180.6 201.7 198.7 195.9 197.3 203.1 210.3 203.3
State and local 184.7 200.3 190.0 194.5 198.0 202.8 206.1 209.8
aSo»rce: Adapted from Department of Commerce Survey of Current Business. Gross Product by Industry.
1981. Table 7.1-7.2.
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facility: the latest closure cost estimate (as -previously
defined) and, when this estimate has been adjusted for
inflation, the latest ad]usted closure cost estimate.
1-5 Financial Assurance Mechanism for Closure [40 CF3
Sections 122.2S(a)(l) and 254.143]
State which of the following mechanisms is used.
1. Closure trust fund
2. Surety bond guaranteeing payment into a closure trust
fund
3. Surety bond guaranteeing performance of closure
4. Closure letter of credit
5. Closure insurance
6. Financial test and corporate guarantee for closure
A fully executed financial assurance mechanism(s) must be
made available at the time of permit issuance. In states
that have only Phase I authorization, provide a completed
but unexecuted copy of financial assurance mechanism(s) for
closure in the Fart B application.
Originally signed copies of each of the chosen instruments
must be delivered to the Regional Administrator. When a
mechanism is used for multiple facilities, submit criteria
of financial assurance to the Regional Administrator in
each region where the mechanism is applied; include a list
showing the EPA identification number, name, address, and
the amount of funds for closure assumed by the mechanism
for each covered facility.
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In states that do not have Phase I authorization, existing
facilities were required to submit a copy of financial
assurance mechanism(s) by July 6, 1982. In states that
have Phase I or Phase II authorization, facilities must
comply with the applicable state laws and regulations.
(Note: An owner or operator of a new facility must have
the chosen instrument delivered to the Regional Administra-
tor by certified mail at least 60 days before the date on
which hazardous waste is first received, and the instrument
must become effective no later than the date of first
receipt.) Instruments must be revised as appropriate, and
evidence must be submitted to the Regional Administrator
within 60 days of the revision to the current cost estimate
for closure of a facility '(Reference 59).
I-5a Closure Trust Fund [40 CFR Sections 264.143(a) and
264.151(a)(l)J
A trust fund is a mechanism whereby the site owner or
operator sets aside funds in the form of cash or marketable
securities to pay for the proper closure of the site. The
trustee, a financial institution, controls the fund and
invests the money in low-risk assets. All income earned by
such investments is retained in the fund and reinvested
along with fund principal.
Upon closure of the facility, monies in the fund are avail-
able to reimburse authorized expenditures for closure when
itemized bills are submitted to the Regional Administrator.
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Funds remaining aftsr all closure requirements have been
fulfilled are returned to the facility's owner or operator.
During interim status, payments into the trust are made
annually over 20 years or over the remaining life of the
facility, whichever is less. (This is referred to as the
"pay-in" period.) After a permit has been issued, the
pay-in period is reduced to the life of the initial permit.
A Federal permit may be written for a maximum of 10 years.
The trustee will furnish annual valuations at least 30 days
before the anniversary data of establishment of the fund to
both the grantor (i.e., facility owner or operator) and the
Regional Administrator of the .closure trust fund at each
facility. Valuations are based on market values no more
than 60 days prior to the anniversary date of establishment
of the fund.
During the pay-in period, the minimum annual payment is
equal to the unfunded liability of the facility (the esti-
mated closure divided by the number of years remaining in
the pay-in period):
C5" - CV
Minimum annual payment = ~ .7—=-•
where CZ = the current cost estimate for closure.
C7 = is the current value of the trust fund.
Y = is the number of years remaining in the pay-in
period.
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The first payment should be made at the time the trust fund
is established and subsequent payments, no later than 30
days after each yearly anniversary date of the trust fund.
After the pay-in period is completed, the funding level of
the trust fund must be revised within 60 days of any change
in the cost estimates.
After the pay-in period is completed, the owner or operator
must maintain the value of the trust fund at a level equal
to or greater than the CE value. Release of amounts from
the fund requires written instructions from the Regional
Administrator to the trustee.
The trustee must be a bank or other financial institution
that has the authority to act as a trustee and whose trust
operations are regulated and examined by a Federal or state
agency. The trustee may accept written directions from the
grantor concerning investment guidelines and objectives;
however, the trustee must abide by the "prudent man"
doctrine for investments and may not include securities or
other obligations of the grantor in the trust fund port-
folio. All expenses of the trust, including taxes, broker-
age commissions, legal services, and trustee compensation—-
to the extent not paid directly by the grantor—are paid by
the fund. The trustee must notify the Regional Administrator
within 10 days following the expiration of the 30-day
period of the failure of the grantor to make the required
annual payments during the pay-in period.
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Prospective grantors should review all tax aspects of trust
fund operations with their accountants or tax advisors.
Under present statutes, payments into a trust fund are not
considered expenses (and are therefore not deductible) on
Federal income tax returns. (The SPA is awaiting an IRS
ruling on this.) Payments by the trust fund for closure or
post-closure care expenses, however, are deductible in the
year of closure or post-closure care when such expenses are
incurred. Income earned by the trust fund is taxable, even
though it is not distributed to the grantor in the year
earned. The grantor's Federal income tax liability will be
credited (reduced), however, to the extent of any Federal
income taxes paid by the trust fund on a fiduciary return.
The trust fund"is terminated and remaining monies are
returned, to the grantor when one of two conditions have
been met:
1) The requirements for closure have been satisfied.
2) An alternative financial assurance instrument has been
provided to substitute for all or part of the trust
fund.
Only the Regional Administrator can release the trustee
from this obligations under the trust agreement.
The wording of the trust agreement must be identical to the
wording specified in 40 CFR Section 264.151(a)(1), and the
trust agreement must be accompanied by a formal certi-
fication of acknowledgment.
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I-5b Surety Bond [40 CFR Sections 264.143(b), 254.143(c),
254.151(b), and 154.151(c)
A surety bond is a contract whereby a surety company guar-
antees to pay the amount of closure or post-closure care
costs should the owner or operator fail to meet his obli-
gation. A standby trust fund must be established in con-
junction with the surety bond. Payments from a surety
company would be made directly into the standby trust. The
owner or operator need not make any payments into the
standby trust fund.
After obtaining the surety bond from, at a minimum, a
federally acceptable surety company (per Treasury Circular
570), the owner or operator delivers the bond and standby
trust fund documents to the Regional Administrator. The
penal sum of the bond is adjusted yearly to correspond to
adjustments in the closure cost estimate. Adjustments to
the penal sum must be made within 60 days after any changes
in the cost estimate. The bond remains effective until
cancelled with the consent of the Regional Administrator.
The cost to the owner or operator of providing financial
assurance by means of a surety bond includes the cost of
the bond itself plus the incremental opportunity cost of
any capital required to be set aside as collateral. The
direct cost of the surety bond is generally between 1.0 and
2.0 percent of the face value of the bond per year and is
deductible for tax purposes. The EPA expects the use of
77
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surety bonds for financial assurance to be limited (based
on discussions with the Surety Association of America).
Wording for the surety bond is specified in 40 CF3. Section
264.15KO.
I-5c Closure Letter of Credit [40 CF3 Sections 264.143d) and
264.151(d)J
A letter of credit is an instrument issued by a financial
institution on behalf of the owner or operator of the
hazardous waste facility that gives EPA the right to draw
from the issuing institution to cover the costs of closure
in the event the firm fails to meet its obligation. In a
sense, the financial institution substitutes its credit for
that of the facility.
,'
The owner or operator establishes a standby trust fund in
. conjunction with a letter of credit in an amount equal to
or greater than the current closure cost estimate. Both
instruments are delivered to the Regional Administrator and
are updated annually, as appropriate. Adjustments to the
value of the letter of credit oust be made within 60 days
of any changes in the closure cost estimate.
The institution issuing the letter of credit must be a bank
or other financial institution that has authority to issue
letters of credit and whose operations for this purpose are
regulated and examined by a Federal or state agency. The
letter of credit is irrevocable; it is issued for a period
of at least one year, with automatic extensions for at
78
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least one additional year unless 90-day notification is
given to the Regional Administrator.
Upon determination, under Section 3008 of RCRA, that the
owner or operator has failed to meet his closure obli-
gations, the Regional Administrator may draw on the letter
of credit. Drafts under the letter of credit are deposited
into a standby trust fund, from which payments are made for
approved closure expenses.
The cost to the owner or operator of providing financial
assurance by means of a letter of credit includes the cost
of the letter of credit itself plus the incremental oppor-
tunity cost of. any capital required to be set aside as
collateral. The annual direct cost of the letter of credit
is generally between 0.25 and 2.0 percent of the value of
the letter of credit, depending on the credit-worthiness of
the firm. Such costs are deductible for income tax pur-
poses. Collateral required for letters of credit typically
averages 20 percent of the value of the letters of credit.
Wording for the letter of credit is specified in 40 CFR
Section 264.151(d).
I-3d Closure Insurance [40 CFR Section 264.143(e) and
264.151(e)J
A firm- may purchase an insurance policy for the amount of
the estimated closure cost. The insurance company will pay
the cost of closure up to the full amount of the policy
whenever closure occurs.
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The faca value of the policy is at least the amount of
current closure cost. Premiums paid during the active life
of the size serve to fund the full amount of the policy,
although it may not have a cash value. At the end of sits
life, the insurer will pay out funds, up to the face amount
of the policy, to reimburse authorized expenditures for
closure. The faca amount of'the insurance must be adjusted
accordingly within 60 days of any change in the cost esti-
mates. The policy cannot be cancelled except for failure
to pay the premium, and then only 120 days after providing
notification of such failure to both the Regional Admin-
istrator and the owner or operator.
The owner or operator submits a certificate of insurance
[worded as specified in 40 CFR Section 254.151(e)] signed
by the insurer and indicating the face amount of the
policy. The insurer must be licensed to transact insurance
business or eligible to provide insurance as an excess or
surplus line insurer in one or more states. Either the
face amount of the insurance must be adjusted to equal or
exceed the covered cost of closure, or other forms of
financial assurance must be provided to make up the dif-
ference .
The key issue regarding the insurance mechanism is the
deductibility of premium payments for tax purposes. If the
premiums are deductible, the insurance policy would be
similar to the trust fund without the adverse tax trsa-cnent
30
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of fund payments. Until the tax issue is resolved, how-
ever, it is doubtful whether any significant interest in
this option will develop. Currently, no insurance firms
are offering to issue this kind of policy.
I-5e Financial Test and Corporate Guarantee [40 CFR Sections
264.143(1), 264.151U), and 264.151(h)]
The owner or operator can establish financial assurance for
closure of one or more facilities by passing a financial
test. The test [wording at 40 CFR Section 264.143(f)(1)]
is based on the facility's most recent audited financial
statements, and it must be recertified on an annual basis.
The test takes into account the current adjusted cost of
closure and post-closure care of all facilities that are
not covered by an'alternative financial mechanism. If a
facility passes the financial test, it need not provide any
additional assurance that it can meet its closure cost
obligations. A parent company that passes the financial
test can provide a guarantee of its subsidiary's obli-
gations .
To certify satisfactory financial conditions under the
financial test, the owner or operator supplies to the
regional administrator: (1) a letter from the facility's
chief financial officer [wording in 40 CFR Section
' 264.151(f)]; (2) an auditor's report confirming the results
of the test; (3) the auditor's opinion; (4) a letter from a
guarantor corporation, if applicable [wording in 40 CFR
Section 264.151(g)]; (5) any other information requested by
31
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the Regional Administrator. The auditor aust be an inde-
pendent certified public accountant. If a facility fails
to provide certification of satisfactory financial condi-
tion at any time prior to termination of its closure obli-
gations, an alternative financial assurance mechanism mist
be supplied within 30 days.
I-5f Combinations
I-5f(l) Use of Multiple Financial Mechanisms [40 CF3 Section
264.143(g)J
A facility's use of multiple financial mechanisms requires
a copy of a combination of trust fund agreements, surety
bonds guaranteeing payment into a trust fund, letters of
credit, insurance, and state guarantees. Neither the
financial test* nor surety bonds guaranteeing performance of
closure can be used to provide partial financial assurance
for closure of a single facility. The combined financial
assurance provided for a facility must equal or exceed the
facility's current (adjusted) closure cost estimate.
I-5f2) Use of Financial Mechanisms for Multiple Facilities
[40 CIR Section 264.143(h)] """
A single financial mechanism may be used to provide finan-
cial assurance for closure of more than one facility.
Total funding of the mechanism must equal or exceed the sum
required for each facility considered separately. Evidence
of financial assurance must be supplied to the Regional
Administrator in each region where covered facilities are
located; it should include a list showing the EPA identi-
fication number, name, address, and amount of funds for
closure assured by the mechanism for each facility.
32
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1-6 Post-Closure Cost Estimate [40 CFR Sections 122.15(a)
(16) and 264.144]
These regulations only apply to disposal facilities.
1-7 Financial Assurance Mechanism for Post-closure [40 CFR
Sections 122.15(a)(16) and 264.145]
These regulations only apply to disposal facilities.
I-8 Liability Requirements [40 CFR Section 122.15(a)(17)
and 264.147J
In states that have only Phase I authorization, provide
evidence that the liability coverage will be effective at
the time of permit issuance. This may be done by stating
which mechanism will be used and providing a copy of the
proposed mechanism. In states that do not have Phase I,
authorization of liability coverage, existing facilities
must submit evidence by July 17, 1982, for sudden and
nonsudden (for surface impoundments, landfills, or land
treatment facilities only) accidental occurrences that
cause injury to persons or property. Evidence may be
provided by submitting a certificate of insurance, by
passing a financial test (self-insurance), or any com-
bination of the two. Coverage amounts apply to all facil-
ities owned or operated by the insured. Only states and
the Federal government are not required to provide lia-
bility coverage. In states that have both Phase I and II
authorization, facilities must comply with state laws and
regulations that are or will be in effect at the time of
application submitted. Coverage must be maintained until
certification of closure of all "facilities.
33
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I-3a Sudden Insurance [40 CF3 Sec-ions 264.-147(a), 154.151(1),
and 254.1511:) ]
All facility owners and operators must have coverage for
sudden occurrences (accidents that are not continuous or
repetitive in nature) in the amount of at least si million
per occurrence, with an annual aggregate of 32 million,
exclusive of legal defense costs.
If insurance is used to cover all or part of this lia-
bility, you must submit proof with your permit application
to each the EPA Regional Administrator in each Region in
which covered facilities are located. Such proof may be in
the form of a signed duplicate original of either (1) the
policy's Hazardous Waste Facility Liability Endorsement
[wording in 40 C7R Section 264.151(g)], or (2) the Cer-
tificate of Liability Insurance [wording in 40 CFR
264.1SKJ)].
Alternatively, a facility may use a financial test or any
combination of insurance and a financial test as evidence
of liability.
Existing facilities must submit the required documents by
July IS, 1982, in states that do not have Phase I authori-
zation, and according to stare law and regulations, in
states that have Phase I or Phase II authorization.
I-3b Nonsudden Insurance [40 CT3. Sections 264.147(b),
254.151(1), and 264.151(])]
These requirements apply only to surface impoundments,.
34
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landfills, or land treatment disposal facilities that are
not addressed in this manual.
I_3c Financial Test [40 CFH Sections 264.174(f), 264.15KJ)]
Owners or operators may provide assurance for all or part
of their financial liability requirements by passing a
financial test. .The test [wording in 40 CFR Section
264.147(f)] is based on the facility's most recent audited
financial statements and must be recertified on an annual
basis. To certify satisfactory financial condition under
the financial test, you must supply the Regional Admin-
istrator with (1) a letter from your Chief Financial
Officer [wording at 40 CFR Section 264.151(g)]; (2)-an
auditor's report confirming the results of the test; (3)
the auditor's opinions; (4) any other information requested
by the Regional Administrator.
The auditor must be an independent certified public ac-
countant. If a facility fails to provide certification of
satisfactory financial conditions for any portion of the
required liability coverage, such coverage must be provided
within 30 days through an insurance policy.
I-8d Variance Procedures [40 CFR Section 264.147(c)]
An owner or operator may obtain approval from the Regional
Administrator for a reduction in the required liability
amounts under this section. Such approval depends on an
evaluation of the degree and duration of risks associated
with the ownership or operation of each facility or group
85
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of facilities and on other technical and engineering infsr-
aacion as determined necessary by the Regional Admin-
istrator .
I-3e Ad-ustaent Procedures [40 CFR Section 2S4.147(d)]
The Regional Administrator may elect to increase the
amounts of liability coverage required for any facility or
group of facilities, and may elect to impose nonsudden
liability coverage requirements on treatment of storage
facilities. Such a determination is based on an evaluation
of the degree and duration of risks and what is deemed
necessary to protect human health and the environment. Any
adjustment of the level of required coverage for a facility
that has a permit is treated as a permit modification under
40 CFS Sections 122.15(aH7)(iii) and 124.5.
1-9 State Mechanisms
I-9a Use of State-Reouired Mechanisms [40 CFR Section 122.15
(2)(1S), 254.149]
If a state has hazardous waste regulations equivalent to or
greater than Federal liability requirements or financial
assurance for closure, submit a copy of the state-required
financial mechanisms and a letter requesting that the state
mechanism be acceptable. Include the facility's Z?A identi-
fication number, name, and address and the amounts of cov-
erage. If the state cove'rage is. less than Federal require-
ments, the owner or operator must provide proof of addi-
tional financial assurance mechanisms to equal Federal
requirements.
36
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To obtain approval for state-assumed coverage, the owner or
operator must submit a letter written by the state to the
Regional Administrator describing the nature of the state's
assumption of responsibility, together with a request that
such assumption be considered acceptable. The letter must
include the facility's EPA identification number, name, and
address and the amount of funds for closure or liability
coverage that are guaranteed by the state.
I-9b State Assumption of Responsibility [40 CFS. Section
264.150J
A state may assume either the owner's or operator's legal
responsibility for closure and liability or the financial
responsibility to cover those requirements in accordance
with the Federal standards. If state guarantees for finan-
cial responsibility are less than the amounts estimated for
closure, the owner or operator of the facility must supply
additional financial assurance mechanisms to cover the
shortfall.
j. OTHER FEDERAL LAWS [40 CFR Sections 122.25(a)20 and 122.12]
The EPA must ensure that RCRA permits are consistent with
the requirements of applicable Federal laws, such as the
Wild and Scenic Rivers Act, National Historic Preservation
Act of 1966, Endangered Species Act, Coastal Zone Manage-
ment Act, and the Fish and wildlife Coordination Act.
Therefore, it is necessary to consider the potential impact
of the facility on these special environmental areas, and
information related to the facility's compliance with other
Federal laws in the RCRA permit application.
87
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K. CZRTI?ICATION [40 CFH Sections 122.5(a) and (d)]
Applications aust be accompanied by a certification letier
reading as follows:
"I certify under penalty of law that I have personally
examined and am familiar with the information sub-
mitted in this document and all attachments and that,
based on aiy inquiry of those individuals immediately
responsible for obtaining the information, I believe
that the information is true, accurate, and complete.
I am aware that there are significant penalties for
submitting false information, including the possi-
bility of fine and imprisonment."
The required signatures are as follows: (1) for a corpo-
ration, a principal executive officer (at least at the
level of vice-president); (2) for a partnership or sole
proprietorship, a general partner or the proprietor,
respectively; (3) for a municipal, state, Federal, or other
public agency, either a principal executive officer or
ranking elected official.
38
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PART 2
MODEL RCRA PERMIT
APPLICATION
39
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PART 2
MODEL RCRA PSRMIT APPLICATION
Part 2 presents a model of a Part A application, a Part 3
application, and certification for a fictitious hazardous waste
management facility.
Appendix A contains general information and hazardous
characteristics.of waste; Appendix 3 contains inspection log
sheets; and Appendix C contains a Trust Agreement.
90
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Date: 2/26/82*
Revision No.: 1
A
SECTION A
PART A APPLICATION
The Part A application includes the completed forms that
follow, a facility map (Figure 2), and a facility photograph
(Figure 3).
X
T"
This is a suggested notation to facilitate revisions to the
Part B Permit Application.
91
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at.
Revision No. : 0
A
O»« «• '«»»0'>S
3100 WEST ELETEMTB ST
CONT1NWI ON MVIMH
92
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Date: 2/26/82
Revision No.: 0
A
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714 0 115 S'516'7 8 9
93
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Date: 2/26/82
Revision No.: 0
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94
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Date: 2/26/82
Revision No.: 0
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95
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96
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Date: 2/26/82
Revision No.: 0
A
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97
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Revision No.: 0
A
KSI DINT I Al MCA
!UWT«UK 5 «. i
M» OWE: 9/10/81
1 in. • 2640 ft
Figure 2. A topographical map of Tankopile Finishing
Company and surrounding area.
98
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Date: 2/26/82
Revision No.: 0
A
(An actual photograph would include existing structures
and future hazardous waste storage areas.)
Figure 3. Facility photograph, June 2, 1980.
99
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Revision No.:
B
SECTION B
FACILITY DESCRIPTION
This section provides a general description of the hazard-
ous waste management facility as required by 40 CFR §122.25(a).
This description is intended to acquaint the permit application
reviewer/permit writer with an overview of the facility. More
complete details can be found in other parts of this permit
application.
B-l General Description T40 CFR 122.25(a)m 1
Tankopile Finishing Company, Inc., is located 3 miles east
of the city limits of Anytown, Rhode Island. The street
address is:
Tankopile Finishing Company, Inc.
3100 West llth Street
Washington County
Anytown, Rhode Island 02881
The mailing address is:
Tankopile Finishing Company, Inc.
P.O. Box 1982
Anytown, Rhode Island 02881
This facility is primarily a manufacturer of metal automo-
tive parts (i.e., body parts, hubs, and trim) and household
appliance housings and parts. Hazardous wastes are gen-
erated by metal fabrication, cleaning, finishing and
100
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Date: 2/26/82
Revision No.: 0
3
coating operations. Fabrication and machining of metal
parts generates metal grindings. Cleaning of metal parts
in hydrochloric acid generates pickle liquor sludge and
spent pickle liquor. Vinyl acetate and vinyl chloride
sludges are generated by the metal coating operations. The
waste trichloroethane results from vapor degreasing of
metal parts. The metal hydroxide sludge is generated as a
byproduct from recycling wastes from chromium and lead
plating operations.
The contact and party responsible for the hazardous waste
management activities at Tankopile is:
John Q. Smith
Environmental Engineer
(401) 555-6789
B-2 Topographic Map [40 CFR 122.25(a)(19)1
Figure 4 is a topographic map showing the facility bound-
aries, buildings, waste storage areas, and other details.
Figures 5 and 6 are topographic maps showing 5-ft contour
intervals of elevation and the 100-year floodplain area,
respectively. These maps also show surface waters. The
scale on these maps is 1 in. equals 880 ft. whereas the
regulations request a scale of L in. equal to not more than
200 ft. This was discussed with the permit application
reviewer at EFA and this submission was considered accept-
able (see letter to J. Q. Smith dated 12/1/31 from
C. Siegel submitted separately).
101
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Revision No.: 0
B
WLQWING/
FVTUKt
,WSTl MU
Ml*
N
DMIN
IQM1NG/IM.MOIM «U
MSTC Mil «l»
880 ft
SCALE
NAP DATE: 9/1Q/81
Figure 4- Facility map of Tankopile Finishing Company.
102
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Date: 2/26/82
Revision No.: 0
B
'25
130
130
130
SCALE
QATE: 9/10/81
Figure 5. Facility map with 5-foot contour intervals of elevation
(feet MSL).
103
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t.f
Revision No
B
125
130
130
SCALE
MTE: 9/10/81
ZONES SUBJECT TO
100-YEAR FLOODS
Figure 6. Facility map showing 100-year floodplain.
104
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Date: 2/26/82
Revision No.: 0
B
Land Uses: Figure 7 shows surrounding land-use areas.
Other industry lies south of the facility; the rest of the
surrounding area is undeveloped. Zoning maps of the area
may be obtained from the City of Anytown Planning Com-
mission.
Hazardous Waste Management Facility Boundary: The haz-
ardous waste management facilities consist of the drum
storage area (100 55-gallon drums), two 7500-gallon storage
tanks, and one 50-yd3 waste pile (Figure 4). The figure
also shows the location of the future waste pile area which
is outside the 100-year floodplain. The existing waste
pile area is within the 100-year floodplain (Figure 6).
wind Rose: Figure 8 shows an annual wind rose of meteor-
ological data collected from 1965 through 1974 at the
nearest weather station, approximately 5 miles west of the
Tankopile facility in Anytown, Rhode Island.
Access Control: The facility is surrounded by a fence, and
a guard house is situated at the only entrance to the
plant. Employees must show identification to obtain ac-
cess; visitors must sign in and out and wear a visitor's
badge. Access control is discussed in further detail in
Section F-la.
Injection and withdrawal Wells: The site has no injection
wells. One withdrawal well is located north of the electric
substation (see Figure 4) and is used to supply cooling
water for vapor degreasers at the facility. No other wells
are located on-site or off-site within 1000 feet of the
facility.
105
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Date: 2/26/82
Revision No.: 0
3
LEGAL BOUNDARIES
OF FACILITY
LEGEND
I*, [^ OTHER INDUSTRY
5] WOODED HARSH
MOODS OR BRUSH
SAND
NAP DATE: 4/20/79
1000 ft
i
SCALE
Figure 7. Surrounding land use.
106 •
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Date: 2/26/82
Revision Ko.: 0
B
ANYTOWN, RHODE ISLAND
1965 - 1974
29,216 OBSERVATIONS
7.15 CALM
WIND SPEED, knots
8. Uind rose.
107
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Date: 2/26/82
Revision No.: 0
B
Buildings; Treatment, Storage, and Disposal Areas; Other
Structures: Figure 3 shows the building and structures on
the property as well as the waste storage areas.
Recreation Areas: Not applicable.
Runoff Control Systems: A combined sewer system with
collection drains located throughout the facility collects
runoff from the processing and warehouse areas (Figure 4).
Runoff from the container and waste pile storage areas is
collected in holding tanks prior to discharge to the sewer
system. Section F-4b discusses runoff control in greater
detail.
Access and Internal Roads: Figure 4 shows the roads within
the plant area and the one road leading into the plant.
Storm, Sanitary and Process Sewers: Tankopile's combined
sewer system, which collects sanitary .sewage and storm
water, has drains located in the office building, lunch
room, first aid building, processing area, and warehouse
area. The system also extends to the container storage
area and waste pile storage area receiving runoff. Runoff
collected in the container storage area and waste pile
storage area does not mix with sanitary waste until it
passes through the holding tanks as discussed in section
F-4b. The combined sewer system is shown in Figure 4.
There are no process sewers at this facility.
108
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Date: 2/26/82
Revision No.: 0
B
Loading and Unloading Areas: Concrete loading/unloading
areas are provided on the east side of the tank storage
area and at the warehouse. A loading/unloading area is
provided on the west side of the container storage area and
a loading/unloading area will be located on the south side
of the future waste pile.
Fire Control Facilities: The three fire hydrants provided
are located near the lab, the processing area, and the
warehouse.
Surface Waters: The only surface water within 1000 feet of
the facility is the Queen River shown in Figures 4 through
6.
^
Flood Control/Drainage Barriers: General drainage on the
property is toward the river. A fence surrounds the con-
tainers to keep them within the storage area during a minor
flood. Alternatively, when a 100-year flood is evident,
the containers will be removed to a disposal facility.
Current plans call for the waste pile to be moved outside
the 100-year floodplain. The tanks are already located
outside the floodplain.
B-3 Location Information [40 CFR 122.25(a)(11) and'264.18]
3-3a Sersmic Standard
Because this is an existing rather than a new facility, the
seismic standard does not apply.
109
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Date: 2/26/82
Revision No.: 0
B
B-3b Floodplain Standard
The Tankopile Finishing Company, Inc., facility is located
immediately west of the Queen River and 1.3 miles east of
the Chipuxet River. The 100-year floodplain elevation at
the facility is 125 feet mean sea level (MSL).
Figure 9 shows a portion of the Federal Insurance Adminis-
tration (FIA) flood map for the city of Anytown. The zones
labeled "AO" on the map indicate areas of 100-year shallow
flooding with depths between 1 and 3 feet. (This refers to
depth of flooding in a given area rather than rise of the
river by one to three feet.) The Zone B portions of the
facility property indicate areas between the limits of the
100-year flood and the 500-year flood or areas subject to
100-year flooding with average depths of less than one
foot. The remainder (the most northern and western sections)
of the property, designated as Zone C, is an area that is
not subject to flooding. More than half of the facility
property is located within the 100-year floodplain and is
subject to floods of one to three feet in depth.
B-3b(l) Demonstration of Compliance
B-3b(l)(a) Flood Proofing and Flood Protection Measures
The slow-flowing Queen River may subject the property to
occasional shallow (one to three foot depths) floods, but
no wave action'can reasonably be expected.
Waste containers (55-gallon drums) are stored in a fenced-
in area located in Zone AO. Although the container storage
110
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Date: 2/2S/32
Revision No.: 0
B
LISAL BOUNDARIES
OF FACILITY
1000 ft
SCALE
NAP DATE: 4/20/79
LESENO
ZONE AO • AREA OF 100-TEAR FLOOD;
FLOOD ELEVATION OF
12S fMt NSL.
ZONE B
- AREA BETWEEN LIMITS OF
100-rEAR FLOOD AND 500-
YEAR FLOOD; OR AREAS
SUBJECT TO 100-rEAR
FLOODING WITH AVERAGE
DEPTHS LESS THAN ONE
(1) FOOT OR «H£RE THE
CONTRIBUTING DRAINAGE
IS LESS THAN ONE SQUARE
MILE. FLOOD ELEVATION
OF 130 fMt MSL.
ZONE C - AREAS OF MINIMAL FLOODING.
Figure 9. Federal insurance Administration (FIA) 100-year floodplain map.
Ill
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Date: 2/26/82
Revision No.: 0
B
i
area is subject to floods, the closed drums would be con-
tained by the fence should a flood occur. In the event of
a 100-year flood, the drums will be removed to a disposal
facility.
B-3b(l)(b) Flood Plan
The container storage area located in the east corner of
the property, in zone AO, is in the 100-year floodplain.
In the event of a 100-year flood, the drums will be moved
by Hazardous Spills Cleaned (OSC), Inc. (EPA I.D. No.
RI0090000000) 1200 East Twelfth Street, Anytown, Rhode
Island, to Ace Storage, Inc., 4700 West Eleventh Street,
Anytown, Rhode Island (EPA I.D. No. RI009899999).
Tankopile has contracted with OSC, Inc., a firm that
specializes in hazardous waste transport and hazardous
spill cleanup activities. Tankopile has entered into a
contractual agreement with OSR that guarantees that OSR
will make the necessary personnel and equipment available
to move our waste to Ace Storage within 4 hours notice.
The contractual agreement is available at the facility for
review. OSR will move the palletized drums by fork-lift
truck onto a flat-bed truck, which will transport the drums
5 miles to Ace Storage. OSR has entered into a contractual
agreement with Ace Storage that states that they will
accept the Tankopile waste within 8 hours' notice.
112
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Date: 2/26/82
Revision No.: 0
B
It is estimated that it would take 8 hours to move 100
drums (4 per pallet), which is well within the warning time
before the occurrence of a 100-year flood.
Some small likelihood of a potential accident is possible
when moving the drums from the storage area and loading
them onto the flat-bed trucks. Therefore, Tankopile's
emergency coordinator will be responsible for ensuring that
the contractor personnel follow all necessary safety
procedures.
B-3b(2) Plan for Future Compliance
The waste pile currently located in the east corner of the
property, in Zone AO, would be subject to washout should a
100-year flood occur. Plans are being completed for con-
structing a storage area for the waste pile in the northern-
most corner of the property along the eastern boundary.
This is' a Zone C area, not subject to flooding (100-yr).
The planned waste pile storage area will be constructed
according to the production schedule provided in Table 2
and will meet the same design specifications as the exist-
ing waste pile storage area. Moving the waste pile from
its current location will prevent material washout from the
pile due to flooding. (See Section 0-3a for design of
waste pile.) The old waste pile will be closed in accord-
ance with the procedures specified in the closure plan.
113
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Date: 2/26/32
Revision No.: 0
B
TABLE 2. WASTE PILE CONSTRUCTION SCHEDULE
Item
Date of completion
Begin construction
Ground water table control
system
Leachate collection system
Foundati on
Liner
Leachate and runoff collection
system
Base
Run-on diversion ditch
Begin receiving wastes
March 1, 1982
March 26, 1982
April 16, 1982
April 23, 1982
April 30, 1982
May 14, 1982
May 21, 1982
June 7, 1982
June 15, 1982
114
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Date: 2/26/82
Revision No.: 0
B
This facility will be in compliance with 40 CFR Section
264.18(b) by June 1983 when the waste pile is moved to a
aonflooding area.
B-4 Traffic Patterns [40 CFR 122.25(a)(10)]
Access to Tankopile Finishing Company is from Interstate 95
to State Highway 102 east and right on River Road. After a
distance of approximately 5 miles on River Road, a left-hand
turn is made at West Eleventh Street, and the plant entrance
is on the left about 1/2 mile from the intersection.
Figure 10 shows the onsite traffic pattern. The main road,
parking lots, and dead-end roads are two-way; the two main
loops within the property are one-way. Most cars are
confined to the parking lot and entrance road. Within the
plant, traffic vehicles consist mostly of front-end loaders
and trucks. About five semitrailers enter the plant each
day. Four front-end loaders are used throughout the plant
on a constant basis; and two additional front-end loaders
are used as needed.
Traffic Control: Traffic is controlled by one-way direction
and stop signs. These are also indicated in Figure 10.
Access Road Surfacing: All roads are constructed of 5 in.
of bituminous concrete pavement (blacktop), composed of 3H
in. of bituminous concrete base material and 1^ in. of
bituminous concrete surface material; this overlays 9 in.
of compacted aggregate base.
115
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Date: 2/26/82
Revision No.: 0
B
® STOP SIGN
fUTUl LOADING/UNLOADING AREA
Figure 10. Traffic flow (not to scale).
116
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Date: 2/26/82
Revision No.: 0
B
Load-Bearing Capacity: All roads are capable of bearing
loads up to 50,000 pounds per axle. The bulk tanker truck
used to remove inventory from the tank storage area has a
curb weight of 28,000 Ibs. Assuming removal of 7,500 gal
from either of the storage tanks, the tanker will weigh
approximately 91,000 Ibs. The flatbed truck used to remove
drums from the facility has a curb weight of 30,000 Ibs.
Assuming removal of 100 drums at 500 Ibs/drum, the loaded
flatbed truck will weigh about 80,000 Ibs. Therefore, the
facility roads can bear the weight of the trucks.
Traffic Control Signals: Not applicable.
117
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Date: 2/26/82
Revision No.: 0
C
SECTION C
WASTE CHARACTERISTICS
This section describes the chemical and physical nature of
the hazardous wastes stored at the Tankopile facility and the
waste Analysis Plan for sampling, testing, and evaluating the
wastes to assure that sufficient information is available for
their safe handling. The information submitted is in accordance
.with the requirements of 40 CFR §122.25(a)(2) and (3).
C-l Chemical and Physical Analyses [40 CFR 122.25(aH2)1
List of Hazardous Wastes Stored at Facility: Hazardous
wastes are stored at this facility in 55-gallon drum con-
tainers, 7500-gallon tanks, and a waste pile. Current
inventory consists of
100 containers (55-gallon drums)
Two 7500-gallon tanks
One 50-yd5 waste pile
The containers (55-gallon drums) can be broadly classified
into Group A, B, and C containers, grouped separately due
to incompatibility of the wastes. The contents of each
group are listed below:
Group A Yellow drums Pickle liquor sludge (D002, D007,
and D008)
Group B Blue drums Metal grindings (D007 and D008)
118
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Date: 2/26/82
Revision No.: 0
C
Group C White drums Vinyl acetate sludge (D001)
Vinyl chloride sludge (D001)
The pickle liquor sludge is corrosive, and it is toxic
because of its extractable lead and hexavalent chromium
content. The vinyl acetate and vinyl chloride sludges are
ignitable; both have flash points below 60°F. The metal
grindings are toxic; they contain large amounts of extract-
able lead and hexavalent chromium.
Spent pickle liquor [hydrochloric acid (HC1)] and spent
1,1,1-trichloroethane solvent (also referred to as methyl
chloroform) that have become contaminated and diluted
through use in metal cleaning and finishing operations are
stored separately in tanks. Spent pickle liquor is a
listed hazardous waste, assigned hazardous waste number
K062 (40 CFR 261.32) because of its corrosivity and EP
toxicity. It is corrosive because it has a pH of less than
2; it is toxic because of its extractable hexavalent
chromium and lead content. The 1,1,1-trichloroethane is
also a listed hazardous waste, assigned number F001 (40 CFR
261.31) because of its toxicity.
A 50-yd3 (maximum) waste pile is used to store metal hydroxide
sludges which are toxic due to their 'extractable lead and
hexavalent chromium content. The EPA hazardous waste
numbers assigned to these sludges are D007 and 0008.
waste Analyses: Table 3 lists the hazardous wastes stored
119
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TABLE 3
WASTES, ASSOCIATED HAZARDS, AND BASIS FOR HAZARD DESIGNATION
Chemical
Hazard
Basis for hazard designation
Tanks
Pickle liquor
(hydrochloric acid)
1,1,1-tri ch1oroethane
Drums
Vinyl acetate sludge •
Vinyl chloride sludge
Pickle liquor sludge
Metal grindings
Waste pile
Metal hydroxide sludge
Corrosive, Listed waste K062 has pH of 1
Toxic EP toxic, lead and hexavalent
chromium
Toxic Listed waste F001
Ignitible Flash point of pure vinyl acetate
is 18°F. Tested flash point for
waste is 25°F.
Ignitible ' Flash point of pure vinyl chloride
is -108°F. Tested flash point
for waste is 6°F.
Corrosive, Has pH of 1;
Toxic EP toxic, lead and hexavalent
chromi urn
Toxic EP toxic, lead and hexavalent
chromi urn
Toxic EP toxic, lead and hexavalent
chromium
120
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at the Tankopile facility, their associated hazard classi-
fication, and the basis for the hazard classification. .In
most cases the classification is based on known charac-
teristics of the wastes, such as ignitability, reactivity,
corrosivity, or EP toxicity analyses. For listed wastes,
the classification is based on the listing. Figures 11
through 17 show the waste analysis results.
Waste Handling: All wastes (except those in the waste
pile) are labeled; the label describes the contents of each
tank or container and its associated hazard (corrosivity,
toxicity, or ignitability). This practice informs workers
handling these wastes of the associated hazards so that
appropriate precautions can be taken. Details regarding
the tanks, containers, storage areas; and personnel train-
ing are presented in other sections of this application.
General information and hazardous characteristics of the
waste types are included in Appendix A.
C-2 Waste Analysis Plan f40 CFR 122.25(a)(3)1
C-2a Parameters and Rationale
Table 4 shows the hazardous wastes stored at the facility,
the analytical parameters that apply to each, and the
rationale for their selection.
C-Zb Test Methods
Table 5 shows the test methods that are used to measure the
analytical parameters. All test methods are from Test
121
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LABORATORY DATA
n IPNT Tankooile s^^*,
PN
AGOG BATP 1/4/82 (L — C
ANALYST E. Smeal V^^V
^_ ^
Sample No.
CF 102
1,1,1-tri-
:hloroetha
90S
•
V ANALY
C\ MET MO
/ CMECKI
IP
B
sit lj_l ,1-tncnloroethane
3 NUMBER
•a
808
„
Figure 11. Laboratory analysis results - 1,1,1-tricfiloroethane.
122
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RCRA 3A=ARD ASSESSMENT TEST REPORT
Client: TankooilB Finuninq Company
^^*^*"^p
IF:
PEDCo Lab
1261.21 Ita»ITABII.ITf
Flash point
1261.22 COKHOSIvm
I 0
HACZ~"1
1261.23
Acid labile cyanide
Acid labil* suifida
•F (Max. allowed 140T)
PH <12.5
n»/yr (lux
6.35 mm/yr)
Sample type. Solid „ S«aisolid Liquid x
Xzliquldor seBiMlid. non-eilterable soiida - L_»
NOT2* Xf MV&« contains less than 0.5% oonfiltrable aolids.
filtrate la the extract.
Analytical Maulta
Values are concentrations of conatituent in extract.
Constituent
Arsenic
Bariua
Concentration, ng/1
Ciromiua, total
Ojromiua. nexavelent
Mercury
Seleniua
Silver
Lindane
Methoxychlor
Toxaphene
2.4-0
2,4,5-W
M
.001
1
Naxiauv concentration
•Hewed, aq/1
S.O
100.0
1.0
5.0
5.0
5.0
0.2
1.0
5.0
0.02
0.4
10.0
0.5
10.0
1.0
70CD Environmental. Inc. Submitted by:.
Figure 12. Laboratory analysis results for pickle liquor.
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RCRA iUZAJU) ASSESSMENT TEST REPORT
f<
PH: annn
1261.21 TgHITABILITY
Flash point .
1261.22 eoMOSIvm
?«i
NACX""corrosion rate
1261.23 REACTIVITY
Acid labile cyanide
Acid labile
Date Kept
•F (Max. allowed 140*7)
M <12.S
•/yr (Mu
6.3S «/yr)
Liquid
type: Solid __^__ ---
iriiquid or aemiaolid, non-filterable
MOTE: Zf aanple contain! leaa taan 0.5% aonfiltrable
the filtrate i* the extract.
Analytical tesults
value* are concentration* of constituent in extract.
Coaemtratien. «9/l
ATM&iC
Barium
CadBium
Chrouu*. total
Chromium, hoxavalmt
Mercury
Silver
Endria
Lladan*
Metnoxychlor
2,4-0
2,4.5-TP
Haxiaum concentration
alloiMd. nq/1
5.0
100.0
1.0
s.o
s.o
5.0
0.2
1.0
5.0
0.02
0.4
10.0
0.5
10.0
1.0
rironemtal. Xnc. Submitted byi.
Figure 13. Laboratory analysis results for vinyl acetate sludge.
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RCRA HAZARD ASSESSMENT TEST REPORT
_ DM* mnn
Tinfcooile Flnnhino Camganv ™« iUHB-
1261.21 IPIITABILITY
yiaah point 6 'T (lUx. allowed 140«f>
1261.22 eOMOSrV
(2< pa c!2.5 allowed)
•/yr (MM. allatMd 6.35
1261.23
Acid labil*
Acid
1261.24
Saapl* typ«s Solid _ S«l«olid
If liquid or MUMlid. non-eilt*ratola solids
HOTS: If •«apl« eonuuia !••• than 0.5% aonfiltrabl* solida.
tte filtr»*« i» th« •xcraee.
Analytical Results
Values arc eonentrauoa* of constituent in extract.
Constituent concentration, ng/1 Mauana concentration
Arsenic
aariua
Cadao.ua
Caromiia*. total
Chromiua. hexavalant
Lead
Mercury
Seleniua
Silver
Metnosycalor
Toxapnene
2.4-0
2.4.5-W
1. too. Subsatted byt.
Figure 1*. Laboratory analysis results for vinyl chloride sludqe.
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RCRA HAZARD ASSESSMENT TEST REPORT
T«nkani1t Finishing Company - ; — PM: - £000
1261.21 I SUITABILITY
FlMh point T (tux. allowed 140«F)
12(1.22 CORROSIVIT*
pH 1.3 __ (2< pH <12.5 allowed)
corrosion rate "" m«/yr (Max. allowed 6.35 an/yr)
1261.23 REACTIVITY
Acid labile cyanide
Acid labile sulfide
1261.24 EP TOXICITY
SMtpl. typ«: Solid S«l»0lid
If liquid or Mmiaolid.non^filtarabl* solids
MOTE: If staple contains less than 0.3% nonfiltrable solids.
the filtrate is the extract.
Analytical Results
Values are concentrations of constituent in extract.
Constituent Concentration, sq/1 Maximal concentration
allowed. Bg/1
Arsenic '° 01 5-°
nS
1 Ql
IT
S3 C
in
Bariua
Cadmium
Chromium, total
Chromium, aexavalent
Lead
Mercury
Selenium
Silver 'O.ooi
0.02
- 5.0
~ 5.0
"" 5.0
.001 0.2
01 1.0
Ml 5.0
Methoxychlor
Toxaphene
2.4-0
2.4.5-TP
PEDCo Environmental. Xac. Submitted byi.
Figure 15. Laboratory analysis results for pickle liquor
sludge.
126
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Client:
Tankooile Finishing Company
1000
IP; •'Soa (metal grinding)
PEOCO Lab Ho.; CF 107 Date Received;
Reported;
1261.21 ICMITABIL2TY
flash point _
{261.22 CORKOS3
•T (Max. allowed 140*7)
HACZ corrosion rate
1261.23 KEACTTVITT
Acid labile cyanide
Acid labile sulfite
1261.24 8P TOXIC1TT
Saople typet Solid
(2< pH <12.S aliened)
tm/yt (Max. allowed 6.35 ao/yr)
Seodsolid
liquid or aeaiMlid, nbn-filtarabi* solids -
HOTZ: If taaple eoneaine leea than 0.5% aonfiltrable aolids.
the filtrate is the extract.
Analytical Reaulta
Valaee are coneentratiene of constituent in extract.
Constituent
Concentration, ag/1
Areenie
Bariua
CadBiua
Chroaiua. total
Chromiua. hexavalent
Mercury
Seleniiai
Silver
todrin
Netboxyenlor
Toxaphene
2.4-0
2.4.5-W
<0.01
0.6
as. s
'0-0"
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RCflA HAZARD ASSESSMENT TEST REPORT
Client; Tankopile Finishing Company
PNt
4000
1261.21 ISUITABILITY
Flash point
1261.22 CORBOSIVITY
m'T (Max. allowed 140*T)
PH
RACCcorrosionrate"'
1261.23 HEACTIVITt
Acid labile cyanide
Acid labile sulfide
1261.24 EP TOXICITT
Sample typet Solid
If liquid or aemisel]
(2< pa <12.5 allowed)
, »»/yr (Max. allowed 6.35 mm/yr)
___ Semiaolid
non-filterable '•
Liquid
HOTE: tf aaaple contains leaa than 0.5% oonfiltrable solida,
the filtrate la the exrraet.
Analytical Results
Values are concentrations of constituent in extract.
Constituent
Concentration, me/1
Arsenic
Bariua
Cadmium
Chromium, total
Chromium, hexavalent
tead
Mercury
Selenium
Sili
Methoxychlor
Toxaphene
2,4-0
2,4.5-TP
«0 01
JL&.
49.9
Maximum concentration
allowed, mg/1
5.0
100.0
1.0
5.0
5.0
5.0
0.2
1.0
5.0
0.02
0.4
10.0
0.5
10.0
1.0
tal. Inc. Submitted byt
Figure 17. Laboratory analysis results for metal hydroxide sludge.
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TABLE 4
PARAMETERS AND RATIONALE FOR THEIR SELECTION
Hazardous waste
Parameter
Rationale
Pickle liquor
(hydrochloric acid)
1,1,1-trichloroethane
PH, EP
toxicity
(Pb, Cr 8)
1.1,1-
trichloro-
ethane
Vinyl acetate sludge Flash point
Vinyl chloride sludge Flash point
Pickle liquor sludge
Metal grindings
PH, EP
toxicity
(Pb, Cr 9)
EP toxicity
(Pb, Cr 8)
The waste is a listed hazardous waste
(K062) due to its toxicity (lead and
hexavalent chromium) and due to its
corrosivity (pH <2).
This is a listed toxic waste (F001).
There is no reason to believe this
waste will contain any other toxic
constituents in significant concen-
trations.
This waste is ignitible. Practical
grade vinyl.acetate has a flash point
of 18°F. Knowledge of this value
helps to ensure the safe handling of
these wastes.
The waste is ignitible. Practical
grade vinyl chloride has a flash point
of -108aF. Knowledge of this value
helps to ensure the safe handling of
these wastes.
The waste has an estimated pH value of
less than 2, making it a corrosive
waste. Also it may contain toxic
levels of lead and hexavalent chromium.
The grindings contain lead and
hexavalent chromium compounds.
Metal hydroxide sludge EP toxicjty The sludge contains lead and
(Pb, Cr s) hexavalent chromium compounds.
. 129
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TABLE 5
PARAMETERS AND TEST METHODS
Parameter
Test method
Reference
pH
Flash point
EP toxicity
1,1,1-tri ch1oroethane
Lead
Chronri urn
Electrometric
Pens Icy-Martens.
closed-cap tester
EP toxicity test
procedure
GC/FID
Atomic absorption
Atomic absorption
Test Methods for Evaluating
Solid Waste. Physical/
Chemical Methods U.S. EPA
SW-846
ASTM Standard
D-93-79 or D-93-80
40 CFR 261. Appendix II
Test Methods for Evaluating
Solid Waste. Physical/
Chemical Methods U.S. EPA
SW 846.
Methods for chemical
analysis of water and
wastes, EPA-600/4-79/020,
March 1979.
Methods for chemical analysis
of water and wastes
EPA-600/4-79/020
March 1979
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Methods for Evaluating Solid Waste, Physical/Chemical
Methods (EPA Office of Water and Waste Management, SW-846,
1980), or other EFA-approved methods.
C-2c Sampling Methods
Table 6 lists the hazardous wastes stored at the facility
and the methods used to sample each.
C-2d Frequency of Analyses
As Table 7 shows, each waste is analyzed yearly. Because
wastes generated at this facility do not change significant-
ly, this minimum frequency will continue as long as the
quality control program indicates that the products are
within 1 percent of specifications. Additional analyses
will be performed if a process change should affect the
hazardous characteristics of a waste. These analyses will
be conducted at the discretion of the plant manager or the
regulatory agency.
,C-2e Additional Requirements for Waste Generated Offsite
This facility only handles on-site generated wastes; there-
fore, requirements for wastes received from off-site gener-
ators do not apply.
131
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TABLE 6
METHODS USED TO SAMPLE HAZARDOUS WASTES
Hazardous waste
Pickle liquor
1,1,1-trichloroethane
Ul
K)
Vinyl acetate sludge
Vinyl chloride sludge
Sampling method
Sampling a Storage Tank
from "Samplers and
Sampling
Procedures for Hazard-
ous Waste Streams."
EPA-600/2-80-018,
page 36, which appears
in reference for
sampler
Sampling a Storage Tank
from "Samplers and
Sampling
Procedures for Hazard-
ous Waste Streams."
EPA-600/2-80-018,
page 38, which appears
in reference for
sampler
ASTM Standard 0346-75.
Soil or rock-like
material
ASTM Standard 0346-75.
Soil or rock-like
material
Description of sampling
Composite sample using a
Coliwasa sampler from 3
grab samples at top, middle,
and bottom of tank
Composite sample using a
Coliwasa sampler from 3
grab samples at top, middle,
and bottom of tank
Representative composite
sample from 3 grab samples
at top, middle, and bottom
of drum using a split tube
thief sampler
Representative composite
sample from 3 grab samples
at top, middle, and bottom
of drum using a split tube
thief samplers
Reference for sampler
Test Methods for the
Evaluation of Solid
Waste. Physical/Chemical
Methods EPA-SW-846
Test Methods for the
Evaluation of Solid
Waste. Physical/Chemical
Methods EPA-SW-846
n
Test Methods for the
Evaluation of Sol id
Waste. Physical/Chemical
Methods, EPA-SW-846
Section 3.2.4
Test Methods for the
Evaluation of Solid
Waste. Physical/Chemical
Methods. EPA-SW-846
Section 3.2.4
v o
(D Oi
< rt
H (D
in ..
H-
O
D K)
"Z 10
O en
• \
.. oo
NJ
(continued)
-------
(ABLE 4 (continued)
Hazardous waste
Pickle liquor sludge
Metal grinding*
Sampling method
Metal hydroxide sludge
Ul
ASTM Standard 0346-75.
Soil or rock-like
material
ASTM Standard 0140-70.
Crushed or powdered
material
ASTM Standard 0346-75.
Soil or rock-like
material
Description of sampling
Representative composite
sample from 3 grab
samples at top. middle,
and bottom of drum
using a split tube thief
sampler
Representative composite
sample from 3 grab samples
at top, middle, and bottom
of drum using a Trier
scoop
Composite sample using a
Trier scoop from 6 grab
samples through three
different points near the
top of the pile .to points
diagonally opposite the
point of entry
Reference for sampler
Test Methods for the
Evaluation of Solid
Waste. Physical/Chemical
Methods, EPA-SW-846
Section 3.2.4
Test Methods for the
Evaluation of Solid
Waste. Physical/Chemical
Methods, EPA-SW-846
Section 3.2.5
Test Methods for the
! Evaluation of Solid
Waste. Physical/Chemical
Methods, EPA-SW-846
Section 3.2.5
n
n> PI
< ft
H- fl>
in ••
H-
o
& 10
O a\
oo
to
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Vinyl acetate sludge
Vinyl chloride sludge
Pickle liquor sludge*
Metal grindings
Metal hydroxide sludge
TABLE 7
FREQUENCY OF ANALYSIS
Hazardous waste
Pickle liquor
(hydrochloric acid)
1 , 1 , 1- tr i ch 1 oroethane
Analysis
pH, EP toxicity
(Pb, Cr)
1,1,1-trichloro-
Frequency
Annually
Annually
ethane
Flash point
Flash point
pH, EP toxicity
(Pb, Cr)
EP toxicity
(Pb, Cr)
EP toxicity
(Pb, Cr)
Annual ly
Annual ly
Annually
Annual ly
Annually
134
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D
SECTION D
PROCESS INFORMATION
The information provided in this section is submitted in
accordance with the requirements of 40 CFR Part 122.25(b)(l),
(2), and (4). Other regulations addressed to complete this
section include 40 CFR §264.17, §264.175, §264.176, §264.177,
§264.191, §264.192, §264.198, §264.199, §264.252, §264.253,
§264.256, and §264.257.
This section discusses specific process information for the
storage of containers, tanks, and waste piles. The Tankopile
Finishing Company has a 1125-ft2 container storage area, two
7500-gallon storage tanks, and one 50-yd3 waste pile. The waste
pile containment system, container storage area, and tank storage
area designs and specifications were all certified by a registered
professional engineer.
D-l Containers f40 CFR 122.25(bHl) 1
D-la Containers
The maximum inventory of drums in storage at any given time
during the operating life of the facility is not expected
to exceed 100 drums. The container storage area, which is
located outdoors at the northeast end of the facility, cur-
rently holds this amount. Drummed waste includes vinyl
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acetate sludge, vinyl chloride sludge, pickle liquor sludge,
and metal grindings, all of which contain free liquids.
Consequently, specific information provided in this section
will follow a format required for containers storing free
liquids.
There is 1125 ft2 in the container storage area, 225 ft2
for ramp areas providing forklift access to each of the
storage sections, 27 ft2 for sump areas, and 469 ft2 for
aisle space. The remaining 404 ft2 is actual storage area,
and is divided into three sections (storage areas A, B, and
C) separated by curbs to permit the storage of incompatible
wastes. A plan view and cross-sectional view of the con-
tainer storage area is provided in Figures 18 and 19.
Storage areas A, B, and C presently hold 44, 34, and 22
drums, respectively. Stacked three drums high, storage
areas A, B, and C have the capacity to hold as many as 210,
102, and 51 drums, respectively, or a total of 363 drums,
however 100 drums or less are stored in this area at any
given time.
O-la(l) Description of Containers
Steel 55-gallon drums are used at the facility to store the
wastes listed above in D-la. The drums are color coded and
constructed of low carbon steel that meets U.S. Department
of Transportation Specification No. 17C. The ignitable
vinyl acetate and vinyl chloride sludges are contained in
drums painted white to reflect solar heat as a possible
136
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0
r
/GATE
[GATE
CON
AIS
NCE
|
ft
|
1
1
ft
I
t
ft
|
1
i
LE
— 5 f
MM
RAM
l-
P
• 12 ft —
1 1
t '
1 1
' 1
20(ORUNS
1
_ 5 ft -4! S f t -j
RAMP TO
STORAGE
AREA A
12 DRUMS
RAMP TO
STORAGE
AREA 8
RAMP TO
STORAGE
AREA C
12 DRUMS
— i
--
-••
1
1
1
1
^
— •
- 6 ft '- 12 ft
1 ' '
1 1 1
1
! j i
PRIMARY |— 2«* DRUMS
AISLE | T i
i 1 1
>l 1 1
! I"K-
L -JJ ,
SUMP >.
CURB ' PUMP
! 14-
V | 22 DRUMS
1 1 ! !
r~ ' '
y^ ' •— Sn
/PRIMARY "1
AISLE 3 f*
» SUMP/
PUMP^
! \
10 DRUMS!
! 1
H
^__
— • __
^©
3 ft
^^•••VM
(P)
/
V
\
^
®
)
15
" ~
i
.-
10
5
L
r
S
— SECONDARY
/ AISLES
Figure 18. Plan view of container storage area.
137
-------
U)
n
12
ac
in
i
rt
i
i
i
;
^
i
i
I
_
t±
DRUM — »•
i
...
PAUIT — MI
RAHP-J
— »-_ £l
^
1
1
1
i
>
-* —
1
10
1
I
— 5 ft »-
tt
ft
CL
rr1
1
1
1
i
»
i
i
3
i
i
D
j
i
3-. !
n i
~ | SUHP j
1 J_
rtNLL
CHQUNO
- SUHP
PUMP
V
TO HOLDING
TANK C
D » O
(D 0»
< rt
H ID
(A ••
H-
O
3 10
Z to
Fi9"re 19. Cross-sectional view of container storaqe area.
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Date: 2/26/82
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D
ignition source. These drums are protected against corro- .
sion by epoxy phenolic Linings. Yellow drums are used to
store pickle liquor sludge are equipped with polyethlyene
liners. Blue drums used to store metal grindings do not
require a liner for chemical protection.
D-la(2) Container Management Practices
Prior to transfer to the container storage area, sludge and
grinding wastes generated in the processing area are placed
in the proper color-coded drums, sealed, and labeled accord-
ing to Department of Transportation regulations for hazard-
ous materials. Transfer of drums to the container storage
area is performed by a forklift truck. The forklift operator
.'
accesses the storage area with a key and places the yellow
(corrosive sludge) drums in storage area A, the blue (toxic
metal grindings) drums in storage area B, and the white
(ignitable sludges) drums in storage area C. During the
transfer of drums from the process area to the container
storage area, the yellow, blue, and white drums are always
transferred separately from the other colors because of
their incompatibility. At Tankopile there are no sources
of ignition such as an open flame.
The drums are stored on pallets to elevate them from con-
tact with standing liquids, and if necessary, the drums are
stacked as high as 12 ft (3 drums). Primary aisle space of
at least 5 ft is maintained at all times, and the container
storage area is inspected regularly (see Section F-2)."
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D
D-la(3) Secondary Containment System Design and Operation
The container storage area pad is constructed of concrete,
designed for loads of 25 lb/in2. A 6-in.-high concrete
curb lines the perimeter of the storage area to provide a
holding capacity of 3276 gallons, or more than 50 percent
of the total volume held by the estimated maximum inventory.
Below are the calculations involved in determining holding
capacity:
1125 ft2 - 225 ft2 (ramp areas) = 875 ft2
750 ft2 x 0.5 ft (curb height) = 443 ft3
1 ft3 = 7.48 gal
438 ft3 x 7.48 gal = 3276 gal
The concrete pad is presently in good condition, free of
any gaps holes or cracks. The concrete pad in area A is
specially coated with epoxy to prevent damage in the event
of a spill. Two other 6-in. curbs within the storage area
were constructed as partitions to permit the storage of
incompatible wastes in the same storage area. The base of
the storage area is constructed of 6-in.-thick concrete,
and the surface in each storage section is sloped 2 percent
towards its respective sump area.
The pad will be regularly inspected as discussed in Section
F-2 to ensure that i't remains impervious and in good condi-
tion. Automatic sump pumps activated by level switches are
installed in each of the sump areas. The pumps operate at
32 gallons per minute sending collected liquids to three
140
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D
separate secondary holding tanks (see Section D-la(4)).
This prevents any possible overflow of the collection
system from precipitation, leaks, or spills. To date, the
secondary containment system has been able to hold rainfall
from the most severe thunderstorms without risk of rising
above the curb:
Run-on is prevented from entering the containment area by
several means. Besides the presence of a 6-in. curb at the
perimeter of the storage area, the land immediately sur-
rounding the containment area is graded to encourage drainage
away from the area. In addition, drain tiles at the perimeter
of the containment curb drain any collected water to the
sewer system.
A 12-ft-high, chain-link fence with two lockable gates was
installed to ensure safety and security (Figure 18).
D-la(4) Removal of Liquids From Collection System
Storage areas A, B, and C have separate sump areas and sump
pumps to allow for the removal of any leaks or spills to
three secondary holding tanks located just west of the
processing area (Figure 4). A 10,000-gallon holding tank
receives precipitation, leaks, or spills from storage area
A, a 35,000-gallon holding tank receives discharges from
storage area B and leachate runoff from the waste pile
area, and a 5,000-gallon holding tank receives discharges
from storage area C. These collection systems were designed
141
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to handle the maximum 24-hour rainfall recorded in Anytown
(in 24 years). Discharges remain in the holding tanks
until laboratory analyses indicate whether they are either
hazardous or acceptable for release to the municipal sewer
system. If laboratory analyses indicate that a holding
tank contains hazardous waste, the material will be removed
from the tank, drummed, labeled, and transferred to the
appropriate container storage (A, B, or C).
D-lb Containers Without Free Liquids
The Tankopile Finishing Company does not currently manage
containers without free liquids. Therefore, Permit Applica-
tion Sections D-lb, D-lb(l), D-lb(2), D-lb(3), and D-lb(4)
are not applicable.
D-2 Tanks [40 CFR 122.25(b) (2) 1
D-2a Description of Tanks
Two 7500-gallon vertical tanks with a total holding capacity
of 15,000 gallons provide storage for wastes generated from
the degreasing, painting, and metal finishing operations.
The two storage tanks, designated as ST-101 and ST-102,
contain spent hydrochloric acid (pickle liquor) and 1,1,1-
trichloroethane solvent, respectively (Figure 20). The
pickle liquor waste has a specific gravity of 1.0507, and
the 1,1,1-trichloroethane solvent waste has a specific
gravity of 1.299. Both tanks have been fabricated and
stamped in accordance with ASME Code Section VIII, 1971.
Table 8 gives the individual tank dimensions and capacities.
142
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LEGEND
n n
8J
FROM
PROCESSING,
1 - NOZZLE FOR LEVEL TRANSMITTER
2 - PRESSURE SAFETY VALVE
3 - SPARE
4 - INLET
5 - MANHOLE
6 - OUTLET
7 - LIQUID LEVEL TRANSMITTER
8 - WASTE FEED CUTOFF VALVE
ST-102
UK. jji«U|-—•-•
AREA | I
FROM
PROCESSING
AREA
Figure 20. Waste storage tanks.
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TABLE 8
PHYSICAL CHARACTERISTICS OF STORAGE TANKS
Item
Tank Identification No.
ST-101
ST-102
Capacity, gal
Shell thickness, in. (design)
Shell thickness, in. (present)
Dimensions, in.
Straight side
Diameter
7500
0.703
0.699
200.4
118.1
7500
0.703
0.700
200.4
118.1
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The shells of Tanks ST-101 and ST-102 are constructed of
standard A285 Grade B carbon steel (0.22% carbon) with a
tensile strength of 50,000 to 70,000 psi.
Each tank is structurally supported in eight equally spaced
locations on the concrete slab. The supports are raised 6
in., and each is secured to the slab by four No. 4 rods
with three No. 3 ties. The tanks are secured to supports
with 4-3/4-in. Type AB-3 anchor bolts. Tanks ST-101 and
ST-102 are both equipped with an 18-in. manhole, a conser-
vation vent, a liquid level transmitter, an inlet and
•outlet, and spare nozzles. The pad is designed for loads
of 250 lb/in2.
D-2b Tank Corrosion and Erosion
Storage tanks ST-101 and ST-102 are glass-lined (3/32-inch
or 2 mm) for chemical and corrosion resistance. Glass-lined
tanks have been shown to be very resistant to a variety of
chemicals in a wide range of concentrations, including
hydrochloric acid. Furthermore, water absorption is minimal,
and organic liquids such as 1,1,1-trichloroethane produce
no measurable chemical effect on the glass lining. According
to manufacturer specifications,, glass linings exposed to
boiling hydrochloric acid solutions (20 percent) exhibit
low corrosion rates of 0.01626 and 0.02108 tnm/yr. At the
range of rates, the expected lifetime for a -0.91 mm thick
lining would be 43 to 56 years. Since Tankopile's tanks
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are lined with 2 mm of glass, their expected lifetime is
roughly 90 - 120 years.
Weld seams on tanks ST-101 and ST-102 were examined by
radiography and liquid penetrant. The radiogr'aphic inspec-
tion detected no discontinuities in the weld seams, such as
porosity, tungsten inclusions, incomplete penetration, slag
inclusions, lack of fusion, cracks, icicles, burnthrough,
or undercut, that were judged unacceptable to the code.
The liquid penetrant also failed to detect any discontinui-
ties in the weld seams. The glass linings of the tanks
were spark-tested at 6000 volts for discontinuities, and
none were found.
D-2c Tank Management Practices
A simplified process flow diagram is shown in Figure 21.
Spent 1,1,1-trichloroethane solvent wastes and spent hydro-
chloric acid wastes generated from the degreasing and metal
finishing operations are pumped directly to ST 102 and
ST101, respectively, storage tanks through separate piping
systems (3-inch lines). When the tanks are filled to near
capacity, the spent hydrochloric acid is pumped to a tanker
(by use of a positive displacement pump) and transported to
a local publicly owned treatment works (POTW) for treatment.
The 1,1,1-trichloroethane solvent is pumped to a tanker in
a similar manner, and the waste is transported to a reclama-
tion facility.
146
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ATMOSPHERE
PROCESSING
AREA
LIQUID LEVEL
TRANSMITTER
HYDROCHLORIC ACID
UASTE STREAM
70 gal/day
LIQUID LEVEL
TRANSMITTER
1.1.1 - TRICHLOROETHANE
UASTE STREAM
HC1 VAPOR
(UNKNOWN RATE)
CONSERVATION
VENT
7.000 gal/shipment
ATMOSPHERE
60 gal/day
TRICHLOROETHANE VAPOR
(UNKNOWN RATE)
CONSERVATION
VENT
7,000 gal/shipment
TRUCKED
TO
POTU
TRUCKED TO
RECLAMATION
FACILITY
Figure 21. Process flow diagram.
o 50 o
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A piping and instrumentation diagram showing the storage
tanks, instrumentation, and waste feed cutoff valves is
presented in Figure 22. Inlet valves are manually operated
to control waste flow and prevent overfilling.
The waste storage tanks are situated on a 44-ft by 22-ft
concrete pad. The pad is 1 ft thick and reinforced with
No. 5 rods at the top and bottom spaced 12 in. apart.
The pressure safety valves installed on the storage tanks
are Teflon-coated and spring-set to relieve pressures at ±6
in. H20 (0.22 psig). The required capacity of the vents is
7500 scf/h and they are pressure set at 110 percent over-
pressure. Exit from the vents is connected directly to the
atmosphere, which provides a constant back pressure. Under
normal conditions the vents operate at 55°F, although their
range is 0°F to 110°F.
The Taylor Model 3423 TD liquid-level transmitter is a
remote seal instrument that measures liquid levels from 0
to 200 in. H20. The pressure differential in a closed tank
actuates the transmitter and converts the differential
pressure measurement into an electrical signal (level
indicator) by a resistance-strain gage circuit. The trans-
mitter is powered by 24V d.c. and has an output range of 4
to 20 raA d.c. Calibration accuracy of the instrument is ±
0.5 percent of span (0.25 percent ultimate capability).
The measuring element operates at ambient temperatures of •
148
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10 ATMOSPHERE
vo
PICKLING TANKS
PROCESS AREA
VAPOR OEGRLASERS
PUMP
PUMP
PRESSURE SAFE1V VALVE
UAS1E HYDROCHLORIC
ACID STORAGE TANK
51-101
-CXI -
10 ATMOSPHERE
PRESSURE SAfETV VALVE
HASTE 1RICHLOROETHANE
STORAGE TANK
ST-IO*
r-CXl *•
TRUCKED TO
POIM
TRUCKED TO
RECLAMATION
FACILITY
LEGEND
LI • Level Indicator
LAW • Level Indicator Alara
Figure 22. Piping and instrumentation diagram for hazardous waste storage in tanks.
< ft
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-40°? to 300°F, whereas the transmitter housing can with-
stand temperatures of -40°F to 185°F. The explosion-proof
transmitter housing is made of aluminum with a low copper
content and is mounted directly to the tank.
As discussed in Section F-2a(2), the tank level indicators
are inspected daily. Since the tanks are slowly filled two
to three times per year, the daily inspection should allow
ample time to prepare for emptying the tanks. As a back-up
precaution, level indicator alarms (LAH) have been added to
each tank to warn of high fill levels. In such an unlikely
event, the tank inlet valves can be manually closed to
prevent the tanks from overfilling.
D-3 Waste Piles
The waste pile area presently located in the northeastern
section of the facility, approximately 500 ft from the
warehouse building, was installed in May 1978. This pile
will be moved by June 1982 to a new location on the site
which will meet the same design specifications and oper-
ating procedures as the existing waste pile.
Wastes generated by the processing operations at Tankopile
Finishing Company and destined for the waste pile area
consist of metal hydroxide sludge, which is classed as a
toxic hazardous waste because of its hexavalent chromium
and lead content. The waste pile contains free liquids;
consequently, specific information provided in this section
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follows the format required for waste piles with free
liquids.
Several control systems and structural features of the
waste pile area are discussed throughout this section;
therefore, reference to section and plan views of the waste
pile area (Figures 23 and 24) will greatly assist the
reader. Some of the control systems and structures
addressed are control of wind dispersal; control of run-on;
collection of leachate and run-off; foundation; waste pile
base; containment system design; vegetation and rodent
control; and equipment and procedures for waste pile move-
ment.
0-3a Piles With Free Liquids
D-3a(l) Control of Wind Dispersal
Two design factors were addressed to control wind dispersal
of the hazardous waste pile. First, the slope of the pile
was reduced to 7:1, which creates a relatively flat pile
with less resistance to air flow. Second, the banks of the
containment area, which were built to protect the liner and
foundation, further reduce pile exposure to wind currents,
because they rise one foot above ground level. As a result
of both of these factors, only about 1H ft of the waste
pile is exposed to air flow. Furthermore, as a result of
regular inspections, the waste pile will be moistened by a
water truck before the waste pile becomes dry and fugitive
emissions develop.
151
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Ln
PITCH
MM
LHd MUNIIO
/ STANDARD 4' DIA.
/ PRBCAiT MM. WITH
I tCtB-NTRIC COMB TOP
TO SUMP BQUIPPSO
MITM
PUMP
4' THICK
BENTONHC
•' WIWi CRUSHED STOHS
CUTOFF
OfiCP
COLL6CTIOM
SUMP
CLAY
L« ACM ATM COLLBC-TIOM
PIPING,
SUBOHAIM
LOvvSH ^.
-IABLB
COKICRCfB
TICK CONNECTION
»t»PonftTEO PIPE
COLLECTION SUMP
CONTAINMENT SYSTEM SECTION
Figure 23. Containment system section.
-------
ID MO1.MN6
OlILH
. TO MI^IN TO Mr. t M
Figure 24. Conta iiimeiit system plan.
CONTAINMENT SYSTEM PLAN
A-B OBMIQIM A«aoc:iATH»
AHCHITMCT* AMD BIMUIMBBUB
4>B>eM KO.. CIMCIMMATI. O»«|O
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D-3a(2) Control of Run-on
The run-on diversion system consists of a ditch (diversion
canal) surrounding the waste pile containment system. The
ditch is 10 ft wide and has 4:1 sloped banks. The banks of
the diversion canal are lined with several inches of elay
soil with a permeability of 10~* on/s (measured using a
Double Ring Infiltrometer) to reduce infiltration (which
could possibly reach the leachate and ground water collec-
tion systems). In addition to the moderate slope of the
diversion canal banks, riprap was applied to the banks to
reduce erosion. The diversion canal is sloped away from
the waste pile area and drains by gravity directly to the
Queen River.
D-3a(3) Collection of Leachate and Runoff
The leachate and runoff collection system is composed of a
network of 6-in.-diameter, vitrified clay, perforated pipe
connected together and then inserted through the liner and
foundation to a sump area. Pipe leaving the foundation to
the sump area is 6-in.-diameter, vitrified clay, nonper-
forated pipe that allows conveyance of runoff to the sump
area without contaminating the soil.and ground water. The
piping network consists of three parallel sections of pipe
at the bottom of the pea gravel, perpendicularly connected
at one end by another section of pipe. Leachate and runoff
collected in the perpendicular pipe is gravity-fed to an
adjoining pipe and carried through the liner and foundation
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D
to a sump area where it is automatically pumped to a 35,000-
gallon holding tank. Waste in the holding tank will be
analyzed for lead and hexavalent chromium and subsequently
discharged to the sewer system if found not to be a hazard-
ous. If the waste is hazardous, it will be trucked to
Waste Treatment, Inc. located in Anytown, Rhode Island.
0-3a(4) Foundation
The foundation supporting the synthetic liner, base, runoff
collection and removal system, and the waste pile is con-
structed of a Bentonite-treated soil 4 in. thick. The
floor of the foundation covers 1600 ft2 (40 feet square)
and the walls are sloped 3:1, which results in an upper
foundation opening of 4096 ft2 (64 feet square). The
manufacturer of the Bentonite material used for this waste
pile projects that it will last for a period of 20 years.
D-3a(5) Waste Pile Base
The base material supporting the waste pile consists of 2S
ft of coarse sand on top of 1H ft of pea gravel. The base
materials serve several functions. First, the sand and
gravel combination permits rapid percolation of runoff
through the base to a holding tank via the runoff collec-
tion and removal system. This prevents precipitation and
free liquids from overflowing the banks of the containment
system. Secondly, the base material reduces both the
concentration and contact time between contaminated runoff
and the chlorinated polyethylene (CPE) liner, which in turn
155 '
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D
increases the longevity of the liner. Finally, the base
permits movement of mechanical equipment in the waste pile
area without damage%to the liner and prevents exposure of
the liner to direct sunlight which can dry the liner and
significantly reduce its life. After periodic removal of
the waste pile to a disposal site, any lost sand will be
replaced to the original design depth. The waste pile base
is designed for loads up to 15 lb/in2.
D-3a(5)(a) Containment System Design
Adjoined to the foundation with adhesive and mechanical
fasteners is a chlorinated polyethylene (CPE), oil-resistant,
reinforced liner (primary liner) 45 mil in thickness. The
CPE liner, which has a permeability of less than 10"12 on,
was specifically recommended for the metal hydroxide sludge
by the manufacturer because they are compatible. The
existing liner has a project life of 10 years, which expires
in Hay, 1998. The new liner, scheduled to be put under the
waste pile when it is moved in June, 1982, is also projected
to last 20 years, until June, 2002. Other pertinent character-
istics of the CPE liner are provided in Table 9.
D-3a(5)(b) Leachate Detection, Collection, and Removal System
Directly underneath the foundation is a layer of sand and
pea gravel, under which is a network of 6-in.-diameter,
vitrified clay, perforated pipes. Under the pipes is a
6-in.-thick layer of bentonite clay. This backup leachate
collection system is designed to operate in the event of
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TABLE 9
PROPERTIES OF CHLORINATED POLYETHYLENE
(CPE) OIL-RESISTANT LINER
Property
Minimum
nanufacturing
specifications
Test method
1. Fabric (polyester)
2. Laminate thickness
3. Cold bend (36 mil)
4. Tensile strength, Ib
Grab method
5. Tear strength, Ib
Tongue tear method
6. Puncture resistance, Ibs.
7. Hydrostatic resistance
3. Dimensional stability
2 h at 150°F
1 h at 212°F
9. Ozone resistance
10. Seam strength, Ib
Denier, 2*i tpl
t 10% of specified
thickness
-25°F
No cracks
200
80
NAa
2SO
< t 2%
No effect
170
ASTM 0-751
ASTM 0-2136 •
1/8 In. mandrel
ASTM D-751
ASTM D-751
FTM-101B
2031
ASTM 0-751
ASTM D-
1204-54
ASTM 0-1149
3 ppm at 30%
strain at 104°F
for 72 h
ASTM 0-751
NA - not available.
157
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liner failure. If a leak develops in the containment
system, the leachate will percolate rapidly through the
sand and gravel to the leachate collection system and
provide an early warning of liner failure. The piping
network of the leachate collection system consists of seven
60-ft parallel sections of pipe spaced approximately 10 ft
apart and an additional perpendicular pipe that connects
all the pipes. The perpendicular pipe drains any collected
leachate to a leachate-monitoring manhole. The perpen-
dicular pipe, which extends from the side of the sand and
pea gravel to the manhole, is glazed and has lipped connec-
tions secured with caulk. If the pipe were not impervious
groundwater could penetrate the system and indicate false
negative leachate quantities. The 4-ft-diameter manhole is
equipped with a 2-ft-deep collection sump and ladder for
manual measurement of leachate collection. The sump area
has a capacity of 188 gallons. If leachate is collected
and removal is desired, a portable sump pump is used to
evacuate the manhole to 55-gallon drums for analyses, and
if necessary, to storage and disposal.
D-3a(6) Ground Water Table Control
As described under separate cover in the "Hydrogeologic
Evaluation Report", the ground water table in the Anytown,
Rhode Island area is typically 10 ft below ground surface.
Therefore, Tankopile Finishing Company constructed the
following ground water table control system in an effort to
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prevent the ground water table from rising to the leachate
collection system (giving false positive leachate quanti-
ties). A network of 6-in.-diameter, vitrified clay, per-
forated pipes (subdrains) were installed at a depth of 10*s
ft within 3-ft-wide cutoff trenches filled with crushed
stone. The cutoff trenches extend vertically from a foot
below ground surface to a depth of 11 ft. The network
consists of five subdrain sections, four forming a square
(80 ft to a side) around the containment area and another
connecting two of the sides. Ail of the subdrains drain
together, by gravity, to a ground water-monitoring manhole
and sump. Ground water in the sump is automatically pumped
to the outlet of the run-on diversion canal for discharge
into the Queen River. Ground water 'discharged from the
manhole is metered for informational purposes.
D-3a(7) Vegetation and Rodent Control
Prior to the construction of the waste pile containment
system in May 1978, isopropyl N-phenylcarbamate (herbicide)
was applied to the immediate area. If vegetation is
observed during the life of the waste pile, weeds will be
removed by hand or another herbicide treatment will be
applied.
In an effort to control rodents in the area, chloralose
(rodenticide) was applied in the vicinity of the waste pile
area.
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D-3a(8) Equipment and Procedures for Waste Pile Movement
The waste pile is moved by using a front-end loader and a
dump truck. The dump truck is equipped with sides and a
cover to ensure that the load will not overflow or be
exposed to wind or precipitation during loading, unloading,
and transport. One front-end loader is used on the pile to
ensure that the liner is not punctured by the dump truck.
D-3b Waste Piles without Free Liquids
Presently, the Tankopile Finishing Company does not manage
a waste pile without free liquids, therefore, Sections
D-3b, D-3b(l), D-3b(2), D-3b(3), and D-3b(4) are not appli-
cable.
D-4 Surface Impoundments
Presently, the Tankopile Finishing Company does not manage
a surface impoundment, therefore, Section D-4 is not appli-
cable.
D-5 Incinerators
Presently, the Tankopile Finishing Company does not manage
an incinerator, therefore, Section D-5 is not applicable.
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E
SECTION E
GROUND WATER MONITORING SYSTEMS
The requirements for ground water monitoring are not applic-
able to a storage facility such as Tankopile Finishing Company,
which stores containers and tanks and operates a waste pile (not
intended for disposal).
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F
SECTION F
PROCEDURES TO PREVENT HAZARDS
The information provided in this section is submitted in
accordance with the requirements of 40 CFR Part 122.25(a)(4),
(5),(6),(8), and (9). Other regulations addressed to complete
this section include 40 CFR §264.14, §264.15, §264.17, §264.174,
§264.194, and §264.254.
Tankopile Finishing Company will address the following
subject areas (referenced above): general security provisions;
inspection schedule; request for a waiver of preparedness and
prevention requirements; spill prevention, containment, and
countermeasures plan; and prevention of accidental ignition or
reaction of ignitible, reactive, or incompatible wastes.
F-l Security
F-la Security Procedures and Equipment
In addition to the general security provisions of fencing,
gates, and guards discussed below, 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 report upset conditions immediately. In addition to the
two-way portable radios carried by guards and operators, a
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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 communications outside the
plant.
Employees are required to show identification cards when
reporting for work, and visitors and contractors entering
the plant must sign a log sheet (Figure 25) and obtain
visitor passes.
F-la(l) 24-hour Surveillance System
Security at Tankopile Finishing Company is maintained by a
staff of trained security guards, who primarily monitor
entry and exit from the active portion of the facility and
provide security measures within the plant premises.
The main entrance gate at the east end of the facility is
operated by remote control from the guard house, which is
occupied by two armed guards 24 hours a day, 7 days a week,
except during plant shutdowns for holidays at which time
the gates remain locked. Guards normally work an 8-hour
shift with a crew of six guards per day. During each
shift, one of the guards makes a walkthrough of the facil-
ity at scheduled intervals while the other remains in the
guard house.
?-la(2) Barrier and Means to Control Entry
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TANKOPILE FINISHING COMPANY
ANYTOWN, RHODE ISLAND
Visitor/Contractor Entry Log Sheet
Time
Date
Iff
Out
Name
Affiliation
Contact
Purpose of
visit
50 O
n at
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Figure 25. Log sheet.
CD
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P
F-la(2)(a) Barrier
Except for two company parking lots, the entire facility is
enclosed within a 7-ft-high, chain-link fence topped by
three strands of barbed wire. The fence has two gates; one
located at the southwest end of the facility, which is
locked at all times, and the other at the east end of the
facility, which serves as the main entrance to the facil-
ity. In addition, a 12-ft-high, chain-link fence with two
lockable gates was 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.
F-la(2)(b) Means to Control Entry
As discussed in Section F-la(l), entry to the facility is
controlled by two armed guards stationed at the main
entrance gate. Employees are required to show identi-
fication cards when reporting for work, and visitors and
contractors entering the plant must sign a log sheet and
obtain visitor passes.
F-la(3) Warning Signs
Signs which are legible from a distance of 25 feet are
posted at all fence gates and several other fence locations
around the active portion of the facility; these signs are
visible from all angles of approach, and bear the legend
"Danger - Unauthorized Personnel Keep Out." Also, "No
Smoking" signs which are legible for a distance of 25 feet
have been placed in the container storage area.
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F-lb Waiver
The Tankopile Finishing Company does not request a waiver
of the requirements stated in Part 264.14(a)(l) and (2)
regarding injury to intruder and violation by intruder.
F-2 Inspection Schedule
F-2a General Inspection Requirements
The Tankopile Finishing Company conducts regular inspec-
tions of the facility for equipment malfunctions, struc-
tural deterioration, operator errors, and discharges that
could cause or lead to the release of hazardous waste con-
stituents and adversely affect the environment or threaten
human health.
F-2a(l) Types of Problems
Table 10 presents the schedule for inspecting monitoring
equipment, safety and emergency equipment, security devices,
operating and structural equipment, the container storage
area, the tank storage area, tanks (internally and externally),
• and the waste pile area. The items listed in the table are
considered important because of their role in preventing,
detecting, or responding to environmental or human health
hazards. Provided with each item is a list of problems
normally encountered.
F-2a(2) Frequency of Inspection
•
Also provided in Table 10 is a recommended frequency of
inspection for each item.
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TABLE 10. INSPECTION SCHEDULE
Area/aqulpMOl
Specific llw
lypot of prableat
frequency
at Impact Ion
Hunllorlng equipment
lately and emergency
equipment
liquid level trantalltert (lenkt)
Cantervatlan vent* (lenkt)
leachato delectlon. collection, and ituoval tytleei
(•atle pita)
Ground Meier table caalral tytlu (tittle pile)
•unofl collection and reaeval tytle* (uatle pile)
Ground velar tablo Meter Mlar (located In imp)
Standard IndutlrUI abtorbant* (Serb-All. Varalcultle. ale )
Sindbaai
Siml
Aaiarbani baaa
ttiarfeant p*di
Slr*»
Suteartlbla pump
flailbla iMMt ullli quick couplt fllllnai
&S-gallau druBt (ilnl. iltlnliit ilial)
{••rgiocy ilmMr and ayaiiaili
ftca thlaldt and ailra pralaclUa ayiBlatttt
Oltpaiabla ratplralari
ChaaUal cartridge ratplralart nllh canrldgai far arganlc
wtpori and acid gaiai. kail- and full-face lypat
Cnail-wiunlad gat aiaik cannltlari
ielf-canlalnad breallilng apparalut (SCBA)
Parlibla tuap
lira blanketi
lira aillngulinari
fire elera tytlea
lalephane tytlen
Public addrett (PA) lytlea
Ctntrtlort
feMrgency llgbllng lytlea
IIril eld eijulpMnl and tuppllat
&l«u> cleener
fraleclUa clalblng (iBferaealila lull body cmeralU. glavtt.
•nd fael caverlnyi)
Oecanlaailiiallaa ficlllly (ihauert. dlrly roam, clean raoa)
IrenMlllar tlunal. elaclrlcal circuitry, poxar
Spring adjutleunl er clicking
CroundtMter collected, groundwater conleainaied.
tupp puap failure, ealtrntl evidence of Mlfuncilon
level of grotfutuater, •ilernal evidence of mlfuncllon.
tuip puap failure
iroundwaier collected, grounduaier conlaaiinaled.
tuff puap failure, enternil evidence of •>« I function
Clagglng, •alfuncllon of digital dltplay. rolor
clicking, wearing of giari
Out of Hock
lora er worn
Out of ttock
Out of Hock
Out of ilock
r. clogging
Crack* or Mlal. fitting! illck
Cor rot I on. ttructural daaaga
Water preuure. leaking, drainage
Ifaken or dlrly equipment
Out of iteck
Spent chaailcal ediorbanl. taalt
Cannlitert bacoae ailiautlad
Air quantity In reterve. air delivery tytlea. oaltlure
In tank (cold Mather)
Power, clogging
Olipamlng
Haedi reckarglng
•oner failure
Potter failure
•aver failure, ipeakart
fuel tupply. (park plugi, ell
•altary failure, light*
lira* out of tlock or Inoperallva
Malar tupply. fuel tupply
Hole*, normal near and tear
Utter prattura. leaking, drainage, upkeep
0« I ly
Dally
Daily
Dally
0 CO
to
o
-------
TABLE 10(continued)
•raa/aojulpMiil
Specific Urn
lypet of problm
frequency
ol tntpacllun
Security davlcai facility fane*
tail gat* (aaln antranca)
Wail gala and lock
Container ilorigt araa fanca
Cantalnar ttoraga arai gala and lock
(••ola control to aatl gala
1«o-»iy radlot
Operating and ilruclural Su>p puipt (automatic)
aqulpawnt Ollai
laiat or loimdillont
Stop puep (Mnual)
00
Container ttoraga araa
Suap araai
lank itructural tupportt
rlplng to holding lankt
Holding lanki
Storagi araal
Container placeaent and Itack Ing
Sealing of conlalnart
labeling of conlalnart
Container!
Segregation of Incompatible wattat
Fallal.
fence, gala and lock
Bate er foundation
Olket
Suap area
Suep puapt (automatic)
Oebrlt end rafuta
ftaapt
Warning tlgnt
Corral Ion. daajag* to chain-link fanca or barbad «lra
Corral Ion. daaaga to chain-link fanca or barbad «lra
Corroilon. daoiaga la chain-link fanca or barbad ulra.
sticking or corroding lock
Corroilon. da*ago lo chain-link fanca or barbad xlra
Corroilon, daoiagt to chain-link fanca or barbad ulra,
(ticking or corroding lock
Irantalttar or racaUar, ttlcklng of gata
Iraniailttar or racalvar
Salting adjuttaanl. ponar. clogging
Cracki. datarlorallon
froilen; um«an tttllaMnt, crackt and ipalllng In
concrala padi. bata rlngt and plart. datarlorallon of
Hilar Mot batman link bottooi and foundation, vat
apota
Povar. clogging
Irailon. unanan lattlaaant. crock! and ipalllng In
cone rat a
Iroilon. unavan lattlaaant. cracki and ipalllng In
concratt. «at ipoti
Concnto datarlarallon and cracking, corrotlon of plpa
lupporti
ton of aalal thlcknan. laaki. carrot Ion or
datarlorallon
Corroilon. dlicolerallon. crackt. bucklai. and bulgaa
Itlll. ipllll •
Alila tptca. halght of Itacki
Opan lldi
lopropar Idantlf (cation, data Billing
Corroilon. laakaga. tlruclural oafacti
Sloraga ol Inco^atlbla nattat In t»< araa
Oaaagad
-------
TABLE 10 (continued)
Araa/ai|ulpMnl
ipOClflC llaO)
lypet ol probleaii
frequency
ol impact ton
lank tleraua area Mid
ancillary aqulpejanl
lank (eilarnally)
lank (Internally!
Watte |>l la aita
OUt
Bati or foundation
Su«# pup (Miwal)
Smp area
Warnlny tlgn
F>lpai
Valvat
fIlllnyi
Onarflll control value (Mnual) and level IndUalor
ladder
foundallon/ttruclural tupperlt
•Ipa cannacllont
Protective coaling
lank lilt 11
lank root
lank botlaai
Anchor belli
Naulai
lank root
Inlarnal tupporlt
lank thaiI
lank Halloa
Mala Jalnlt
Mania connacllon Jo I nit
Clatt lining
llvalt
Plpacall tupparl
lun-an Jlmrtlan dllcn
[nlranca road toil guard ralU
lunoll dl«trtlon canal and drain
Mind dltpartal conlrol lyilaa
foundation
lynlhtllc llnar
lata
I Inir taaait
Jolnlt
Crackt. dalorloratlon Waakly
Crackt. tpalllny, unavan talllaaanl, aretlun. »cl tpolt Maakly
•owar. clogging Waakly
Crack I. ipalllng. unavan aalllaMnl. arotlon. wal tpolt Uaakly
Oaaagad Weakly
latt ol atalal Ihlcknatt. laakt. cor rot Ion or Waakly
dalarleratlon
Coti ol Mlal Ihlcknatt. liakt. corrotlon or Uaakly
dalarlorallon
lott ol Mlal IbUknatt. laakt, corratlon or Wiakly
dalarlorallon
loti ol Mlal Ihlcknatt. laakt. corrotlon or Dally
dalarlorallon. (ticking, daaagad Handle
Oaoagod. ilruciural liability Wictly
Crackt. ipalllng unavan talllaMnl. arotlon. ual apolt Weakly
lilarnal carrot Ion. cracki. dlttorllon WaaUy
lull tpalt. bllttart. Ilia Illllng Waakly
Corral Ian. deceleration, cracki. bucklat, oulgat Waakly
Hallunctlan ol taalt. blockaga of Mater dralni on root. Waakly
corrotloo
Carretlon, dltcalorallon. cracki, bucklat. bulgat Waakly
Oltlarlloo. carrot Ion Waakly
Crackt. corroiIon kaakly
Hallunclloa of roof't tooli. corratlon, latt ol Mlal yaarly
Ihlcknatt
OaKrlorallon. diprattlant yearly
Corrotlon al «apar tpaco, and liquid lavol Una. "
cracking, buloat. nolat. Ion of Mlal. Ihlcknatt. Ktl'l
taut
Corrotlon pill, tprung taut. rl*tlt. dapratilant. yaarly
bolloa Ihlcknatt. una«annatt of botloa,
Cracking »«»rl>'
Cracking yearly
Cracking. bubHlat /«'[/
llghtnalt. corroilon yeaily
Oaprattlont >aarly
Obtlrucllont la I Ian. bank aratlon, loota riprap Waakly
tutt ofgraval. fuglllti ••litlent, corrotlon and Uaakly
llghlnatt al guard ralll
Obtlruclloni, drain cloggad Waakly
frequency of xalar appllcillon, drynett end tlopa of Dally
pile
Crackt or braakt »l Intlallallon
lean, holet. teperallan of layart. ihln tpali. crackt. Al Intlallallaa
ihrlnkaga. nardnett. e«caitl«e paraaablllly. blltlart
(ration, eiputad era* to liner, daplh Waakly
laar. llgMnatt al tea* »« Intlallallen
llgblnatl of connacllon »« Intlallallon
I »D
(D Ol
< rt
H-ro
u ..
to
CO
M
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Revision No.: 0
F
F-2b Specific Process Inspection Requirements
F-2b(l) Container Inspection
Inspections of the container storage area will be conducted
per the inspection schedule provided in Table 10. Results
of each inspection will be recorded on inspection log
sheets entitled, "Operating and Structural Equipment Inspec-
tion Log Sheet," "Security Devices Inspection Log Sheet,"
and "Container Storage Area Inspection Log Sheet" (Supplement
1-B). Information requested on the log sheets, similar to
that of log sheets for tanks, waste piles, etc., includes
the inspector's name and title, date and time of inspection,
item of inspection, typical problems encountered, status of
the item, observations, and the date and nature of repairs
and remedial action. Typical problems encountered with
each item of inspection, included in the inspection schedule,
are provided on the log sheet to serve as a reminder to the
inspector and to ensure a complete inspection. The inspector
is required to check the status of each item and indicate
whether its condition is acceptable or unacceptable.
Regardless of the status, observations are made as to the
number of containers, aisle space, height of container
stacking, inventory quantities, storage tank levels, observa-
tion of runoff in waste pile area, and more. If the status
of a particular item is unacceptable, appropriate and
complete information is recorded, including date and nature
of repairs and remedial action.
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F-2b(2) Tank Inspection
Tank inspections will be conducted per the inspection
schedule provided in Table 10. Results of each inspection
will be recorded on inspection log sheets entitled, "Moni-
toring Equipment Inspection Log Sheet," "Operating and
Structural Equipment Inspection Log Sheet," "Tank Storage
Area and Ancillary Equipment Inspection Log Sheet," "External
Tank Inspection Log Sheet," and "Internal Tank Inspection
Log Sheet" (Appendix). Upon completion of the inspec-
tion log sheets, they will be inserted in the inspection
log three-ring binder previously discussed in Section
F-2JD(1).
F-2b(3) Waste Pile Inspection
During the installation of the waste pile liner system,
strict quality assurance of the workmanship was part of
standard installation procedure. The liner was inspected
for uniformity, damage and imperfections. The waste pile
inspections will be conducted per the inspection schedule
provided in Table 10. Results of each inspection will be
recorded on inspection log sheets entitled, "Monitoring
Equipment Inspection Log Sheet," "Operating and Structural
Equipment Inspection Log Sheet," and "Waste Pile Area
Inspection Log Sheet." Upon completion of the inspection
log sheets, they will be inserted in the inspection log
three-ring binder previously discussed in Section F-2b(l).
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F-2c Remedial Action
If inspections reveal that non-emergency maintenance is
needed, they will be completed as soon as possible to
preclude further damage and reduce the need for emergency
repairs. If a hazard is imminent or has .already occurred
during the course of an inspection or any time between
inspections, remedial action will be taken immediately.
Tankopile Finishing Company personnel will notify the
appropriate authorities per the Contingency Plan (see
Section G) and initiate remedial actions. In the event of
an emergency involving the release of hazardous constituents
to the environment, efforts will be directed towards contain-
ing the hazard, removing it, and subsequently decontaminating
the affected area. Refer to the Contingency Plan for
further details.
F-2d Inspection Log
An inspection log is maintained for each calendar year in a
three-ring binder that is subdivided by sections for each
area/equipment. After an inspection, each log sheet is
filed in the binder according to area/equipment, which
provides a case history of a particular item. The inspec-
tion log notebook is always kept with the inspection sched-
ule in the Environmental Engineer's office. As required,
records of inspections are kept for at least 3 years from
the date of inspection. A copy of the inspection log
sheets may be found in the Appendix.
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F-3 Waiver of Preparedness and Prevention Requirements
The applicant does not wish to request a waiver of the
preparedness and prevention requirements under 40 CFR §264
Subpart C. Requirements of this Subpart are primarily
addressed in Section D, Section F, and Section G of this
application.
F-3a Equipment Requirements
Internal and external communications, emergency equipment,
and fire control equipment are discussed in Section F and
Section G.
F-3b Aisle Space Requirements
Aisle space requirements are addressed in Sections 0-la(2),
F-5c, and G.
F-4' Preventive Procedures, Structures, and Equipment
F-4a Loading/Unloading Operations
Loading operations at the facility, other than removal
operations at the container, tank, and waste pile storage
areas, take place in the processing area. Except for tank
storage wastes, wastes generated in the processing area are
collected in hoppers and loaded into drums or front-end
loader for transport to the appropriate storage area.
During loading operations spills are unlikely; however, in
the event of an accident the material will be contained
with sandbags, standard industrial absorbents, absorbent
boom and pads, or dirt. Contaminated materials will be
contractor-hauled to a permitted hazardous waste landfill,-
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F
and affected areas of the facility and equipment will be
decontaminated.
The only areas that involve unloading operations at Tankopile
Finishing Company are the container storage area and the
waste pile area. Wastes stored in the tank area are piped
directly from the processing area to the storage tanks.
Several precautions have been taken to reduce the potential
for hazards during unloading operations in the container
storage area. First, three ramps were designed and con-
structed to facilitate the smooth and accessible movement
of a forklift truck in and out of each of the storage area
sections (Figure 18). Second, at least 5 feet of aisle
space is maintained at all times. Third, pallets are used
in the transport of drum containers.
Unloading operations in the waste pile area involve the
transport of wastes from the processing area to the waste
pile via front-end loader or dump truck. The front-end
loader is equipped with a cover to prevent hazardous waste
dispersal. Entrance to the waste pile area is by a gravel
road, which slopes away from the pile to prevent run-on
from entering the waste pile area (Figure 24). At the
intersection of the road entrance and the diversion canal,
a guard rail was installed on both sides of the road to
prevent the front-end loader from driving into the canal
and spilling the waste. The front-end loader is driven up
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F
the access ramp where its contents are emptied onto the
waste pile.
F-4b Runoff
Runoff from the container storage area and waste pile area
is collected and automatically pumped to three holding
tahks located just east of the container storage area
(Figure 4). Runoff from Storage Area A is diverted to
Holding Tank A, runoff from Storage Area B and the waste
pile area is collected in Holding Tank B, and runoff from
Storage Area C is diverted to Holding Tank C. Runoff con-
tained in Holding Tanks A and C is discharged to the munici-
pal sewer system if no leaks or spills from containers are
detected during inspection, contents of Holding Tank B,
which consists of runoff from Storage Area B and runoff and
leachate from the waste pile area, will be examined by
laboratory analyses and either discharged to the sewer
system (if determined not to be a hazardous waste) or
drummed and stored onsite for later disposal at a facility
authorized to accept the waste types. In the event that a
spill or leak is detected in Storage Areas A or C, runoff
collected in their respective holding tanks will be managed
similarly to waste received in Holding Tank B discussed
above.
Runoff from all other areas of the facility drains directly
into the municipal sewer system.
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Because the Tankopile Finishing Company is located in a
100-year floodplain, provisions have been made to minimize
flooding, and emergency procedures have been established
for the possible but unlikely occurrence of a flood. These
procedures are discussed in the Emergency Procedures section
of the Contingency Plan (Section G).
F-4c Water Supplies
Ground water contamination is prevented by eliminating the
discharge of hazardous materials onto the unprotected
ground. The container storage area is constructed of a
concrete base, dikes, sump areas, sump pumps, and holding
tanks to contain leaks, spills, and precipitation. The
waste pile area is also designed and constructed to prevent
water supply contamination. Refer to Section D-3a for a
complete description of the design and construction of the
waste pile area, including a leachate collection system,
wind dispersal control system, and runoff and run-on collec-
tion system.
F-4d Equipment and Power Failure
In the event of a brief power interruption, emergency
generators will be started to maintain process operations,
and the emergency lighting system will activate automatic-
ally supplying lighting to all facility buildings and
property. If there is a prolonged power outage, the waste
feed lines to the tank storage area will be manually shut
off and all plant operations will be shut down. After
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F
shutdown, maintenance personnel will check for malfunction
and equipment failures, and the Anytown Power and Light
will be contacted immediately for assistance. Refer to
Emergency Procedures in the Contingency Plan for more
details.
F-4e Personnel Protection Equipment
General information on the major chemical components of the
wastes in the container, tank, and waste pile areas is
provided in the Appendix under General Information and
Hazardous Characteristics of Wastes. The sheets present
information on various chemicals regarding toxicity, fire
and explosion hazards, protective equipment recommenda-
,'
tions, and first aid. Available protective equipment is
presented under Emergency Equipment and Provisions of the
Contingency Plan (see Section G). Use of protective equip-
ment is covered in the initial and annual Personnel Train-
ing Programs (see Section H), which satisfies the Occupa-
tional Safety and Health Standards of 29 CFR Part 1910
Subpart I - Personal Protective Equipment.
F-5 Prevention of Reaction of Iqnitable, Reactive, and
Incompatible Wastes
F-5a Precautions to Prevent Ignition or Reaction of Ignitable
or Reactive Wastes
The container storage area is the only area on the facility
property where ignitable wastes are stored. No reactive
wastes are stored at the facility. The containers, as dis-
cussed in Section D-la(l), are compatible with the contained
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F
wastes; therefore, the only source of ignition is external
to the containers. To prevent a possible source of external
ignition, drums containing ignitable wastes are painted
white to reflect solar heat and signs are placed in the
container storage area clearly marked with the legends, "No
Smoking" and "Danger - Unauthorized Personnel Keep Out."
Sparkproof tools (brass hammers, wrenches, etc.) are used
on all containers and tanks storing ignitable materials.
F-5b General Precautions for Handling Ignitable or Reactive
Wastes or Accidentally Mixing Incompatible Wastes
General precautions for handling ignitable or reactive
wastes were discussed above. Incompatible wastes are not
mixed at Tankopile Finishing Company.
F-5c Management of Ignitable or Reactive Wastes in Containers
Precautions taken in the container storage area to prevent
accidental fire and explosion include the proper storage of
containers (e.g., stacking, aisle space, and labeling and
sealing of containers), dikes, sump areas and sump pumps,
and appropriate warning signs.
Prior to storage, each container is sealed and labeled.
This prevents precipitation from entering the drum, and
identifies the contents of the container and the date
wastes were generated. Containers are stored on pallets to
minimize contact with precipitation, leaks, or spills, and
they are never stacked more than three containers high. A
minimum of 5 ft is maintained in the aisles to allow access
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F
for a forklift without risk of damaging containers by
scraping or puncturing.
t
The container storage area is located 700 ft from the
closest company property line (Figure 4), which is in
compliance with the National Fire Code Standards for out-
door storage of containers holding ignitable or reactive
wastes.
F-5d Management of Incompatible Wastes in Containers
Drums used at TanJcopile Finishing Company are color-coded
white for vinyl acetate and chloride sludges, yellow for
pickle liquor sludges, and blue for metal grindings. This
system prevents an operator from placing waste in a container
that previously held an incompatible waste.
Incompatible wastes stored in the container storage area
are separated by 6-in.-high curbs, and each of the three
storage area sections has a separate sump area, sump pump,
and holding tank to prevent mixing of the wastes.
F-5e Management of Ignitable or Reactive wastes in Tanks
Hazardous waste properties of storage tank waste materials
generated from the finishing operations at the Tankopile
Finishing Company are corrosivity and toxicity. No ignit-
able or reactive waste materials are stored in the tanks.
The location of the waste storage tanks complies with the
buffer zone requirements for stable liquids (operating
pressure 2.5 psig or less) contained in the National Fire
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F
Protection Association's 1981 "Flammable and Combustible
Liquids Code" for vertical tanks with emergency relief
venting. The storage tanks are designed to relieve pres-
sures in excess of 0.22 psig. The facility provides pro-
tection for exposures by location- within the jurisdiction
of the Anytown Fire Department and by operation of its own
fire brigade.
F-5f Management of Incompatible Waste in Tanks
Waste materials stored in the tank storage area are incom-
patible. When 1,1,1-trichloroethane comes in contact with
acid or acid fumes, highly toxic chloride fumes are gener-
ated. The tanks therefore have separate piping systems.
Pressure safety valves were installed on both tanks to"
relieve pressure buildup and prevent a possible explosion.
Furthermore, regular inspections as discussed in section
F-2b(2) will be conducted to ensure safe operations.
F-5g Management of Ignitable or Reactive Wastes in Waste Piles
Ignitable or reactive wastes are not stored in the waste
pile at Tankopile Finishing Company.
F-5h Management of Incompatible Wastes in Waste Piles
Incompatible wastes are not stored in the waste pile at
Tankopile Finishing Company.
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G
SECTION G
CONTINGENCY PLAN
The information contained herein is submitted in accordance
with the requirements for a Contingency Plan, as contained in
40CFR§122.25(a)(7) and §264 Sub part D.
Contingency Plan [40 CFR 122.25U)(7) 1
The intent of §264, Subpart D (Contingency Plan and Emer-
gency Procedures), of RCRA is to ensure that facilities
that treat, store, or dispose of hazardous wastes have
established the necessary planned procedures to follow in
the event an emergency situation should arise.
The intent of the requirements under 40 CFR §264, Subpart C
(Preparedness and Prevention), which was described in
Section F, is to ensure that the facility is properly
designed and equipped to minimize the possibility of acci-
dents and prevent the occurrence of emergency situations.
The requirements under 40 CFR §264 Subpart 0 address the
actions that are to be taken if an accident should occur.
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G-l General Information
This contingency plan is for the Tankopile Finishing Com-
pany, Inc., located at 3100 West llth Street. Anytown,
Rhode Island 02881. Tankopile is primarily a manufacturer
of metal automotive parts (i.e., body parts, hubs, and
trim) and household appliance housings and parts. Mary P.
Jones is the owner and operator of the facility. Ms. Jones
may be reached at (401) 555-6789 from 9 a.m. to 5 p.m. on
weekdays. Mr. John Smith, Environmental Engineer, is the
primary emergency coordinator at the facility and may be
reached at (401) 555-3219 from 9 a.m. to 5 p.m. on week-
days. Other emergency coordinators may be reached at this
telephone extension during other hours.
Tankopile stores hazardous waste in three locations. A
waste pile with a maximum storage of 50 yd2 is used to
store metal hydroxide wastes. Two 7,500-gallon tanks are
used to store 1,1,1-trichloroethane waste solvent and spent
pickle liquor. A container storage area has an estimated
maximum storage capacity of 100 drums. A general site plan
and a full description of the facility is contained in
Section B. A description of the wastes is contained in
Section C. " Included in the copies of the Contingency Plan
provided to emergency organizations, these.two sections (B
and C) have been added as Appendices.
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G-2 Emergency Coordinators
If an emergency situation develops at the facility, the
discoverer should contact an emergency coordinator listed
in Table 11. John Smith, primary Emergency Coordinator,
should be contacted first, and if he is not available, the
others should be called (in the order listed) until someone
is reached. The primary Emergency Coordinator and alternates
have complete authority to commit all resources of the
company in the event of an emergency. Table 12 lists
organizations that could possibly be contacted by the
Emergency Coordinator in the event of an emergency.
TABLE 11
EMERGENCY COORDINATORS
Home Work Home
Name Title address phone No. phone No.
John Smith Environmental Engineer 453 Elm St. Ext.3219 221-2932
Joseph Williams Plant Manager 911 5th St. Ext.3225 362-3801
Albert Brown Vice President, Operations 1101 Main St. Ext.3220 921-4410
G-3 Implementation of the Contingency Plan
The decision to implement the contingency plan depends upon
whether or not an imminent or actual incident could threaten
human health or the environment. The purpose of this
section is to provide guidance to the emergency coordinator
in making this decision by providing decision-making criteria.
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TABLE 12
EMERGENCY CONTACTS
Date: 2/26/82
Revision: 0
G
Emergency
Organizati on/agency
Emergency No.
Injury
Fire/explosion
Hazardous material
spill or release
If spill reaches
navigable water
Natural disaster
Potential flood
All of the above
Anytown Hospital
Washington County Hospital
Rhode Island
Medical College
Poison Control Center
Washington County Fire Oept.
Anytown Fire Dept.
Anytown Fire Dept.
Washington County Fire Oept.
U.S. EPA Region I Response
Center
Rhode Island Emergency
Management
National Response Center
Washington County Emergency
Management Agency*
Army Corp of Engineers
Engineer
Rhode Island Emergency
Management Agency*
American Red Cross
911
Ambulance - 863-4800
Info. - 863-3232
821-8305
724-5050
798-6818
722-5351
722-5351
798-6818
24-hr. emergency No.
617/472-3815
401/702-4895
800/424-8802
911 or 724-4444
401/704-4362
24-hr. No. -
401/826-4739
722-1821
* This agency may also be contacted in any emergency event if necessary.
They will coordinate the proper agencies/organizations as needed.
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The contingency plan will be implemented in the following
situations:
1. Fire and/or Explosion
a. A fire causes the release of toxic fumes.
b. The fire spreads and could possibly ignite
materials at other locations onsite or could
cause heat-induced explosions.
c. The fire could possibly spread to offsite
areas.
d. Use of water or water and chemical fire
suppressant could result in contaminated
runoff.
e. An imminent danger exists that an explosion
could occur, causing a safety hazard because
of flying fragments or shock waves.
f. An imminent danger exists that an explosion
could ignite other hazardous waste at the
facility.
g. An imminent danger exists that an explosion
could result in release of toxic material.
h. An explosion has occurred.
2. Spills or Material Release
a. The spill could result in release of flam-
mable liquids or vapors, thus causing a fire
or gas explosion hazard.
b. The spill could cause the release of toxic
liquids or fumes.
c. The spill can be contained onsite, but the
potential exists for ground water contamina-
tion.
d. The spill cannot be contained onsite, result-
ing in offsite soil contamination and/or
ground or surface water pollution.
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3. Floods
a. The potential exists for surface water'
contamination.
G-4 Emergency Response Procedures
G-4a Notification [40 CFR 264.56(a)]
In the event of an emergency situation the emergency coor-
dinator will be notified first; subsequently, all facility
personnel, appropriate federal, state, or local agencies,
and fire or police departments will also be notified. See
Figures 26 and 27. .
G-4b Identification of Hazardous Wastes [40 CFR 264.56(b)]
The emergency coordinator will immediately identify the
character, exact source, amount and area extent of the
release. The initial identification method will be to
utilize visual analysis of the material and location of the
release. The containers are color coded as to their con-
tents and are in distinct separate locations. The tanks
and piping from the process area to the tanks are labeled
to identify whether they hold waste pickle liquor or tn-
chloroethane. The waste pile area would only have metal
hydroxide sludge. If for some reason the released material
cannot be identified, visual samples will be taken for
chemical analysis.
G-4c Assessment [40 CFR 264.56(c) and (d)]
The emergency coordinator will assess possible hazards,
both direct and indirect, to human health or the environ-
ment.
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EMERGENCY
/ OCCURS \
SPILL
OR
MATERIAL
RELEASE
FIRE
AND/OR
EXPLOSION
IF POSSIBLE
CONTAIN SPILL
IF POSSIBLE CONTAIN
OR EXTINGUISH FIRE
CALL EMERGENCY
COORDINATOR
IMPLEMENT
CONTINGENCY
PLAN
NOTIFY LOCAL, STATE,
AND IF NECESSARY.
FEDERAL AUTHORITIES
CALL FIRE DEPARTMENT
Figure 26. Overview of emergency plan of action.
50 C»
ID Pi
< ft
H ro
in ••
H-
o
3 ro
\
25 M
O en
oo
K)
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G
t
uni«
•"«-» 7. M.,»™f,.
NUBBJIS M 1 .»IU». I IB
loci
««M •• uni
•IffHSI V H«nt *4 OC
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G-4d Control Procedures [40 CFR 264.52(a)] .
Potential accidents fall under three general classifica-
tions: (1) fire and/or explosions, (2) spills or material
release, (3) floods. Natural disasters such as earthquakes
or hurricanes are assumed to fall into one of these three
classifications. An overview of the emergency plan of
action is outlined in Figure 26. Figure 27 is a more
detailed emergency plan of action, including phone numbers.
Fire and/or Explosion
The storage tank, container, and waste pile areas can be
easily accessed by fire-fighting and other emergency
vehicles and equipment. A paved blacktop road, about 25 ft
in width, passes within 100 ft of each of these-areas.
This road is kept clear at all times.
A company fire brigade will be on standby during all general
plant emergencies. During times of power failure or severe
weather, fire protection personnel will be assigned to
protect personnel and property. If a fire should break
out, concentration will be placed on preventing the fire
from spreading to nearby areas. The fire-fighting effort
will be carried out by the fire brigade until outside
assistance has arrived.
The following actions will be taken in the areas affected
by the fire or explosion:
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1. Fire doors in buildings will be closed.
2. Hazardous work in all areas will be shut down
immediately.
3. All feed lines and additional equipment will be
shut down, as necessary and practical.
4. The Emergency Coordinator will be contacted (See
Table 10.)
5. The area will be cleared of all personnel not
actively involved in fighting the fire. These
persons are to report to the designated rally
points for accountability. Rally points are
designated in Figure 28. All persons in Section
1 on Figure 28 proceed to Rally Point 1; those in
Section 2 to Rally Point 2.
6. All injured persons will be removed, and medical
treatment will be administered by qualified
personnel.
Because fire is always a potential hazard in spills of
flammable materials, possible sources of ignition have been
eliminated. Vehicular' traffic and hazardous work in the
area will cease until the spill is contained and safety is
restored. If spilled materials are flammable, the fire
brigade will respond with foam equipment and hoses. Flush-
ing with large quantities of water or foaming of the spill
will be performed if advised by the fire brigade chief.
If a highly flammable material is released (e.g., propane
or natural gas), all persons within at least a quarter-mile
radius of the release will be notified. All ignition
sources within this area will be eliminated. Use of motor
vehicles within this area will be restricted or eliminated
to avoid ignition of the vapor, which can cause a flashback
to the source and an initial explosion of fire of wide
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rijTUK
3WI»
SECTION
1
7 --^acra
:!»t»vai -
<
SECTION 1 | SECTION 2
380 ft
y
OATt: 8/10/81
"igure 2£. Sally points in the event of fir« or axoioslon.
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brigade chief is always the lead shift foreman. Super-
visors of unaffected areas will stay with their personnel
and be ready to evacuate and account for the persons under
their supervision.
An "all clear" signal will be given when the fire has been
extinguished and the safety of personnel is no longer
endangered. The fire brigade chief will determine when the
emergency has passed and consult with the Emergency Coor-
dinator before the "all clear" signal is given. All emer-
gency equipment used in the emergency must be cleaned and
fit for use prior to resumption of plant operation in the
affected areas.
Spills or Material Release
In the event of a major emergency involving a chemical
spill, the following general procedures will be used for
rapid and safe response and control of the situation.
Emergency contacts found in Figure 27 provide a quick-
reference guideline to follow in the event of a major
spill.
If an employee discovers a chemical spill or process upset
resulting in a vapor release, he or she will immediately
report it to the area supervisor.
The area supervisor will contact the designated Emergency
Coordinator at the time of the incident, when contacted,
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the designated Emergency Coordinator will obtain informa-
tion pertaining to the following:
1. The material spilled or released
2. Location of the release or spillage of hazard-
ous material
3. An estimate of quantity released and the rate
at which it is being released
4. The direction in which the spill or vapor or
smoke release is heading
5. Any injuries involved
6. Fire and/or explosion or possibility of these
events
7. The area and materials involved and the
intensity of the fire or explosion.
This information will help the Emergency Coordinator to
assess the magnitude and potential seriousness of the spill
or release. If the accident-is determined to lie within
the company's emergency response capabilities, the Emergency
Coordinator will contact and deploy the necessary inplant
personnel. If the accident is beyond plant capabilities,
the Emergency Coordinator will contact the appropriate
agencies. A list of agencies and phone numbers can be
found in Table 12.
The initial response to any emergency will be to protect
human health and safety, and then the environment. Identi-
fication, containment, treatment, and disposal assessment
will be the secondary response.
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In the event of a leak or spill in the tank area, all feed
lines to the storage tanks will be closed. The dike sur-
rounding the tank storage area has the capacity to hold the
largest tank and any rainfall. Immediately after the spill
is detected, a local contractor will be summoned to remove
any standing liquids and haul the spilled material to a
facility approved to handle that particular waste.
If for some reason a chemical spill is not contained within
a dike or sump area, an area of isolation will be established
around the spill. The size of the area will generally
depend on the size of the spill and the materials involved.
If the spill is large and involves a tank or a pipeline
rupture, an initial isolation of at least 100 ft in all
directions will be used. ' Small spills or leaks from a tank
or pipe will require evacuation of at least 50 ft in all
directions to allow cleanup and repair and to prevent
exposure. When any spill occurs, only those persons in-
volved in overseeing or performing emergency operations
will be allowed within the designated hazard area. If
possible the area will be roped or otherwise blocked off.
If the spill results in the formation of a toxic vapor
cloud (by reaction with surrounding materials or by out-
break of fire) and its release (due to high vapor pressures
under ambient conditions), further evacuation will be
enforced. An area at least 500 ft wide and 1000 ft long
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will be evacuated downwind if volatile materials are spilled.
Because the distance to the closest urban area is about 5
miles, it is unlikely that evacuation of its population
will be necessary in the event of a release of toxic mate-
rial. Industrial areas within a mile of the plant will be
notified, however, if a large quantity of spilled material
ignites. Because winds in the area tend to vary, the
quickest and most accurate assessment of meteorological
conditions is accomplished by calling the National Weather
Service at 798-5558 or Anytown Airport at 861-6610.
If the control and cleanup of a spill, release, or fire is
within the capabilities of company personnel and local
response teams, the Rhode Island Department of Environmental
Management or the National Response Center will not be
notified unless one of the following occurs:
0 A spill discharges to the Queen River and the
quantity of hazardous material spilled is
equal to or greater than the reportable
quantity specified under 40 CFR Part 117.
0 One thousand gallons or more of oil is spilled
in a single event. If a lesser quantity has
been spilled but has entered a storm sewer
leading to the Queen River, it is advisable -
to contact local and state authorities for
assistance if it is not possible to intercept
the spill at the. outfall or prevent the oil
slick from moving downstream.
e The spill involves other hazardous materials
not listed but used at the plant if they' pose
an actual or potential hazard to life or
property.
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As called for in regulations developed under the Comprehen-
sive Environmental Liability and Compensation Act of 1980
(Superfund), our practice is to report a spill of a pound
or more of any hazardous material for which a reportable
quantity has not been established and which is listed under
the Solid Waste Disposal Act, Clean Air Act, Clean Water
Act, or TSCA. We also follow the same practice for any
substances not listed in the Acts noted above but which can
be classified as a hazardous waste under RCRA.
If the Emergency Coordinator determines that the company is
unable to handle the emergency, then local, state, and
Federal authorities will be notified of the situation.
Evacuation of all potentially affected plant areas will be
initiated as soon as possible.
The following guidelines will be used in case of an acci-
dental episode involving waste materials. These are general
guidelines, and circumstances may dictate some alterations
to these procedures.
Most waste spills and leaks are easily contained within the
dikes and sumps provided in the tank area. Small spills
occurring in a diked area are flushed with plenty of water,
to the sump provided in that area. If necessary, a portable
sump pump is used to pump the diluted waste material into
55-gallon drums. Procedures for handling large spills were
discussed earlier in this section.
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For all large spills or serious leaks the following guide-
lines will be followed as closely as possible:
1. If a leak develops or a spill occurs from a
waste storage tank, pipeline pump, etc., the
person discovering the discharge will leave
the immediate area and contact the Emergency
Coordinator. The Emergency Coordinator will
obtain the following information:
a. Person(s) injured and seriousness of
injury.
b. Location of the spill or leak, material
involved, and source (tank, pipeline,
etc.).
c. The approximate amount spilled, an
estimate of the liquid and/or gas
discharge rate, and the direction the
liquid flow or gaseous cloud is moving.
d. Whether or not a fire is involved.
2. Next, the Emergency Coordinator will:
a. Initiate evacuation of the hazard area.
For small spills or leaks, isolate at
least 50 ft in all directions. For
large spills, initially isolate at
least 100 ft in all directions and keep
all persons upwind of spill.
b. Obtain medical attention for any injured
persons. It may be helpful to instruct
the caller in initial first aid pro-
cedures. Then call the hospital.
c. Call the fire department if a fire is
involved that cannot be extinguished by
plant personnel. Fight small fires
with dry chemicals, C02, or foam, and
large fires with water spray, fog, or
foam. Keep heat-exposed containers
cooled with water spray and remove them
from the fire if possible. IF A RISING
SOtJND COMES FROM A VENTING DEVICE OR
THE TANK BEGINS TO DISCOLOR, WITHDRAW
FROM THE AREA IMMEDIATELY.
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d. Dispatch emergency personnel to the
site to take the appropriate action.
e. Contact the proper authorities (Figure
27 and Table 11) if the spill or release
is large. Contact local authorities
first so that, if necessary, downstream
water users and/or persons downwind of
the vapor can be notified and, if
necessary, evacuated. If a large spill
occurs, the initial evacuation area
downwind should be 0.2 mile long (=1000
ft) by 0.1 mile wide (sSOO ft). If a
tank containing waste becomes involved
in a fire, isolate an area H male in
all directions.
3. Cleanup personnel will:
a. Make sure all unnecessary persons are
removed from the hazard area.
b. Put on protective clothing and equip-
ment.
c. If the flammable waste is involved,
remove all ignition sources, and use
spark and explosion proof equipment and
clothing in containment and cleanup.
d. If possible try to stop the leak.
Special materials will be kept on hand
for temporary repairs.
e. Remove all surrounding materials that
could be especially reactive with
materials in the waste. Determine the
ma]or components in the waste at the
time of the spill.
f. Use absorbent pads, booms, earth,
sandbags, sand, and other inert mate-
rials to contain, divert and clean up a
spill if it has not been contained by a
dike or sump. Most spills contained
within the dike or sump can be pumped
back into the appropriate sto'rage tank
or drum.
g. If wastes reach a storm sewer, try to
dam the outfall to the Queen River by
using sand, earth, sandbags, etc. If
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this is done, dilute wastes in the
storm sewer with large quantities of
water and pump this material out into a
temporary holding tank or drums as soon
as possible. If a spill enters the
river or has entered a storm drain, use
absorbent booms and sweeps around the
outfall to contain and absorb water-
insoluble organics.
h. Place all containment and cleanup
materials in drums for proper disposal.
Some items, such as absorbent rags or
booms may have to be cut up.
i. Place all recovered liquid wastes and
contaminated soil in drums for removal
to an approved disposal site.
Following are procedures to follow if a large amount of
material spills onto unprotected ground and ground water is
contaminated. Because the water table level onsite is only
about 10 ft below the ground surface, cleanup and contain-
ment of spills reaching or likely to reach the groundwater
will be accomplished by construction of interceptor trenches.
Ground water flow is in the general direction of the Queen
River. The trench will be constructed across the entire
front of the migrating body of material (i.e., the trench
will be a few feet wider on either side of the spill
boundaries as can be determined from surface observations).
Figure 29 illustrates this. This trench will be as narrow
as the excavating equipment will allow. It will be con-
structed to a depth of 1 to 4 ft below the water table
surface. The downstream wall of the trench will be lined
with an impermeable and resistant material to prevent
further migration of the spilled material. If the trench
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IMPERMIA8LE
BARRIER
RECOVERY
WELL
Figure 29. Interceptor trench.
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is deep enough, the contaminated water will collect in the
ditch and will be pumped out as required. A pump to create
a zone of depression will be used to increase speed of
recovery. This is accomplished by first placing a 16- to
18-in. diameter galvanized culvert pipe, slotted or perforated
and capped on the bottom, in the bottom of the trench about
midway from each end. Fiberglass or steel window screening
is then wrapped around the pipe where it is slotted and
then secured with wire. The trench is then backfilled
within 2 ft of the ground surface with gravel and finished
with native soil. Figure 30 shows a cross section of an
interceptor trench. When pumping is required to prohibit
/<
contamination of the water table, a submersible pump is
lowered into the culvert. Pumping will be done continuously
to prevent the contaminant from moving around the ditch.
When recovering a flammable material from the ground water,
explosion- and spark-proof pumping equipment, tools, and
clothing is used because of the possible presence of
explosive vapors. Smoking, and heat sources in the area
will be eliminated.
All emergency equipment used in the emergency must be
cleaned and fit for use prior to resumption of plant opera-
tions in the affected areas.
Floods
Approximately half of the facility property is located
within the 100-year flood plain and is subject to floods of
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COVER
LOCAL BACKFILL-
MATERIAL
:---:-:->:-:- WATER TABLE •:-;-:-:-:->:-:-:-:-:-:-:->:-
CULVERT mm
RECOVERY ;l;S
WELL ipa
•x'x'x" x"r";'x":-i'x-S""x"X'
IMFERMEAIBLE'
BARRIER
GRAVEL :>>:
OR STONE :>:-:
Figure 30. Interceptor trench
(cross-section).
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1 to 3 feet in depth. The present waste pile and drum
storage areas are within the 100-year flood plain.
The drum storage area and waste pile are both subject to
flooding. The long-term solution is to move these func-
tions to higher ground. If a flood occurs before this
relocation, the following steps should be taken:
1. Check with the National Weather Service in
Providence, Rhode Island, or the Army Corps
of Engineers for a projected flood crest.
2. If the crest will result in less than 1 ft
of water in the waste pile or drum area, the
areas will be diked with sandbags up to a
level 1 ft over the projected level.
3. If the crest will result in more than 1 ft
of water in the waste pile and drum areas,
the waste will be removed to a waste disposal
facility. It is estimated the drums will
take 3 to 4 hours to remove. The waste pile
is expected to take up to 8 hours to remove;
therefore a sandbag dike will be constructed
to protect the site during the removal time.
4. Should a fire, explosion, spill or material
release occur during the flooding, the
sections addressing these occurrences will
be consulted.
G-4e Prevention of Recurrence or Spread of Fires, Explosions or
Releases [40 CFR 264.56(e)]
Actions to prevent the recurrence or spread of fires,
explosions or releases include stopping processes and
operations, collecting and containing released waste, and
recovering or isolating containers. The onsite training
manual addresses the specific actions to be taken in an
emergency. In addition, if the facility stops operations
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in response to an emergency, the emergency coordinator will
monitor valves, pipes, and other equipment for leaks,
pressure build up, gas generation or ruptures.
G-4f storage and Treatment of Released Material [40 CFR 264.56(g)]
Immediately after an emergency, the emergency coordinator
will make arrangements for treatment, storage, or disposal
of recovered waste, contaminated soil, surface water, or
any other contaminated material.
G-4g Incompatible Wastes [40 CFR 264.56(h)]
The emergency coordinator will ensure that wastes which may
be incompatible with the released material are treated,
stored or disposed of until cleanup procedures are completed.
G-4h Post-Emergency Equipment Maintenance [40 CFR 264.56(h)(2)]
After an emergency event, all emergency equipment listed in
section GS will be cleaned so that it is fit for use or it
will be replaced. Before operations are resumed an inspection
of all safety equipment will be conducted as discussed in
section F-2. The Regional Administrator, state, and local
authorities will be notified that post-emergency equipment
maintenance has been performed and operations will be
resumed.
G-4i Container Spills and Leakage [40 CFR 264.171]
Refer to section G-4d for a discussion of emergency response
procedures for container spills and leakage.
G-4] Tank Spills and Leakage [40 CFR 264.194(c)]
Refer to section G-4d for a discussion of tank spills and
leakage emergency response procedures.
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G-4k Waste Piles
G-4k(l) Indication of Waste Pile Containment System Failures
Per the inspection schedule discussed in section F-2, the
waste pile storage area will be inspected on a weekly
basis. If during an inspection liquid is detected in the
leachate monitoring manhole a sample will be collected and
analyzed for lead and hexavalent chromium. If lead and/or
hexavalent chromium is detected, the containment system
evaluation and repair plan will be implemented. If inspec-
tion of the membrane liner indicates there are tears,
holes, separation of layers, thin spots, cracks, shrinkage,
hardness, excessive permeability, or blisters, the plan
will also be immediately implemented. Other.indications of
waste pile containment system failure which would require
implementation of the plan include: deterioration or
loosening of the joint holding the liner to the foundation,
loss of base material or soil covering liner, exposing the
liner to direct sunlight, or foundation deterioration or
cracking.
G-4k(2) Elements of a Containment System Evaluation and Repair
Plan
If there are indications of waste pile containment system
failure, the containment system evaluation and repair plan
will be implemented immediately. The plan clearly outlines
the steps necessary to evaluate the extent of damage to the
containment system and measures necessary to correct a
containment deficiency. Structures involved in the
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containment system evaluation include: the foundation,
liner, leachate, and runoff collection system, waste pile
base, leachate monitoring manhole, and perimeter soil
embankment. The most vulnerable unit of the containment
system is the liner which will undergo the following tests
to ensure integrity:
visual inspection for cracks, holes, etc.
laminate thickness
cold bend
tensile strength
tear strength
puncture resistance
hydrostatic resistance
dimensional stability
ozone resistance
seam strength
Other structures will require thorough visual inspection
for deficiencies. Also included in the plan is a schedule
of actions in the event of containment failure and a descrip-
tion of repair techniques.
G-4k(3) Criteria and Procedures for Removal of Waste File From
Service in Case of Positive Failure of the Containment
System [40 CFR 264.255(b), 264.255(c), and 264.255(d)(1)]
In the event there is a positive failure of the containment
system the waste pile will be removed from service. Front-
end loaders will be used to remove the waste pile from the
containment system and load the haul trucks. Waste will be
disposed of at a facility approved to handle that particular
waste. Newly generated waste will be stored in 3 cu. yd.
dumpsters until the containment system is repaired.
G-4k(4) Restoration of a Waste Pile to Service [40 CFR 264.255(e)]
After removing the waste pile from service and disposing of
the waste pile, the containment system will be repaired as
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soon as possible. Depending upon the severity of the
repair work, a registered professional engineer will certify
that the containment system still meets the design specifica-
tions approved in the RCRA permit.
G-4k(5) Course of Action After Waste Pile is Removed From
Service (40 CFR 264.255(f) and 264.258]
When the waste pile containment system is permanently
removed from service the following steps will be necessary
to close the facility and restore the grounds to their
original appearance:
1. Remove hazardous waste pile to a facility approved
to handle that particular waste.
2. Remove base, liner, foundation, underdrains,
underdrain collection sump, leachate collection
system, and leachate monitoring manhole, and
dispose of at a facility approved to handle that
particular waste.
3. Remove any contaminated soil and dispose of at a
facility approved to handle that particular
waste.
4. Remove groundwater subdrains and store for reuse
or resale.
5. Fill diversion ditch and pit from waste pile
containment system with onsite soil and grade.
6. Apply seed and straw in an effort to reclaim the
area.
7. Decontaminate front-end loaders, haul trucks,
pumps, etc. in the container storage area and
. dispose of resulting wastes appropriately.
8. An independent registered professional engineer
will certify closure of the waste pile contain-
ment system.
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G-5 Emergency Equipment
Location of emergency equipment is shown on Figure 31. The
plant employs several mechanisms for fire control. First,
three fire hydrants are located in the plant area Each
hydrant will deliver 500 gal/min of water. Approximately
1000 ft of hose is stored in the warehouse.
Also available for fire control are portable fire extin-
guishers; at least one extinguisher is located in each of
the following areas:
Drum storage area
Storage tank area
Processing area
Warehouse
Electric substation
Lab
Offices
These fire extinguishers are dry chemical Types A, B, and
C. Type A is capable of extinguishing fires involving
ordinary combustible materials such as wood, cloth, paper,
rubber, and many plastics; Type 3 is capable of extin-
guishing fires involving flammable liquids, oils, greases,
tars, oil base paints, lacquers, and flammable gases; and
Type C is capable of extinguishing fires involving ener-
gized electrical equipment. All. extinguishers comply with
National Fire Code standards for portable fire extinguishers,
and they are inspected after each use or at least monthly.
•
Records of these inspections are kept in the operating log.
Equipment for use in containing and cleaning up spilled
hazardous wastes is stored in the warehouse. A list of
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FH - FIRE HYDRANT
FE - FIRE EXTINGUISHER
FA - FIRST AID EQUIPMENT
EMS - EYE WASH AND SHOWER
SCC - SPILL CONTROL AND CLEANUP EQUIPMENT
PCE - PROTECTIVE CLOTHING AND EQUIPMENT
Figure 31. Location of emergency equipment.
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equipment and materials stored and maintained in the ware-
house is listed in Table 13, along with the function of
each.
First aid supplies at the first aid station include the
following:
0 Bandage materials
- band aids
- gauze pads and rolls
• adhesive tape
- butterfly bandages
Antibacterial ointments
Splints
Aspirin
Emetic - Syrup of Ipecac
Local and topical anesthetics
Eyewash bottle and solution
Emergency eyewash fountains and showers are located at the
east and west ends of the waste storage tank area. Each
unit consists of a drench showerhead with "panic bar"-operated
frost-proof valve and an eyewash with a dirt cover and
"panic bar"-operated frost-proof valve. A sign reading
"EMERGENCY SHOWER AND EYEWASH FOUNTAIN11 is posted at each
unit. A hose station is also located near the eyewash/shower
station at the west end of the tank storage area.
Protective clothing and equipment is provided to protect
employees during normal and emergency operations. Hard
hats, protective eyewear, and steel-toed boots or shoes are
the minimum protective clothing required. Other protective
clothing equipment available on site include:
Clothing
- Plastic aprons and gauntlets
- Rubber and Neoprene boots
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TABLE 13. MATERIALS AND EQUIPMENT FOR SPILL CONTAINMENT AND CLEANUP
Materi al(sI/equipment
Quantity
Substances contained/
absorbed/cleaned up
Notes
Standard Industrial
absorbents (Sorb-All,
Vermiculite, etc.)
A drum should be
placed In all plant
areas where small
spills are suspect.
For small spills of oil,
solvents, aqueous mate-
rials. Do not use for
acids or caustics unless
first neutralized.
Each drum should be accom-
panied with broom (or
shovel) and dustpan.
Sandbags
Sand
800-1000
50-100 yd3
10
Absorbent boom,
weighted or with
curtain or skirt
Sand Is unreactive with
most any chemical except
hydrofluoric acid.
Sand Is unreactive with
most any chemical except
hydrofluoric acid.
In water, most Insoluble
or slightly soluble
organics. Most materials
on land. Do not use for
acids.
Keep in readily acces-
sible area(s) near most
concentrated area(s) of
tanks or drums.
Use primarily for contain-
ment or large spills.
Containment and cleanup
of small spills. Also,
keep in barrels in areas
where small spills may
occur more frequently (drum
storage areas, process pads,
etc.). Keep covered if
outside.
Employ one boom around
out-fall discharge on
permanent basis and one
for backup.
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TABLE 13 (continued)
Material(s)/equipment
Quantity
Substances contained/
absorbed/cleaned up
Notes
Absorbent pads
Carton (100 pads-
Conwed)
...
Straw
15-20 bales
Submersible pump
In water, most insoluble
qr slightly soluble
organics. Host materials
on land. Do not use for
acids.
Petroleum, distillates,
oil, organic solvents.
Oo not use for acids or
caustics.
See manufacturers (Gould,
Flygt, Peabody) for
specifications on mate-
rial-handling capabili-
ties.
Will float on water so are
most helpful in cleaning
up materials contained
within the boom boundaries
or in diked areas where a
chemical sheen has formed
on water collected within.
Also, place around equipment
or in areas where leakage
or spillage occurs frequently
(i.e., pumps, loading/unloading
areas).
Can be used for diking
and absorption for land
spills. If booms become
saturated, can be tied
together and used to con-
tain and absorb water spills.
Since they sink partly below
water surface, they are useful
for substances slightly heavier
than water.
Can be used to remove diked
liquids, etc.
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(continued)
CD
10
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TABLE 13 (continued)
Material(s)/equ1pment
Quantity
Substances contained/
absorbed/cleaned up
Notes
Flexible (Neoprene) 75 ft minimum
hoses with quick
couple fittings.
55-galIon drums; steel, Variable
stainless steel
N.A.
Neoprene is resistant to
most acids and solvents,
but not all. For instance,
benzene wi11 degrade
Neoprene.
Most organics (steel); acids,
caustics, contaminated
absorbent materials
(stainless steel).
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- Short and long rubber gloves
- Rain suits
- Chemical-resistant suits (Tyvek, polyurethane,
polyethylene)
- Polyethylene gloves
Equipment
- Face shields and extra protective eyeglasses
- Disposable respirators
- Chemical cartridge respirators w/cartridges for
organic vapors and acid gases; half- and full-
face types
- Chest-mounted gas mask cannisters
- Self-contained breathing apparatus (SCBA)
operated in pressure-demand mode
This equipment is located in the warehouse for easy access
by personnel.
G-6 Coordination Agreements
Tankopile has made the following arrangements to assist in
response to emergency situations.
1. An agreement has been made with a local dis-
posal facility to provide a tank truck on a
24-hour basis.
2. Copies of the contingency plan have been
given to the local police and fire depart-
ments, the hospital, and the state and local
Emergency Response Teams. These agencies
were asked to review and comment on the plan
and have detailed the actions they will take
in response to any emergency.
The following organizations have been sent copies of the
contingency plan:
Fire Chief Charles Lang
Anytown Fire Department
6th and Main Streets
Anytown; Rhode Island 02881
Fire Chief David Kuntz
Washington County Fire Department
11934 State Route 43
Brixton, Rhode Island 02881
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Dr. Joyce Henderson
Anytown Hospital
2914 Elm Street
Anytown, Rhode Island 028B1
Dr: Joseph Smyth
Washington County Hospital
1293 State Route 43
Georgetown, Rhode Island 02881
Mr. Robert Burns
Rhode Island Emergency Management Agency
1200 Washington Boulevard
Providence, Rhode Island 02908
Ms. June Davidson
Washington County Emergency Management Agency
11850 State Route 43
Brixton, Rhode Island 02881
G-7 Evacuation Plan
All emergencies require prompt and deliberate action1. In
the event of any major emergency, it will be necessary to
follow an established set of procedures. Such established
procedures will be followed as closely as possible; however,
in specific emergency situations, the Emergency Coordinator
may deviate from the procedures to provide a more effective
plan for bringing the situation under control. The Emergency
•Coordinator is responsible for determining which emergency
situations require plant evacuation.
The facility employs a warning system with a specific alarm
signal to initiate evacuation of all plant areas. In
addition to the alarm, the internal telephone system is
used to notify key plant personnel as to the nature of the
emergency and recommended plan of action. Total plant
evacuation is initiated only by an Emergency Coordinator.
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A fire alarm system is'installed with alarm boxes located
at critical areas throughout the plant. The fire alarms
can also be used to summon aid in other emergency situations.
All applicable employees are familiar with alarm box locations
In the event plant evacuation is called for by the Emer-
gency Coordinator, the following actions will be taken:
1. The signal for plant evacuation will be
activated.
2. The guards will immediately open the gates.
No further entry of visitors, contractors,
or trucks will be permitted. All vehicle
traffic within the plant will cease to allow
safe exit of personnel and movement of
emergency equipment.
3. ALL personnel, visitors, and contractors
will immediately leave through the exit
gate.
4. No persons shall remain or reenter the
location unless specifically authorized by
the person or persons calling for the evacu-
ation. In allowing this, the person in
charge assumes responsibility for those
persons within the perimeter. Those within
the fenced area will normally only include
fire brigade personnel or emergency teams.
5. ALL persons will be accounted for by their
immediate supervisors. Supervisors will
designate certain gates as the safest exits
for his or her employees and will also
choose an alternate exit if the first choice
is inaccessible. To assist in this endeavor,
the Emergency Coordinator will use the
internal telephone system to call the area
supervisor, to inform him or her of the
nature of the emergency.
6. During exit, the supervisor should try to
keep his or her group together. Rally
points for specific areas are shown in
Figure 28. Immediately upon exit through
the gare, the highest ranking supervisor
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will prepare a list of all personnel at the
exit gate. All other personnel who have
persons reporting to then should report
immediately to the front gate for final
accounting.
7. Upon completion of the employee list, the
supervisor in charge will hand-carry the
list to the Emergency Coordinator. All
other personnel will remain at the gate
area.
8. Contract personnel should also be listed
with the name of their company. Contract
foremen should report to the front gate.
9. The names of fire brigade and/or other
emergency team members involved in emergency
response will be reported, in writing, to
the front gate by designated response team
personnel.
10. A final tally of persons will be made by the
Emergency Coordinator.
11. No attempt to find persons not accounted for
will involve endangering lives of others by
reentry into emergency areas.
12. A plant guard at each gate will also main-
tain an updated list of all personnel to aid
in the accountability procedure.
13. Reentry into the fenced area will be made
only after clearance is given by the Emer-
gency Coordinator. At his direction, a
signal or other notification will be given
for reentry into the plant.
14. In all questions of accountability, immedi-
ate supervisors will be held responsible for
those persons reporting to them. Visitors
will be the responsibility of those employees
they are seeing. Contractors are the respon-
sibility of those persons administering the
individual contracts. Truck drivers are the
responsibility of the warehouse supervisor
or the -area supervisor where the truck is
loading/unloading. The guards will aid in
accounting for visitors, contractors, and
truckers by reference to the sign-in sheets.
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15. Drills are held to practice all of these
procedures and are treated with the same
seriousness as an actual emergency.
G-8 Required Reports [40 CFR 264.56(d) and 264.56(1)1
As required by §264.56(J), any emergency event (e.g., fire,
explosion, etc.) that requires implementing the contingency
plan will be reported in writing within 15 days to the EPA
Regional Administrator. A reporting form for emergency
events is shown in Figure 32.
In addition to these reporting requirements for state and
Federal authorities, Tankopile also has internal reporting
requirements. The following incidents require that an
incident report be completed and returned to the safety
director within 5 working days and made part of the oper-
ating record:
1. All fires
2. Rupture disc releases
3. Unusual gas or vapor releases
4. Chemical spills of more than 10 gallons (or
smaller volumes if highly toxic materials are
involved)
5. All injuries except minor cuts and bruises
(all burns and chemical irritations)
6. All equipment damage due to malfunction or
operating error
7. All "near misses" of the above variety that
could have had serious consequences
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REPORTING FORM FOR EMERGENCY EVENTS
Name, address, and phone number of owner or operator
Name, address, and phone number of facility
Date, time, and type of incident (e.g., fire, explosion, etc.)
Name and quantity of material(s) involved
Extent of injuries (if any)
Assessment of actual or potential hazards to human health or the environment
(if applicable)
Estimated quantity and disposition of material recovered from the incident
Send to:(Name)
U.S. EPA, Region I
Regional Administrator (EPA)
JFK Federal Bldg.
Boston, Massachusetts 02203
(Name) Chief
Environmental Emergency Branch
U.S. EPA, Region I
JFK Federal Bldg.
Boston, Massachusetts 02203
Figure 32. Sample reporting form for emergency events.
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Amendments to the Contingency Plan
The contingency plan will be reviewed and immediately
amended, if necessary, whenever:
1. The facility permit is revised
2. The plan fails in an emergency
3. 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 in
the response necessary in any emergency
4. The list of emergency coordinators change
5. The list of emergency equipment changes
G—9 Amendments to the SPCC Plan
The TanJcopile Finishing Company, prior to the submission of
this application, did not have a Spill Prevention, Control
and Countermeasure (SPCC) Plan. Therefore, §264.52(b) is
not applicable, and the requirements for spill prevention,
control and countermeasures were addressed in various
sections of this contingency plan.
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SECTION H
PERSONNEL TRAINING
The information contained in this section outlines the
personnel training program for Tankopile's hazardous waste
storage facility in accordance with the requirements of 40 CFR
§122.25(a)(12) and §264.16.
H-l Outline of Training Program [40 CFR 122.25(a)(12)1
H-la Job Titles and Duties
Figure 33 shows the organization of personnel at the
facility. Only four employees are directly involved with
the handling of waste: The environmental engineer, the
environmental operations foreman, and two operators.
Management responsibilities involving compliance with RCRA
regulations but not involving actual handling of the wastes
are split between the environmental engineer and the plant
manager. Maintenance personnel (i.e., electricians and
mechanics) work in the waste handling area, but they do not
handle wastes directly. The duties, responsibilities, and
qualifications of each position follow:
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PLANT MANAGER
Joseph A. Williams
ENVIRONMENTAL ENGINEER
John q. Smith*
ENVIRONMENTAL
OPERATIONS FOREMAN
Stephen S. Ray*
OPERATORS
Michael H. ATwood*
Jerry I. Slate*
'indicates those personnel directly involved with hazardous waste activities,
Figure 33. Organization chart for Tankopile's HWM facility.
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Position Title: Environmental Engineer
Name of employee: John Q. Smith
Position Responsibilities and Duties:
0 Emergency Coordinator for all hazardous waste
activities.
0 Training of plant personnel in the proper
handling of raw materials,.intermediates,
finished products, and waste byproducts.
0 Responsible for all air, water, and solid waste
control systems on the site.
0 Obtains all required permits and licenses or
modifications of same from local, state, and
Federal regulatory bodies.
0 Resolves problems involving permits and licenses
from local, state, and Federal regulatory
agencies.
0 Notifies proper authorities in emergency situa-
tions.
0 Reports to Plant Manager.
0 Regularly inspects plant grounds and all facili-
ties for status of air, water, and solid/
hazardous waste emissions and controls.
0 Consults with maintenance foreman on questions
involving emergency action.
0 Drafts and submits to plant manager all required
reports to EPA or the State.
Experience and Qualifications:
0 B.S. degree in Chemical, Civil, or Environmental
Engineering. B.S. Degree in Chemistry also
acceptable.
0 1-3 years experience in industrial or municipal
pollution control management.
0 Training and/or experience in hazardous waste
management is desireable.
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Position Title: Environmental Operations Foreman
Name of employee: Stephen S. Ray
Position Responsibilities and Duties:
0 Overall operation and maintenance of the
hazardous waste storage facility.
0 Maintains facility compliance with RCRA and other
permits.
0 Oversees operators and reviews their performance.
0 Trains operators to:
Operate materials/drum handling equipment
safely and effectively
Handle leaks, spills, and emergency situa-
tions
0 Maintains operating log, monitoring records,
maintenance records, inspection records, per-
sonnel training records, and all other required
records.
0 Notifies plant environmental engineer, plant
manager, and if so directed, proper authorities
in emergency situations.
0 Schedules all maintenance and repairs to struc-
tures and equipment for HWM facility.
0 Oversees mechanic/electrician doing both
scheduled and unscheduled maintenance and repair
work to be sure he is not releasing hazardous
wastes to the environment or contaminating
himself.
0 Reports to environmental engineer.
Experience and Qualifications:
0 Associate (2-yr) degree in Chemical, Civil,
Environmental, or Mechanical Engineering.
0 2-3 years experience in plant operation.
0 Hazardous waste management experience helpful but
not required.
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Note: If applicant has no hazardous waste exper-
ience, special training in the functions and
operation of a hazardous waste storage facility
will be required before assuming job responsibil-
ities. This training will be provided by
Tankopile.
Position Title: Operator
Names(s) of employee(s): Michael H. Alwood
Jerry I. Slate
Position Responsibilities:
0 Reports to environmental operations foreman.
0 Operates waste handling equipment.
0 Reviews all incoming wastes and assigns wastes to
proper storage location.
0 Inspects tanks, drums, and other storage equip-
ment, and any gauges, dials, and recorders as
required for proper operation and structural
integrity.
.° Inspects drum storage area for evidence of leaks
and spills and inappropriately placed drums.
0 Inspects emergency equipment on a regular basis.
0 Assists in training of new operators and
mechanics to handle hazardous waste spills and
leaks safely and in such a way as to avoid
exposures.
0 Makes appropriate entries into operating log,
monitoring records, inspection records, and
maintenance records, and files them according to
established system.
0 Notifies foreman and other plant authorities as
necessary in emergency situations.
8 Takes emergency action on own authority in
accordance with estaclishecTprocedures.
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Experience and Qualifications:
0 High school diploma
0 2-3 years experience as plant operator with
related activities.
Note; Operator will also be required to maintain
and inspect other pollution control equipment on
the site.
H-lb Training Content, Frequency, and Technique
The program developed at Tankopile for training employees
in the safe handling of hazardous wastes has been organized
into a "training manual." Provisions are made for updating
or revising the text as necessary to ensure compliance with
the terms of the RCRA permit. Each employee has his or her
own copy of the manual. An outline of the training manual
is shown in Figure 34. This training manual is kept on
file at the facility, and is available to EPA officials for
review.
During the training program, employees are instructed on
(1) the hazardous nature of chemicals and chemical wastes
in general, (2) the purpose of RCRA and importance of
maintaining compliance with RCRA regulations, (3) the
hazardous nature of the wastes being stored in the facility,
(4) proper handling and storage procedures for wastes,
(5) emergency procedures and contingency plan.
The manual is used as the basis or -framework for training
Tankopile personnel in the proper procedures, equipment,
and systems to be used in managing hazardous wastes.
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Preface
1.0 Introduction
1.1 Chemical hazards .
1.2 The Resource Conservation and Recovery Act - RCRA
2.0 Facility and Process Description
2.1 Description of wastes to be managed
2.2 Description of storage facility
2.3 Key terms of the permit
2.4 Normal/routine operations
2.5 Waste analysis
2.6 Recordkeeping and reporting requirements
2.7 Security
2.8 Inspections
3.0 Emergency Procedures and Contingency Plans
3.1 Emergency coordinator
3.2 Emergency procedures
3.3 Emergency communications/phone numbers and alarms
3.4 Location, maintenance, inspections, and use of
emergency equipment
3.5 Procedures for waste feed cutoff systems
3.6 Spill control and response to groundwater con-
tamination incidents
3.7 Fires and explosions
3.8 Power interruption or failure
3.9 Tornadoes, hurricanes, and severe storms
Appendix A Summary of RCRA Regulations for Hazardous Waste
Storage Facilities
Appendix B Summary of Conditions Specific in Tankopile's
RCRA Permit
Appendix C Training Programs in Hazardous Waste Management
Figure 34. Outline of Hazardous Waste Training Manual
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For key personnel, Tankopile plans to supplement the train-
ing outlined in the manual with attendance at one or more
technical seminars or training programs on hazardous mate-
rials. A list of such seminars or programs is included in
Appendix C of the training manual.
•
A brief description of each section of the training manual
follows:
Section 1 - Introduction
This section of the manual introduces Tankopile employees
to the general classes and characteristics of chemicals and
chemical wastes that can be hazardous to health and property.
In this context, the terms toxicity, reactivity, corrosivity,
and ignitability are defined. It is Tankopile's policy
that each employee handling chemical substances (raw materials,
finished products, byproducts, and wastes) respect them and
be aware of these potential hazards. The company's policy
on the use of protective clothing and safety equipment to
prevent accidental worker exposures and releases to the
environment of hazardous chemicals and wastes is introduced.
The authority for regulating hazardous wastes under the
Resource Conservation and Recovery Act (RCRA) also is
discussed. The regulatory framework for classifying haz-
ardous wastes, setting operational•standards, and per-
mitting procedures and achieving compliance is explored.
The RCRA permit for Tankopile (once it is received) will
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also be studied to be sure that each employee is familiar
with its terms.
Section 2 - Storage of Hazardous Wastes at Tankopile
This section focuses on the types of hazardous wastes that
are handled and stored at Tankopile, normal/routine storage
operations, and procedures for maintaining compliance with
the RCRA permit (e.g., waste analysis, recordkeeping,
inspections, and security). A site diagram showing the
dimensions, capacity, and relative position of each storage
area (tanks, containers, and piles) is included.
Training for normal or routine operating conditions includes
the following topics:
0 Proper operation and maintenance of the storage
facility
0 Scheduled inspections
0 Purpose and use of security and communications
systems
0 Monitoring requirements for tracking and recording
the operation of the facility
0 Recordkeeping requirements and procedures
Section 3 - Emergency and Contingency Plans
The third section of the training manual provides detailed
instruction on steps to be taken in the event of an emergency
such as a waste spill or fire, power outage, or damage from
wind and storms. The emergency coordinator is clearly
identified, as are emergency phone numbers and directions
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for locating and using onsite emergency equipment, alarms,
and communications. Contingency plans are also detailed.
This manual is used in classroom training for both intro-
ductory training and annual review. All personnel involved
with hazardous waste are required to complete 20 hours of
classroom training in addition to 6 weeks on-the-job training.
Also personnel receive an 8-hour classroom review training
session once a year. This is supplemented with attendance
by the environmental engineer at seminars and conferences
involving hazardous waste management.
H-lc Training Director
The personnel training program is directed by Mr. John Q.
Smith, the plant Environmental Engineer. Mr. Smith has
been with Tankopile for 10 years. He received a M.S.
degree in Environmental Engineering from the University of
Cincinnati in 1971. He has been trained in all aspects of
Hazardous Waste Management and attended various seminars on
this subject. Records of his previous and ongoing training
are kept on file at the personnel office.
H-ld Relevance of Training to Job Position
Mr. John Q. Smith, the plant Environmental Engineer, is
responsible for teaching hazardous waste management procedures,
including contingency plan implementation, to all waste
handling personnel. The training program is tiered (Figure
35) in some areas to provide training to personnel at
levels that are relevant to their positions within the
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Environmental Engineer
Environmental Operation
Foreman
Operators
Personal
safety
B
i B
B
Release
prevention
and re-
sponse
B
B
B
Contingency
plan
B
B
L
Emergency
procedures
B
B
B
Hazardous
waste man-
agement
and prac-
tices
B
B
L
Record
keeping
B
L
L
Hazardous waste
handl ing and
operations
B
B
B
w B = broad Instruction
10 L = limited instruction
Figure 35. Level of training for hazardous waste personnel.
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plant. For example, the foreman receives training in
recordkeeping and other procedures required for compliance,
whereas the operators do not. Operators are more spec:fical-
ly trained to maintain proper and safe operating procedures
and to respond effectively in the event of a spill or other
emergency.
H-le Training for Emergency Response
This training program is designed to ensure that personnel
not only handle hazardous wastes in a safe manner but also
properly respond to emergency situations. The program
trains hazardous waste handling/management personnel to
maintain compliance under both normal operating conditions
and emergency conditions.
Training elements addressing nonroutine and emergency
situations (unscheduled shutdowns and startups related to
storms, power outages, fires, explosions, spills) include:
0 Procedures for locating, using, inspecting,
repairing, and replacing facility emergency and
monitoring equipment
0 Key procedures for automatic waste feed cutoff
systems
0 Emergency communication procedures and alarm
systems
9 Response to fires or explosions
0 Response to ground water contamination incidents
and. procedures for containing, controlling, and
mitigating spills
0 Shutdown of operations and power failure procedures
9 Procedures for evacuation of nearby areas
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In addition to the hazardous waste management personnel, a
company fire brigade is on standby for response to all
fires and other general plant emergencies. This fire
brigade is trained both with classroom training methods and
fire drills. The classroom training is required for intro-
ductory training and as an annual review for each member
assigned to the fire brigade. The fire brigade training is
not addressed in the hazardous waste training manual. For
more information contact Tankopile's safety officer, George
Shoe at 555-6790. The fire drills occur at a minimum of
six times a year and are unannounced.
H-2 Implementation of Training Program
The director of the training program and all current waste-
handling personnel have been fully trained at the time of
this submittal. In the future, all new personnel will
complete this training program within 6 months of assignment
to the hazardous waste storage facility or within 6 months
of their date of employment, whichever is later. No employee
hired to work at this facility will work unsupervised prior
to completion of the training program.
Employees are required to meet annually for review and
update of this training program and to discuss and study
the following subjects:
1) All hazardous wastes currently being handled at
the facility, noting any changes in waste type,
volume, source, characteristics, or location that
have occurred during the past year.
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2) The status of storage and operating conditions
and procedures, noting any areas where there are
problems or potential for problems. Employees
participate in developing effective solutions.
3) The requirements contained in the facility's RCRA
permit, noting any changes that have occurred
during the past year. Areas where maintenance of
compliance is a problem are identified and dis-
cussed, and effective solutions are sought.
4) Incidents that have occurred in the past year
that warranted use of contingency plans and/or
emergency action. This review focuses on the
cause of the incident and identification of steps
to be taken to prevent or to ensure better han-
dling of such events in the future.
The annual review will also utilize the facility's annual
report to EPA as a working document for the review.
Records documenting the job title for each position, job
descriptions, names of employees, and completed training
programs (both introductory and review) will be kept onsite
in the personnel office of Tankopile Finishing Company.
These records will be kept until closure of the facility
for current employees and for 3 years from the date of the
individual employee's termination for former employees.
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SECTION I
CLOSURE PLAN, POST-CLOSURE PLAN, AND
FINANCIAL REQUIREMENTS
This Section is submitted in accordance with the require-
ments of 40 CFR §122.25(a)(13), §264.112 through 115, §264.178,
§264.197, and §264.258. This plan identifies all steps that
will be necessary to partially close the facility at any point
during its intended operating life and to completely close the
facility at the end of its intended operating life. The plan
also addresses the conditions and reasons under which partial
•
closure will occur. A post-closure plan is not required because
this is not a disposal facility and all wastes are being removed
at closure
Tankopile will maintain an onsite copy of the approved
closure plan and all revisions to the plan until the certifica-
tion of closure completeness has been submitted and accepted by
EPA, Region I. The Tankopile owner will notify the Regional
Administrator at least 180 days prior to the date we expect to
begin final closure. The closure date for closure of the entire
facility will be 2002. Upon completion of closure, the Tankopile
owner will submit to the Regional Administrator a certification
by both the Tankopile owner and by a local independent registered
professional engineer that the facility has been closed in
accordance with the specifications in the approved closure plan.
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1-1 Closure Plan [40 CFR 122.25(a)(13)1
I-la Closure Performance Standard [40 CFR 264.111]
This closure plan was designed to ensure that the facility
will not require further maintenance and controls, minimizes
or eliminates threats to human health and the environment,
and avoids escape of hazardous waste, hazardous waste
constituents, leachate, contaminated rainfall, or waste
decomposition products to the ground or surface waters or
to the atmosphere. If there is evidence of any spills or
leaks, samples will be taken and analyzed to determine the
extent of contamination in the soil and if necessary, in
groundwater. Any contaminated soil will be excavated,
removed, and disposed of at a proper disposal facility.
Any contaminated groundwater will be remedied. The entire
site will be regraded subsequent to closure to prevent
erosion. The following sections discuss in detail efforts
to be made at Tankopile to satisfy the closure performance
standard.
I-lb Partial and Final Closure Activities
Tankopile expects to perform partial closure when we remove
our waste pile from its current location in the eastern
portion facility to a new location in the northern portion
facility. Final closure activities on the waste pile will
occur in 1982. Our procedures for final closure of the
waste pile, including waste removal, cleanup and decontam-
ination activities, are described in Section I-ld(3) of the
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I
closure plan. Partial closure of the container storage and
tank storage operations are not planned. However, in the
event that future circumstances or decisions force us to
discontinue our hazardous waste tank storage or hazardous
waste container storage activities, Sections I-ld(2) and
I-ld(l) of the closure plan present our procedures for
final closure of each of the two storage areas. Any modifi-
cations to our existing facility equipment, structures,
instruments or procedures related to the management of the
three distinct portions of the facility will result in
Tankopile updating the partial closure plan, and revising
the closure plan accordingly. .
At a maximum we expect the operation to consist of storage
of 100 drums, 2 tanks and 1 waste pile during the life of
the facility. Section I-lc of the closure plan describes
the maximum inventory of wastes in storage at any given
time during the operating life of Tankopile. Tankopile
will secure permission to dispose of its wastes and enter
into contractual agreements with XTC (an off-site surface
impoundment) and the FEI hazardous waste landfill.
I-lc Maximum Waste Inventory
The following table shows the maximum inventory of wastes
in storage at any given time during the operating life of
Tankopile for 1 waste pile, 100 containers, and 2 tanks.
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Waste pile:
metal hydroxide sludge 50 yd3
50 yd0 total
Containers:
metal grindings 1870 gal
vinyl acetate sludge 605 gal
vinyl chloride sludge 605 gal
pickle liquor sludge 2420 gal
5500 gal total
Tanks:
pxckle liquor 7500 gal
1,1,1-trichloroethane 7500 gal
15000 gal total
I-Id Inventory Removal and Disposal or Decontamination of Equip-
ment
Following waste removal, all piping to and from the two
storage tanks will be disconnected, dismantled and decontam-
»
inated. The work will be supervised and performed using
qualified Tankopile personnel. Personnel will be equipped
with acid/solvent resistant coveralls (olefin material,
coated with heavy polyethylene film), head protection,
neoprene-coated gloves and boots -resistant to solvents and
acids. Both the wrists and ankles will be taped (electrical
tape) to protect against upward and inward splash. Full
face respirators with organic vapor and acid gases filter
cartridges that seal directly to the mask will be used.
Chemical neutralizers and spill control pillows will be
employed in the event of any spills resulting from pipe
drainage during the disconnection and dismantling process.
Spill saturated spill control pillows will be placed in a
55-gallon polyethylene-lined, steel recovery drum located
at the dismantling area for temporary storage.
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Since contact of hydrochloric acid with some metals produces
explosive hydrogen gas, extreme caution will be taken to
utilize non-sparking tools and equipment during all cleanup
and decontamination activities. Strict supervision will
include provision for no open flames, hot surfaces, or
smoking to be present in and surrounding the work areas.
The 3-in lines which transport the waste from the plant to
the storage tanks will be dismantled. Positive displacement
pumps, used to pump the wastes to tankers, and valves will
be disconnected. In cases when it is difficult to remove
all liquid or solid residues as these residues may be
trapped behind heavy scale or rust or may be too viscous
for pumping, the pipes, valves, pumps, dump trucks, and
forklift trucks will be steam-cleaned to remove the residues.
All contaminated wash waters, generated as a result of the
steam-cleaning process, will be pumped by a positive dis-
placement pump into a tanker truck and transported to the
XTC facility (an off-site surface impoundment) located 30
miles from Tankopile in Kranville, Rhode Island (EPA 1.0.
Number RI0000020000).
Soils in the facility are not expected to be contaminated
by the waste storage at Tankopile. However, the possibility
of contamination occurring during the dismantling and
cleaning of equipment and structures exists. An allowance
has been made in the closure costs for removal and disposal
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r
of approximately 20 yd3 using a front-end loader. If
evidence of possible areas of soil contamination (in the
form of soil discoloration or odor) exists, a soil sampling
program will be instituted to determine the extent of soil
contamination in those areas. At least one soil sample
will be taken from the waste pile area (after removal of
the liner) and one sample near the container storage area,
where unloading operations occur. Augor soil borings with
collected samples will be transported to a laboratory with
GC/MS and atomic absorption capabilities. If contamination
is found in the- soil, those areas will be excavated to the
depth at which no contamination is detected. All soils,
contaminated equipment to be disposed, and solid residues
will be loaded and transported by truck to the PEI landfill
located 10 miles east of this facility in Newburg, Rhode
Island (EPA 1.0. Number RI0000010000).
Prior to leaving any of the site locations undergoing
decontamination, decontamination of personnel protective
clothing will be conducted by removing all bulk material
from the boots and spraying, washing, and scrubbing with
detergent solution all outside protective clothing mate-
rials as well as exposed skin surfaces (i.e., facial area). '
I-ld(l) Closure of Containers
All the drum containers in the Tanxopile container storage
area will first be removed for transport to tiie PEI landfill.
Because of the incompatibility of the types of wastes, the
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corrosive sludge drums, toxic metal gnndings drums, and
ignitable sludgejs drums will each be transported along with
the pallets on separate truck trips to the landfill. The
drums will be moved utilizing a forklift.
The container storage area will then be decontaminated with
a series of solvent washes and all waste water and residues
generated will be collected in the sumps and pumped to the
holding tanks for immediate analysis and, if laboratory
analysis indicates that the waste is hazardous, the material
will be pumped from the holding tanks into tanker trucks
and sent for off-site disposal at the XTC surface impound-
ment. If laboratory analysis shows no evidence of contam-
ination, waste water and residues in the holding tanks will
be discharged to the sewer system. The automatic sump
pumps in each of the sump areas will then be removed and
decontaminated as described in Section I-Id.
Approximately 550 gallons of waste water and residue are
anticipated to result from the container storage area
decontamination process.
I-ld(2) Closure of Tanks
The final spent hydrochloric acid waste load stored in the
tank is pumped to a tanker (by use of a positive displace-
ment pump) and transported to the local publicly owned
treatment works (POTW) for treatment. The 1,1,1-trichloro-
ethane solvent is pumped to a tanker in a similar manner,
and the waste is transported to a reclamation facility.
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1,1,1-trichloroethane, upon contact with acid or acid
fumes, can evolve highly toxic chloride fumes and HC1 may
react with water or steam to produce toxic and corrosive
fumes. For safety considerations due to the proximity of
the two tanks to each other, Tankopile elects not to perform
dismantling, cleaning and decontamination of the two tanks
and associated piping concurrently, but in a sequential
manner. Using properly qualified Tankopile personnel
protected as described in I-Id, the following procedures
will be used to decontaminate each of the two tanks:
First, the waste outlet valve will be opened to allow waste
residuals remaining on the bottom to drain from the tanks.
The waste will be drained from the tanks into 55-gallon
polyethylene-lined, steel recovery drums located directly
beneath the outlet. When filled, the drums will be sealed
and sent off-site by truck to the PEI landfill for disposal.
The waste outlet valve will then be closed.
A 2,000 gallon-per-hour steam cleaning unit (capable of
washing a 16,000-gallon area of storage capacity/hour) will
be rented to decontaminate the tanks. This process will
generate residues in the form of contaminated wash waters.
The waste outlet valve will again be opened and contaminated
wash waters will be drained into 55-gallon steel recovery
drums, sealed, and sent off-site by truck to the XTC surface
impoundment for disposal. Approximately 2000 gallons of
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contaminated wash waters are anticipated to be generated
during the steam cleaning of all tanks and equipment.
All the ancillary equipment associated with the tank will
be detached from the tank. The equipment to be disconnected
includes the nozzle for the level transmitter, piping
inlets and piping exits. The pipes will be decontaminated
by steam cleaning. Any visible spills or leakage detected
during the disconnection process will immediately be remedied
by spill saturation pillows, as discussed in Section I-ld.
To assess whether the tank steam cleaning process has been
successful for the 1,1,1-trichloroethane storage tank, a
member of the clean-up team will enter the tank with full
protective gear and a combustible gas/oxygen detector. The
team member will assess the hazard of the tank by local
diffusion measurement of the percent of lower explosive
limit of any residual 1,1,1-trichloroethane vapor in the
tank. The detected presence of measured oxygen levels
below 19.5%, or of combustible gas will result in rewashing
the tank. For the HC1 tank, litmus paper will be used for
sampling the pH of the last drainage wash water. A neutral
.pH reading will indicate decontamination is complete.
Next, the concrete slab supporting the tank will be steam
cleaned. The tank will then be dismantled from the founda-
tion structure supports and either sold for scrap or resold.
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I-ld(3) Closure of Waste Pile
The waste pile presently located in the northeastern sec-
tion of the facility will be removed by June 1982. Closure
of the waste pile will involve removal of the metal hydrox-
ide sludge from the waste pile area. Tankopile personnel
dressed in protective equipment described in Section I-Id
will participate in the closure of the pile. Due to the
design of the containment system of our waste pile storage
area, the 2'6" of sand and the 1'6" of pea gravel underlying
the pile must be removed since the waste pile has in all
probability contaminated these layers. Extra precaution
will be taken in removing the pea gravel to avoid damaging
the CPE liner and the"4"-thick bentonite layer liner beneath
the pea gravel. The waste materials, excavated by a front-
end loader, will be loaded onto a dump truck equipped with
equipment to avoid release of hazardous material over the
sides. The material will be transported to the PEI landfill
for disposal.
To avoid contamination of soils surrounding the piping due
to cracking or stresses due to excavation, the surface of
the bentonite liner will be flushed with water, to drain and
clean the perforated clay underdrains and remove residual
materials from the pipe that goes to the collection sump.
Leachate collected in the sump will be pumped into a tanker
truck for transport to the XTC surface impoundment. After
several flushings in this manner, the clay layer will be
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excavated with a backhoe and the leachate collection piping
system, waste pile underdrains, and the submersible pump
will be removed. The materials (except for the pump) will
be transported to the PEI landfill for disposal. The pump
will be steam cleaned for reuse. Soils in the excavated
zone and within the perimeter ditch will be examined for
signs of contamination and at least one soil core sample
taken, as discussed in Section I-Id. If there is no proven
contamination of the area, the excavation will be backfilled
with fill soil from local sources and regraded. The collec-
tion sump will be backfilled to prevent collection of
rainwater and erosion.
I-le Schedule for Closure
Within 90 days after receipt of the final volume of hazard-
ous wastes, final closure activities will be initiated.
Completion of closure will be within ISO days of this
occurrence. All financial calculations are based on a
closure date in the year 2002. The Regional Administrator
will be notified by Tankopile 180 days before beginning
final closure. The proposed schedule for closure is shown
in Figure 36. Final closure will be supervised and certi-
fied by a professional engineer, in addition to the owner
or operator.
I-lf Extensions for Closure Time [40 CFR 264.113(a) and 264.113(b)]
Tankopile Finishing Company will not require an extension
for closure time.
246
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Activity
1. Receipt of ,
final volume of
hazardous waste
2. Removal/disposal of final
waste inventory
3. Solvent wash of tank
storaye and pipiny system
pile liner
4. Removal /disposal of
solvent washinys
5. Dismantling and scrapping
or selling of storaye
tanks and pipiny.
Removal of pile liner.
6. Soil sampling
7. Removal of contaminated
soil
8. Completion of closure and
certification subwittal to
EPA Regional Administrator
Day
10
k
••
20
••
30
•
40
—
•
50
60
70
80
90
••
100
s
110
•M
120
•
130
140
ISO
160
170
180
A
"s?
O
tu
< rt
Figure 36. Anticipated closure schedule.
H-
O
3 10
5JIO
O en
M
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1-2 Post-closure Plans [40 CFR 122.25(a)(13)1
Post-closure care will not be needed for this facility
because this is not a disposal facility.
1-3 Notice in Deed and Notice to Local Land Authority [40 CFR
122.25(a)(14)]
Because Tankopile is only a hazardous waste storage facility
and not a disposal facility, notation is not necessary in
the deed informing potential purchasers of restrictions
associated with a disposal site, as required by 40 CFR
264.120.
1-4 Closure Cost Estimate f40 CFR 122.25(a)(15) and 264.1421
The closure cost information presented is submitted in
accordance with the requirements of 40 CFR §122.25(a)(15),
§264.142, and §264.143.
An estimated $57,500 (March 1982 cost estimate) will be
needed to close the Tankopile hazardous waste storage
facilities. The closure costs are presented by activity in
Table 14. Activities include removal of waste inventory,
decontamination, disposal of wash solvents, disposal of
contaminated soil, and closure certification.
The assumptions made in the cost.estimate are as follows:
1. Removal of final waste inventory. The waste volume is
100 drums of assorted wastes; 7500 gallons of waste
HC1, 7500 gallons of waste 1,1,1-trichloroethane, and
50 yd3 of metal hydroxide sludges. Disposal cost
estimates are based on land disposal of the drums and
waste pickle liquor, incineration of the waste 1,1,1-
trichloroethane .
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TABLE 14. CLOSURE COST ESTIMATE3
A. Tanks
1. Removal of final waste Inventory
a. Disposal cost (7,500 gal HC1 waste
@ 50.10/lb) 5 6,000
b. Disposal cost (7,500 gal 1,1,1-trichloro-
ethane 9 50.15/lb) 9,000
c. Plant labor (8 h 0 S12/h) 96
d. Hauling (2 trips @ S350/trip) 700
Subtotal 515,000
2. Decontamination of storage tanks, piping, and
pipe liner
a. Solvent (100 gal @ S2/gal) 5 200
b. Supervision (20 h # S20/h) 400
c. Labor (40 h @ S12/H) 480
d. Dismantling of two 7500-gal tanks and
ancillary equipment (8Q h @ S12/h) 960
e. Disposal cost of solvent, water washes and
spill control pillows (35 drums @ $40/drum) 1,400
f. Discharge cost to the city sewer system 260
Subtotal $3,700
8. Containers
1. Removal of final waste inventory
a. Disposal cost (100 drums of various chemicals
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TABLE 14(continued)
2. Disposal of contaminated base material, liner,
foudnation, and contaminated soil
a. Removal (50 tons: 80 h @ $62/h)
b. Hauling (2 trips @ 5350/trip)
c. Disposal (50 tons @ SSO/ton)
d. Disposal of residual liquid from sump
Subtotal
3. Decontamination of equipment
a. Rental of steam cleaner (2 day @ $75/day
b. Disposal of decontamination residues
(5 drum @ $407drum)
Subtotal
0. Soil Sampling and Analysis
1. Core samples
2. Core analyses
Subtotal
E. Closure Certification
1. Labor (P.E. 48 h @ S60/h)
2. Expenses (6 days @ $75/day)
3. Transportation (300 mi @ $0.23/mi
Subtotal
F. Subtotal
1. Plus 15% administration
2. Plus 15% contingencies
G. Total Closure Cost
$ 4,960
700
4,000
250
$9,900
400
600
^^•^^M
$ 1,000
$ 3,400
$44,300
6,600
6.600
$57,500
"1982 dollars.
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2. Decontamination of storage tanks, piping, and pile
liner.Tanks and piping for the HC1 tank will be
washed with water, whereas the 1,1,1-trichloroethane
tank will be washed with an alcohol wash. After
removal of the waste pile, the pile liner will also be
removed by plant personnel.
3. Removal of solvent washings. It is estimated that two
drums of water wash and two drums of alcohol solvent
wash will require disposal. Cost is estimated at
$40/drum.
4. Disposal of soil in contaminated area. Although the
soil is not expected to be contaminated by the waste
storage at Tankopile, an allowance has been made in
the closure costs for removal and disposal of approxi-
mately 20 yd3. It is assumed that 1 yd3 of soil will
weigh approximately 1 ton.
5. Closure certification. The cost of certification of
closure by a professional engineer (P.E.) is estimated
on the basis of a labor rate of $40 per hour and an
estimate of other expenses for a 6-day period.
6. Total costs were calculated by adding IS percent
administrative costs and 15 percent for contingencies.
This closure cost estimate will be kept on file at the
Tankopile facility. It will be revised whenever a change
in the closure plan affects the cost of closure. It will
'be adjusted annually (from the date of its original develop-
ment) to reflect changes in closure cost brought about by
inflation. The Department of Commerce's Annual Implicit
Price Deflator for Gross National Product* will be used to
make this adjustment.
Published by U.S. Dept. of Commerce in its monthly publication
"Survey of current Business."
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1-5 Financial Assurance Mechanism for Closure [40 CFR Sections
122.25(a)(l), 264.143, and 264.1501
I-5a Closure Trust Fund [40 CFR Sections 264.143(a) and
264.151(a)(l)]
Tankopile will establish a closure trust fund as the selec-
ted financial assurance mechanism at the Anytown National
Bank. An originally signed duplicate of the trust agree-
ment will be sent to the Regional Administrator by certi-
fied mail. A copy of the agreement is attached as appendix
C. A payment of one-tenth of the estimated closure cost
will be deposited annually in this account. Although the
expected life of the facility is 20 years, the duration of
the permit is expected to be 10 years. Consequently, the
payment period will be 10 years.
I-5f Combinations
1-6 Post-Closure Cost Estimate [40 CFR Sections 122.25(a)(16)
and 264.144T
Since all wastes will be disposed of off site', there will be
no post-closure activities or costs.
1-7 Financial Assurance Mechanism for Post-Closure [40 CFR
Sections 122.25(a)(16) and 264.145T
Since all wastes will be disposed of offsite, there will be
no post-closure activities or costs.
1-8 Liability Insurance [40 CFR Sections 122.25(a)(17) and 264.1471
I-8a Sudden Insurance [40 CFR Sections 264.147(a), 264.151(1),
and 264.151(j)]
Tankopile has obtained liability insurance for sudden and
accidental occurrences in the amount of $1 million per
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occurrence with an annual aggregate of S2 million exclusive
of legal defense costs. An originally signed certificate
of liability insurance has been sent to the Regional Admin-
istrator by certified mail. The certificate is worded as
specified in 40 CFR 264.151(g).
I-8b Nonsudden Insurance [40 CFR 264.147(b), 264.151(1), and
264.15KJ)]
Tankopile is a storage facility, therefore, no liability
insurance is required for a nonsudden accidental occurrence.
I-8c Financial Test [40 CFR 264.147(f) and 264.151(j)]
Tankopile has an insurance policy for sudden and accidental
occurrences, therefore, the financial test is not necessary.
I-8d Variance Procedures [40 CFR Section 264.147(c)]
Tankopile will not request the Regional Administrator for a
reduction of liability amounts.
I-8e Adjustment Procedures [40 CFR Section 264.147(d)]
If the Regional Administrator increases the amounts of
liability coverage or elects to improve nonsudden liability
coverage requirements, Tankopile will immediately seek an
adjustment to the insurance policy discussed above.
1-9 State Assumption of Responsibility [40 CFR 264.150]
Tankopile will not request state assumption of the legal or
financial responsibilities.
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SECTION J
OTHER FEDERAL LAWS
Information will be provided in accordance with the re-
quirements of 40 CFR Part 122.25{a)(20) at the request of the
EPA Region I office. At this time, however, we believe this
facility is in compliance with the following Federal laws; Wild
and Scenic Rivers Act, National Historic Preservation Act of
1966, Endangered Species Act, Coastal Zone Management Act, and
the Fish and wildlife Coordination Act.
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CERTIFICATION
I certify under penalty of law that I have personally
examined and am familiar with the information submitted in this
document and all attachments and that, based on my inquiry of
those individuals immediately responsible for obtaining the
information, I believe that the information is true, accurate,
and complete. I am aware that there are significant penalties
for submitting false information, including the possibility of
fine and imprisonment.
Date: "? V] ov(d\. £b. /? 7 2- Signature.: /))0<,/U/ / . S^-J^-t/i^o
Mary P ./Tones', President
255
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Combustible Liquids Code. Boston, 1977.
34. National Institute of Occupational Health and Safety. A
Guide to Industrial Respiratory Protection. 1976.
35. Fire protection book 70-1 of Plant Protection manual.
Plant Engineering. Technical Publishing Co. 1981.
36. Elements of industrial fire control, book 70-5 of plant
protection manual. Plant Engineering. Technical Pub-
lishing Co. 1980.
37. Schupack, M. How to inspect and evaluate prestressed
concrete tanks. Public Works, September 1981. p. 88-39.
38. Valach, D., and A. Gaines. Corrosion monitoring in chloro-
solvents plant saves over $60,000 per year. Chemical
Processing, March 1981. p. 20.
39. Earley, D. E. Source assessment: Rail tank car, tank
truck and drum cleaning - state-of-the-art. Publication
EPA-600/2-78-004g. Cincinnati, Ohio, April 1978.
40. California Department of Health Services. Samples and
sampling procedures for hazardous waste. Publication
EPA-600/2-80-018. January 1980.
258
-------
41. National Board of Boiler and Pressure Vessel Inspectors.
National Board Inspection Code, A manual for boiler and
pressure vessel inspectors. 1155 North High Street, Colum-
bus, Ohio. 1973.
42. Matrecon, Inc. Lining of waste impoundment and disposal
facilities. Environmental Protection Publication SW-870.
Washington, U.S. Government Printing Office, 1980.
43. Tryon, G. H., and G. P. McKinnon. Fire protection hand-
book, 13th ed. National Fire Protection Association.
1969.
44. Office of Solid Waste Management Programs. Hydrologic
simulation on solid waste disposal sites. Environmental
Protection Publication SW-868. September 1980.
45. Huibregtse, K. R., et al. Manual for the control of haz-
ardous material spills. Volume I, Spill assessment and
water treatment: techniques. Publication EPA-600/2-77-227.
1977.
46. OSHA Standards, 29 CFR 1910.
47. U.S. Army Engineer Waterways Experiment Station. Guide to
the disposal of chemically stabilized and solidified waste.
Environmental Protection Publication SW-872. Environmental
Laboratory. Washington, U.S. Government Printing Office,
1980.
48. National Fire Protection Association. Fire protection
guide on hazardous materials. 6th ed. 1975.
49. 'U.S. Environmental Protection Agency. A method for deter-
mining the compatibility of hazardous waste. Publication
EPA-600/2-80-076. Cincinnati, Ohio, April 1980.
50. Robinson, J. S., Hazardous chemical spill cleanup, Noyes
Data Corporation, Park Ridge, N.J., 1979.
51. Environmental Protection Agency Background document -
Listing of hazardous wastes. (40 CFR 261) Sections 261.31
• and 261.32, and its Appendix A. Health and Environmental
Effect Profiles.
52. Weiss, G. Hazardous chemicals data book. Noyes Data,
1981.
53. Smith, A. J., Jr., Managing hazardous substances accidents.
McGraw-Hill Book Company, 1981.
259
-------
54. Acurex Corporation and Metcalf & Eddy, Inc. Closure of
hazardous waste surface impoundments. Environmental Pro-
tection Publication SW-873. Washington, U.S. Government
Printing Office, 1980.
55. Bureau of Law and Business, Inc. Employer's handbook of
hazardous waste training programs. Stamford, Connecticut.
1982.
56. Southwest Research Institute, Department of Special
Studies. Technical Resource Documents - Land Disposal and
Other Facilities.
57. American Petroleum Institute. Guide for inspection of
refinery equipment, chapter 5, third edition. December
1978. Washington, D.C.
58. National Fire Protection Association. Cleaning small tanks
and containers. NFPA No. 327, 1975. Boston, Massa-
chusetts .
59. Financial Assurance for closure and post-closure care:
requirements for owners or-operators of hazardous waste
treatment, storage or disposal facilities. Guidance Docu-
ment. ICF, Inc., SW-955. May 1982.
260
-------
Date: 2/26/82
Revision: 0
APPENDIX A
GENERAL INFORMATION AND HAZARDOUS
CHARACTERISTICS OF WASTES
Excerpted from: Dangerous
Properties of Industrial
Materials, Fourth Edition, 1975
by N. Irving Sax
261
-------
Dace: 2/26/82
Revision No. : 0
HYDROCHLORIC ACID
Gcaml lafoRutfcM
Synonym: nuwuiie tad: calonhydnc tad: hydroaca
chJortde.
a-TXICHLOROrTHANE
ParanUiHa
Mai «: J4.47. op: -I14JX. bp: -4CIT. d: I.6J9
I/UtBT (pil a in fermcd only it IB iBlutaior u PIIHBL
Fin Haauri: Hiialy dantnwa woca urpciad to beat or
Spomaacaui Heatuif: No.
EiptoiiBa Haard; Smn. IB tat (arm of vapor '
upoaid 10 heat or oana>
DoaacrHaard: Voy danijiDiK *baa bnart n
^afflpmitioni it caun hiibly loac Auaai of pooa*
faoa: can reaa vigorously with oudian« maw-
mhv Btfora uonni or hamflinf iha maunai o-
mncaana for ita am should ba obiaioad (ram ttaa
SpoRiaaaoai Hatu«: No.
Eipiouon Haard: Unknown.
Dauttr Haard: Oantcroua: wbaa baaud to i
•ooa, it buna tad omat acnd ftoaaa; i
wnaondiaati
roue IMAM umv COM
-------
Date: 2/26/82
Revision No.: 0
Synonym, plumbum.
Bluoh-tray. loft mtuL
Famuli. Pb.
Al •»: M7.21. mp: 3Z7.4IX bp: I630X A. 11JM «
»varC. np. pranv: 1 an *t 9WC
TiMt 5. Afiiflail
to MB* *n b»
M«V mt
(X UnmuB
-fh. TH - 52k. Onyt
. Emu -ft at 0.40
TH'Zly. O«inwndia>
f» at 9.013 (II «V 0061
at am* M«V. -Pb
r^
n§
(lf«) M«V.
•m
1-1
i Saw). TV» - tafia. Otctyi to
-SI by toMMM 4*t of 0.16 (5*), a>» (11%). OJ8
(14*) fcfcV. Ate «BM T'i «< OL34. 030 MtV wd
M*fVyin
Blnnm U««Bnn>1* n^^^&nBBBnl^ <^ *4^ fcwnnBi jn*T
-------
Date: 2/26/82
Revision No.: 0
CnOMIUMCOMFOUNDI
Tone Hurt Hume:
torte
•d at » lad pmcfl My hi fond, dtttftr i
IM bMi of ite aadt.« iht bmdtlM. teMMi at
~ tarn tad to to
«d pnvw dOTriy. Itey «• fnnnUy
•. IMM tteMft qoMdin. Th«y hal ilo^y.
OMA, pWflHHMB Of liM HMl ttfflHH B
tea iiiuduMi w dtfofniy a( tta on*.
xrfttal
264
-------
Date: 2/26/82
Revision No.: 0
LEAD COMPOUNDS
Teaic Hacard Rauaa:
Acute Local: 0.
Acute Syiienue- Intouoa 3: Inhalauoo 3.
Chronic Local: 0.
Chronic Syiumic: Incawwa 1. Inhalation 1: Skin Ab-
wOfpuofi 3.
Toaieolov Lead paoonint a one of the uommonmt of
occupational dbvaie*. The praaencc of kad-beanai
oaieruua or tad eompoundi in ea mduMnai plant
daea not aaceuanly mull ia eapoaun on the pan
of the workman. The toad IBUH be in tuch (arm.
ad a dninbMod. e> to (an emrenee UNO the body
i of tha workman ia ojenunhle quality.
i cea be uid to «UL II • a
of ae laaea aad kidnryi
(Section I).
Mode of entry owo body:
I. By atfMBUoa of OH '
X Throw* the akin: that root m of ^
l*"a"*to 2*001 of the
uanBBB.gfao
to ha more tone than mnallic toad or other lead
eompoundi. Lted inenaie u wy toaic. due 10 the
greacoce o( the anetuc radical.
. and Symptom*: Indutinal toed pooonui com-
monly occur* followine prolonted tipoiure to lead
or M compound*. The common clinical type* of
lead pouooinc may be damned accordini to their
diaieal picture u (a> tiimenunr: (b) aeuromoior.
aad (e) encephalic. Some caae* may thow a com-
bmaooo of dimcal type*. Tbe tiimentary type oc-
cur* moat frequently, and a characieruad by ah-
datmaal docarafofl or pain. Seven cue* may pr*»
aem actual colic. Other complainu are eomiipeuoa
and/or diarrhea, Ion of appetite, metallic lawe.
aauata and •omiuns, laauiude. imomiua. weakaeu.
jam tod anode paint, imutbiuiy. headache and
-tun— Pallor, lead line on the fumv oyorrhea,
loai of awjBPL abdoBitnal tendcrncu, baaopbilic
latmia. diohi aibtmununa,
ration, aad a lacreate in the toad i
of UN whole Mood, an turn* »hieh aw
to the aeuromuacular type, the dnef
B) aMineii (requently of tha tiunaor Bode* of
the WIM aad hand, unuaural or bilateral. Other.
™*d* aTQ«"» ,»*"c» are aibrtct to coatuat UM
ally ureaent. bat an at at enen n a the ato»
Slr^'aUfaMdfto PMBMta baffo'aa
of toad an OBBaary to
lK aborpooa a by i
A taBflaV pBWaf Of
to prnimnj niiuiiiia OB the
tta pom of new of
bold ua a the body cad neniiielly a
JbM^llfv flM
Inejlll7« IBB
n the body thaa aonully .
which * nrdy itven. Tbe lo» of
of
mat vorker U foUoew rapid tod heavy lead
I ramdly ihrouih the i
ea IBIBUBB the luaea, aad in tetacuvely
by the oaml nerveo* iy*un The diaical
• thai can a uuelly a eacepbelopethyJWth to-
uooi a the central nervou* lyttem an reached only
whaa the workptace • heavily
tad often
_! by Ham) of
^ There • uwally atuper.
wnh or without aoavoutian,
I IB <***t|> ExQtaaoB, fianfu-
^^ i jg m.irftf ca*e> of
than duniMO, then may ba lymptema of bead-
Tba
•ynaiiia i^ai^am ••• «^BWWW""» ^ •»• •^^"
A* retard* the effect of toad oa the wtae blood
caUa, then a ao untformity of owmton. Ia addnaw
10 us effect oa the red ovJt of uabtood. laadpio-
deaihi annbutad to toad poaomot od
mental work oa tmmaht, have ihowa .
t of the kidney*, over, male fonadt.
ad other tame*. Moaa of
A diacBoao) of lead i
oa the beia of any finale diaical or labora-
tory Oadias, Than nuu b* a salary of usmncsm
(a
el uumptiihle with the ducBan. tad oonorm*
aiary laboratory ten. lacrean of uipplod red blood
,—11. QBj^ .«-•»».», (art devetad lead ut blood cad
M. aon thaa aor at/100 ad blood ad
value* par mar of urme. AB laereea of
iad certaiB tmino teuh) ia unne
Ouminiiic rnnmlintirm of toad
EOTA may ba uaaful UK
foaod IB tha blood • frtcuemry m aapjoi of OOT
mt per 100 ce of wboei blood. Tbfunoary lead e*.
cmioa onarBtty eaoadi & I aw per liter of unaa,
The UBUcny of the Tanaaa toad uunmmndi ao>
pean to depend upon erwral (acton: (V) the Mh>
bdny of the uaapoaad a the body IhudK (2) the
Sneneei of the pamclm of the compound: ntB.
bility • ereatar. of couna. ia praporuea to the flae-
IMBB at the pamdea: (3) condition uadar wtfBB
the uumpound a b-5»?*d! "J"**B*J—*J™JJ
umophan will bo much IOB> whan the powder •
kept damp. Of the vanoua lead compound* the
certeoaaa, the oonomide tod mtfaia ire < ' '
of Lead Fooooaar It ba bee
IBB eheUurjf tent, calawn ethyienediimae.
Huaetuie, tad reUted eompoundi in nfttly «*•
Saoota IB renonnf ibwrbed lead from (hi t»
tuea of the body. (The therapeune aeenoi of IBB
md ud Ca EDTX)
Ca EDTA la tUton* only when
lamvenoualy. Venoua douaa ichedulei ban beet
proooMd. An effecnvo renne • J u 6 BIBB of
Na Ca EOTA ia 300 ce to 300 ce at i percaa
fJucoM by intrivenoui dnp over a period of 1 to
I houra. Tmunem may be «*
-------
Date: 2/26/82
Revision: 0
APPENDIX B
INSPECTION LOG SHEETS
266
-------
MMIIOIING fQUintfNI IMSriCIIOH IOC SMH
Intptctor't niM/tlll*
0*U of Intptcllon
IIM of Intptctlon
(•onlh/diy/ytir)
{•Hilary HM)
IIM
liquid Itvil IrtDMlttiri (lanki)
Conttmatlon unit (lanki)
Ittchtlt dtltcllon. collection.
and rioovtl tytlM (mtU plU)
Ground tialtr lib It control tytlM
(unit pllt)
lunoff colltctlan *nd ruowil
tyllta (M*I|I plU)
Ground w«l*r libU Hitir «l«r
(laciltd In tumf}
lyptt of prablut
Irtntiltlir tlynil. •Itclrlctl
circuitry, pontr
Spring (djuilMnt or tllcklng
Irokin plpt or conmctlon. lick of
gr««il In pipit, cloggtd Itolti In
pip*. »ngl« of drilnig*. ground
Mittr CalltcUd. luoy piap fallurt
Broktn plpt or connect Ion. Itck of
grivil In plpt. cloggtd nolti In
plpt. tnglt ol drtlntgt
Braktn plpt or conntctlon. Uck of
gr<»tl In plpt, cloggtd noltt In
pipt. tnolt of driliugt. luip
pu«p Itllurt
Clogging, •ilfuncllon of dlglltl
dllplty. rotor (licking. Mitring
of gtart
-tc-tpiltfH
(VI
Unacctpliblt
Oblirvitlont
Ottt anil n«lun ol
rcptlrt/rciirdldl tcl Ian
ro
a\
Figure B-l. Monitoring equipment inspection log sheet.
500
n PI
< r+
H n
u> ••
00
tv>
-------
SMIIY AHO IHIRCIHCV IQUlPrtfNI INSPfCIIOM IOC SHU I
10
0\
CO
Intpiclor'i naM/lllla
Data ol Inspection
HM of Intpectlun
(•onlh/day/yaar |
(•IllUry ll«)
lira
Standard Industrial abtorbtnlt
(Sorb-All, Varalcollte. lie )
Sindbagi
Sand
Abiorbanl boos
Abtorbcnt pads
Slrax
SubMrilbU puap
f lulbl* tiom vllh quick caupli
Illtlngi
SS-gillon drum (iltil, titlnltti
tlttli
fMrgtncy ih(M*r and
fact ihlildi and titra proltcllon
tyiglitltl
Oltpetalil* rctplralora
Chtclcal carlrldgt rttplratort Milk
cartrldytl for organic napori and
acid gam. halt and full fact
lypci
lyptt of problrai
Out of stock
lorn or worn
Out ol tlock
Out of alock
Out of llock
Out of stock
Povar, clogging
Cracki or holai. filling! stick
Cor rot Ion, tlruclural diugo
Malar pranura. laaklng. draliuga
•rokan or dirty aqulpMnl
Out of ttock
Sptnt chnlcal adiortanl. itali
Acciplib
Slat,
•bit
uAIcciptiBU'
Ol»tr«allon»
Oat* and nature of
rrpalrt/i««rdl4l action
Figure B-2. Safety and emergency equipment inspection log sheet.
JdO
n to
< r»
H re
in ••
Z is)
O CTi
00
K)
-------
Figure B-Z(contlmied)
to
a\
ID
IK*
Chatl-Munlad gat calk cannltltrt
Scll-cenlalnad breathing apparatus
(SCBA)
Portable tuav puap
lira blanket!
flri eillngullhert
flri «Ura tytleai
telephone tyileo)
Public addrtit syilu
C«n«r*lart
iMrgcncy llflMlog iy»l»
f Irtl lid cqulpMnl and >u|iplltt
cltanir
Proltcllv* clothing (l«P*r«tilili
lull-body cov*r«llt. gloixl. and
loot covtrlngtl
Uccunlaalntllan facility (thoutri,
dirty raua. cl«n row)
lypat el pr«bl«t
Caonltltri bttuM •>h
-------
sicuiiiv otvias IHSNCIION IOG SHIII
to
-j
o
Intpeclor'l naM/lllle
Dale of Iniptcllan
lUt at Intptcllon
(Miith/day/yeer)
(•Hilary UM|
Ill*
facility fence
E«t gait (aatn entrance)
Htit gtlt Mid lock
Contilntr storage irca tenet
Conttlnir storage erea gilt ind
lock
Icule control la east gale
I wo -way rtdlot
lyptt of problwi
Corroi Ion. dMiat la chiln link
fenc* or birbii ulrt
Corroi Ion. dMigt to chain link
fine* or barbti ulrt
Corrotlon. daaagt to ckaln link
fence or barbti ulre. flicking
or corroding lock
Corrosion, dwege to cbtln link
fence or barbel ulre
Corroiloa. daaage lo chain link
fence or barbed Hire, iltctlng
or corroding lock
Iran»llter or receiver, itlcklng
of gale
Irantolller or receiver
S'llH
-Acc.pUbli
(Vt
Unacceptable
•
Obtervatlont
0
• \
.. 00
to
-------
OPIIAIING AND SIIUCIIUUl iQUIfMHI IMSHCIIOM 101 Will
10
Iniptclor't iMM/lllli
0*11 of Intpoclla*
HM ol Intptctlon
(•onlb/diy/yoar )
(•IMUry lUt)
ll» •
Suop piapt (autooJillc)
Simp piiapt (•inuall
Olkn
lUttt or foundation!
I«H»
iuip crcn
lint tlruclurtl tiyporli
f Iplng la holding Itnlt
Holding Unkt
lyptt ol prabUu
{•Ulna (djutlMnl. poutr.
clogging
foMir. clogging
Crtcki. diltrlorallon
froiloa. untvoa tctlltwnl. crtckt
•nd iptlllng In cancnlt ptdt.
but rlngi ind pltrt. diltrlar*-
llon ol n»l§r toil btlMttn lint
bollo* «nd foundation. «(l ipait
(ration, unovon toltliMnl. crukl
•nd tptlllng In conceit*
{ration, unovon toltltMnt. cracki
•nd tootling In cancroti. Ml
•pan
Cancril* doltrlarillan end crick-
Ing, carratloa of plpi tupporti
lott of Mill tblckntit. lotki,
car rot Ion. or dolorlorallon
Carrotlun. dltcelarillon. crockt.
buckloi. and bulgot
, Slltu
~«ccipi«bfr
•«•
iW- -.
Untcciplibli
Obtorvitlont
Olio ind noluro ol
ropllrt/rcaedlll action
Figure B-4. Operating and structural equipment inspection log sheet.
< ft
H-CB
in ..
H-
§,
00
ro
-------
CONUIMil SIOIAGf AUA INSPfCIION IOC SHifl
10
-4
10
Intpactor'i iuM/lltU
Oil* of Iniptctlaa
HM al Intpacllon
(•onlh/day/yaar)
(•Hilary il-a)
llm
Cental liar placeMnl ind (lacking
Staling of contalnari
libeling of container!
Conltlntri
Segregation ot Incompatible uailai
Pal let 1
Feme, git* and lack
Bitt or foundation
Dltet
Suof> area
Suap punpl (auloaillcl
lypoi of problaat
Altla tpaca. hilgtit of ttacka
Opan lldi
latiropar Idantlflcatlon. diU
•tiling
Corroiloo. laaiaga. tlruclural
da facts
Sloraga of Incoopatlbl* vaitM In
IIM arta
Daaagod (t g . orokan Mood, uarp-
Ing. nalli Bluing)
Corrotlon. daaaga lo chain link
tanco. (ticking or corroding lock
Cracki. ipalllng. unavan tittlnant
arotlon. vat tpott
Cracki. dalcrlorallan
Crackt. ipalllng. uncoan ttllla-
•cnt aroilon. nal tputi
Sattlng adjuil«nl. powar. clogging
Slltu
•cciplabl*
HI
UntccaptabU
•
Obiar«allon«
Oal* and nature of
rapalrt/rCBidlll action
Figure B-5. Container storage area Inspection log sheet.
» u
n ai
< rt
H n
IA ••
H
o
3 rO
Z ts>
O
• X.
.. OD
to
o
-------
Figure O-S(contlnued)
IIM
lypt* Q> problem
Slitu
Obitr«ttIant
0*t< iml n*lur« a>
r*pdrt/r«Mdlil tclion
Oilirli ind rttui*
Clog tup pup. MillMllci. poi-
tlbl* r««ellon vllh U«kt
(rack*, tpalllng. uM«tn tiltlt-
Mn(. trot Ion
Wtrnlngk tlgnt
Nl
jo a
« m
< rt
H n
la ••
O 01
Kl
-------
UN* SIORAGf Ml* WO MICIIIMV fOUIPMN! INSrlCIION IOC Will
Intptclor'l nnw/llllt
Oitt of Inipa'cllMi
MM of Iniptcllon
(•Hilary tlw)
Itc-
lypli al probltBi
Slalut
Accoplabtr
llnacccptablt
Obl*r»tloni
Date and natui* of
rei»alri/ie«»dial aMIon
Dike
Bait or foundation
Suip puip (Manual)
Su«p arta
to Marnlng ilgni
•** riptl
Val»l
rilllngi
0>arflll control vtlva (•inutl)
Cracki. dotorloratlon
tracki. ipalllng, untvt* lollla-
awnt. trotlon, not tpoli
•OMT. clogging
Cracki. •palling, unoton itltlt-
awnt. orotlon. Ml ipoli
Oauagtd
lota of wlal thlcknttt, leak*.
corroilon, or dttarloratlon
loti of Mill thlckntit. Uiki.
corroilon. or dtlarlorillon
Ion of Mlal Ihlcknaii. laakl.
corroilon. or dilarloritlon
loia of Mlol IMckntii. Uaka.
corroilon. or daltrlorallon.
•licking. daMgtd handle
Figure B-6. Tank storage area and ancillary equipment Inspection log sheet.
joo
n o>
< rt
H n
in ••
H
a: to
O cr<
o>
to
-------
lllflMAl IMH IHSKC1ION IOC iMIH
Intpiclor'i niM/IIIU
Oilt af Inipicllon
DM of Intptcllon
(•anth/diy/yair)
(•Hilary HM)
typtt af problrat
Slll.ui.UL -, ,
Acctptibli Untcciplibli
Obtirvillont
Dilt iml ntluri af
rtptlrt/rtMdltl *cllo
10
-J
U1
lounililloa/tlriKlunl iu|iparl>
ripi canmcllaui
PraliclU* catling
link thtll
Iink roof
link BOIIOB
Anchor bollt
Nunlct
. tlruclurtl tlcblllly
Crick t. ipilllng unevtn titlliatnt.
•roilon. M«I ipolt
filirail corrotlan. cricki, dltlor-
lloa
•utt tpolt. blltlirt. Ill* I If ling
Carrot Ian. dltcolorillon, cricki.
buckUl. bulgif
Nilfuncllan af i*ilt. blockig* of
•lltr drilni oo roof, corral Ion
Carrot Ion. dlicolanllon, cricki.
bucklit, bulgat
Oltlarllon. corrotlon
Crickt. corratlon
Figure B-7. External tank inspection log sheet.
yt o
n 01
< r»
H IP
W ••
H-
O
0M
as to
o ot
00
Kl
-------
IN1IIM1 IMM INSmilON IOG SHHt
Inipictor'a nuM
Oile af Iniptctlen
MM of Intptctlon
(•onth/day/ytar)
(•Hilary DM)
ll»
link roof
Inltrnal support*
lank thill
i
link fcotlM
Malt Jolnlt
Noli It connection JoInU
Clan lining
lUilt
•Ipicoll itipparl
lyptt of problwi
Naltumllon o« roof'i Halt, cor-
rollon. Ion ol aalal Ihlcfcraii
Otltrlarallon. dcprtnloni
Carrot Ion af vapor »p«c«. and
liquid Uvtl Una. cracking.
bulgti. holti. loll ol Mill
Ihlckntit. laani
Corroilon pill, iprung »M>.
rl«al«. dtprdtlont. tolloa Ihlck-
naii. unavannan ol bolloa
Cracking
Cracking
Cracking, bubblti
tlgnlntfi. corroilon
Otpraiilont
Slllu
7KcTp(*6li
'
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WASH Pllf All* INSPfCIIM IOC iWII
to
Imptclor't niM
Data af Inline* Ion
HM of Inspection
(•onlh/day/yaar )
(•Hilary UM)
lln
lun-on diversion ditch
intranet road and guard rallt
lunoff dlvarilon canal and drain
Hind dlipartal control lyitia
foundation
Synthetic llnar
late
1 Iner !•••»
Julnlt
lypat of problaat
Obilructloni lo Ilex, bant orotlon.
loota riprap
lott of gravil. fuylll«a ••Itilont.
corroilon and llghlntll ot guard
ralU
Otiilruclloni. drain clogged
fraquincy of Malar application.
drynatt and tlopa of pi la
Crack* or braakt
Itart. bolat. itparallon of Ityart.
Into ipoli. crackt. ihrlnkagt.
bardnaii. aicattUa paraaablllly.
bllilari
i rot Ion. aipoiad araa lo llmr.
dtplh
lair, llghlnatt of taaai
llgtilnttt of connection
Slalu
'•cciplabTo
•
ilnaccaptabU
Obtarnallant
.......
Oalt anj iidluiv of
r«ualrt/if«
S5M
O a\
to
-------
Date: 2/26/82
Revision No.: 0
APPENDIX C
TRUST AGREEMENT
278
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mat A«rMMnt. tiw '»qr»««it.- mcwid
into *a at July 10. 1*12 By and Battmn
Nary P. Jam*. • Mtad* Island corporation.
we 'creator.* tnd Jonn victor, an Anytomi
national tana. CM *Tn»tM*.
Whereaa. the United States Environmental
Protection Agency. "SPA/ an agency of the
United Statee Government, has established
certain regulations applicable to the Cnntor.
requiring that an owner or operator of a
hesardoiu waata managemant facUity ihail
provide asiunace that funds will be
available when needed for dosun and/or
posi-dotun can of tat facility.
Whereaa. dw Grantor baa elected to
esteWish a trust to provide all or pert of «och
financial aaaenaet tar the faeJUne*
idennfied hereuL
Whereae. the Creator, acting through fta
d*> atjtbonxed officen. baa eelectad the
Trasree to fat tht outee under thie
Lead me Traateo I* willing ta act
the Creator cad dw
Administrator from the Fund for closure and
poit-cloeun expenditures in tucb inounu u
the EPA Regional Adnumimtor shall duvet
m writing, la addition, Ihe Trustee thail
refund to the Grantor inch amounts w the
EPA Regional Administrator specifies in
writing. Upon refund, each fund* shall no
longer constitute part of the Fund aa defined
Station JL AymtiMi Compnung wt fluid.
Payment* made to the Trustee far tht r*und
ibMcot^ of cash or locHiitioe acceptable
to the Trustee.
Steam d Thwiw Manafmnt tbt
Trntw thin iantt ud man* the prtaoBftl
.nd maoM of the Fund end Iwep the Fund
inveeted ea • nogie road withom dUUneaoa
with general investment paliatt end
gn^-ii... whlch dw Creator may
cammumcait in writing to dw Traalae
time ta ome. subnet, however, ta the
(a) ToeeiL exchange, convey, transfer, or
otherwise dispose of any property held by it
by public or private sale. No person dealing
with the Tnuiee shall be bound to see to (he
application of the pnrshaaa money or to
Inquire tote the validity or expediency of any
such tale or other disposition:
(b| To make, execute, acknowledge, and
deliver aay and til documents of transfer and
eaaveyaace tnd any and ail other
Instruments dial may be necessary or
appropriate to carry out the powers herein
(ranted
(c| To register any aecunoee held la the
Fund in its own name or in the name of a
atasBMt and to bold any security in bearer
form or in book entry, or ta oambiae
oernncalea representing each securities with
ffff^frmimm of tfej same laBot head by the
Treats* la other fktooary ceoeaoee. or to
dtpaert or arrange for tht deposit of each
memiaiiaedautnldtpaaitary
Secrraa J. Offitutuu. A*«
kgnemant
(•I Tito t
I the Fend, the:
iwimnapecttadwt
fund eaieiy • tht interest of the heneflnaiy
and with the care, xUO. |
rtht<
Miun. wiMid OM in the
i of • Uko
of a
ead with Uw
Co* fiuimotca, Thia Agreement ptrtamt ta
the r«aliiieeend cool esUBUteo identified aa
attached SchteMt A [on Sctierhila A. far i
faolHy U*t tat EPA I
id thai
orpoali ---
thereof, for which 1 ---
demoMBaiad by thia AgreeBiem|.
SteuoH 3. EtteUiifiatataffliad Tat
Grantor and the Traatee hareay emMlaa a
trast fund, the Tuna." for the benefit of EPA.
The C«nti»*nd the Tnutee intend that no
third parry haw acceea to the Fuad escepl aa
hermi provided. The Fund ta eeubhabad
uuluUy aa canaUbRg of the property, wbacb
u acceptable to the Traitee. deacnbed la
Schedule B attached hereto. Such pro
and aay other property wbaeqaeatly
rooUgattontofta*
rof
tat faeUittee. or aay of thanr i
defined ia tat laeiotmeni Company Act of
ttea. aa aiaendiit l» UA& aOa-ajal. ihail
not bo acqiand or bald, oaleaa they an
i or other obUgtooaa of the Federal
ora
(hi Tho Troatat U aothoratd ta ta«aal the
Fond la one or demand daponta of the
Traatao. to the •Meal laeand by an aaancy ol
the Federal or Suit
-------
Stction a. Advia ofCoumtl T*t Tnattt .tfoo ptyMt U f«o»»*d ban iht Groom
n»t from time to time caniuli with eounatL teUf Ihtl ponad. Afttr tht ptylnpmadli
who mi) bt eaiuMl le Iht Ciutar. with aaapltitd, tht Tnuttt thall not bt icqulnd
tnptn IB My quttuon mnof H to Iht to ttnd • noflet of nontuymtnL
conitruction of ihu Aqrtonnni or My teflon Steuan U Ammdmmu o/AfrtMMUi Thif
to b» taken nrrmmdir. Tin Tnatetihallbt Agrwrmtnt mty bo tntndtd by tn
hill% prottettd. to tht niMt ptmutitd by tutramtni In wrung tstaitod by iht
Uw. ui acting ueoe (fat advice of eoaniel. Grantor. Iht Tnutot. and Iht apprapnatt
Sfcuon U. Trutfi* CaaipMMlian. Tbt EPA Raawaal Admimimior. or by tht
ItaMttihaUbtmtitlodtorMMMfa!* TTMIM and tht ipprvpnatt BPA Ra»tmil
umiriiniiurm fir' 1~~* T~ Admlmtntor If iht Cranior OMMS u «ati
QBBlfPVnaMMUM ItM ••• M*VIHW w ^^B v« «p /WHIIUUWVtWX H 9MMW ^VIVHIIH WV^^wv "^ — ™—^
tawntini from ttant lo ttot with tteCnnur. Stetwa IT IrrnecabiUtf out Tomnauan.
Stcuan 13. Sucatier That*, nt Tn»U» Sabttd to Iht mht of tht p«1iM to MMad
gwrmisnorihtCnnioraayrnlMadM tto A*vta>tat M provtttd ta faction 10. thu
Tnutn. but taeh t^m»t»ea eTftpliiiiminl i^>i thtll bt Uwumhlo Md thall enptHmt
»htU not bttfitcflv* until tht GftBtorhM mttlttfmintttd tt tht wrtmn Mntntnt of
mamu noi ww •iwwwww •«••• MM vMiwHiv- «^ aBoJ miiwua « IDW wnnwj ««JMBBM
appointed •taecnaartr.Moi and tfajti tbt Grantor tht Traiita. and the EPA
mcenior aceeptf tht anpuinoooBL Tht RtBenaJ AdmniMratar. or by Iht Traotot
tuecBMor tnutte thall ho-t Iht MOM pawn .^ £, gp/t ntilnnil Ailinmltlioiiw If tht
Md dntitt at thott cauttrad upon tht Gaum uaoott in tilil Tl|nai lumlnonioi nf
Ttuttte hoioiuidor. Upon the otBBOttor ibt Tint I all loinolmiii nuti pnipoitT 1«"
truiltt't acceptance of tht opvanUBOBtW >..! aM| ^i,!,..!,,^^, «B)OB«OO. thall bo
2tHmnI|?'*1'bt
•bMmet of wntttn notict ta tht oontrmry. that wonhm tpodfltd IB 40 CPP. JB4.181lilU) at
Dotvatcomtitutinsachanftara taeh rtnilidani wtn camataud aa tht date
ttmination of tbt niihortty of any POMOB to firtl above wrttttn.
act on bthtlf of tht Cnntor or EPA
btrtundtr bat ocaurtd. Tbt Tnutat ihall . - -
ktvtnodBtytoactinthtabtanetofnch ttmuuimt, Tanaeoilo naioua* Co. too.
ardtn. nqutiu. and uuuucttoat froa the ^ „..
Cramer and/or EPA. nctpt oa |
5tetiaii IS Nonet ofNo«para*u. The B«ii«-it. «nyta» -itiaatl
Tnuttt ihill notify tht Greater tad tht **>
rppropHait 7A Rational AdBumatnior. by
OBtlfitd null within 10 dayt (oUowtnj the
tuirtiion of Iht SMay period after the
i eitabluaauBi of the Tl-at
280
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