United States
           Environmental Protection
           Agency
          Office of
          Solid Waste and
          Emergency Response
     EPA
DIRECTIVE NUMBER: 9523.50-lA
TITLE: post_ciosure Part B Permit Requirements

APPROVAL DATE;. 11/18/86
EFFECTIVE DATE:  11/18/86
ORIGINATING OFFICE: osw
Q FINAL
D DRAFT
 STATUS:

REFERENCE (other documents):
OSWER     OSWER      OSWER
    DIRECTIVE   DIRECTIVE   D

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United States Ertvironmenta Protection Agenc , [ interim rective Num sr
Washington DC 20460 I
‘&EPA OSWER Directive initiation Request q - 2 o - .
Originator Information
Name 01 Contact Person Mail Code Teleorione Numoer
George Faison WH—563 382-2221
Lead Office cus ‘ oorove0 f r Review
0 OERR Signature of Office Director Date
OSW 0 AA.OSWER IA& 1D w - LtQ 4 _. u - - (
Ttle
Post—Closure Part B Permit Requirements
Si rnmary of Directive
Lists the minimum 270.14(b) information which should be
submitted in an application for a post-closure permit.
Type ot ectIve Manual ? oIic’/ O,,ecrive. Announcement. erc) Sc3Ljs
0
Dratt t._.. ‘Jew
Policy Directive 0 Cv’Si0n
Does tn’s Directije Supersede Previous Oirectiveis Yes No Does IC Suoot ment P evicus Di,ec:i eisj J Yes Li °
It Yes to either Question What Directive number (irtel
i eview Phan
0 AA.OSVVER 0 OUST 0 OECM 0 Other Specify)
0 OERR 0 OWPE 0 0CC
0 OSW 0 Regions 0 CPPE
Th , Request Meets OSW€R Directives System Format
S a ure of Lead Offrce Directives Officer Date
A L) 4A a. ._ I 1 iq— .
Oat
Si ofO5WERD i tivesOffice

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
M DV B OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM OSWER Directive *9540.6-lA
SUBJECT: Post—Closure Permit Part B Requirements
FROM: Marcia E. Williams, Directort4 )J/ S
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. Outlined 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 (5270.14):
— A copy of the post—closure inspection schedule (5270.14(b)(5))
— Floodplain information (S270.14(b)(ll)(iii — iv))
— A copy of the post—closure plan (5270.14(b)(l3))
— Documentation of t ie notice in deed or an appropriate
alternative instrument (5270.14)(b)(l4))
— Cost estimate for post—closure and post—closure financial
mechanism (5270.14)(b)(l6))
— A copy of the state financial instrument if appropriate
(5270.14)(b) (18))
— Groundwater data and information demonstrating compliance with
requirements for detection monitoring, compliance monitoring
and corrective action, as applicable (S270.].4 (C))

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—2—
B. New information required by HSWA, including at le st:
— Information on solid waste management units and releases
from those units (S264.lO1; see RSI $3)
— Financial responsibility for corrective action (if applicable)
— For landfills and surface impoundments, exposure information
(S270.1O(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 (5270.14(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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