&EPA
              $!•<••
           Envtronm«nui Protection
              Solid W||i« tno
DIRECTIVE NUMBER: 9480.03(85)
TITLE: Technical Justification for Closure Within 30 Days
     of Last Receipt of Hazardous Waste
            APPROVAL DATE:  8-2-85
            EFFECTIVE DATE:  8-2-85
            ORIGINATING OFFICE:  office of solid waste
            Q FINAL
            D DRAFT
             STATUS:
                        [  1
                 A- Pending OMB approval
                 B- Pending AA-OSWER approval
                 C- For review &/or comment
                            D- In development or circulating
            REFERENCE (other documtnu):       headquarters
  DIRECTIVE    DIRECTIVE    L

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PARTS 264—265 TSDF TECHNICAL REQUIREMENTS DOC: 9480.03(85)
Key Words: Closure, Final Cover
Regulations: 40 CFR 264.221, 264.251, 264.301
Subject: Technical Justification for Closure Within 30 Days of Last
Receipt of Hazardous Waste
Addressee: R. Kent Anderson, Land Disposal Branch
Originator: Susan Hughes, EPA Specialist, Financial and Assessment Branch
Source Doc: 9480.03(85)
Date: 8—2—85
Summary:
This memo describes design and operating standards required to minimze the
formation and migration of leachate to adjacent subsurface soil ground water or
surface water. The memo also addresses reglatory provisions for waivers from
the liner nd leachate collection and removal requirements; no waivers exist
for the closure provisions.

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9480.03 (85)
E- 2ig
TechnicaL Justification for Closure hithin 30 Days of Last.
Receipt o Easardoua Waste
R. Kent árson
Land Disposal Branch (W}1—565E)
Susan Hughes, EPA Special is t
rinancia]. and Assessment Branch (WH—562a)
I was able to find very little time specific information
to support the above, however the following may be helpful.
- Tb. hazardoue waste reguLations are based on a two—part
‘pr.v.ntion and care system who’s overall goal is to minimize
th. formation and migration of leachate to the adjacent subeurfac
soil. gro ind water, or surface water. The regulatory goal of
minimizing the formation and migration of Leachat. is achieved
through th. design and operating standards that require the use of
(I.) a lin.r that is designed and installed to prevent any migration
of waste out of th. unit to the adjacent subsurface soil or ground
water or surfac, water throughout the active lif, of the unit7
(2) th. installation of leachate collection and rencvsl systems
and run—cc controls for waste pile, and landfills, and the
removal or solidification of wastes and waste re .i4uea at closure
for surface impoundments7 and (3) the place’nent of a final cover
(cep) placed on top to minimize the p•rcoi t.ion of liquid.. ih -to
the unit. EPA is relying prinicipally on c e final cover (cap)
rather than the bottom liner to provide pcst-closure protection
of ground watsr.
Whit. the regulations contained provisions for waivers from.
the liner a isachat. eoll•ction and removal requirements, no
such provisions were allowed for the closure provisions. The
reasons being that aside from ground—water protection, the final
v.ra2w,. (a) prevents the bathtub effect (i.e., filling
vi b 1.achat. and overilcwing)7 (b) protection of surface water\
119r ru* —offz ant’ (c) discouragement of direct access to the waz e.
I. to the July 26, 1982, Federal Register , .Voi. 47 ,\
- .43,pp 32312—32316.
H —S65 z1ent.An4erson:pin:S2o6 : 382—4654:WSM:8/2/85

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Unrt Stat.a Office of
£nvIrovrn .nijI Pyoi.ctiofl So u Waits a
EtIierQ.r cy Rea ons.
DIRECTIVE NUMBER: 9480.03(85)
TITLE: Technical Justification for Closure Within 30 Days
of Last Receipt of.Hazardous Waste
APPROVAL DATE: 8285
EFFECTIVE DATE: 8285
ORIGINATING OFFICE: Office of Solid Waste
FINAL
O DRAFT
A— Pending O approval
STATUS: - [ ] B— Pending AA-OSWER approval
C— For review &/or co=ent
- [ ] - D— In development or circulating
REFERENCE (other documants): headquarters
fl ibc
DIRECTIVE b(flE; CT1VE £

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PARTS 264—265 TSDF TECHNICAL REQUIRE NTS DCC: 9480.03(85)
Key Words: Closure, Final Cover
Regulations: 40 CFR 264.221, 264.251, 264.301
Subject: Technical Justification for Closure Within 30 Days of Last
Receipt of Hazardous Waste
Addressee: R. Kent Anderson, Land Disposal Branch
Originator: Susan Hughes, EPA Specialist, Financial and Assessment Branch
Source Doe: 9480.03(85)
Date: 8—2—85
Summary:
This memo describes design and operating standards required to rninimze the
formation and migration of leachate to adjacent subsurface soil ground water or
surface water. The memo also addresses reglatory provisions for waivers from
the Liner and Leachate collection and removal requirements; no waivers exist
for the closure provisions.

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9’ 8O.O3 ( 35)
2Ls
T chniCa1 uitification for Closure ,ithin 30 Days of Last
Receipt o azardoue Waste
R. ! nt raon
Land Dispo*mi. Branch (WH—565E)
Susan aughes EPA Specialist
linanc.ial and Assessment Branch (WH—562 )
I was able to find very little time specifLc nfor
to support the above, however the following ay be helpful.
The hazardous waste regulations are based on a two—part
prevention and caxe system who’s overall goal La to ninim z.
the formaticn and migration of Leachate to the ad)acent subeurfac.
soil. grnund water, or surface water. The regulatory goal . of
einin.tziziq the formation and migration of leachate is achieved
through the design and operating standards that require the use of
(1) a liner that. is designed and installed to prevent any migration
of vsIt• out of the unit to the adjacent subsurface soil or ground
water or surface water throughout the active life of the un .t;
(2) tha installation of leachate collection and re val system..
and run—oa controls for waste piles and landfills, and the
re val or solidification of wastes and waste residues at closure
for surface impoundments; and (3) the placeaent. of a final cover
(cap) placed on tap to nu nim. ze the percoi. zion of U.quids into
th. unit. EP& is relying prinicipally on c.-ie final cover (cap)
rather than the bottom liner to provide pcst-closure protection
of gr nd water.
imii.a the rsçnlationa contained provis ona for waivers fr
the liner a. leachate eoll.cticn and r.oval requirements, no
-s’zch pra isions were eii.owed for the closure prov sions. The
reasons being that said. froa ground—water protection, the fine].
v.xaJse,. (a) prevents the bathtub effect (i .e., fLIling
vi 1sechat and ov.rilowing)r (b) protection of surface water
1r rua —otf 1 an* (c) discouragement of direct access v.o the waste.
W 74r J s I. to the July 24, 1982, Federal. Register , •Vol. 47
143, pp 32312—32316.
WR—56SX .nt:An4e rson:pm:S2O6 : 382—4654:WSZI:8/2/85

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