Post-Closure Part B Permit Requirements.


     &EPA
               United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response

DIRECTIVE NUMBER: 9523.50-lA
TITLE: Post_Ciosure Part B Permit Requirements

   3OVALDATE: n/18/86
EFFECTIVE DATE: n/18/86
ORIGINATING OFFICE: osw
B FINAL
G DRAFT
 STATUS:

REFERENCE (other documents):
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                     OSJVER      OSWER
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Linitea States Environmentat Protection Agency I Interim Directive Num
Washington. DC 20460 I
I 9540--6—3A
&EPA OSWER Directive Initiation Request
ig c- ca -•)1\.
Originator Information
Name of Contact Person
George Faison
Mail Code I Telepnone Nurnoer
WH-563 f 382-2221
Lead Office 0 OUST Approvea for Review
0 OERR OWPE Signature of Office Director Date
OSW 0 AA.OSWER : 3A& 1LY) w LL) LQ .a, I -
title
Post—Closure Part B Permit Requirements
,
Summary of Directive
Lists the minimum 270.14(b) information which should be
submitted in an application for a post-closure permit.
lype at Di’ective (Manual Policy Directive. Announcement, etci Status
0 Drat 0 New
Policy Directive Final 0 Revision
Does mis Directive Supersede Previous Directivets,) Yes No Does It Suppiement Previous Directivet si
If Yes to Either Question. What Directive (number rifle)
No
eview Plan
0 AA .OSwER 0 OUST 0 OECM 0 Other Specily)
0 DEAR 0 OWPE 0 OGC
0 osw 0 Regions 0 OPPE
This Request Meets OSWER Directives System Format
of Lead Office Directives Officer Date
I
t) -4 - i 11 14--
Date
turofOSWEAOirctivesOffice I

I
CPA C. .... . 1qc

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L UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
PR
NOV B OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM OS Directive #9540.6-lA
SUBJECT: Post—Closure Permit Part B Requirements
FROM: Marcia E. Williams,
Office of Solid Waste
TO: Waste Management Division Directors,
Regions I—x
This Office has recently received a number of Inquiries
concerning information requirements for Part B post—closure permit
applications. O.ptlined below is a brief discussion of those
requirements and a list of information elements which should be
included in such applications.
40 CFR 270.14 establishes the information requirements for
RCRA permit applications. Because of the inherent differences
between an operating permit and a permit covering only post—closure
care activities, some of the information requirements for an
operating permit will not be applicable to a permit for the post—
closure care period. Section 270.10(c) gives EPA and States the
authority to determine that an application is complete whenever an
application form and supplemental information are completed to the
satisfaction of the Director. We therefore recommend that the
Director only require information be submitted which is relevant
to post—closure care activities. Relevant information may be
determined on a case—by—case basis. At a minimum, however, it
should include:
A. Pre—HSWA Regulatory Requirements (S270.14):
— A copy of the post—closure Inspection schedule (S270.l4(b)(5))
— Floodplain information (S270.14(b)(ll)(iii — iv))
— A copy of the post—closure plan (S270.14(b)(13))
— Documentation of the notice in deed or an appropriate
alternative instrument (S270.14)(b)(14))
— Cost estimate for post—closure and post—closure financial
mechanism (S270.14)(b)(l6))
— A copy of the state financial instrument If appropriate
(S270.14)(b) (18))
— Groundwater data and information demonstrating compliance with
requirements for detection monitoring, compliance monitoring
and corrective action, as applicable (s270.14 Cc))

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—2—
B. New information required by HSWA, including at least:
— Information on solid waste management units and releases
from those units (S264.]O1; see RSI #3)
— Financial responsibility for corrective action (if applicable)
— For landfills and surface impoundments, exposure information
(S270.].O(j)) (Note that lack of exposure information would
not result in an incomplete application, but would be a
separate violation).
As stated above, this list represents the minimum information
that should be required. In some cases, it may be appropriate to
require additional information depending on the nature of the
facility, waste characteristics and other factors. For example,
if a facility is expected to handle wastes (e.g. leachates)
during the post—closure period which could potentially cause
environmental or public health damage if mismanaged or if acci-
dents were to occur, it may be advisable to require a contingency
plan (S270.14(b)(7).
If you have any further questions, please contact George Faison
at 382—2221.
cc: RCRA Branch Chiefs
Permit Section Chiefs

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