Hazardous Waste Combustion Unit
Permitting Manual
COMPONENTS
How To Review A Part B Permit Application
U.S. EPA Region 6 Center for Combustion
Science and Engineering
Tetra Tech EM Inc.
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COMPONENT THREE
HOW TO REVIEW A PART B PERMIT
APPLICATION
JANUARY 1998
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
CONTENTS (Continued)
Section Page
11.1.5.6 Closure ofWaste Piles 3-159
11.1.5.7 Closure of Surface Impoundments 3-160
11.1.5.8 Closure of Incinerators 3-161
11.1.5.9 Closure of Landfills 3-163
11.1.5.10 Closure of Land Treatment Facilities 3-164
11.1.5.11 Closure of Miscellaneous Units 3-165
11.1.5.12 Closure of Boilers and Industrial Furnaces 3-166
11.1.5.13 Closure of Containment Buildings 3-168
11.2 POST-CLOSURE PLAN/CONTINGENT POST-CLOSURE 3-169
11.3 NOTICES REQUIRED FOR DISPOSAL FACILITIES 3-170
11.4 CLOSURE COST ESTIMATE 3-171
11.5 FINANCIAL ASSURANCE MECHANISM FOR CLOSURE 3-173
11.6 POST-CLOSURE CARE COST ESTIMATE 3-177
11.7 FINANCIAL ASSURANCE MECHANISM FOR POST-CLOSURE CARE ... 3-178
11.8 THIRD-PARTY LIABILITY REQUIREMENTS 3-179
11.9 USE OF STATE-AUTHORIZED MECHANISMS 3-182
12.0 REVIEWING CORRECTIVE ACTION PLANS FOR SOLID WASTE MANAGEMENT
UNITS—SECTION J 3-184
13.0 REVIEWING THE APPLICABILITY OF OTHER FEDERAL LAWS—SECTION K .. 3-185
14.0 REVIEWING THE FACILITY CERTIFICATION—SECTION L 3-188
15.0 PREPARING NOTICE OF DEFICIENCIES 3-190
15.1 THE TIMING 3-191
15.2 THE COMMENTS 3-193
15.3 THE ATTACHMENTS 3-194
15.4 THE MEETING 3-195
16.0 THE COMPLETE PART B PERMIT APPLICATION 3-196
16.1 DRAFT PERMIT OR "NOTICE OF INTENT TO DENY" 3-198
16.2 THE PUBLIC COMMENT PERIOD 3-199
16.3 APPEALS 3-201
17.0 FUTURE CHANGES TO THE PART B APPLICATION 3-202
17.1 CLASS 1 MODIFICATIONS 3-203
17.2 CLASS 2 MODIFICATIONS 3-204
17.3 CLASS 3 MODIFICATIONS 3-205
17.4 TEMPORARY AUTHORIZATION 3-206
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-iv
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
CONTENTS
Section Page
ABBREVIATIONS AND ACRONYMS 3-vi
BIBLIOGRAPHY 3-viii
1.0 INTRODUCTION 3-1
1.1 EXISTING FACILITIES 3-3
1.2 NEW FACILITIES 3-9
1.3 OVERVIEW OF THE PERMITTING PROCESS 3-10
1.4 COORDINATION OF THE APPLICATION SUBMITTAL AND REVIEW
PROCESS 3-15
2.0 REVIEWING THE PART B PERMIT APPLICATION 3-17
2.1 DIVIDING THE APPLICATION 3-19
2.2 SUGGESTED PART B APPLICATION FORMATS 3-21
2.3 TOOLS AVAILABLE TO ASSIST IN THE REVIEW 3-22
2.4 THE COMPLETENESS DETERMINATION 3-23
2.5 THE TECHNICAL ADEQUACY DETERMINATION 3-24
2.6 HANDLING CONFIDENTIAL BUSINESS INFORMATION 3-25
2.7 WASTE MINIMIZATION PLAN REVIEW 3-27
2.8 AVOIDING FUTURE CHANGES TO THE APPLICATION (AND THE
PERMIT) 3-28
2.9 CROSS REFERENCE BETWEEN COMPONENT 3 OF THE PERMITTING
MANUAL AND THE SUGGESTED PART B PERMIT APPLICATION
FORMAT 3-29
2.10 HUMAN HEALTH AND SCREENING LEVEL ECOLOGICAL RISK
ASSESSMENT 3-32
3.0 REVIEWING THE PART A APPLICATION—SECTION A 3-40
4.0 REVIEWING THE FACILITY DESCRIPTION—SECTION B 3-43
4.1 GENERAL DESCRIPTION 3-44
4.2 TOPOGRAPHIC MAP 3-46
4.3 LOCATION INFORMATION 3-49
4.4 TRAFFIC INFORMATION 3-51
5.0 REVIEWING WASTE CHARACTERISTICS—SECTION C 3-52
5.1 CHEMICAL AND PHYSICAL ANALYSES 3-54
5.1.1 Containerized Waste 3-56
5.1.2 Waste in Tank Systems 3-57
5.1.3 Waste in Piles 3-58
5.1.4 LandfilledWastes 3-59
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-i
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
CONTENTS (Continued)
Section Page
5.1.5 Waste in Incinerators 3-60
5.1.6 Wastes to be Land Treated 3-62
5.1.7 Waste in Miscellaneous Treatment Units 3-63
5.1.8 Waste in Boilers and Industrial Furnaces 3-64
5.2 WASTE ANALYSIS PLAN 3-66
5.2.1 Parameters and Rationale 3-68
5.2.2 Test Methods 3-69
5.2.3 Sampling Methods 3-71
5.2.4 Frequency of Analyses 3-73
5.2.5 Additional Requirements for Wastes Generated Off site 3-75
5.2.6 Additional Requirements for Ignitable, Reactive, or Incompatible
Wastes 3-76
5.2.7 Additional Requirements Pertaining to Boiler and Industrial Furnaces 3-77
5.2.8 Additional Requirements Pertaining to Containment Buildings 3-78
5.3 WASTE ANALYSIS REQUIREMENTS PERTAINING TO LAND DISPOSAL
RESTRICTIONS 3-79
6.0 REVIEWING PROCESS INFORMATION—SECTION D 3-81
6.1 REVIEWING INFORMATION REGARDING CONTAINERS—40 CFR
PART 264 SUBPART I 3-86
6.2 REVIEWING INFORMATION REGARDING TANK SYSTEMS—40 CFR
PART 264 SUBPART J 3-88
6.3 REVIEWING INFORMATION REGARDING WASTE PILES—40 CFR
PART 264 SUBPART L 3-90
6.4 REVIEWING INFORMATION REGARDING SURFACE IMPOUNDMENTS—
40 CFR PART 264 SUBPART K 3-91
6.5 REVIEWING INFORMATION REGARDING INCINERATORS—40 CFR
PART 264 SUBPART O 3-92
6.5.1 Justification for Exemption 3-93
6.5.2 Trial Burn 3-94
6.5.3 Data Submitted in Lieu of Trial Burn 3-96
6.6 REVIEWING INFORMATION REGARDING LANDFILLS—40 CFR PART 264
SUBPART N 3-97
6.7 REVIEWING INFORMATION REGARDING LAND TREATMENT—40 CFR
PART 264 SUBPART M 3-98
6.8 REVIEWING INFORMATION REGARDING MISCELLANEOUS UNITS—
40 CFR PART 264 SUBPART X 3-99
6.9 REVIEWING INFORMATION REGARDING BOILER AND INDUSTRIAL
FURNACE UNITS—40 CFR PART 266 SUBPART H 3-101
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
CONTENTS (Continued)
Section
6.10 REVIEWING INFORMATION REGARDING CONTAINMENT BUILDINGS—
40 CFR PART 264 SUBPART DD 3-104
6.11 REVIEWING INFORMATION REGARDING DRIP PADS—40 CFR PART 264
SUBPART W 3-105
6.12 REVIEWING INFORMATION REGARDING AIR EMISSIONS FROM
PROCESS VENTS—40 CFR PART 264 SUBPART AA 3-106
6.13 REVIEWING INFORMATION REGARDING AIR EMISSIONS FROM
EQUIPMENT LEAKS—40 CFR PART 264 SUBPART BB 3-111
6.14 REVIEWING INFORMATION REGARDING AIR EMISSIONS FROM
TANKS, SURFACE IMPOUNDMENTS, AND CONTAINERS—40 CFR
PART 264 SUBPART CC 3-118
6.14.1 Applicability 3-121
6.14.2 Exemptions 3-123
6.14.3 Tank Standards 3-125
6.14.4 Surface Impoundment Standards 3-127
6.14.5 Container Standards 3-128
6.14.6 Closed-Vent Systems and Control Devices Standards 3-130
6.14.7 Inspection and Monitoring Requirements 3-132
6.14.8 Recordkeeping Requirements 3-133
6.14.9 Reporting Requirements 3-134
7.0 REVIEWING GROUND WATER MONITORING SYSTEM INFORMATION-
SECTION E 3-135
8.0 REVIEWING PROCEDURES TO PREVENT HAZARDS—SECTION F 3-136
9.0 REVIEWING CONTINGENCY PLANS—SECTION G 3-139
10.0 REVIEWING PERSONNEL TRAINING RECORDS—SECTION H 3-142
11.0 REVIEWING CLOSURE PLANS, POST-CLOSURE PLANS, AND FINANCIAL
REQUIREMENTS—SECTION I 3-144
11.1 CLOSURE PLANS 3-145
11.1.1 Closure Performance Standards 3-146
11.1.2 Partial Closure and Final Closure Activities 3-148
11.1.3 Maximum Waste Inventory 3-149
11.1.4 Schedule for Closure 3-150
11.1.5 Closure Procedures 3-152
11.1.5.1 Inventory Removal 3-153
11.1.5.2 Disposal or Decontamination of Equipment, Structures,
and Soils 3-154
11.1.5.3 Closure of Disposal Units/Contingent Closures 3-156
11.1.5.4 Closure of Containers 3-157
11.1.5.5 Closure of Tanks 3-158
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-iii
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
CONTENTS (Continued)
EXHIBITS
Exhibit Page
1.1-1 DOCUMENTATION REQUIREMENTS FOR EXISTING AND NEW
FACILITIES WITH NEWLY REGULATED BIFS 3-6
1.3-1 PERMITTING PROCESS TIMELINE 3-12
2.9-1 CROSS REFERENCE BETWEEN COMPONENT 3 OF THE PERMITTING
MANUAL AND THE SUGGESTED PART B PERMIT APPLICATION FORMAT 3-30
2.10-1 INFORMATION NEEDED TO INITIATE HUMAN HEALTH RISK
ASSESSMENT 3-34
2.10-2 INFORMATION NEEDED TO INITIATE SCREENING LEVEL ECOLOGICAL
RISK ASSESSMENT 3-39
4.2-1 XYZ COMPANY TOPOGRAPHIC MAP 3-48
14.0-1 EXAMPLE PART B PERMIT APPLICATION CERTIFICATION 3-189
ATTACHMENTS
Attachment
A EXAMPLE PART B PERMIT APPLICATION FORM
B CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
C PERMIT PROCESS STEPS FOR INTERIM STATUS AND NEW HAZARDOUS WASTE
COMBUSTION FACILITIES
D DRAFT GUIDANCE ON INCINERATOR CLOSURE
E PART A PERMIT APPLICATION
F LOGIC DIAGRAM FOR DETERMINING APPLICABILITY OF SUBPART CC
STANDARDS
G EXAMPLE CLOSURE PLAN AND FINANCIAL REQUIREMENTS
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-v
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
ABBREVIATIONS AND ACRONYMS
ADEM Alabama Department of Environmental Management
APCS Air pollution control system
ASTM American Society for Testing and Materials
AWFCO Automatic waste feed cutoff
BIF Boiler and industrial furnace
Btu British thermal unit
CAA Clean Air Act
CBI Confidential business information
CD Calibration drift
CE Calibration error
CEQ Council on Environmental Quality
CEMS Continuous emissions monitoring system
CFO Chief financial officer
40 CFR Title 40, Code of Federal Regulations
CO Carbon monoxide
COPC Constituent of potential concern
CPA Certified public accountant
CKD Cement kiln dust
CQA Construction quality assurance
CZMA Coastal Zone Management Act
DRE Destruction and removal efficiency
DOT U.S. Department of Transportation
EAB Environmental Appeals Board
ESA Endangered Species Act
ESP Electrostatic precipitator
FR Federal Register
FWCA Fish and Wildlife Coordination Act
FWS U.S. Fish and Wildlife Service
GC Gas chromatography
H2S Hydrogen sulfide
FiHRA Human health risk assessment
HRA Hourly rolling average
HSWA Hazardous and Solid Waste Amendments
HWDF Hazardous waste derived fuel
HWM Hazardous waste management
HWMU Hazardous waste management unit
IS Interim status
KDHE Kansas Department of Health and Environment
km Kilometer
kPa KiloPascals
LDR Land disposal restrictions
MACT Maximum Achievable Control Technology
MDL Method detection limit
m3 Cubic meters
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
ABBREVIATIONS AND ACRONYMS (Continued)
NHPA National Historic Preservation Act
NOD Notice of deficiency
ORD Office of Research and Development
OSW Office of Solid Waste
OSWER Office of Solid Waste and Emergency Response
O2 Oxygen
PAH Polynuclear aromatic hydrocarbon
PCB Polychlorinated biphenyl
PCDD/PCDF Polychlorinated dibenzo-p-dioxin/polychlorinated dibenzofuran
PIC Product of incomplete combustion
POHC Principal organic hazardous constituent
ppmv Parts per million by volume
ppmw Parts per million by weight
PST Performance specification test
QA/QC Quality assurance/quality control
QAPP Quality assurance project plan
RAWP Risk assessment work plan
RCRA Resource Conservation and Recovery Act
RFI RCRA facility investigation
SIC Standard industrial classification
SLERA Screening level ecological risk assessment
SOP Standard operating procedure
SQL Sample quantitation limit
SVOC Semivolatile organic compound
SWMU Solid waste management unit
TBP Trial burn plan
TBR Trial burn report
TNRCC Texas Natural Resources Conservation Commission
TSDF Treatment, storage, and disposal facility
UTM Universal Transverse Mercator
USGS U.S. Geological Survey
U.S.C. United States Code
U.S. EPA U.S. Environmental Protection Agency
VOC Volatile organic compound
WAP Waste analysis plan
WSRA Wild and Scenic Rivers Act
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
BIBLIOGRAPHY
A.T. Kearney, Inc. 1983. "Permit Writer's Guidance Manual (For Treatment and Storage in Tanks and
Containers)." Alexandria, Virginia.
PRC Environmental Management, Inc. (PRC). 1995. "Resource Conservation and Recovery Act
(RCRA) Closure and Post-closure Care Cost Estimating Methodology." Sponsored by U.S.
EPA Region 4. Atlanta, Georgia.
Tetra Tech EM Inc. 1997. "CostPro RCRA Closure and Post-closure Care Cost Estimating Software -
Version 3.0." Sponsored by U.S. EPA Region 4. Atlanta, Georgia.
U.S. Environmental Protection Agency (EPA). 1980. "RCRA Personnel Training Guidance Manual for
Owners or Operators of Hazardous Waste Management Facilities." Accession No. 2362. Call
Number PB87-193348. September 1.
U.S. EPA. 1981. "Financial Requirements (40 CFR Parts 264 and 265, Subpart H); Standards
Applicable to Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal
Facilities (TSDF) Under RCRA, Subtitle C, Section 3004." Office of Solid Waste and
Emergency Response (OSWER). Washington, B.C. January 15.
U.S. EPA. 1982. "Facilities Storing Hazardous Waste in Containers: Guidance for Permit Writers."
Office of Solid Waste (OSW) PB88-105689.
U.S. EPA. 1982. "Financial Assurance for Closure and Post-closure Care: Requirements for Owners
and Operators of Hazardous Waste TSDFs, A Guidance Manual." OSWER. Washington,
D.C. May 15.
U.S. EPA. 1982. "Liability Coverage; Requirements for Owners and Operators of Hazardous Waste
TSDFs; A Guidance Manual." OSWER. Washington, D.C. November 15.
U.S. EPA. 1983. "Guidance Manual for Hazardous Waste Incineration Permits." OSWER.
Washington, D.C. EPA/SW-966. July.
U.S. EPA. 1983. "Permit Applicants' Guidance Manual for the General Facility Standards of 40 CFR
Part 264." SW-968. October.
U.S. EPA. 1984. "Financial Requirements; Interim Status Standards (40 CFR Part 265 Subpart H);
Final Draft Guidance." OSWER. Washington D.C. January 15.
U.S. EPA. 1984. "Permitting of Hazardous Waste Treatment/Storage Tanks." OSWER 9483.01(84).
February 23.
U.S. EPA. 1986. "Background Document - Final Rule, Closure/Post-closure and Financial
Responsibility Requirements, Hazardous Waste TSDFs." OSWER. Washington, D.C. April.
U.S. EPA. 1986. "RCRA Groundwater Monitoring Technical Enforcement Guidance Document."
OSWER 9950.1. September 9.
U.S. EPA. 1986. "RCRA Facility Assessment Guidance." OSWER. 9502.00-05. October 9.
U.S. EPA Region 6
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
BIBLIOGRAPHY (Continued)
U.S. EPA. 1986. "Guidance Manual: Cost Estimates for Closure and Post-Closure Plans (Subparts G
and H)." OSWER. Policy Directive No. 9476.00-6. November.
U.S. EPA. 1986. "Final RCRA Comprehensive Ground-Water Monitoring Evaluation (CME)
Guidance Document." OSWER 9950.2. December 19.
U.S. EPA. 1986. "Environmental Protection Agency: Hazardous Waste Management System:
Standards for Owners and Operators of Miscellaneous Units." OSW 375. December.
U.S. EPA. 1987. "RCRA Facility Investigation (RFI) Guidance." OSWER 9502.00-06C. July 1.
U.S. EPA. 1987. "Hazardous Waste Miscellaneous Unit Standards: Applicable to Owners and
Operators." OSW 2534. December 10.
U.S. EPA. 1988. "Hazardous Waste Incineration: Questions and Answers." OSW. EPA/530-SW-88-
018. April.
U.S. EPA. 1988. "The EPA Manual for Waste Minimization Opportunity Assessments." Hazardous
Waste Engineering Research Laboratory. EPA 600/2-88/025. April.
U.S. EPA. 1988. "Permitting Hazardous Waste Incinerators." EPA/530-SW-88-024. April.
U.S. EPA. 1988. "Executive Summary: RCRA Ground Water Monitoring Technical Enforcement
Guidance Document." OSWER 9950.1-A. July 11.
U.S. EPA. 1988. "Model RCRA Permit for Hazardous Waste Management Facilities." OSWER.
Washington, D.C. EPA/530-SW-90-049. September.
U.S. EPA. 1988. "RCRA Permit Quality Protocol." OSWER. Washington, D.C. EPA/530-SW-90-
050. September.
U.S. EPA. 1988. "Final Rule on Modifying RCRA Permits." 53 Federal Register (FR) 37935.
September 28.
U.S. EPA. 1988. "Guidance for Conducting Remedial Investigation and Feasibility Studies Under
CERCLA." Office of Emergency and Remedial Response. Washington, D.C. October.
U.S. EPA. 1989. "Handbook: Guidance on Setting Permit Conditions and Reporting Trial Burn
Results." Office of Research and Development (ORD). Washington D.C. EPA/625/6-89/019.
January.
U.S. EPA. 1989. "Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods." EPA
SW-846. OSWER. Washington D.C. March.
U.S. EPA. 1989. "Statistical Analysis of Ground-Water Monitoring Data at RCRA Facilities: Interim
Final Guidance." EPA 8909-0036. April 1.
U.S. EPA. 1989. "Handbook: Hazardous Waste Incineration Measurement Guidance Manual."
OSWER. Washington, D.C. EPA/625/6-89/021. June.
U.S. EPA. 1989. "Modifying RCRA Permits." OSWER. Washington, D.C. September.
U.S. EPA Region 6
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
BIBLIOGRAPHY (Continued)
U.S. EPA. 1990. "Handbook: Quality Assurance/Quality Control Procedures for Hazardous Waste
Incineration." Center for Environmental Research Information. Cincinnati, Ohio. EPA/625/6-
89/023. January.
U.S. EPA. 1990. "Preamble to the RCRA Subparts AA and BB Final Rules." 55 FR 25494.
Washington, B.C. June 21.
U.S. EPA. 1991. "Burning of Hazardous Waste in BIFs: Final Rule." 56 FR 7134. February 21.
U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF Regulations." OSWER
Washington D.C. EPA-530-R-92-011. March.
U.S. EPA. 1992. "RCRA Ground-Water Monitoring: Draft Technical Guidance." PB93-139350.
November.
U.S. EPA. 1993. "Strategy for Combustion of Hazardous Waste." May.
U.S. EPA. 1993. "Waste Minimization Program in Place." OSWER. May.
U.S. EPA. 1993. "RCRA Public Involvement Manual." OSW. Washington, D.C. EPA/530-R-93-
006. September.
U.S. EPA. 1993. "Completeness/Technical Adequacy Evaluation Checklist." Revision 8. OSWER.
Washington D.C. December.
U.S. EPA. 1993. "RCRA Part B Permit Application Checklist Canned Comments." Revisions.
OSWER. Washington, D.C. December.
U.S. EPA. 1994. "Exposure Assessment Guidance for RCRA Hazardous Waste Combustion
Facilities, Attachment B Guidance on Trial Burns." OSWER. Washington, D.C. April.
U.S. EPA. 1994. "Waste Analysis at Facilities That Generate, Treat, and Dispose of Hazardous
Waste." OSWER. Washington D.C. No. 9938.4-03. April.
U.S. EPA. 1994. "Draft RCRA Waste Minimization Plan." OSWER. Washington, D.C. May.
U.S. EPA. 1994. "Memorandum on Trial Burns." OSWER. Washington, D.C. EPA/530-F-94-023.
July.
U.S. EPA. 1994. "Waste Analysis Guidance for Facilities That Burn Hazardous Wastes." Draft.
Enforcement and Compliance Assurance (ECA). Washington D.C. EPA 530-R-94-019.
October.
U.S. EPA. 1994. "Environmental Fact Sheet - EPA Announces Strategy for Hazardous Waste
Minimization and Combustion." OSWER. EPA/530-F-94-027. November.
U.S. EPA. 1994. "Permit Process Steps: For Interim Status Hazardous Waste Combustion Facilities
and for New Hazardous Waste Combustion Facilities." OSWER. Washington, D.C.
EPA/530-F-94-036. November.
U.S. EPA Region 6
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
BIBLIOGRAPHY (Continued)
U.S. EPA. 1994. "Update on Implementation of the Hazardous Waste Minimization and Combustion
Strategy." OSWER. EPA/530-F-94-037. November.
U.S. EPA. 1994. "Preamble to the RCRA Subpart CC Final Rule." 59 FR 62896. Washington, D.C.
December 6.
U.S. EPA. 1995. "TSCA Confidential Business Information Security Manual." Office of Pollution
Prevention and Toxics. Washington, D.C. April.
U.S. EPA. 1995. " RCRA Ground-Water Monitoring Enforcement Guidance." EPA 8708-0003.
August 1.
U.S. EPA. 1995. "RCRA Expanded Public Participation and Revisions to Combustion Permitting
Procedures: Final Rule." 60 FR 63433. December 11.
U.S. EPA. 1996. "Preamble to the RCRA Subpart CC Final Rule." 61 FR 59932. Washington, D.C.
November 25.
U.S. EPA. 1996. "Regulatory Completeness Checklist for Hazardous Waste Treatment, Storage, and
Disposal Facilities, Subpart AA Process Vents - Module D-10." Draft. OSWER. Washington,
D.C.
U.S. EPA. 1996. "Regulatory Completeness Checklist for Hazardous Waste Treatment, Storage, and
Disposal Facilities, Subpart BB Equipment Leaks - Module D-ll." Draft. OSWER.
Washington, D.C.
U.S. EPA. 1996. "Regulatory Completeness Checklist for Hazardous Waste Storage, Treatment, and
Disposal Facilities, Subpart CC Air Emission Standards - Module D-12." Draft. OSWER.
Washington, D.C.
U.S. EPA. 1996. "Subpart CC Inspection Procedures and Checklists." Draft. U.S. EPA Region 4.
Atlanta, Georgia. December 20.
U.S. EPA. 1996. "Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods." SW-846,
Third Edition. December.
U.S. EPA. 1997. "Generic Quality Assurance Project Plan (QAPP)." Center for Combustion Science
and Engineering, Multimedia Planning and Permitting Division, U.S. EPA Region 6. Dallas,
Texas. December.
U.S. EPA. 1997. "Generic Trial Burn Plan (TBP)." Center for Combustion Science and Engineering,
Multimedia Planning and Permitting Division, U.S. EPA Region 6. Dallas, Texas. December.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous Waste Combustion
Facilities." Center for Combustion Science and Engineering, Multimedia Planning and
Permitting Division, U.S. EPA Region 6. Dallas, Texas. EPA-R6-098-002. January.
U.S. EPA. 1998. "Protocol for Screening Level Ecological Risk Assessment at Hazardous Waste
Combustion Facilities." Center for Combustion Science and Engineering, Multimedia Planning
and Permitting Division, U.S. EPA Region 6. Dallas, Texas. EPA-R6-098-003. January.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
BIBLIOGRAPHY (Continued)
U.S. EPA Region 6
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
1.0 INTRODUCTION
Regulations:
Title 40 Code of Federal Regulations (CFR) Parts 124 and 270
40 CFR Part 270 Subpart B
40 CFR Part 270.62
40 CFR Part 270.66
Guidance:
Explanation:
No specific references are applicable to this section of the manual.
Owners or operators of combustion units (such as incinerators or boilers and
industrial furnaces [BIF]) that burn hazardous waste must obtain an operating
permit from the appropriate regulatory agency: the U.S. Environmental Protection
Agency (EPA) Regional Office or, if authorization has been obtained, a state
agency. U.S. EPA has established specific regulations and procedures in 40 CFR
Parts 124 and 270 that govern the content of permit applications, as well as the
review, approval, and issuance of permits or permit modifications. An example
Part B permit application is included as Attachment A.
In general, the permitting process includes the following basic steps: submittal of
the permit application; completeness review using checklist; submission of "Notice
of Deficiencies" (NOD) to applicant; preparation of a draft permit; public
comment period; and issuance of final permit decision.
For hazardous waste combustion units, the permitting process also requires a trial
burn. A trial burn is a test to determine whether the unit can meet performance
requirements specified by the regulations. Other data, such as data required to
complete human health and screening level ecological risk assessments, that the
permitting authority deems necessary can also be collected to ensure the facility
can be operated in a manner that is protective of human health and the
environment.
Procedures differ for permitting "new facilities" versus "existing facilities." A
detailed explanation of permitting procedures and definitions of existing and new
facilities located in Sections 1.1, 1.2, and 1.3. In general, the differences between
these procedures are the points at which (1) the trial burn and risk assessment fit
into the overall permitting procedure, and (2) the permit writer must evaluate the
trial burn and risk assessment information.
For the purpose of determining feasibility of compliance with performance
standards and operating conditions, the permitting authority must establish
conditions in the permit for the combustion unit. Applicants must propose a trial
burn plan (TBP) that, at a minimum, includes an analysis of each waste stream, a
detailed engineering description of the combustion unit, the collection of data
adequate to complete the risk assessment process, and various other items
specifically described in the CFR or state regulations. When reviewing the TBP
for adequacy, the permit writer should refer to Component 1—How to Review a
Trial Burn Plan.
U.S. EPA Region 6
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Check For: The permit review team should check to ensure that the following information is
available:
• Completeness review checklist items
Technical adequacy checklist items
Specific elements required by regulations
Example Situation: Not applicable to this section of the manual.
Example Action: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
1.1
EXISTING FACILITIES
Regulations:
Guidance:
Explanation:
40CFRPart270.10(e)(4)
40 CFR Parts 260.10 and 270.2
40 CFR Part 266.103(a)(l)(ii)
U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." OSWER. Washington, D.C. EPA 530-R-92-011. March.
Section 10.1.1 and Table 10-1.
Existing combustion units operating under interim status (IS) must either (1)
submit a permit application when requested by the permitting authority, or (2)
voluntarily submit the permit application before the permitting authority calls for a
permit. RCRA regulations do not require the permitting authority to immediately
review an application, should a facility submit a permit application voluntarily.
To expedite the review process, the permitting authority may require that the TBP
and RAWP be submitted before the remainder of the Part B permit application.
For BIF facilities, the permit scheduling requirements are presented in
Exhibit 1.1-1.
Existing facilities are combustion units that were "in existence" at the time of
statutory or regulatory changes that subjected them to RCRA. Such facilities are
considered to be operating under IS. Unless subject to statutory permitting
deadlines, regulatory agencies will call in permit applications for existing facilities
(that is, notify the facility owner or operator that the Part B must be submitted).
The procedures for calling in the Part B vary among permitting authorities.
BIFs may have been "in existence" on the date of the final BIF rule (February 21,
1991) in three cases, and therefore are defined as existing facilities:
• Newly regulated facilities (that is, facilities that became regulated as a
result of the final BIF rulemaking [February 21, 1991, 56 FR 7186]
and notified of hazardous waste activity and submitted a Part A
permit application)
IS facilities that contain BIFs newly regulated by the final BIF
rulemaking (such facilities must have submitted an amended RCRA
Part A application)
Permitted facilities with BIFs that were newly regulated by the final
BIF rulemaking (such facilities must have submitted a permit
modification to U.S. EPA or the state under 40 CFR Part 270.42 or
similar authorities).
Because existing facilities already are operating, the permit application for those
facilities need not include conditions for initial startup and shakedown. For BIFs,
the trial burn may be waived only if certain requirements are met [see 40 CFR
Part 270.22(a)]). However, U.S. EPA Region 6 currently requires all new and
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-3
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
existing combustion units to conduct a risk burn even if a trial burn may be
waived according to regulation. The decision to approve or deny a permit for
existing facilities is made after trial burn results and risk burn results have been
submitted and evaluated.
Check For:
Example Section:
The permit writer should check for the following:
Facility's status with regard to other IS or RCRA-permitted units
BIFs that applied for or received an incinerator permit
Compliance with IS requirements
All RCRA hazardous waste management units (HWMU) that exist on the site,
whether operating under IS or fully permitted, must be identified. If a hazardous
waste unit is undergoing a permit modification, all components to be modified
must be identified. These issues help to determine when the revised Part A or
Part B permit application must be submitted to the regulatory authority. If the
facility's units are fully permitted, the facility permit must be modified to include
the combustion unit if it is being constructed or modified. Also, information on
existing units such as tanks, container processing areas, container storage areas,
and other related units must be re-evaluated to ensure (1) that the units meet
current regulations, and (2) the information presented is adequate to complete the
risk assessment process. For example, assume a facility permit modification is
being requested for a scrubber upgrade. It would be appropriate at this time to
review facility compliance with recent tank vent regulations under RCRA Subpart
CC.
If a BIF is currently undergoing review for an incinerator permit, U.S. EPA can
decide whether the unit will be permitted under RCRA as a BIF or an incinerator.
If U.S. EPA decides that the unit will be permitted as an incinerator, conditions
should be added to the permit to ensure that the unit complies with the
requirements applicable to BIFs. When deciding whether to continue with the
incinerator permit or change to a BIF permit, U.S. EPA might consider the
following:
Technical changes required to bring the incinerator permit up to BIF
permit requirements (for example, if little or no changes are required,
the incinerator permit would be preferable. If many technical changes
are required, it may be better to permit the unit as a BIF).
• Schedule impact
• Facility needs (for example, the facility may need the permit in the
near future to be able to dispose of a waste on site)
The decision to continue to permit as an incinerator or as a BIF should be
discussed among the permitting agencies, facility, and any other involved groups.
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-4
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
If the facility contains a BIF that is already operating under an incinerator permit,
it may continue to do so until the permit expires, is renewed, or is reopened. At
that time, the unit should be permitted as a BIF. See Exhibit 1.1-1 (page 3-6) for
examples of existing and new facilities permit review processes. Section 10.1.1 of
the "Technical Implementation Document for U.S. EPA's BIF Regulations" (EPA
1992) discusses permitting issues.
An IS facility will be required to submit all the necessary documents to fulfill the
RCRA Part B permit trial burn planning process and site-specific human health
and ecological risk assessments. During review of these documents, inadequacies
may appear. In this case, the permitting agency or the state can take enforcement
action depending on the severity of the inadequacy and the facility's past
compliance record. Any inadequacies, such as design data, that affect the Part B
permit application are usually addressed through an NOD.
Example Comments:
Inadequacies in the Part B permit application occur when an IS facility does not
have as-built drawings or construction upgrades. NODs usually accommodate
these issues without incurring unnecessary delays or excessive costs. The NOD
usually can be rectified if the facility provides additional information, especially if
it is an older facility that was in operation before 1980.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-5
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 1.1-1
DOCUMENTATION REQUIREMENTS FOR EXISTING AND NEW FACILITIES WITH NEWLY REGULATED BIFS
Documentation
30 10 Notification
(EPA Form 8700-12)
Part A Permit
Application
(EPA Form 8700-23)
Precompliance
Certification
Compliance
Certification
Existing Facilities
Not Previously Subject to
Interim Status or Permit
Requirements with BIF
Subject to RCRA
Regulations for First Time
Submit to U.S. EPA by May
22, 1991, if facility was
handling hazardous waste
fuel on February 21, 1991,
if not previously submitted
Submit to U.S. EPA by
August 21, 1991
Submit to U.S. EPA by
August 21, 1991
Submit to U.S. EPA by
August 21, 1992 or as
extended
Interim Status RCRA
Facility3 with Newly
Regulated BIF
Should have been
submitted to U.S. EPA
before initiation of
hazardous waste
activity
Submit revised Part A
to U.S. EPA by
August 2 1,1 991
Submit to U.S. EPA by
August 21, 1991
Submit to U.S. EPA by
August 21, 1992 or as
extended
Permitted RCRA
Facility" with Newly
Regulated BIF
Should have been
submitted to U.S.
EPA before initiation
of hazardous waste
activity
Submit Class 1
modification (e.g.,
could be a revised
Part A) to U.S. EPA
by August 2 1,1 991
Submit to U.S. EPA
by August 21, 1991
Submit to U.S. EPA
by August 2 1,1 992 or
as extended, unless
permit modification
issued by that date
Facility with Permitted
and Interim Status RCRA
Units0 on Site and with
Newly Regulated BIF
Should have been submitted
to U.S. EPA before
initiation of hazardous
waste activity
Submit revised Part A or
Class 1 modification to U.S.
EPA by August 21, 1991
Submit to U.S. EPA by
August 21, 1991
Submit to U.S. EPA by
August 21, 1992 or as
extended, unless permit
modification issued by that
date
Facility with BIF Unit Under
RCRA Incinerator Standards
Should have been submitted to
U.S. EPA before initiation of
hazardous waste activity
If BIF was operating under
interim status incinerator
standards or if BIF was not
allowed by U.S. EPA to
continue permit review process,
submit revised Part A to U.S.
EPA by August 21, 1991
If BIF was operating under
interim status incinerator
standards or if BIF was not
allowed by U.S. EPA to
continue permit review process,
submit to U.S. EPA by August
21, 1991
If BIF was operating under
interim status incinerator
standards and/or if BIF not
allowed by U.S. EPA to
continue permit review process,
submit to U.S. EPA by August
21, 1992 or as extended
New Facility
Not applicable4
Submit to U.S.
EPA as part of
RCRA permit
application
Not applicable
Not applicable
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-6
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 1.1-1 (Continued)
DOCUMENTATION REQUIREMENTS FOR EXISTING AND NEW FACILITIES WITH NEWLY REGULATED BIFS
Documentation
Part B Permit
Application6
Public Notification
by Applicant of
Request for Permit
Modification
Published in Local
Newspaper
Existing Facilities
Not Previously Subject to
Interim Status or Permit
Requirements with BIF
Subject to RCRA
Regulations for First Time
When requested by U.S.
EPA, submit by date set
(which will be at least 6
months after request)
Not applicable
Interim Status RCRA
Facility" with Newly
Regulated BIF
When requested by
U.S. EPA, submit by
date set (which will be
at least 6 months after
request)
Not applicable
Permitted RCRA
Facility15 with Newly
Regulated BIF
Submit Class 3
modification to U.S.
EPA by February 17,
1992
Not applicable for
Class 1 modification;
publish within 7 days
before or after
submittal of Class 3
modification
Facility with Permitted
and Interim Status RCRA
Units0 on Site and with
Newly Regulated BIF
If revised Part A submitted
on August 21, 1991, submit
Part B by date set by
Agency (which will be at
least 6 months after U.S.
EPA request); if Class 1
modification submitted by
August 21, 1991, submit
Class 3 modification to U.S.
EPA by August 17, 1992
Not applicable unless
facility submits Class 3
modification in which case
within 7 days before or after
submittal of Class 3
modification
Facility with BIF Unit Under
RCRA Incinerator Standards
If revised Part A submitted on
August 21,1991, submit Part B
by date set by Agency (which
will be at least 6 months after
U.S. EPA request); if facility in
process of obtaining incinerator
permit, continue process if U.S.
EPA allows; if facility operates
under incinerator permit,
continue operation until permit
is reopened or expires, then
submit BIF permit application
Not applicable unless facility
submits Class 3 modification in
which case within 7 days before
or after submittal of Class 3
modification
New Facility
Submit to U.S.
EPA at least
180 days before
physical
construction
expected to
begin
Not applicable
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-7
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 1.1-1 (Continued)
DOCUMENTATION REQUIREMENTS FOR EXISTING AND NEW FACILITIES WITH NEWLY REGULATED BIFS
Documentation
Notification sent by
applicant to parties
on facility mailing
list
Public meeting held
by applicant
Existing Facilities
Not Previously Subject to
Interim Status or Permit
Requirements with BIF
Subject to RCRA
Regulations for First Time
Not applicable
Not applicable
Interim Status RCRA
Facility3 with Newly
Regulated BIF
Not applicable
Not applicable
Permitted RCRA
Facility with Newly
Regulated BIF
Within 90 days after
Class 1 modification
is effective; within 7
days before or after
submittal of Class 3
modification
For Class 3
modifications, no later
than 15 days before
close of 60-day
comment period
Facility with Permitted
and Interim Status RCRA
Units0 on Site and with
Newly Regulated BIF
Same as public notification
For Class 3 modifications,
no later than 15 days before
close of 60-day comment
period
Facility with BIF Unit Under
RCRA Incinerator Standards
Not applicable
Not applicable
New Facility
Not applicable
Not applicable
Source: U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF Regulations." OSWER. Washington, B.C. EPA-530-R-92-011. March. Table 10-1, pages 10-2 through
10-4.
a Facility has interim status units that are not BIFs (e.g., storage tanks, thermal treatment units)
b Facility has permitted units that are not BIFs (e.g., storage tanks, thermal treatment units)
c Facility has interim status and permitted units on site that are not BIFs (e.g., storage tanks, thermal treatment units)
d Facility is still required to file for a U.S. EPA identification number
Includes TBP and RAWP
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-8
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
1.2 NEW FACILITIES
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 260.10
U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." OSWER. Washington, D.C. EPA 530-R-92-011. March.
Section 10.1.1 and Table 10-1.
RCRA specifies that new facilities are not allowed to be constructed or to operate
without a permit. Therefore, the regulatory agency must issue a permit before
construction begins. Under 40 CFR Parts 270.62 (incinerators) and 270.66
(BIFs), permitting requirements specify that the permit conditions must limit
operations for new facilities after construction. Specifically, the regulations
discuss three distinct phases of operation after construction is completed but
before the final permit is issued: the startup and shakedown period (pretrial burn
period); trial burn period; and post-trial burn period. Assuming the trial burn was
successful, permit conditions are modified, if necessary, and the facility proceeds
to operate under the final permit, the fourth phase of the process, see Component
7—How to Prepare Permit Conditions.
The permit reviewer should check for the following:
Determine if a BIF is considered a "new facility" or "existing facility" by
reviewing the February 21, 1991, Federal Register (56 FR 7186) to
determine if the facility was "in existence"
For a currently nonregulated incinerator, determine if waste streams are
newly identified as hazardous waste, thereby causing the unit to be a
"new" facility
The U.S. Army is currently constructing a series of hazardous waste combustion
units to destroy obsolete chemical weapons at the Anniston Army Depot in
Anniston, Alabama. Before beginning construction of these units, a permit for the
facility was issued by the Alabama Department of Environmental Management
(ADEM).
Concurrent with final planning and design activities, the U.S. Army submitted a
complete RCRA Part B permit application for the chemical weapons destruction
facility—before beginning construction activities. This application included a
TBP, RAWP, and trial burn quality assurance project plan (QAPP). The permit
application was reviewed several times, and the facility completed the permitting
process (including the public participation process, see Component 7—How to
Prepare Permit Conditions). ADEM subsequently issued a permit prior to
construction; the permit will be modified based on the results of the trial burn.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-9
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-10
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
1.3
OVERVIEW OF THE PERMITTING PROCESS
Regulations:
40 CFR Parts 124 and 270
40 CFR Part 270.62
40 CFR Part 270.66
Guidance:
Explanation:
Check For:
No specific references are applicable to this section of the manual.
The permitting process for a combustion unit occurs in one of two sequences,
either: (1) for an IS unit, or (2) for a new unit. These sequences are shown in
Exhibit 1.3-1, see pages 3-12 through 3-14.
As illustrated in the two sequences, the major difference between the permitting
process for an interim status unit and a new unit is that the trial burn for an
interim status unit is conducted before the draft permit is prepared, whereas for a
new unit, the draft permit is prepared before the trial burn and before construction
for the new unit can begin. Sections 1.1 and 1.2 of this component address
specific issues regarding interim status unit and new unit permitting.
The timelines provided above incorporate regulations promulgated under the
RCRA Expanded Public Participation Rule, 60 FR 63417, December 11, 1995.
The rule focuses on four goals:
Involve the public earlier in the permitting process
• Provide more opportunities for public participation
Expand public access to information
• Offer guidance to improve public participation
Some of the new requirements stipulated in the rule include:
• Applicant must hold an informal public meeting before applying for a
permit
• Agency must send a notice to everyone on the facility mailing list
announcing that the application has been submitted
• Agency may require the facility to establish an information repository
Agency must notify the public prior to a trial burn by sending a notice
to everyone on the facility mailing list
The rule applies to facilities seeking a RCRA permit and RCRA permit renewals
with a significant change. A state permitting agency can implement the rule as
long as it has RCRA authority and has adopted the rule as state legislation.
Otherwise, the U.S. EPA Regional offices will administer the rule.
• Ensure the facility mailing list is comprehensive and includes all
appropriate neighboring citizens, businesses, and industry
Confirm that the repository location is appropriate and accessible
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-11
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Consider attending any community or public meeting coordinated by the
facility or local citizens groups
Example Situation: The Kansas Department of Health and Environment (KDHE) received a permit
application for the Ash Grove Cement in Chanute, Kansas, on May 31, 1995. The
following is a list of steps KDHE and Ash Grove Cement completed during the
permitting process:
• U.S. EPA review of permit application—June to October 1995
• Trial burn test—April 1994
• Draft permit issued— 1995
• Public comment period—1995
• Public hearings—1995
Example Action: KDHE issued the final permit for tanks and containers on August 5, 1996, and the
final permit for the cement kilns was issued by U.S. EPA Region 7 on August 15,
1996.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-12
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 1.3-1
PERMITTING PROCESS TIMELINE
Permitting Activity
Responsible Organization
Permitting
Agency
Facility
Any
Concerned
Group or
Individual
Approximate Timeline
INTERIM STATUS UNITS
Conduct pre-application meeting
Submit Part A and Part B applications
(including TBP) and RAWP
Provide notice of receipt of application
Review the application and RAWP
Establish and maintain an information
repository
Provide notice of trial bum
Conduct the trial burn
Prepare TBR
Review TBR and risk assessment
results
Prepare draft permit determination
Request public comment/hearing
Decide permit fate: deny or approve
File permit appeal
Seek judicial appeal
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Some time prior to submittal of
application
Day 0
Day 1
Day 1 through Day 120
(average 4 months)
Approximately Day 30, update
information throughout the
active life of the project
Approximately 30 days before
the trial burn
Day 120 through Day 130
(conservative 10 day estimate)
Day 130 through Day 220 (90
days allowed by regulation;
extensions may be granted by
permitting authority on a
case-by-case basis)
Day 220 through Day 280
(average 2 months)
Day 280 through Day 310
(average 1 month)
Day 3 10 through Day 370
(average 2 months, a minimum
of 45 days required by
regulation, may last longer if
public hearing process is
prolonged)
Day 370 through Day 400
(average 1 month)
Appeal must be filed within 30
days of permit decision
Once permit appeals process is
completed, judicial review can
begin
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-13
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 1.3-1 (Continued)
PERMITTING PROCESS TIMELINE
Permitting Activity
Responsible Organization
Permitting
Agency
Facility
Any
Concerned
Group or
Individual
Approximate Timeline
NEW UNITS
Conduct pre-application meeting
Submit Part A and Part B application
(including TBP) and RAWP
Provide notice of receipt of application
Review the application and RAWP
Establish and maintain an information
repository
Prepare draft permit determination
Request public comment/hearing
Issue four-phased permit or deny the
permit
File permit appeal
Seek judicial appeal
Operate during start-up/shakedown
period (Phase One)
Provide notice of trial bum
Conduct the trial bum (Phase Two)
Operate during the post-trial burn
period (Phase Three)
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Some time prior to submittal of
application
Day 0
Day 1
Day 1 through Day 300
(average 10 months)
Approximately Day 30, update
information throughout the
active life of the project
Day 300 through Day 360
(average 2 months)
Day 360 through Day 420
(average 2 months; a minimum
of 45 days required by
regulation, may last longer if
public hearing process is
prolonged)
Day 420 through Day 450
(average 1 month)
Appeal must be filed within 30
days of permit decision
Once permit appeals process is
completed, judicial review can
begin
Day 450 through Day 630
(startup averages 3 months;
shakedown can last up to 720
hours, or 3 months; by
regulation, an extension may be
granted on a case-by-case basis)
Approximately 30 days before
the trial burn
Day 630 through Day 640
(conservative 10 day estimate)
Day 640 until the final
operating permit is issued
(approximately 7 months)
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-14
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 1.3-1 (Continued)
PERMITTING PROCESS TIMELINE
Permitting Activity
Responsible Organization
Permitting
Agency
Facility
Any
Concerned
Group or
Individual
Approximate Timeline
NEW UNITS
Prepare TBR
Review TBR and risk assessment
results
Prepare final operating permit (Phase
Four)
•
•
•
•
Day 640 through Day 730 (90
days allowed by regulation;
extensions may be granted by
permitting authority on a case-
by-case basis)
Day 730 through Day 820
(average 3 months)
Day 820 through Day 850
(average 1 month)
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-15
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
1.4
COORDINATION OF THE APPLICATION SUBMITTAL AND REVIEW PROCESS
Regulations:
Guidance:
Explanation:
Check For:
No regulations are applicable to this section of the manual
No specific references are applicable to this section of the manual.
Because the RCRA Part B permit application for any combustion unit is a
complex document, it is highly recommended that a preapplication meeting be
scheduled. Attendees should include: the U.S. EPA Regional lead permit writer
and contractor personnel who will review the application, state and local agency
personnel who will review the application, and facility personnel responsible for
preparing the application. If the application is for an existing facility operating
under IS, the meeting should be scheduled after the permit application has been
called in.
Reviewing the RCRA Part B permit application requires a team effort. A lead
permit writer should be assigned to manage and coordinate all review activities
and formulate the final approval of the application. The lead writer should
identify qualified staff and contractor personnel to evaluate specific portions of the
permit application (see Component 1—How to Review a Trial Burn Plan). The
lead writer should develop the review schedule with critical completion dates and
conduct regular meetings with the teams to discuss progress, problems, and
potential delays, and resolve issues as they arise.
The regulations at 40 CFR Part 270.10 provides for a two-step review process:
(1) a completeness review to determine if all applicable sections have been
submitted, and (2) the detailed technical review. Many regulatory agencies
combine these two steps and do not consider the application complete until it
contains all the information necessary to complete the risk assessment process and
develop draft permit determinations.
It is important to coordinate permit application efforts with the state agency
authorized to issue either all or portions of a RCRA permit or a state Clean Air
Act (CAA) permit.
To coordinate the application submittal and review process, the permit reviewer
should prepare, determine, or establish the following:
Preapplication meeting with agenda as follows:
Design and operation of the combustion unit
• Format of the permit application
• Requirements for the trial burn
• Requirements for the risk assessment
• Whether the facility will use the U.S. EPA Region 6 generic TBP as a
template for the TBP
Recent guidance or policy directives that could affect information
required for the application
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-16
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Relevant issues to expedite the permitting process
• Proposed schedules
• Whether the state agency has RCRA/Hazardous and Solid Waste
Amendments (HSWA) authorization
Whether the authorized agency has the necessary expertise to technically
review the application
• Determine the state agency's proposed review schedule
• Determine which agency ultimately will be responsible for drafting the
permit conditions
• Review process completion time frame
Example Section: Not applicable to this section of the manual
Example Comments: Not applicable to this section of the manual
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-17
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.0
REVIEWING THE PART B PERMIT APPLICATION
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Parts 124 and 270
40 CFR Part 270 Subpart B
40 CFR Part 270.62
40 CFR Part 270.66
No specific references are applicable to this section of the manual.
The review of a RCRA Part B permit application consists of a completeness
review and a technical adequacy determination. The review process can be more
efficient if the applicant uses the proper format for the application, and the
reviewers are aware of special procedures that must be followed during the review
process.
The following subsections describe procedures for reviewing the Part B permit
application, as follows:
Dividing the Application (see Section 2.1)
Suggested Part B Application Formats (see Section 2.2)
Tools Available to Assist in the Review (see Section 2.3)
The Completeness Determination (see Section 2.4)
The Technical Adequacy Determination (see Section 2.5)
Handling Confidential Business Information (see Section 2.6)
• Waste Minimization Plan Review (see Section 2.7)
Avoiding Future Changes to the Application (and the Permit) (see Section
2.8)
• Cross Reference Between Component 3 of the Combustion Manual And
The Suggested Part B Permit Application Format (see Section 2.9)
Human Health and Screening Level Ecological Risk Assessment Data
Requirements (see Section 2.10)
The permit reviewer is responsible for and should complete the following:
• Obtain suggested formats for the Part B permit application
• Obtain tools available to assist in the review
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-17
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Divide the application into manageable sections and forward them to team
members with relevant expertise
• Conduct the completeness determination
• Complete the technical adequacy determination
Example Situation:
Example Comments:
The XYZ Company has submitted what it says is a complete RCRA Part B permit
application for a hazardous waste incinerator with on site ash disposal. The
proposed site is in a rural area of southwestern Alabama; the nearest incorporated
city is 25 miles away, but the facility is 1 mile off a major interstate.
Lois and Clark have been assigned to review the application for completeness and
technical adequacy. Lois will review sections dealing with ash disposal, general
site location, and landfill designs. Clark will review all technical aspects of the
incinerator, scrubber, control room, and associated on site laboratory facilities.
During her review, Lois noted that the landfill construction quality assurance
(CQA) was signed by the company attorney attesting that the plan met or exceeded
all design criteria required for a hazardous waste landfill.
According to 40 CFR Part 264.19(a), only a registered professional engineer can
develop and sign the CQA. Lois wrote an NOD stating that the CQA should be
reviewed and signed by the person who developed it and who will be responsible
for implementing the construction program.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.1
DIVIDING THE APPLICATION
Regulations:
Guidance:
Explanation:
Check For:
No regulations are applicable to this section of the manual
No specific references are applicable to this section of the manual.
In general, it is more efficient to use a multidisciplined team to review a Part B
permit application. A team brings more expertise and skills to the review and
allows the lead permit writer to assign specific sections of the application to
members of the team, expediting the review process. Before the agency receives a
permit application, a permit review team should be assembled.
When the permit application has been received , the lead permit writer should meet
with the review team and divide the application into various sections to expedite
the evaluations of completeness and technical adequacy. In determining how to
divide the application, the lead permit writer should consider whether the
completeness and technical adequacy reviews will be conducted as separate tasks
or concurrently. If a separate completeness check is conducted prior to the
technical adequacy evaluation, junior staffer staff without specific disciplines
may be used. However, if the technical adequacy check occurs concurrently, it
will be necessary to assign sections of the application to staff having appropriate
expertise. In addition, during the division of labor, the lead permit writer should
discuss the type of quality controls to be used to ensure accuracy of the review.
For example, certain staff may be designated to act as internal technical reviewers
for application reviews when they have no direct involvement.
The lead permit writer should record how the application is divided and to whom
the sections are assigned to help track application distribution. The lead permit
writer should encourage and facilitate communication among reviewers, both
directly to the lead permit writer and between team members. Communication will
help resolve issues and staff will be more likely to identify inconsistencies in the
application. In addition, the lead permit writer should hold regular review team
meetings to discuss the progress of the permit application and resolve issues
identified by the team.
The lead permit writer also should provide the team members with Part B
completeness/technical evaluation checklist and completion instructions.
The lead permit writer should:
Meet with the review team on a regular, scheduled basis
Divide application for completeness determination and technical
evaluation reviews
• Designate and record staff review assignments
• Facilitate and promote communication among team members
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Example Section: The XYZ Company submitted a Part B permit application for a hazardous waste
incinerator with an on site landfill for incinerator ash only. The application
contained the following parts:
1. General Facility Standards
2. Preparedness and Prevention
3. Contingency Plan and Emergency Procedures
4. Manifest System, Recordkeeping, and Reporting
5. Closure and Post-Closure
6. Financial Requirements
7. Use and Management of Containers
8. Tank Systems
9. Landfills
10. Incinerators
11. Air Emission Standards for Equipment Leaks
12. Organic Air Emissions Standards for Tanks
Example Comments: While reviewing the CFR, Lois noted that the Part 264 standards include
requirements for releases from solid waste management units (SWMU). Although
the landfill standards are addressed, Lois determined that XYZ should address the
release standard in the application. An NOD was written requesting XYZ
Company to address this subpart of the regulations.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-20
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.2
SUGGESTED PART B APPLICATION FORMATS
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40 CFR Parts 270.13 and 270.14 through 270.27
No specific references are applicable to this section of the manual.
Although there is no required format for a RCRA Part B permit application,
permits that are organized according to a review checklist will generally expedite
the completeness and technical adequacy review process. It is recommended that
the applicant be given or instructed to follow the RCRA Part B Permit Application
Review Checklist (see Attachment B of this component) when preparing the permit
application. This checklist will reduce the time and effort needed to determine if
the application is complete and will simplify locating and cross-referencing
information.
• States may have separate required Part B application formats, which
should be referenced and used as appropriate. (For example, the applicant
should not be required to submit two Part B applications with similar
information, just in different formats.) Attachment A includes the Texas
Natural Resources Conservation Commission (TNRCC) application form.
The XYZ Company submitted a Part B permit application. Lois and Clark were
asked to review and approve the Part B permit. The application was formatted
according to the 1993 RCRA Part B permit application review checklist.
However, information regarding Subparts AA, BB, and CC (air emission
standards for equipment leaks and tanks, containers, and surface impoundments)
and the RAWP were included as attachments to the application. The XYZ
Company explained that since the 1993 checklist did not contain sections for AA,
BB, CC, or the RAWP, the company decided that the information should be
submitted as an attachment to the application rather than as a separate section.
Lois and Clark located the Subpart AA, BB, and CC information and the RAWP
and determined it was complete enough to warrant a technical adequacy review.
However, they also shared with XYZ Company a draft version of a more recent
Part B permit application review checklist to use as reference. They suggested
that the company review and compare the checklist to the Part B permit
application to determine whether the application responds to the information
requirements for Subparts AA, BB, CC, and RAWPs.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.3
TOOLS AVAILABLE TO ASSIST IN THE REVIEW
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40 CFR Parts 124 and 270
No specific references are applicable to this section of the manual.
In addition to the regulations and technical permit writer guidance documents cited
in this manual, several tools are available to assist the permit writer with review
of Part B applications. These tools include:
• The RCRA Part B Permit Application Review Evaluation Checklist
(see Attachment B)
The U.S. EPA 1993 RCRA Part B Permit Application Checklist
Canned Comments, Revision 8
Various federal or state facility inspection checklists
• RAWP informational requirements listing (see Section 2.10)
The permit reviewer should check for the following:
• Confirm that the checklists are current; for example, older checklists may
not include the 1995 Public Participation Rule or the 1996 Subpart CC
rule requirements
• Confirm that all determinations based on the results of the completed
checklist are consistent with the regulations
The XYZ Company submitted a Part B permit application formatted in
accordance with the 1993 RCRA Part B permit application review checklist
Lois and Clark received the application and compared its format against a 1997
review checklist. They found that the 1993 review checklist did not provide as
great a level of detail as the 1997 checklist; however, the checklists were similar.
As a result, Lois and Clark distributed the relevant sections of the 1997 checklist
along with corresponding portions of the application to the appropriate reviewers.
Although the 1997 checklist offers a greater level of detail than the older version,
it should not promote a more or less complete permit application because the
RCRA-required information remains the same. A more recent checklist simply
provides the reviewer with a more comprehensive and more up-to-date tool, but
does not replace the need to review and understand the regulations.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.4 THE COMPLETENESS DETERMINATION
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40 CFR Part 270 Subpart B
40 CFR Part 124
No specific references are applicable to this section of the manual.
The completeness review is the first step to processing the permit application. The
applicant must submit Parts A and B of the permit application and any relevant
supporting data, technical reports, or other documentation. If required information
is missing, the reviewer will send the applicant an NOD.
The reviewer should:
Ensure that team members properly use an up-to-date Part B
Completeness/Technical Evaluation Checklist during the review process.
The checklist is included in Attachment B of this component.
Compare the checklist to current regulations and refer to the regulations to
ensure that all required information is accounted for during the review
• Identify and compile sections of the checklist that are relevant to the
facility's operation
Review inspection reports, previously submitted Part A permit
applications (if applicable), and the RCRA facility assessment (if
available), to ensure that the application addresses all units that are
subject to permitting requirements
• Be aware of any recently promulgated final rules
• Be aware of any proposed rule changes
The XYZ company stated that since the proposed maximum achievable control
technologies (MACT) rule for hazardous waste combustors is not final, none of
those regulations or issues apply to the combustion unit.
Lois and Clark advised XYZ Company to review the MACT rule and be prepared
to address any issues that apply to its facility even though the regulation is only
proposed. Even though the regulation is not promulgated, U.S. EPA may still
impose requirements the agency feels are necessary to protect human health and
the environment. To assist the company, Lois and Clark highlighted portions of
the regulations they determined were potentially applicable to the facility.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.5 THE TECHNICAL ADEQUACY DETERMINATION
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 270 Subpart B
40 CFR Part 124
No specific references are applicable to this section of the manual.
During the technical review, each reviewer will thoroughly analyze the technical
information submitted and determine if the facility has met appropriate
requirements. Various U.S. EPA guidance documents provide specific details for
technical adequacy evaluations and evaluating data supplied by the applicant.
The reviewer should:
• Double-check cross references to other sections of the application to
ensure accuracy
Ensure that the approach offered by the applicant does not simply restate
the regulatory requirement, but provides details on how the requirement
will be achieved and shows that it is consistent with U.S. EPA and state
guidance and policy
• Reference resources or documents used, and document all assumptions
made during the technical adequacy evaluation
Examples of various portions of the Part B permit application appear in
Sections 3.0 through 14.0 of this component.
Example Comments: Examples of various technical adequacy review comments on the Part B permit
application appear in Sections 3.0 through 14.0 of this component.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.6
HANDLING CONFIDENTIAL BUSINESS INFORMATION
Regulations:
40 CFR Part 2 Subpart B
RCRA42U.S.C. 6901
Guidance:
Explanation:
No specific references are applicable to this section of the manual.
Permit applicants may identify specific process or other information in the
application as "confidential business information" (CBI). Claims will be
evaluated by the lead permit writer to determine if they are valid. Procedures are
identified by the regulations established in 40 CFR Part 2 Subpart B. Information
deemed CBI must be handled in accordance with U.S. EPA or state policies and
site-specific protocols to prevent its disclosure to unauthorized recipients.
Offices will usually designate certain secure storage areas for maintaining CBI
data. Contractors and subcontractors must have programs in place and provide
documentation of such programs to properly manage CBI. CBI may be reviewed
only by staff who have appropriate approval.
However, when the facility appears to have claimed as CBI a majority of the
technical information contained in the application, the permit writer should explain
to the facility the following issues:
Large sections claimed as CBI inhibit timely review because only
authorized personnel can review the material; the reviewer must
work behind closed doors, and only limited personnel can share the
information and provide technical assistance
• Claiming large sections of the application as CBI can create the
perception of secrecy which may cause distrust by the community
Some of the material claimed as CBI may already be publicly
available as manufacturer or vendor data, so that the CBI claim will
not prevent disclosure
• Similar material for similar facilities may have been claimed as non-
CBI
Check For:
The reviewer must:
Determine, to the extent practicable, the validity of CBI claims (this can
be difficult)
• Handle CBI in accordance with site-specific policies—in particular, the
reviewer should revisit CBI handling policies before receiving CBI
material
Example Situation: Lois and Clark of Metropolis were selected to review XYZ Company's (the
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
facility) Part B permit application. In reviewing Section D of the application,
Lois notes that the facility has claimed all process information as CBI, and that the
applicant's economic viability would suffer if the information were to be made
publicly available. As an example, all of the combustion unit and air pollution
control device design specifications and proposed normal operating conditions are
claimed as CBI.
Example Action: Although this position may be true for portions of the process information section,
it is unlikely that everything in that section is CBI. However, Lois and Clark
should be sensitive to the facility's concern regarding proprietary information.
Keeping this in mind, Lois should strongly encourage the applicant to revise
Section D of its application, marking as CBI only specific portions that are
genuinely proprietary.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-26
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.7 WASTE MINIMIZATION PLAN REVIEW
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40CFRPart264.73(b)(9)
No specific references are applicable to this section of the manual.
The "Strategy for Combustion of Hazardous Waste" identifies waste minimization
as one of eight goals to maximize the reduction of hazardous waste, and to ensure
safety and reliability of hazardous waste combustion in incinerators and BIFs.
The strategy emphasizes aggressive use of waste minimization measures and
voluntary actions to reduce demand for waste combustion.
The permit writer should:
Identify and inform the owner or operator of potential opportunities to
incorporate waste minimization techniques in the facility's operations
• Assign waste minimization plan review to an internal waste minimization
expert
As Lois and Clark were reviewing XYZ Company's Part B permit application,
they realized XYZ was not taking advantage of obvious waste minimization
opportunities. XYZ's permit application discloses an existing contract with a
manufacturer that generates 50,000 gallons per month of slightly contaminated
acetone. The permit application showed that this waste stream is discharged to the
tank farm with ultimate disposal in the incinerator. XYZ has an opportunity to
segregate this stream and either construct a solvent recovery process on site or
transfer the stream to a permitted recycling operation.
Lois and Clark scheduled a meeting with the XYZ Company Environmental
Director, the Operations Director, and the Facility Manager to discuss this
opportunity to aggressively carry out a waste minimization program. By recycling
the solvent, XYZ Company would receive credit for implementing a waste
minimization program and the solvent could be reused by the generating industry
or another secondary solvent user.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-27
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.8 AVOIDING FUTURE CHANGES TO THE APPLICATION (AND THE PERMIT)
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
No regulations are applicable to this section of the manual
No specific references are applicable to this section of the manual.
The permit writer should attempt to minimize the potential for permit
modifications in the short-term. Understanding of the facility's current and future
operations during the initial review period avoids reopening the permit for minor
changes (basically spending extra unnecessary time). If the permit application
review process will not be significantly delayed, the permit writer should
encourage the applicant to project any reasonable and potential changes or
additions to the HWMU and practices. As a result, an applicant may include
additional HWMUs in the permit application. While this approach is not required
by the regulation, it often benefits both the reviewing agency and the regulated
party.
The reviewer should consider:
• Discussing with the owner or operator any potential changes or plans that
may reasonably affect the facility during the short term (that is, 5 or 10
years into the future)
While discussing Section D of the Part B permit application with the company,
Lois discovered that the XYZ Company plans to add a new production process in
about 2 years. The hazardous waste stream generated by this process will require
storage in a tank farm and must eventually be sent to the on-site BIF unit. XYZ
officials told Lois they did not consider the added process pertinent to the current
permit application.
To avoid reviewing a new Part B permit application and the costly supplemental
trial burn in 2 years, Lois strongly encourages XYZ Company to include all the
design and facility modifications necessary to implement the new process in the
current submittal. She suggests that XYZ Company modify the BIF TBP to
include a waste similar to, or the same as that generated by, the new process, so
that an additional trial burn will not be required.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-28
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.9 CROSS REFERENCE BETWEEN COMPONENT 3 OF THE PERMITTING MANUAL
AND THE SUGGESTED PART B PERMIT APPLICATION FORMAT
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
No regulations are applicable to this section of the manual
No specific references are applicable to this section of the manual.
This cross reference will assist permit writers in finding information located in this
component of the Combustion Manual as they review Part B permit applications.
This format follows the format suggested in the RCRA Part B Permit Application
Review Checklist found in Attachment B to this component.
Developing a method to manage cross referencing will increase the review
efficiency of the lead permit writer (see Exhibit 2.9-1, see page 3-30)
Lois and Clark were concerned that XYZ Company must comply with Subpart
CC of RCRA, and direct all volatile organic compound (VOC) emissions to the
incinerator or into activated carbon containers. This information is provided in
Section D, Subpart CC of the permit application and Lois found additional
information in Section 6.14 of Component 3 of the Combustion Manual.
Lois will find guidance, regulations, and an explanation of the requirements of
Subpart CC. This information will assist her in conducting the technical adequacy
review of the permit application.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 2.9-1
CROSS REFERENCE BETWEEN COMPONENT 3 OF THE PERMITTING MANUAL AND
THE SUGGESTED PART B PERMIT APPLICATION FORMAT
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U.S. EPA Region 6
Center for Combustion Science and Engineering 3-30
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 2.9-1 (Continued)
CROSS REFERENCE BETWEEN COMPONENT 3 OF THE PERMITTING MANUAL AND
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U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
2.10 HUMAN HEALTH AND SCREENING LEVEL ECOLOGICAL RISK ASSESSMENT
Regulations:
Guidance:
Explanation:
No regulations are applicable to this section of the manual.
The U.S. EPA 1998 Region 6 risk protocols are considered to be the compilation
of all existing guidance documents on this subject.
The U.S. EPA 1998 Region 6 Human Health Risk Assessment (HHRA) and
Screening Level Ecological Risk Assessment (SLERA) protocols provide an
additional method for evaluating the protectiveness of a permit. The permitting
agency can carry out, or require the applicant to conduct, an HHRA and SLERA
to measure the risks to humans and the surrounding environmental receptors
associated with emissions from a specific hazardous waste combustion facility.
By comparing the risks against acceptable target levels and properly considering
the degree of uncertainty inherent in the analysis, a permitting agency can evaluate
whether the permit is protective of human health and the environment.
The HHRA and SLERA reports are not specifically required in the permitting
regulations. However, the authority to request HHRAs and SLERAs is based on
the requirements of RCRA Section 3005(c)(3), which states that "each permit
issued under this section shall contain such terms and conditions as the
Administrator (or the State) determines necessary to protect human health and the
environment." Because the current technical standards do not address many of the
hazards associated with emissions from the combustion of hazardous waste,
protectiveness for combustion units is not ensured even when the permit conforms
to regulations.
It is suggested that a RAWP for preparing the HHRA and SLERA reports be
submitted along with the Part B permit application. Although the review of the
two documents will differ slightly (particularly with respect to the agency review
team members), the information is interrelated. Also, as discrepancies arise and
information changes, the documents should be revised and refined to be accurate
and consistent.
The protocol documents provides extensive guidance and direction on how to
conduct a HHRA and SLERA and prepare the associated reports. The protocols
outline the information needed to conduct the screening and develop the report. At
times the HHRA and SLERA require information that is also needed in the Part B
application. In these cases, it is suggested that the HHRA and SLERA reference
the information in the Part B rather than repeat it. This situation is common for
information contained in the TBP (see Section D-5b of the application) and
HHRA and SLERA. A listing of the information required for the HHRA report
appears in Exhibit 2.10-1 (see page 3-34). A listing of the information required
for the SLERA report appears in Exhibit 2.10-2 (see page 3-39). This list
consolidates the information requested in the protocol documents.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Check For:
Because the following sections of the Part B permit application are usually
affected by requirements of the HHRA and SLERA, confirm that these sections
are consistent with the HHRA and SLERA:
Section B - General Facility Information: for example, length of time the
unit has been in operation
Section C - Waste Characteristics: for example, complete evaluation of
the waste burned in the unit
Example Section:
• Section D - Process Information: for example, number of fugitive
emission points (equipment leaks)
The XYZ Company submitted the Part B permit application for the existing BIF
unit at their manufacturing facility. The cover letter stated that the RAWP would
be submitted within the next 6 months.
Example Comments: Lois sent a letter to the XYZ Company acknowledging receipt of the Part B permit
application. She informed the company that review of the application would be
delayed until the RAWP was received. The permitting agency believes that the
information between the RAWP and Part B application are interrelated and should
be reviewed concurrently for maximum efficiency.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 2.10-1
INFORMATION NEEDED TO INITIATE HUMAN HEALTH RISK ASSESSMENT
Certain information is necessary to properly conduct a human health risk assessment. This information
falls into nine general categories:
• Identification of sources of stack and fugitive emissions
• Information on RCRA fugitive emission sources
• Information on fugitive emissions from cement kiln dust management and transportation
• Information on emissions from process upsets
• Supporting information for estimating stack emission rates and identifying compounds of
potential concern
Supporting information for stack emission rate estimates for facilities not yet operational
Information on physical characteristics of surrounding area
Ambient data
• Air dispersion modeling results
Each category is discussed in detail below.
1. Identification of Sources of Stack and Fugitive Emissions
Facility plot map that clearly labels and provides in Universal Transverse Mercator
(UTM) coordinates (specify if North American Datum of 27 or North American
Datum 83) the following:
Coordinates of stacks for combustion units burning hazardous waste
• Corners and heights of buildings located within five times the building height from
the stack and that have a height greater than 40 percent of the stack height
• Locations of RCRA fugitive emission sources associated with the treatment,
storage, or disposal of hazardous wastes. Complex piping and process areas near
numerous fugitive emission sources may be grouped into a single combined source
with a summed emission rate. For combined sources, the coordinates defining the
aerial extent of the area should be provided. Generally, RCRA fugitive emission
sources identified for evaluation include the RCRA combustion units and ancillary
piping and tanks. However, fugitive emissions from other RCRA treatment,
storage, or disposal units may also require evaluation in some cases.
Principal business and primary production processes
U.S. EPA Region 6
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 2.10-1 (Continued)
Identification and location of other RCRA treatment, storage, or disposal units
Period of time that each combustion unit burning hazardous waste has been in operation
Period of time that each combustion unit has been burning hazardous waste
Period of time that each combustion unit has been projected to burn hazardous waste
Combustion unit normal and maximum production rates
Type of air pollution control system (APCS) associated with the combustion unit
Combustion unit energy consumption and production rates
Description of previously operated combustion units that burned hazardous waste
Description of combustion units that are planned to burn hazardous waste
2. Information on RCRA Fugitive Emission Sources
Number and location of RCRA fugitive emission sources
Compound specific emission rate (for example, grams per second) and total mass (annual
basis) estimates for all RCRA fugitive emission sources, including applicable supporting
documentation:
Number and description of equipment identified as potential sources of fugitive
emissions (for example, 5 tanks, 40 pumps, and 20 valves), including process
design drawings if necessary
Characterization of each waste stream in contact with the equipment or source
Time each source is in operation specific to each waste stream
Percent by weight of each organic compound in each waste stream
Type of waste stream service (light or heavy liquid) as defined in U.S. EPA 1993
guidance Protocols for Equipment Leak Emission Estimates, EPA-453/R-93-026
Frequency and probable cause of known emissions
• Aboveground height of the emission point
• Air monitoring information, such as routine organic vapor monitoring of
combustion unit
Physical description of other RCRA units not included as ancillary equipment to
the combustion unit, but that are sources of fugitive emissions that may be
evaluated during the risk assessment
3. Information on Fugitive Emissions from Cement Kiln Dust (CKD) Management and
Transportation
Number and location of CKD management, transportation, storage, and disposal areas or
units
• Procedures for CKD management, transportation, storage, and disposal
• Containment procedures, including fugitive dust prevention and area of exposed CKD
• Exposed surface area of CKD disposal unit
• Physical data including particle size distribution and density
• Data including organic and inorganic analytical tests similar to those used for sampling
combustion gases
• CKD recycling rate
• Ambient air monitoring data
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-35
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 2.10-1 (Continued)
4. Information on Emissions from Process Upsets
Description of process upsets or failures at the facility as defined below:
Process Upset—The release of compounds or pollutants from a hazardous waste
combustion unit into the ambient air while the unit is not being operated as intended, or
during startup or shutdown. Process upset emissions usually result from a disturbance in
the hazardous waste combustion system. Upset emissions are generally expected to be
greater than stack emissions during normal operations because the process upset results in
incomplete destruction of the wastes or other physical or chemical conditions within the
combustion system that promote the formation or release of hazardous compounds via the
combustion unit stack. Upset emissions usually occur when the hazardous waste
combustion unit is not operating within the limits specified in a permit or regulation.
Historical operating data demonstrating frequency and duration of process upsets. These
data may include tables, figures, or charts indicating the following data for the last 5 years:
• Number of days per year a process upset was experienced
Number of days per year the combustion unit was in operation
• Condition used to determine process upset occurrence
Length of time—for each occurrence—the unit was in upset status (minutes)
• Total length of time the unit was in operation per year
Combustion unit conditions during each process upset (at a minimum, this
information should include instantaneous or hourly rolling average values—as
appropriate—for all process operating parameters controlled by permit or
regulation)
5. Supporting Information for Estimating Stack Emission Rates and Identifying Compounds of
Potential Concern
Descriptions of the waste feed streams burned during stack sampling, including chemical
composition and physical properties, which demonstrate that the waste feeds are
representative of normal site-specific wastes
• Trial burn test data that include:
• Facility description
Test objectives
• Summary of test results
Test plan protocol
• Quality assurance/quality control results
Data validation results
• Process operating data
Continuous emissions monitoring system (CEMS) data
U.S. EPA Region 6
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 2.10-1 (Continued)
Process instrumentation and CEM calibration records
• Laboratory analytical data
Sampling and analytical procedures
• Field testing data
• Discussion of unit operations or waste feeds (commercial waste disposal, plastics,
polychlorinated biphenyl (PCB) wastes, explosives, or mixed wastes) conducive to
producing emissions containing dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF),
PCBs, polynuclear aromatic hydrocarbons (PAFi), nitroaromatics, phthalates, or other
risk-causing compounds
Discussion of information required for the constituent of potential concern (COPC)
identification process including:
• Any nondetect compounds that should be retained as COPCs because they are
present in the waste
• Evaluation of the realistic emission potential of nondetect compounds
Evaluation of the 20 largest tentatively identified compound peaks obtained during
gas chromatography (GC) analysis of emissions during the trial burn
6. Supporting Information for Stack Emission Rate Estimates for Facilities Not Yet Operational
• Stack test reports for facilities of similar technology, design, operation, capacity, auxiliary
fuels, waste feed types, and APCS
• All stack test reports for combustion units used to develop emission rate estimates
Description of how the combustion data used represents similar technology, design,
operation capacity, auxiliary fuels, waste feed typed and APCS
Demonstration that the data used to develop the emission rate estimates were collected
using appropriate sampling and analysis procedures
7. Information on Physical Characteristics of Surrounding Area
• Identification and description (including UTM coordinates) of current and reasonable
potential future land use of undeveloped areas within the facility property boundary
including (1) livestock grazing, gardening, or farming, (2) fishing, (3) residential, and
(4) ecological habitats
8. Ambient Data
Identification and summary of ambient data collected at the facility that describe the
concentrations of hazardous constituents found in media including biota, animal tissue,
fish tissue, sediments, soils, air, and surface water
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-37
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 2.10-1 (Continued)
9. Air Dispersion Modeling Results
Air dispersion modeling (typically ISCST3) input files and output files used to support
risk evaluation of all emission sources at the facility. The input files should be in
electronic format suitable for direct insertion into ISCST3 as required to directly
reproduce the modeling effort. The output files should be in electronic format as provided
by ISCST3 for all sources and all receptor grid nodes (locations). These files include
modeling results to all receptor grid nodes modeled (not only the selected exposure
scenario locations evaluated in the facility's risk assessment) to provide air dispersion
modeling data for subsequent risk evaluation of any receptor grid node (consult
combustion risk assessment guidance for receptor grid node resolution) within 3 kilometers
of the centroid of the sources at the respective facility.
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-38
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 2.10-2
INFORMATION NEEDED TO INITIATE SCREENING LEVEL ECOLOGICAL
RISK ASSESSMENT
1. Land use map (out to at least 10 kilometer (km) showing the following types of land use:
Agricultural
Residential
Industrial
Other Urban
Forest
Water
Wetland
Rangeland
Barren Land
2. Current aerial photographic coverage out to 10 km.
3. Topographic map coverage out to 50 km.
4. Selection of all applicable and appropriate food webs from the list presented in the protocol.
5. Representative receptors for each trophic level of each selected food web. Include natural history
information for each selected receptor.
6. Type, location, and size of special ecological habitats within 50 km. Examples include wildlife
refuges, wildlife management areas, and designated scenic rivers or water bodies.
7. Name and location of threatened or endangered species, including migratory species and plant
species.
8. Selection of all applicable or appropriate receptor scenarios from the ones presented in the
protocol.
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-39
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
3.0
REVIEWING THE PART A APPLICATION—SECTION A
Regulations:
Guidance:
Explanation:
Check for:
40 CFR Part 270.1
40 CFR Part 270.13.
Application for a Hazardous Waste Permit-Part A. U.S. EPA Form 8700-23.
Notification of Regulated Waste Activity. U.S. EPA Form 8700-12.
These two documents contain application forms with instructions and may be
obtained from an U.S. EPA regional office or state RCRA program office.
Every owner or operator of a hazardous waste treatment, storage, or disposal
facility (TSDF) must apply to U.S. EPA or the authorized state for a U.S. EPA
identification number. Part A of the permit application is filed with the U.S. EPA
regional administrator or state director (in authorized states) on a form provided
by the regional administrator or state director. U.S. EPA Form 8700-23 replaces
obsolete U.S. EPA Forms 3510-1 and 3. Detailed instructions for completing the
Part A application are included with the application forms (see Attachment E of
this component).
Although the majority of the information in Part A is also contained in the Part B
application, the submittal of Part A is critical for the following reasons: (1) if an
existing facility wanted to operate under IS before receiving a permit, a Part A
application must have been submitted by the specified notification date; (2) if an
existing facility is found to be operating without a permit and it never submitted
the Part A application, the facility does not have authorization to operate under IS
and is a candidate for enforcement action; or (3) if a facility wishes to be permitted
as a new facility, then the Part A application must accompany the Part B
application.
The permit writer should ensure that the information presented in the Part A is
consistent with the information submitted with other parts of the Part B
application, including the TBP and RAWP.
Ensure the following elements in the Part A application are completed:
• Facility Operator
• Name of operator
Address of operator
• Telephone number of operator
Ownership status
Federal
State
Private
Public
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Other (explain)
• Facility Owner
• Owner name
• Owner address
• Owner telephone number
Facility name
Address
• Location (latitude and longitude)
New or existing facility
• Facility mailing address
• Facility contact
• Address
• Telephone number
Name of operator
Address
• Telephone number
• Type of operator
• Change of operator
• Date changed
• Type of owner
• Change of owner
• Date changed
• Standard Industrial Classification (SIC) codes (up to four)
• Other environmental permits
• Description of the nature of the business
• Processes and design capacity of each process
• Additional treatment processes and design capacity of each
• Description and amount of each hazardous waste managed
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-41
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Detailed topographic map
Scale drawing of the facility
Detailed photograph of the facility
Signed certification
Owner signature
• Operator signature
Other authorized signature (s)
Example Situation: Lois and Clark were reviewing the Part A submittal and noted that the topographic
maps for the area where XYZ Company plans to construct the facility were out of
date. The maps were dated 1966 and the contour intervals were not sufficiently
clear. Because the maps were more than 30 years old, they did not accurately
depict surrounding land use that has changed since 1966.
Example Action: Clark wrote an NOD to reflect his concern that the Part A topographic maps were
outdated and not accurate. He requested that the facility procure a more recent
map.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-42
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4.0
COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
REVIEWING THE FACILITY DESCRIPTION—SECTION B
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 270.14
No specific references are applicable to this section of the manual.
This section normally appears as Section B of the permit application. It provides
a general overview of the facility and includes information regarding the nature of
the facility's business, surrounding land use, and geographic details.
Ensure that all of the following subsections, at a minimum, are listed under
Section B of the permit application:
• General description (see Section 4.1)
• Identification of site-specific risk assessment information
• Topographic map showing a distance of 1,000 feet around the facility at a
minimum (see Section 4.2)
• Location information (see Section 4.3)
• Traffic patterns (see Section 4.4)
See Sections 4.1 through 4.4 for specific examples.
Example Comments: See Section 4.1 through 4.4. for specific comments.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
4.1 GENERAL DESCRIPTION
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
40CFRPart270.14(b)(l)
No specific references are applicable to this section of the manual.
This section briefly describes the facility to provide the permit writer with an
overview of the facility's operations. If a TBP accompanies the Part B permit
application, this information may also appear in the beginning of the TBP. It is
acceptable, and sometimes easier, if this information appears only in the TBP to
promote the TBP's independence as a document and avoid repetition between the
Part B application and the TBP. In addition, the Part A application also provides
some of the information listed below. However, in this case, it is more desirable
for the information to be listed in both the TBP and the Part A application to
facilitate information retrieval.
The permit writer should check for:
• Brief description of the facility
• Explanation of the nature of the business
• Description of the processes involved in hazardous waste generation and
management
• List of industries served if managing wastes from off site
• General facility information:
• Facility name
• Facility contact
• Facility address (both mailing and physical address)
• Facility telephone number
• Facility U.S. EPA identification number
While reviewing the facility description, Clark noticed that the annual generation
rate of ash was not discussed; the facility planned to dispose of ash on site at a
landfill to be constructed. Ash will be generated from the incinerator, the
baghouse, the spray dryer absorber, and from the BIF operations on site. The rate
of ash generation is important to determine landfill size and operating cell life in
the landfill operations.
Example Comments: Clark wrote an NOD to XYZ Company explaining that the annual generation rate
of ash must be estimated. This information would provide the engineering
guidance for landfill cell size and life expectancy.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-45
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
4.2
TOPOGRAPHIC MAP
Regulation:
Guidance:
Explanation:
Check For:
40CFRPart270.14(b)(19)
40 CFR Part 270.14(c)(3) and (c)(4)(I),
40 CFR Part 264.95
40 CFR Part 264.97
No specific references are applicable to this section of the manual.
According to 40 CFR Part 270.14(b)(19), the Part B application must include a
topographic map that shows the facility and a distance of 1,000 feet around it at a
scale of 1 inch to not more than 200 feet. The map must include contours of 5 feet
if relief is greater than 20 feet and controls of 2 feet if relief is less than 20 feet.
The map must include a scale and date, 100-year flood plain areas, surface waters
including intermittent streams, surrounding land uses, map orientation, and legal
boundaries of the facility site. The map must also indicate the location of:
Access control points
Injection and withdrawal wells
Buildings, structures, sewers (storm, sanitary, and process)
Loading and unloading areas
Fire control facilities
Flood control or drainage barriers and run-off control systems
Proposed and existing FIWMUs and SWMUs.
Multiple maps may be used. The topographic map provides the permit writer with
an aerial view of the facility's boundaries (and sometimes FIWMUs) in
comparison to various geographic formations (in particular, surface water
drainage) and surrounding land use. The regulations listed above identify the
information that should be provided on the map.
The following items should be identified:
• Map scale and date
• 100-year flood plain areas
• Surface waters including intermittent streams
• Surrounding land use
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
• A wind rose and orientation, with north clearly shown
• Legal boundaries of the hazardous waste management (HWM) facility
• Access control
• All proposed buildings, building dimensions, internal roads, fire control
facilities, and ancillary structures
• Barriers for drainage or flood control
• Location where hazardous waste will be treated, stored, or disposed
• UTM coordinates and overlays showing prevailing wind patterns, both
direction and speed
• Such risk assessment information as may be required for the site-specific
risk assessment
Example Situation:
Example Action:
The XYZ Company submitted Exhibit 4.2-1 (see page 3-48), a copy of a 1979
U.S. Geological Survey (USGS) topographic map. The map has no scale and is in
black and white and of poor quality. The map does not clearly show the proposed
facility boundaries, does not provide the UTM coordinates, and does not show
surface water and intermittent streams. Also, there is no overlay presenting wind
speed and direction that will be required as part of the site- specific risk
assessment.
In his review of Exhibit 4.2-1 (see page 3-48), Clark noted that some of the basic
requirements presented in 40 CFR Part 270.14(b)(19) were missing from the map.
An official NOD was developed instructing XYZ Company to review the
requirements presented in the CFR, procure a recent color topographic map, and
revise the presentation. Additionally, Clark informed XYZ Company that
information concerning topography, land use patterns, site building heights, and
annual wind direction and speed data would be required for inclusion in the site-
specific risk assessment.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 4.2-1
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U.S. EPA Region 6
Center for Combustion Science and Engineering
3-48
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
4.3
LOCATION INFORMATION
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Part 264.18(a) and (b)
40 CFR Part 264 Appendix VI
40 CFR Part 270.14(b)(l l)(i) through (v)
No specific references are applicable to this section of the manual.
This section describes the location of the facility with respect to 100-year flood
plains and areas with seismic activity. If a new facility will be located in an area
listed in 40 CFR Part 264 Appendix VI, additional information must be provided
on the seismic activity of the area and the physical location of the facility. The
application must also document whether the facility is located within a 100-year
flood plain. If so, additional information must be provided that describes how the
facility's design takes into account a potential flooding scenario and plans for
future compliance with floodplain standards.
In addition to the above, the application should include site-specific risk
assessment information for indirect exposure pathways. The pathway groupings
are related to human ingestion of media and food by soil ingestion and
consumption of aboveground and root vegetables, beef and milk, and fish. The
affected community includes the subsistence farmer, subsistence fisher, adult
resident, and child resident.
The permit writer should check for:
• Statement indicating whether the facility is located in an area listed in
40 CFR Part 264 Appendix VI; if so, a complete description of how the
facility meets the seismic standards (including supporting information)
should be included
• A Federal Insurance Administration Map (or equivalent) that documents
whether the facility is located in a 100-year flood plain
• If the facility is located in the flood plain, extensive engineering and
operating protocols should be provided to demonstrate how the facility
deals with flooding
• If the facility has applied for a waiver from the flood proofing and flood
plan requirements, a comprehensive set of operating procedures must be
in place to safely remove the waste before flood waters can reach the
facility
• Land use information in surrounding areas out to approximately 10 km
from the incinerator stack or from the source
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Example Section: Lois and Clark were reviewing this section of XYZ Company's application and
were comparing the proposed location to a USGS topographic map in the office.
Lois notices that the general location map of the facility showed the wind was
directly out of the west almost 85 percent of the time. When she drew a 10 km
circle around the facility, it showed that 8.5 km to the east was a sugar beet farm.
This information was not included in XYZ Company's location information
submission.
Example Comments: Lois wrote a technical adequacy review noting the sugar beet farm was not
identified. Lois instructed XYZ Company to include this as part of the site-
specific risk assessment. Because this information was not included in the Part B
permit application, Lois wrote an NOD covering the overall location information
and requiring XYZ Company to identify any of the five pathway groupings
discussed in Section 4.3 of the revised submission.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-50
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
4.4 TRAFFIC INFORMATION
Regulation:
Guidance:
Explanation:
Check For:
40CFRPart270.14(b)(10)
No specific references are applicable to this section of the manual.
This section describes the traffic patterns and road use of the facility. It informs
the permit writer how hazardous wastes are transported on facility premises.
The permit writer should check for:
• On site traffic patterns
• Estimated volumes, including number and types of vehicles
• Traffic control signs, signals, and procedures
• Access road surfacing and load-bearing capacity
Lois and Clark were reviewing the facility description for XYZ Company and
noted that there was no discussion of the estimated number and types of vehicles
entering the facility daily. A blind turn was found around the tank farm where
tractor trailer-type trucks could encounter oncoming traffic and not be able to
avoid an accident.
Example Comments: Lois wrote an NOD to XYZ Company about the missing number and type of
vehicles entering daily. She also suggested XYZ Company review the traffic flow
and proposed plant layout to avoid the blind curve noted.
Notes:
Example Situation:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.0
REVIEWING WASTE CHARACTERISTICS—SECTION C
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Part 270.14(b)(2) and (3)
No specific references are applicable to this section of the manual.
This information normally appears as Section C of the permit application and
includes 3 parts: (1) chemical and physical analyses (see Section 5.1 of this
component), (2) the waste analysis plan (WAP) (see Section 5.2 of this
component), and (3) waste analysis requirements pertaining to land disposal
restrictions (LDR) (see Section 5.3 of this component). This information is
necessary to ensure proper waste management. The chemical and physical
analyses section includes up-to-date laboratory analysis of wastes managed at the
facility. The WAP provides the facility's plan for ongoing sampling and analysis
to properly manage wastes. Requirements pertaining to LDRs lists requirements
unique to wastes managed under LDRs.
The permit writer should check for:
• Adequate characterization of the waste to meet regulatory requirements
• Any process-specific waste characterization requirements
• A complete WAP using all applicable U.S. EPA or American Society for
Testing and Materials (ASTM) methods
Approved sampling procedures to obtain representative waste samples
Regulatory requirements for wastes that have LDR restrictions
Documentation of all WAP QA/QC procedures
Incorporation of data requirements for the HHRA and SLERA into waste
characterization procedures
• Quantitation limits for LDR wastes and RAWP COPC analysis
• Acknowledgment that sampling and analysis is an ongoing effort—not
something done sporadically
XYZ Company submitted the chemical and physical analysis of the hazardous
waste to be handled at the facility. In the submission, Lois noted that XYZ
Company neglected to present data on metals content of the waste. The
regulations require the submittal of all information that must be available to treat,
store, or dispose of the wastes properly.
Example Comments: Because information on metals content of the wastes was not presented and Lois
knew that metals were important in developing the site-specific risk assessment,
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-52
Example Section:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
she wrote the following NOD to XYZ Company instructing it to produce the
necessary information.
"Section C of the application fails to present hazardous waste stream
characterization methods or procedures for metals content. Please revise the WAP
to include appropriate sampling and analysis methods to determine metals
concentration in the hazardous waste stream. Provide information on the method
selection rationale."
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-53
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.1
CHEMICAL AND PHYSICAL ANALYSES
Regulation: 40 CFR Parts 264.13(a), 266.102(a)(2)(ii), 266.102(b), and 270.14(b)(2)
Guidance: No specific references are applicable to this section of the manual.
Explanation: For each hazardous waste managed at the facility, the application should include
(1) a waste description, (2) hazardous characteristics, (3) the basis for designation
as hazardous, and (4) a laboratory report detailing the chemical and physical
analysis of representative samples. Analytical results must include all information
needed to treat, store, or dispose of the waste according to applicable requirements
under 40 CFR Parts 264, 268, or 270; specifically, waste classified as:
Containerized Waste (see Section 5.1.1)
Waste in Tank Systems (see Section 5.1.2)
Waste in Piles (Section 5.1.3)
Landfilled Waste (see Section 5.1.4)
Waste in Incinerators (see Section 5.1.5)
Wastes to be Land Treated (see Section 5.1.6)
Waste in Miscellaneous Treatment Units (see Section 5.1.7)
Waste in BIFs (see Section 5.1.8)
Check For: The permit writer should check for the application for certain information:
• Waste characteristic data as recent as possible for the waste being
submitted for treatment or disposal
Recurring waste stream characterization data reconfirmed at least
annually, or as appropriate
• Sampling and analysis methods consistent with current
EPA-approved procedures
Typical waste characterization and analytical data in all feed streams, at a
minimum:
VOCs
SVOCs
PCBs
PCDD/PCDFs
• Metals
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Chlorine
Solids and ash
Physical characteristics such as heat value, density, and viscosity
Example Section:
Example Comments:
XYZ Company had included an analytical procedure for mercury analysis that
deviates from the U.S. EPA method. XYZ has provided details on the method, the
digestion, and the QA/QC based on laboratory results. Lois was concerned that it
was not a U.S. EPA-approved method and requested the company to compare the
method with approved mercury analytical procedures.
In an NOD, Lois requested that the XYZ Company conduct a side-by-side
comparison of the proposed mercury analysis method and the U.S. EPA SW-846
approved method. She indicated that spike and recovery results must be presented
along with duplicate analysis and results of waste mercury results on a statistically
valid sample size. Lois informed XYZ Company that these results would be
reviewed by experts at the U.S. EPA and would have to merit their approval
before the mercury analysis proposed by the company could be approved for
general use at the facility.
Lois also informed XYZ Company that any analytical data older than 1 year
would be unacceptable and must be updated. Lois indicated that all analyses
submitted for inclusion in the Part B permit application should follow U.S. EPA-
approved sampling and analysis procedures to expedite the review process.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.1.1 Containerized Waste
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Parts 264.172 and 270.15(b)(l)
40 CFR Part 264.314
No specific references are applicable to this section of the manual.
This section should provide waste characteristic data which demonstrate that the
wastes are compatible with container construction materials.
The permit writer should check for:
• Documentation and test results that show whether the container stores
wastes that contain free liquids. If the wastes contain free liquids, a
secondary containment system must be in place.
The most common free liquids test is the Paint Filter Liquids Test,
Method 9095 in SW-846.
Information regarding the construction material of the containers (in
particular, the interior surface) and the types of compounds that are
compatible with the material. For example, the facility should provide
vendor data or manufacturers specification sheets that document which
compounds either are, or are not, compatible with the container's
construction materials.
Example Situation:
Lois and Clark were concerned that XYZ Company would receive and try to
incinerate containers that contained free liquids. However, XYZ Company stated
in the incinerator permit application that no containers containing free liquids
would be fed to the combustion unit. Lois asked the company to explain how it
could guarantee no free liquids would be included in containers fed to the
combustion unit.
Example Action:
Notes:
XYZ Company responded that all 55-gallon drums containing hazardous waste
would be shredded in a controlled environment, then passed directly into the rotary
kiln via a ram/air lock device. The shredding and feeding process would be
monitored under closed circuit TV cameras and can be stopped if an operator
determines that excess liquid has entered the process. The liquids would then be
contained, collected, and routed to the liquid injection portion of the treatment
system. The same feeding system would be used for smaller containers if free
liquids are a concern.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.1.2 Waste in Tank Systems
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Parts 264.190(a), 264.191(b)(2), and 264.192(a)(2)
No specific references are applicable to this section of the manual.
This section should provide waste characteristic data to demonstrate that tank
construction materials are compatible with wastes stored in the tank.
The permit writer should check for:
• Documentation and test results that show whether the tank stores wastes
that contain free liquids. If the wastes contain free liquids, a secondary
containment system must be in place.
The most common free liquids test is the Paint Filter Liquids Test,
Method 9095 in SW-846
Information on the construction material of the tank (in particular, the
interior surface) and the types of compounds that are compatible with the
material. For example, the facility should provide vendor data or
manufacturers specification sheets that document which compounds either
are, or are not, compatible with the tank's construction materials.
In its Part B permit application, XYZ Company certified that the tank system's
integrity had not been violated, there were no leaks, and it was fit for use.
During the review, Lois noticed that the certification was signed by the president
of the company. Lois remembered from 40 CFR Part 264 Subpart J—Tank
Systems, the certification must be signed and stamped by a qualified, registered
professional engineer.
Example Comments: Lois wrote the following NOD for the tank system certification. "The tank system
integrity certification must be signed by a qualified, registered professional
engineer. The engineer must be registered in the state in which the facility is
located. The facility might be best served if this engineer was independent of the
company."
Notes:
Example Section:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.1.3 Waste in Piles
Regulation: 40 CFR Part 264.250(c)(l) and (4)
Guidance: RESERVED
Explanation: Since these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.1.4 Landfilled Wastes
Regulation: 40 CFR Parts 264.13(c)(3) and 264.314
Guidance: RESERVED
Explanation: Since these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.1.5 Waste in Incinerators
Regulation: 40 CFR Parts 264.341 and 270.62(b)(2)(I)
Guidance: U.S. EPA. 1992. "TID for EPA's BIF Regulations." OSWER. Washington
D.C. EPA-530-R-92-011. March. Section 5.2.6.
Explanation: This section should provide the results of analysis for each waste or waste mixture
to be burned during operation, and information on the waste feed proposed for the
trial burn or risk burn.
Check For: • The following analytical data, at a minimum, should be provided for each
waste stream to be burned:
Heating value
• Viscosity of pumpable wastes (liquids)
Physical form of nonpumpable wastes (nonliquids)
• Identification and quantification of (1) the waste via
SW-846 Method 8260 and 8270, and (2) Appendix VIII
constituents reasonably expected to be present in the waste
PCB concentration (Method 8270)
PCDD/PCDF concentration (Method 8290)
• Total chlorine/chloride concentration
• Ash content
• BIF metals concentration (antimony, arsenic, barium, beryllium,
cadmium, chromium, lead, mercury, silver, thallium, nickel, and
selenium); the authority for this requirement is based on the
Omnibus Provision
Ultimate and proximate analysis
Waste stream selection for various test requirements
Destruction and removal efficiency (DRE) test requires wastes
with indicator organic compounds used for tracking destruction
efficiency of the incinerator
• Risk burn test typically requires worst-case waste streams
operating under normal conditions in order to measure PIC
formation
• Quantification limits for various analytical methods should be reviewed to
ensure that the minimum sample quantitation limit (SQL) is sufficient to
enable accurate calculation of waste feed rates. This issue is important
with regard to (1) calculating the DRE for each constituent based on the
constituent concentration in each waste feed stream, and (2) calculating
emission rates for completing the risk assessment process.
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Sampling and analytical methods used to collect samples for analysis
should be documented so that the permit writer can confirm that
appropriate methods were employed and corresponding techniques were
used
Example Section: Lois and Clark were reviewing the waste incineration section of XYZ Company's
Part B permit application and noticed that no specific organic compounds had
been quantified. The Appendix VIII organic compounds identified were listed, but
no quantities were provided. To assign matrix principal organic hazardous
constituents (POHC), it is important to know which compounds are present in the
highest concentrations. It is also important that U.S. EPA-approved stack
sampling methods and analysis procedures be available for compounds designated
as POHCs.
Example Comments: Clark wrote XYZ Company an NOD and requested a quantitative analysis of
native organic constituents in the waste streams be provided.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.1.6 Wastes to be Land Treated
Regulation: 40 CFR Parts 264.271(a)(l) and (2), 264.272, 264.276 and Part 261
Appendix VIII and 270.20(b)(4)
Guidance: RESERVED
Explanation: Because this issue is not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.1.7 Waste in Miscellaneous Treatment Units
Regulation: 40 CFR Part 270.23(d)
Guidance: RESERVED
Explanation: Because this issue is not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.1.8 Waste in Boilers and Industrial Furnaces
Regulation: 40 CFR Parts 266.102(b) and 270.66(r)
Guidance: U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." EPA-530-R-92-011. OSWER. Washington D.C. March. Section
5.2.6.
Explanation: This section should provide analytical results for each fuel, industrial furnace feed
stock, hazardous waste, or hazardous waste mixture to be burned during
operation. It should also provide analytical results for the feed streams proposed
for the trial burn or performance test. These results are also required for any vent
gas streams routed to the BIF.
Check For: • The following analytical data, at a minimum, should be provided for each
feed stream:
• Heating value
Viscosity of pumpable wastes (liquids)
• Physical form of nonpumpable wastes (nonliquids)
• BIF metals concentration (antimony, arsenic, barium, beryllium,
cadmium, chromium, lead, mercury, silver, thallium, nickel, and
selenium)
PCB concentration (Method 8270)
PCDD/PCDF concentration (Method 8290)
• Total chlorine/chloride concentration
• Ash content
• Viscosity or description of the physical form of the feed stream
Ultimate and proximate analysis
For each hazardous waste stream as fired, the following analytical data, at
a minimum, should be provided:
• Identification and quantification via SW-846 Methods 8260 and
8270
If blending is to occur prior to firing, a detailed analysis of the
hazardous waste prior to blending, the blending material, blending
ratios, and description of blending procedures
Blended materials should have an "as blended" analysis before
being fired to provide an accurate assessment of the composition
of the material fed to the BIF
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Example Section:
The TBP or Part B permit application should contain waste characteristic
data. It is not recommended that this information appear twice between
the two documents. Rather, it should appear in one of the two documents
and be referenced, as needed.
• Additional analytical requirements needed to satisfy the risk assessment
(see Section 5.0 of this component).
Quantification limits for various analytical methods should be reviewed to
ensure that the minimum SQL is adequate to enable accurate calculation
of waste feed rates. This issue is important in calculating the DRE for
each constituent based on the constituent concentration in each waste feed
stream. This issue is further discussed in Component 1—How to Review
a Trial Burn Plan, Sections 3.1.4.4 and 3.1.4.6.
• Sampling and analysis methods should be documented so that the permit
writer can confirm that appropriate methods were employed and
corresponding techniques were used.
Lois reads the Waste in BIF section of the facility's Part B permit application
which states:
Example Comments:
"To ensure a safe and steady state operation, hazardous waste-derived fuel
(HWDF) sometimes needs to be blended to provide a uniform fuel before it can be
burned in a cement kiln system. The contents of each incoming shipment and each
blend of individual shipments will be sampled and analyzed. Based on
composition, heat value, and the contents of each sample, a blend of different
amounts of HWDF from incoming loads and in storage tanks will be prepared.
All blended HWDF will be analyzed for burning acceptance to demonstrate
compliance with all applicable regulatory specifications and Certification of
Compliance limits. HWDF in storage tanks can be blended between tanks to
improve the quality prior to energy recovery in the kilns. HWDF from each tank
that will be utilized in the blending process.
The text states that HWDF will be blended to improve the quality of the fuel prior
to energy recovery in the kilns; however, the specific criteria are not clear. While
the Part B permit application states that wastes will be analyzed before they can
be burned, Lois requests in an NOD that the facility revise this section to identify
the types of wastes that are likely candidates for blending and to what composition
levels the waste will be blended.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.2 WASTE ANALYSIS PLAN
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Parts 264.13(b) and (c)
40 CFR Parts 266.102(a)(2)(ii) and 266.104(a)(2)
40 CFR Part 268.7
40CFRPart270.14(b)(3)
No specific references are applicable to this section of the manual.
The regulation requires that a WAP be provided in the permit application. The
WAP should describe the methodologies for conducting the analyses required to
properly treat, store, or dispose of hazardous wastes. In addition, the WAP should
also demonstrate compliance with LDRs. The goal of the WAP is to establish a
sampling and analysis plan that will (1) provide data that support the facility's
demonstration of compliance with the waste feed and residual management
requirements, and (2) provide data necessary to complete the risk assessment
process.
The following subsections identify various elements required in a WAP. The
format of a WAP is flexible but should contain all stated elements:
Parameters and Rationale (see Section 5.2.1)
Test Methods (see Section 5.2.2)
Sampling Methods (see Section 5.2.3)
Frequency of Analyses (see Section 5.2.4)
Additional Requirements for Wastes Generated Off site
(see Section 5.2.5)
• Additional Requirements for Ignitable, Reactive, or Incompatible
Wastes (see Section 5.2.6)
Additional Requirements Pertaining to BIFs (see Section 5.2.7)
Additional Requirements Pertaining to Containment Buildings
(see Section 5.2.8)
Certain elements must be contained in every WAP.
The most current EPA-approved methodologies (or justification as to why
non-EPA methods are proposed) should be included in the WAP
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The WAP should specify, by name and method number, the sampling and
analysis methods proposed. It is not acceptable to simply state that the
most current EPA-approved methods will be used
To ensure that analytical methods do not become outdated, the WAP
should propose that future updates to sampling and analysis methods will
be incorporated into the facility's WAP
The WAP should be updated either when (1) existing HWMUs become
regulated (such as an existing BIF unit coming under regulation in 1991),
(2) new units are proposed through permit modifications: (3) new waste
streams are handled, or (4) facility operating process changes dictate a
need for revision
Methods proposed in the WAP should specify detection limits that are
adequate to support accurate waste feed rate calculations.
Example Section:
Example Comments:
XYZ Company submitted a detailed WAP which states that a representative
sample of hazardous waste will be collected before it is accepted and burned. This
plan provides the basis for acceptance or rejection of incoming wastes based on
criteria established by XYZ Company for acceptable waste and from results of the
trial burn conducted under authority of the regulatory officials.
The WAP covers RCRA Part B operations and combustion unit (incinerator and
boiler) operations. Permit limitations are specified for each waste disposal option
and the WAP is used to demonstrate compliance, assure QA/QC for the results,
and complete the risk assessment process.
In his review, Clark notes that XYZ Company does not receive the same wastes at
the incinerator as are received at the boiler. In some cases, the boiler receives
wastes that have been blended by the incinerator operations. XYZ Company must
address the waste analysis requirements of 40 CFR Parts 264.13 and 266.102 for
wastes received by the incinerator operations.
Because the operations overlap, Clark requested XYZ Company develop a WAP
and waste dispatching procedure that clearly shows waste streams sent to the
RCRA Part B-permitted incinerator and waste streams used as fuel in the boiler.
Clark expressed concern that wastes designated for the incinerator with its quench
and scrubber system could be sent to the boiler which lacks an equivalent APCS.
Because the combustion processes differ, Clark wanted to ensure that only unit-
specific approved wastes could be sent to either the incinerator or BIF.
Notes:
5.2.1 Parameters and Rationale
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40CFRPart264.13(b)(l)
No specific references are applicable to this section of the manual.
The WAP should contain a list of analytical parameters supported by a rationale
for their selection. It is important to note that the WAP must include all feed
streams to the combustion unit and any process residues (such as scrubber effluent
or ash). It may also include stack gas samples, if the permit writer specifies
regular stack testing as a permit condition.
The permit writer should check for the following information:
Rationale should be provided for each parameter (for example, total
chlorine/chloride) as required under 40 CFR Part 266.102[b])
• For parameters that are not specifically required by regulation, the
rationale must provide greater detail as to how a particular analysis will
provide sufficient information on the feed stream's properties to comply
with specific facility operating requirements
Lois and Clark were reviewing the Parameters and Rationale section of the XYZ
Company's WAP. They noticed that the plan called for mercury analysis using
atomic absorption spectroscopy (AAS). Clark reviewed SW-846 analytical
procedures for metal analysis and found that by using AAS for mercury analysis,
the company was not likely to detect mercury in most samples because of the poor
detection limit.
Clark wrote XYZ Company an NOD for the Parameters and Rationale section of
the WAP recommending that all waste streams must be analyzed for mercury
using the cold vapor atomic absorption technique. This technique yields a much
lower detection limit and will develop more reliable data for inclusion in the
facility site-specific risk assessment.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.2.2 Test Methods
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40CFRPart264.13(b)(2)
U.S. EPA. 1994. "Waste Analysis Guidance for Facilities that Burn Hazardous
Wastes." Draft. EPA 530-R-94-019. Enforcement Compliance Assurance
(EGA). Washington D.C. October. Sections 2 and 3.
The WAP should list test methods used to test for selected parameters.
The permit writer should:
Confirm that each test method is clearly identified
Confirm that test methods are those generally acceptable to the permitting
authority, such as SW-846 and ASTM
• Compare the test methods proposed in the TBP and RAWP with those
proposed in the WAP; when possible, it is advisable to use the same
methods in the TBP as in the WAP to promote a comparable data set
• Ensure a representative sample is collected
• Ensure that the SQL and method detection limit (MDL) for each method
is clearly explained and understood during the review process
Confirm that facility proposed modifications to accepted methods have
supporting documentation
During their review of the Test Methods section of the WAP, Lois and Clark
noticed that method numbers were not consistent and that some methods appeared
to be facility modifications of SW-846 methods.
Lois noticed that XYZ Company proposed in the TBP and RAWP that all waste
samples would be analyzed by an outside laboratory. The company stated
"analysis by an outside laboratory would further verify the validity of the trial
burn results." Lois was concerned that the on site laboratory should also
participate in the analysis of all waste samples for, at a minimum, WAP
parameters. These data would serve as a direct comparison with the contract
laboratory for validity and provide the permitting authority much needed
information about the performance of the on site laboratory.
Clark wrote an NOD requesting XYZ Company use a method numbering system
that is consistent with EPA-approved analytical methods. He suggested that XYZ
Company follow SW-846 and ASTM for those methods. Clark requested that any
modified methods use the original number with the letter "M" at the end to indicate
it was a modified SW-846 method.
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Lois wrote an NOD to XYZ Company requiring the on-site facility laboratory to
actively participate in the trial burn. She requested the on site laboratory take split
samples and analyze them for the same parameters as the contract laboratory. She
also requested that all QA/QC results be included in the trial burn report.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.2.3 Sampling Methods
Regulation: 40 CFR Part 264.13(b)(3)
40 CFR Part 261 Appendix I
40 CFR Part 266 Appendix IX
Guidance: U.S. EPA. 1994. "Waste Analysis Guidance for Facilities that Burn Hazardous
Waste." Draft. EGA. Washington D.C. EPA 530-R-94-019. October.
Sections 2 and 3.
Explanation: The WAP should list sampling methods used to obtain a representative sample of
each feed stream to be analyzed. The WAP should also identify the sampling
location.
Check For: The permit writer should check that the WAP contains certain components:
Each sampling method should be clearly identified. If the sampling
method is a U.S. EPA or ASTM method, the method number and
reference should be provided. If the sampling method is something other
than ASTM (facility-specific sampling method), the facility should
provide documentation to support and justify the use of the non-ASTM
method. In addition, complete documentation (for example, standard
operating procedures [SOP]) should be provided to support its rationale
for not using the U.S. EPA method.
• The most recent version of the reference source should be used for
sampling methods.
Compare sampling methods proposed in the TBP and RAWP with those
proposed in the WAP. Methods should be consistent, or at least
comparable, so that data obtained during the trial burn and the data
obtained day-to-day can be easily compared. Comparability becomes a
critical issue with regard to obtaining a representative sample. It is
imperative that a sound approach be used to obtain a representative
sample and that the approach used during the trial burn can be replicated
during normal operations.
• The method used to collect a representative sample varies depending on
the number of different feed streams sent to the combustion unit, and how
those streams are managed prior to firing. The U.S. EPA 1994 Waste
Analysis Guidances for Facilities that Burn Hazardous Waste offers
suggestions on sampling and analysis strategies. It explains different
approaches depending on whether the unit receives a variety of wastes in
batches versus a dedicated feed unit. It is strongly recommended that this
guidance be consulted before preparing a WAP.
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Example Situation: During her review of the Sampling Methods section of XYZ Company's Part B
permit application, Lois notices the following statement:
"All hazardous waste derived fuel for the BIF that requires testing and analysis
will be collected by the fuels technician from XYZ Company. Samples of
baghouse dust, kiln ash, and any nonhazardous fuels will be collected by
operations personnel."
Example Action: Lois notes that while this section describes sampling associated with hazardous
waste fuel, baghouse dust, kiln ash and nonhazardous fuels, it does not identify
and cite the sampling methods to be used to obtain a representative sample of each
material. In accordance with 40 CFR Part 264.13(b)(3), Part 261 Appendix IX,
Lois requests that XYZ Company revise this section to properly identify and cite
sampling methods to be used. She also requests that the XYZ Company document
that the chosen sampling method is appropriate for the type and nature of the
waste.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.2.4 Frequency of Analyses
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40CFRPart264.13(b)(4)
U.S. EPA. 1994. "Waste Analysis Guidance for Facilities that Burn Hazardous
Waste." EGA. Washington D.C. EPA 530-R-94-019. October. Section 3.0.
The WAP should describe the frequency of repetition for analysis.
The permit writer should check that:
• The frequency of sampling and analysis is clearly identified and justified.
• Any variances in the frequency of sampling and analysis depending on the
variability of feed streams to the unit is explained.
Any statistical analysis used in determining an appropriate sampling and
analysis frequency is completed in accordance with the procedures outlined in
U.S. EPA 1994 Waste Analysis Guidance for Facilities that Burn Hazardous
Waste.
In the WAP, XYZ Company states that the process waste stream used to supply fuel
to the boiler will be sampled and analyzed annually. In the RCRA Part B permit
application, XYZ Company discusses a possible process change prompted by recent
research results producing higher product yields than are produced by present
operations. Lois notes that no change in fuels sampling and analysis is proposed for
the process that will be modified.
Clark was reviewing the frequency of analysis section and noted that XYZ Company
proposed to prepare weekly composites of all waste streams received from a pesticide
manufacturing client. XYZ claims that it would be too time consuming and costly to
analyze every waste stream received from the pesticide company.
Lois wrote XYZ Company an NOD based on the frequency of analysis for a process
waste stream that may change. The NOD said that annual analysis was sufficient
with quarterly fingerprint analyses to confirm no process changes have occurred as
long as the process generating the waste did not change.
Clark wrote XYZ Company an NOD informing them that it was unacceptable to
composite samples from the pesticide manufacturer for weekly analysis. Clark
informed XYZ Company that the pesticide production process was too variable to
permit one composite sample to be analyzed. He suggested that XYZ Company
contact the pesticide manufacturer and develop a waste coding system so that samples
from each production process could be collected and analyzed separately. Clark stated
that, should the permitting authority express future concerns about the validity of the
samples or see that analysis was not showing anticipated variances, additional
sampling and analysis would be required.
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Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.2.5 Additional Requirements for Wastes Generated Off site
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40 CFR Parts 264.13(b)(5) and (c)
40CFRPart264.73(b)(l)
No specific references are applicable to this section of the manual.
The WAP should describe procedures used to inspect or analyze a representative
portion of wastes generated off site.
The permit writer should check that:
The application describes and justifies the facility's statistical method
used to determine a representative sample of incoming waste
• Procedures are in place to ensure that hazardous waste received matches
the accompanying manifest or shipping papers
For each shipment of drummed wastes received from off site, all drums with the
same generator/process/waste facility identification number will be gathered
together. In this way, XYZ Company can identify how many drums are part of
the same generating process. XYZ Company proposes in the WAP to sample 10
percent of each lot of waste by randomly sampling wastes and comparing the
fingerprint analytical results with the manifests to confirm that the total shipment
meets facility acceptance criteria.
Although Clark generally agrees with the concept of random sampling of drummed
waste, XYZ Company must offer some limitations. In
SW-846 provides examples on conducting a random number sampling event. It
also discusses the limitations of random sampling when only a few drums of a
certain waste are received. Clark wrote an NOD and suggested that XYZ
Company review the procedures described in SW-846 and revise the drum
sampling program accordingly.
Notes:
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5.2.6 Additional Requirements for Ignitable, Reactive, or Incompatible Wastes
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40CFRPart264.13(b)(6)
40 CFR Part 264.17
No specific references are applicable to this section of the manual.
The WAP should describe methods used to meet additional waste analysis
requirements necessary for treating, storing, or disposing of ignitable, reactive, or
incompatible wastes.
The permit writer should check that:
• The facility is able to identify wastes that fall into these categories and
take precautions to handle the waste appropriately and safely.
Clark reads the Additional Requirements for Ignitable, Reactive, or Incompatible
Wastes section of the facility's Part B permit application as follows:
"Before any transport container of liquid FiWDF can be unloaded, the
compatibility of its contents with the contents of the designated receiving vessel
will be verified according to the following procedure:
"A representative sample from each transport container will be mixed in a
container with a sample of the material in the vessel in an amount proportional to
the volume in the vessel. The mixture will be agitated, and a thermometer will be
used to measure any temperature change. The mixed sample will be observed
after 5 minutes to determine if any adverse reactions have taken place, particularly
polymerization or heat generation. If polymerization or a temperature increase of
10°C or more is observed, the FiWDF will be considered incompatible. The 5-
minute observation time is adequate to ensure that no polymerization reaction has
occurred. The 10°C temperature increase is large enough to indicate that a
reaction has occurred."
Clark agrees with the test for incompatibility and requests in an NOD that the
generation of gas be included as an observation. If gas is noted during a
10-minute reaction time, a reaction generating hydrogen or some toxic gas such as
hydrogen sulfide (H2S) may be occuring. If gas is observed, the facility must
review the manifest and existing analytical data to determine if any flammable or
toxic gases are being generated. Usually, temperature and polymerization are
sufficient to determine compatabiilty.
Notes:
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5.2.7 Additional Requirements Pertaining to Boiler and Industrial Furnaces
Regulation: 40 CFR Part 266.102(e)(6)(ii)(C)
40 CFR Part 266.102(e)(6)(iii)
Guidance: No specific references are applicable to this section of the manual.
Explanation: As stated in Section 5.1.8 of this component, regulations require characterization
for certain constituents. This information is needed to establish feed rates for each
constituent. The facility must propose a method for determining all feed rates for
which limits must be established. As a result, the sampling and analysis methods
outlined in the WAP, along with the feed rate monitoring method (to determine
mass flow rates), are used to establish feed rate limits.
Check For: • See Component 1—How to Review a Trial Burn Plan for additional
information regarding waste analysis requirements for BIFs
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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5.2.8 Additional Requirements Pertaining to Containment Buildings
Regulation: 40 CFR Part 264.1100
Guidance: RESERVED
Explanation: Because these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
5.3 WASTE ANALYSIS REQUIREMENTS PERTAINING TO LAND DISPOSAL
RESTRICTIONS
Regulation:
Guidance:
Explanation:
40 CFR Part 262.10
40 CFR Part 262.11
40 CFR Part 264.13
40 CFR Part 264.73
40 CFR Part 266.102(a)(2)(ii)
40 CFR Part 268
40CFRPart270.14(b)(3)
U.S. EPA. 1992. Federal Register. 57 FR 37194. August 18.
U.S. EPA. 1993. Federal Register. 58 FR 29860. May 24.
U.S. EPA. 1994. Federal Register. 59 FR 4790. September 19.
LDRs influence waste analysis requirements when waste is either shipped from an off
site source to a hazardous waste TSDF, or when residues from the facility are shipped
off site for treatment, storage, or disposal. LDRs require accompanying analytical
data for each that demonstrate whether the waste is a restricted waste, and if so,
whether it is properly managed under the LDRs at 40 CFR Part 268. Restricted
waste types and corresponding treatment standards vary greatly. As a result, the
process of determining whether LDRs apply and if so, what type of data is required, is
site specific. LDRs also require extensive documentation of waste characteristics and
how the waste is managed.
The operation of a hazardous waste combustion facility is affected by LDRs both in
receiving wastes and disposing of generated residues. These two situations are
described below.
When a hazardous waste combustion facility receives waste from off site, the waste
generator should have already conducted the analysis required to determine whether
LDRs apply and if so, whether the proposed waste treatment meets prescribed LDR
treatment standards. To ensure that the waste meets facility receiving criteria, the
receiving facility must implement independent waste analysis plan procedures.
However, the facility need not conduct LDR waste analysis in addition to the
generator's to determine whether LDR requirements are met. The receiving facility
should confirm that LDR-required notices and certifications that accompany the waste
are in order.
After the waste is treated in the combustion unit, the facility must then determine if
various residues generated (such as incinerator ash or scrubber wastewater) are
subject to LDRs. If so, the facility must submit the required notice and certification to
the land disposal facility (for example, a landfill receiving the ash) or the treatment or
storage facility (for example, an organics recovery process, such as distillation or
stream stripping, receiving the scrubber waste water). Extensive records must be
maintained to document compliance with LDRs.
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Because LDRs are a complex set of regulations, the Combustion Manual will not
expand on this discussion. The permit writer is encouraged to seek out more
detailed information in the guidance documents listed above specific to LDR
requirements.
Check For: Not applicable to this section of the manual.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.0
REVIEWING PROCESS INFORMATION—SECTION D
Regulations:
Guidance:
Explanation:
No regulations are applicable to this section of the manual
No specific references are applicable to this section of the manual.
This section normally appears as Section D in the permit application. A
corresponding process information section under Section D should be provided for
each of the various types of HWMUs located at the facility. Each section should
clearly describe how design, operation, and monitoring of the unit will comply
with applicable, unit-specific requirements.
The TBP normally appears as part of Section D. As a result, much of the
information required for the combustion unit process description is also required
for the TBP. Where applicable, the following subsections reference the
appropriate section of Component 1—How to Review a Trial Burn Plan, for
additional instruction regarding reviewing these overlapping parts of the Part B
application.
The following types of HWMUs listed under 40 CFR Parts 264 and 266 are
discussed:
• Containers, 40 CFR Part 264 Subpart I (see Section 6.1)
• Tank systems, 40 CFR Part 264 Subpart J (see Section 6.2)
• Incinerators, 40 CFR Part 264 Subpart O (see Section 6.5)
• Miscellaneous units, 40 CFR Part 264 Subpart X (see Section
6.8)
BIFs, 40 CFR Part 266 Subpart H (see Section 6.9)
• Air emissions from process vents, 40 CFR Part 264 Subpart AA
(see Section 6.12)
• Air emissions from equipment leaks, 40 CFR Part 264
Subpart BB (see Section 6.13.)
Air emissions from tanks, containers, and surface impoundments,
40 CFR Part 264 Subpart CC (see Section 6.14)
Photographs or diagrams of these HWMUs can be found at the end of this section.
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Check For:
COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
The following types of HWMUs listed under 40 CFR Part 264 are not discussed
in detail because they are not normally associated with combustion units:
• Waste piles (see Section 6.3)
• Surface impoundments (see Section 6.4)
• Landfills (see Section 6.6)
• Land treatment (see Section 6.7)
• Containment buildings (see Section 6.10)
• Drip pads (see Section 6.11)
The reviewer should check for the following:
Example Section:
When the HWMUs are located at a manufacturing facility, it is often
helpful to have information regarding manufacturing processes related to
the HWMUs.
The XYZ Company's permit application states that a BIF feed tank receives liquid
waste from four different production processes. Clark believes that for the safe
management and blending of these wastes it is necessary to understand the
processes associated with those four production processes. This information
would allow XYZ Company to better understand any variances that might occur
in the waste characteristics and how they might affect blending and BIF
operations. The generating company may be reluctant to provide this type of
process detail, mainly because some of this information is considered confidential
or proprietary. In these cases, XYZ Company should meet with the generating
industry and explain the reasons for requesting the information, and suggest that
XYZ Company would tailor the information in a manner that is not considered
proprietary.
Example Comments: Clark informed XYZ Company that if they could not reach an agreement with the
generators of the BIF fuel, the permit writer must handle the information
according to (CBI) requirements throughout the permit review period.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Boiler Unit
Tank System
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Container
Rotary Kiln
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Surface Impoundment
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.1 REVIEWING INFORMATION REGARDING CONTAINERS—40 CFR
PART 264 SUBPART I
Regulations:
Guidance:
Explanation:
40 CFR Parts 270.15 and 270.17
40 CFR Part 264 Subpart I and Part 264 Subpart CC
No specific references are applicable to this section of the manual.
This section provides guidance to permit writers on specific permit application
information requirements for the use and management of containers storing
hazardous waste. Facilities commonly store hazardous waste in containers prior
to treatment in the combustion unit. Specifically, this section discusses
requirements for (1) containment systems, (2) buffer zones, (3) incompatible waste
management, and (4) emission standards.
Containers storing hazardous waste containing free liquids, as defined by
40 CFR Part 260.10, or wastes listed as F020, F021, F022, F023, F026, or F027,
must have a containment system of sufficient volume to contain 10 percent of the
volume of containers or the volume of the largest container, whichever is greater.
The volume of the containment system must be adequate to account for
accumulated precipitation, unless runon controls are provided for the containment
system. The containment system must be designed to prevent containers from
contacting liquids either from leaks or precipitation. The base of the containment
system must be impervious to leaks, spills, or accumulated precipitation until
collected material is detected and removed. Permit applicants must provide
adequate documentation to demonstrate compliance with containment system
requirements.
Containers not storing wastes with free liquids need not be stored within a
secondary containment system, but the storage area must be designed to prevent
containers from contacting liquids. The permit applicant must provide
information to demonstrate that containers do not contain free liquids and a
description of how containers are kept from contact with standing liquids.
If the secondary containment system is subject to precipitation runon, the permit
applicant must describe how accumulated liquid will be removed. Analytical
procedures to determine whether the liquid is contaminated with hazardous waste
must also be described.
Permit applicants must also demonstrate that containers storing ignitable or
reactive hazardous wastes are located at least 15 meters from the facility's
property line. Containers storing ignitable or reactive wastes must be protected
from heat or other sources of ignition as required by 40 CFR Part 264.17(a).
Incompatible wastes must not be placed in the same container and must be
separated by a dike, berm, wall, or other device. The application must describe
container management procedures to prevent accidental ignition or reaction of
wastes in containers.
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Subpart CC of 40 CFR Part 264 describes requirements to prevent air emissions
from containers. Specific requirements are discussed in a separate section in this
guidance manual.
The permit application must contain sufficient information to allow the reviewer to
determine whether secondary containment has enough volume to hold the contents
of leaking containers plus precipitation. Container storage areas located outside
pose special challenges when determining whether the volume of the secondary
containment is adequate. The permit applicant must show calculations
demonstrating that the secondary containment storage capacity can hold potential
precipitation plus the volume needed to contain waste spills or leaks. Historical
records of local rainfall events are used to predict maximum 25-year, 24-hour
rainfall amounts. Historical precipitation records obtained from the National
Weather Service may represent a location different from the facility. Inaccurate
data can result in undersized secondary containment.
Check For:
Example Situation:
Example Action:
The permit writer should check:
• Whether containers store free liquids
• Whether secondary containment is impervious to liquids
• Whether the volume of secondary containment is adequate
• Whether a buffer zone for ignitable and reactive wastes has been provided
• Whether procedures to manage incompatible wastes are in place
• Whether emission controls or containers used to comply with air emission
requirements are provided
The XYZ Company hazardous waste management facility is located
approximately 100 miles from the nearest city where National Weather Service
precipitation records are kept. In addition, there are four cities surrounding the
XYZ Company facility all within the 100-mile range and all with different
precipitation amounts and 25-year, 24-hour rainfall events.
Clark recommended that XYZ Company immediately install rain gauges and
anemometers at the proposed facility. He further recommended that XYZ
Company construct the secondary containment surrounding the container storage
area to handle the largest 25-year, 24-hour event recorded at the four surrounding
cities.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.2 REVIEWING INFORMATION REGARDING TANK SYSTEMS—40 CFR PART 264
SUBPART J
Regulations:
Guidance:
Explanation:
40 CFR Parts 264.190, 270.16, and 270.27
No specific references are applicable to this section of the manual.
Facilities commonly store hazardous waste in tanks prior to treatment in the
combustion unit. This section provides guidance to permit writers regarding
information requirements for permitting tank systems at BIF facilities. This
section describes required (1) engineering descriptions, (2) secondary containment,
(3) operating controls, (4) reactive, ignitable, or incompatible waste storage, and
(5) air emission controls.
In addition to the detailed tank system requirements of 40 CFR Part 264.190,
permit applicants must provide a written assessment certified by an independent,
qualified, registered professional engineer that attests to the structural integrity
and suitability of the tank system to handle hazardous waste. The permit
application must also include a detailed description of dimensions and capacities
of each tank. Descriptions of feed systems, bypass, flow cutoff, and pressure
controls along with a diagram of piping, instrumentation, and process flows for
each tank must be included in the permit application. If the tank system is in
contact with soil or water, the permit applicant must describe materials and
equipment used to provide external corrosion protection as required by 40 CFR
Part 264.192(a)(3)(ii). If the tank system is not yet installed, the permit applicant
must describe in detail how the tank system will be installed to maintain
compliance with 40 CFR Part 264.192(b), (c), (d), and (e).
New tank systems (as defined by 40 CFR Part 260.10) storing liquid hazardous
wastes are required to have secondary containment designed, constructed, and
operated according to the standards in 40 CFR Part 264.193 (a), (b), (c), (d), (e),
and (f). Existing tank systems (as defined by 40 CFR Part 260.10) are required to
have secondary containment according to the schedule provided in 40 CFR Part
264.193. In either case, if secondary containment is required, the permit applicant
must provide information documenting that the secondary containment has enough
volume to contain 100 percent of the volume of the largest tank within its
boundaries, as well as precipitation from a 25-year, 24-hour rainfall event.
The permit applicant must also provide information describing operating methods
to prevent tank overfill and to prevent spills and leaks while transferring wastes to
or from the tank system. Specific operating requirements are found in 40 CFR
Part 264.194.
Similar to containers, procedures to manage ignitable, reactive, or incompatible
wastes in tanks must be included in the permit application. Specific requirements
are found in 40 CFR Parts 264.198 and 264.199. Subpart CC requirements
regarding air emissions from tanks are discussed in Section 6.9.
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Check For:
Example Section:
Example Comments:
The permit writer should check for:
• Detailed tank system description including materials of construction and
any applicable construction codes such as ASME or American Petroleum
Institute (API)
• Dimensions and tank capacities
• Feed system, bypass, and cutoff control descriptions
• Piping, instrumentation, and process flow diagram
• Ignitable, reactive, and incompatible waste management
• New or existing tank system
• Tank integrity assessment
• Secondary containment description
• Overflow and spill prevention
During their review, Lois and Clark noted that Subpart J of the XYZ Company
Part B permit application called for a roll-off box to be used as a container. The
application pointed out that the roll-off box was not portable, as it was planned to
be used as a stationary vessel. The application stated that hazardous waste would
be unloaded into the roll-off box from portable containers, mixed with sawdust,
and then used as a fuel in a BIF unit. The roll-off box meets the definition of
tanks described in 40 CFR Part 260.10. When reviewing the XYZ Company's list
of tanks at the facility, Lois noted that the roll-off box was not included.
Lois and Clark determined that according to the process described in the XYZ
Company Part B permit application, the roll-off box to be used as a fixed process
unit for blending hazardous waste meets the definition of a tank. The Part B
application was deemed inadequate because it did not provide a detailed
description of the dimensions and capacity of the roll-off box, as well as a tank
integrity assessment certified by an independent, qualified, registered professional
engineer. Lois and Clark required XYZ Company to describe in detail: (1)
methods to prevent spills and overflows; (2) procedures to prevent the accidental
ignition or reaction of hazardous waste in the roll-off box; (3) procedures to
prevent mixing incompatible wastes in the roll-off box; and (4) secondary
containment. Finally, Clark asked that XYZ Company further amend the
application to describe the roll-off box as a tank in the facility diagram and to
amend the Part A application to include the roll-off box in the list of tanks.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.3 REVIEWING INFORMATION REGARDING WASTE PILES—40 CFR PART 264
SUBPART L
Regulations: 40 CFR Parts 260.10 and 264.250
Guidance: No specific references are applicable to this section of the manual.
Explanation: Since these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.4 REVIEWING INFORMATION REGARDING SURFACE IMPOUNDMENTS—40 CFR
PART 264 SUBPART K
Regulations: 40 CFR Parts 260.10 and 264.220
Guidance: No specific references are applicable to this section of the manual.
Explanation: Since these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.5 REVIEWING INFORMATION REGARDING INCINERATORS—40 CFR PART 264
SUBPART O
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40 CFR Parts 264.340 through 264.351 and Parts 270.19
No specific references are applicable to this section of the manual.
This section normally appears as Section D-5 of the permit application. The bulk of
the information listed in this section is required to be submitted in support of the TBP
or RBP. The following subsections (see Sections 6.5.1 through 6.5.3) reference
applicable portions of Component 1—How to Review a Trial Burn Plan. Incinerator
regulations are augmented by several EPA-sponsored guidance documents. Therefore,
it is critical that permit writers become intimately familiar with pertinent guidance
documents.
The reviewer should check for the following:
• For facilities with more than one incinerator on site, ensure the application
makes a clear distinction among feed streams, operating protocols, and trial
burns or risk burns planned for each unit. Except when air modeling or a risk
assessment, each unit should be thoroughly reviewed independently of each
other, unless operations among them are related.
• Incinerator regulations are augmented by the BIF regulations under the
Omnibus Provision. This authority is granted by RCRA Section 3005 [40
CFR Parts 270.1 l(k) and 270.32(b)(2)] and allows U.S. EPA, in an effort to
protect human health and the environment, to request additional information
and apply guidance or appropriate regulation in addition to the incinerator
regulations. As a result, many BIF-specific regulations, such as establishing
feed rates for BIF-specific metals, are transferred onto incinerators.
Therefore, it is imperative that a permit writer for an incinerator be intimately
familiar with BIF regulations and guidance.
The XYZ Company application stated that the incinerator will comply with all
requirements listed in 40 CFR Part 264 Subpart O, applicable sections of 40 CFR
Parts 261, 268, and 270, and the incineration guidance documents.
Lois wrote an NOD requesting that the application be amended to state the incinerator
will also comply with requirements listed in the BIF regulations, 40 CFR Part 266,
and BIF guidance documents. The TBP, RBP, and other permit application
information should be revised as needed to incorporate these regulations and guidance.
Under the Omnibus Provision, U.S. EPA can request that facilities comply with
applicable regulation and guidance in an effort to protect human health and the
environment.
Notes:
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6.5.1 Justification for Exemption
Regulation: 40 CFR Part 264.340(b)
Guidance: No specific references are applicable to this section of the manual.
Explanation:
See Component 1—How to Review a Trial Burn Plan—Section 2.0, for additional
discussion.
A waste can sometimes qualify for an exemption from a trial burn. This
exemption is usually granted because the waste contains none of the hazardous
constituents listed in 40 CFR Part 261, Appendix VIII and because the waste is
listed as hazardous solely because it is ignitable, reactive, or corrosive. The
permit authority can exempt these wastes from a formal trial burn; however, the
permitting authority will likely still require a risk burn for the exempted wastes.
Check For: Not applicable to this section of the manual.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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6.5.2 Trial Burn
Regulation:
Guidance:
Explanation:
Check For:
40CFRPart270.62(b)(l)
No specific references are applicable to this section of the manual.
See Component 1—How to Review a Trial Burn Plan —Section 3.0, for
additional discussion.
All RCRA regulated combustion units must develop a TBP or RBP, conduct the
trial burn or risk burn, and pass the performance standards for the unit. TBPs and
RBPs are usually submitted as free standing documents but are part of the overall
Part B permit application.
TBPs must include detailed engineering descriptions of the combustion unit,
hazardous waste feed system, any APCS, automatic waste feed cutoff (AWFCO),
and stack gas and pollution control monitoring system. Complete TBP
information requirements are found in 40 CFR Part 270.62(b).
Component 1 of this manual details the specific informational requirements of a
TBP. Also, Attachment A to Component 1, U.S. EPA Region 6 Generic TBP,
outlines the format and content of a typical TBP.
The information requirements for permit applicants seeking a waiver from a trial
burn are essentially as extensive as those required for a TBP.
The permit writer should check for:
Detailed description of the combustion units
Detailed waste analysis
Description of AWFCO
Description of APCS (if applicable)
Description of process monitoring system
Waste feed rates
Production rates
Process operating parameters
Management of residues
• Determination of interim status or new combustion unit
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
• Trial burn waiver documentation
Direct transfer operations
Trial burn test protocol
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.5.3 Data Submitted in Lieu of Trial Burn
Regulation:
Guidance:
Explanation:
Check For:
40CFRPart270.19(c)
No specific references are applicable to this section of the manual.
See Component 1—How to Review a Trial Burn Plan —Section 4.0, for
additional discussion.
The regulations allow a facility with multiple combustion units to conduct a trial
burn on one unit and set operating limits for similar units. To be classified as
similar, the unit should use the same source of hazardous waste feed, have
identical dimensions, and have similar operating controls and comparable
continuous emission monitoring system (CEMS). All maintenance should also be
identical.
Even though the permitting authority may accept trial burn data from a different
combustion unit, a risk burn may be still required for each unit.
The permit writer should check for:
• Combustion unit dimensions
• Comparable operating conditions
• Use of the same hazardous waste feed and auxiliary fuel
• CEMS comparisons
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.6 REVIEWING INFORMATION REGARDING LANDFILLS—40 CFR PART 264
SUBPART N
Regulations: 40 CFR Parts 260.10 and 264.300
Guidance: No specific references are applicable to this section of the manual.
Explanation: Since these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.7 REVIEWING INFORMATION REGARDING LAND TREATMENT—40 CFR PART 264
SUBPART M
Regulations: 40 CFR Parts 260.10 and 264.270
Guidance: No specific references are applicable to this section of the manual.
Explanation: Since these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.8 REVIEWING INFORMATION REGARDING MISCELLANEOUS UNITS—40 CFR
PART 264 SUBPART X
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Parts 270.23 and 264.600.
No specific references are applicable to this section of the manual.
BIF facilities may conduct other treatment or disposal processes in units that are
most appropriately defined as miscellaneous units. Examples of potential
miscellaneous units are open burning/open detonation, carbon and catalyst
regeneration, shredders, filter presses, thermal desorption units, and can crushers.
Specific technical standards have not been developed for miscellaneous units;
therefore, this section discusses general permit application requirements found in
40 CFR Part 270.23.
Permit applicants are required to provide a detailed description of the
miscellaneous unit, including physical characteristics, construction materials, and
dimensions. Additionally, permit applicants must provide detailed plans and
engineering reports describing how the unit will be located, designed, constructed,
operated, maintained, monitored, inspected, and closed. For disposal units, the
permit applicant must submit a post-closure plan.
The permit applicant must also provide detailed hydrologic, geologic, and
meteorologic assessments, and land use maps for the region surrounding the
facility to demonstrate compliance with environmental performance standards
contained in 40 CFR Part 264.601. The permit application must also include
information on potential routes and the potential magnitude and nature of exposure
to humans or other environmental receptors of hazardous waste constituents.
Finally, for a treatment unit, the permit application must provide a demonstration
of treatment effectiveness.
The permit writer should check for the following:
• Detailed description of the miscellaneous unit
• Characteristics of wastes to be managed
• Compliance with environmental performance standards
• Potential exposure pathways
• Potential exposure magnitude
• Treatment effectiveness
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Example Section:
Example Comments:
XYZ Company noted in the Part B permit application that it intends to install and
use a material shredder in conjunction with a BIF unit. Lois was familiar with the
use of shredders in conjunction with an incinerator or a BIF and that they are
sometimes permitted as a miscellaneous unit. In her review of the XYZ Company
shredder, Lois noted that the application lacked detail on where the shredder was
to be located (indoors or outdoors), what type of material for shredding was
planned, what kind of explosion control system or spark abatement system would
be included, the location to which the shredder feed would discharge, and the size
of the discharged solids.
Lois wrote XYZ Company an NOD concerning the planned installation of the
material shredder. The NOD requested that XYZ Company identify the
manufacturer of the shredder, other applications of this type of shredder, the
design capacity of the shredder, and the power requirements and physical
dimensions of the shredder. Lois requested that the company describe:
(1) prevention of fires/explosions; (2) specific types of waste planned for the
shredder; (3) design of secondary containment system; (4) procedures for
prevention of shredding incompatible wastes; and (5) how the discharge would be
used as feed to the BIF and the heat content of the discharged shredded material.
Lois asked that the XYZ Company have an independent, qualified, registered
professional engineer review the operation and prepare a signed report on the
overall safety and feasibility of the operation including fugitive emissions control.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.9 REVIEWING INFORMATION REGARDING BOILER AND INDUSTRIAL FURNACE
UNITS—40 CFR PART 266 SUBPART H
Regulations:
Guidance:
Explanation:
40 CFR Part 270.22
40 CFR Part 270.66
40 CFR Part 266 Subpart H.
No specific references are applicable to this section of the manual.
This section normally appears as Section D-9 of the permit application and
provides guidance to permit writers on the information requirements specific to
BIF units. A BIF unit is defined in 40 CFR Part 260.10 and includes the
following types of units:
• Boilers
• Cement, lime, aggregate, and phosphate kilns
• Coke ovens
• Blast furnaces
• Smelting, melting, and refining furnaces
• Titanium dioxide chloride process oxidation reactors
• Methane reforming furnaces
• Pulping liquor recovery furnaces
• Combustion devices used to recover sulfur from spent sulfuric
acid
Certain halogen acid furnaces
Other similar devices burning hazardous waste to produce or
recover a product
Owners and operators of BIF units must conduct a compliance test and submit the
results in accordance with 40 CFR Part 270.66, except in certain circumstances.
If the permit applicant is operating a boiler under the specific requirements of 40
CFR Parts 266.104(a)(4) and 266.110 (described below), a trial burn to
demonstrate the DRE of the boiler is not required. To qualify for the DRE trial
burn waiver, the permit applicant must demonstrate that the boiler under
consideration meets all of the design and operating parameters specified in 40
CFR Part 266.110. These parameters include prohibitions against burning
hazardous wastes listed for dioxins, minimum fossil fuel firing rates of 50 percent,
minimum heat input to boiler of 40 percent of the maximum design heat input,
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minimum fuel heat value of 8,000 British thermal units per pound (Btu/lb), and a
carbon monoxide (CO) emission rate on an hourly rolling average (HRA) of no
greater than 100 parts per million by volume (ppmv) corrected to 7 percent oxygen
on a dry-gas basis. To qualify for the waiver, the applicant must meet further
restrictions on the design of the boiler and the physical characteristics of the fuel,
such as viscosity and particle size.
BIFs may qualify for a DRE trial burn waiver if, because of the type of hazardous
waste fuel burned, and the design and operation of the BIF unit, the unit meets the
low-risk waste exemption requirements of 40 CFR Part 266.109. Extensive
documentation, including emission dispersion modeling to demonstrate that
hazardous waste burning will not pose unacceptable adverse public health effects,
is required of permit applicants claiming a low-risk waste exemption. Permit
applicants who receive a waiver from the DRE standard also qualify for a waiver
from the particulate standard if Tier I or adjusted Tier I metals feed rate screening
limits are met. Permit applicants may also seek a waiver from a trial burn for
hydrogen chloride and chlorine provided that the facility complies with Tier I or
adjusted Tier I feed rate screening limits for chlorine and meets the additional
documentation requirements of 40 CFR Part 270.22(a)(5). BIF units most likely
to qualify for the low-risk waste exemption are located at facilities that burn only
hazardous wastes containing extremely low concentrations of metals, chlorine, and
ash. Facilities meeting these criteria may not automatically waive the requirement
to conduct a risk burn under the authority of 40 CFR Part 270.11 (k). Currently,
U.S. EPA recommends that site-specific risk assessments be conducted as part of
RCRA permitting for BIFs as being necessary to protect human health and the
environment.
Much of the specific information about the BIF unit that is required in the permit
application is related to the unit's performance during a trial burn. Permit
applicants may choose to submit data from a trial burn conducted at a similar unit
burning similar hazardous waste instead of conducting a trial burn at the unit for
which a permit is sought. If this option is chosen, data must be submitted in
accordance with 40 CFR Part 270.22(a)(6). For example, if a facility has two
identical boilers that burn the same waste stream, it is common to conduct a trial
burn on one unit, and use the data to develop permit conditions for both boilers.
Additionally, a facility may choose to submit past Certification of Compliance test
data in lieu of a trial burn. The permitting agency determines the adequacy of this
data and whether it meets trial burn and risk burn data requirements.
Other information required by 40 CFR Part 270.22 includes documentation
justifying an alternative hydrocarbon limit and an alternative metals
implementation approach, if applicable. Additionally, all permit applicants must
submit information describing AWFCO systems; direct transfer operations, if
applicable; and documentation to show that waste residues from the BIF unit are
excluded from regulation, if applicable.
Permit applicants seeking permits for new BIF units (those not operating under IS)
must follow the requirements of 40 CFR Parts 270.66(b) through 270.66(f).
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Permit applicants seeking a permit for a BIF unit operating under IS must follow
the requirements of 40 CFR Part 270.66(g). These regulations list specific
requirements for submitting TBPs and conducting trial burns.
Permit applicants must submit detailed information about the physical
characteristics of the waste, including heating value, viscosity, or physical form,
and a description of hazardous constituents listed in 40 CFR Part 261 Appendix
VIII. The description of hazardous constituents must be based on an analysis
conducted according to techniques specified in "Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods," U.S. EPA Publication SW-846, or
equivalent methods. Permit applicants must also submit a detailed description of
any waste blending processes in accordance with 40 CFR Part 270.66(c)(2)(iii).
Check For:
Example Section:
Example Comments:
See Section 6.5.2 of this component.
While burning hazardous waste, BIF units must be continuously monitored for
various parameters, including combustion chamber temperature. Temperatures
are difficult to accurately measure in the combustion chamber in certain types of
BIF units such as cement kilns because the harsh environment causes premature
failure of the temperature sensor. Several permit applicants have proposed using a
surrogate for combustion chamber temperature by measuring the temperature at
some other location. Initially, these applications contained inadequate
documentation to substantiate the claim that the surrogate temperature accurately
reflected the actual temperature.
Demonstrate that the temperature measured at the kiln chain section is directly
proportional to the combustion chamber temperature through the entire
temperature operating range. Provide actual comparative data as well as the
theoretical basis for using chain section temperature as a surrogate for combustion
chamber temperature.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.10 REVIEWING INFORMATION REGARDING CONTAINMENT BUILDINGS—40 CFR
PART 264 SUBPART DD
Regulation: 40 CFR Parts 260.10, 264.1100, 264.1101, and 264.1102
Guidance: No specific references are applicable to this section of the manual.
Explanation: Since these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.11 REVIEWING INFORMATION REGARDING DRIP PADS—40 CFR PART 264
SUBPART W
Regulations: 40 CFR Parts 260.10 and 264.570
Guidance: No specific references are applicable to this section of the manual.
Explanation: Since these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.12 REVIEWING INFORMATION REGARDING AIR EMISSIONS FROM PROCESS
VENTS—40 CFR PART 264 SUBPART AA
Regulation:
Guidance:
Explanation:
40 CFR Parts 264.1030 and 270.24
No specific references are applicable to this section of the manual.
Subpart AA of RCRA establishes air emission standards for process vents for
operations listed below that manage hazardous waste with an annual average total
organics concentration of 10 parts per million by weight (ppmw) or greater:
• Distillation
Fractionation
• Thin-film evaporation
Solvent extraction
Air stripping
Steam stripping
Photographs or diagrams of these process units can be found at the end of this
section.
A process vent is any open-ended pipe or stack that is vented to the atmosphere
either directly, through a vacuum-producing system, or through a tank (for
example, a bottoms receiver or a surge control tank). The emissions control
standard requires that facilities maintain total organics emissions below an
allowable level or that they install and operate control equipment to reduce total
organic emissions by 95 percent by weight. The rule does not require the use of
any specific types of equipment, but rather describes acceptable control equipment
and operating criteria. Various types of inspection, monitoring, recordkeeping,
and reporting are also required.
The process types listed above are not normally associated with combustion units;
they are more commonly found at hazardous waste recycling facilities.
Occasionally, these hazardous waste processes may be located at a manufacturing
site; however, it is more common that these same processes are considered to be
part of the manufacturing process handling an intermediate product.
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Check For: The reviewer should check to:
• Ensure that the process is one of the operations listed in the regulation;
otherwise, Subpart AA does not apply.
Ensure that the process is part of the hazardous waste treatment system;
otherwise, Subpart AA does not apply.
• If applicable, ensure that adequate information is provided to demonstrate
compliance with 40 CFR Parts 264.1030 and 270.24, Subpart AA.
If applicable, determine the number and location of all process vents, and
review the estimate of the fugitive emission rate for each source in
accordance with risk assessment protocol (see also Section 2.10 of this
component)
Example Section: Clark reads in the application that XYZ Company processes a stream through a
series of three distillation columns. XYZ Company assumes that Subpart AA
does not apply because the stream is not a hazardous waste.
Example Comments: Clark requests that the facility provide the following information to explain
whether Subpart AA applies:
Describe the stream being processed, in particular whether it is considered
a waste as defined by RCRA
• If the stream is a waste, then further describe if the waste is classified as
hazardous
If the stream is a hazardous waste, then determine if the annual average
total organic concentration of the waste is 10 ppmw or greater
• If the waste meets the greater than 10 ppmw criteria, the facility must
demonstrate that the emissions controls for the distillation columns meet
the standards prescribed in Subpart AA.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Distillation Columns
Solvent
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-4— t-
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S * Solvent 2
C R,xA , xs )
frj M
Solvent
Fractionation Process
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
y -S -I" e m
Thin-film Evaporation
feed
interface
extract
raffinate
Solvent Extraction
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Air Stripping Process
Steam Stripping Process
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.13 REVIEWING INFORMATION REGARDING AIR EMISSIONS FROM EQUIPMENT
LEAKS—40 CFR PART 264 SUBPART BB
Regulation:
Guidance:
Explanation:
40 CFR Parts 264.1050 and 270.25
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." U.S. EPA Region 6. EPA-R6-098-002. January.
Section 2.2. Page 2-2.
Subpart BB establishes standards for air emissions leaks from equipment that
contains or contacts hazardous waste streams with organic concentrations of
10 percent by weight or greater. The definition of equipment includes the
following:
• Valves
• Pumps
• Compressors
• Pressure relief devices
• Sampling connection systems
• Open-ended valves or lines
• Flanges
• Control devices or systems required under 40 CFR Part 264
Subparts AA, BB, or CC
Photographs or diagrams of these types of equipment can be found at the end of
this section.
After the affected equipment is identified, the facility is required to establish a
monitoring, inspection, and repair program to address all equipment and
corresponding requirements. Recordkeeping is an essential element of Subpart BB
standards and can require considerable effort, depending on the size of the facility.
The facility must submit a semiannual report that details the results of the
inspection and monitoring plan.
After a facility becomes subject to any one of RCRA Subparts AA, BB, or CC, it
is subject to the other two subparts, as long as the substantive requirements of that
subpart are met. For example, after a 90-day storage tank becomes subject to
Subpart CC, all pieces of equipment associated with that tank are subject to
Subpart BB if the hazardous waste in the tank has an organic concentration of 10
percent by weight or greater (the substantive requirement of Subpart BB).
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Check For:
Example Section:
Example Comments:
There are times when it is difficult to determine which pieces of equipment are
associated with a HWMU and which are associated with a process unit. This
problem is common with the transfer piping between a process vessel, such as a
process bottoms receiver, and a hazardous waste storage tank either feeding
directly to a BIF or acting as a surge tank prior to the BIF feed tank. The
applicant should address the transfer lines between the tank and the process unit
and identify the point at which the stream is first considered to be a "waste."
From that point on, it can be assumed that the equipment, transfer lines, and
storage vessels are subject to any applicable RCRA air emission standards.
• An inventory of all affected equipment should be provided with the
application [see 40 CFR Part 264.1064(b)]. The inventory should list the
following:
• Equipment type, identification number, and FiWMU identification
Location within the facility
• Material service (gas/vapor or heavy or light liquid)
Documentation of (or assumption that) the material has an
organic concentration of 10 percent by weight or greater
Compliance method
Additional information is required for each type of equipment.
An inspection, maintenance, and monitoring plan should be included in the
application. The plan should include methods of inspections, log forms to
be completed on inspection, and a demonstration that the proposed plan
complies with the requirements specified in the regulation.
• An estimate of the fugitive emission rate for each piece of equipment, in
accordance with the risk assessment protocol (See Section 2.10 of this
component).
In reviewing the XYZ Company submission regarding 40 CFR Part 264
Subpart BB—Air Emission Standards for Equipment Leaks, Lois noted that the
company did not submit an inspection checklist for pumps to be used in hazardous
waste transfers. She further noted that XYZ Company did not indicate how it will
determine if equipment used for hazardous waste is leaking other than noticing the
spill after major component failure has occurred. Lois refers the deficiency to
Clark to develop the NOD.
The full text submitted by the facility discusses air emission standards for
equipment leaks and benzene operations and generally states that the facility will
comply with the requirements of 40 CFR Part 264 Subpart BB and Part 61
Subpart FF for equipment leak detection monitoring, recordkeeping, corrective
action, and reporting. However, Clark notes that these sections do not explain
how the equipment and components will be identified or how leaks are detected,
measured, and controlled. These sections should clearly explain procedures
implemented to comply with standards for equipment leaks and benzene
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
operations, and Clark asks that the facility revise these sections accordingly.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Valve
Pump
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
ImBteoolsr
CrankcaselFTamsi
Compressor
Second Sutge Cylinrfei
Pressure Relief Valve
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Sampling Connection System
Open-ended Line
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Control System - Carbon Beds
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.14 REVIEWING INFORMATION REGARDING AIR EMISSIONS FROM TANKS,
SURFACE IMPOUNDMENTS, AND CONTAINERS—40 CFR PART 264
SUBPART CC
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Parts 264.1080 through 264.1090 and 270.27
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." U.S. EPA Region 6. EPA-R6-098-002.
Section 2.2.
This regulation establishes air emission control requirements for containers (also
regulated under 40 CFR Part 264.170 Subpart I—Use and Management of
Containers); tanks (also regulated under 40 CFR Part 264.190 Subpart J—Tank
Systems); and surface impoundments (also regulated under 40 CFR Part 264.220
Subpart K—Surface Impoundments) that treat, store, or dispose of hazardous
waste. Various scenarios are listed that provide exemptions from the regulation,
which should be explored as part of the applicability determination.
Corresponding standards or control levels apply to each of the three HWMUs
listed above. The control level varies depending on the waste managed within the
unit and the volume of the tank or container. Because surface impoundments are
not normally associated with combustion units, those technical requirements will
not be discussed in this component.
Because this regulation is recent, many facilities may not be familiar with the
technical, recordkeeping, and reporting requirements. As a result, many
applications may be deficient. To promote a more complete application, the
permit writer should draft the NOD to request specific information, as identified
by the regulation.
After a facility becomes subject to any one of RCRA Subparts AA, BB, or CC, it
is subject to the other two subparts as long as the substantive requirements of that
subpart are met. For example, after a 90-day storage tank becomes subject to
Subpart CC, all pieces of equipment associated with tank are subject to Subpart
BB if the hazardous waste in the tank has an organic concentration of 10 percent
by weight or greater (the substantive requirement of Subpart BB).
The Part B permit application should include the following subsections:
• Applicability
• Exemptions
• Tank standards
• Surface impoundments
• Container standards
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Closed-vent systems and control devices
• Inspection and monitoring
Recordkeeping
The reviewer should check for the following:
An inventory listing all tanks and containers (including less-than-90-day
storage units), their design capacity, waste managed and its
characteristics, location at the facility, and any emission control devices
used
• If control devices are currently used, specific and detailed information is
required to demonstrate that the device meets the control standards listed
40 CFR Parts 264.1033 and 264.1087(c)(l)
• This regulation is considered "self-implementing" and became effective on
December 6, 1996. For existing facilities, physical emission control
requirements were to be in place by that date. If the facility was not able
to meet that date, an implementation schedule was to be in place that
documented how the controls will be installed and operating by December
8, 1997 (See 40 CFR Part 265.1082). However, if the permit is either
reopened or an initial RCRA permit is under consideration, the facility
should propose and attempt to install the required emission controls on
issuance of the RCRA operating permit if issuance is expected prior to
December 8, 1997. However, 40 CFR Part 270.27(a)(7) states that if the
facility cannot comply with Subpart CC by the date the permit is issued
(if issued before December 8, 1997), the facility may extend the
compliance date to December 8, 1997, or later, on a case-by-case basis, at
the discretion of the U.S. EPA Regional Administrator, see 40 CFR
Part 265.1082(c), or authorized state permitting agency director.
• For new facilities, applicable air emission control requirements must be in
place on facility startup. Existing facilities that do not meet IS
notification and operating requirements must be permitted as new facilities
and cannot manage hazardous waste in the affected units until a permit is
issued and all applicable air emission control requirements are in place.
• Fugitive emission rate must be estimated for each affected unit, in
accordance with the risk assessment protocol (See Section 2.10 of this
component).
Example Section: Continuing her review of the facility's Part B permit application, Lois reads as
follows:
"Hazardous waste derived fuel (HWDF) is supplied to feed lines from a central
charging column (similar to a surge tank) that is loaded (charged) intermittently on
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
demand."
Example Comments: It is unclear to Lois which tank or tanks are used as feed tanks to the kilns.
Portions of the text indicate that some of the storage tanks can be fed directly to
the kiln (not including any direct transfer facilities). However, the application
states that HWDF is supplied to kiln feed lines from a central charging column
that is filled intermittently on demand. Lois asks that the facility revise this
section to clearly explain which tanks are used as direct feed tanks to the kiln and
which tanks are used for HWDF storage before being sent to the kiln feed tanks.
This issue is important with regard to applicability of and compliance with the
Subpart CC regulations.
Notes:
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6.14.1 Applicability
Regulation: 40 CFR Part 264.1080
Guidance:
Explanation:
Check For:
Example Situation:
No specific references are applicable to this section of the manual.
Before technical requirements for an affected unit can be determined, an
applicability determination must first be made. Subpart CC standards apply to
TSDF owners and operators subject to RCRA Subtitle C permitting requirements,
and to certain hazardous waste generators accumulating waste on site in permit-
exempt tanks and containers. Specifically, the rule applies to TSDFs that manage
hazardous waste in tanks, surface impoundments, or containers subject to either
Subparts I, J, or K of RCRA. Examples of RCRA permit-exempt tanks and
containers that are subject to Subpart CC include containers and tanks used to
accumulate hazardous waste on site for 90 days or less, pursuant to 40 CFR Part
262.34(a). However, satellite accumulation areas operated by generators under 40
CFR Part 262.34 are not subject to the Subpart CC standards.
Attachment F to this component provides a logic diagram for determining the
applicability of RCRA Subpart CC air emission control standards to FiWMUs. It
is recommended that this logic diagram guide the review of the information
presented in the permit application.
The reviewer should check for the following:
• A specific set of conditions must be satisfied to quality for each
exemption. The facility is responsible for demonstrating compliance with
these conditions. If a unit appears to meet one of the exemptions, it is
imperative that all information required to demonstrate that the exemption
is merited be provided. If a unit is considered to meet an exemption but
some of the information provided in the permit is discovered during an
inspection or other future facility review to be incorrect or inaccurate, the
facility will be held accountable for noncompliance during the regulated
operating life of the unit. The likelihood of a facility claiming an
unsupported exemption for a unit is greater during IS because U.S. EPA
is not required to review facility information on Subpart CC. Therefore,
this situation may first be discovered during the permit application review.
The unit must first be subject to Subparts I, J, or K, and the waste must
contain an average volatile organic concentration of greater than 500
ppmw at the point of waste origination.
Ninety-day storage tanks and containers must comply with air emission
standards under Subpart CC—they are not exempt from this regulation.
In reviewing the Applicability section of XYZ Company's Part B permit
application, Lois notes that the facility operates a tank used for bulk feed of an
incinerator. The facility claims that Subpart CC does not apply. Lois also noticed
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Example Action:
that the facility failed to mention any tanks or containers used for 90 days or less
and how those units would comply with Subpart CC.
While Subpart CC applies to incinerator feed tanks, these tanks might fulfill the
requirements for an exemption from air emissions control standards listed in 40
CFR Part 264.1082(c)(5). The exemption conditions state that the tank must be
located in an enclosure vented to a control device. This exemption allows the tank
to forego emission control standard requirements. However, the control device
(regulated under 40 CFR Part 264.1087) is required to undergo inspections and
monitoring according to a written plan, as required under 40 CFR Part
264.1088(b). Lois asks that the facility revise this section to demonstrate
compliance with exemption requirements, if applicable.
Lois also reminded the facility that tanks or containers used for 90 days or less
must also comply with Subpart CC requirements. She pointed out that
compliance with the air emission controls could be as simple as using U.S.
Department of Transportation (DOT)-approved containers and fixed roof tanks.
She advised the facility to revise the application to address tanks and containers
used for 90 days or less.
Notes:
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6.14.2 Exemptions
Regulation: 40 CFR Part 264.1082
Guidance:
Explanation:
Check For:
Example Section:
No specific references are applicable to this section of the manual.
A unit may be exempt from Subpart CC standards for a variety of reasons; 40
CFR Parts 264.1080(b) and 264.1082(c), as well as the logic diagram
(Attachment F of this component), list various exemptions.
Rigorous waste determination procedures outlined in 40 CFR Part 264.1083(a)
and (b) must be followed when attempting to demonstrate certain exemptions from
the regulation. These procedures are detailed and must be followed closely to
obtain acceptable data.
The waste determination procedures identified in 40 CFR Part 264.1083(a) and
(b) are necessary only if the facility wishes to pursue an exemption. If a facility
does not wish to pursue an exemption, it has only to address the unit's
applicability based on design capacity and knowledge of the managed waste, and
to provide any analysis [for example, 264.1083(c) or (d)] required under the
emission control standard. The facility should also discuss how the design
operation of the unit complies with the applicable standard.
The reviewer should check for the following:
• The application should clearly identify any exemptions the applicant is
pursuing
The application should identify and demonstrate compliance with each
requirement specified by the exemption
• Waste determination procedures should be followed as specified in the
regulation. Any deviation should be clearly explained and justified
A facility manages 60 5 5-gallon containers in a RCRA-permitted container
storage area. The containers manage waste from about 20 different sources. The
containers are not used for treatment using a waste stabilization process. The
facility suspects that the average volatile organic concentration is about 500
ppmw. Because use of DOT-approved containers, packaging, and handling
methods complies with both container Levels 1 and 2 standards (see
Section 6.14.5 of this component), the facility could assume that the waste
contains an average volatile organic concentration greater than 500 ppmw and
state that it will use DOT containers and handling methods, thereby demonstrating
compliance with Subpart CC standards.
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Example Comments: XYZ Company contacted each of the 20 companies that supply the 60 55-gallon
containers stored in the RCRA-permitted storage area. Each company was
requested to provide documentation that the process produces a waste stream with
a volatile organic concentration greater than 500 ppmw. With the results supplied
by each company, XYZ Company would justify use of DOT containers and
handling methods, thus demonstrating compliance with Subpart CC standards. In
this way, XYZ Company was spared the cost and effort of conducting extensive
waste analysis for 20 separated waste streams to demonstrate compliance with the
regulation.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
6.14.3 Tank Standards
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 264.1084
No specific references are applicable to this section of the manual.
Two levels of air emission controls exist for tanks. Attachment F to this
component presents the two levels of control. Control level is determined by
(1) the tank capacity, (2) the maximum organic vapor pressure of the hazardous
waste managed in the tank, (3) whether the waste is heated, and (4) whether the
waste is treated using a waste stabilization process. The options that determine
control levels require specific information on design criteria and operating
protocols. In addition, specific inspection and monitoring requirements apply to
the two control options.
In general, the tank may be opened to the atmosphere during routine inspection,
maintenance, sample collection, or other activities needed for normal operation.
Also, pressure relief valves may open during normal operations to maintain
internal tank pressure. Finally, a safety device may be opened at any time to avoid
an unsafe condition.
The reviewer should check for the following:
• A complete and clear description of the waste managed in the tank, along
with the tank design criteria and operating protocols
Tank capacity
Maximum organic vapor pressure of hazardous waste to be managed in
the tank
• The expected maximum temperature of waste in the tank
• Design of vapor control system proposed for the tank
• Estimated fugitive emission leak rate of vapor from the tank
• Inspection and maintenance program for vapor control system
XYZ Company's permit application states, "In accordance with Tank Level 1
controls, the 100 cubic meters (m3) tank is equipped with a fixed roof."
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Example Comments: The application should be revised to more clearly demonstrate compliance with the
RCRA Subpart CC air emission standards for tanks. For a 100 m3 fixed roof tank
to meet Tank Level 1 standards, the maximum organic vapor pressure of the waste
must be less than 27.6 kiloPascals (kPa). The application should provide vapor
pressure information in accordance with the maximum organic vapor pressure
determination procedures outlined in 40 CFR Part 265.1084(c).
Notes:
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6.14.4 Surface Impoundment Standards
Regulation: 40 CFR Part 264.1085
Guidance: No specific references are applicable to this section of the manual.
Explanation: Since this unit is not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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6.14.5 Container Standards
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 264.1086
No specific references are applicable to this section of the manual.
Three levels of air emission controls exist for containers. Attachment F to this
component presents the three levels of control. Air emission control levels are
determined by (1) container capacity, (2) whether the container is in light material
service, and (3) whether the waste is treated using a waste stabilization process.
The options that determine control levels require specific information on container
design criteria, handling and packaging procedures, operating protocols, and
emission control device specifications. In addition, specific inspection and
monitoring requirements apply to three control options.
The regulation allows periods of uncontrolled emissions venting. In general, the
container may be opened to add hazardous waste or other material, remove
hazardous waste, or obtain access inside the container when routine activities
other than waste transfer are required. Pressure relief valves may open during
normal operations to maintain container integrity. Finally, a safety device may be
opened at any time to avoid an unsafe condition.
The reviewer should check for the following:
Container capacity
Container service
Waste stabilization procedures, if applicable
Handling procedures for drums
Operating protocols
• Emission control specifications
Inspection and monitoring program
Estimated fugitive emission rate from each container
Drum material transfer procedures
Clear presentation of waste to be managed in the containers
The XYZ Company permit application states, "The drummed hazardous wastes
are managed in industry standard containers. The average volatile organic
concentration is assumed to be greater than 500 ppmw."
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Example Comments: The application should be expanded to more clearly explain the type of containers
that are used to manage hazardous waste. In particular, the information should
respond to requirements listed in RCRA Subpart CC for air emission controls
standards for HWMUs. Because the average volatile organic concentration is
assumed to be greater than 500 ppmw, either Container Level 1 or 2 standards
must be instituted. The statement "industry standard containers" does not specify
the type of container, nor does it demonstrate compliance with Subpart CC
requirements.
Notes:
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6.14.6 Closed-Vent Systems and Control Devices Standards
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40 CFR Part 264.1087
No specific references are applicable to this section of the manual.
Regulations describe various types of closed-vent systems and control devices.
Basic design criteria are defined in 40 CFR Part 264.1033. Operating protocols,
inspection, and monitoring requirements are specified depending on the type of
control device employed.
It is common at hazardous waste combustion facilities to route emissions from
hazardous waste storage tanks to the combustion chamber for organics emission
control. This method is accepted under control device standards.
The reviewer should check for the following:
• Type of closed-vent system
• Control devices installed on vent system
• Inspection and monitoring program
• Whether volatile emission vent system is connected to the combustion unit
• How volatile emissions are controlled when the combustion unit is not
operating
The capacity of the volatile emission collection/control system that is used
when the combustion unit is not operating
The XYZ Company application states that volatile organic emissions from
hazardous waste storage tanks in tank farm HW-10 are collected through a
common manifold system routed to the combustion unit through the combustion
air blower. These tanks are exempt from Subpart CC standards because they are
used for bulk feed of hazardous waste to a combustion unit; see 40 CFR Part
264.1082(c)(5).
Lois requests that the application be revised to demonstrate compliance with
RCRA Subpart CC air emission control standards for hazardous waste storage
tanks in tank farm HW-10. It appears from earlier information that these tanks
are not feed tanks for the combustion unit; rather, these tanks store hazardous
waste immediately prior to the actual feed tank. As a result, these tanks do not
qualify for an exemption under 40 CFR Part 264.1082(c)(5). The application
should explain how the manifold system and combustion unit meet the
requirements for a closed-vent system and control device under 40 CFR
Part 264.1087.
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Notes:
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6.14.7 Inspection and Monitoring Requirements
Regulation: 40 CFR Part 264.1088
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section requires that a written plan be developed and implemented for the
inspections detailed in the unit-specific standards (40 CFR Parts 264.1084
through 264.1087).
Check For: The reviewer should check for the following:
• An inspection and monitoring plan
Example Section: Clark noticed that in XYZ Company's Part B application, there is no mention of
inspection and monitoring for containers or tanks subject to Subpart CC.
Example Comments: Clark requested that XYZ Company's application be amended to include the
inspection and monitoring requirements in 40 CFR Part 264 regarding Subpart
CC standards. The requirements vary depending on the individual hazardous
waste management unit (tanks or containers) and control devices (for example,
internal floating roof or combustion device).
Notes:
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6.14.8 Recordkeeping Requirements
Regulation: 40 CFR Part 264.1089
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
No specific references are applicable to this section of the manual.
In general, records need only be maintained if a physical air emission control
(either an internal floating roof or emission control device) is used to comply with
regulations. Waste analysis results, either for waste determination or vapor
pressure, should also be maintained in the facility operating record.
The reviewer should check for the following:
• Type of device that requires records
• Existence of a plan to manage and store the records
Clark noted that the XYZ Company's application states that waste determination
procedures and results are recorded and maintained in accordance with the RCRA
Subpart CC requirements.
Clark requested that the application discuss how the recordkeeping procedures
demonstrate compliance with the RCRA Subpart CC requirements listed in 40
CFR Part 264.1089. Recordkeeping requirements are specific to the hazardous
waste management unit and control device employed. In addition, the application
should confirm that records will be maintained in the facility operating record for a
minimum of 3 years. Air emission control equipment design documentation must
be maintained in the operating record until the air emission control equipment is
replaced or otherwise no longer in service.
Notes:
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6.14.9 Reporting Requirements
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 264.1090
No specific references are applicable to this section of the manual.
Written reports are required only if a noncompliance event has occurred; for
example, an exempt unit managed waste with an average volatile organic
concentration greater than 500 ppmw, or treated hazardous waste failed to
achieve applicable requirements. Written reports are also required if a control
device failed to operate in compliance with permit conditions for 24 hours or
longer or a flare operated with visible emissions for 5 minutes or longer.
The reviewer should check for the following:
Ensure that the application addresses the RCRA requirement for
reports and how the information required in the reports will be
gathered through the site inspection plan
In the XYZ Company application, there is no mention of reporting in response
to RCRA Subpart CC. As a result, Lois was unsure whether the company was
unaware of reporting requirements or whether the reporting did not apply.
Example Comments: Lois recommended that the application be augmented to discuss the reporting
requirements required under RCRA Subpart CC. The application should
explain the circumstances that will dictate a reporting event and when the
reports will be submitted.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
7.0 REVIEWING GROUNDWATER MONITORING SYSTEM
INFORMATION—SECTION E
Regulations: 40 CFR Part 270.14(c) and 40 CFR Parts 264.90 through 264.100.
Guidance: No specific references are applicable to this section of the manual.
Explanation: Requirements for groundwater monitoring information that must be included in the
permit application is found in 40 CFR Part 270.14(c). Groundwater monitoring
regulations are not applicable to BIF units; however, if the facility also has a
surface impoundment, waste pile, land treatment unit, or landfill that receives
hazardous waste after July 26, 1982, specific regulations in 40 CFR Parts 264.90
through 264.100 apply to those regulated units.
Check For: Not applicable to this section of the manual.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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8.0
REVIEWING PROCEDURES TO PREVENT HAZARDS—SECTION F
Regulations:
Guidance:
Explanation:
40 CFR Parts 270.14(b), 270.14(b)(5), 270.14(b)(6), 274.14(b)(8), 270.14(b)(9),
270.15, and 270.16
40 CFR Part 264
40 CFR Parts 266.102(e)(8), 266.111(e)(3), and 266 Appendix IX.
No specific references are applicable to this section of the manual.
This section provides guidance to permit writers on information requirements for
permit applications for prevention of hazards. Specifically, this section describes
(1) security procedures and equipment, (2) inspection procedures, (3)
preparedness and prevention procedures, (4) general hazard prevention
procedures, and (5) accidental ignition or waste reaction prevention.
Title 40 CFR Part 270.14(b)(4) requires the permit applicant to describe security
procedures and equipment specified in 40 CFR Part 264.14 or to provide
justification for requesting a waiver from these requirements. In general, security
must be adequate to prevent or minimize the unknowing or unauthorized entry of
persons or livestock onto the active portion of the facility. The permit application
must include either a description of a 24-hour surveillance system to continuously
monitor or control access to active portions of the facility or, if such a system is
not feasible, a description of a barriers system with controlled entries to active
portions of the facility. For most facilities with BIF units, this requirement can be
met through the use of a fence of adequate height, either alone or in combination
with a natural barrier, such as a cliff, around the active portion of the facility.
Additionally, warning signs must be posted at all approaches to the active portion
of the facility in all languages commonly spoken in the geographic area. A request
for a waiver from these requirements must demonstrate that unknown or
unauthorized contact with waste is not harmful and that disturbance of waste or
the waste management equipment will not result in a violation of 40 CFR Part
264. Situations in which a waiver from these requirements is appropriate are
expected to be extremely rare, and requests for such a waiver must include a
detailed risk analysis to demonstrate that security provisions are not necessary.
Title 40 CFR Part 270.14(b)(5) requires the permit applicant to provide a general
inspection schedule to fulfill the requirements of 40 CFR Parts 264.15, 264.174,
and 264.195. Inspection requirements specific to BIF units are found in 40 CFR
Parts 266.102(e)(8), 266.1 l(e)(3), and 266 Appendix IX. This schedule must be
submitted in the permit application and should include a description of the
equipment to be inspected and define inspection frequency. Additionally, the
permit applicant must state how deteriorations or malfunctions will be remedied.
A log of these inspections must be kept for at least 3 years. Facilities with
combustion units commonly include regulated container or tank storage units.
Container storage areas must be inspected weekly for leaking containers or
evidence of container or containment system deterioration caused by corrosion or
other factors. Hazardous waste storage tanks, related ancillary equipment, and
secondary containment systems must be inspected once each operating day to
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detect corrosion and hazardous waste releases. Combustion units and associated
equipment must be inspected each operating day for leaks, spills, fugitive
emissions, and signs of tampering. Direct transfer equipment must be inspected at
least once each operating hour when hazardous waste is being transferred from the
transport vehicle (container) to the combustion unit. CEMS must be inspected
daily to ensure proper operation. Additionally, CEMS must be subjected to a
daily calibration drift (CD) test, quarterly calibration error (CE) test, and an
annual performance specification test. Additional monitoring and inspection
procedures may apply to demonstrate compliance with permit conditions relating
to the monitoring, verification, or control of fugitive emissions made to complete
the risk assessment.
Title 40 CFR Part 270.14(b)(6) requires a permit applicant comply with
preparedness and prevention requirements contained in 40 CFR Part 264 Subpart
C or submit a request for a waiver from preparedness and prevention
requirements. Preparedness and prevention requirements include proper design
and operation of the unit to prevent releases of hazardous waste constituents, and
provision of an internal communication or alarm system for summoning
emergency response personnel, fire fighting equipment, and spill control
equipment. The owner or operator is required to test and maintain all equipment
and systems required to respond to emergencies and to attempt to make
arrangements to familiarize local authorities with waste characteristics treated at
the unit and potential hazards posed by such wastes. If the permit applicant
requests a waiver from preparedness and prevention requirements, a justification
for this request must be included in the permit application. As with requests for
waivers from security requirements, conditions that justify a waiver from
preparedness and prevention requirements are extremely rare.
Requirements for general hazard prevention are specified in 40 CFR Part
270.14(b)(8). For combustion units, in general, the permit applicant must address
hazards related to (1) loading and unloading of ignitable or toxic waste,
(2) potential contamination of water supplies by runoff during occasional flooding,
(3) potential releases from equipment failure or power outages, and (4) exposure
of facility personnel to hazardous wastes from equipment maintenance or
operation. Repairing or replacing pumps and lines containing hazardous waste at
combustion units pose a threat of release to the environment or of exposure to
maintenance personnel. The permit applicant must identify all hazards involved in
these operations and the steps that will be taken to prevent these hazards.
Title 40 CFR Part 270.14(b)(9) requires the permit applicant to describe
precautions to prevent accidental ignition or reaction of ignitable, reactive, or
incompatible wastes. Specific regulatory requirements that must be met are found
in 40 CFR Part 264.17. Ignitable wastes must be separated and protected from
ignition or reaction sources. The permit applicant must describe precautions that
will be taken to prevent uncontrolled fires, explosions, or other violent reactions
and precautions to prevent damage to the integrity of the combustion unit.
Provisions must be included for physical separation of ignitable wastes, either by
distance or engineering controls such as berms or other barriers, to prevent
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commingling of incompatible wastes. Incompatible wastes are not commonly
burned in combustion units; however, if they are, permit applicants must describe
precautions to be used to prevent hazardous reactions in pipelines, tanks, or in
combustion units. Precautions may include methods to flush pipelines or to
provide separate pipelines to combustion units.
Check For:
The reviewer should check for the following:
• Security procedures
• Inspection procedures
• Preparedness and prevention procedures
• General hazard prevention procedures
• Accidental ignition or waste reaction prevention
• Posting of signs at appropriate points
• Control of deterioration or malfunctions, to the extent possible
• Container inspection schedule and record
• Pump, piping, joints, and flange inspection and record
• Inspection of direct transfer equipment and record
• Arrangements with local fire and emergency authorities
BIF units may burn either solid or liquid hazardous wastes as fuel. Current
technology also promotes the blending of certain types of solid hazardous wastes
with liquids to yield a pumpable hazardous waste fuel. Both solid and liquid
waste fuels containing solids tend to be abrasive to pipelines and may cause wear,
resulting in leaks or releases to the environment.
Example Comments: The application should demonstrate that the BIF unit will be subject to thorough
visual inspections (at least daily) when it contains hazardous waste for signs of
leaks, spills, fugitive emissions, and tampering.
Notes:
Example Section:
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9.0
REVIEWING CONTINGENCY PLANS—SECTION G
Regulations:
Guidance:
Explanation:
40CFRPart270.14(b)(7)
40 CFR Part 264.50
No specific references are applicable to this section of the manual.
A contingency plan must be included in the permit application, as
specified in 40 CFR Part 270.14(b)(7); regulatory requirements for the
contingency plan are specified in 40 CFR Part 264 Subpart D.
The purpose of the contingency plan is to minimize hazards from fires, explosions,
or unplanned releases of hazardous waste or hazardous constituents. The plan
should be implemented whenever a fire, explosion, or a release of hazardous waste
constituents threatens human health or the environment. The contingency plan
must specify (1) the facility's emergency response team and emergency response
coordinators by name, address, and telephone numbers; (2) arrangements the
facility has made with local authorities and emergency response teams; (3) types
and locations of emergency equipment kept at the facility; (4) an evacuation plan
for facility personnel; and (5) the locations of copies of the contingency plan at the
facility. The contingency plan must be updated and amended, as necessary, and
must be made available to all personnel who may be involved in emergency
response actions.
The contingency plan must include descriptions of the following:
• Procedures for the emergency coordinator to alert all facility
personnel in case of emergency and to notify state and local
agencies
• Plans for the emergency coordinator to identify the character,
source, amount, and areal extent of any explosion, fire, or release
Means to assess possible hazards to human health or the
environment from an explosion, fire, or release
• Procedures for the emergency coordinator to respond to fires,
explosion, or releases of hazardous wastes at the facility
Provision for treatment, storage, and disposal of released material
Recordkeeping and reporting to U.S. EPA or an authorized state
each time the facility implements its contingency plan
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Combustion units commonly operate 24 hours a day, 7 days a week, and an
emergency coordinator must be either at the facility at all times or be able to
respond within a short time. To facilitate contact, both home and office phone
numbers and addresses of emergency coordinators must be included in the
contingency plan.
Wastes managed at facilities with combustion units are often ignitable and may
also be corrosive, reactive, or toxic. Special precautions must be taken when
responding to fires, explosions, or hazardous waste releases. In the event of an
emergency, to ensure quick response, the contingency plan must describe
arrangements with local authorities. For example, emergency response
capabilities of each potential emergency response team should be described, as
well as how and where the emergency response team will receive detailed
instructions from the emergency coordinator. Permit applicants often do not
describe in detail where the off site emergency response teams are to meet the
emergency coordinator. Specific arrangements should be described in the
contingency plan, such as " The emergency coordinator will meet the fire
department at Gate B" or "The emergency coordinator will give specific
instructions to the fire department over the telephone when the call for assistance
is made."
Check For:
Example Section:
Example Comments:
The reviewer should check for the following:
Names of emergency coordinator(s)
Office and home addresses and telephone numbers
Emergency coordinator(s) authority and qualifications
Specific arrangements with local authorities
Emergency equipment list
Emergency equipment maintenance schedule
Evacuation plan
Clark was reviewing the contingency plan submitted by XYZ Company and noted
that it did not comply with 40 CFR Part 264.52(c). This part of the regulation
requires the facility owner to describe arrangements with local police departments,
fire departments, hospitals, contractors, and state and local emergency response
teams to coordinate emergency services. The contingency plan submitted by XYZ
Company stated that all of the above agencies had been contacted but did not
present evidence they would provide the necessary services to XYZ Company.
Clark wrote an NOD that stated the application should provide names, addresses,
and telephone numbers (both home and office) of primary and alternate emergency
coordinators.
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In addition, it should describe coordination agreements with local police and fire
departments, hospitals, contractors, and state and local emergency response teams
to familiarize them with the facility and actions needed in case of emergency.
Notes:
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10.0 REVIEWING PERSONNEL TRAINING RECORDS—SECTION H
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Parts 264.16 and 270.14(b)(12)
No specific references are applicable to this section of the manual.
Title 40 CFR Section 270.14(b)(12) requires that the permit application describe
the introductory and continuing training programs for combustion unit operators.
Regulatory standards for training are contained in 40 CFR Part 264.16. In
general, permit writers should ensure that the training will support safe hazardous
waste management and will ensure compliance with applicable hazardous waste
management regulations. The training program must address routine operations
and emergency procedures, including contingency plan implementation. The
program must specify appropriate training procedures relevant to job positions for
employees who will handle or may come into contact with hazardous waste. It
must also specify the training frequency, techniques to be used, and training record
maintenance, such as training course outlines and documentation that training has
been completed. Permit writers should require applicants to furnish evidence that
instructors are qualified and a detailed description of the training program.
In the case of combustion unit operations, facility personnel must be trained to
safely shut down the combustion unit in an emergency. Personnel must also know
how to respond to hazardous waste leaks or spills.
The reviewer should check for the following:
Training program outline
• Inclusion of contingency plan
Job titles
Job descriptions
Training director qualifications
Description of training type and amount
BIF units are required to operate under conditions that limit emissions of metals,
organic compounds, chlorine and hydrogen chloride, and particulates. Emissions
are controlled by establishing applicable operating parameters for AWFCO
systems. System malfunctions could cause the BIF unit to deviate from its
operating parameters. BIF unit operators must know the applicable parameters to
determine whether the BIF unit is functioning properly.
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In reviewing the facility's training program, Clark concludes that it is too general
and is not facility specific. For example, the facility indicated that it requires
40-hour health and safety training for all BIF unit operations personnel; however,
the facility does not indicate that the health and safety training has been
supplemented with site-specific information, including a review of the facility's
contingency plan.
The training program must address routine and emergency procedures and should
include the following, if applicable: (1) procedures for using, inspecting,
repairing, and replacing facility emergency and monitoring equipment; (2) key
parameters for AWFCO systems, communications, or alarm systems; (3) response
to fires; (4) response to groundwater contamination incidents; and (5) operations
shutdown.
Example Comments:
This section should demonstrate that facility personnel are able to respond
effectively to emergencies and are familiar with both routine and emergency
procedures, equipment, and systems. Clark requests that the facility revise this
section accordingly.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
11.0 REVIEWING CLOSURE PLANS, POST-CLOSURE PLANS, AND FINANCIAL
REQUIREMENTS—SECTION I
Regulation: 40 CFR Parts 270.14(b)(13) and (15) through (18), 264.110 through 264.151,
264.178, 264.197, 264.228, 264.258, 264.280, 264.310, and 264.351
Guidance: No specific references are applicable to this section of the manual.
Explanation: Closure and post-closure procedures ensure protection of the public and
environment against leakage of hazardous wastes to the environment from closed
facilities that formerly stored, treated, or disposed of such wastes. The owner or
operator must have a detailed written estimate, in current dollars, of the cost of
closing the facility in accordance with all applicable regulations.
Check For: • Written closure plan (see Section 11.1)
Written post-closure plan (see Section 11.2)
Appropriate procedures for filing notices required for disposal facilities
(see Section 11.3)
• Written closure cost estimate (see Section 11.4)
• Financial assurance plan for closure, in current dollars (see Section 11.5)
• Written post-closure cost estimate (see Section 11.6)
• Financial assurance plan for post-closure, in current dollars (see
Section 11.7)
Third-party liability coverage scheme (see Section 11.8)
Appropriate use of state-authorized mechanisms, as applicable (see
Section 11.9)
Example Section: See following subsections for specific example sections.
Example Comments: See following subsections for specific example comments.
Notes:
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11.1 CLOSURE PLANS
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
40 CFR Parts 112(a)(l) and (2), 264.113, 264.114, and 264.115
No specific references are applicable to this section of the manual.
The written closure plan should include all elements listed in Subsections 11.1.1
through 11.1.5. The plan should clearly describe how each hazardous waste
management unit will be safely closed and how the overall facility closure plan
will be conducted. Attachment G of this component provides an example facility
closure plan.
The reviewer should check for the following:
Clearly written plan
Inclusion of all components of the facility
Disposal of current inventory and decontamination materials using
acceptable practices
• Review closure plan periodically for technical adequacy and incorporating
new techniques
Discussion of closure of combustion units and BIFs as applicable
Recognition of differences in closure of a RCRA hazardous waste
treatment facility and a BIF
The XYZ Company developed a detailed closure plan for all parts of the facility.
The waste receiving area, laboratory, storage and various treatment areas
including the combustion unit were encompassed in the plan. All these plans were
deemed complete and adequate by Clark. However, when the plan for the XYZ
Company BIF was reviewed, it said only that "waste flow will cease when the BIF
is closed."
Clark feels this plan is inadequate because it fails to state whether the BIF will
remain in operation using virgin fuel. It also does not mention the waste feed lines
from the generating process and whether they must be dismantled, cleaned, or sent
to a Class I landfill for ultimate disposal. Clark requested XYZ Company
specifically address closure of the BIF in significantly more detail.
Notes:
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11.1.1 Closure Performance Standards
Regulation:
Guidance:
Explanation:
Check For:
Example Situation:
40 CFR Part 264.111
No specific references are applicable to this section of the manual.
The closure plan should demonstrate that performance standards listed in
40 CFR Part 264. Ill will be met. The application should specifically address
each of the points listed in the regulation.
The reviewer should check for the following:
• How the closure plan minimizes the need for further maintenance
How the closure plan controls, minimizes, or eliminates the post-closure
escape of hazardous waste, hazardous constituents, leachate,
contaminated runoff, or hazardous waste decomposition products to the
soils, ground and surface waters, or atmosphere
• How the closure plan complies with the Subpart G requirements and unit-
specific closure requirements
Lois and Clark read the Closure Performance Standard section of the facility's
Part B permit application which states:
"Kilns closure will be verified with collection of refractory brick samples and the
coating material atop the refractory brick after a sufficient burn period (for
example, a minimum of three raw material residence periods). Clean closure will
be demonstrated for each kiln when average metal and organic sample
concentrations meet the following criteria:
"Refractory brick:
Coating on the
refractory brick:
less than SQL or
less than the average plus two standard
deviations for background samples of similar
virgin brick
less than SQLs or
less than the average plus two standards
deviations for background samples of clinker or
kiln feed or cement kiln dust."
Example Action:
In this section, performance standards for clean closure are proposed for the kilns,
associated duct work, APCS, and any other structures or operating equipment that
have come into contact with hazardous wastes. These proposed closure
performance standards are not adequate for demonstrating any effect from
hazardous waste burned in the kilns on the refractory brick coating and on the
residue adhering to internal surfaces of the electrostatic precipitators (ESP), the
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duct work, and the exhaust stack. In accordance with 40 CFR Parts 264.111 and
266.112, Lois and Clark ask that the facility revise its closure performance
standards for determining that hazardous waste does not significantly affect
refractory brick coating or the residue on internal surfaces of the ESP, the duct
work, and the exhaust stack. The revision should demonstrate conformance
through a comparison of waste-derived residue concentrations with health-based
limits, as established in 40 CFR Part 266.112(b)(2)(I) and (ii). Furthermore, the
revisions must include a table that presents (1) the health-based limits for each of
the 40 CFR Part 261 Appendix VII hazardous constituents contained in the
hazardous wastes listed in Part A of the permit application, (2) the method for
analyzing residues for each of those hazardous constituents, and (3) the
corresponding sample quantification limits of those analytical methods for each
hazardous constituent.
Notes:
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11.1.2 Partial Closure and Final Closure Activities
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
Example Action:
Notes:
40 CFR Parts 264.112(b)(l) through 264.112(b)(7)
No specific references are applicable to this section of the manual.
If the facility anticipates closing portions of its operations overtime, a partial
closure schedule must be proposed along with partial and final closure activities.
The facility must identify the maximum extent of operations that will remain
active during the life of the facility. A more conservative approach to the facility's
potential for partial closure is advisable; for example, consider that a presently
available on site method of waste treatment and disposal will not be available
during partial to final closure. Therefore, an off site means of treatment or
disposal of the waste would be necessary.
The reviewer should check the following:
• Partial and final closure schedules
• Extent of operations during the life of the facility
• Evaluation of the need to conduct (and costs associated with) a revised
risk assessment in case of partial closure
In reviewing the facility's proposed closure plan, Lois notes that it does not
contain any provision for partial closure, should partial closure ever become
necessary (for example, possible shutdown of one kiln with one remaining
operational) (40 CFR Part 264.112).
Lois asks in and NOD that the facility revise the Part B application to discuss the
possibility of partial closure and, if applicable, revise the closure plan to address
partial closure.
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11.1.3 Maximum Waste Inventory
Regulation: 40 CFR Part 264.112(b)(3)
Guidance:
Explanation:
Check For:
Example Section:
Example Comments:
No specific references are applicable to this section of the manual.
This section must describe the maximum inventory of wastes that could be on site
at any time during the active life of the facility.
The reviewer should check for the following:
• Be sure that the amount of waste handled during closure equals the
permitted volume of waste. It is safer to assume that the total permitted
volume of waste will be handled during closure. In this way, the closure
cost estimate will be conservative, thereby providing adequate funds for
closure
It is assumed that the volume of waste managed during closure will not exceed the
maximum quantity of waste handled during normal operations. Historical
operating records indicate that during the facility's highest production period, the
maximum volume of waste managed equaled 60 percent of the permitted capacity.
The closure plan should be amended to assume that the volume of waste be
managed during closure will be the full permitted capacity rather than just a
portion. While under historical operating conditions the maximum permitted
volume of waste has not been handled, there is nothing to prevent the unit from
handling the maximum permitted volume of waste in the future. Unless the permit
is modified to limit the unit to a lower volume of waste, the closure plan and
associated cost estimate should assume that the maximum permitted volume of
waste will be managed during closure.
Notes:
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11.1.4 Schedule for Closure
Regulation:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Parts 264.112(b)(2) and (6) and 264.113 (a) and (b)
No specific references are applicable to this section of the manual.
This section must include a schedule for closure activities.
The reviewer should check for the following:
Time required to close each FiWMU
Time required for other associated closure activities
Estimate of the expected year of final closure
Assurance that all closure activities will be completed within 180 days
after receiving the final volume of waste
• A request for extension that satisfies one of the following requirements:
• Closure will require more than 90 or 180 days
Facility has the capacity to receive additional waste
• Likelihood that another owner will recommence operation of the
site within 1 year
• Evidence that closure would be incompatible with continued
facility operation
• A demonstration that all steps will be taken to prevent a threat
from the unclosed but inactive facility
Clark reads the Schedule for Closure section of the facility's Part B permit
application, which states:
"It is likely that hazardous wastes will no longer be sent to the boiler within the
next 10 years; however, the boiler will remain in operation to provide needed
steam for plant operating equipment." It is unclear when the boiler will be
officially closed in accordance with RCRA standards.
Although it appears to be acceptable to continue boiler operation longer than 1
year after the final volume of waste has been received, a RCRA closure date for
the boiler must be determined. It is important to include the boiler in all closure
planning activities, such as closure procedures, cost estimates, and schedule.
Clark asks that the facility revise this section to reflect an estimated date for boiler
closure in accordance with RCRA standards.
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Notes:
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11.1.5 Closure Procedures
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
Example Action:
40 CFR Parts 264.112 and 264.114
No specific references are applicable to this section of the manual.
This section identifies requirements for both general and unit-specific closure
procedures. It is important that each of these areas is reviewed to promote a more
comprehensive closure plan and more accurate closure cost estimate.
The reviewer should check the items in Subsections 11.1.5.1 through 11.1.5.13.
Lois and Clark were reviewing the XYZ Company closure plan and the
description of other activities necessary during the closure period to ensure that all
partial closures and final closure satisfy the closure performance standards. Clark
noted that XYZ Company had failed to address how runon water (rain water)
would be collected or controlled at the last active landfill cell during closure.
Clark wrote XYZ Company an NOD because the closure regulations clearly state
that a detailed description for control of runon water during closure must be
included. Clark requested that XYZ Company clearly explain how runon water
will be controlled while closure of the last landfill cell is occurring. He requested
that the explanation address the issue of water in the cell and the disposition of all
collected water originating from the hazardous waste area and landfill cell.
Notes:
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11.1.5.1 Inventory Removal
Regulation: 40 CFR Parts 264.112 and 264.114
Guidance: No specific references are applicable to this section of the manual.
Explanation:
Check For:
This section should discuss the volume of hazardous waste and identify the types
of off site disposal or treatment methods to be used.
• Methods for waste removal
• Methods for waste transportation
• Methods for waste treatment
• Methods for waste storage
• Methods for waste disposal
• Types of off site hazardous waste management units to be used
The XYZ Company application stated, "the final inventory of hazardous waste
stored in the tank farm will be routed to appropriate disposal." Because XYZ
Company operated both a boiler and an incinerator, Lois was unsure of the
disposal method for the final inventory of hazardous waste.
Example Comments: Lois wrote an NOD requesting the facility to clearly identify the specific disposal
method for the hazardous waste inventory remaining in the tank farm at the start
of closure.
Notes:
Example Section:
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11.1.5.2 Disposal or Decontamination of Equipment, Structures, and Soils
Regulation: 40 CFR Parts 264.112(b)(4) and 264.114
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section should describe, in detail, the steps needed to decontaminate or
dispose of all facility equipment, structures, and contaminated soils.
Check For: • Decontamination procedures, including (1) estimated volume of water
used per square foot of surface cleaned; (2) method of decontamination
(for example, either by high pressure washing or steam cleaning);
(3) proposed cleaning solvents, if needed; and (4) method of collection,
storage, and treatment of decontamination fluids.
• Criteria for determining decontamination
• List of equipment, structures, and soils, including estimated depth of
contaminated soil to excavate
Disposal of contaminated soil and residues
Decontamination of cleanup materials and equipment
Demonstration that decontamination has been effective
Example Section: The XYZ Company application stated that once site soils have been excavated, the
heavy equipment used during excavation will be decontaminated and then used to
refill and compact the hole with clean soil. The contaminated soils will be sent off
site for appropriate disposal.
Example Comments: Clark requested that the application provide the following information regarding
decontamination, soil excavation, and disposal:
Types of heavy equipment anticipated for use during excavation
and backfill
• Volume of soil expected to be excavated
• Procedures for decontamination of the heavy equipment, including
volume of water used for surface cleaning and wash area for the
trucks
• Methods of collection, sampling, analysis, transportation off site,
and disposal of the decontamination water
Methods of sampling, analysis, transportation off site, and
disposal of the excavated soils
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This information is needed to evaluate the adequacy of the closure plan and to
promote a more accurate closure cost estimate.
Notes:
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11.1.5.3 Closure of Disposal Units/Contingent Closures
Regulation: 40 CFR Parts 270.14(b)(13), 270.17(f), 270.18(h), 270.21(e), 264.228(a)(2),
264.228(c)(l)(I), 264.258(c)(l)(I), 264.310(a), and 264.601
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section should describe closure for units that will continue to contain wastes
or contaminated materials after closure. This is common for units such as waste
piles, surface impoundments, and miscellaneous units. However, it is not common
for types of equipment related to hazardous waste combustion, for example,
boilers, incinerators, tanks, containers, and container storage areas. Therefore,
this section is not discussed in depth in this manual.
Check For:
Example Section:
Closure procedures
Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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11.1.5.4 Closure of Containers
Regulation: 40 CFR Parts 264.178, 264.112(b)(3), and 270.14(b)(13)
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section should address closure of all containers and the associated container
storage area.
Check For: • Hazardous waste removal and disposal methods (ensure that incompatible
wastes and other nonsimilar wastes are to be handled separately during
closure)
• Container decontamination and disposal methods
• Site decontamination procedures for, and disposal of, linings, concrete,
soil, and decontamination fluids
• Methods for verifying decontamination
• Maximum inventory of waste (it is conservative to assume the maximum
inventory to be equal to the maximum permitted volume of waste)
Example Situation:
Example Action:
Lois reads the Closure of Containers section of the Part B permit application,
which states:
"During closure, all organic wastes will be transferred to a holding tank prior to
piping to a transport tanker for shipment off site to a permitted commercial
hazardous waste incinerator."
It is inappropriate and unsafe to mix organic wastes into one holding tank without
confirming that the wastes are compatible. Lois asks that the facility review the
various organic waste streams and explain why they can be safely mixed into one
holding tank. If mixing the wastes is no longer a viable option, Lois also asks that
the facility propose an alternative method for handling organic wastes during
closure.
Notes:
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11.1.5.5
Regulation:
Guidance:
Explanation:
Check For:
Closure of Tanks
Example Situation:
Example Action:
40 CFR Parts 264.197, 264.112(b)(3), and 270.14(b)(13)
No specific references are applicable to this section of the manual.
This section should address closure of tank systems and associated equipment,
such as the containment system, liners, sumps, other structures, and surrounding
contaminated soils (if applicable).
Hazardous waste removal and disposal methods (ensure that incompatible
wastes and other nonsimilar wastes are to be handled separately during
closure)
Tank system (including the tank shell itself, if applicable) decontamination
and residue disposal methods
• Site decontamination procedures for, and disposal of, linings, concrete,
soil, other structures, and decontamination fluids
• Methods for verifying decontamination
• Maximum inventory of waste (it is conservative to assume the maximum
inventory to be equal to the maximum permitted volume of waste)
Clark reads the Closure of Tanks section of the Part B permit application, which
states:
"Tank system components, such as the containment system (the concrete, stairs,
and sump), will be decontaminated using a high-pressure wash. Decontamination
fluids will be collected and stored in 500-gallon holding tanks prior to off site
disposal."
Clark realizes that this section does not explain how or if the tank itself will
undergo decontamination. If it will be decontaminated, the section should explain
how the tank shell will be high-pressure washed and how decontamination fluids
will be collected. If the tank will be left in place, the section should explain the
criteria to be used to evaluate whether if decontamination efforts were successful
(for example, identify constituent concentration action levels to be used to decide
whether the tank has been "cleaned" enough). If the tank will be torn down, then
the section should explain how the process will occur. Clark asks that the facility
revise this section based on his comments.
Notes:
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11.1.5.6 Closure of Waste Piles
Regulation: 40 CFR Parts 264.258 and 270.18(h)
Guidance: RESERVED
Explanation: Because these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
11.1.5.7 Closure of Surface Impoundments
Regulation: 40 CFR Parts 264.228(a)(l), (2), and (b) and 270.17(f)
Guidance: RESERVED
Explanation: Because these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
11.1.5.8
Closure of Incinerators
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Parts 264.351 and 270.14(b)(13)
No specific references are applicable to this section of the manual.
This section should describe how all hazardous waste and hazardous waste
residues will be removed from the incinerator and all associated structures and
equipment. Alternatively, the facility may propose to dismantle and dispose of the
incinerator and associated units as hazardous waste. It is more common for
facilities to attempt to reduce equipment contamination as much as possible,
dismantle the unit, and then send it off site for disposal, rather than attempt to
fully clean-close the unit and leave it in place. However, if any contaminated
components or wastes remain after closure, plans must be submitted to close the
unit as a landfill and to provide post-closure care.
For U.S. EPA guidance on combustion unit closure the permit writer should
reference the U.S. EPA Draft Final Report, "Draft of Guidance of Incinerator
Closure" attached to Lionel Vega's memorandum dated October 30, 1990, on
"Draft Guidance on Incinerator Closure." This guidance is included as
Attachment D.
Ensure that all pieces of equipment are accounted for when assessing the
extent of closure activities. Examples include, but are not limited to, the
following:
• Ductwork
• Piping
APCS equipment
• Sumps
Exhaust stack
• Equipment as defined by RCRA (for example, pumps and valves)
Any other structures or operating equipment that has come into
contact with hazardous waste
Example Situation
• Ensure that all hazardous waste and residues are accounted for when
assessing the extent of the volume of waste handled during closure.
Examples include, but are not limited to, the following:
Ash
Scrubber waters
• Scrubber sludges
Refractory brick
Clark reads the Closure of Incinerators section of the Part B permit application,
which states:
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"To ensure removal of all organic constituents from the refractory brick surface
inside the incinerator, the incinerator will be fired on natural gas only for 8 hours
at temperatures exceeding the average maximum normal operating temperature."
Example Action: It is not acceptable to state that a high-temperature burn will adequately destroy
organic compounds from the refractory brick. Clark asks that the facility revise
this section to propose confirmation sampling to demonstrate that hazardous
organic constituents do not remain on the refractory brick. The revised section
should also explain a course of action to be taken if refractory brick samples
indicate the presence of hazardous organic constituents.
Notes:
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11.1.5.9 Closure of Landfills
Regulation: 40 CFR Parts 264.310(a) and 270.21(e)
Guidance: RESERVED
Explanation: Because these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
11.1.5.10 Closure of Land Treatment Facilities
Regulation: 40 CFR Parts 264.280(a) and 270.20(f)
Guidance: RESERVED
Explanation: Because these units are not normally associated with combustion units, this section
will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
11.1.5.11 Closure of Miscellaneous Units
Regulation: 40 CFR Part 270.23(a)(2)
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section should describe, in detail, how all hazardous waste and hazardous
waste residues will be removed from the treatment process or equipment and how
the unit will be decontaminated.
Check For: • Ensure that all structures and equipment associated with the miscellaneous
unit are accounted for when assessing the extent of closure activities
• Closure requirements for miscellaneous units should be similar to those
required for other FiWMUs
Example Section: The XYZ Company application stated that the waste feed processing unit (the pug
mill) will be disassembled during closure and shipped to an off site industrial
landfill. However, no mention was made regarding cleaning and sampling of the
unit before shipment off site.
Example Comments: Lois requested that closure plan in the application be revised to incorporate
decontamination, sampling, and analysis of the pug mill. Also, the method for off
site disposal should be revisited in case the pug mill cannot be fully
decontaminated and must be sent to a hazardous waste landfill.
Notes:
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11.1.5.12
Closure of Boilers and Industrial Furnaces
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Part 266.102(a)(2)(vii)
U.S. EPA. 1992. "TID for EPA's BIF Regulations." OSWER. Washington,
D.C. EPA-530-4-92-11. March. Section 5.4.3, pages 5-30 and 5-31.
This section should describe how all hazardous waste and hazardous waste
residues will be removed from the BIF and all associated structures and
equipment. Alternatively, the facility may propose to dismantle and dispose of the
BIF and associated units as hazardous waste. It is more common for facilities to
attempt to reduce the contamination of the equipment as much as possible,
dismantle the unit, and then send it off site for disposal, rather than attempt to
fully clean-close the unit and leave it in place. However, if any contaminated
components or wastes remain after closure, plans must be submitted to close the
unit as a landfill and to provide post-closure care.
For U.S. EPA guidance on combustion unit closure the permit writer should
reference the U.S. EPA Draft Final Report, "Draft of Guidance of Incinerator
Closure" attached to Lionel Vega's memorandum dated October 30, 1990, on
"Draft Guidance on Incinerator Closure." This guidance is included as
Attachment D.
• Ensure that all pieces of equipment are accounted for when assessing the
extent of closure activities. Examples include, but are not limited, to the
following:
• Ductwork
Piping
• APCS equipment
Sumps
• Exhaust stack
Equipment as defined by RCRA (for example, pumps and valves)
• Any other structures or operating equipment that has come into
contact with hazardous waste
Ensure that all hazardous waste and residues are accounted for when
assessing the extent of the volume of waste handled during closure.
Examples include, but are not limited to, the following:
• Ash
• Scrubber waters
Scrubber sludges
• Refractory brick
• Because a BIF is an integral part of the facility's production processes,
there may be times when the BIF will stop receiving hazardous waste but
will continue to operate to maintain the facility's production levels. If this
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is the case, the facility should clearly explain how the BIF will be operated
during its remaining life when not receiving hazardous waste. Because
BIF rules address only the BIF's operation when receiving hazardous
waste, no specific rules have been promulgated that address BIF
monitoring during the period when it stops receiving hazardous waste and
officially undergoes RCRA closure. As a result, the facility must explain
how the unit will be operated so that it will not pose a threat to human
health or the environment.
Example Section:
Example Comments:
The XYZ Company application states, the cement kiln will stop receiving
hazardous waste in approximately 15 years because the source of the HWDF will
cease operations at that time. However, the cement kiln will continue to operate
for approximately 15 years after hazardous waste feed to the unit is stopped. As a
result, the cement kiln will no longer be considered a hazardous waste
management unit and will not need to undergo RCRA closure."
Clark commented that the application should be augmented to address RCRA
closure requirements when the cement kiln both stops receiving hazardous waste
and when it undergoes physical decommissioning approximately 15 years later.
Even though the unit may not have been burning hazardous waste when it
undergoes physical closure, it still must undergo RCRA closure because it once
operated as a RCRA unit. When the unit stops receiving hazardous waste but
continues to operate, the facility should outline the operating procedures to ensure
that continued operation will not pose a threat to human health or the environment.
Notes:
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11.1.5.13 Closure of Containment Buildings
Regulation: 40 CFR Part 264.1102
Guidance:
Explanation:
Check For:
No specific references are applicable to this section of the manual.
This section should address how hazardous waste and residues stored in a
containment building will be removed. If any wastes or contaminated components
remain after closure, plans should be submitted to close the building as a landfill
and to provide post-closure care.
• Ensure that all of the following items are accounted for when assessing the
extent of closure:
Containment system
• Contaminated soils (if applicable)
All structures and equipment contaminated with waste or leachate
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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11.2 POST-CLOSURE PLAN/CONTINGENT POST-CLOSURE
Regulation: 40 CFR Parts 270.14(b)(13), 270.17(f), 270.18(h), 270.20(f), 270.21(e),
270.23(a)(3), 264.118, 264.197(b), 264.197(c)(2), 264.228(b), 264.228(c)(l)(ii),
264.258(b), 264.258(c)(l)(ii), 264.280(c), 264.310(b), and 264.603
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section addresses post-closure and contingent post-closure care (where
proposed closure activities do not result in clean-closed conditions, then the
facility must institute post-closure care.) Because these scenarios are not
commonly associated with combustion units, this section will remain reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
11.3 NOTICES REQUIRED FOR DISPOSAL FACILITIES
Regulation: 40 CFR Parts 264.115 and 264.280
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section addresses notices required for disposal facilities such as surface
impoundments, waste piles, land treatment areas, and landfills. Because these
units are not normally associated with combustion units, this section will remain
reserved.
Check For: RESERVED
Example Section: RESERVED
Example Comments: RESERVED
Notes:
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11.4 CLOSURE COST ESTIMATE
Regulation:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Parts 264.142 and 265.142
No specific references are applicable to this section of the manual.
Closure cost estimates usually are provided as an attachment to the closure plan.
The cost estimate serves as the basis for determining the amount of financial
assurance that is required for closure.
The reviewer should check for the following:
Written, detailed estimate, in current dollars, of the cost of closing the
facility in accordance with the regulations
• The cost of final closure must be equal to a point in the facility's active
life when closure would be most expensive
Closure cost must include:
Transportation
• Treatment and disposal
Management of decontamination liquids
• Sampling and analysis
• The closure cost must assume that a third party will close the facility
• No salvage value can be included in the cost estimate
• The estimate cannot incorporate a zero cost for hazardous wastes that
might have economic value
The estimate must specify contingency cost estimates
Estimate must be updated annually provided and to the permitting
authority
In reviewing the facility's closure plan (see Attachment G of this component),
Clark notes that Table 1-3 presents closure cost estimates for the existing facility,
and Table 1-4 presents closure cost estimates for the "complete facility." The term
"complete facility" means the facility when all proposed FIWMUs listed in the
Part A permit application are constructed. However, these closure cost estimates
are not complete because they do not include closure costs for (1) sampling
residues in duct work, APCS, and any other structures or operating equipment that
have come into contact with hazardous wastes to demonstrate that closure
performance standards are met, and (2) decontaminating kilns, APCS, and any
other structures or operating equipment to meet closure performance standards.
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Example Action: In accordance with 40 CFR Parts 270.14(b)( 15) and 264.142, Clark requests that
the facility revise Tables 1-3 and 1-4 to include closure costs for the
above-referenced sampling and decontamination activities.
Notes:
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11.5 FINANCIAL ASSURANCE MECHANISM FOR CLOSURE
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Parts 264.143 and 265.143
No specific references are applicable to this section of the manual.
Requirements for financial assurance help to ensure that funds are available to
cover the closure costs should owners or operators be unable or unwilling to pay
them. Owners and operators of more than one TSDF must provide financial
assurance equal to the sum of the cost estimates for all of their facilities. A single
financial mechanism may be used to meet requirements for financial assurance for
more than one facility. A combination of several mechanisms may be used to meet
requirements for one or more facilities.
Financial mechanisms that may be used to demonstrate financial assurance for
closure include: (1) trust fund, (2) surety bond, (3) letter of credit, (4) insurance,
(5) financial test, and (6) corporate guarantee. The wording of each financial
mechanism must be identical to the wording specified in 40 CFR Part 264.151 or
the appropriate state code. In some states, financial mechanisms must be executed
on state-issued forms.
The reviewer should check for the following:
• When trust funds are used to demonstrate financial assurance for closure:
• The owner or operator must make annual payments into the trust
fund or otherwise maintain the value of the trust fund at no less
than the amount specified by the established minimum payment
formula.
Owners or operators generally must make payments into the trust
fund annually over the life of the initial permit or over the
remaining operating life of the facility, whichever is shorter.
The annual valuation statement submitted by the trustee should be
checked to ensure that the funds held in trust are adequate to
demonstrate financial assurance for closure.
Owners or operators may not withdraw funds from the trust fund
without first obtaining permission from U.S. EPA or the
appropriate state agency.
If the operating life of the facility extends beyond the pay-in
period, the owner or operator must continue to update the trust
fund annually to account for inflation.
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If the trust fund is established after another mechanism has been
used, the first payment must be at least the amount that the fund
would contain if the trust fund had been used all from the
beginning.
• At closure, the value of the trust fund must be at least equal to the
current closure cost estimate.
When surety bonds are used to demonstrate financial assurance for
closure:
• The penal sum of the bond must be at least equal to the current
closure cost estimate.
The surety company must be listed in the current U.S. Treasury
Department Circular 570.
• The owner or operator must establish a standby trust fund in
conjunction with the surety bond.
When letters of credit are used to demonstrate financial assurance for
closure:
• The face value of the letter of credit must be at least equal to the
current closure cost estimate.
The owner or operator must establish a standby trust fund in
conjunction with the letter of credit.
• When insurance is used to demonstrate financial assurance for closure:
• The face value of the insurance policy must be at least equal to
the current closure cost estimate.
In addition to the certificate of insurance, each insurance policy
should be reviewed to: (1) determine if the terms of the policy are
consistent with numerous requirements specified in 40 CFR Parts
264.143(e), and (2) identify any terms or conditions specified in
the policy (for example, deductible levels) that may be
unfavorable to U.S. EPA or the state agency.
• Recently, certain TSDF owners and operators have begun to
submit certificates of insurance from captive insurance companies
to demonstrate financial assurance for closure. Because captive
insurance companies are held within the same corporate family as
the owner or operator, the use of such insurance may be
inappropriate to demonstrate financial assurance. Depending on
state regulations.
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When the financial test is used to demonstrate financial assurance for
closure:
• To satisfy the criteria of the financial test, the operator must
demonstrate an investment grade bond rating or meet two of three
financial ratios. The owner or operator also must meet criteria
for tangible net worth; domestic assets; and, if necessary, net
working capital.
• If an owner or operator is basing eligibility to use the financial
test, in part, on the demonstration of an investment-grade bond
rating, care should be taken to ensure that the rating is
representative of the financial condition of the firm and has not
been defeased or otherwise inflated artificially through the use of
other support mechanisms, such as insurance policies or
intercompany agreements.
• The chief financial officer (CFO) letter must demonstrate that the
owner or operator has complied fully with all requirements for the
financial test. The letter must be signed by the CFO of the owner
or operator.
Eligibility to use the test is determined annually and through an
evaluation of the owner's or operator's financial data for the
latest completed fiscal year. For example, financial data for fiscal
year 1996 may be used only to demonstrate eligibility for use of
the financial test in 1997. The financial test must be updated
within 90 days after the close of the firm's fiscal year.
• Reports from independent certified public accountants (CPA)
must be examined carefully to confirm that (1) data in the
owner's or operator's financial statements correctly represent the
financial condition of the owner or operator, and (2) data in the
CFO's letter are taken directly from, or can be derived from, the
year-end financial statements of the owner or operator for the
latest completed fiscal year.
• The special report from the independent CPA should comment
directly on the value of a firm's domestic assets.
Eligibility to use the financial test depends, in part, on the ratio of
the owner's or operator's tangible net worth, net working capital,
and domestic assets to the total closure costs for all facilities
covered under the test. Also, owners and operators may use the
financial test to demonstrate financial assurance for an unlimited
number of TSDFs in multiple states or jurisdictions. It often is
necessary, therefore, to contact each state or jurisdiction in which
a facility that is covered by the financial test is located to confirm
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that closure cost estimates specified for each of those facilities are
accurate and have been updated properly for inflation.
• When the corporate guarantee is used to demonstrate financial assurance
for closure:
The guarantor must annually meet all requirements of the
financial test.
• In addition to documents required to pass the financial test, the
guarantor must submit a guarantee agreement for closure and
post-closure care. The wording of the agreement must be
identical to the wording specified in the regulations.
The guarantor must be: (1) the direct, higher-tier parent
corporation of the owner or operator; (2) a firm whose parent
corporation also is the parent corporation of the owner or
operator; or (3) a firm with a "substantial business relationship"
with the owner or operator.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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11.6 POST-CLOSURE CARE COST ESTIMATE
Regulation: 40 CFR Parts 264.144 and 265.144
Guidance: No specific references are applicable to this section of the manual.
Explanation: Cost estimates for post-closure care usually are provided as an attachment to the
closure plan. The cost estimate serves as the basis for determining the amount of
financial assurance that is required for post-closure care.
Check For: The reviewer should check for the following:
See the items listed under Section 11.4. The process for the post-closure
care cost estimate is the same as that for closure cost estimate.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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11.7 FINANCIAL ASSURANCE MECHANISM FOR POST-CLOSURE CARE
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Parts 264.145 and 265.145
No specific references are applicable to this section of the manual.
The owner or operator of a permitted RCRA hazardous waste management facility
is required to prepare a contingent closure and post-closure plan. This plan must
provide a detailed written estimate, in current dollars, of the annual cost of post-
closure monitoring and maintenance of the facility in accordance with all
applicable regulations.
The reviewer should check for the following:
The written detailed post-closure plan
Cost to conduct post-closure care, in current dollars
Estimated number of years post-closure care will be required
Establishment of post-closure trust fund or surety bond guaranteeing
payment into a post-closure trust fund, or a surety bond guaranteeing
performance of post-closure care or post-closure insurance or other
financial instruments outlined in the regulations
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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11.8 THIRD-PARTY LIABILITY REQUIREMENTS
Regulation:
Guidance:
Explanation:
40 CFR Parts 264.147 and 270.14(b)(17)
No specific references are applicable to this section of the manual.
Requirements for financial assurance for third-party liability help to ensure that
funds will be available to pay costs arising from bodily injuries and property
damage to third parties caused by TSDF operations. TSDF owners and operators
are required to maintain financial assurance for third-party liability for sudden
accidental occurrences in the amounts of $ 1 million per occurrence and $2 million
annual aggregate, exclusive of legal defense costs. Owners and operators of
hazardous waste land disposal facilities must maintain total financial assurance
for third-party liability for sudden and nonsudden accidental occurrences in the
amounts of $4 million per occurrence and $8 million annual aggregate, exclusive
of legal defense costs. If it is determined that the levels of third-party liability
coverage required under regulations are not consistent with the degree and
duration of risk associated with TSDF operations or a group of TSDFs, U.S. EPA
or state agencies may increase coverage levels as necessary to protect human
health and the environment.
Check For:
The reviewer should check for the following:
• Financial mechanisms that may be used to demonstrate financial
assurance for third-party liability:
Trust fund
• Surety bond
Letter of credit
• Insurance
Financial test
• Corporate guarantee
• Weakness and limitation of each of the financial mechanisms
• When insurance is used to demonstrate third-party liability:
• Levels of per occurrence and annual aggregate coverage.
• Terms consistent with requirements specified in 40 CFR Part
264.147(a)(b)
Terms and conditions in the policy such as deductibles
When the financial test is used to demonstrate financial assurance for
third-party liability:
• The same financial test may be used to demonstrate financial
assurance for closure and post-closure care and third-party
liability.
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Requirements for use of the financial test for third-party liability
are essentially the same as for closure and post-closure care.
• To satisfy the criteria of the financial test for third-party liability,
the operator may be required to demonstrate an investment grade
bond rating or meet two of three financial ratios. The owner or
operator also must meet criteria for tangible net worth; domestic
assets; and, if necessary, networking capital.
• Eligibility to use the financial test depends, in part, on the ratio of
the owner's or operator's tangible net worth, net working capital,
and domestic assets to the annual aggregate amount of third-party
liability coverage to be demonstrated under the test.
When the corporate guarantee is used to demonstrate financial assurance
for third-party liability:
• The guarantor must annually meet all requirements of the
financial test for third-party liability.
In addition to documents required to pass the financial test, the
guarantor must submit a certified copy of a guarantee agreement
for third-party liability. The wording of the guarantee agreement
must be identical to the wording specified in the regulations.
• U.S. corporations must submit to U.S. EPA or the appropriate
state agency written statements from the attorneys general or the
insurance commissioners of (1) the state in which the guarantor is
incorporated and (2) each state in which a facility covered by the
corporate guarantee is located. The statements must confirm that
the corporate guarantee is legally valid and an enforceable
obligation in that state.
• Foreign corporations must submit to U.S. EPA, or the
appropriate state agency written statements from the attorneys
general or the insurance commissioners of (1) the state in which
the guarantor has its principal place of business, and (2) each
state in which a facility covered by the corporate guarantee is
located. The statements must confirm that the corporate
guarantee is legally valid and an enforceable obligation in that
state.
Foreign corporations must identify a registered agent for service
of process in (1) the state in which the guarantor has its principal
place of business, and (2) each state in which a facility covered by
the corporate guarantee is located.
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Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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11.9 USE OF STATE-AUTHORIZED MECHANISMS
Regulation: 40 CFR Parts 264.149 and 265.149, 270.14(b)(18)
Guidance: No specific references are applicable to this section of the manual.
Explanation: In certain circumstances, owners and operators may use mechanisms authorized
under state regulations to demonstrate financial assurance. These circumstances
arise when:
• The state has been authorized to administer the RCRA program
• The state has not been authorized but has promulgated regulations
that require owners and operator of TSDFs to demonstrate
financial assurance for closure and post-closure care or third-
party liability, owners or operators may use mechanisms
authorized under state regulations to demonstrate the assurance,
provided that such mechanisms are at least equivalent to
mechanisms authorized under the federal code.
Check For: The reviewer should check for the following:
Examples of state-authorized mechanisms that are used in some states to
demonstrate financial assurance for TSDFs for closure and post-closure
care or third-party liability include cash bonds, certificates of deposit,
securities, and escrow accounts.
• In general, the value of such mechanisms must be at least equal to the
current estimates of closure and post-closure care cost or the annual
aggregate amount of third-party liability coverage to be demonstrated.
• Requirements for these mechanisms are specific to states that authorize
their use. Permit reviewers must consult pertinent state regulations to
determine the exact criteria established for use of each state-authorized
mechanism.
In many cases, states have adopted and modified the federal financial
assurance mechanisms approved under RCRA Subtitle C to meet the
needs of their programs. For example, states often make minor changes to
the required wording for such mechanisms to establish jurisdiction and
authority for executing them. Such modifications may result in subtle
variations in the requirements established for use of those mechanisms in
each host state.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
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Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
12.0 REVIEWING CORRECTIVE ACTION PLANS FOR SOLID WASTE MANAGEMENT
UNITS—SECTION J
Regulations:
Guidance:
Explanation:
40CFRPart270.14(d).
RCRA Part B Permit Application Review Checklist, Section J.
Information requirements for the identification of SWMUs and a description of
any releases from the SWMUs are found in 40 CFR Part 270.14(d). This may
involve sampling and analysis as required by 40 CFR Part 270.14(d)(3).
Title 40 CFR Part 270.14(d) requires the permit applicant to identify all past and
present SWMUs at the facility, including those used for hazardous and
non-hazardous wastes. Examples of SWMUs are: landfills, surface
impoundments, waste piles, land treatment units, tanks, injection wells,
incinerators, wastewater treatment tanks, container storage areas, waste handling
areas, transfer stations, and waste recycling operations.
Each SWMU must be characterized, as much as possible, by (1) unit type;
(2) location on a topographic map; (3) engineering drawings; (4) dimensions;
(5) construction materials; (6) dates when the unit was in operation; and (7) a
description and quantity of wastes placed in each unit. If there are no past or
existing SWMUs at the facility, the permit applicant must document the
methodology used to make that determination. The applicant must supply all
available information on releases from the units.
Check For: Not applicable to this section of the manual.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
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13.0 REVIEWING THE APPLICABILITY OF OTHER FEDERAL LAWS—SECTION K
Regulations:
Guidance:
Explanation:
40 CFR Parts 270.(b) (20) and 270.3.
No specific references are applicable to this section of the manual.
Permit applicants must demonstrate that the permit will not result in
noncompliance with (1) The Wild and Scenic Rivers Act (WSRA), 16 United
State Code (U.S.C.) 1273 et seq., (2) The National Historic Preservation Act
(NHPA) of 1966, 16 U.S.C. 470 et seq., (3) The Endangered Species Act (ESA),
16 U.S.C. 1531 et seq., (4) The Coastal Zone Management Act (CZMA), 16
U.S.C. 1451 et seq., and (5) The Fish and Wildlife Coordination Act (FWCA),16
U.S.C. 661 et seq.
WSRA prohibits U.S. EPA from authorizing any water resources project that
adversely affects an established wild and scenic river. Permit applicants must
demonstrate that construction of the facility will have no direct, adverse effect
on any waterway designated a wild and scenic river.
Section 106 of the NHPA requires U.S. EPA, before issuing a combustion unit
permit, to consider potential effects of permitted activities on properties listed,
or eligible for listing, on the National Register of Historic Places. Requirements
of the act are implemented in cooperation with state preservation offices and,
when appropriate, the Advisory Council on Historic Preservation. The Section
106 process requires that all historic properties present in the area potentially
affected by proposed activities be identified. National Register criteria should be
used to evaluate properties that may be affected by the undertaking and that
have not been previously evaluated for National Registry eligibility. If the
property is found to be eligible using these criteria, it should be considered to be
eligible for the National Register for Section 106 purposes.
If historic properties may be affected by proposed activities, these effects should
be evaluated by using the criteria specified in 40 CFR 800.9. If an effect is
found, U.S. EPA, in consultation with the state historic preservation officer,
must determine whether the effect is considered adverse. If the effect is found
to be adverse, U.S. EPA must (1) notify the Council on Environmental Quality
(CEQ) and (2) work with the state historic preservation officer to seek ways to
avoid or reduce the effects on historic properties. A memorandum of agreement
must be executed if U.S. EPA and the state historic preservation officer agree on
how the effects will be taken into account. The memorandum of agreement
must be reviewed and approved by the CEQ, if the CEQ was not involved in
formulating the memorandum of agreement. As specified in 40 CFR Part 800.8,
a finding of no adverse effect must be fully documented to explain how the
finding was reached.
The U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries
Service share responsibility for implementing the ESA. Section 7(a)(2) of ESA
requires every federal agency, including U.S. EPA, to ensure that any action it
authorizes, funds, or carries out, is not likely to (1) jeopardize the continued
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Check For:
Example Section:
existence of any listed species offish, wildlife, or plants, or (2) result in
destruction or adverse modification of critical habitats. If the prospective permit
applicant has reason to believe that the combustion unit may affect listed species
or critical habitat, the applicant may request U.S. EPA to enter into early
consultation with FWS. Section 7(a)(3) of ESA authorizes prospective permit
applicants to request, in writing, an early consultation with FWS to determine
whether the proposed action is likely to violate the ESA. Early consultation
should be conducted before the permit application is filed and should involve
FWS, U.S. EPA, and the permit applicant, as specified in 40 CFR Part 402.11.
If FWS determines, after the preliminary consultation, that the proposed
activities may violate the provisions of ESA Section 7(a)(2), a formal
consultation is required and must be conducted as specified in 40 CFR Part
402.11. After concluding the final consultation, the FWS must deliver a
"biological opinion" stating whether proposed actions are likely to jeopardize the
continued existence of a listed species or will result in the destruction or adverse
modification of critical habitat (jeopardy biological opinion). A jeopardy
biological opinion must include alternatives, if any, that the permit applicant can
take to minimize the impact of proposed activities on listed species and critical
habitats. If FWS is unable to develop such alternatives, it must indicate that, to
the best of its knowledge, no reasonable and prudent alternatives exist.
CZMA requires all federally conducted or supported activities, including
development projects directly affecting the coastal zone, to be implemented in a
manner consistent with approved state coastal zone management programs.
Federally licensed or permitted activities affecting the coastal zone also must be
conducted in a manner consistent with the state's approved management
programs. States are authorized to review federal permit applications to
determine whether proposed activities are consistent with approved states
coastal zone management plans.
If combustion unit construction involves the modification of any body of water,
FWCA requires U.S. EPA to consult with the appropriate state agency to ensure
that the proposal conserves wildlife resources.
The reviewer should check for the following:
• Compliance with WSRA
• Compliance with NHPA
• Compliance with ESA
• Compliance with CZMA
Compliance with FWCA
One of the most common deficiencies in permit applications with regard to other
federal laws is inadequate documentation to demonstrate that the facility has
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investigated how these laws affect its operations. Clark reviews a permit
application which simply states that there are no endangered species likely to be
affected by combustion unit operation. This application is inadequate without
documentation to show how that conclusion was reached.
Example Comments: Clark asks that the facility clarify whether the discussion of endangered species
means that there are no endangered species identified in the area or that there are
endangered species in the area not likely to be affected by the combustion unit.
In either case, he also requests that the facility provide the rationale for this
determination, such as written opinion from the FWS.
Notes:
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14.0 REVIEWING THE FACILITY CERTIFICATION—SECTION L
Regulation:
Guidance:
Explanation:
Check For:
Example Situation:
40 CFR Part 270.11
No specific references are applicable to this section of the manual.
This information normally appears as Section L of the permit application. All
permit applications must be accompanied by a certification letter, as specified in
40 CFR Part 270.1 l(d). The responsible individual must sign the certification
letter. The regulation identifies the appropriate responsible individual for the
following business scenarios: (1) a corporation, (2) a partnership or sole
proprietorship, and (3) a municipality, state, federal, or other public agency.
The reviewer should check for the following:
Ensure that the language in the facility's certification letter matches
exactly 40 CFR Part 270.1 l(d).
The facility should identify which of the three business scenarios listed
above applies.
Confirm that the certification letter signatory complies with 40 CFR Part
270.1 l(d) requirements.
Confirm that the certification letter is currently signed by the correct
corporate officer. If the application is a modification, check to see if the
individual listed has changed since the last permit application review.
Lois reads the Section Certification section of the part B permit application, as
presented in Exhibit 14.0-1, (see page 3-189).
Example Comments: According to 40 CFR Part 270.11, the Part B permit application must contain a
certification letter with an appropriate signatory. For a corporation, the
signatory must be a principal executive officer at least at the level of vice
president. However, the facility certification letter has been signed by the plant
manager. Lois asks that the facility either revise this section to explain how the
plant manager meets the required signatory level, or submit a new certification
letter reflecting an appropriate signatory.
Notes:
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
EXHIBIT 14.0-1
EXAMPLE PART B PERMIT APPLICATION CERTIFICATION
SECTION L
CERTIFICATION
[40 CFR Part 270.11(D), K.A.R. 28-3 l-9a]
"I certify under penalty of the law that this document and all
attachments were prepared under my direction or supervision, in
accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system or those
persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief,
true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of
fine and imprisonment for knowing violations."
Date: Signature: Original Signed by Plant Manager
Plant Manager
15.0 PREPARING NOTICE OF DEFICIENCIES
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Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Parts 124 and 270 Subpart B
40 CFR Part 270.62
40 CFR Part 270.66
No specific references are applicable to this section of the manual.
Any deficiencies identified during the completeness and technical adequacy
evaluation of the permit application are documented in an NOD that is sent to
the applicant. The NOD generally consists of an introductory cover letter, a
summary of major deficiencies, and a listing of specific deficiencies with
descriptive comments. The NOD also may contain attachments, such as a copy
of the completed Part B permit application review checklist and references to
guidance documents or other information, to assist the applicant in revising the
application.
The reviewer should consider the following in preparation of the NOD:
• Timing for notification of major gaps or deficiencies in the permit
application (see Section 15.1)
Comments that would help the applicant address the issues adequately
(see Section 15.2)
Attachments that may be helpful to the applicant (see Section 15.3)
Meetings after the applicant has reviewed the NOD (see Section 15.4)
While reviewing the TBP in the Part B permit application, Lois notes that XYZ
Company does not propose to test for dioxins and furans in stack gas samples.
Example Comments: Lois prepares the following comment:
"The facility does not propose to test for dioxin and furans. Revise the TBP to
specify stack gas sampling and analysis for dioxins and furans. The current
accepted methodology for dioxin testing is Method 0023A found in U.S. EPA
1996 SW-846. Dioxin and furan testing is required because these compounds
have been shown to be significant contributors to risk in indirect risk
assessments."
Notes:
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15.1 THE TIMING
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
No regulations are applicable to this section of the manual
No specific references are applicable to this section of the manual.
During review of the permit application, it is more efficient to identify and
immediately report major gaps or deficiencies to the applicant. In the meantime,
if the application is not entirely inadequate, the reviewer may continue
evaluating sections of the application that are not affected by revisions.
By notifying the applicant immediately of "major problems" in an initial NOD
(such as major sections that are incomplete, or sections that clearly do not meet
technical adequacy criteria) rather than wait until a formal NOD is sent, the
applicant can anticipate and begin to revise those sections of the application. A
more detailed NOD can follow later after the more detailed review is completed.
The reviewer should:
Identify and immediately set aside sections of the application that are
clearly deficient and review only those sections that will not be altered
by revisions
Notify the applicant by telephone of sections that will require major
revisions
• Send written NODs outlining major problems
Continue review of the sections not substantially deficient
Review revised application addressing major problems as outlined in the
first NOD
• Send comprehensive NOD
As Clark begins to review the Part B permit application for XYZ Company, he
notices that the facility has submitted a permit application without the TBP.
Example Comments: Clark prepares the following letter to the facility:
"U.S. EPA Region 6 has reviewed your BIF Part B permit application and found
that you did not submit a TBP in accordance with 40 CFR Part 270.22.
"Pursuant to 40 CFR Part 124.3(c), you are required to submit a TBP to U.S.
EPA Region 6 within 30 days from the date of this letter. U.S. EPA Region 6
will review the plan within 15 days of its submittal. The trial burn report should
also be submitted to U.S. EPA Region 6 within 100 days from the completion
date of the trial burn, but no later than May 1, 1997.
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"Pursuant to 40 CFR Part 270.10(e)(5), failure to submit a timely or complete
Part B application for facilities that qualify for interim status is grounds for
termination of interim status. Therefore, failure to correct these deficiencies
may result in an enforcement action.
"To assist you in the preparation of a TBP, enclosed is a copy of the U.S. EPA
Region 6 Generic TBP. This plan may serve as guidance for trial burn
performance objectives, methodology, and protocol that should be considered to
obtain the data necessary for permitting purposes."
Notes:
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15.2 THE COMMENTS
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 124
No specific references are applicable to this section of the manual.
The specificity of the reviewer's comments contained in the NOD will largely
affect how well the applicant revises the permit application. In general,
comments should cite specific sections or exact needs in terms of data,
documentation, or explanation to satisfy regulatory requirements. If necessary,
cite examples in relevant guidance documents to demonstrate what is needed.
Vague comments, such as "be more specific" or "provide more explanation,"
will result in further misunderstanding and will require additional rounds of
reviews and revisions.
The reviewer should:
Review all comments associated with technical inadequacies to ensure
that they are not vague, but state specifically the information required
Write comments objectively; do not try to assume the facility's position,
attitude, or rationale underlying a poorly prepared or inadequate section
Attempt to promote only one round of revisions by preparing specific
and direct comments identifying incomplete and technically inadequate
sections of the application
The XYZ Company TBP was reviewed by Lois and Clark and found to be
deficient in many areas. For example, Lois noticed that the CEMS used to
monitor CO would be capable of accurately measuring CO concentrations in the
stack up to 500 ppmv. Lois knew that U.S. EPA requirements for this critical
combustion indicator constituent required dual range devices so that the
magnitude of upset conditions could be measured as well as concentrations
during normal operations.
Example Comments: Lois wrote XYZ Company an NOD requesting more detail on the CEMS and
particularly on the CO analyzer.
Lois should also reference the Appendix IX performance specification test
requirements and inform XYZ Company that a single range CO instrument is
not acceptable.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-194
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
15.3 THE ATTACHMENTS
Regulations:
Guidance:
Explanation:
Check For:
No regulations are applicable to this section of the manual.
No specific references are applicable to this section of the manual.
Various attachments, such as completed checklists, copied sections of relevant
guidance documents, or references to guidance or policy documents, may be
included with the NOD. In particular, it is often advantageous to provide the
applicant with a copy of completed checklists and other internal working
documents used to review the application as an attachment to the NOD. These
attachments will assist the applicant to not only better organize the revisions, but
to better understand the regulatory agency's rationale or justification for
deeming the application technically inadequate.
The reviewer should consider:
Providing completed checklists as an attachment to the NOD
Specifically referencing guidance documents used during the review or
providing a list of those documents as an attachment to the NOD
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-195
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
15.4 THE MEETING
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
No regulations are applicable to this section of the manual.
No specific references are applicable to this section of the manual.
It may be advantageous to schedule a meeting with the applicant after receipt
and review of the NOD. A meeting may help to clarify deficiencies noted in the
application and to discuss other issues, such as expanded public participation
during the permitting process.
Prepare for the meeting by:
• Reviewing the deficiencies identified in the NOD and discussing with
team members the best approach for resolving them with the applicant
Obtaining all guidance and policy documents used or cited to justify
NODs. Those documents should be brought to the meeting and
discussed, if necessary
Developing an agenda to keep the meeting focused
Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-196
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
16.0 THE COMPLETE PART B PERMIT APPLICATION
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Parts 124 and 270 Subpart B
40 CFR Part 270.62
40 CFR Part 270.66
No specific references are applicable to this section of the manual.
After the regulatory agency sends the facility an NOD regarding the permit
application, the facility will be allowed a specified time to respond. Subsequent
revisions must be reviewed for completeness and technical adequacy. If further
revisions are required, the regulatory agency may again issue NODs. The
regulatory agency must notify the applicant after the application is deemed
complete. However, if the facility continues to provide inadequate information
or fails to respond in a timely manner, the agency may consider issuing a
"Notice of Intent to Deny." If this notice is issued, a public comment period
must take place followed by a final permit determination and potential appeals.
At an IS facility where hazardous waste management is ongoing, submittal of the
complete Part B permit application can take a very long time. In the meantime,
since the TBP is usually a stand alone document, the permit authority will
request the RCRA trial burn be conducted. This occurs in order to establish
permit limits for the combustion unit incorporating performance standards
published as regulations. The TBP will be submitted, reviewed, revised, and the
trial burn conducted before the complete Part B permit application is submitted.
Assuming that the Part B application is complete and technically adequate, the
following eight steps occur for new facilities: (1) preparation of the draft
permit; (2) public comment on the draft permit; (3) permit determination (in
four-phases); (4) construction and pretrial burn operation (Phase 1); (5) of the
trial burn (Phase 2); (6) post-trial burn operation (Phase 3); (7) final operating
conditions (Phase 4); and (8) potential permit appeals. After the trial burn, an
additional public comment period may be required if final operating conditions
require major modifications (for example, an additional trial burn).
The permit reviewer, after reviewing the Part B permit application, should:
Prepare a draft permit or "notice of intent to deny"
Allow for a public comment period
Complete permit appeals process
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-197
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-198
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
16.1 DRAFT PERMIT OR "NOTICE OF INTENT TO DENY'
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 124, Subparts A and B
No specific references are applicable to this section of the manual.
After review of the Part B permit application and completion of the trial burn (in
the case of existing facilities), the regulatory agency will prepare a draft permit
determination. If the facility is unable to meet statutory or regulatory standards,
a "Notice of Intent to Deny" is prepared. The U.S. EPA Region 6 Model RCRA
Permits (see Component 7, Attachments C through F) are excellent guides to
preparing a permit using a modular approach to the permit structure.
The reviewer should examine the following prior to issuing a draft permit:
The classification as either major or minor is assigned to the facility by
the U.S. EPA Regional Director or authorized state agency director. A
major HWM facility is considered the subject of widespread public
interest or raises major issues [See 40 CFR Part 124.8 (a)]. A minor
HWM facility is simply a non-major HWM facility. Draft permits for
hazardous waste combustion units normally require preparation of a fact
sheet.
If the facility is categorized as major, confirm that a fact sheet is
prepared (see 40 CFR Part 124.8).
If the facility is categorized as minor, confirm that a statement of basis is
prepared (see 40 CFR Part 124.7).
Supporting documents and notes and correspondence associated with
drafting the permit must be placed in the administrative record for the
facility.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-199
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
16.2 THE PUBLIC COMMENT PERIOD
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 124
No specific references are applicable to this section of the manual.
After preparation of the draft permit or in the case of a "Notice of Intent to
Deny," the regulatory agency must allow a public comment period. During this
period, the regulatory agency solicits, reviews, and responds to public
comments. For RCRA permits, the public notice must allow at least 45 days for
comment.
The agency must prepare a "Response to Public Comments." This document
responds to major comments and explains what, if any, provisions of the draft
permit have been changed as a result.
During the public comment period, anyone including the permitting agency may
request a public hearing. The agency must provide 30 days notice before the
hearing starts. In a hearing, arguments for and against the permit are presented
by various individuals and organizations, such as environmental groups,
neighborhood organizations, the facility, and the permitting agency. A
governmental board or commission presides over the hearing and passes
judgement in favor of or opposing issuing the permit.
Since promulgation of the Expanded Public Participation Rule (see Section 1.3
of this component), the public is encouraged to be involved in the permitting
process before the permit application is submitted throughout review of the
application, and during permit preparation. To promote community awareness
and understanding, facilities are encouraged to coordinate a public involvement
program that incorporates public meetings, facility tours, and information
transfer. The permitting agency is responsible for various public notices and
directing facilities to U.S. EPA guidance documents that suggest effective
methods for public involvement.
The administrative record must be established and maintained,
see 40 CFR Parts 124.6(e) and 124.9 for requirements
All public comments are collected and accounted for (including oral
comments submitted during the public hearing)
"Response to Public Comments" must be prepared within
60 days after the close of the comment period.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-200
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-201
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
16.3 APPEALS
Regulations:
Guidance:
Explanation:
40 CFR Part 124
No specific references are applicable to this section of the manual.
After a permit decision is made, any person who filed comments on the draft
permit or participated in the public hearing on the draft permit may petition the
U.S. Environmental Appeals Board (EAB) to review any condition of the permit
decision.
After the administrative permit appeals process has been completed, the
petitioner could then seek judicial review in federal court. However, the
decision of the EAB is final pending a decision in federal court, unless the
federal court grants a petition to stay the EAB's decision pending the decision of
the federal court.
Check For: Not applicable to this section of the manual.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-202
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COMPONENT 3— HOW TO REVIEW A PART B PERMIT APPLICATION
17.0 FUTURE CHANGES TO THE PART B APPLICATION
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 270 Subpart D
No specific references are applicable to this section of the manual.
Facilities may require modifications to existing RCRA permits for various
reasons; including a change in facility operations, or statutory or regulatory
changes.
U.S. EPA has established three classes of permit modifications and
administrative procedures for approving modifications in each (see 40 CFR Part
270.42 Appendix I).
Class 1 addresses routine and administrative changes and represents a
range of modifications with the least potential for environmental impact
(see Section 17.1).
Class 2 primarily addresses improvements in technology and
management techniques and represents a range of modifications with
moderate potential for environmental impact (see Section 17.2).
Class 3 represents major changes to a facility and its operations and
represents a range of modifications with the greatest potential for
environmental impact (see Section 17.3).
In some final rulemakings, U.S. EPA will explain whether new requirements
will obligate permitted facilities to obtain a Class 1, 2, or 3 modification. Class 2
and 3 modifications require public comment periods. U.S. EPA can also allow
temporary authorization to allow the facility to complete form closure or
corrective action activities while awaiting approval of permit modifications (see
Section 17.4).
The reviewer should check for the following:
• A reference to Appendix I of 40 CFR Part 270.42 as to whether the
proposed modification meets one of the listed modifications
Sufficient explanation of the change to clearly demonstrate which class
applies
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-203
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
11.1 CLASS 1 MODIFICATIONS
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 270.42
No specific references are applicable to this section of the manual.
In general, Class 1 modifications do not require approval by the regulatory
agency before they are implemented. Within 90 days of implementing the
change, a facility making a Class 1 modification must notify the public by
sending a notice to all parties on its mailing list. Any member of the public may
request the regulatory agency to review a Class 1 modification. In addition, U.S.
EPA may deny any Class 1 modification. These types of changes typically apply
to information in the Part A permit application and the general information
section of the Part B permit application
Whether the modification appears in Appendix I to 40 CFR Part 270.42
Examples of Class 1 modifications include:
Correction of typographical errors
Changes in name, address, or telephone numbers of emergency
coordinators
Example Comments: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-204
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
17.2 CLASS 2 MODIFICATIONS
Regulations: 40 CFR Part 270.42
Guidance:
Explanation:
Check For:
Example Section:
No specific references are applicable to this section of the manual.
Class 2 modifications require the facility to submit a request for approval of the
change to the permitting agency. A facility may begin construction 60 days after
submitting a request, although the permitting agency may delay all or part of the
construction.
The facility must notify citizens and organizations on the facility mailing list
about the modification and publish a notice in a major local newspaper. This
notice must occur within 7 days of the facility's change request. The newspaper
notice marks the start of a 60-day comment period and also announces the time
and place of an informal meeting. The permitting agency must consider those
comments before rendering a final permit decision.
Class 2 permit modifications include a default provision to ensure that the
permitting agency responds promptly to the facility's request. The permitting
agency may upgrade the facility's request to a Class 3 if there is significant
public concern or if the facility's request is too complex for Class 2 procedures.
Whether the modification appears in Appendix I to 40 CFR Part 270.42
Examples of Class 2 modifications include:
Change of inspection schedule frequency or content
Modification of tank unit or secondary containment system
without increasing system capacity
Example Comments: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-205
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
17.3 CLASS 3 MODIFICATIONS
Regulations:
Guidance:
Explanation:
40 CFR Part 270.42
No specific references are applicable to this section of the manual.
Class 3 modifications must initially follow the same public notice, comment, and
meeting procedures as for Class 2. The permitting agency must prepare a draft
permit modification, allow 45 days for public comment on the draft, hold a
public hearing, if requested, and then issue or deny the permit modification
request.
Whether the modification appears in Appendix I to 40 CFR Part 270.42
Examples of Class 3 modifications include:
Change to increased feed rate to a BIF unit by more than 25
percent
Extension of final compliance date
Example Comments: Not applicable to this section of the manual.
Notes:
Check For:
Example Section:
U.S. EPA Region 6
Center for Combustion Science and Engineering
3-206
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COMPONENT 3—HOW TO REVIEW A PART B PERMIT APPLICATION
17 A TEMPORARY AUTHORIZATION
Regulations: 40 CFR Part 270.42
Guidance: No specific references are applicable to this section of the manual.
Explanation: For certain Class 2 or 3 modifications, the permitting agency may grant a facility
temporary authorization for certain activities, such as corrective action or closure
activities, for up to 180 days. The facility must notify the public within 7 days
of making the request. However, the permitting agency may grant temporary
authorization without notifying the public. A facility may renew a temporary
authorization only by requesting a permit modification and initiating public
participation.
Check For: Not applicable to this section of the manual.
Example Section: Not applicable to this section of the manual.
Example Comments: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 3-207
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ATTACHMENT A
EXAMPLE PART B PERMIT APPLICATION FORM
(108 Sheets)
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TEXAS NATURAL RESOURCE CONSERVATION COMMISSION
PERMIT APPLICATION FOR
INDUSTRIAL AND HAZARDOUS WASTE
STORAGE/PROCESSING/DISPOSAL FACILITY
PART B
FORM AVAILABILITY:
This form, as well as other Industrial and Hazardous Waste documents, is available on the TNRCC OnLine bulletin
board service at (512) 239-0700 and on the Internet World Wide Web, Waste Management home page at address
http://www.tnrcc.state.tx.us
INTRODUCTION:
This permit application is generally a reorganized summary of the Part B information requirements of 40 CFR Part
270 and 30 Texas Administrative Code (TAG) Chapter 305 Subchapters C and D and Chapter 335. The TNRCC
may request additional information before a permit is issued, if regulatory requirements change.
The original application plus all copies should be submitted to:
Texas Natural Resource Conservation Commission
Attention: Permits Section, MCI30
Industrial & Hazardous Waste Division
P. O. Box 13087
Austin, Texas 78711-3087
TELEPHONE INQUIRIES: (512) 239-6595 - Technical - Permits Section, Industrial & Hazardous Waste Division
(512) 239-6832 - Waste Identification - Waste Evaluation Section, Industrial &
Hazardous Waste Division
(512) 239-1230 - Office of Air Quality, New Source Review
(512) 239-0600 - Legal - Legal Division
(512) 239-0357 - Fees - Financial Administration Division
APPLICATION REVIEW PROHIBITION:
The Texas Natural Resource Conservation Commission (TNRCC) shall not review an application for a new
commercial hazardous waste facility, and the application shall be deemed not to have been received, until the
emergency response information required by Section III.F. of the application has been reviewed and declared by
TNRCC staff to be complete and satisfactory. [30 TAG 281.26, 30 TAG 305.50(12)(c)(I)]
PERMIT ISSUANCE PROHIBITED [30 TAG 335.205]: The TNRCC shall not issue a permit for:
1. a new hazardous waste management facility or an areal expansion of an existing facility if the facility or expansion
does not meet the requirements of 30 TAG 335.204 (relating to Unsuitable Site Characteristics).
2. a new hazardous waste landfill or the areal expansion of an existing hazardous waste landfill if there is a practical,
economic, and feasible alternative to such a landfill that is reasonably available to manage the types and classes of
hazardous waste which might be disposed of at the landfill.
TNRCC Part B Instructions
TNRCC-0376 (Rev 3/11/97) 3-A-l
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3. a new commercial hazardous waste management facility as defined in 30 TAG 335.202 (relating to Definitions) or
the subsequent areal expansion of such a facility or unit of that facility if the owner/operator proposes to locate the
boundary of the unit within 1A of a mile (2,640 feet) of an established residence, church, school, day care center,
surface water body used for a public drinking water supply, or dedicated public park.
4. a new commercial hazardous waste management facility that is proposed to be located at a distance greater than 1A
mile (2,640 feet) from an established residence, church, school, day care center, surface water body used for a public
drinking water supply, or dedicated public park unless the applicant demonstrates to the satisfaction of the
commission that the facility will be operated so as to safeguard public health and welfare and protect physical
property and the environment, at any distance beyond the facility's property boundaries.
5. a proposed hazardous waste management facility, or a capacity expansion of an existing hazardous waste
management facility if a fault exists within 3,000 feet of the proposed hazardous waste management facility or of the
capacity expansion of an existing hazardous waste management facility unless the applicant performs the
demonstration found in 30 TAG 335.205(h).
See 30 TAG 335 Subchapter G: Location Standards for Hazardous Waste Storage, Processing, or Disposal for additional
details and information.
COMPLETING THIS APPLICATION:
This permit application form has been designed to solicit specific information, with reports to be attached or
inserted. A response must be made for each informational request in the application form. If an item is not
applicable please state "not applicable" and explain. All information included in the application must be listed by
the format of the application. For example, if an engineering report is attached to the application to fulfill the
requirements of Section V, then each subsection of the engineering report must correlate with the corresponding
subsection in the application form (e.g., Subsection V.A.2. of the report would be proposed construction schedules).
If information is provided which does not correspond with the application form, the specific rule or regulation which
requires submittal of the information must be cited. Each report should be attached behind the summary form or
table for the report and submitted as one document with the pages sequentially numbered at the bottom. Maps,
bluelines, and drawings that cannot be folded to 8-1/2" x 11" may be submitted as separate documents. Engineering
plans and specifications submitted with an application must be approved and sealed by a Registered Professional
Engineer, with current registration required by the Texas Engineering Practice Act.
Facilities which will receive industrial and hazardous wastes from off-site sources must also provide information on
these wastes and associated waste management units in accordance with 30 TAG 335.2.
For those who pre-filed a Part A application, certain items may have been omitted. These omissions must be
addressed at this time. Additionally, if hazardous waste management methods have changed since the filing of the
Part A, please provide an updated Part A.
Pursuant to Section 361.067 of the Texas Solid Waste Disposal Act, the TNRCC is required to mail a copy of this
application or a summary of its contents to other regulatory agencies. Section I may be considered a summary of the
entire application provided that all questions are completely answered. Therefore, Section I responses must not rely
solely on cross-references to other sections of the application.
GROUNDWATER CONTAMINATION:
If groundwater monitoring has detected the presence of hazardous constituents in the facility ground water, the
owner or operator must submit a Compliance Plan Application in addition to this application. The TNRCC Permits
Section, Industrial and Hazardous Waste Division can provide the Compliance Plan Application form.
SUBMITTAL:
The complete application should be typewritten or printed neatly in black ink. If the application has been prepared
using word processing, the third copy should consist of paper copies of all plans and maps and a computer diskette
of the remaining document. The document should be formatted in WordPerfect® word processing software up to and
including version 6.1 or a 100% compatible format. Files may be compressed using PKZIP® Ver. 2 or a 100%
compatible program.
TNRCC Part B Instructions
TNRCC-0376 (Rev 3/11/97) 3-A-2
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For a new, original permit application or renewal, submit:
1. an original updated Part A permit application plus three (3) full copies, if appropriate;
2. the original Part B application plus three (3) full copies;
3. six (6) additional copies of Section I: General Information; and
4. a check for payment of permit application fees transmitted directly to the TNRCC Financial Administration
Division with a photostatic copy of the check included in the original Part B permit application.
For major amendments to an issued hazardous waste permit, submit:
1. an original updated Part A permit application plus three (3) full copies, if appropriate;
2. an original Part B application plus three (3) full copies, consisting of, at a minimum, Section I of the Part B
plus replacement pages for the changed portions of the application that change as a result of the
amendment;
3. an explanation of why the major amendment is needed;
4. six (6) additional copies of Section I: General Information; and
5. a check for payment of permit application fees transmitted directly to the TNRCC Financial Administration
Division with a photostatic copy of the check included in the original Part B permit amendment
application.
For minor amendments to an issued hazardous waste permit, submit:
1. an original updated Part A permit application plus three (3) full copies, if appropriate;
2. an original Part B application plus three (3) full copies, consisting of, at a minimum, Section I of the Part B
plus replacement pages for the changed portions of the application that change as a result of the
amendment; and
3. an explanation of why the minor amendment is needed; and
4. a check for payment of permit application fees transmitted directly to the TNRCC Financial Administration
Division with a photostatic copy of the check included in the original Part B permit amendment
application.
For Class 3 modifications to an issued hazardous waste permit, submit:
1. an original updated Part A permit application plus three (3) full copies, if appropriate;
2. an original Part B application plus three (3) full copies, consisting of, at a minimum, Section I of the Part B
plus replacement pages for the changed portions of the application that change as a result of the
modification;
3. a description of the exact changes to be made to the permit conditions and supporting documents
referenced by the permit;
4. an explanation of why the Class 3 modification is needed;
5. evidence of the public notice mailing and publication (after the public meeting, please submit a statement
that the public meeting was held within the required timeframes); and
6. a check for payment of permit application fees transmitted directly to the TNRCC Financial Administration
Division with a photostatic copy of the check included in the original Part B permit modification
application.
For Class 2 modifications to an issued hazardous waste permit, submit:
1. an original updated Part A permit application plus three (3) full copies, if appropriate;
2. an original Part B application plus three (3) full copies, consisting of, at a minimum, Section I of the Part B
plus replacement pages for the changed portions of the application that change as a result of the
modification;
3. a description of the exact changes to be made to the permit conditions and supporting documents
referenced by the permit;
4. an explanation of why the Class 2 modification is needed;
5. evidence of the public notice mailing and publication (after the public meeting, please submit a statement
that the public meeting was held within the required timeframes); and
6. a check for payment of permit application fees transmitted directly to the TNRCC Financial Administration
Division with a photostatic copy of the check included in the original Part B permit modification
application.
For Class 1' modifications to an issued hazardous waste permit, submit:
TNRCC Part B Instructions
TNRCC-0376 (Rev 3/11/97) 3-A-3
-------
1. An original updated Part A permit application plus three (3) full copies, if appropriate;
2. an original Part B application plus three (3) full copies, consisting of, at a minimum, Section I of the Part B
plus replacement pages for the changed portions of the application that change as a result of the
modification;
3. a description of the exact changes to be made to the permit conditions and supporting documents
referenced by the permit;
4. an explanation of why the Class I1 modification is needed;
5. a check for payment of permit application fees transmitted directly to the TNRCC Financial Administration
Division with a photostatic copy of the check included in the original Part B permit modification
application.
For Class 1 modifications to an issued hazardous waste permit, submit:
1. an original Part B application plus three (3) full copies, consisting of, at a minimum, Section I of the Part B
plus replacement pages for the changed portions of the application that change as a result of the
modification;
2. a description of the exact changes to be made to the permit conditions and supporting documents referenced
by the permit;
3. an explanation of why the Class 1 modification is needed;
4. a check for payment of permit application fees transmitted directly to the TNRCC Financial Administration
Division with a photostatic copy of the check included in the original Part B permit application.
If several modifications are submitted as one application, the application review will proceed at rate of the amendment or
modification which has the longest timeframe.
APPLICATION REVISIONS:
Please submit any application revisions with a revised date and page numbers at the bottom of the page(s).
WAIVERS:
Any request for waiver of any of the applicable requirements of this permit application must be fully documented.
DESIGNATION OF MATERIAL AS CONFIDENTIAL:
The designation of material as confidential is frequently carried to excess. The Commission has a responsibility to
provide a copy of each application to other review agencies and to interested persons upon request and to safeguard
confidential material from becoming public knowledge. Thus, the Commission requests that the applicant (1) be
prudent in the designation of material as confidential and (2) submit such material only when it might be essential to
the staff in their development of a recommendation.
The Commission suggests that the applicant NOT submit confidential information as part of the permit application.
However, if this cannot avoided, the confidential information should be described in non-confidential terms
throughout the application, cross-referenced to Section XII: Confidential Material, and submitted as a separate Section
XII. document or binder, and conspicuously marked "CONFIDENTIAL."
Reasons of confidentiality include the concept of trade secrecy and other related legal concepts which give a business
the right to preserve confidentiality of business information to obtain or retain advantages from its right in the
information. This includes authorizations under 5 U.S.C. 5552(b)(4), 18 U.S.C. 1905, and special rules cited in 40 CFR
552.301-2.309
Section 361.037 of the Texas Solid Waste Disposal Act does not allow an applicant for an industrial solid waste permit
to claim as confidential any record pertaining to the characteristics of the industrial solid waste.
The applicant may elect to withdraw any confidential material submitted with the application. However, the permit
cannot be issued, amended, or modified if the application is incomplete.
EPA EXPOSURE ASSESSMENT:
TNRCC Part B Instructions
TNRCC-0376 (Rev 3/11/97) 3-A-4
-------
In accordance with 30 TAG 305.50(8) and 40 CFR 270.100, any Part B application submitted for a facility that stores,
processes, or disposes of hazardous waste in a surface impoundment or a landfill (including post-closure) must be
accompanied by exposure information of the potential for the public to be exposed to hazardous wastes or hazardous
constituents through releases related to the unit. This exposure information is considered separate from the permit
application, as stated in 40 CFR 270.10(c).
PRE-APPLICATION MEETING/PUBLIC PARTICIPATION ACTIVITIES [30 TAG 335.391]:
The TNRCC encourages applicants to hold a pre-application meeting with the public to allow both the applicant and
the public to identify potential issues. Applicants are also encouraged to hold a pre-application meeting with TNRCC
Permits Section staff and to notify the Permits Section, Industrial and Hazardous Waste Division of an intent to file a
permit application.
If a local review committee has been established to facilitate communication between the applicant and the local host
community, the applicant should summarize the activities of the committee and submit this summary with the
application. Any report completed by the review committee must also be submitted.
TNRCC Part B Instructions
TNRCC-0376 (Rev 3/11/97) 3-A-5
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SAMPLE APPLICATION MAP
ALL ADJACENT LANDOWNERS SHALL BE IDENTIFIED
RESIDENTIAL
2
INDUSTRIAL
UNDEVELOPED
4
UNDEVELOPED
1
2nd Street
INDUSTRIAL
NDUSTRIAL
UNDEVELOPED
INDUSTRIAL
mile
Scale
TNRCC Part B Instructions
TNRCC-0376 (Rev 3/11/97)
3-A-6
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LANDOWNERS CROSS-REFERENCED TO
APPLICATION MAP
The persons identified below would be considered as affected persons.
1. Mr. & Mrs. Samuel L. Davis
11901 Knights Bridge
Austin, Texas 78759
2. Mr. & Mrs. Edward Sanchez
1405 Craigmont Lane
Waco, Texas 76710
3. Tex-Link Corp.
8411 Zip Street
Houston, Texas 77590
4. Mr. & Mrs. Ted Goldsby
3210 20th Street
Waco, Texas 76724
5. Jaxson Brewing Co.
4240 Line Road
Dallas, Texas 77640
6. Plainview Company
6647 Star Blvd.
Houston, Texas 77590
7. ABC Chemicals, Inc.
1212 Austin Ave.
Dallas, Texas 77640
8. Big-C Bottle Co.
10024 N.W.Hwy.
Bovina, Texas 79402
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Table of Contents
I. GENERAL INFORMATION 1
A. Applicant 1
B. Authorized Persons 1
C. Facility 2
D. Application Type and Facility Status 2
E. Facility Siting Summary 3
F. Wastewater and Stormwater Disposition 3
G. Adjacent Landowners List 4
H. Signature on Application 4
II. FACILITY SITING CRITERIA 7
A. Requirements for Storage or Processing Facilities, Land Treatment Facilities, Waste Piles, Storage
Surface Impoundments, and Landfills 7
B. Additional Requirements for Storage Surface Impoundments 8
C. Additional Requirements for Waste Piles 9
D. Additional Requirements for Land Treatment Facilities 9
E. Additional Requirements for Landfills (and Surface Impoundments Closed as Landfills with Wastes in
Place) 10
F. Flooding 10
G. Additional Information Requirements 11
III. FACILITY MANAGEMENT 12
A. Compliance History and Applicant Experience 12
B. Personnel Training Plan 12
C. Security 12
D. Inspection Schedule 12
E. Contingency Plan 13
F. Emergency Response Plan 14
TABLE HID. INSPECTION SCHEDULE 16
TABLE III.E.l ARRANGEMENTS withLOCAL AUTHORITIES 17
TABLE III.E.2. EMERGENCY COORDINATORS 18
TABLE III.E.3. EMERGENCY EQUIPMENT 19
IV. WASTES AND WASTE ANALYSIS 20
TABLE IV.A. WASTE MANAGEMENT INFORMATION 21
TABLE IV.B. WASTES MANAGED IN PERMITTED UNITS 22
TABLE IV.C. SAMPLING AND ANALYTICAL METHODS 23
V. ENGINEERING REPORTS 24
A. General Engineering Reports 24
B. Container Storage Areas 25
C. Tank Systems and Secondary Containment 26
D. Surface Impoundments 26
E. Waste Pile Report 29
F. Land Treatment Units 32
G. Landfills 33
H. Incinerators 36
I. Boilers and Industrial Furnaces 37
J. Drip Pads 37
K. Miscellaneous Units 38
L. Containment Buildings 38
TABLE V.B CONTAINER STORAGE AREAS 39
TABLE V.C TANKS 40
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TABLE V.D.I SURFACE IMPOUNDMENTS 41
TABLE V.D.6 SURFACE IMPOUNDMENT LINER SYSTEM 42
TABLE V.E.I WASTE PILES 43
TABLE V.E.3 WASTE PILE LINER SYSTEM 44
TABLE V.F.I. LAND TREATMENT UNITS 45
TABLE V.F.2. LAND TREATMENT UNIT CAPACITY 46
TABLE V.F.3 LAND TREATMENT PRINCIPAL HAZARDOUS CONSTITUENTS 47
TABLE V.G.I. LANDFILLS 48
TABLE V.G.3. LANDFILL LINER SYSTEM 49
TABLE V.G.3 (continued) LANDFILL LEACHATE COLLECTION SYSTEM 50
TABLE V.H.I INCINERATORS 51
TABLE V.H.2 PRINCIPAL ORGANIC HAZARDOUS CONSTITUENTS 52
TABLE V.I.I BOILERS AND INDUSTRIAL FURNACES 53
TABLE V.I.2 PRINCIPAL ORGANIC HAZARDOUS CONSTITUENTS 54
TABLE V.J.I DRIP PADS 55
TABLE V.J.2 DRIP PAD SYNTHETIC LINER SYSTEM 56
TABLE V.K MISCELLANEOUS UNITS 57
TABLE V.L CONTAINMENT BUILDINGS 58
VI. GEOLOGY REPORT 59
A. Geology and Topography 59
B. Facility Ground Water 62
C. Exemption from Ground-water Monitoring for an Entire Facility 65
D. Unsaturated Zone Monitoring 65
TABLE VI.A.4 WASTE MANAGEMENT AREA SUBSURFACE CONDITIONS 67
TABLE VI.B.3.b UNIT GROUND WATER DETECTION MONITORING SYSTEM 68
TABLE VI.B.3.C GROUNDWATER SAMPLE ANALYSIS 69
VII. CLOSURE AND POST-CLOSURE PLANS 70
A. Closure 70
B. Closure Cost Estimate 70
C. Post-closure 71
D. Post-closure Cost Estimate 71
TABLE VILA UNIT CLOSURE 73
TABLE VII.B UNIT CLOSURE COST ESTIMATE 74
TABLE VII.C.5 LAND-BASED UNITS CLOSED UNDER INTERIM STATUS 75
TABLE VII.D UNIT POST-CLOSURE COST ESTIMATE 76
TABLE VILE CLOSURE/POST-CLOSURE COST SUMMARY 77
VIII. FINANCIAL ASSURANCE 78
A. Financial Assurance Information Requirements for all Applicants 78
B. Applicant Financial Disclosure Statements 78
C. Applicants Requesting Facility Expansion, Capacity Expansion, or New Construction 79
TABLE VIII.C ESTIMATED CAPITAL COSTS 80
IX. RELEASES FROM SOLID WASTE UNITS AND CORRECTIVE ACTION 81
A. Preliminary Review Checklists 82
B. Appendices to Preliminary Review 87
C. Preliminary Review Submittal Format 87
X. AIR EMISSION STANDARDS 88
A. Process Vents and Equipment Leaks 88
B. Optional TNRCC Office of Air Quality Information 89
TABLE X.A.1 Process Vents 91
TABLE X.A.3 Equipment Leaks 92
XI. HAZARDOUS WASTE PERMIT APPLICATION FEE 95
TABLE XI-1 HAZARDOUS WASTE UNITS (FOR APPLICATION FEE CALCULATIONS) 97
TABLE XI-2 HAZARDOUS WASTE PERMIT APPLICATION FEE WORKSHEET 98
TNRCC Part B Instructions
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XII. CONFIDENTIAL MATERIAL 99
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TNRCC Part B Instructions
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TEXAS NATURAL RESOURCE CONSERVATION COMMISSION
ATTN: Permits Section-MC130
Industrial and Hazardous Waste Division
P. O. Box 13087
Austin, Texas 78711-3087
INDUSTRIAL AND HAZARDOUS WASTE PART B PERMIT APPLICATION
I.GENERAL INFORMATION
A. Applicant1:
(Individual, Corporation, or Other Legal Entity Name)
Address:
City: State: Zip Code:
Telephone Number:
If the application is submitted on behalf of a corporation, please identify the Charter Number as recorded with the
Office of the Secretary of State for Texas.
(Charter Number)
B.Authorized Persons
1 .List those persons or firms, including a complete mailing address and telephone number, authorized to act for the
applicant during the processing of the permit application.
2.If the application is submitted by a corporation or by a person residing out of state, the applicant must register an
Agent in Service or Agent of Service with the Texas Secretary of State's office and provide a complete mailing address
for the agent. The agent must be a Texas resident.
3.List the individual and his/her mailing address that will be responsible for causing notice to be published in the
newspaper.
'The operator has the duty to submit an application [30 TAG 305.43(b)]. The permit will specify the
operator and the owner who is listed on Part A of this application [Section 361.087, Texas Solid Waste Disposal Act].
TNRCC Part B Application
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1C.Facility for which application is submitted:
(Facility Name)
Address:
City: , Texas Zip Code:_
Telephone Number:
TNRCC Registration No.: EPA ID. No.:.
County:
ID. Application Type and Facility Status
1. permit amendment modification
new major Class 3
interim status minor Class 2
renewal Class 1'
RD&D Class 1
2.In either column, check all that apply.
proposed hazardous waste management facility existing hazardous waste management facility
on-site on-site
off-site off-site
commercial commercial
recycler recycler
land disposal land disposal
areal or capacity expansion
3.1s the facility within the Coastal Management Program boundary? Yes. No.
For any questions regarding the Coastal Management Program, pleae contact 1-800/85-BEACH (852-3224).
4.Provide a brief verbal description of the portion of the facility covered by this application, including the changes for
which an amendment or modification is requested.
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I.E.Facility Siting Summary
Is the facility located or proposed to be located:
1.within a 100-year floodplain?
YES NO
2.in wetlands?
YES NO
3.in the critical habitat of an endangered species of plant or animal?
YES NO
4.on the recharge zone of a sole-source aquifer?
YES NO
5.in an area overlying a regional aquifer?
YES NO
6.(for a new commercial hazardous waste management facility or subsequent areal expansion of such a facility or unit
of that facility as defined in 30 TAG 335.202) within 1A of a mile (2,640 feet) of an established residence, church,
school, day care center, surface water body used for a public drinking water supply, or dedicated public park?
YES NO
If YES, the TNRCC shall not issue a permit for this facility.
I.F.Wastewater and Stormwater Disposition
1 .Is the disposal of any waste to be accomplished by a waste disposal well at this facility?
NO YES (WDW Permit No(s). )
2. Will any point source discharge of effluent or rainfall runoff occur as a result of the proposed activities?
YES NO
3.If YES, is this discharge regulated by a NPDES or TNRCC permit?
YESPermit No. (TNRCC)
Permit No. (NPDES)
NODate TNRCC discharge permit application filed.
Date NPDES discharge permit application filed
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I.G.Adjacent Landowners List
Submit a map indicating the boundaries of all adjacent parcels of land, and a list of the names and mailing addresses of
all adjacent landowners and other nearby landowners who might consider themselves affected by the activities
described by this application. Cross-reference this list to the map through the use of appropriate keying techniques.
The map should be a USGS map, a city or county plat, or another map, sketch, or drawing with a scale adequate
enough to show the cross-referenced affected landowners. The list should be updated prior to any required public
notice.
I.H. Signature on Application
The person who signs the application form will often be the applicant himself; when another person signs on behalf of
the applicant, his title or relationship to the applicant will be shown. In all cases, the person signing the form must be
authorized to do so by the applicant. An application submitted by a corporation must be signed by a principal
executive officer of at least the level of vice president or by his duly authorized representative, if such representative is
responsible for the overall operation of the facility from which the activity described in the form originates. In the
case of a partnership or a sole proprietorship, the application must be signed by a general partner or the proprietor,
respectively. In the case of a municipal, state, federal, or other public facility, the application must be signed by a
principal executive officer, a ranking elected official, or another duly authorized employee. A person signing an
application on behalf of an applicant must provide notarized proof of authorization.
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APPLICATION SIGNATURE PAGE
(applicant) (Title)
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 the submitted information is true, accurate and complete. I am aware there are
significant penalties for submitting false information, including the possibility of civil penalty and criminal fines.
Signature: Date:.
TO BE COMPLETED BY THE APPLICANT IF THE APPLICATION IS SIGNED BY AN AGENT FOR THE
APPLICANT
_, hereby designate.
(Print or Type Name) (Print or Type Name)
as my agent and hereby authorize said agent to sign any application, submit additional information as may be
requested by the Commission; and/or appear for me at any hearing or before the Texas Natural Resource Conservation
Commission in conjunction with this request for a Texas Water Code or Texas Solid Waste Disposal Act permit. I
further understand that I am responsible for the contents of this application, for oral statements given by my agent in
support of the application, and for compliance with the terms and conditions of any permit which might be issued
based upon this application.
Printed or Typed Name of Applicant or Principal Executive Officer
Signature
SUBSCRIBED AND SWORN to before me by the said.
on this day of , 199_
My commission expires on the day of , 199_
Notary Public in and for
County, Texas
(Note: Application Must Bear Signature & Seal of Notary Public)
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INTERIM STATUS LAND DISPOSAL UNIT(S) CERTIFICATION
For all land disposal units managing wastes which are newly listed or identified as hazardous wastes, the following
certification must be executed by or on the date 12 months after the effective date of the rule identifying or listing the
waste as hazardous. If the applicant fails to certify compliance with these requirements, the applicant shall lose
authority to operate under interim status. [40 CFR 270.73(d)]
(applicant) (Title)
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 the submitted information is true, accurate and complete.
I further certify that in accordance with Section 3005(e)(3) of the Resource Conservation and Recovery Act, as
amended, the subject land disposal unit(s) are in compliance with all applicable groundwater monitoring and financial
responsibility requirements of 30 TAG Sections 335.112, 335.116, and 335.117. I am aware there are significant
penalties for submitting false information, including the possibility of civil penalty, criminal fines, and imprisonment.
Signature: Date:
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II.FACILITY SITING CRITERIA.
Unless requesting an areal expansion, all existing hazardous waste management facilities and capacity expansions of
existing facilities need only complete Section II.F. and the applicable portions of II.G. Please note however, that
additional technical information may be requested to address any facility siting characteristics noted in Section I.E.
For all new hazardous waste management facilities or areal expansions of existing hazardous waste management
facilities, provide a Site Selection Report for the facility which includes all information regarding Unsuitable Site
Characteristics found in 30 TAG 335 Subchapter G. The report must address each requirement applicable to the type
of activity submitted in the application. Reference specific rule numbers whenever possible. Supporting information
may be cross-referenced to other parts of this application such as Section V - Engineering Report or Section VI -
Geology Report, but information submitted in previous applications must be fully reproduced herein. In addition,
provide the following information.
A.Requirements for Storage or Processing Facilities, Land Treatment Facilities, Waste Piles, Storage Surface
Impoundments, and Landfills.
Is the facility located or proposed to be located:
Lin wetlands?
YES NO
Provide the source of information.
2.in the critical habitat of an endangered species of plant or animal?
YES NO
Provide the source of information. If YES, then submit in Section V information demonstrating that design,
construction, and operational features will prevent adverse effects on such critical habitat.
3.on the recharge zone of a sole-source aquifer?
YES NO
Provide the source of the information. If YES, then for storage and processing facilities (excluding storage surface
impoundments), submit in Section V information demonstrating that secondary containment is provided to preclude
migration to groundwater from spills, leaks, or discharges. Land treatment facilities, waste piles, storage surface
impoundments, and landfills may not be located on the recharge zone of a sole-source aquifer.
4.in an area overlying a regional aquifer?
YES NO
If YES, then submit site-specific information in Section V and/or Section VI demonstrating compliance with 30 TAG
335.204(a)(4), (b)(4), (c)(4), (d)(4), or (e)(4), as applicable.
5.in areas where soil unit(s) are within five feet of the containment structure, or treatment zone, as applicable, that have
a Unified Soil Classification of GW, GP, GM, GC, SW, SP, or SM, or a hydraulic conductivity greater than 10'5 cm/sec?
YES NO
Provide information to verify the above. If YES, then provide additional information in Sections V and/or Section VI
demonstrating compliance with 30 TAG 335.204(a)(5), (b)(5), (c)(5), (d)(5), or (e)(5), as applicable.
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6.in areas of direct drainage within one mile of a lake at its maximum conservation pool level, if the lake is used to
supply public drinking water through a public water system?
YES NO
If YES, then provide information in Section V demonstrating compliance with 30 TAG 335.204 (a)(6), (b)(7), (c)(6), or
(e)(8) as applicable.
7.in areas of active geologic processes, including but not limited to erosion, submergence, subsidence, faulting, karst
formation, flooding in alluvial flood wash zones, meandering river bank cuttings, or earthquakes?
YES NO
If YES, then specify in Section V the design, construction, and operational features of the facility that will prevent
adverse effects resulting from the geologic processes.
8. within 30 feet of the upthrown side or 50 feet of the downthrown side of the actual or inferred surface expression of a
fault that has reasonably been shown to have caused displacement of shallow Quaternary sediments or of man-made
structures?
YES NO
If YES, then specify in Section V the design, construction, and operational features that will prevent adverse effects
resulting from any fault movement.
If a fault is found to be present, the width and location of the actual or inferred surface expression of the fault,
including both the identified zone of deformation and the combined uncertainties in locating a fault trace, must be
determined by a qualified geologist or geotechnical engineer and reported in Section VI.
II.B.Additional Requirements for Storage Surface Impoundments
Is the storage surface impoundment located or proposed to be located:
1.a. within 1000 feet of an area of active coastal shoreline erosion even though the area is protected by a barrier island
or peninsula?
YES NO
If YES, then submit in Section V.D design, construction and operational features of the facility which will prevent
adverse effects resulting from storm surge and erosion or scouring by water.
b.within 5000 feet of a coastal shoreline subject to active shoreline erosion and which is unprotected by a barrier
island or peninsula.
YES NO
If YES, then submit in Section V.D design, construction and operational features which will prevent adverse effects
resulting from storm surge and erosion or scouring by water.
2.on a barrier island or peninsula?
YES NO
II.C.Additional Requirements for Waste Piles
Is the waste pile located or proposed to be located:
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1.a. Within 1000 feet of an area subject to active coastal shoreline erosion even though the area is protected by a
barrier island or peninsula?
YES NO
If YES, then submit in Section V.E design, construction, and operational features on the facility which will prevent
adverse effects resulting from storm surge and erosion or scouring by water.
b. Within 5000 feet of a coastal shoreline subject to active shoreline erosion and which is unprotected by a barrier
island or peninsula.
YES NO
If YES, then submit Section V.E design, construction, and operational features which will prevent adverse effects
resulting from storm surge and erosion or scouring by water.
2.on a barrier island or peninsula?
YES NO
II.D.Additional Requirements for Land Treatment Facilities
Is the land treatment facility located or proposed to be located:
1. within 1000 feet of an established residence, church, school, day care center, surface water body used for a public
drinking water supply, or dedicated public park which is in use at the time the notice of intent to file a permit
application is filed with the commission, or which is in use at the time the permit application is filed with the
commission?
YES NO
2.a.within 1000 feet of an area subject to active coastal shoreline erosion even though the area is protected by a barrier
island or peninsula?
YES NO
If YES, then submit in Section V.F design, construction, and operational features which will prevent adverse effects
resulting from storm surge and erosion or scouring by water.
b.within 5000 feet of a coastal shoreline subject to active shoreline erosion and which is unprotected by a barrier
island or peninsula.
YES NO
If YES, then submit Section V.F design, construction and operational features, which will prevent adverse effects
resulting from storm surge and erosion or scouring by water.
3.on a barrier island or peninsula?
YES NO
II.E.Additional Requirements for Landfills (and Surface Impoundments Closed as Landfills with Wastes in Place)
Is the landfill located or proposed to the located:
1 .within 1000 feet of an established residence, church, school, day care center, surface water body used for a public
drinking water supply, or dedicated public park which is in use at the time the notice of intent to file a permit
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application is filed with the commission, or which is in use at the time the permit application is filed with the
commission?
YES NO
2.(for commercial hazardous waste landfills) in the 100-year floodplain of a perennial stream that is delineated on a
flood map adopted by the Federal Emergency Management Agency after September 1, 1985, as zone Al-99, VO, or
Vl-30?
YES NO
3.a. Within 1000 feet of an area subject to active coastal shoreline erosion even though the area is protected by a
barrier island or peninsula?
YES NO
If YES, then submit in Section V.G design, construction, and operational features which will prevent adverse effects
resulting from storm surge and erosion or scouring by water.
b. Within 5000 feet of a coastal shoreline subject to active shoreline erosion and which is unprotected by a barriers
island or peninsula.
YES NO
If YES, then submit in Section V.G design, construction, and operational features which will prevent adverse effects
resulting from storm surge and erosion or scouring by water.
4.On a barrier island or peninsula?
YES NO
II.F.Flooding
1.Identify whether the facility is located within a 100-year floodplain. This identification must indicate the source of
data for such determination and include a copy of relevant documentation (e.g., flood maps, if used and/or
calculations). The boundaries of the hazardous waste management facility must be shown on the floodplain map. If
the facility is not subject to inundation as a result of a 100-year flood event, do not complete F.2.-5. below. An
applicant for a proposed hazardous waste landfill, areal expansion of a hazardous waste landfill, or a commercial
hazardous waste land disposal unit may not rely solely on floodplain maps prepared by the Federal Emergency
Management Agency or a successor agency for this determination.
2.If the facility is located within the 100-year floodplain the applicant must provide information detailing the specific
flooding levels and other events (e.g., Design Hurricane projected by Corps of Engineers) which impact the flood
protection of the facility. Information shall also be provided identifying the 100-year flood level and any other
special flooding factors (e.g., wave action) which must be considered in designing, construction, operating, or
maintaining the facility to withstand washout from a 100-year flood.
3.State whether any flood protection device exist at the facility (e.g., floodwalls, dikes, etc.), designed to prevent
washout from the 100-year flood.
a.If YES, provide in Section V an engineering analysis to indicate the various hydrodynamic and hydrostatic forces
expected to result at the facility as a consequence of a 100-year flood.
Include structural or other engineering studies showing the design of operational units (e.g., tanks, incinerators) and
flood protection devices (e.g., floodwalls, dikes) at the facility and how these will prevent washout.
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b.If NO, the applicant shall provide in Section V a plan for constructing flood protection devices and a schedule
including specific time frames for completion. Provide engineering analyses to indicate the various hydrodynamic
and hydrostatic forces expected to result at the facility as a consequence of a 100-year flood.
Include structural or other engineering studies showing the design of operational units (e.g., tanks, incinerators) and
flood protection devices (e.g., floodwalls, dikes) at the facility and how these will prevent washout.
4.If applicable, and in lieu of flood protection above, provide a detailed description of procedures to be followed to
remove hazardous waste to safety before the facility is flooded including:
a.Timing of such movement relative of flood levels, including estimated time to move the waste, to show that such
movement can be completed before flood waters reach the facility. Indicate which specific events shall be use to
begin waste movement (e.g., Hurricane warning, Flash Flood watch, etc.).
b. A description of the location(s) to which the waste will be moved and a demonstration that these facilities will be
eligible to receive hazardous waste in accordance with appropriate regulations (i.e., a permitted facility).
c.The planned procedures, equipment, and personnel to be used and the means to ensure that such resources will be
available in time for use.
d.The potential for accidental discharges of the waste during movement and precautions taken to preclude accidental
discharges.
II.G.Additional Information Requirements
l.For a new hazardous waste management facility2, include a map of relevant local land-use plans and descriptions of
the major routes of travel in the vicinity of the facility to be used for the transportation of hazardous waste to and from
the facility covering at least a five (5)-mile radius from the boundaries of the facility. [30 TAG 305.50(10)(A)&(D)]
2.For a new commercial hazardous waste management facility as defined in 30 TAG 335.202 or the subsequent areal
expansion of such a facility or unit of that facility, indicate on the map the nearest established residence, church,
school, day care center, surface water body used for a public drinking water supply, and dedicated public park.
3.For new commercial hazardous waste management facilities, identify the public roadways used by vehicles traveling
to and from the facility within a minimum radius of 2.5 miles from the facility as well as the following: [30 TAG
305.50(12)(A)]
a.the major highways nearest the facility irrespective of distance;
b.the average number, gross weight, type, and size of vehicles used to transport hazardous waste.
4.Include the names and locations of industrial and other waste-generating facilities within 0.5 miles for a new on-site
hazardous waste management facility and the approximate quantity of hazardous waste generated or received annually
at those facilities. [30 TAG 305.50(10)(B)&(C)]
5.Include the names and locations of industrial and other waste-generating facilities within 1.0 miles for a new
commercial hazardous waste management facility and the approximate quantity of hazardous waste generated or
received annually at those facilities. [30 TAG 305.50(10)(B)&(C)]
6.For existing land disposal facility units provide documentation that the information required by 30 TAG 335.5 has
been placed in the county deed records. If previously submitted, please reference the submittal by date and
registration number.
2 For the purposes of Section II.G, "new" means as of 6/07/91.
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7.If a surface impoundment or landfill (including post-closure) is to be permitted, provide exposure information to
accompany this application and in accordance with 30 TAG 305.50(8) and 40 CFR 270.10Q. This information will
be considered separately from the TNRCC application completeness determination.
8.For a requested capacity expansion of an existing hazardous waste management facility, please provide in Section
VI. A. Lathe requested fault delineation information. [30 TAG 305.50(4)(F)]
III.FACILITY MANAGEMENT
A. Compliance History and Applicant Experience
Provide listings of all non-compliances concerning solid waste management by the permit holder in the preceding five
(5) years at the permitted site, all non-compliances concerning solid waste management at any site in Texas owned,
operated, or controlled by the applicant, a summary of the attempts of the permit holder to correct environmental
violations, and an indication of the indebtedness of the permit holder or applicant to the State of Texas as required by
30 TAG 305.50(2).
For a new commercial hazardous waste management facility, provide a summary of the applicant's experience in
hazardous waste management as required by 30 TAG 305.50(12)(E).
B.Personnel Training Plan.
Provide an outline of the facility training plan which includes all the information required by 40 CFR 264.16.
Indicate which training will be repeated annually.
C. Security
Describe how the facility complies with the security requirements of 40 CFR 264.14 or submit a justification
demonstrating the reasons for requesting a waiver of these requirements.
D.Inspection Schedule
Provide an inspection schedule summary for the facility which reflects the requirements of 40 CFR 264.15, 264.33
and, where applicable, the specific requirements in 40 CFR 264.174, 264.193, 264.195, 264.226, 264.254, 264.273,
264.303, 264.347, 264.574, 264.602, 264.1033(1), 264.1034, 264.1052, 264.1053(e), 264.1057, 264.1063,
264.1101(c)(4), 270.14(b)(5), 270.17(c), 270.18(d), 270.20(c)(5), 270.2l(d), 270.23(a)(2), 270.25(a)(6), and
270.26(c)(14). The inspection schedule should reflect the requirements described below. The schedule should
encompass each type of hazardous waste management (HWM) unit (i.e., facility component) and its inspection
requirements. In addition, complete Table HID. for all units to be permitted.
The owner or operator must inspect the facility for malfunctions and deterioration, operator errors, and discharges
which may be causing or may lead to the release of hazardous waste constituents to the environment or which may
pose a threat to human health. The owner or operator must conduct these inspections often enough to identify
problems in time to correct them before they harm human health or the environment.
The owner or operator must develop and follow a written schedule for inspecting other basic elements such as
monitoring equipment, safety and emergency equipment, security devices, the presence of liquids in leak detection
systems, where installed, and operating and structural equipment (such as dikes and sump pumps) that are important to
preventing, detecting, or responding to environmental or human health hazards.
If the owner or operator of a facility which contains a waste pile wishes to pursue an exemption from the ground-water
monitoring requirements for that waste management unit, the inspection schedule must include examination of the
base for cracking, deterioration, or other conditions that may result in leaks. The frequency of inspection must be
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based on the potential for the liner (base) to crack or otherwise deteriorate under the conditions of operation (e.g.,
waste type, rainfall, loading rates, and subsurface stability).
III.E.Contingency Plan
(This portion of the application does not apply to post closure applications.) If the owner or operator has already
prepared a Spill Prevention, Control, and Countermeasures (SPCC) Plan or some other emergency or contingency plan,
he need only amend that plan to incorporate hazardous waste management provisions that are sufficient to comply
with the requirements of this section. Provide a Contingency Plan which includes all the information required by 40
CFR Part 264 Subparts C and D, except for 40 CFR 264.56(d). This plan must also include a drawing of the facility
which shows the location of all emergency equipment. In addition, complete the following tables to summarize
information expressed in more detail in the plan.
1 .Arrangements with Local Authorities
Complete Table III.E. 1. to indicate arrangements (if made) with local authorities to familiarize local fire and police
departments, local hospitals, equipment suppliers, and local and State emergency response teams with the layout of
the facility, properties of hazardous waste handled at the facility and associated hazards, places where facility
personnel would normally be working, entrances to and roads inside the facility, and possible evacuation routes.
Provide documentation of the attempts and any arrangements made with local authorities and emergency response
teams.
2.Emergency Coordinator's List
List in Table III.E.2. the persons qualified to act as emergency coordinator. List the alternates in the order in which
they will assume responsibility.
3.Emergency Equipment List
List in Table III.E.3. all types of emergency equipment at the facility [such as fire-extinguishing systems, spill-control
equipment, communications and alarm systems (internal and external), and decontamination equipment], if this
equipment is required. Briefly outline the equipment capabilities.
If the owner or operator wishes to request a waiver from any of the preparedness and prevention requirements, he must
submit a justification demonstrating the reasons for requesting the waiver, as discussed below.
III.F.Emergency Response Plan
For a new commercial hazardous waste management facility, the application shall contain evidence sufficient to
demonstrate that emergency response capabilities are available or will be available before the facility first receives
waste. An emergency response plan must be provided which satisfies the requirements of 30 TAG 305.50(12)(C-D).
This plan must show that the proposed facility has sufficient emergency response capabilities for managing a
reasonable worst-case emergency condition associated with the operation of the facility. (For financial assurance
requirements associated with the emergency response activities, please see Section VIII.C.3.)
1 .Practice Drills
In addition to the contingency plan required under 40 Code of Federal Regulations Part 270.14(b)(7), provisions
specifying procedures and timing of practice facility evacuation drills are required. Provide a description and a
frequency for facility evacuation drills.
2.If a private corporation, municipality or county group will provide emergency response actions at the proposed
facility, include a copy of the contract for this type of agreement with this application or state that documentation will
be submitted before the facility accepts wastes.
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3.Historical weather data for the area should be documented and submitted. Information should be included regarding
how emergency response operations may be affected by weather conditions. (Local rainfall extremes, average rainfall
amounts, average wind speeds and directions, potential for major weather events such as hurricanes, tornados, icy
conditions, flash flooding etc., should be addressed.)
4.A definition of a worst-case emergency for the proposed facility should be described in the application. This worst-
case emergency should take into account the possible complications involved with a facility emergency compounded by
adverse weather conditions. It should also detail spills, fires, explosions, etc. This worst case scenario should be
developed with the help of local governmental entities where possible. Emergency planning should include both
unexpected emergencies and emergencies occurring as a result of a predictable event such as a flood or hurricane. For
areas which are prone to hurricanes and flash flooding, the worst case which allows for a realistic situation should be
used. For example, response teams should be well versed in reacting to events such as a 100-year flood.
5.A training program for personnel who will respond to these types of emergencies must be provided and must include
the requirements described in OSHA Federal Register 1910 and EPA Federal Register 311, the Texas Hazard
Communication Act, SARA Title III 302, 304, 311, 312, and 313. If emergency response actions are contracted out, the
contracted employees must be properly trained and documentation of this training must be maintained on-site. All
responders to emergencies at the proposed facility must be involved in training and drills at the facility in order to be
thoroughly familiar with the facility and its operations.
6.The application must include a description and identification of first-responders. This should include the
identification of all involved employee positions, locals and contractors. The duties of the facility employee who is to
be the on-scene coordinator (OSC) must be described. Additional information must be provided detailing the OSC's role
in the emergency response activities. This person must have the authority to commit the resources needed to carry out
the Emergency Response Plan. His duties must be thoroughly described so that it is clear whether he will remain in
control once the emergency response team arrives or whether he will relinquish control to another incident commander
upon that person's arrival on the scene. Additionally, there must be a qualified OSC on-site or on call 24 hours a day.
The name, address and phone numbers (home and work) of the OSC(s) must be listed in the Emergency Response Plan.
Where more than one person is listed, one must be named as the primary OSC and others must be listed in the order in
which they will assume responsibility as alternates.
T.Local or regional emergency medical services or hospitals which have experience in hazardous materials training must
be identified in the application. The names, addresses and phone numbers of the hospitals or medical centers should be
listed here and updated as necessary. Additionally, maps showing the quickest routes to the medical services must be
provided. A description of decontamination procedures for injured personnel prior to transport to medical services must
also be provided. The decontamination and transport of injured people to appropriate medical centers must be included
in the emergency evacuation training and drills.
8.A pre-disaster plan which includes training drills must be included in the application. This plan should include a
schedule for staging evacuations of the facility and for emergency response training drills. At least two evacuations
and two emergency response drills should occur annually. The plan should also include additional drills for responding
to "predictable" emergencies such as floods and hurricanes. The plan must include the following (or must reference
applicable sections of the Contingency Plan): a description of arrangements already in place with local authorities;
emergency phone numbers; internal communication or alarm systems and proper alarm codes; a list of all types of
emergency equipment at the facility, including a physical description and the capabilities of each item on the list, and the
location of each item (a map would be useful here); a description of decontamination equipment; an evacuation plan
including signals, evacuation routes and alternate evacuation routes; listing of pertinent first responder emergency
phone numbers, and codes for other types of communication devices; and a description of actions that will be
preformed in the event that a "predictable" emergency occurs.
9.Describe the mechanism which will be used to notify first responders and appropriate local governmental entities that
an emergency has occurred. Also describe the mechanism which will be used to notify all applicable governmental
agencies when an incident occurs (i.e., TNRCC, Texas Parks and Wildlife, General Land Office, TNRCC Office of Air
Quality, Texas Department of Health, and the Texas Railroad Commission).
10.Evidence must be provided that shows coordination with the Local Emergency Planning Committee (LEPC) and any
local comprehensive emergency management plan. The applicants should be able to show compliance with SARA Title
III.
1 l.Any medical response capabilities proposed for the facility property must be detailed in the application.
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TABLE III.D. INSPECTION SCHEDULE
Facility Unit(s) and Basic Elements
Possible Error, Malfunction, or Deterioration
Frequency of Inspection
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TABLE III.E.1 ARRANGEMENTS with LOCAL AUTHORITIES
Police:
Address:
Person Contacted:
Phone:
Agreed Arrangements :
Fire:
Address:
Person contacted:
Phone:
Agreed Arrangements*
Hospital:
Address:
Person Contacted:
Phone:
Agreed Arrangements*
Other:
Address:
Person Contacted:
Phone:
Agreed Arrangements*
For new commercial facilities
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TABLE III.E.2. EMERGENCY COORDINATORS
Name
Home
Address
Office Phone(s)
and/or Pager
Home Phone(s)
Primary:
Alternates:
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TABLE III.E.3. EMERGENCY EQUIPMENT
Equipment
Location
Physical Description
Capabilities
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IV.WASTES AND WASTE ANALYSIS
A.(Section IV.A of the application does not apply to post closure applications.) For a new hazardous waste
management facility or for a facility hazardous waste management capacity expansion, complete Table IV.A. for each
waste, source, and volume of waste to be stored, processed, or disposed of in the facility units to be permitted as
required by 30 TAG 305.50(9). For on-site facilities, list "on-site" for the waste source. For off-site facilities, list the
source of the waste. If unknown, identify potential sources (e.g., industries/processes to be serviced).
B.For all hazardous waste management facilities, complete Table IV.B for each waste and debris to be managed in a
permitted unit. Provide a verbal description, EPA waste codes, EPA hazard codes (I, C, R, E, H, T), TNRCC waste
classification (IH, I, II, III or H, 1, 2, 33), and TNRCC waste codes.
C.Complete Table IV.C. for each waste and debris proposed to be sampled and analyzed and include sampling location,
sampling method, sample frequency, analytical method, and desired accuracy level for each waste and debris to be
managed in a permitted, storage, processing, or disposal unit at the facility.
D.Waste Analysis Plan
The Waste Analysis Plan must address the requirements of 40 CFR 264.13 and 268.7. The Plan should include
supplemental and coordinating information on how the facility will analyze wastes and debris (as listed in Table IV.B) to
be managed in permitted units. The plan must address the determination of land disposal restrictions. Generators must
determine and certify with the manifest the land disposal restriction status of a waste, even if the waste or debris is not
intended for land disposal. Land disposal treatment facilities must identify the treatment process and analytical
procedures to be used, and include them in the waste analysis plan. Land disposal restriction records must be
maintained at the facility until closure of the facility [40 CFR 264.73(b)]. Landfill facilities must determine through the
Paint Filter Liquids test if there is free liquid in a bulk or containerized waste to be landfilled. If so, it must be stabilized;
adding adsorbents alone is not acceptable, even for containerized waste.
For off-site facilities the waste analysis plan must specify procedures which will be used to inspect and, if necessary,
analyze each movement of industrial and hazardous waste or hazardous debris received at the facility to ensure it
matches the identity of the waste designated on the accompanying shipping ticket. The plan must describe methods
which will be used to determine the identity of each movement of waste and debris managed at the facility and sampling
method used if the identification method includes sampling in order to store, process, or dispose of the wastes and
debris in accordance with 40 CFR Parts 264 and 268 and any abnormal characteristics which may upset further treatment
or processing operations. Include rejection criteria for shipments of waste and debris received at the facility
For on-site facilities the waste analysis plan must specify the normal characteristics of the waste (including EPA
hazardous waste codes, EPA hazard codes, and 40 CFR 261 Appendix VIII Hazardous Constituents) which must be
known to store, process, or dispose of the wastes and debris in accordance with 40 CFR Parts 264 and 268 and any
abnormal characteristics which may upset further treatment or processing operations.
The methods and equipment used for sampling waste materials will vary with the form and consistency of the waste
materials to be sampled. Those sampling methods listed in 40 CFR 261 Appendix I, for sampling waste with properties
similar to the indicated materials, or equivalent sampling methods approved by EPA under 40 CFR 260.20 and 260.22, will
be considered by the TNRCC to be acceptable.
3For newly generated wastes classified after 1/01/93. Existing wastes must be reclassified by 1/01/95.
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TABLE IV.A. WASTE MANAGEMENT INFORMATION
Waste
Source
Volume (tons/year)
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TABLE IV.B. WASTES MANAGED IN PERMITTED UNITS
No.
Waste
EPA Waste Codes
EPA Hazard Codes
(I, C, R, E, H, T)
TNRCC Waste
Classifications
(IH, I, II, III or H,
1, 2, 3')
TNRCC Waste Codes
'For newly generated wastes classified after 1/01/93. Existing wastes must be reclassified by 1/01/95.
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TABLE IV. C. SAMPLING AND ANALYTICAL METHODS
Waste No.1
Sampling Location
Sampling Method
Frequency
Parameter
Test Method
Desired
Accuracy
Level
'from Table IV.B, first column
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V.ENGINEERING REPORTS
The engineering report represents the conceptual basis for the storage, processing, or disposal units at the hazardous
waste management (HWM) facility. It should include calculations and other such engineering information as may be
necessary to follow the logical development of the facility design. Plans and specifications are an integral part of the
report. They should include construction procedures, materials specifications, dimensions, design capacities relative to
the volume of wastes (as appropriate), and the information required by 40 CFR 270.14(b)(8), 270.14(b)(10). For landfills,
surface impoundments, and waste piles, a Construction Quality Assurance Plan, that considers the guidance in EPA
publication 530-SW-85-014, should be submitted.
For facilities which will receive wastes from off-site sources, the engineering report must also contain information on the
units which will manage these off-site wastes in accordance with 30 TAG 335.2.
Certain ancillary components or appurtenant devices must be addressed in the Part B application. These include but are
not limited to sumps, pipelines, ditches, and canals. The technical information and the level of detail required will vary
with the nature, scope, and location of the ancillary component. At a minimum they should be included in descriptions
of piping and process flow. More information may be required. A single area containing a large number of ancillary
components or a remote appurtenant device in an unusually sensitive location may warrant some specific permit
requirements. All ancillary components must be included in calculating closure cost estimates.
In each of the unit-specific sections, describe precautions taken to prevent accidental commingling of incompatible
wastes. If reactive or ignitable wastes are to be managed, or if incompatible wastes are deliberately commingled, provide
information to ensure that precautions are taken to avoid danger due to:
-generation of extreme heat or pressure, fire, explosion, or violent reaction;
-production of uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health;
-production of uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosion;
-damaging the structural integrity of the device or facility containing the waste; or
-threatening human health or the environment by any other means.
Comprehensive consideration should be given to ensure that the facility is designed in accordance with good public
health and hazardous waste management practices. The application will be evaluated primarily for the aspects of design
covered by the regulations. Nothing in any approval is intended to relieve the facility owner or operator of any liabilities
or responsibilities with respect to the design, construction, or operation of the project.
A.General Engineering Reports
1 .General Information
Provide an overall plan view of the entire facility. Identify each hazardous or industrial solid waste management unit
(container storage area, tank, incinerator, etc.) to be permitted in relation to its location and the type of waste managed in
that unit. Also provide a plan view at an appropriate scale to clearly show the location of all hazardous waste
management units to be permitted on one or more 8 VJ' x 11" sheets. Indicate on this plan view how the design or
operation provides for buffer zones or waste segregation as appropriate for incompatible, ignitable, or reactive wastes.
Submit a topographic map or maps of the facility which clearly shows the information specified in 40 CFR 270.14(b)(19),
270.14(c)(3), and 270.14(d)(l)(I) (for large HWM facilities, the TNRCC will allow the use of other scales on a case-by-case
basis). Please note that the term "facility" includes all contiguous land, structures, other appurtenances, and
improvements on the land for storing, processing, or disposing of hazardous and industrial solid waste.
2.Features to Mitigate Unsuitable Site Characteristics
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For all new hazardous waste management storage and/or processing facilities or areal expansions of existing hazardous
waste management storage and/or processing facilities, include in the engineering report design, construction, and
operational information specified in 30 TAG 335.204(a)(l) and (a)(3)-(9).
3.Construction Schedules
a.In order to meet the required design standards, extensive retrofitting of some facilities may be required. In the worst
case, the applicant may elect to close certain operations rather than comply with the RCRA standards. Thus, the permit
may specify a schedule of compliance requiring the accomplishment of given tasks within specific time frames. As
required, indicate an appropriate schedule(s) of compliance in this application. The schedule should provide for facility
compliance as soon as possible and in accordance with 40 CFR 270.33(a)(2) and 270.33(b).
b.For commercial hazardous waste management facilities, permit applications (new, renewal, or interim status
applications), major amendments, or Class 3 modifications submitted after 11/23/94 must include a construction
schedule. A construction schedule must be submitted even if the application does not include an addition of units or a
revision to permitted units. This schedule should comply with the requirements of 30 TAG 305.149.
4.Pro vide detailed plans and specifications which when accompanied by the engineering report will be sufficiently
detailed and complete to allow the Executive Director to ascertain whether the facility will be constructed and operated
in compliance with all pertinent permitting requirements. Engineering plans and specifications must be prepared under
the supervision of and sealed by a Registered Professional Engineer, with current registration as required by the Texas
Engineering Practice Act. For some facilities, plans in the form of a standard piping and instrumentation diagram will be
sufficient. Overall dimensions and materials of construction must be shown.
V.B.Container Storage Areas
Provide an engineering report which includes all of the information specified in 40 CFR 264.170-264.173, 264.175-264.177,
and 270.15. Complete Table V.B and list the container storage areas covered by this application to be permitted. List the
N.O.R. unit number, the waste managed in each unit (the numbers in the far left column of Table IV.B are sufficient), the
rated capacity or size of each unit (including the maximum number of each type of container to be stored at each unit),
the areal dimensions, stack height, aisle spacing, containment volume, whether ignitable, reactive, or incompatible waste
will be stored in each unit, and whether processing will occur within the unit.
1.Container storage areas must have a containment system that is capable of collecting and holding spills, leaks, and
precipitation. In addition to the requirements of 40 CFR 270.15, include in the design report the following:
a.Capacity of the containment relative to the number and volume of containers to be stored, plus for unenclosed areas,
the amount of rainfall collected prior to removal. The TNRCC recommends using a 25-year, 24-hour rainfall event for this
extra capacity.
b.Run-on into the containment system must be prevented, or a collection system with sufficient excess capacity must be
provided. If run-on is collected within the containment system, delineate the area(s) from which run-on is collected. The
25-year, 24-hour rainfall event should be used to calculate the excess capacity.
2. Wastes Containing No Free Liquids
Storage areas that hold only wastes that do not contain free liquids need not have a containment system, except as
provided by 40 CFR 264.175(d), provided that compliance with 40 CFR 264.175© is demonstrated. This demonstration
must be submitted as part of the application and must include:
a.test procedures and results or other documentation or information to show that the wastes do not contain free liquids;
and
b.a description of how the storage area is designed or operated to drain and remove liquids or how containers are kept
from contact with standing liquids..
V.C.Tank Systems and Secondary Containment
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Provide an engineering report which includes all of the information specified in 40 CFR 264.190-264.194, 264.196, 264.198-
264.199, and 270.16. Complete Table V.C and list the tanks covered by this application to be permitted. List the N.O.R.
unit number, whether the unit is for storage and/or processing, the waste managed in each unit, the rated capacity of
each unit, overall dimensions of each unit, and whether ignitable, reactive, or incompatible waste will be stored in each
unit.
Submit written assessments that were reviewed and certified by an independent, qualified registered professional
engineer that attests to the structural integrity and suitability of handling the hazardous waste for each tank system, as
required under 40 CFR 264.191-264.192 for existing tanks which do not have secondary containment meeting the
standards of 40 CFR 264.193. The engineer signing the written assessment must make the certification specified in 40
CFR270.11(d).
V.D. Surface Impoundments
Provide an engineering report which includes all of the information specified in 30 TAG 305.50(6), 335.168, 335.169, and
40 CFR 264.19, 264.220, 264.222-264.225, 264.226(a) and (c), 264.227, 264.229-264.231, and 270.17.
For storage surface impoundments at a new hazardous waste management facility or which are part of an areal expansion
of an existing hazardous waste management facility, include in the engineering report design, construction, and
operational information specified in 30 TAG 335.204(d). For any surface impoundment to be closed as a landfill (where
wastes will remain after closure of the impoundment) at a new hazardous waste management facility or which are part of
an areal expansion of an existing hazardous waste management facility, include in the engineering report design,
construction, and operational information specified in 30 TAG 335.204(e).
For all impoundments, include in the report the following information.
1 .Complete Table V.D. 1 and list the surface impoundments covered by this application to be permitted. List the waste
managed in each unit and the rated capacity or size of each unit.
2.Describe the surface impoundment. A plan view and cross-section of the surface impoundment should be included
with the engineering report.
3 .Freeboard
Specify the minimum freeboard to be maintained and the basis of the design to prevent overtopping resulting from
normal or abnormal operations; overfilling; wind and wave action; rainfall; run-on; malfunctions of level controllers,
alarms, and other equipment; and human error. Show that adequate freeboard will be available to prevent overtopping
from a 100-year, 24-hour storm.
If the impoundment is inflow sensitive, it should be equipped with a high-level alarm based on a different level sensor
than that used for automatic control.
4. Waste Flow
Describe the means that will be used to immediately shut off the flow of waste to the impoundment to prevent
overtopping or in the event of liner failure, and include appropriate detailed drawings.
If the surface impoundment is a flow-through facility describe the flow of waste, including a hydraulic profile.
5.Dike Construction
a.If dikes are used, include the following certification as part of the engineering report:
"I, (qualified Registered Professional Engineer) Texas P.E. Registration Number , certify under penalty of law
that I have personally examined and am familiar with the design and construction of the dikes that are a portion of
(surface impoundment unit name) .
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I further certify that I have evaluated the dike design and materials of construction using accepted engineering
procedures, and have determined that the dike, including the portion of the dike providing freeboard, has structural
integrity, and:
l)Will withstand the stress of the pressure exerted by the types and amounts of wastes to be placed in the
impoundment; and
2)Will not fail due to scouring or piping, without dependence on any liner system included in the impoundment
construction.
(Signature) Date:
(SEAL)"
b.The structural integrity of the dike system must be certified by a qualified Registered Professional Engineer before a
permit is issued. If the impoundment is not being used, the dike system must be certified before it can be put into use.
c.A report shall accompany the dike certification which summarizes the activities, calculations, and laboratory and field
analyses performed in support of the dike certification. Describe the design basis used in construction of the dikes.
Include the following analyses as attachments to the engineering report:
l)Slope Stability Analysis
2)Hydrostatic and Hydrodynamic Analysis
3)Storm Loading
4)Rapid Drawdown
d.Earthen dikes should have a protective cover to minimize wind and water erosion and to preserve the structural
integrity of the dike. Describe the protective cover used and describe its installation and maintenance.
6.Containment System
Technical Guideline No. 6 contains suggested methods of leak detection system construction and EPA publication 530-
SW-85-014 provides design guidance for liner systems. The applicant is strongly encouraged to test each synthetic
liner after installation by an electrical leak location system such as developed by Southwest Research Institute, or
equivalent approved by the Executive Director. Construction above the liner may not proceed until any detected leaks
are sealed.
a.Complete Table V.D.6 for each surface impoundment to be permitted.
bin the engineering report, describe the design, installation and operation of liner and leak detection components. The
description must demonstrate that the liner and leak detection system will prevent discharge to the land, and ground and
surface water. Include the following analyses as attachments to the engineering report.
For artificial liners:
1) Seaming method
2) Surface preparation method
3)Tensile Strength
4)Impact Resistance
5)Compatibility Demonstration
6)Foundation Design (including Settlement Potential, Bearing Capacity and Stability, and Potential for Bottom Heave
Blow-out)
For soil liners:
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7)Waste Migration Analysis (based on head, porosity, and permeability) for the most mobile and least attenuated waste
constituents
8)Atterberg Limits, % passing a #200 sieve, and Permeability
9)Moisture Content
10)Standard Proctor Density, Compaction Data
For leachate collection systems:
1 l)Pipe Material and Strength
12)Pipe Network Spacing and Grading
13)Collection Sump(s) Material and Strength
14)Drainage Media Specifications and Performance
15)Analyses showing that pipe and pipe perforation size will prevent clogging and allow free liquid access to the pipe.
16)Compatibility Demonstration
c. Specify the liner system installation date and expected lifetime of liner system (years).
d. Whether the liner is chemically resistant to the waste and how this resistance was determined. Attach any tests or
documentation to the engineering report.
e.Submit a quality assurance/ quality control plan for all components to demonstrate that all components will be
properly installed and will perform to design specifications.
7.Surface impoundments that receive waste on or after May 8, 1985 (or for newly-regulated units, the effective date of
the new RCRA regulation) into new units and/or lateral expansions or replacements of existing units must meet the
minimum technological requirements of the Hazardous and Solid Waste Amendments of 1984, unless an appropriate
waiver is granted by the Commission. The minimum technological requirements include the installation of two or more
liners and a leak detection system between such liners. Plans and specifications for both new and existing surface
impoundments must demonstrate conformity with 30 TAG 335.168.
8.Run-on Diversion
Describe how the surface impoundment system will manage stormwater run-on. Stormwater run-on must be diverted
away from a surface impoundment. Use at least a 100-year, 24-hour rainfall event in the design and analysis of diversion
structures. Where dikes are used to divert run-on, they must be protected from erosion. Include all analyses used to
calculate run-on volumes.
9.Exemption from Double-Liner Requirements
Owners or operators of hazardous waste surface impoundments will be exempted from the double-liner requirements if
the Commission finds, based on a demonstration by the owner or operator, that alternative design and operating
practices, together with location characteristics are at least as effective as a double liner in preventing migration of
hazardous constituents to the ground water or surface water. If an exemption is sought, submit detailed plans and
engineering and hydrogeologic reports, as appropriate, describing alternate design and operating practices that will, in
conjunction with location aspects, prevent the migration of any hazardous constituents into the ground water or surface
water at any future time.
V.E. Waste Pile Report
This section applies to owners or operators of industrial solid waste facilities that store or process hazardous waste in
piles. A hazardous waste pile that will be closed with wastes left in place must be managed as a landfill. Existing
portions of waste piles are those areas that were listed on the original Part A and on which wastes have been lawfully
placed.
Provide an engineering report which includes all of the information specified in 30 TAG 335.170 and 40 CFR 264.19,
264.250, 264.252-264.253, 264.254(a) and (c), 264.255-264.257, 264.259, and 270.18.
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For waste piles at a new hazardous waste management facility or which are part of any areal expansion of an existing
hazardous waste management facility, include in the engineering report design, construction, and operational
information specified in 30 TAG 335.204(c).
For all waste piles, include in the report the following information.
1 .Complete Table V.E. 1 and list the waste piles covered by this application. List the waste managed in each unit and the
rated capacity or size of the unit.
2.Describe the waste pile, including any structure surrounding or enclosing the waste pile.
3.Containment System
TNRCC Technical Guide No. 6 contains suggested methods of leachate collection system construction and EPA
publication 530-SW-85-014 provides design guidance for liner systems.
a.Complete Table V.E.3 and specify the type of containment/liner system.
b.In the engineering report, describe the design, installation, construction, and operation of the liner and leachate
collection system. The description must demonstrate that containment systems will prevent discharge to the land,
surface water, or ground water. Include the following analyses as attachments to the engineering report, when
applicable to the containment system being described.
For artificial liners:
1) Seaming method
2) Surface preparation method
3)Tensile Strength
4)Impact Resistance
5)Compatibility Demonstration
6)Foundation Design (including Settlement Potential, Bearing Capacity and Stability, and Potential for Bottom Heave
Blow-out)
For soil liners:
7)Waste Migration Analysis (based on head, porosity, and permeability) for the most mobile and least attenuated
constituents.
8)Atterberg Limits, % passing a #200 sieve, and Permeability
9)Moisture Content
10)Standard Proctor Density, Compaction Data
For leachate detection, collection, and removal system:
1 l)Capacity of system
(a)rate of leachate removal
(b)capacity of sumps
(c)thickness of mounding and maximum hydraulic head
12)Pipe Material and Strength
13)Pipe Network Spacing and Grading
14)Collection Sump(s) Material and Strength
15)Drainage Media Specifications and Performance
16)Analysis showing that pipe and perforation size will prevent clogging and allow free liquid access to the pipe.
17)Compatibility Demonstration
c.Containment/liner system installation date and expected lifetime of liner system (years).
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d.Whether the containment/liner system is chemically resistant to the waste and how this resistance was determined.
Attach any tests or documentation to the engineering report.
e.Submit a quality assurance/ quality control plan for all components to demonstrate that all components will be
properly installed and will perform to design specifications.
4. Wind Dispersal
Piles containing hazardous waste which could be subject to dispersal by wind must be covered or otherwise managed
so that wind dispersal is minimized. Describe practices to control wind dispersal (e.g., cover or frequent wetting) of the
hazardous waste.
5.Run-on Diversion
Describe measures used to control run-on and divert run-on from the unit. The owner or operator must design,
construct, operate, and maintain a run-on control system capable of preventing flow onto the active portion of the pile
during peak discharge from at least a 100-year, 24-hour storm.
Include all analyses used to calculate rates of flow, run-on volume and depth, and for the ditches on plant property,
back-water calculations.
Any tanks or basins associated with the run-on control systems must be emptied or otherwise managed expeditiously
after a storm to maintain the design capacity of the system.
6.Run-off Control
Describe measures used to control run-off from the unit. Include all analyses used to calculate the run-off volumes.
The owner or operator must design, construct, operate, and maintain a run-off management system to collect and control
at least the water volume resulting from a 100-year, 24-hour storm.
Collection and holding facilities (e.g., tanks or basins) associated with the run-off control systems must be emptied or
otherwise managed expeditiously after storms to maintain the design capacity of the system.
7.Give a description of design and operating procedures to properly manage and dispose of any residuals (e.g., leachate)
that may be generated during waste management. Describe the management process and any equipment used.
8.Provide a description and listing of all equipment and procedures used to place the waste in or on the pile, and to
expose the liner surface if necessary for inspection. A containment system must be protected from plant growth which
could puncture any component of the system.
9.Exemption from Liner and Leachate Collection Requirements
The owner or operator will be exempted from the liner and leachate collection requirements if the Commission finds,
based on a demonstration by the owner or operator, that alternative design and operating practices, together with
location characteristics will prevent migration of hazardous constituents to the ground water or surface water. If an
exemption is sought, submit detailed plans and engineering and hydrogeologic reports, as appropriate, describing
alternate design and operating practices that will, in conjunction with location aspects, prevent the migration of any
hazardous constituents into the ground water or surface water at any future time.
10.Exemption from Ground-water Monitoring
A waste pile may be exempt from ground-water monitoring if the following standards are met:
a.The pile (including its underlying liners) must be located entirely above the seasonal high water table; and
b.The waste pile is inside or under a structure that provides protection from precipitation so that neither run-off nor
leachate is generated, provided that:
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(l)Liquids or materials containing free liquids are not placed in the pile;
(2)The pile is protected from surface water run-on by the structure or in some other manner;
(3)The pile is designed and operated to control dispersal of the waste by wind, where necessary, by means other than
wetting; and
(4)The pile will not generate leachate through decomposition or other reactions; or
c.The pile must have a leachate collection and removal system above the top liner; and
d.(l)(a)The pile must be underlain by two liners, which are designed and constructed in a manner that prevents the
migration of liquids into or out of the space between the liners and a leak detection system which must be designed,
constructed, maintained, and operated between the liners to detect any migration of liquids into the space between the
liners; and
(b)A demonstration must be made that there is a low potential for migration of liquid from the waste pile to the
uppermost aquifer during the active life of the waste pile (including the closure period). The owner or operator must
base any predictions made on assumptions that maximize the rate of liquid migration; or
(2)(a)The pile must be underlain by a liner (base) that is designed, constructed, and installed in a manner that prevents
the migration of liquids or waste beyond the liner; and
(b)The wastes in the pile must be removed periodically, and the liner must be inspected for deterioration, cracks, or other
conditions that may results in leaks. The frequency of inspection will be specified in the inspection plan and must be
based on the potential for the liner (base) to crack or otherwise deteriorate under the conditions of operation (e.g., waste
type, rainfall, loading rates and subsurface stability).
The liner(s) used to satisfy 10.d. must be of sufficient strength and thickness to prevent failure due to puncture,
cracking, tearing, or other physical damage from equipment used to place waste in or on the pile or to clean and expose
the liner surface for inspection.
V.F.Land Treatment Units
This section applies to owners and operators of facilities that use land treatment units to treat hazardous waste. This
section may be completed by a certified soil scientist. If there are separate standards for new or existing units they will
be specified in that particular subsection. The regulations governing land treatment units and summarized in this
section can be found in Title 31 Texas Administrative Code Section 335.171.
Provide an engineering report which includes all of the information specified in 30 TAG 305.50(6), 335.171, 335.172, 40
CFR 264.270-264.272, 264.274-264.279, 264.281-264.283, and 270.20 for each land treatment unit.
For land treatment units at a new hazardous waste management facility or which are part of an areal expansion of an
existing hazardous waste management facility, include in the engineering report design, construction, and operational
information specified in 30 TAG 335.204(b).
For all land treatment units, include in the report the following information.
1 .Complete Tables V.F. 1 and V.F.2. and list the land treatment units covered by this application. List the waste managed
in each unit and the rated capacity or size of the unit. If different wastes are placed on separate portions of the land
treatment area, each one of these portions is considered a land treatment unit, and requires a separate summary form and
engineering report.
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The treatment zone is defined as the soil area of the unsaturated zone of a land treatment unit within which hazardous
constituents are degraded, transformed, or immobilized. In this section, specify the depth of the treatment zone. The
maximum depth of the treatment zone for new land treatment units must be:
a.No more than 1.5 meters (5 feet) from the surface; and
b.More than 1 meter (3 feet) above the seasonal high water table.
2.Describe the land treatment unit. A plan view and cross-section of the unit should be included with the engineering
report.
3.Complete Table V.F.3 and list the wastes for which the treatment demonstration will be made and the principal
hazardous constituents in each waste. Specify in the report the data sources to be used to make the demonstration such
as laboratory data, field data, operating data, literature, or other.
4.Run-on Diversion
Describe measures used to control run-on and divert run-on from the unit. Include all the analyses used to calculate the
run-on volumes.
The owner or operator must design, construct, operate, and maintain a run-on control system capable of preventing flow
onto the active portion of he land treatment unit during peak discharge from at least a 100-year, 24-hour storm.
Any tanks or basins associated with the run-on control system must be emptied or otherwise managed expeditiously
after storms to maintain the design capacity of the system.
5.Run-off Control
Describe measures used to control the run-off from the unit, and minimize hazardous constituents in the run-off, include
all the analyses used to calculate the run-off volumes.
The owner or operator must design, construct, operate and maintain a run-off management system to collect and control
at least the water volume resulting from a 100-year, 24-hour storm.
Collection and holding facilities (e.g., tanks or basins) associated with run-off control systems must be emptied or
otherwise managed expeditiously after storms to maintain design capacity of the system.
6. Wind Dispersal
The owner or operator of a land treatment unit containing hazardous waste which could be subject to dispersal by wind
must cover or otherwise manage the land treatment unit so that wind dispersal is minimized. Describe practices to
control wind dispersal (e.g., cover or frequent wetting) of the hazardous waste.
7.Treatment Demonstration
A description of the treatment demonstration required under 40 CFR 264.272 and 270.20(a) shall be included with the
engineering report. If the owner or operator intends to conduct field tests or laboratory analyses in order to make the
demonstration, he must obtain a treatment or disposal permit.
8.Food Chain Crops
Several conditions must be satisfied if food-chain crops are to be grown in or on the treatment zone. A demonstration
must be prepared similar to the one described in the Treatment Demonstration and submitted at least 90 days prior to the
planting of crops. The demonstration need not be submitted with this application. However, a description of the
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demonstration must be included as part of the engineering report. This demonstration may be combined with the
Treatment Demonstration description, as some of the information required is identical.
V.G.Landfills
Provide an engineering report which includes all of the information specified in 30 TAG 305.50(5 & 6), 335.173, 335.174-
176,40 CFR 264.19,264.300,264.302,264.303(a), 264.304-264.309,264.311-264.313,264.316-264.317, and 270.21. The text of
the report should be written to supplement engineering plans, specifications, and test results necessary to provide a
detailed description of how the landfill will comply with these standards.
For landfills at a new hazardous waste management facility or which are part of an areal expansion of an existing
hazardous waste management facility, include in the engineering report design, construction, and operational
information specified in 30 TAG 335.204(e).
For all landfills, include in the report the following information.
1 .Complete Table V.G. 1 and list the landfills (and number of cells, if applicable) covered by this application. List the
waste managed in each unit and the rated capacity or size of the unit. If wastes are segregated in some manner please
list the cell number in which wastes are placed next to each waste type.
2.Describe the landfill. A plan view and cross-section of the landfill should be included with the engineering report.
3.Containment System
TNRCC Technical Guideline No. 6 contains suggested methods of leachate collection system construction and EPA
publication 530-SW-85-014 provides design guidance for liner systems. The applicant is strongly encouraged to test
each synthetic liner after installation by an electrical leak location system such as developed by Southwest Research
Institute, or equivalent approved by the Executive Director. Construction above the liner may not proceed until any
detected leaks are sealed.
a.Complete Table V.G.3 and specify the type of liner and leachate collection systems used for the landfill.
b.In the engineering report, describe the design, installation, construction, and operation of the liner and leachate
collection components. The description must demonstrate that the liner or leachate control system will prevent
discharge to the land, ground water, and surface water.
For artificial liners:
1) Seaming method
2) Surface preparation method
3)Tensile Strength
4)Impact Resistance
5)Compatibility Demonstration
6)Foundation Design (including Settlement Potential, Bearing Capacity and Stability, and Potential for Bottom Heave
Blow-out)
For soil liners:
7)Waste Migration Analysis (based on head, porosity, and permeability) for the most mobile and least attenuated waste
constituents
8)Atterberg Limits, % passing a #200 sieve, and Permeability
9)Moisture Content
10)Standard Proctor Density, Compaction Data
For dikes:
1 l)Slope Stability Analysis
12)Hydrostatic and Hydrodynamic Analyses
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13)Ability to withstand scouring from leaking liner
For leachate detection, collection, and removal system:
14)Capacity of the system:
(a)rate of leachate removal
(b)capacity of sumps
(c)thickness of mounding and maximum hydraulic head
15)Pipe Material and Strength
16)Pipe Network Spacing and Grading
17)Collection Sump(s) Material and Strength
18)Drainage Media Specifications and Performance
19)Analyses showing that pipe and pipe perforation size will prevent clogging and allow free liquid access to the pipe.
20)Compatibility Demonstration
c. Whether the liner system and leachate collection components are chemically resistant to the waste and how this
resistance was determined. Attach any tests or documentation to the engineering report.
d. Submit a quality assurance/ quality control plan for all components to demonstrate that all components will be
properly installed and will perform to design specifications.
4.Landfills that receive waste on or after May 8, 1985 (or for newly-regulated units, the effective date of the new RCRA
regulation) into new units and/or lateral expansions or replacements of existing units must meet the minimum
technological requirements of the Hazardous and Solid Waste Amendments of 1984, unless an appropriate waiver is
granted by the Commission. The minimum technological requirements include the installation of two or more liners and
a leachate collection system above and between the liners. Plans and specifications for both new and existing landfills
must demonstrate conformity with 30 TAG 335.173.
5.Site Development Plan
Describe the methods used to deposit waste in the landfill. This description should include rate of waste deposition,
waste segregation, average lift size, maximum lift, average cell or trench size, maximum cell or trench size, and other
information necessary to depict how the landfill will be developed. Do not include liner or leachate collection system
information, closure information, or handling of special wastes. This will be included elsewhere in the report.
6.Run-on Control
The owner or operator must design, construct, operate, and maintain a run-on control system capable of preventing flow
onto the active portion of the landfill during peak discharge from at least a 100-year, 24-hour storm.
Collection and holding facilities associated with the run-on control system must be emptied or otherwise managed
expeditiously.
In the engineering report, include the following analyses:
a.Run-on volume and depth calculations from the peak discharge of the 100-year, 24-hour storm; and
b.For ditches on the plant property, back-water calculations.
7.Run-off Control
The owner or operator must design, construct, operate, and maintain a run-off management system to collect and control
the water volume resulting from a 100-year, 24-hour storm.
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-44
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Include all analyses used to calculate run-off volumes.
Collection and holding facilities (e.g., tanks or basins) associated with run-off control systems must be emptied or
otherwise managed expeditiously after storms to maintain design capacity of the system.
8. Wind Dispersal
If the landfill contains any particulate matter which may be subject to wind dispersal, the owner or operator must cover
or otherwise manage the landfill to minimize wind dispersal. Check off the method used to control wind dispersal on the
summary form. Based upon the characteristics of the material to be landfilled describe the likelihood of wind dispersal
occurring. Describe in detail any method and/or control mechanism used to prevent wind dispersal.
9.Liquid Waste
If liquid waste or waste containing free liquids is to be stabilized and then placed in the landfill, the procedures used to
stabilize the waste must be described in the engineering report. The waste must be treated prior to landfilling using a
treatment technology that does not solely involve the use of a material that functions primarily as a sorbent. Provide
supporting documentation to verify that an appropriate stabilization procedure is used to comply with 30 TAG 335.175.
10.Exemption from Double-Liner Requirements
Owners or operators of hazardous waste landfills will be exempt from the double-liner requirements if the Commission
finds, based on the demonstration by the owner or operator, that alternative design and operating practices, together
with location characteristics, are at least as effective as a double liner in preventing migration of hazardous constituents
to the ground water or surface water.
The demonstration must consider:
a.The nature and quantity of the wastes;
b.The proposed alternate design and operation;
c.The hydrogeologic setting of the facility, including the attenuative capacity and thickness of the liners and soils
present between the landfill and ground water or surface waters; and
d. All other factors which would influence the quality and mobility of the leachate produced and the potential for it to
migrate to ground water or surface water.
11. Above-grade Benefits
The engineering report must evaluate the benefits, if any, associated with the construction of the landfill above existing
grade at the proposed site, the costs associated with the above-grade construction, and the potential adverse effects, if
any, which would be associated with the above-grade construction.
V .H. Incinerators
Provide an engineering report which includes all of the information specified in 30 TAG 305.171-305.174, 40 CFR 264.340,
264.342-264.346, 264.347(a), 264.348-264.350, and 270.19.
Note: A permit is not required prior to conducting a trial burn for existing incinerator operating under 30 TAG 335.2(c).
However, without the prior approval of the Executive Director the operator cannot be certain that the trial burn data will
be sufficient to demonstrate compliance with regulations. Applicants are encouraged to obtain approval prior to
conducting a test burn. For any trial burn plan approved by the TNRCC or EPA, the applicant shall submit a
certification that the previously conducted trial burn was conducted in accordance with the approved trial burn plan.
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-45
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1 .Complete Table V.H. 1 and list the incinerators covered by this application. List the waste managed in each unit, the
rated capacity or size of the unit, and the types of continuous emission monitors to be used to ensure permit compliance
(e.g.,., O2, CO, THC).
2.If a trial burn will be performed, designate one or more of the 40 CFR 261 Appendix VIII organic compounds present in
the wastes to be incinerated as Principal Organic Hazardous Constituents (POHCs). Selection will be based upon the
degree of difficulty of incineration of these compounds and upon their concentration or mass in the waste feed. These
POHCs will be used to determine the destruction and removal efficiency (DRE) specified in the performance standards of
40 CFR 264.343. In addition, complete Table V.H.2.
3.Submit a Quality Control/Quality Assurance Plan for all sampling, analysis, and monitoring activities which will occur
in conjunction with the trial burn.
V.I.Boilers and Industrial Furnaces
Provide an engineering report which includes all of the information specified in 30 TAG 305.50(13), 305.571-573, 335.221-
335.229, and 40 CFR 266.100-266.102, 266.104-266.112, and 270.22.
1 .Complete Table V.I. 1 and list the boilers and/or industrial furnaces by this application. List the waste managed in each
unit and the rated capacity or size of the unit.
2.If a trial burn will be performed, designate one or more of the 40 CFR 261 Appendix VIII organic compounds present in
the wastes to be incinerated as Principal Organic Hazardous Constituents (POHCs). Selection will be based upon the
degree of difficulty of incineration of these compounds and upon their concentration or mass in the waste feed. These
POHCs will be used to determine the destruction and removal efficiency (DRE) specified in the performance standards of
40 CFR 264.343. In addition, complete Table V.I.2.
3.Submit a Quality Control/Quality Assurance Plan for all sampling, analysis, and monitoring activities.
V.J.Drip Pads
Provide an engineering report which includes all of the information specified in 40 CFR 264.570-573 and 270.26. Include
with this engineering report the required certification signed by an independent, qualified, registered professional
engineer, stating that the drip pad design meets the requirements of 40 CFR 264.573(a)-(f).
1 .Complete Table V.J. 1 and list the drip pads covered by this application to be permitted. List the N.O.R. unit number,
the waste managed in each unit, the rated capacity of each unit, and the overall dimensions of the unit (including
perimeter curb or berm height) that will be in contact with the waste.
2.For either new drip pads4 or existing drip pads for which the owner/operator elects to comply with the synthetic liner
requirement of 40 CFR 264.573(b), please complete Table V.J.2 Drip Pad Synthetic Liner System.
V.K.Miscellaneous Units
A miscellaneous unit is a unit other than a container, tank, incinerator, boiler, industrial furnace, landfill, surface
impoundment, waste pile, underground injection well, land treatment area, drip pad, or unit eligible for an R, D & D
permit that is used to process, store, or dispose of hazardous waste.
For each miscellaneous unit for which an operating permit is sought, provide an engineering report which includes all of
the information specified in 40 CFR 264.600-264.602, and 270.23. Complete Table V.K and list the miscellaneous units
4New drip pads are those drip pads constructed after 12/06/90 and which had no binding contract for
construction. If electing to comply with 40 CFR 264.573(b), the requirement to install a leakage collection system of
40 CFR 264.573(b)(3) applies only to those drip pads constructed after 12/24/92 and which had no binding contract
for construction.
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-46
-------
covered by this application. List the waste managed in each unit and the rated capacity or size of the unit. If the
information requested is not applicable, an explanation must be submitted.
l.Any other information which is descriptive of the relationship between the miscellaneous unit and the environment.
Application information may include design requirements of 30 TAG 305 and 335, 40 CFR Part 264 Subparts I through 0,
Part 270, and Part 146 that are appropriate for the miscellaneous unit or portions of the unit being permitted.
2.For a unit which involves combustion, you must complete the TNRCC Office of Air Quality Addendum, Section X of
PartB.
V.L.Containment Buildings
Provide an engineering report which includes all of the information specified in 40 CFR 264.1100-110 l(c)(3), and
264.1101(d)-(e). Complete Table V.L. and list the containment buildings covered by this application to be permitted. List
the N.O.R. unit number, whether the unit is for storage and/or processing, the waste or debris managed in each unit, the
rated capacity of each unit, and the overall dimensions of the unit (including containment wall height) that will be in
contact with the waste or debris.
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-47
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TABLE V.B CONTAINER STORAGE AREAS
List the container storage areas covered by this application to be permitted. List the waste managed in each unit and the rated capacity or size of the unit.
No.
Container
Storage Area
N.O.R.
Unit #
Waste No.s1
Rated Capacity
Dimensions
Stacking
height
Aisle
Spacing
Containment Volume
o s
s-s
£1 ^
^
^ Cfl
PI OS
<^
s^
s~<5
^4
^i
Ignitable^
Reactive^2
Incompatible3
Waste
^
^
'from Table IV.B, first column
2If YES, provide in the engineering report drawings demonstrating compliance with the buffer zone requirement of 40 CFR 264.17 and 264.176.
3If YES, provide in the engineering report a description of the procedures used to ensure compliance with 40 CFR 264.17 and 264.177.
TNRCC Part B Application
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A-3-48
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TABLE V.C TANKS
List the tanks covered by this application to be permitted. List the waste managed in each unit and the rated capacity or size of each unit.
No.
Tank
N.O.R.
Unit #
Storage
and/or
Processing
Waste No.s1
Rated Capacity
Dimensions
Containment Volume
5'
2,s
S^ ^
^
3S
^
S><^
^4
~s
Ignitable3^
Reactive3^
Incompatible4
Waste
I
^
'from Table IV.B, first column
2lf the tank has been derated or if the permitted capacity is otherwise different from the design capacity, specify in the engineering report.
3If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.198 and provide drawings demonstrating compliance with any applicable
buffer zone requirements and 40 CFR 264.17.
4lf YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17 and 264.199.
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TABLE V.D.I SURFACE IMPOUNDMENTS
List the surface impoundments covered by this application to be permitted. List the waste managed in each unit and the rated capacity or size of each unit.
No.
Surface
Impoundment
N.O.R. #
Waste No.s1
Rated
Capacit
y
Dimensions
Distance from
lowest liner to
groundwater
Action
Leakage Rate
2
31
^
I
Ignitable3D ,. 3 4
6 'Reactive * ..,,
F020, F021, FOllfVm^ff^^and
F0275 Waste (Y?N) °
'from Table IV.B, first column
2If not required in accordance with 40 CFR 264.222, state "NOT REQUIRED."
3If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17 and 264.229.
4If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17 and 264.230.
5If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.231.
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TABLE V.D.6 SURFACE IMPOUNDMENT LINER SYSTEM
Surface Impoundment
Primary Liner
Material
Permeability
(cm/sec)
Thickness
Secondary Liner
Material
Permeability
(cm/sec)
Thickness
Clay Liner
Material
Permeability
(cm/sec)
Thickness
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TABLE V.E.I WASTE PILES
List the waste piles covered by this application. List the waste managed in each unit and the rated capacity or size of the unit.
No.
Waste Pile
N.O.R.
Unit#
Waste No.s1
Rated Capacity
Dimensions
Distance from
lowest liner to
groundwater
Action
Leakage Rate
^s
3
^
3!'
^
lgnitable3D ,. 3 4
* 'Reactive T ..,,
'Incompatible ,
T020,(gmfffF^f^'^23, F026,
^
^
'from Table IV.B, first column
2If not required in accordance with 40 CFR 264.252, state "NOT REQUIRED."
3YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17 and 264.256.
4If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17 and 264.257.
5If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.259.
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TABLE V.E.3 WASTE PILE LINER SYSTEM
Waste Pile
Primary Liner
1
^
a:
£
"1 —
TO 3
Irir
v^-
gj
s~
TO
&
Secondary Liner
1
~s
a:
£
"1 —
TO 3
Irir
v^-
s
s~
TO
&
Clay Liner
1
~s
a:
£
"1 —
TO 3
ITO^
v^-
s
s~
TO
£
TNRCC Part B Application
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TABLE V.F. 1. LAND TREATMENT UMTS
List the land treatment units covered by this application. List the waste managed in each unit and the rated capacity or size of the unit.
No.
Land Treatment Unit
N.O.R.
Unit#
Waste No.s1'2
Dimensions
Distance from
lowest liner to
groundwater
lemtable3^, .. 3
6 . 'Reactive ,
Incompatible •,
F021, F022, Ftj2fo/026,
and Wn?.75nr—*-
N
<^
'from Table IV.B, first column
2If cadmium is present in the waste, state the concentration in the report.
3If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17 and 264.281.
4If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17 and 264.282
If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.283.
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TABLE V.F.2. LAND TREATMENT UNIT CAPACITY
For the land treatment units listed in Table IV.F.I, specify the waste treatment capacity.
No.
Land Treatment Unit
N.O.R.
Unit#
Rated Capacity
1
^ 1
^~ •»•
<2< Orq
§•
0'
1
t 1
•J' »q
1
o
1
t 1
K^, >i'
§ Orq
i3
o'
p
^
1 1
TO Orq
t-1
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TABLE V.F.3 LAND TREATMENT PRINCIPAL HAZARDOUS CONSTITUENTS
List the wastes for which the demonstration will be made and the principal hazardous constituents in each waste.
Indicate by an (*) asterisk which constituents will be treated and rendered nonhazardous.
Waste
Hazardous Constituents
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A-lvi
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TABLE V.G.I. LANDFILLS
List the landfills covered by this application. List the waste managed in each unit and the rated capacity or size of the unit.
No.
Landfill
N.O.R. Unit
#
Waste No.s1
Rated
Capacity
Dimensions
Distance from
lowest liner to
groundwater
Action Leakage
Rate
s ^'
^
>!'
"
Isnitable30 .. 3
6 'Reactive ,
Incompatible •,
F020, F021, F922,
F023, F026, and
F0275 Waste.
K^
"^
'from Table IV.B, first column
2If not required in accordance with 40 CFR 264.302, state 'NOT REQUIRED.'
3If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17 and 264.312.
4If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17 and 264.313.
If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.317'.
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TABLE V.G.3. LANDFILL LINER SYSTEM
No.
Landfill
Primary Liner
Material
Permeability
(cm/sec)
Thickness
Secondary Liner
Material
Permeability
(cm/sec)
Thickness
Clay Liner
Material
Permeability
(cm/sec)
Thickness
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TABLE V.G.3 (continued) LANDFILL LEACHATE COLLECTION SYSTEM
Landfill
Primary Leachate Collection System
Drainage
Media
Collection
Pipes
(including
risers)
Filter Fabric
Geofabric
Sump
Material
Secondary Leachate Collection System
Drainage
Media
Collection
Pipes
(including
risers)
Filter Fabric
Geofabric
Sump
Material
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TABLE V.H.1 INCINERATORS
List the incinerators covered by this application to be permitted. List the waste managed in each unit and the rated capacity or size of each unit.
No.
Incinerator
N.O.R.
Unit#
Waste No.s1
Waste Physical
Form
Rated Capacity
£
TO
i*J
»
TO
S
^,
1-
^
Continuous Emission
Monitors
Reactive" ,
Incompatible2^
F020, F021, F922,
F023, F026, or F0273
Waste
O
"^
'from Table IV.B, first column
2If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17.
3If YES, the DRE requirement for the unit is 99.9999%
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TABLE V.H.2 PRINCIPAL ORGANIC HAZARDOUS CONSTITUENTS
List the wastes for which the trial burn demonstration will be made and the principal organic hazardous constituents
(POHCs) in each waste.
Waste
Principal Organic Hazardous Constituents
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TABLE V.I.1 BOILERS AND INDUSTRIAL FURNACES
List the boilers and industrial furnaces covered by this application to be permitted. List the waste managed in each unit and the rated capacity or size of each unit.
No.
Boilers and Industrial
Furnaces
N.O.R.
Unit#
Waste No.s1
Waste
Physical
Form
Rated Capacity
£
*
8
S
a
1-
^
Continuous Emission
Monitors
Reactive" ,
Incompatible2^
F020, F021, F922,
F023, F026, or F0273
Waste
O
"^
'from Table IV.B, first column
2If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17.
3If YES, the ORE requirement for the unit is 99.9999%
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TABLE V.I.2 PRINCIPAL ORGANIC HAZARDOUS CONSTITUENTS
List the wastes for which the trial burn demonstration will be made and the principal organic hazardous constituents in
each waste.
Waste
Principal Organic Hazardous Constituents
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TABLE V.J.I DRIP PADS
List the drip pads covered by this application to be permitted.
No.
Drip Pad
N.O.R.
Unit#
Storage and/or Processing
Waste No.s1
Overall Dimensions
Collection System Volume
'from Table IV.B, first column
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TABLE V.J.2 DRIP PAD SYNTHETIC LINER SYSTEM
Drip Pad
Synthetic Liner
Material
Permeability
(cm/sec)
Thickness
Leakage Detection System
Material
Permeability
(cm/sec)
Thickness
Leak Collection System
Material
Permeability
(cm/sec)
Thickness
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TABLE V.K MISCELLANEOUS UNITS
List the miscellaneous units covered by this application to be permitted. List the waste managed in each unit and the rated capacity or size of each unit.
No.
Miscellaneous Unit
N.O.R.
Unit#
Storage, Processing, and/or
Disposal
Waste No.s1
Rated
Capacity
Dimensions
Ignitable2^
Reactive2^
Incompatible2
Waste
^
'from Table IV.B, first column
2If YES, describe in the engineering report the procedures used to ensure compliance with 40 CFR 264.17.
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TABLE V.L CONTAINMENT BUILDINGS
List the containment buildings covered by this application to be permitted.
No.
Containment Building
N.O.R.
Unit#
Storage and/or
Processing
Waste No.s1
Rated Capacity
Overall Dimensions
'from Table IV.B, first column
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VI. GEOLOGY REPORT
This portion of the application applies to owners or operators of new hazardous waste management facilities; areal
and/or capacity expansions of existing hazardous waste management facilities; and existing industrial solid waste
facilities that store, process or dispose of hazardous waste in surface impoundments, landfills, land treatment units,
waste piles (except those waste piles that meet the requirements of item V.E. lO.b. of this application), and tanks or
drip pads which require a contingent post-closure plan.
Submit a Geology Report which includes at a minimum the following information.
A. Geology and Topography
1. Active Geologic Processes
Provide a description of the active geologic processes in the vicinity of the facility. A qualified
geologist shall perform the geological field work, prepare the cross-sections, geologic maps, and
interpret these. This description should include:
a. An identification of any faults (active or otherwise) in the area of the facility. The
preparer should determine which Holocene sediments or man-made structures have
been displaced. The report should contain a description of the investigation
techniques used to identify faults and should assess the degree, if any, to which a
particular fault increases the long-term potential for waste migration. The clearance
required from active faults to ensure that liner systems will not be disrupted will be
based upon site specific factors such as the zone of significant surface deformation,
uncertainty in locating the fault, activity of the fault, and a distance to provide a
reasonable margin of safety. These issues should be addressed when discussing the
offset of an industrial solid waste facility unit from an active fault.
To satisfy the requirements of 30 TAG 305.50(4)(F) and 305.50(10)(E), for a proposed
hazardous waste management facility or a modification or amendment of a permit which
includes a capacity expansion of an existing hazardous waste management facility,
submit the following.
1) A geologic literature review should be conducted, from which useful
information on the possibility of faulting at a given site may be revealed. This
includes, but is not limited to, maps of surface faults, subsurface structure,
and field investigations by the author(s).
2) Descriptions and maps of faulting, fracturing, and lineations in the area are
necessary. An aerial photo with lineation interpretations is suggested.
3) The maps and cross-sections are to be constructed using an amount of data
necessary to adequately describe the geology of the area. Surface data,
including data regarding known surface expressions, such as surface faults,
gas seeps, lineations, etc., should be accounted for in the subsurface
interpretations. A surface structure map should be prepared, incorporating
all of the subsurface data as well as known surface features.
4) A minimum of two structural cross-sections, utilizing available oil field and/or
water well electric log data, shall be made perpendicular to each other,
crossing at the proposed surface unit location. These cross-sections should
define geologic units, indicating especially Holocene sediments and
Underground Sources of IDrinking Water (USDWs), as well as lithology. The
cross-sections should be constructed from the surface, down through the
shallowest major structure or the base of the Holocene, whichever is deeper.
These cross-sections need to be on a scale necessary to depict the local
geology (3000' radius from the site location minimum). If needed to
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adequately describe the local geology, then a larger radius or deeper area of
review may be necessary.
5) A minimum of two structural subsurface maps need to be prepared. One map
should be made on the shallowest mappable subsurface marker, the other on
a deeper horizon that shows the underlying major structure. Additional maps
may be necessary.
6) Field surveillance will be necessary to check the area of the facility for surface
features, such as lineations, and to investigate potential surface faults as
indicated by, but not limited to, aerial photos, topographic maps, and seismic
and subsurface structural maps.
7) The above requirements do not limit the use of any additional information,
such as seismic data, isopach maps, or potentiometric maps, that may help in
defining the geology of the area of review.
8) If faulting exists within 3000 feet of the surface unit, it must be demonstrated
that the fault has not had displacement within Holocene time. If such a fault
does exist, it cannot pass within 200 feet of the surface unit.
9) If a fault that has been active within the Holocene is located within 3000 feet
of the surface unit, it must be demonstrated that, a.) the fault is not
transmissive, i.e., it will not provide for groundwater movement that would
result in endangerment to human health or the environment, and b.) there is
no actual and/or potential problem of subsidence, which could endanger the
stability of the surface unit.
b. A discussion of the extent of land surface subsidence in the vicinity of the facility
including total recorded subsidence and past and projected rates of subsidence. For
facilities located at low elevations along the coast which have experienced appreciable
rates of subsidence, the potential for future submergence beneath Gulf water should
be addressed.
c. A discussion of the degree to which the facility is subject to erosion. The potential for
erosion due to surface water processes such as overland flow, channeling, gullying,
and fluvial processes such as meandering streams and undercut banks should be
evaluated. If the facility is located in a low-lying coastal area, historical rates of
shoreline erosion should also be provided.
2. Regional Physiography and Topography (applicable only to owners or operators of facilities that
store, process, or dispose of hazardous waste in surface impoundments, landfills, land treatment
units, waste piles, except waste piles exempt for groundwater monitoring requirements, and tanks
which require a contingent post-closure plan)
a. Distance and direction to nearest surface water body
b. Slope of land surface
c. Direction of slope
d. Maximum elevation of facility
e. Minimum elevation of facility
3. Regional Geology (applicable only to owners or operators of facilities that store, process, or
dispose of hazardous waste in surface impoundments, landfills, land treatment units, waste piles,
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except waste piles exempt for ground-water monitoring requirements, and tanks which require a
contingent post-closure plan)
Provide a description of the regional geology of the area. This section should include:
a. A geologic map of the region with text describing the stratigraphic and lithologic
properties of the map units. An appropriate section of a published map series such as
the Geologic Atlas of Texas prepared by the Bureau of Economic Geology is
acceptable.
b. A description of the generalized stratigraphic column in the facility area from the base
of the lowermost aquifer capable of providing usable ground water to the land surface.
At least the uppermost 1,000 feet of section below the facility should be described. The
geologic age, lithology, variation in lithology, thickness, depth, geometry, hydraulic
conductivity, and depositional history of each geologic unit should be described based
upon available geologic information. Regional stratigraphic cross sections should be
provided, where available.
4. Subsurface Soils Investigation Report
This section should contain the results of an investigation of subsurface conditions for each
land based unit and/or unit which requires contingent closure and post-closure care. If several
units are in close proximity, a single investigation for the area will suffice. This report should
include:
a. The logs of borings performed at the waste management area. All borings must be
conducted in accordance with established field exploration methods. Investigation
procedures should be discussed in the report. A sufficient number of borings should
be performed to establish subsurface stratigraphy and to identify and allow assessment
of potential pathways for pollution migration. Borings must be sufficiently deep to
allow identification of the uppermost aquifer and underlying hydraulically
interconnected aquifers. Borings should penetrate through the uppermost aquifer and
all deeper hydraulically interconnected aquifers, deep enough to identify the aquiclude
at the lower boundary. Borings should be completed to a depth at least 30 feet below
the deepest excavation planned at the waste management area. The required number
of borings will increase or decrease depending on the heterogeneity of subsurface
materials. Locations with stratigraphic complexities such as non-uniform beds which
pinch out, vary significantly in thickness, coalesce, or grade into other units, will
require a significantly greater degree of subsurface investigation than areas with simple
hydrogeologic frameworks. Boring logs should include a detailed description of
materials encountered including any discontinuities such as fractures, fissures,
slickensides, lenses or seams. Whenever possible, electric logs should be run on each
borehole. The hollow stem auger boring method is recommended in those instances
where an accurate determination of initial water levels is important. A key explaining
both the symbols used on the boring logs and the classification terminology for soil
type, consistency, and structure should be provided.
b. Cross-sectional drawings prepared from the borings depicting the generalized soil
strata profile at the site. For small waste management areas two cross sections prepared
perpendicular to each other will normally suffice.
c. A text which describes the investigator's interpretations of the subsurface stratigraphy
based upon the field investigation. If appropriate, soils may be assigned to generalized
strata to aid in the discussion.
d. Complete Table VI.A.4 and provide in the report data which describes the geotechnical
properties of the subsurface soil materials. All laboratory and field tests must be
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performed in accordance with recognized procedures. A brief discussion of test
procedures should be included. All major strata encountered during the field
investigation phase should be characterized with regard to: Unified Soil Classification,
moisture content, percent less than number 200 sieve, Atterberg limits (liquid limit,
plastic limit, and plasticity index), and coefficient of permeability. Field permeability
tests should be used to determine the coefficient of permeability of sand or silt units
and should also be used to supplement laboratory tests for more clay-rich soils. In
addition, particle size distribution and relative density based upon penetration
resistance should be determined for coarse-grained soils. For fine-grained soils the
following parameters should also be determined: cohesive shear strength based upon
either penetrometer or unconfined compression tests, dry unit weight, and degree of
saturation(s). For the major soil strata encountered, the maximum, minimum, and
average for each of these variables should be compiled.
For land treatment units, provide a description of the surficial soils at the site which
includes:
(1) The name and description of the soil series at the site;
(2) Important physical properties of the series such as depth, permeability,
available water capacity, soil pH, and erosion factors;
(3) Engineering properties and classifications such as USDA texture, Unified Soil
Classification, size gradation, and Atterberg limits (liquid limit, plastic limit,
and plasticity index); and
(4) The cation exchange capacity (CEC) of the soil(s) expressed in units of
meq/lOOg.
Much of this information may be obtained by consulting the county soil survey
published by the United States Department of Agriculture, Soil Conservation Service.
If available, a copy of an aerial photograph showing soil series units on the land
treatment area should be provided.
If an aerial photograph is not available, include a soil series map as an attachment to
this subsurface soils investigation report.
VI. B. Facility Ground Water
If past monitoring has shown the presence of hazardous constituents in the ground water, the owner or
operator must submit a Compliance Plan Application with this application. The TNRCC Permits Section,
Industrial and Hazardous Waste Division can provide instructions for the Compliance Plan Application.
1. Regional Aquifers
Provide a description of the regional aquifers in the vicinity of the facility based upon available
geologic references. The section should provide:
a. Aquifer names and their association with geologic units described in paragraph
V.A.S.b.;
b. A description of the constituent materials of the aquifer(s);
c. A description of the water-bearing and transmitting properties of the aquifer(s);
d. Whether the aquifers are under water table or artesian conditions;
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e. Whether the aquifers are hydraulically connected;
f. A regional water table contour map or potentiometric surface map for each aquifer, if
available, from published references;
g. An estimate of the rate of ground-water flow in units of ft/yr;
h. Values for total dissolved solids content of ground water from the aquifers;
i. Identification of areas of recharge to the aquifers; and
(An application for a new hazardous waste surface impoundment, waste pile, land treatment unit,
or landfill, which is to be located in the apparent recharge zone of a major or minor aquifer, as
designated by the Texas Water Development Board in the publication entitled Water for Texas,
Today and Tomorrow (1990) or subsequent revision must include a hydrogeologic report
documenting the potential effects, if any, on the regional aquifer in the event of a release from
the waste containment system. (30 TAG 305.50(6)])
j. The present use of ground water withdrawn from aquifers in the vicinity of the facility.
The preparer should update paragraph III.C.I.e. of the Part A permit application to ensure that
all water wells within 1 mile of the property boundaries of the facility have been located. The
aquifer(s) yielding water should be identified for each well.
2. Provide groundwater conditions for each land based unit or unit which requires post closure care
which includes all the information specified in 30 TAG 335.156-335.167. This discussion should
also include:
a. Records of water level measurements in borings. The boring logs prepared in response
to paragraph VI.AAa.) should be annotated to note the level at which ground water is
first encountered and the level of ground water after equilibration. Normally a 24-hour
period is adequate for equilibration of ground water but an extended period may be
required for saturated clay deposits. This information should also be presented on the
cross sections required in paragraph VI.AAb.) and in a table.
b. Records of maximum and minimum static water level measurements in monitor wells.
Historic water level measurements made during any previous ground-water monitoring
should be presented in a table for each well.
c. Upper and lower limits of the uppermost aquifer and deeper aquifers which are
hydraulically interconnected to it beneath the facility boundary. In most cases this
identification would include surface contour maps of the top and bottom surfaces.
d. A site specific water table contour map or potentiometric surface map for the uppermost
aquifer, and the basis for such identification (the information obtained from
hydrogeologic investigations of the facility area). The predicted groundwater flow
direction and rate should be indicated.
e. A discussion of the variation of hydraulic gradient across the site, including vertical
gradient. Calculations for the maximum, minimum, and average ground-water flow
velocities for each aquifer identified should also be provided, including pump test data
where appropriate.
f. An analysis of the most likely pathway(s) for pollutant migration in the event that the
primary barrier liner system is penetrated.
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3. Description of the Current and Proposed Well System for Detection Monitoring Program.
The ground-water monitoring standards apply to owners and operators of facilities that treat,
store, or dispose of hazardous waste in surface impoundments, waste piles, land treatment units,
landfills, or tanks without satisfactory secondary containment for which a post-closure care plan
or permit is required. If a waste management unit meets certain standards it may qualify for an
exemption to the ground-water monitoring requirements. An exemption for a unit does not
exempt an entire facility. (See the instructions for each type of unit for a specific exemption.) A
facility-wide exemption is described in Section VI.C.
It is important to note that even if the proposed program may use the same well system as the
present program, the sampling parameters may be different.
a. Include in the design report a description of the proposed detection monitoring
program. This description should contain all requirements of 30 TAG 335.163-335.164.
Provide a justification for the selected suite of waste specific parameters specified in
Table VI.B.3.C below based on toxicity, mobility, persistence, and concentrations in
light and dense non-aqueous phase components of the waste. Describe the proposed
sampling, analysis, and statistical comparison procedures to be utilized in evaluating
groundwater monitoring data. Specify the statistical method and process for
determining whether constituent concentrations in groundwater are above background,
in accordance with 30 TAG 335.163. Refer to the EPA guidance document entitled
Statistical Analysis of Ground-Water Monitoring Data at RCRA Facilities - Interim Final
Guidance (April 1989) (document # EPA/530-SW-89-026) for recommended methods.
b. Complete Table VI.B.3.b to specify the proposed well system for each unit or waste
management area which requires groundwater monitoring.
c. Complete Table VI.B.3.C to specify:
1) the suite of waste specific parameters (indicator parameters, waste
constituents, or reaction products) which will be analyzed at each sampling
event for each well or group of wells. These parameters must provide a
reliable indication of the presence of hazardous constituents in the ground
water;
2) the sampling frequencies and calendar intervals (e.g., monthly; quarterly
within the second 30 days of each quarter; semiannually within the first 30
days of the 2nd and 4th quarters, etc.);
3) the detection limit of the sample preparation and analysis methods for the
selected parameters. This detection limit will represent the capability of the
sampling and analysis to reliably and accurately determine the presence of
the selected parameters in the sample; and
4) the concentration limit which will be the basis for determining whether a
release has occurred from the waste management unit/area. Concentration
limits shall be based on background values for the waste management
unit/area, or Practical Quantitation Limit (PQL) values identified in 40 CFR 264,
Appendix IX. If background values are lower than PQLs, the applicant may
choose respective PQLs as concentration limits for hazardous constituents.
d. Submit drawings depicting the monitoring well design, current and proposed.
e. Submit at least one map of the entire facility and additional maps or drawings if
necessary on one or more S'/z" x 11" sheets of sufficient scale to show the following in
adequate detail.
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1) Monitoring well locations, current and proposed
2) Soil-pore liquid and core sampling points, current and proposed
3) Waste management unit(s)/area
4) Property boundary
5) Point of compliance
6) Direction of ground-water flow
7) Extent of any known plume of contamination
VI. C. Exemption from Ground-water Monitoring for an Entire Facility
In accordance with 30 TAG 335.156, a waste management facility may be exempt from ground-water
monitoring if the owner or operator can demonstrate that there is no potential for migration of liquid from
any regulated unit to the uppermost aquifer during the active life of the regulated unit (including the
closure period) and post-closure care period. This demonstration must be submitted with the permit
application, and must be certified by a qualified geologist or geotechnical engineer.
This exemption does not apply to Unsaturated Zone Monitoring. Owners and operators of Land
Treatment Units must monitor the unsaturated zone under all circumstances.
The following areas should be addressed in the demonstration, and any predictions must be made on
assumptions that maximize the rate of liquid migration:
1. Thickness of soil between the base of the unit and saturated zone
2. Thickness of saturated zone
3. Head pressure of the fluids
4. Properties of the saturated and unsaturated zone (including permeability, effective porosity, and
inhomogeneity).
5. Total life of facility
The criteria used for the evaluation of this demonstration are more stringent than those used for
evaluations of demonstrations submitted prior to permitting. Thus it is necessary for an owner or operator
to submit another demonstration even if one was submitted and approved previously.
This type of exemption differs from the exemptions described under the Landfills, Surface Impoundments,
and Waste Piles Sections. An owner or operator may pursue a facility-wide exemption as well as an
exemption for a particular unit, if the owner or operator wishes.
VI. D. Unsaturated Zone Monitoring
This section applies only to facilities which contain land treatment units. Attach any previous monitoring
data to the monitoring report.
1. List all hazardous constituents that have been or will be monitored.
a. Current parameters
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b. Proposed parameters
2. Number of soil-pore liquid sampling points
a. Depth of sampling points
b. Equipment used for soil pore liquid monitoring
3. Number of soil core sampling points
a. Depth of soil core sampling points
b. Indicate on a facility map locations of all sampling points.
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TABLE VI.A.4 WASTE MANAGEMENT AREA SUBSURFACE CONDITIONS
Boring
Number
Depth Below
Grade
Stratum
use
Symbol
Liquid Limit
Plasticity
Index
Percent Passing
#200 Sieve
Permeability
Percent
Porosity
Maximum depth:
_ feet below grade
feet above MSL
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TABLE VI.B.3.b UNIT GROUNDWATER DETECTION MONITORING SYSTEM
For each unit/area which requires ground-water monitoring, specify the number and type of wells which will comprise the groundwater monitoring system for the unit/area. Prepare
additional tables as necessary.
Waste Management Unit/Area Name1
Well Number^
Hydrogeologic Unit Monitored
Type (e.g.,. point of compliance, background, observation,
etc.)
Up or Down Gradient
Casing Diameter and Material
Screen Diameter and Material
Screen Slot Size (in.)
Top of Casing Elevation (ft, MSL)
Grade or Surface Elevation (ft, MSL)
Well Depth (ft, )
Screen Interval, From(ft)
To(ft)
Facility Coordinates (e.g., lat/long or company coordinates)
'From Tables in Section V.
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TABLE VI.B.3.C GROUNDWATER SAMPLE ANALYSIS
For each well or group of wells, specify the suite of parameters for which groundwater samples will be analyzed.
Well No(s).
Parameter
Sampling
Frequency
Detection Limits
Concentration Limits1
1 The concentration limit is the basis for determining whether a release has occurred from the waste management unit/area.
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VII. CLOSURE AND POST-CLOSURE PLANS
Submit a full closure plan and post-closure plan, if applicable which contains all the information required by 30 TAG
335.8,335.169,335.172,335.174,335.177-335.178,335.551-335.569,40 CFR264.112,264.118,264.178,264.197,264.228,
264.258,264.280,264.310,264.351,264.575,264.601,264.603,264.1102,270.14(b)(13), 270.17(1), 270.18(h), 270.20(f),
270.21(e), 270.23(a)(3), and 270.26(c)(16) where applicable. The owner of property on which an existing disposal
facility is located must also submit documentation that a notation has been placed in the deed to the facility that
will in perpetuity notify any potential purchasers of the property that the land has been used to manage hazardous
wastes and its use is restricted (see 30 TAG 335.5). For hazardous waste disposal units that were closed before
submission of the application, the applicant should submit documentation to show that plats and notices required
under 40 CFR 264.116 and 264.119 have been filed.
A. Closure
This section applies to the owners and operators of all hazardous waste management facilities to be
permitted. The applicant must close the facility in a manner that minimizes need for further maintenance
and controls, or eliminates, to the extent necessary to protect human health and the environment, the post-
closure escape of hazardous waste, hazardous constituents, leachate, contaminated rainfall, or waste
decomposition products to the ground water, or surface waters, or to the atmosphere.
The facility type and type of unit to be closed can determine the level of detail sufficient for a closure plan.
For each unit to be permitted, complete Table VILA and list the facility components to be decontaminated,
possible methods of decontamination, and possible methods of disposal of wastes and waste residues
generated unit during closure.
Additionally, if the applicant plans to close a surface impoundment in accordance with 30 TAG
335.169(a)(l) and the impoundment does not comply with the liner requirements of 30 TAG Section
335.168(a) then the closure plan for the impoundment must include both a plan for complying with 30 TAG
335.169(a)(l) and a contingent plan for complying with 30 TAG 335.169(a)(2).
Guidance on design of a closure cap and final cover for landfills is given in TNRCC Technical Guideline
No. 3, and EPA publication 530-SW-85-014 presents guidance on construction quality assurance of liner
construction.
If a waste pile does not comply with the liner requirements of 30 TAG Section 335.170(a)(l) then the
closure plan for the waste pile must include both a plan for complying with 40 CFR 264.258(a) and a
contingent plan for complying with 40 CFR 264.258(b).
The final certification of closure of a land treatment unit may be prepared by an independent qualified soil
scientist in lieu of an independent registered professional engineer.
B. Closure Cost Estimate (including contingent closure) [30 TAG 335.178, 40 CFR 264.142]
This section applies to owners or operators of all hazardous waste facilities, except state and federal
agencies. A detailed estimate, in current dollars, of the cost of closing the facility should be included in
the report. The cost estimate must include the cost of closure at the point in the facilities operating life
when the extent and manner of its operation would make closure the most expensive. The TNRCC has
published Technical Guideline No. 10 for calculating closure costs which should be consulted. Closure
costs should be developed on the basis of abandonment of the site at full capacity and closure activities
to be conducted by a third party with no operable on-site equipment. The costs for closing each unit
must be detailed.
1. If closure costs are based on contractor bids, the applicant should submit a copy of the bid
specification and each contractor's response.
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2. If closure costs are based on a detailed analysis, the applicant should submit details of item
costs and number of each item, and details of costs for equipment rental, third party labor and
supervision, transportation, analytical costs, etc. Provide an itemized cost estimate similar in
style and content to Table VII.B for a complete, third party permitted facility closure and
summarize in Table VILE.
As units are added or deleted from these tables through future permit amendments or
modifications, the remaining itemized unit costs should be updated for inflation when re-
calculating the revised total cost in current dollars.
3. The closure plan may propose on-site disposal of wastes, residues, etc. during closure of a unit,
and this may be executed if on-site capacity exists in other units during closure of a unit.
However, the cost estimate for closure must be based on off-site shipment and disposal during
closure of all wastes, waste residues, wastes generated by decontamination, contaminated
stormwater, and leachate.
4. For each surface impoundment, waste pile, or tank system required to have a contingent closure
plan, the cost for closure under the contingent closure plan should be detailed, as well as the
cost of proposed closure. The more expensive of the cost of the proposed closure of a unit
versus the cost of the contingent closure of the unit should be used in the total facility closure
cost estimate.
VII. C. Post-closure
This section applies to owners or operators of all hazardous waste disposal facilities. This section also
applies to certain waste piles, tanks and surface impoundments from which the owner or operator intends
to remove wastes at closure but which are required to have contingent post-closure plans.
Post-closure care of each hazardous waste management unit must continue for 30 years after the date of
completing closure of the unit and must consist of monitoring and reporting of the ground-water
monitoring systems in addition to the maintenance and monitoring of waste containment systems.
Continuation of certain security requirements may be necessary after the date of closure. Post-closure
use of property on or in which hazardous waste remains after closure must never be allowed to disrupt
the integrity of the containment system. In addition, submit the following information.
1. The post-closure care plan for a landfill or of a surface impoundment, waste pile, miscellaneous
unit, or tank system closed with wastes or waste constituents left in place, or closed under a
contingent closure plan, must demonstrate compliance with 30 TAG 335.174(b).
2. The name, address, and phone number of the person or office to contact about the disposal
facility during the post-closure period; and
3. A discussion of the future use of the land associated with each unit.
4. For landfills, surface impoundments, waste piles, and land treatment areas closed under interim
status, submit the required documentation of 40 CFR 270.14(b)(14).
5. Landfills, surface impoundments, waste piles and land treatment areas that received hazardous
wastes after July 26, 1982 or for which closure was certified after January 26, 1983 must be
included in post-closure care plans unless they have been determined to have closed by removal
equivalent to the closure standards in 40 CFR 264 Subpart G. If such a demonstration has been
made pursuant to 40 CFR 270.1(c)(5), but an equivalency determination has not been made,
please submit a copy of the demonstration documentation. If an equivalency determination has
been made pursuant to 40 CFR 270.1(c)(6), applicant should submit a copy of the determination.
Complete Table VII.C.5 for all land based units closed under interim status.
VII. D. Post-closure Cost Estimate [40 CFR 264.144]
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This section regarding post-closure cost estimate applies to owners or operators of all hazardous waste
disposal facilities, except state and federal agencies, and certain waste piles, tank systems, and surface
impoundments from which the owner or operator intends to remove wastes at closure, but which are
required to have contingent closure and post-closure plans. A detailed estimate, in current dollars, of the
annual cost of monitoring and maintenance of the facility in accordance with the applicable post-closure
regulations must be included in the report. The TNRCC has published Technical Guideline No. 10 for
calculating post-closure costs, which should be consulted. Costs should be developed in detail for 30
years of post-closure care activities to be conducted by a third party, for each applicable unit.
1. The applicant should submit details of item costs and number of each item for off-site disposal of
leachate and bailed monitor well water, labor and supervision, monitor well sampling and analyses,
inspection and repair of the cap(s), mowing and re-seeding of the vegetative cover, maintaining
site security, etc. Provide an itemized cost estimate similar in style and content to Table VII.D for
complete, third party permitted facility post-closure care and summarize in Table VILE.
As units are added or deleted from these tables through future permit amendments or
modifications, the remaining itemized unit costs should be updated for inflation when re-
calculating the revised total cost in current dollars.
2. Total annual cost of post-closure care for the facility including costs of contingent post-closure
care should be multiplied by 30 years.
5 or the remainder of 30 years from the date of closure certification for each unit if the unit has been previously
certified closed.
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TABLE VILA UNIT CLOSURE
For each unit to be permitted, list the facility components to be decontaminated, the possible methods of decontamination, and the
possible methods of disposal of wastes and waste residues generated during unit closure:
Equipment ofHWM Unit
Possible Methods of Decontamination1
Possible Methods of Disposal1
'Applicants may list more than one appropriate method.
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TABLE VII.B UNIT CLOSURE COST ESTIMATE
Task
(Name of permitted unit, e.g.,
Verbal description
Verbal description
Verbal description
Verbal description
TankTK-1)
of task (waste amount generated x
of task (waste amount generated x
of task (waste amount generated x
of task (waste amount generated x
disposal cost/unit amount)
disposal cost/unit amount)
disposal cost/unit amount)
disposal cost/unit amount)
Other tasks (such as labor, lab analysis, transportation, certifications, etc.)
Other tasks
(Name of permitted unit, e.g.,
Verbal description
Verbal description
Verbal description
Verbal description
Surface Impoundment West)
of task (waste amount generated x
of task (waste amount generated x
of task (waste amount generated x
of task (waste amount generated x
subtotal
Contingency (10% minimum)
Total Unit Closure Cost
disposal cost/unit amount)
disposal cost/unit amount)
disposal cost/unit amount)
disposal cost/unit amount)
Other tasks (such as labor, lab analysis, transportation, certifications, etc.)
Other tasks
subtotal
Contingency (10% minimum)
Total Unit Closure Cost
Cost
$$,$$$
$$,$$$
$$,$$$
$$,$$$
$$,$$$
$$,$$$
$$$,$$$
$$,$$$
$$$,$$$ (199J
$$,$$$
$$,$$$
$$,$$$
$$,$$$
$$,$$$
$$,$$$
$$$,$$$
$$,$$$
$$$,$$$ (199J
1 TOTAL PERMITTED FACILITY CLOSURE COST (all unit costs combined)
$,$$$,$$$ (199 ) ||
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TABLE VII.C.5 LAND-BASED UNITS CLOSED UNDER INTERIM STATUS
N.O.R. Unit#
Unit Description1
Date of Receipt of
Last Waste3
Date of Closure
Certification3
'indicates a unit for which a 40 CFR 264 closure equivalency determination has been requested pursuant to 40 CFR
270.1(c)(5).
Indicates a unit for which a 40 CFR 264 closure equivalency determination has been made pursuant to 40 CFR 270.1(c)(6).
3Give month, day and year.
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TABLE VII.D UNIT POST-CLOSURE COST ESTIMATE
Task
(Name of permitted unit, e.g.,. East Landfill)
Verbal description of annual task, e.g
cost/unit amount)
Verbal description of annual task, e.g
amount)
Verbal description of annual task, e.g
events/well/year x lab analysis cost)
Verbal description of annual task
Other annual tasks
Other annual tasks
,. leachate collected (amount generated x disposal
,. cap maintenance (material needed x cost/unit
,. detection monitoring system (# of wells x # sample
subtotal
Contingency (10% minimum)
TOTAL UNIT POST-CLOSURE CARE COST x 30 yrs. (or other post-closure care period)
(Name of permitted unit, e.g.,. Surface Impoundment West)
Verbal description of annual task, e.g
cost/unit amount)
Verbal description of annual task, e.g
amount)
Verbal description of annual task, e.g
events/well/year x lab analysis cost)
Verbal description of annual task
Other annual tasks
Other annual tasks
,. leachate collected (amount generated x disposal
,. cap maintenance (material needed x cost/unit
,. detection monitoring system (# of wells x # sample
subtotal
Contingency (10% minimum)
TOTAL UNIT POST-CLOSURE CARE COST x 30 yrs. (or other post-closure care period)
1 TOTAL PERMITTED FACILITY POST-CLOSURE COST (all unit costs combined)
Cost
$$,$$$
$$,$$$
$$,$$$
$$$,$$$
$$,$$$
$,$$$,$$$ (199J
$$,$$$
$$,$$$
$$,$$$
$$$,$$$
$$,$$$
$,$$$,$$$ (199 )
$,$$$,$$$ (199 J H
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TABLE VILE CLOSURE/POST-CLOSURE COST SUMMARY
Closure Cost Estimate
Unit
TOTAL CLOSURE COST ESTIMATE
Cost
(199J6
Post-Closure Cost Estimate
Unit
TOTAL POST-CLOSURE COST ESTIMATE
Cost
(199 )6
6As units are added or deleted from these tables through future permit amendments or modifications, the
remaining itemized unit costs should be updated for inflation when re-calculating the revised total cost in current
dollars.
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VIII. FINANCIAL ASSURANCE
A. Financial Assurance Information Requirements for all Applicants ( 30 TAG 305.50(4)(A-E), 335.179)
1. Financial Assurance for Closure
An owner or operator must establish financial assurance for the closure of the facility no later than
60 days prior to the first receipt of hazardous waste. Please refer to 40 CFR 264.143 for the financial
assurance requirements for closure, and provide a signed statement from an authorized signatory
per 30 TAG 305.44 regarding how the owner or operator will comply with this provision.
If the financial mechanism(s) has been obtained, provide a copy of the mechanism(s)
2. Financial Assurance for Post Closure Care (applicable to disposal facilities and contingent post
closure care facilities only)
An owner or operator subject to post closure monitoring or maintenance requirements must
establish financial assurance for the post closure care of the facility no later than 60 days prior to
the first receipt of hazardous waste. Please refer to 40 CFR 264.145 for the financial assurance
requirements for post closure, and provide a signed statement from an authorized signatory per
30 TAG 305.44 regarding how the owner or operator will comply with this provision.
If the financial mechanism(s) has been obtained, provide a copy of the mechanism(s)
3. Liability Requirements
All owners or operators must establish financial assurance for third party sudden liability
coverage of the facility no later than 60 days prior to the first receipt of hazardous waste. Owners
or operators of disposal facilities must establish financial assurance for third party sudden and
nonsudden liability coverage of the facility no later than 60 days prior to the first receipt of
hazardous waste. Please refer to 40 CFR 264.147 for the financial assurance requirements for
liability coverage, and provide a signed statement from an authorized signatory per 30 TAG 305.44
regarding how the owner or operator will comply with this provision.
If the financial mechanism(s) has been obtained, provide a copy of the mechanism(s).
B. Applicant Financial Disclosure Statements for a permit, permit amendment, or permit modification (30
TAG 305.50(4))
1. A statement signed by an authorized signatory per 30 TAG 305.44 explaining in detail how the
applicant demonstrates sufficient financial resources to construct, safely operate, properly close,
and provide adequate liability coverage for the facility.
2. Audited financial statements for the last two years and the most current quarterly financial
statement prepared according to generally accepted accounting principles. If audited statements
have not been prepared for the applicant, copies of the applicant's last two years of financial
statements and tax returns shall be submitted. The copies of the tax returns shall be certified by
original signature of an authorized officer or owner as being a "true and correct copy of the return
filed with the Internal Revenue Service." Additionally, an audited financial statement shall be
prepared and submitted for the most recent fiscal year. All financial statements shall include a
balance sheet, income statement, cash flow statement, notes to the financial statements, and the
accountant's opinion letter.
3. For publicly traded companies, copies of Securities and Exchange Commission Form 10-K for the
last two years and the most current Form 10-Q.
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4. For privately-held companies, written disclosure of the information that would normally be found
in Form 10-K including, but not limited to, the following:
a) descriptions of the business and its operations;
b) identification of any affiliated relationships;
c) credit agreements and terms;
d) any legal proceedings involving the applicant;
e) contingent liabilities; and
f) significant accounting policies.
C. Applicants Requesting Facility Expansion, Capacity Expansion, or New Construction
Provide the following information as applicable to the particular financial circumstances:
1. Estimate of capital costs for expansion and/or construction. Complete Table VIII.C.
2. Evidence of financial resources to construct, operate safely, close, and provide liability coverage
for the facility.
a) Applicants demonstrating through financial statements or existing credit arrangements
sufficient financial resources to construct, operate, and close the facility may address this
requirement with the signed statement submitted to satisfy Section B.I.
b) Applicants that must obtain additional financing through a new stock offering or new debt
issuance for construction or expansion as requested in this application shall submit the
following information:
i) a financial plan sufficiently detailed to clearly demonstrate that the applicant will
be in a position to readily secure financing for construction, operation, and closure
if the permit is issued. The submitted financial plan must be accompanied by
original letters of opinion from two financial experts, not otherwise employed by
the applicant, who have the demonstrated ability to either finance the facility or
place the required financing. The opinion letters must certify that the financial
plan is reasonable, certify that financing is obtainable within 180 days of issuance
of the permit, and include the time schedule contingent upon permit issuance for
securing the financing. Only one opinion letter from a financial expert, not
otherwise employed by the applicant, is required if the letter renders a firm
commitment to provide all the necessary financing; and
ii) a written detail of the annual operating costs of the facility and a projected cash
flow statement including the period of construction and first two years of
operation. The cash flow statement must demonstrate the financial resources to
meet operating costs, debt service, and financial assurance for closure, post
closure, and liability coverage requirements. A list of the assumptions made to
forecast cash flow shall also be provided.
3. For new commercial hazardous waste management facility applications, a written statement signed
by an authorized signatory per 30 TAG 305.44 explaining how the applicant intends to provide
emergency response financial assurance per 30 TAG §305.50(12)(C) or (D).
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TABLE VIII.C ESTIMATED CAPITAL COSTS
Estimated
Capital
Costs
Site preparation, fencing, paving, curbing, lighting, roadways
Foundations, buildings, other structures, utilities and connections, drainage system, HVAC
system, Electrical system, wastewater system
Process and control equipment
Auxiliary equipment, including but not limited to exhaust hoods, fans, ducting, pumps,
piping, conveyors, stacks, storage tanks, process tanks, waste disposal facilities, pollution
control equipment, and fire protection system
Process integration and instrumentation
Emergency response equipment
Transportation equipment
Office equipment
Engineering design, supervision, overhead
Construction expenses including permits, insurance, temporary facilities, and clean-up
Contractor's fees and overhead
Contingency
Total
The estimates listed above were derived from the following sources:
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IX. RELEASES FROM SOLID WASTE UNITS AND CORRECTIVE ACTION
The Texas Solid Waste Disposal Act, 30 TAG 335.167, 40 CFR 270.14(d) and Section 3004(u) of the Hazardous and
Solid Waste Amendments of 1984 (HSWA) require that each hazardous waste management permit application
review shall address corrective action for all releases of hazardous waste or 40 CFR 261 Appendix VIII hazardous
constituents from any solid waste management unit (SWMU) at a facility, regardless of the time at which waste
was placed in such unit.7 Current EPA interpretation of this requirement has resulted in a Corrective Action
process that begins with a RCRA Facility Assessment (RFA) to determine if corrective action is necessary.
The first step in the RFA is the development of a Preliminary Review (PR) from all available documentation for
a facility (including but not limited to all facility documents, Part A, and Part B of the permit application, TNRCC
correspondence files and inspection reports, etc.) The PR compiles available information on every SWMU that
has ever existed at the facility. A unit checklist is completed for each SWMU. On a unit-by-unit basis, the PR
may recommend no further action for:
well-designed and well-managed units
units that have not managed hazardous wastes or wastes containing hazardous constituents
units already under corrective action by enforcement order
units scheduled to be addressed in a compliance plan, or
units which are RCRA regulated units and will be authorized in the hazardous waste permit.
In addition, the unit checklists are summarized in a Facility Checklist. If there is a known release or potential for
a release of hazardous waste or hazardous constituents from a unit, the PR may recommend a RCRA Facility
Investigation (RFI) to determine the extent of the release for future corrective action, or stabilization as an
appropriate and immediate corrective action.
The second step is a Visual Site Inspection (VSI) of the entire facility. The RFA is the combination of the PR and
VSI documentation and any sample results. The RFA process should be scheduled so as to be completed during
the latter stages of the Technical Review process or no later than one month in advance of the preparation of an
initial draft permit for the facility. The RFA includes recommendations for whether further investigation or
corrective action is warranted.
The requirements for an RFI or any other corrective action will be included in the permit, in the associated
compliance plan which is mandatory for facilities with known ground-water contamination, or pursuant to 40 CFR
270.14(d)(3), the applicant may be required to start the RFI or other corrective action before the permit is issued.
The RFI shall comply with all the applicable items contained in the U.S. EPA publication EPA/520-R-94-004,
OSWER Directive 9902.3-2A, RCRA Corrective Action Plan (Final), May 1994, unless an alternate investigation
approach is approved by the Executive Director. An RFI workplan may typically include a soil boring program,
installation of monitoring wells, and sampling and analysis for 40 CFR 261 Appendix VIII and 40 CFR 264
Appendix IX hazardous constituents for surface soils, subsurface strata, surface water, ground water, and/or air.
The permittee shall perform the RFI and report the results. If the RFI Report indicates releases of hazardous waste
or hazardous constituents, then the permittee shall submit a Baseline Risk Assessment (BLRA)/Corrective
Measures Study (CMS) Report. This report shall evaluate the risk, identify and evaluate corrective measure
7For the purposes of HSWA Corrective Action, a SWMU may include, but is not limited to, any landfill, surface
impoundment, land treatment unit, waste pile, underground injection well, incinerator, boiler, industrial furnace, tank,
container storage area, drip pad, containment building, miscellaneous unit; any units exempt from hazardous waste
permitting requirements, such as wastewater treatment units, elementary neutralization units, totally enclosed
treatment units, waste recycle/reuse units, and 90-day accumulation time units; or process units or areas which may
have routine and/or systematic releases to the environment (e.g., process drainage ditches or product storage tanks).
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alternatives, and recommend appropriate corrective measure(s) to protect human health and the environment.
The BLRA/CMS Report shall address all of the applicable items in 30 TAG 335 Subchapter S and the U.S. EPA
publication EPA/520-R-94-004, OSWER Directive 9902.3-2A, RCRA Corrective Action Plan (Final), May 1994.
Upon approval of the BLRA/CMS Report by the TNRCC, the permittee shall submit a Corrective Measures
Implementation (CMI) Workplan to address all of the items for CMI Workplan contained in the U.S. EPA
publication EPA/520-R-94-004, OSWER Directive 9902.3-2A, RCRA Corrective Action Plan (Final), May 1994.
If the CMI does not propose a permanent remedy, then a CMI Workplan shall be submitted as part of a new
compliance plan application or as a modification/amendment application to an existing compliance plan. The
workplan shall contain detailed final engineering design, monitoring plans, and schedules necessary to implement
the selected remedy. Implementation of the corrective measures shall be addressed through a new and/or a
modified/amended compliance plan. Upon installation of a corrective action system based upon the approved
CMI Workplan, the permittee shall submit a CMI Report which includes as-built drawings of the corrective action
system. To report the progress of the corrective measures, the permittee shall submit periodic CMI Progress
Reports to the TNRCC in accordance with the schedule specified in the compliance plan.
Please note that the applicant/permittee may perform voluntary corrective action, stabilization, or "interim
measures" at any time prior to or during the RFA/RFI/CMS/CMI process without prior TNRCC approval. The
TNRCC strongly supports these actions when undertaken to mitigate releases or reduce or minimize exposure and
releases to human health and the environment.
IX. A. Preliminary Review Checklists
For all facility SWMUs (as defined previously), complete the accompanying forms entitled "Preliminary
Review Facility Checklist" (pg. 85) and "Preliminary Review Unit Checklist" (pg. 86). Make additional
copies as necessary. The following instructions are provided in same format as these forms:
PRELIMINARY REVIEW FACILITY CHECKLIST INSTRUCTIONS
Facility Checklist - On the form provided, supply the following information:
Fill out the information block at the top of the page (the reviewer space should remain blank for the TNRCC permit writer).
Facility: City:
ISW Reg No: Date:
Permit No: Reviewer:
EPA ID No:
I. Waste Management Units:
1. RCRA Regulated Units: List all units that received hazardous wastes after July 26, 1982 or for which
closure was certified after January 26, 1983 with the appropriate information under the three provided
column headings as explained in the Unit Checklist instructions.
2. Solid Waste Management Units: List all remaining SWMUs.
II. Reviewed Documents: Enter the appropriate information for sub-items 1-6, including document dates (item 6
should include company files).
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III. Summary: Provide an overall summary of the results of this Preliminary Review noting units and areas of
concern.
IV. Recommended Actions: Summarize the Unit Checklist Recommended Actions and list those units recommended
for further investigation including appropriate Unit No.
PRELIMINARY REVIEW UNIT CHECKLIST INSTRUCTIONS
Unit Checklist - On the form provided, supply the following information for EACH unit or area of concern:
I. Waste Management Unit: Enter SWMU name and facility designated number (e.g., Tank 101)
A. N.O.R. No.: enter TNRCC Notice of Registration (N.O.R.) Number or, if unassigned, a letter designation
(i.e., A-Z)
B. Description: enter type of unit (e.g., above-grade processing tank) and Process Code as listed below:
Process
Code
D79
D80
D81
D83
D99
SOI
S02
SOS
S04
SOS
S06
S99
T01
T02
T03
T04
T80
T81
Unit Type
Disposal
Injection Well
Landfill
Land Application
Surface Impoundment - Disposal
Other Disposal
Storage
Container
Tank - Storage
Waste Pile
Surface Impoundment - Storage
Drip Pad
Containment Building - Storage
Other Storage
Treatment
Tank - Treatment
Surface Impoundment - Treatment
Incinerator
Other Treatment
Boiler
Cement Kiln
Process
Code
T82
T83
T84
T85
T86
T87
T88
T89
T90
T91
T92
T93
T94
X01
X02
X03
X04
X99
Unit Type
Lime Kiln
Aggregate Kiln
Phosphate Kiln
Coke Oven
Blast Furnace
Smelting, Melting, or Refining Furnace
Titanium Dioxide Chloride Process Oxidation Reactor
Methane Reforming Furnace
Pulping Liquor Recovery Furnace
Combustion Device Used in Recovery of Sulfur Values from
Spent Sulfuric Acid
Halogen Acid Furnace
Other Industrial Furnaces Listed in 40 CFR 260 10
Containment Building - Treatment
Miscellaneous (SubpartX)
Open Burning/Open Detonation
Mechanical Processing
Thermal Unit
Geologic Repository
Other Subpart X
C. Dates of Operation: enter the date the unit was placed into service and any other dates the unit changed
status (active, inactive, closed, post-closure) with the appropriate status designation.
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II. Wastes Managed: List all solid wastes ever managed in the unit and include the TNRCC NOR waste #, EPA
Hazard Codes, and EPA waste codes. For each waste, list any hazardous constituent listed in 40 CFR 261
Appendix VIII and 264 Appendix IX, as appropriate.
III. Evidence of Release: Completely describe the release, including time frame, waste amount, to what media, and
any corrective measures taken.
IV. Pollutant Dispersal Pathways: Completely describe the possible and actual run-off pathways (i.e., to which
tributary, creek, river, and bay or through subsoil to which aquifer with groundwater flow gradient, speed, and
direction and any discharge point).
V. Summary: Provide complete unit description including unit type, elements of construction, location, age,
condition, dimensions, size, capacity (i.e., gallons, square feet, cubic yards, etc.), and potential for release.
VI. Recommended Action: Recommend No Further Action, Stabilization (interim measures), or Further Investigation
and justify. Note, corrective action under another authority is justification for No Further Action.
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-93
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Facility:
ISW Reg No:
Permit No:
EPA ID No:
PRELIMINARY REVIEW FACILITY CHECKLIST
City:
Date:
Reviewer:
Waste Management Units:
1. RCRA Regulated Units:
NOR No. Description
Status
2. Solid Waste Management Units:
NOR No. Description
Status
II. Reviewed Documents:
1. RCRA: Part A
PartB
Permit
2. CERCLA:
3. Inspection Reports:
4. Enforcement Actions:
5. Exposure Information:
6. Other Information:
III. Summary:
IV. Recommended Action:
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97)
3-A-94
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PRELIMINARY REVIEW UNIT CHECKLIST
Facility: City:
ISW Reg No: Date:
Permit No: Reviewer:
EPA ID No:
I. Waste Management Unit:
A. NOR No:
B. Description:
C. Dates of Operation:
II. Wastes Managed:
III. Evidence of Release:
IV. Pollutant Dispersal Pathways:
V. Summary:
VI. Recommended Action:
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-95
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IX. B. Appendices to Preliminary Review (PR)
The PR should also include Appendices I-IV to correspond to the Roman numerals in the Unit Checklist:
Appendix I. FACILITY and SWMU LOCATION MAPS
Regional Location Map
Site Location Map
Facility SWMU Map - Use the Notice of Registration (NOR) number to show the location of each unit on
a replicate of the topographic map required in Section V. A. 1 of this application. Also, please note that
the term "facility" includes the entire contiguous property under the control of the owner or operator,
which in most cases is the area shown as the legal description of the site in the facility's Part A permit
application.
Appendix II. WASTES MANAGED
List all wastes managed and 40 CFR 261 Appendix VIII and 40 CFR 264 Appendix IX hazardous
constituents. Provide pertinent health, safety, and risk data on each.
Appendix III. EVIDENCE of RELEASE
Provide any applicable documentation on a release. Provide a map of release locations, SWMU
identification, and paths traveled.
Appendix IV. POLLUTANT DISPERSAL PATHWAYS
Provide a facility, local, and regional map identifying all possible and eventual pathways in which a release
from any unit could or did travel. Provide a facility general cross-section to illustrate vertical pathways
and lateral movements in ground water, including discharges (i.e., seeps, creeks, etc.).
IX. C. Preliminary Review Submittal Format
The PR should be bound with a cover page and contain a Table of Contents with the Facility Checklist
entered first followed by all the Unit Checklists in unit NOR numerical order and alphabetical order.
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-96
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X. AIR EMISSION STANDARDS
Section X.A applies to all permit applications, including post-closure permit applications. Permittees with "one
stop" permits applying for an amendment, modification, or renewal should clearly state whether they wish to
amend, modify, or renew the Office of Air Quality portions of their combined permit or if they intend to seek
separate authorizations, as appropriate, from the OAQ and subsequently delete these requirements from their
hazardous waste permit.
A. Process Vents and Equipment Leaks
For process vents and equipment subject to the requirements of 40 CFR Part 264 Subparts AA and BB,
and Part 270, please provide an air emissions report that includes all of the information required by 40 CFR
264.1032,264.1033,264.1035,264.1052, 264.1059, 264.1060, 264.1064, 270.24, and270.25.8 Indicate on a
facility plot plan the approximate location of process vents and equipment.
Wastewater treatment units, elementary neutralization units, totally enclosed treatment units, and 90 day
accumulation tanks are not subject to control.
1. Complete Table X.A. 1 for all vents on waste management units that manage hazardous waste with
an annual average total organics concentration of 10 ppmw or greater ("process vents").
Specifically include:
a. process vents on distillation, fractionation, thin-film evaporation, solvent extraction, air or
steam stripping operations, and vents on condensers serving these operations; and
b. process vents on tanks (e.g., distillate receivers, bottom receivers, surge control tanks,
separator tanks, and hot wells) associated with distillation, fractionation, thin-film
evaporation, solvent extraction, and air or steam stripping processes if emissions from
these process operations are vented through the tanks.
Emissions caused by natural means such as daily temperature changes or by tank loading and
unloading are not subject to control.
2. For process vents, include the following certification as part of the air emissions report:
"I, owner or operator certify that the operating parameters used in the design analysis reasonably
represent the conditions that exist when the hazardous waste management unit is or would be operating
at the highest load or capacity level reasonably expected to occur.
I further certify that the control device is designed to operate at an efficiency of 95 weight percent or
greater.
OR
I further certify that the total organic emission limits of 40 CFR 264.1032(a) for affected process vents at
the facility can be attained by a control device involving vapor recovery at an efficiency less than 95
weight percent.
(Signature) (date) "
3. For equipment leaks, complete Table X.A.3 for all valves, pumps, compressors, pressure relief
devices, sampling connection systems, and open-ended valves or lines that contains or contacts
hazardous waste streams with organic concentrations of 10% by weight or greater.
Equipment in vacuum service is not subject to control if identified in the facility operating record.
8If the permittee has received a RCRA permit prior to 12/21/90, these requirements for process vents and
equipment may be provided in the permit renewal application.
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-97
-------
4. For equipment, include the following statement as part of the air emissions report:
"I, owner or operator certify that the operating parameters used in the design analysis reasonably
represent the conditions that exist when the hazardous waste management unit is operating at the highest
load or capacity level reasonably expected to occur.
I further certify that the control device is designed to operate at an efficiency of 95 weight percent or
greater.
(Signature) (date) "
B. Optional TNRCC Office of Air Quality Information
In addition to the information requested in Section X.A above, the applicant may optionally elect to combine
the air and waste management permitting, amendment, modification, or renewal of all waste management units
to be permitted in this application and any other permittable air emission sources. The combined permit
application will follow the application processing procedures for an industrial solid waste permit.
1. Area map (to scale) showing the location of the plant and land use in the vicinity of the facility
including buildings, schools, residences, etc. within 3000 feet.
2. Plot plan (to scale) with latitude and longitude showing the plant layout, property boundary and
location of all emission points of air contaminants. Emission points are to be numbered.
3. Specific chemical name of each air contaminant and emission rate in maximum pounds per hour,
maximum tons per year and calculations used to determine emission rates. Fugitive emissions are
to be included. Complete Table l(a) entitled "Emission Sources."
4. Process description, operating schedule, and flow chart in sufficient detail that will explain the
process and operation and a material balance for processes where applicable. The description
should include a discussion of disposal methods for any generated residues and associated air
emissions.
5. Design specifications about each emission control device using the appropriate OAQ table.
6. Volatile organic compound (VOC) concentrations in water or sludges or soil and volumes or
weights of water, sludges or soils to be processed.
7. Exhaust stack or emission point parameters for each emission point including height, diameter,
temperature, velocity and flow rate, except ground level fugitive emissions.
8. Best available control technology (BACT) documentation for all new and modified facilities.
9. Documentation of compliance with any applicable Federal New Source Performance Standard
(NSPS) and Federal National Emission Standard for Hazardous Air Pollutants (NESHAPS).
10. Documentation as to whether a permit is required under new source review requirements of part
C or D or Title I of the Federal Clean Air Act, 42 U.S.C. 7401 et seq., for a major source or major
modification.
11. Information that demonstrates reliability of emission control systems including process
instrumentation, equipment redundancy and operating procedures.
12. Results of atmospheric dispersion modeling certified to have been conducted in accordance with
applicable TNRCC Office of Air Quality (OAQ) procedures. Model results must show maximum
off-property 30-minute and annual ground level concentrations of each air contaminant.
Dispersion modeling results must indicate compliance with all OAQ Rules and Regulations.
Dimensions of buildings/structures that may influence dispersion modeling are to be furnished.
Please consult with OAQ before beginning any modeling study.
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-98
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13. Storage tank data including capacity in gallons, diameter, height, paint color, composition, density,
vapor pressure and molecular weight of liquid stored, maximum hourly and annual throughput and
number of turnovers per year. Complete Table 7 entitled "Storage Tank Summary" for each tank.
14. A statement addressing the applicability of each OAQ regulation.
15. All methods of calculating emissions must be properly referenced with justification for selecting
the values used in any equation.
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-99
-------
TABLE X.A.1 Process Vents
List all process vents covered by this application.
I.D. No.
(if any)
Process Vent
Annual Throughput
Operating Hours
Total Vent Facility Emissions
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97)
3-A-100
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TABLE X.A.3 Equipment Leaks
List all equipment covered by this application
Equipment
I.D. No.
Equipment Type
Waste
Management
Unit N.O.R. No.
Waste Management
Unit Name
% by Weight Total
Organics in Haz.
Waste Stream
Waste State
(gas, vapor,
liquid)
Method of Compliance
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97)
3-A-101
-------
TABLE l(a)
EMISSION SOURCES
PAGE OF _
DATE
Review of applications and issuance of permits will be expedited by supplying all necessary information requested on this Table
AIR CONTAMINANT DATA EMISSION POINT DISCHARGE PARAMETERS
EMISSION POINT
[1
NUMBER
NAME
CHEMICAL COMPOSITION
OF TOTAL STREAM
COMPONENT OR AIR
CONTAMINANT NAME
[21
CONC.
(%v)
[31
AIR CONTAMINANT
EMISSION RATE
#/HR
[4]
TONS/
YR
[51
UTM COORDINATES
OF EMISSION PT. 6]
ZONE
EAST
[meters]
NORTH
STACK SOURCES (7)
HEIGHT
ABOVE
GROUND
[ft.]
HEIGHT
ABOVE
STRUCT.
[ft.]
EXIT DATA
DIA.
[ft.]
VEL.
[fps]
TEMP.
[•F]
AREA
SOURCES [8]
LENGTH
[ft.]
WIDTH
[ft.]
GROUND ELEVATION OF FACILITY ABOVE MEAN SEA LEVEL
TACB STANDARD CONDITIONS ARE 68- F AND 14 7 PSIA [RULE 131 01 00 001(55)]
feet
General Instructions:
Identify each emission point with a unique number for this plant site, consistent with emission point identification used on plot plan, previous permits and Emissions Inventory Questionnaire Limit emission point number to 8 character spaces For each emission point, use as many lines as necessary to list
air contaminant data Typical emission point names are : heater, vent, boiler, tank, reactor, separator, baghouse, fugitive, etc Abbreviations are OK
Typical component names are: air, H2O, nitrogen, oxygen, CO2 CO, NOK, SO2, hexane, particulate matter (PM), etc Abbreviations are OK
Concentration data is required for all gaseous components Show concentration in volume percent of total gas stream
Pounds per hour (#/HR) is maximum emission rate expected by applicant
Tons per year (T/Y) is annual maximum emission rate expected by applicant which takes into account process operating schedule
As a minimum, applicant must furnish a facility plot plan drawn to scale showing a plant benchmark, latitude and longitude correct to the nearest second for the benchmark, and all emission points dimensioned with respect to the benchmark as required by General Application, Form PI-1 This information
is essential for calculation of emission point UTM coordinates Please show emission point UTM coordinates if known
Supply additional information as follows if appropriate:
A Stack exit configuration other than a round vertical stack Show length and width for a rectangular stack Indicate if horizontal discharge with a note
B Stack's height above supporting or adjacent structures if structure is within three (3) "stack heights above ground" of stack
C If emission pint is a flare, show flare data on Table 8
Normally used for fugitive sources Show dimensions of a minimum size rectangle which will "enclose" all fugitive sources included in this emission point number
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97)
3-A-102
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TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-103
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TABLE 7
STORAGE TANK SUMMARY
4-82
I. Applicant's Name:
II.
Tank Parameters (one form for each tank).
1. Location (indicate on plot plan or provide coordinates):
2. Tank No. 3.
4. Nominal Capacity :
5. Dimensions: Diameter
_ barrels or
_ft. Height or Length
Aluminum [ ]
Emission Point No.
gallons
ft.
Light grey or blue [
Other [ ] (Describe
Relocation [ ]
)
6. Color: Chalking white [ ]
Dark color or not paint [ ]
7. Status: New tank [] Altered tank [] Relocation [] Change of Service []
Previous permit or exemption number
8. Type: Fixed roof [] Pressure [] Insulated [] External floating roof []
Open top [ ] Underground [ ] Internal floating roof [ ] Horizontal [ ]
Heated/Cooled [ ] (Temp. • F)
9. For floating roof tanks, please supply the following information:
a. Type of roof: Double deck [ ] Pontoon [ ] Other [ ] (Describe
b. Roof color: Chalking white [] Aluminum [] Other [] (Describe )
c. Shell construction: Riveted [ ] Welded [ ] Other [ ] (Describe
d. Seals:
Primary: Mechanical Shoe [ ] Liquid-Mounted [ ] Vapor-Mounted [ ]
Other [ ] (Describe )
Secondary: Shoe-Mounted [ ] Rim-Mounted [ ] Weather Shield [ ] None [ ]
Other [ ] (Describe_ )
10. Vent Valve
Data
Number
Pressure Setting
Vacuum
Setting
Discharging To:
(Specify "atmosphere" or
name abatement device)
Combination vent
valve
Pressure vent
valve
Vacuum vent
valve
Open vent
III. Properties of Stored Material (If tank is to hold several different materials or mixtures, attach appropriate information)
1. Material to be stored in this tank:
Liquid density at average annual bulk storage temperature:
Average vapor molecular weight
_lbs/gal or
•API
Vapor pressure @ average annual bulk storage temperature: psia @
Vapor pressure @ maximum bulk storage temperature: psia @
Initial boiling point: • F.
If material stored is a solution, please supply the following information:
a. Name of solvent: b. Partial pressure of solvent:
c. Name of solute: d. Partial pressure of solute: _
e. Concentration of solute: wt% or vol% or
• F. (or Ibs. Reid).
•F.
_psia.
_psia.
Ibs/gal.
IV. Operating Data:
1. Maximum filling rate:
bbls/hr or
gal/hr.
ft.
2. Average outage (average distance from top of tank shell to liquid surface):
3. Tank turnovers per year: (Use zero (0) for constant-level tanks).
* NOT APPLICABLE
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97)
3-A-104
-------
XI. HAZARDOUS WASTE PERMIT APPLICATION FEE
In accordance with 30 TAG 305.53, complete Tables XI-1 and XI-2. Use the following information in calculating your
fee. The application fee will be non-refundable once an initial review of the application has been completed. The
applicant's fees are subject to evaluation by the technical staff of the Texas Natural Resource Conservation
Commission (TNRCC). However, the TNRCC reserves the right to assess further fees as may be necessary.
A. The minimum permit application fee for a permit or a permit renewal for each hazardous waste facility to be used
for Storage, Processing, Disposal, or Closure/Post-Closure Care (disposal has already occurred) of hazardous waste
shall be $2,000, plus notice fee and the maximum shall be $50,000, calculated according to these instructions:
1. Process Analysis - $1,000.00.
2. Management/Facility Analysis - $500.00.
3. A facility unit(s) analysis of $500 per unit is charged for the following:
a. each cell of a landfill (note that multiple cells that are identical in type and use are subject to a single
$500 fee);
b. tanks and container storage areas (note that multiple tanks and container storage areas that are
identical in type and use are subject to a single $500 fee)
c. identical in type and use means the following:
(1) made of the same material and same design;
(2) the same size/capacity within + 10%;
(3) store the same waste (as identified by USEPA hazardous waste number - 40 CFR 261 Subparts
C & D); and
(4) have the same management characteristics (e.g., storage only).
4. Site Evaluation - $100 per acre of surface used for hazardous waste management up to 300 acres. No
additional fee thereafter. This shall be calculated as any acreage which will be permitted to manage
hazardous waste. This shall include, for example, the entire area within the secondary containment of a
tank farm, the area within a fence that surrounds individual units (other than the facility fence), or the area
defined by the toe of the dike surrounding a landfill or impoundment, etc.
5. An applicant shall also include with each initial application a fee of $50 to be applied toward the cost of
providing the required notice. An additional notice fee of $15 is required with each application for
renewal.
B. The application fee for a major amendment or a Class 2 or 3 modification to a hazardous waste permit for
operation, closure, or post-closure care is subject to the fees listed below:
1. If a unit is added or a unit area is expanded for any purpose, $100 per additional acre is assessed, until the
total additional acreage reaches 300 acres.
2. If one or more of the following reports are added or are significantly revised, the process analysis fee of
$1000 is assessed:
a. waste analysis plan;
b. site-specific or regional geology report;
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-105
-------
c. site-specific or regional geohydrology report;
d. ground-water and/or unsaturated zone monitoring;
e. closure and/or post-closure care plan; or
f. RCRA Facility Investigations (RFIs), or corrective action reports.
3. A unit analysis fee of $500 per unit is assessed if any of the following occur:
a. if a unit is added (even if identical to units already in place, using the criteria discussed in A. 3
above);
b. if there are design changes in an existing unit; or
c. if a unit status changes from closure to post-closure care.
4. A management/facility fee of $500.
5. The notice fee is $50.
XI. C. The application fee for a minor amendment, a Class 1, or a Class 1' modification of a hazardous waste permit
is $100 plus a notice fee of $50.
TNRCC Part B Application
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TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-107
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TABLE XI-1 HAZARDOUS WASTE UNITS (FOR APPLICATION FEE CALCULATIONS)
Verbal Description of Unit
Rated Capacity
Surface Acreage1
TOTAL4
# of Unit Types2
TOTAL4
Identical Unit Justification3
1 Number of calculated acres
2 Enter number of units except for units identical in type and use which only count toward a single $500 00 fee
3 Explain justification for any units claimed as identical in type and use
4 Enter these totals on the worksheet
TNRCC Part B Application
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3-A-108
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TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-109
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TABLE XI-2 HAZARDOUS WASTE PERMIT APPLICATION FEE WORKSHEET
Name of Applicant:
Solid Waste Registration Number:
1. Process Analysis-$1,000 $_
2.Facility Management Analysis - $500$_
S.Unit Analysis9 - units @ $500 per unit$_
4. Site Evaluation9 - acres @ $100 per acre $
(Maximum of 300 acres)
5.Minor amendment, Class 1, or Class I1 modification - $100$_
6.Cost of Providing Notice - $50 (+ $15 for a renewal)$
PAY THIS AMOUNT TOTAL $
MAKE CHECKS PAYABLE TO:
Texas Natural Resource Conservation Commission - Fund 549
(your canceled check will be your receipt)
COMPLETE AND RETURN WITH PAYMENT TO:
Texas Natural Resource Conservation Commission
Financial Administration Division - MC 214
P.O. BOX 13087
Austin, Texas 78711-3087
The applicant's fees are subject to evaluation by the technical staff of the Texas Natural Resource
Conservation Commission (TNRCC). However, the TNRCC reserves the right to assess further fees as
may be necessitated.
9For these calculations, enter the totals from Table XI-1.
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-110
-------
XII.CONFIDENTIAL MATERIAL
Any information requested in the previous Sections I.-X. of this application which is deemed confidential shall
be provided in this Section as a separate collective document and clearly labeled "CONFIDENTIAL."
TNRCC Part B Application
TNRCC-0376 (Rev 3/11/97) 3-A-lll
-------
ATTACHMENT B
CHECKLIST FOR FEDERAL REVIEW OF
RCRA PERMIT APPLICATIONS
(161 Sheets)
-------
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION A. PART A GENERAL INFORMATION REQUIREMENTS
Section and
Requirement
A-l Description of Activities Conducted
which Require Facility to Obtain a
Permit under the Resource
Conservation and Recovery Act
(RCRA), and Brief Description of
Nature of the Business
A-2 Name, Mailing Address, and Location
of Facility for which the Application is
Submitted, including a Topographic
Map
A-3 Up to Four Standard Industrial
Classification Codes which Best
Reflect the Products or Services
Provided by the Facility
A-4 Operator/Owner's Name, Address,
Telephone Number, and Ownership
Status
A-5 Facility is New, Existing, or Located on
Indian Lands
A-6 Description of Processes to be Used
for Treating, Storing, and Disposing of
Hazardous Waste
A-7 Specification of the Hazardous Wastes
Listed or Designated Under 261
Federal
Regulation
270.13(a),(m)
270.13(b),(l)
270.13(c)
270.13(d),(e)
270.13(f),(g)
270.13(i)
270.13(j)
Review
Consideration"
Ownership status must include status as federal,
state, private, public, or other entity.
Description must include information on whether
this is a first or revised application with date of
last signed permit application.
Description must include design capacity for
these items.
Specifications must include estimate on quantity
of waste to be treated, stored, or disposed of.
Location in
Application15
See Attached
Comment
Number0
SECTA.WPD
5-B-l
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION A. PART A GENERAL INFORMATION REQUIREMENTS
Section and
Requirement
A-8 Listing of all Permits or Construction
Approvals Received or Applied for
Federal
Regulation
270.13(k)
Review
Consideration"
Permits include the following programs:
Hazardous Waste Management under RCRA;
Underground Injection Control under the Solid
Waste Disposal Act; Prevention of Significant
Deterioration, Nonattainment Program, and
National Emissions Standards for Hazardous
Pollutants under the Clean Air Act; ocean
dumping permits under the Marine Protection
Research and Sanctuaries Act; dredge and fill
permits under Section 404 of the Clean Water
Act; or other relevant environmental permits
including state permits.
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTA.WPD
5-B-2
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION B. FACILITY DESCRIPTION
Section and
Requirement
B-l General Description
B-2 Topographic Map
B-2a General Requirements
Scale and Date
The 100-Year Flood Plain Area
Surface Waters
Surrounding Land Use
Wind Rose
Map Orientation
Legal Boundaries
Access Control
Injection and Withdrawal Wells (On
Site and Off Site)
Buildings and Other Structures
Drainage and Flood Control Barriers
Location of the Treatment or Disposal
Unit(s) and Decontamination Areas
Location of Solid Waste Management
Units
Federal
Regulation
270.14(b)(l)
270.14
270.14(b)(19)
270.14(b)(19)(i)
270.14(b)(19)(ii)
270.14(b)(19)(iii)
270.14(b)(19)(iv)
270.14(b)(19)(v)
270.14(b)(19)(vi)
270.14(b)(19)(vii
)
270.14(b)(19)(viii
)
270.14(b)(19)(ix)
270.14(b)(19)(x)
270.14(b)(19)(xi)
270.14(b)(19)(xii
)
270.14(d)(l)(i)
Review
Consideration"
Show a distance of 1,000 feet around the
unit at a scale of 1 inch to not more than 200
feet (multiple maps may be submitted at this
scale), and should be similar to Part A
topographic map.
Other scales may be used if justified.
270.14(b)(19)(x) for example list.
Location in
Application15
See Attached
Comment
Number0
SECTB.WPD
3-B-3
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION B. FACILITY DESCRIPTION
Section and
Requirement
B-2b Additional Information on the
Topographic Map for Land Disposal
Facilities
Uppermost Aquifer and Hydraulically
Connected Aquifers Beneath Facility
Property
Groundwater Flow Direction
Waste Management Areas
Property Boundaries
Point of Compliance Location
Location of Groundwater Monitoring
Wells
Extent of any Groundwater
Contaminant Plume
B-3 Facility Location Information
B-3a Seismic Requirements
Political Jurisdiction in which Facility
is Proposed to be Located
Indication of Whether Facility is
Listed in Appendix VI of 264 (New
Facilities)
New Facility must be Located at
Least 200 feet from a Fault which has
had Displacement in Holocene Time
Federal
Regulation
270.14(c)(3)
270.14(c)(2)
270.14(c)(2)
270.14(c)(3)
270.14(c)(3)
270.14(c)(3);
264.95
270.14(c)(3);
264.97
270.14(c)(4)(i)
270.14(b)(ll);
264.18
270.14(b)(ll)(i),
(ii);264.18(a)
270.14(b)(ll)(i)
270.14(b)(ll)(i)
270.14(b)(ll)(ii);
264.18(a)
Review
Consideration"
Point of compliance is defined in 264.95.
Seismic requirements applicable only to new
facilities.
If facility location is listed in Appendix VI of
264, this information is required.
Location in
Application15
See Attached
Comment
Number0
SECTB.WPD
3-B-4
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION B. FACILITY DESCRIPTION
Section and
Requirement
B-3b Flood Plain Requirements
Copy of Federal Insurance
Administration or other Flood Map
B-3b(l) Demonstration that Facility is
Designed, Constructed, Operated,
and Maintained to Prevent Washout,
or Detailed Description of Procedures
to be Followed to Remove Hazardous
Waste to Safety before Facility is
Flooded
B-3b(l)(a) Engineering Analysis to Indicate the
Various Hydrodynamic and
Hydrostatic Forces Expected to
Result from the 100-Year Flood Plain
Demonstration that no Adverse
Effects will Result from Failure to
Remove Waste by Providing:
Volume and Physical and Chemical
Characteristics of the Waste in the
Facility
Concentration of Hazardous
Constituents that Would Potentially
Affect Surface Waters as a Result of
Washout
Impact of such Concentration on
Current or Potential uses of, and
Water Quality Standards Established
for, the Affected Surface Waters
Federal
Regulation
270.14(b)(ll)(iii)
,(iv);264.18(b)
270.14(b)(ll)(iii)
270.14(b)(ll)(iv)
264.18(b)
270.14(b)(ll)(iv)
; 264.18(b)
270.14(b)(ll)(iv)
;264.18(b)(ii)
270.14(b)(ll)(iv)
;264.18(b)(ii)(A)
270.14(b)(ll)(iv)
;264.18(b)(ii)(B)
270.14(b)(ll)(iv)
;264.18(b)(ii)(C)
Review
Consideration"
Reference source used to determine whether
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain.
Location in
Application15
See Attached
Comment
Number0
SECTB.WPD
3-B-5
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION B. FACILITY DESCRIPTION
Section and
Requirement
Impact of Hazardous Constituents on
the Sediments of Affected Surface
Waters, or the Soils of the 100-Year
Flood Plain, that could Result from
Washout
Plan and Schedule for Future
Compliance
B-4 Traffic Patterns
Estimate of Number and Types of
Vehicles around the Facility
Traffic Control Signs and Signals
Road Surface Composition and Load-
Bearing Capacity
Federal
Regulation
270.14(b)(ll)(iv)
;264.18(b)(ii)(D)
270.14(b)(ll)(v)
270.14(b)(10)
270.14(b)(10)
270.14(b)(10)
270.14(b)(10)
Review
Consideration"
Flood plain requirements applicable if
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain and
not in compliance with 264.18(b).
Show turns across traffic lanes and stacking
lanes, if appropriate.
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTB.WPD
3-B-6
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION C. WASTE CHARACTERISTICS
Section and
Requirement
C-l Chemical and Physical Analyses
C-la Containerized Waste
C-lb Waste in Tank Systems
C-lc Waste in Piles
C-ld Landfilled Wastes
C-le Wastes Incinerated and Wastes used
in Performance Tests
C-lf Wastes to be Land Treated
C-lg Wastes in Miscellaneous Treatment
Units
C-lh Wastes in Boilers and Industrial
Furnaces
C-li Wastes on Drip Pads
Federal
Regulation
270.14(b)(2);
264.13(a)
270.15(b)(l);
264.172
270.16(a);
264.190(a);
264.1 91 (b)(2);
264.192(a)(2)
270.18(a);
264.250(c)(l),
(4)
270.21(a)
264.13(c)(3);
264.314
270.19(c);
270.62(b);
264.341
270.20(b)(4);
264.271(a)(l), (2);
264.272; 264.276,
Part 261 Appendix
VIII
270.23(d)
270.66(c);
266.102(b)
270.26; 264.570
Review
Consideration"
Data generated by testing the waste,
published data on the waste, or data
gathered from similar processes may be
used.
Demonstrate that waste is compatible with
container construction materials.
Demonstrate that tank construction
materials are compatible with waste stored
in tank.
Demonstrate that sorbent materials are
non-biodegradable.
If food-chain crops will be grown in or on
treatment zone, identify hazardous
constituents reasonably expected to be in
or derived from waste.
Location in
Application15
See Attached
Comment
Number0
SECTC.WPD
5-B-7
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION C. WASTE CHARACTERISTICS
Section and
Requirement
C-2 Waste Analysis Plan
C-2a Parameters and Rationale
C-2b Test Methods
C-2c Sampling Methods
C-2d Frequency of Analyses
C-2e Additional Requirements for Wastes
Generated Off Site
C-2f Additional Requirements for
Ignitable, Reactive, or Incompatible
Wastes
C-2g Additional Requirements Pertaining
to BIF Facilities
C-2h Additional Requirements Pertaining
to Containment Buildings
C-3 Waste Analysis Requirements
Pertaining to Land Disposal
Restrictions
Federal
Regulation
270.14(b)(3);
264.13(b),(c)
270.14(b)(3);
264.13(b)(l)
270.14(b)(3);
264.13(b)(2)
270.14(b)(3);
264.13(b)(3)
270.14(b)(3);
264.13(b)(4)
270.14(b)(3);
264.13(b)(5),(c);
264.73(b)
270.14(b)(3);
264.13(b)(6);
264.17
270.22;
266.102(e)(6)(ii)
(C),(e)(6)(m)
270.14(b)(3)
264.1100
270.14(b)(3);
264.13; 264.73;
Part 268
Review
Consideration"
If a sampling method described in 261
Appendix I is not used, facility must
provide detailed description of proposed
method and demonstrate its equivalency.
Describe statistical method used to
determine a representative sample of
incoming waste.
Location in
Application15
See Attached
Comment
Number0
SECTC.WPD
Reviewer:
j-rJ-c
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION C. WASTE CHARACTERISTICS
Section and
Requirement
C-3a Waste Analysis
C-3a(l) Spent Solvent and Dioxin Wastes
C-3a(2) California List Wastes
C-3a(3) Listed Wastes
C-3a(4) Characteristic Wastes
C-3a(5) Radioactive Mixed Waste
Federal
Regulation
270.14(a);
264.13(a)(l);
268.1; 268.7;
268.9; 268.32 -
268.37; 268.41 -
268.43
270.14(a);
264.13(a)(l);
268.2(f)(l); 268.7;
268.30; 268.31
270.14(a);
264.13(a)(l);
268.7; 268.32;
268.42(a); RCRA
Section 3004(d)
270.14(a);
264.13(a)(l);
268.7; 268.33 -
268.36; 268.41 -
268.43
270.14(a);
264.13(a)(l);
268.7, 268.9;
268.37; Part 268
Appendix I, IX
270.14(a);
264. 13(a); 268.7;
268.35(c),(d);
268.36(d);
268.42(d)
Review
Consideration"
Waste that was newly identified or newly
listed as hazardous after 11/08/84 for
which the U.S. Environmental Protection
Agency has not promulgated land disposal
prohibitions or treatment standards are not
subject to land disposal provisions.
Arsenic-containing nonwastewater may
use the extraction procedure (EP) toxicity
test to determine compliance with
treatment standards.
Characteristic D008 lead nonwastewater
and D004 arsenic nonwastewater may use
EP toxicity test to determine compliance
with treatment standards.
Hazardous debris containing radioactive
waste must comply with treatment
standards specified in 268.45.
Location in
Application15
See Attached
Comment
Number0
SECTC.WPD
5-B-9
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION C. WASTE CHARACTERISTICS
Section and
Requirement
C-3a(6) Leachates
C-3a(7) Lab Packs
C-3a(8) Contaminated Debris
C-3a(9) Waste Mixtures and Wastes with
Overlapping Requirements
C-3a(10) Dilution and Aggregation of Wastes
C-3b Notification, Certification, and
Recordkeeping Requirements
C-3b(l) Retention of Generator Notices and
Certifications
C-3b(2) Notification and Certification
Requirements for Treatment Facilities
C-3b(3) Notification and Certification
Requirements for Land Disposal
Facilities
Federal
Regulation
270.14(a);
264.13(a);
268.35(a)
270.14(a);
264.13(a);
268.7(a)(7),(8);
268.42(c); Part 268
Appendix IV
270.13(n);
268.2(g); 268.7;
268.9; 268.36;
268.45
270.14(a);
264.13(a)(l);
268.7; 268.9;
268.41; 268.43;
268.45(a)
270. 14(a); 268.3
270.14(a);264.13;
264.73; 268.7;
268.9(d)
270.14(a);264.13;
268.7(a)
270.14(a);264.13;
268.7(b)
270.14(a);264.13;
268.7(c)(l)
Review
Consideration"
Leachate that originates from newly
identified waste is not coded as F039
waste, but is labeled with newly listed
waste code from which it is derived.
Lab packs containing California list
poly chlorinated biphenyls (PCB) or
dioxins must be treated according to
special incineration requirements detailed
in 268.42(a).
Waste that carries more than one
characteristic or listed waste code must be
treated to the most stringent treatment
requirement for each hazardous waste
constituent of concern.
Location in
Application15
See Attached
Comment
Number0
SECTC.WPD
3-B-10
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION C. WASTE CHARACTERISTICS
Section and
Requirement
C-3b(4) Wastes Shipped to Subtitle C
Facilities
C-3b(5) Wastes Shipped to Subtitle D
Facilities
C-3b(6) Recyclable Materials
C-3b(7) Recordkeeping
C-3c Requirement Pertaining to the Storage
of Restricted Wastes
C-3c(l) Restricted Wastes Stored in
Containers
C-3c(2) Restricted Wastes Stored in Tanks
C-3c(3) Storage of Liquid PCB Wastes
C-3d Exemptions, Extensions, and
Variances to Land Disposal
Restrictions
C-3d(l) Case-by-Case Extensions to an
Effective Date
C-3d(2) Exemption from Prohibition
C-3d(3) Variance from a Treatment Standard
Federal
Regulation
270.14(a);264.13;
268.7(a),(b)(6)
270.14(a);264.13;
268.7(d); 268.9(d)
270.14(a);264.13;
268.7(b)(7)
270.14(a);264.13;
264.73; 268.7(a)
(5),(a)(6),(a)(7),
(d)
270. 14(a); 264.73;
268.50
270. 14(a); 264.73;
268.50(a)(2)(i)
270. 14(a); 264.73;
268.50(a)(2)(ii)
270. 14(a); 264.73;
268.50(f)
270.14(b)(21);
268.5
270.14(b)(21);
268.6
270. 14(a); 264.73;
268.7; 268.44
Review
Consideration"
Recycling facilities must keep records of
name and location of each entity receiving
hazardous waste-derived product.
Location in
Application15
See Attached
Comment
Number0
SECTC.WPD
3-B-ll
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION C. WASTE CHARACTERISTICS
Section and
Requirement
C-3d(4) Requirements for Surface
Impoundments Exempted from Land
Disposal Restrictions
C-3d(4)(a) Exemption for Newly Identified or
Listed Wastes
C-3d(4)(b) Treatment of Wastes
C-3d(4)(c) Sampling and Testing
C-3d(4)(d) Annual Removal of Residues
C-3d(4)(e) Design Requirements
Federal
Regulation
270.14(a);
264.13(b)(7);
268.4; 268.14
270.14(a);264.13;
268.14
270.14(a);264.13;
268.4(a)(l),(b)
270.14(a);
264.13(b)(6);
268.4(a)(2)(i),(iv)
270.14(a);
264.13(b)(7)(iii);
268.4(a)(2)(ii)
270.14(a);264.13;
268.4(a)(3),(4)
Review
Consideration"
If owner/operator continues to treat newly
listed or characteristic hazardous waste
after 48 months from promulgation of new
waste listing or characteristic, surface
impoundment must be in compliance with
268.4.
Location in
Application15
See Attached
Comment
Number0
Notes:
a Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the information in the
application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTC.WPD
3-B-12
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - CONTAINERS
Section and
Requirement
D-l Containers
D-la Containers with Free Liquids
D-la(l) Description of Containers
D-la(2) Container Management Practices
D-la(3) Secondary Containment System
Design and Operation
D-la(3)(a) Requirement for the Base or Liner
to Contain Liquids
D-la(3)(b) Containment System Drainage
D-la(3)(c) Containment System Capacity
D-la(3)(d) Control of Runon
D-la(3)(e) Removal of Liquids from
Containment System
D-lb Containers without Free Liquids
Federal
Regulation
270.15; 264.170
270.15;
264.175(a),(b)
270.14(b)(l);
264.171,172
270.14(a);
264.173
270.15(a)(l);
264.175(a),(d)
270.15;
264.175(b)(l)
270.15(a)(2);
264.175(b)(2)
270.15(a)(3);
264.175(b)(3)
270.15(a)(4);
264.175(b)(4)
270.15(a)(5);
264.175(b)(5)
Review
Consideration"
Containers storing waste with free liquids must
meet secondary containment requirements of
264.175(b).
Specify numbers of containers, sizes, and
specifications.
Containers must be kept closed and must not be
handled in any manner which could cause them
to rupture or leak. Specify aisle space and
stacking height.
Provide detailed design and profile drawings
showing container storage areas.
Demonstrate that base is impervious to waste
stored and precipitation.
Containment system must be designed and
operated to remove liquids resulting from leaks,
spills, or precipitation.
Containment system must have capacity to hold
10 percent of container volume or volume of the
largest container, whichever is greater.
Runon from storm water must be prevented
unless containment system has sufficient excess
capacity.
Accumulated liquids must be removed in timely
manner to prevent containment system from
overflowing.
Location in
Application15
See Attached
Comment
Number0
Dl CONT.WPD
3-B-13
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - CONTAINERS
Section and
Requirement
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
Federal
Regulation
270.15(b)(l)
270.14(a);
264.171; 264.172
270.14(a);
264.173
270.15(b)(2);
264.175(c)
Review
Consideration"
Documentation that waste does not contain free
liquids must be provided by test results or other
information.
Describe numbers, sizes, and specifications of
containers.
Same comment as D-la(2).
Same comment as D-la(3)(b).
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
Dl CONT.WPD
3-B-14
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - TANKS
Section and
Requirement
D-2 Tank Systems
D-2a Tank Systems Descriptions
D-2a(l) Dimensions and Capacity of
each Tank
D-2a(2) Description of Feed Systems,
Safety Cutoff, Bypass Systems,
and Pressure Controls
D-2a(3) Diagram of Piping,
Instrumentation, and Process
Flow
D-2a(4) Ignitable, Reactive, and
Incompatible Wastes
D-2b Existing Tank Systems
D-2b(l) Assessment of Existing Tank
System's Integrity
D-2c New Tank System
D-2c(l) Assessment of New Tank
System's Integrity
D-2c(2) Description of Tank System
Installation and Testing Plans
and Procedures
Federal
Regulation
270.16; 264.191 -
194
270.14(b)(l)
270.16(b)
270.16(c);
264.194(b)
270.16(d)
270. 160);
264.17(b);
264.198,199
270.16(a);264.191
270.16(a),(e);
264.192(a)
270.16(f);
264.192(b)-(e)
Review
Consideration"
Describe type (aboveground, underground)
and specific location of each tank.
Demonstrate that waste is stored or treated in ;
way that protects against ignition or reaction.
A written tank assessment must be certified b}
an independent, qualified, registered
professional engineer.
A written tank assessment must be certified b}
an independent, qualified, registered
professional engineer.
A new tank installation must be inspected by
an independent, qualified, installation
inspector or registered professional engineer.
Location in
Application15
See Attached
Comment
Number0
D2 TANKS.WPD
3-B-15
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - TANKS
Section and
Requirement
D-2d Containment and Detection of
Releases
D-2d(l) Plans and Description of the
Design, Construction, and
Operation of the Secondary
Containment System
D-2d(l)(a) Tank Age Determination
D-2d(l)(b) Requirements for Secondary
Containment and Leak
Detection
D-2d(l)(c) Requirements for External
Liner, Vault, Double-walled
Tank or Equivalent Device
D-2d(l)(d) Secondary Containment and
Leak Detection Requirements
for Ancillary Equipment
D-2d(l)(e) Containment Buildings Used as
Secondary Containment for
Tank Systems
D-2d(2) Requirements for Tank Systems
until Secondary Containment is
Implemented
Federal
Regulation
270.16(g);264.193
270.16(g);
264.1 93 (b)-(f)
270.16(g);
264.193(a)
270.16(g);
264.193(b),(c);
264.1101(b)(3)(iii)
270.16(g);
264.193(d),(e)
270.16(g);
264.193(f)
270.16(g);
264.1101(b)(3)(iii)
270.16(h);
264.193(i)
Review
Consideration"
Leak detection system must be capable of
detecting leaks within 24 hours.
Age of each tank must be accurately
determined to ascertain when secondary
containment requirements apply.
A detailed description of the construction,
installation, and operation of the secondary
containment system is required.
Secondary containment must consist of liner,
vault, double-walled tank, or equivalent
device approved by regional administrator.
Secondary containment is required for
ancillary equipment except as provided in
264.193(f).
A containment building can serve as
secondary containment for a tank system
provided it meets requirements of
264.193(b),(c)(l&2),(d)(l).
Annual leak tests are required until secondary
containment is provided.
Location in
Application15
See Attached
Comment
Number0
D2 TANKS.WPD
3-B-16
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - TANKS
Section and
Requirement
D-2d(3) Variance from Secondary
Containment Requirements
D-2d(3)(a) Variance Based on a
Demonstration of Equivalent
Protection of Groundwater and
Surface Water
D-2d(3)(b) Variance Based on a
Demonstration of No Substantia
Present or Potential Hazard
D-2d(3)(c) Exemption Based on No Free
Liquids and Location Inside a
Building
D-2e Controls and Practices to
Prevent Spills and Overflows
Federal
Regulation
270.16(h);
264.193(g)
270.16(h)(l);
264.193(g)(l),(h)
270.16(h)(2);
264.193(g)(2),(h)
270.16(h);
264.190(a)
270.16(1);
264.194(a),(b);
264.195
Review
Consideration"
Detailed plans and engineering and
hydrogeologic reports are required to
demonstrate equivalent protection of
groundwater and surface water.
Provide detailed assessment of substantial
present or potential hazards posed to human
health or the environment, should a release
enter the environment.
Demonstrate that tanks used to treat or store
hazardous waste contain no free liquid as
defined by Paint Filter Test (SW-846 Method
9095).
Provide detailed description of controls and
practices used to prevent spills and overflows.
Location in
Application15
See Attached
Comment
Number0
D2 TANKS.WPD
3-B-17
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.: Facility Name:
Notes:
a Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
c If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
D2 TANKS.WPD Reviewer:
3 -B -18 Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
D-3 Waste Piles
D-3a List of Wastes
D-3b Liner Exemption
D-3b(l) Enclosed Dry Piles
D-3b(l)(a) Protection from Precipitation
D-3b(l)(b) Free Liquids
D-3b(l)(c) Runon Protection
D-3b(l)(d) Wind Dispersal Control
D-3b(l)(e) Leachate Generation
D-3b(2) Exemption for Monofills
Federal
Regulation
270.18; 264.250-
259
270.18(a)
270.18(b)
270.18(b);
264.250(c)
270.18(b);
264.250(c)
270.18(b);
264.250(c)(l)
270.18(b);
264.250(c)(2)
270.18(b);
264.250(c)(3)
270.18(b);
264.250(c)(4)
270.18(b);
264.25 l(e)
Review
Consideration"
List all hazardous waste to be placed in
waste piles.
Demonstrate that neither runoff, nor leachate
is generated from the pile.
Demonstrate that pile is inside or under
structure that provides complete protection
from precipitation.
Demonstrate that neither liquids, nor
materials containing free liquids are placed
in the pile.
Demonstrate that pile is protected from
surface water runon.
Demonstrate that pile design and operation
controls wind dispersal of waste.
Demonstrate that pile will not generate
leachate through decomposition or other
reactions.
This exemption applies only to waste
generated from foundry furnace emission
controls or metal casting molding sand that
are not hazardous waste for reasons other
than toxicitv characteristics.
Location in
Application15
See Attached
Comment
Number0
D3 WP.WPD
3-B-19
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
D-3b(3)
Alternate Design/No Migration
270.18(c)(l);
264.25 l(b)
This exemption from liner requirements is
based on documenting that design, operating
practices, and local aspects will prevent
migration of hazardous constituents into
ground-water or surface water in the future.
D-3b(4) Exemption Based on Alternative
Design and Location
270.18(c)(l);
264.25l(d)
Document that alternative design and
operating practices, together with location
characteristics, will prevent migration of
any hazardous constituent into groundwater
or surface water at least as effectively as a
double liner with leachate detection system,
and will allow detection of hazardous
constituents through the top liner as least as
effectively.
D-3b(5) Exemption for Replacement
Waste Piles
270.18(c);
264.251(f)
Demonstrate (1) that existing unit was
constructed in compliance with design
standards of Sections 3004(o)(l)(A)(i) and
3004(o)(5) of Resource Conservation and
Recovery Act, and (2) there is no reason to
believe that liner is not functioning as
designed.
D-3c
Liner System
270.18(c)(l);
264.251(a)(l)(i),(c)
Describe liner system and demonstrate that
flow of liquids through liner will be
prevented.
D-3c(l)
Liner Description
270.18(c)(l);
264.251(a)(l)(i),(c)
Describe and draw liner system to
demonstrate that any flow of liquids through
the liner will be prevented.
D-3c(l)(a) Synthetic Liners
270.18(c)(l);
264.251(a)(l),(c)
Describe type, thickness, material, and brand
name and manufacturer of liner.
D3 WP.WPD
3-B-20
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
D-3c(l)(b) Soil Liner
D-3c(2) Liner Location Relative to High
Water Table
D-3c(3) Calculation of Required Soil
Liner Thickness
D-3c(4) Liner Strength Requirements
D-3c(5) Liner Strength Demonstration
D-3c(6) Liner/Waste Compatibility
Testing Results
D-3c(7) Liner Installation
D-3c(7)(a) Synthetic Liner Seaming
Federal
Regulation
270.18(c)(l);
264.251(a),(c)(l)(i)
(B)
270.18(c)(l);
264.251(a)(l)(i)
270.18(c)(l);
264.25 l(a)(l)(i)
270.18(c)(l);
264.25 l(a)(l)(i)
270.18(c)(l);
264.251(a)(l)(i)
270.18(c)(l);
264.251(a)(l)(i)
270.18(c)(l);
264.251(a)(l)(i)
270.18(c)(l);
264.251(a)(l)(i)
Review
Consideration"
Describe bottom composite liner including
its classification, thickness, and hydraulic
conductivity.
Provide data showing seasonal fluctuations
in depth to water table and the location of
seasonal high water table in relation to liner
system.
Calculations using either numerical
simulation techniques (unsaturated flow
conditions) or Darcy Law-derived transit
time equations (saturated flow conditions)
must be provided.
Provide calculations showing minimum
strength requirements for liners considering
pressure gradients, installation and operating
stresses, and climatic change stresses.
Demonstrate that liner exceeds minimum
strength requirements.
Demonstrate that liner material is compatible
with both waste and leachate.
Describe procedures for installing liner.
Describe techniques to be used to bond
membrane liner seams and the strength and
chemical compatibility of seams with waste
and leachate.
Location in
Application15
See Attached
Comment
Number0
D3 WP.WPD
3-B-21
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
D-3c(7)(b) Soil Liner Compaction
D-3c(7)(c) Installation Inspection/testing
Programs
D-3c(8) Liner Coverage
D-3c(9) Liner Exposure Prevention
D-3c(10) Synthetic Liner Bedding
D-3d Liner Foundation Report
D-3d(l) Liner Foundation Design
Description
D-3d(2) Subsurface Exploration Data
D-3d(3) Laboratory Testing Data
D-3d(4) Engineering Analyses
Federal
Regulation
270.18(c)(l);
264.251(a)(l)(i)
270.18(c)(l);
264.254(a)
270.18(c)(l);
264.25 l(a)(l)(iii)
270.18(c)(l);
264.251(a)(l)(i)
270.18(c)(l);
264.251(a)(l)(i)
270.18(c)(l);
264.251(a)(l)(ii)
270.18(c)(l);
264.251(a)(l)(ii)
270.18(c)(l);
264.251(a)(l)(ii)
270.18(c)(l);
264.25 HaKlKii)
Review
Consideration"
Describe procedures for installing soil liner
and compacting liner to achieve desired
permeability. Include maximum height of
lifts to be placed.
Describe quality assurance/quality control
procedures to be used during liner
installation.
Demonstrate that liner will be installed to
cover all surrounding earth likely to be in
contact with waste or leachate.
Demonstrate that either the liner is protected
from, or is resistant to, exposure to climatic
conditions.
Demonstrate that sufficient bedding will be
provided above and below liner to prevent
rupture during installation and operation.
Describe liner foundation design and
materials of construction and ability to
withstand expected static and dynamic
loadings.
Verify engineering characteristics of
foundation materials through subsurface
exploration.
Location in
Application15
See Attached
Comment
Number0
D3 WP.WPD
3-B-22
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
D-3d(4)(a) Settlement Potential
D-3d(4)(b) Bearing Capacity and Stability
D-3d(4)(c) Potential for Bottom Heave or
Blow-Out
D-3d(4)(d) Construction and Operational
Loading
D-3d(5) Foundation Installation
Procedures
D-3d(6) Foundation Installation
Inspection Program
D-3e Leachate Collection and
Removal System
D-3e(l) Upper Leachate Collection and
Removal System
D-3e(2) Leachate Detection System
D-3e(2)(a) Grading and Drainage
Federal
Regulation
270.18(c)(l);
264.251(a)(l)(ii)
270.18(c)(l);
264.251(a)(l)(ii)
270.18(c)(l);
264.251(a)(l)(ii)
270.18(c)(l);
264.25 l(a)(l)(ii)
270.18(c)(l);
264.25 l(a)(l)(ii)
270.18(c)(l);
264.25 l(a)(l)(ii)
270.18(c);
264.25 l(a)(2),(c)
(2)
270.18(c)(l);
264.25 l(a)(2),(c)
(2)
270.18(c)(l);
264.25 l(a)(2),(c)
(3)
270.18(c)(l);
264.25 l(a)(2);
264.221(c¥2Kn)
Review
Consideration"
Describe quality assurance/quality control
procedures to be used during foundation
installation.
Describe design and operation of system to
collect and remove leachate from new
portions of existing waste piles and from
new waste piles.
Describe design and operating conditions to
ensure that leachate depth over the liner
does not exceed 1 foot.
Describe design and operating features of
leachate detection system.
Demonstrate that leak detection system
design meets or exceeds specifications
described in referenced regulations.
Location in
Application15
See Attached
Comment
Number0
D3 WP.WPD
3-B-23
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
D-3e(3)
Chemical Resistance
270.18(c);
264.25 l(a)(2)(i)(A)
264.251(c)(3)
Demonstrate that all leachate collection and
removal system components are chemically
resistant to waste managed in the pile and
the leachate expected to be generated.
D-3e(4)
Strength of Materials
270.18(c);
264.25 l(a)(2)(i)(B);
264.25 l(c)(3)
Demonstrate that system components are of
sufficient strength and thickness to prevent
collapse under expected static and dynamic
loadings.
D-3e(5)
Prevention of Clogging
270.18(c);
264.25 l(a)(2)(n);
264.251(c)(3)
Demonstrate that leachate collection and
removal system's design and operation will
prevent clogging throughout active life and
post-closure period of waste pile.
D-3e(6)
Installation
270.18(c);
264.25 l(a)(2)
Describe installation methods and
construction quality assurance/quality
control procedures.
D-3e(7)
Maintenance
270.18(c);
264.25 l(a)(2)
Describe anticipated maintenance activities
that will be used to assure proper leachate
management system operation throughout
pile's expected active life.
D-3e(8)
Liquid Removal
270.18(c);
264.251(c)(3)
Describe leachate removal system, including
sumps and other equipment, and fate of the
collected leachate.
D-3e(9)
Location Relative to Water Table
270.18(c);
264.25 l(c)(4)
Demonstrate that operation of leak detection
system will not be adversely affected by
presence of groundwater.
D-3f
Action Leakage Rate
270.18(c)(l)(v);
264.252
Action leakage rate must be approved by
regional administrator based on system
design.
D3 WP.WPD
3-B-24
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
D-3f(l) Determination of Action
Leakage Rate
D-3f(2) Monitoring of Leakage
D-3g Leakage Response Action Plan
D-3g(l) Response Action
D-3g(2) Leak and/or Remedial
Determinations
Federal
Regulation
270.18(c)(l)(v);
264.252(a)
270.18(c)(l)(v);
264.252(b)
270.18(c)(l)(v);
264.253
270.18(c)(l)(v);
264.253(a)
270.18(c)(l)(v);
264.253(b),(c)
Review
Consideration"
Determine action leakage rate for waste pile
units subject to 264.25 l(c),(d). Include
adequate safety margin to allow for
uncertainties in design, construction,
operation, and location of leak detection
system, waste and leachate characteristics,
sources of other liquids in system, and
proposed response actions.
Weekly leachate flow rate data must be
converted to average daily flow rate.
Provide response action plan to describe
actions to be taken if flow rate into leak
detection system exceeds action leakage
rate.
Response action plan must describe actions
to be taken to comply with 264.223(b),(c) if
the action leakage rate is exceeded.
Location in
Application15
See Attached
Comment
Number0
D3 WP.WPD
3-B-25
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
D-3g(3) Notifications
D-3h Runon Control System
D-3h(l) Calculation of Peak Flow
D-3h(2) Design and Performance
D-3h(3) Construction
D-3h(4) Maintenance
Federal
Regulation
270.18(c)(l)(v);
264.253(b)
270.18(c)(2);
264.25 l(g)
270.18(c)(2);
264.25 l(g)
270.18(c)(2);
264.25 l(g)
270.18(c)(2);
264.25 l(g)
270.18(c)(2);
264.25 l(g)
Review
Consideration"
Response action plan must indicate that
regional administrator will be (1) notified in
writing within 7 days of determining that
action leakage rate has been exceeded, (2)
provided with preliminary assessment and
action plan within 14 days of initial
determination that action leakage rate has
been exceeded, and (3) provided with status
report within 30 days after original
notification that action leakage rate has been
exceeded. Regional administrator must
receive monthly status reports for as long as
flow rate exceeds action leakage rate.
Describe system that will be used to prevent
runon into active portions of piles.
Identify peak surface water flow expected to
result from 25-year design storm. Describe
data sources and methods used to make
peak flow calculation.
Demonstrate that runon control system
design will prevent runon from reaching
active portions of unit.
Describe runon control system construction
methods and any construction quality
assurance/qualify control procedures.
Describe any maintenance activities required
to assure continued proper runon system
operation throughout unit's active life.
Location in
Application15
See Attached
Comment
Number0
D3 WP.WPD
3-B-26
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
D-3i Runoff Control System
D-3i(l) Calculation of Peak Flow
D-3i(2) Design and Performance
D-3i(3) Construction
D-3i(4) Maintenance
D-3j Management of Collection and
Holding Units
D-3k Control of Wind Dispersal
D-31 Groundwater Monitoring
Exemption
D-31(l) Engineered Structure
Federal
Regulation
270.18(c)(3);
264.25 l(h)
270.18(c)(3);
264.25 l(h)
270.18(c)(3);
264.25 l(h)
270.18(c)(3);
264.25 l(h)
270.18(c)(3);
264.25 l(h)
270.18(c)(4);
264.25 l(i)
270.18(c)(5);
264.251(0
270.18(b);
264.90(b)(2)
270.18(b);
264.90(b)(2)(i)
Review
Consideration"
Describe the runoff control system to be
used to collect and control runoff from
active portions.
Identify the total runoff volume expected to
result from a 24-hour, 25-year storm, and
include data sources and methods used to
make peak flow calculation.
Demonstrate that system has sufficient
capacity to collect and hold total runoff
volume calculated in D-3i(l).
Describe runoff system construction
methods and any construction quality
assurance/qualify control procedures.
Describe any maintenance activities required
to assure continued proper runoff system
operation throughout unit's active life.
Describe how collection and holding
facilities will be managed to maintain system
design capacity.
Describe how pile is covered or otherwise
managed to control wind dispersal.
To receive exemption from groundwater
monitoring requirements of Subpart F,
conditions specified in D-31(l) through D-
31(7) must be met.
Provide design data showing that unit is
engineered structure.
Location in
Application15
See Attached
Comment
Number0
D3 WP.WPD
3-B-27
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
D-31(2) No Liquid Wastes
D-31(3) Exclusion of Liquids
D-31(4) Containment System
D-31(5) Leak Detection System
D-31(6) Operation of Leak Detection
System
D-3(7) No Migration
D-3m Treatment Within the Pile
D-3m(l) Treatment Process Description
D-3m(2) Equipment Used
Federal
Regulation
270.18(b);
264.90(b)(2)(ii)
270.18(b);
264.90(b)(2)(iii)
270.18(b);
264.90(b)(2)(iv)
270.18(b);
264.90(b)(2)(v)
270.18(b);
264.90(b)(2)(vi)
270.18(b);
264.90(b)(2)(vii)
270.18(e)
270.18(e)
270.18(e)
Review
Consideration"
Describe procedures for ensuring that no
liquid waste or waste containing free liquids
will be received by, or contained in, unit.
Demonstrate how liquids, precipitation, and
other runon and runoff will be excluded
from unit.
Describe containment system (both inner
and outer layers) that will enclose waste.
Describe design and operating data
demonstrating leak detection system built
into each containment layer.
Demonstrate means for ensuring continuing
operation and maintenance of leak detection
systems during active life of unit and closure
and post-closure care periods.
Demonstrate to reasonable degree of
certainty that unit will not allow hazardous
constituents to migrate beyond outer layer of
containment system prior to end of post-
closure care period.
If any treatment is conducted in pile, provide
descriptions specified in D-3m(l) through
D-3m(3).
Describe the process by which wastes are
treated and the effect of the treatment on the
wastes.
Describe any equipment or other materials
required to initiate or promote treatment.
Location in
Application15
See Attached
Comment
Number0
D3 WP.WPD
3-B-28
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - WASTE PILES
Section and
Requirement
D-3m(3) Residuals Description
D-3n Special Waste Management Plan
for Piles Containing Wastes
F020, F021, F022, F023, F026,
and F027
D-3n(l) Waste Description
D-3n(2) Soil Description
D-3n(3) Mobilizing Properties
D-3n(4) Additional Management
Techniques
D-3o Construction Quality Assurance
Program
Federal
Regulation
270.18(e)
270. 18(i); 264.259
270.18(i)(l);
264.259(a)(l)
270.18(i)(2);
264.259(a)(2)
270.18(i)(3);
264.259(a)(3)
270.18(i)(4);
264.259(a)(4)
270.18(c)(iv);
264.19
Review
Consideration"
Describe nature and quantity of waste
remaining in pile after treatment is complete.
If waste pile is not enclosed, provide plan
describing how pile will be designed,
constructed, operated, and maintained in
order to protect human health and
environment.
Identify volume, physical, and chemical
characteristics of waste, including potential
to migrate through soil or volatilize or
escape into atmosphere.
Describe attenuative properties of
underlying and surrounding soils or other
materials.
Describe mobilizing properties of other
materials codisposed of with this waste.
Document effectiveness of additional
treatment, design, operating, or monitoring
techniques.
Provide written construction quality
assurance program to comply with
regulations found in 264.19.
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
D3 WP.WPD
3-B-29
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - SURFACE IMPOUNDMENTS
Section and
Requirement
D-4 Surface Impoundments
D-4a List of Wastes
D-4b Liner System Exemption Requests
D-4b(l) Exemption Based on Existing
Portion
D-4b(2) Exemption Based on Alternative
Design and Location
D-4b(3) Exemption for Replacement
Surface Impoundments
D-4c Liner System, General Items
D-4c(l) Liner System Description
D-4c(2) Liner System Location Relative to
High Water Table
Federal
Regulation
270.17(a)
270.17(b)
270.17(b)(l);
264.221(c)
270.17(b)(l);
264.221(d)
270.17(b);
264.221(f)
270.17(b)(l)
270.17(b)(l)
270.17(b)(l),
(3); 264.221(a)
Review
Consideration"
Provide list of all hazardous waste placed, or
to be placed, in surface impoundments.
Existing portions of surface impoundments
with waste in place on November 8, 1994, and
having only vertical expansion are exempted
from liner system requirements. New units,
lateral expansion of existing units, and
replacement units at existing facilities are not
exempt. Provide plan indicating limits of
existing portions.
Provides discussion of the following items that
apply to liner system as a whole.
Provide detailed description of liner system,
demonstrating that any flow of liquids into and
through liners will be prevented. The liner
system includes liner foundation, bottom
composite liner, leachate detection system, top
synthetic liner, and any protective layer placed
to protect top synthetic liner.
Provide geological cross sections showing
groundwater levels with seasonal fluctuations
and liner foundation elevations.
Location in
Application15
See Attached
Comment
Number0
D4 SI.WPD
3-B-30
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - SURFACE IMPOUNDMENTS
Section and
Requirement
D-4c(3) Load on Liner System
D-4c(4) Liner System Coverage
D-4c(5) Liner System Exposure Prevention
D-4d Liner System Foundation
D-4d(l) Foundation Description
D-4d(2) Subsurface Exploration Data
D-4d(3) Laboratory Testing Data
D-4d(4) Engineering Analyses
Federal
Regulation
270.17(b)(l);
264.221(a)(l),(b
)
270.17(b)(l);
264.221(a)(l),
(b)
270.17(b)(l);
264.221(a)(l),
(b)
270.17(b)(l);
264.221(a)(2)
270.17(b)(l);
264.221(a)(2)
270.17(b)(l);
264.221(a)(2)
270.17(b)(l);
264.221(a)(2)
Review
Consideration"
Provide results of calculations defining
maximum loads or stresses that will be placed
on liner system.
Demonstrate that liner system will be installed
to cover all surrounding earth likely to be in
contact with waste or leachate.
Demonstrate that liner system will not be
exposed to elements, or that if exposed,
exposure will not result in unacceptable
degradation of system.
Describe foundation for liner system,
including materials, and indicate bearing
elevations and any load-bearing embankments
placed to support liner system.
The engineering characteristics of liner system
foundation materials should be verified
through subsurface explorations. Provide
information to fully describe these efforts.
Provide index testing results to classify site
materials and lab test data to evaluate
engineering properties of foundation materials.
Provide references to standard test procedures.
Provide engineering analyses based on
subsurface exploration and laboratory testing
data. Include discussion of methods used,
assumptions, copies of calculations, and
appropriate references.
Location in
Application15
See Attached
Comment
Number0
D4 SI.WPD
3-B-31
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - SURFACE IMPOUNDMENTS
Section and
Requirement
D-4d(4)(a) Settlement Potential
D-4d(4)(b) Bearing Capacity
D-4d(4)(c) Potential for Excess Hydrostatic or
Gas Pressure
D-4e Liner System, Liners
D-4e(l) Synthetic Liners
D-4e(l)(a) Synthetic Liner Compatibility Data
D-4e(l)(b) Synthetic Liner Strength
D-4e(l)(c) Synthetic Liner Bedding
D-4e(2) Soil Liners
Federal
Regulation
270.17(b)(l);
264.221(a)(2)
270.17(b)(l);
264.221 (a)(2)
270.17(b)(l);
264.221(a)(2)
270.17(b)(l);
264.221(a),(c)
270.17(b)(l);
264.221(a)(l)
270.17(b)(l);
264.221(a)(l)
270.17(b)(l);
264.221(a)(2)
270.17(b)(l);
264.221(a);
(c)(l)
Review
Consideration"
Provide estimates of total and differential
settlement of liner system foundation.
Provide analysis of allowable bearing capacity
of liner system foundation.
Provide estimates of potential or bottom heave
or blow-out of liner system or line foundation
due to unequal hydrostatic or gas pressures.
For each synthetic liner in system or under
consideration, provide the following general
information: thickness; type; material; brand
name; and manufacturer.
Provide summary and discussion of test
results and conclusions as to suitability of
synthetic liner based on liner/waste
compatibility testing.
Provide data showing that synthetic liners,
including seams, have sufficient strength after
exposure to waste and waste leachate.
Demonstrate that sufficient bedding will be
provided above and below the synthetic liners
to prevent rupture during installation and
operation. Synthetic membrane of bottom
composite liner should be placed directly on
soil portion.
Describe soil portion of bottom composite
liner, including classification, thickness,
hydraulic conductivity, and material
specifications.
Location in
Application15
See Attached
Comment
Number0
D4 SI.WPD
3-B-32
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - SURFACE IMPOUNDMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
D-4e(2)(a) Material Testing Data
270.17(b)(l);
264.221(c)
Provide complete results for index tests,
laboratory and/or in situ permeability tests,
strength tests, consolidation tests, and shrink-
swell properties of soil liner material. Discuss
potential for dispersion and piping of soil due
to flow of liquid through soil liner layer.
D-4e(2)(b) Soil Liner Compatibility Data
270.17(b)(l);
264.221(a)(l)
Provide complete results of permeability
testing of soil liner material using
representative of leachate from surface
impoundment.
D-4e(2)(c) Soil Liner Strength
270.17(b)(l);
264.221(a)(l)
Demonstrate that soil liner has sufficient
strength to support loads/stresses computed in
item D-4c(3).
D-4f
Liner System, Leachate Detection
System
270.17(b)(l);
264.221(c)(2)
D-4f(l)
Systems Operation and Design
270.17(b)(l);
264.221(c)(2),(4
Describe design features of leachate detection
system and how system will function to detect
any leakage through either liner in timely
manner.
D-4f(2)
Drainage Material
270.17(b)(l);
264.221(c)(2)(ii)
Describe leachate detection system drainage
material.
D-4f(3)
Grading and Drainage
270.17(b)(l);
264.221(c)(2)
Indicate slopes of leachate detection system
and provide contour plan for system along
with plan showing layout and spacing of
piping system and any sumps, pumps, etc.
Demonstrate that leak detection system is
appropriately graded to assure that leakage at
any point in liner system is detected in timely
manner.
D4 SI.WPD
3-B-33
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - SURFACE IMPOUNDMENTS
Section and
Requirement
D-4f(4) System Compatibility
D-4f(5) System Strength
D-4f(5)(a) Stability of Drainage Layers
D-4f(5)(b) Strength of Piping
D-4f(6) Prevention of Clogging
D-4f(7) Liquid Removal
D-4f(8) Location Relative to Water Table
D-4g Liner System, Construction and
Maintenance
D-4g(l) Material Specifications
D-4g(l)(a) Synthetic Liners
Federal
Regulation
270.17(b)(l);
264.221(c)(2)(iii
)
270.17(b)(l);
264.221(c)(2)(iii
)
270.17(b)(l);
264.221(c)(2)(iii
)
270.17(b)(l);
264.221(c)(2)(iv
)
270.17(b)(l);
264.221(c)(2)(v)
, (c)(3)
270.17(b)(3);
264.221(c)(4)
270.17(b)(l);
264.221(a)
270.17(b)(l);
264.221(a)
Review
Consideration"
Demonstrate that drainage layer of leachate
detection system has sufficient soil-bearing
capacity to support loads. Provide
calculations snowing that drainage layer
placed on sloped surfaces of surface
impoundment or foundations will be stable
during construction.
Demonstrate that pipes used in piping systems
have sufficient strength to support loads as
computed in item D-4c(3).
Indicate fate of collected leachate, which is
considered hazardous waste.
Provide detailed material specifications for
specific synthetic liner(s) to be used.
Location in
Application15
See Attached
Comment
Number0
D4 SI.WPD
3-B-34
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - SURFACE IMPOUNDMENTS
Section and
Requirement
D-4g(l)(b) Soil Liners
D-4g(l)(c) Leachate Detection System
D-4g(2) Construction Specifications
D-4g(2)(a) Liner System Foundation
D-4g(2)(b) Soil Liner
D-4g(2)(c) Synthetic Liners
D-4g(2)(d) Leachate Detection System
D-4g(3) Construction Quality Assurance
(CQA) Program
Federal
Regulation
270.17(b)(l);
264.221(a)
270.17(b)(l);
264. 221 (a)
270.17(b)(l);
264.221(a)
270.17(b)(l);
264.221(a),(a)(2
)
270.17(b)(l);
264.221 (a);
264.226(a)(l)
270.17(b)(l);
264.221(a)
270.17(b)(l),(4);
270.30(k)(2);
264.19;
264.226(a)
Review
Consideration"
For soil liners constructed of borrowed
material, provide specifications; for soil liners
using in-place soil, provide specifications to
be used to assure that all existing materials
meet requirements of liner design.
Provide material specifications for drainage
layer material, filter fabric or filter layer,
piping, and sumps.
For installed foundations, provide construction
specifications of foundation installation
procedures. For units that use the in-place
material for liner system foundation, provide
construction specifications for preparation.
Describe procedures for installing soil liner.
Provide construction specifications for
placement of synthetic liners.
Provide construction specifications for
placement of leachate detection system
components, including drainage layers,
piping, filter layers, sumps, pumps, etc.
Provide complete details of CQA program to
be used during construction of liner system to
assure that it is built as designed.
Location in
Application15
See Attached
Comment
Number0
D4 SI.WPD
3-B-35
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - SURFACE IMPOUNDMENTS
Section and
Requirement
D-4g(4) Maintenance Procedures for
Leachate Detection System
D-4g(5) Liner Repairs During Operations
D-4h Action Leakage Rate
D-4h(l) Determination of Action Leakage
Rate
D-4h(2) Monitoring of Leakage
D-4i Leakage Response Action Plan
D-4i(l) Response Action
D-4i(2) Leak and/or Remedial
Determinations
D-4i(3) Notifications
D-4j Prevention of Overtopping
Federal
Regulation
270.17(b)(l);
264.221(a)
270.17(b)(l);
264.221(a)
270.17(b)(5);
264.222
270.17(b)(5);
264.222(a)
270.17(b)(5);
264.222(b)
270.17(b)(5);
264.223
270.17(b)(5);
264.223(a)
270.17(b)(5);
264.223(b),(c)
270.17(b)(5);
264.223(b)
270.17(b)(6);
264.221(g)
Review
Consideration"
Describe anticipated maintenance activities
that will be used to assure proper operation of
leachate detection systems throughout surface
impoundment's expected life.
Describe methods that will be used to repair
any damage to liner that occurs while surface
impoundment is in operation (such as a drag
line ripping the liner during cleaning
operations).
Identify action leakage rate for surface
impoundment units subject to liner system
provisions of 264.221(c) and 264.221(d).
Describe design and/or operating procedures
that will protect against impoundment
overtopping/overflow.
Location in
Application15
See Attached
Comment
Number0
D4 SI.WPD
3-B-36
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - SURFACE IMPOUNDMENTS
Section and
Requirement
D-4j(l) Design Features
D-4j(2) Operating Procedure
D-4j(3) Overtopping Prevention
D-4j(4) Freeboard Requirements
D-4j(5) Outflow Destination
D-4k Dike Stability
D-4k(l) Engineer's Certification
D-4k(2) Dike Design Description
Federal
Regulation
270.17(b)(6);
264.221(g)
270.17(b)(6);
264.221(g)
270.17(b)(6);
264.221(g)
270.17(b);
264.221 (g)
270.17(b);
264.221(g)
270.17(d);
264.226(c)
270.17(b)(7);
264.221 (h)
Review
Consideration"
Describe design features used to prevent
overtopping, such as spillways or weirs for
flow-through systems, automatic or manual
controls, and sensors and alarms.
If operating procedures are instrumental to
preventing overtopping, describe those
procedures.
Unless foolproof controls are used to prevent
overtopping, provide results of calculations
showing that adequate freeboard will be
available following 100-year, 24-hour storm
event.
Freeboard requirements associated with
normal and extreme wind activity should be
determined unless automatic controls are used
and freeboard equals or exceeds 2 feet.
Describe fate of liquids released through flow
control devices. Identify location to which
waste would be moved in event of emergency.
Provide data and/or drawings specifying
design layout of the dikes and their
components, including materials of
construction. Determine capability of dikes to
withstand failure from expected static and
dynamic loadings and effects of erosion.
Location in
Application15
See Attached
Comment
Number0
D4 SI.WPD
3-B-37
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - SURFACE IMPOUNDMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
D-4k(3)
Erosion and Piping Protection
270.17(b);
264.221(h)
Demonstrate that dikes are designed and
constructed to minimize erosion and piping,
and to prevent failure due to excessive
erosion. Describe procedures for correcting
erosion problems identified during unit's
operating life.
D-4k(4)
Subsurface Soil Conditions
270.17(b)(7);
264.221(h)
Engineering characteristics of dike foundation
materials should be verified through testing
and subsurface explorations, as necessary.
These explorations may include: test borings;
test pits or trenches; in situ tests; and
geophysical exploration methods.
D-4k(5)
Stability Analysis
270.17(b);
264.221(h)
Describe stability analyses and results for the
following conditions, as appropriate:
foundation soil bearing failure of settlement;
failure in dike slopes; failure of impoundment
cut slopes; build-up of hydrostatic pressure
due to failure of drainage system, dike cover,
and liner; and rapid drawdown.
D-4k(6) Strength and Compressibility Test
Results
270.17(b);
264.221(h)
Provide results of strength and consolidation
tests on dike materials together with
description of sampling procedures and test
methods.
D-4k(7)
Dike Construction Procedures
270.17(b);
264.221(h)
Describe methods to be used to construct
dikes at new units.
D-4k(8) Dike Construction Inspection
Program
270.17(b);
264.221(h)
Describe inspection, monitoring, sampling and
testing methods, and frequencies to be used
during dike construction to assure that new
dikes meet design requirements.
D4 SI.WPD
3-B-38
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - SURFACE IMPOUNDMENTS
Section and
Requirement
D-41 Special Waste Management Plan for
Surface Impoundments Containing
Wastes F020, F021, F022, F023,
F026, and F027
Federal
Regulation
270.17(1);
264.231 (a)
Review
Consideration"
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
D4 SI.WPD
3-B-39
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - INCINERATORS
Section and
Requirement
D-5 Incinerators
D-5a Justification for Exemption
D-5b Trial Burn
D-5b(l) Trial Burn Plan
D-5b(l)(a) Detailed Engineering
Description of Incinerator
D-5b(l)(b) Sampling and Monitoring
Procedures
D-5b(l)(c) Trial Burn Schedule
D-5b(l)(d) Test Protocols
D-5b(l)(e) Pollution Control Equipment
Operation
D-5b(l)(f) Shutdown Procedures
D-5b(l)(g) Incinerator Performance
Federal
Regulation
270. 19; 264.340;
264.351
270.19(a)
270.19(b)
270.19(b)
270.62(b)(2)(ii)
270.19(c)(2)
270.62(b)(2)(iii)
270.62(b)(2)(iv)
270.62(b)(2)(v)
270.62(b)(2)(vi)
270.62(b)(2)(vii)
270.62(a)
Review
Consideration"
To justify exemption under 264.340(b) or (c),
document the following: (1) waste contains
no, or insignificant, concentrations of Part
261, Appendix VIII materials; and (2) waste
is considered hazardous solely because it is
(a) ignitable and/or corrosive, or (b) reactive.
Submit trial burn plan or results of trial burn,
including all required determinations.
Provide information per regulatory citation.
Also, include process and instrumentation
diagram.
Describe sampling and monitoring
procedures during trial burn per regulatory
citation. Sampling and analysis methods
approved by the U.S. Environmental
Protection Agency (EPA) must be used or,
alternatively, a demonstration of equivalence
with EPA-approved methods must be made.
Location in
Application15
See Attached
Comment
Number0
D5 INC.WPD
3-B-40
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - INCINERATORS
Section and
Requirement
D-5b(2) New Incinerator Conditions
D-5b(2)(a) Startup
D-5b(2)(b) Shakedown
D-5b(2)(c) Post-trial Burn Operation
D-5b(2)(d) Incinerator Performance
D-5c Data Submitted in Lieu of Trial
Burn
D-5c(l) Detailed Engineering
Description of Incinerator
D-5c(2) Expected Incinerator Operation
D-5c(3) Design and Operating
Conditions
D-5c(4) Previous Trial Burn Results
D-5d Determinations
Federal
Regulation
270.62(a)
270.62(a)
264.344(c)(l)
270.62(c)
270.62(a)
270.19(c)
270.19(c)(2)
270.19(c)(6)
270.19(c)(4)
270.19(c)(5)
270.62(b¥7)
Review
Consideration"
Provide information per regulatory citation in
lieu of trial burn plan.
Provide information per regulatory citation.
Also, include process and instrumentation
diagram.
Describe results from all previously
conducted, approved trial burns.
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
D5 INC.WPD
3-B-41
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
D-6 Landfills
D-6a List of Wastes
D-6b(l) Exemption Based on Existing
Portion
D-6b(2) Exemption Based on Alternative
Design and Location
D-6b(3) Exemption for Replacement
Landfill Unit
D-6b(4) Exemption for Monofills
D-6b(5) Groundwater Monitoring
Exemption
D-6b(5)(a) Engineered Structure
D-6b(5)(b) No Liquid Waste
D-6b(5)(c) Exclusion of Liquids
Federal
Regulation
270.21; 264.300-
264.317
270.21(a)
270.21(b)(l);
264. 301 (a)
270.21(b)(l);
264.301(d)
270.21(b)(l);
264.301(f)
270.21(b)(l);
264.301(e)
270.21(c);
264.90(b)(2)
270.21(c);
264.90(b)(2)(i)
270.21(c);
264.90(b)(2)(ii)
270.21(c);
264.90(b)(2)(iii)
Review
Consideration"
Existing portions of landfills that have waste
in place on November 8, 1984, and will
have only vertical expansion are exempted
from liner system requirements. Provide
plan showing limits of existing portion.
If exemption from Subpart F groundwater
monitoring requirements is sought, provide
data demonstrating that the following
conditions are met.
Provide design data showing that unit for
which exemption is sought is an engineered
structure.
Describe procedures for ensuring that no
liquid waste or waste containing free liquids
will be received by, or contained, in the unit.
Provide design and operating data
demonstrating how liquids, precipitation,
and other runon and runoff will be excluded
from the unit.
Location in
Application15
See Attached
Comment
Number0
D6 LNDFI.WPD
3-B-42
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
D-6b(5)(d) Containment System
D-6b(5)(e) Leak Detection System
D-6b(5)(f) Operation of Leak Detection
System
D-6b(5)(g) No Migration
D-6c Liner System, General Items
D-6c(l) Liner System Description
D-6c(2) Liner System Location Relative
to High Water Table
Federal
Regulation
270.21(c);
264.90(b)(2)(iv)
270.21(c);
264.90(b)(2)(v)
270.21(c);
264.90(b)(2)(vi)
270.21(c);
264.90(b)(2)(vii)
270.21(b)(l);
264.301(a),(c)
270.21(b)(l);
264.301(a),(c)
270.21(b)(l);
264.301(a)(l)(i)
Review
Consideration"
Describe containment system (both inner
and outer layers) that will enclose waste.
Describe design and operating data
demonstrating leak detection system built
into each containment layer.
Demonstrate means for ensuring continuing
operation and maintenance of leak detection
systems during active life of unit and closure
and post-closure care periods.
Demonstrate that unit will not allow
hazardous constituents to migrate beyond
outer layer of containment system prior to
end of post-closure care period.
Discuss the items that apply to liner system
as a whole.
Provide detailed description of liner system,
demonstrating that any flow of liquids into
and through liners will be prevented. Liner
system includes liner foundation, bottom
composite liner, leachate detection system,
top synthetic liner, and any protective layer
placed to protect leachate collection system
from damage.
Provide geological cross sections showing
groundwater levels with seasonal
fluctuations and liner foundation elevations.
Location in
Application15
See Attached
Comment
Number0
D6 LNDFI.WPD
3-B-43
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
D-6c(3) Loads on Liner System
D-6c(4) Liner System Coverage
D-6c(5) Liner System Exposure
Prevention
D-6d Liner System, Foundation
D-6d(l) Foundation Description
Federal
Regulation
270.21(b)(l);
264.301(a)(l)(i)
270.21(b)(l);
264.301(a)(l)(iii)
270.21(b)(l);
264.301(a)(l)(i)
270.21(b)(l);
264.301(a)(l)(ii)
Review
Consideration"
Provide results of calculations defining
maximum loads or stresses that will be
placed on liner system considering:
• both static and dynamic loads
• stresses due to installation or
construction
• stresses resulting from operating
equipment
• stresses due to maximum quantity of
waste, cover, and proposed post-
closure land use
• stresses resulting from settlement,
subsidence, or uplift
• internal and external pressure
gradients.
Demonstrate that the liner system will not be
exposed to wind or sunlight or, if exposure
to any part of the system is to be permitted,
that such exposure will not result in
unacceptable degradation of that portion of
the system.
Describe foundation for liner system,
including foundation materials and indicate
bearing elevations on geological and
construction drawings. Indicate any load-
bearing embankments placed to support
liner system.
Location in
Application15
See Attached
Comment
Number0
D6 LNDFI.WPD
3-B-44
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
D-6d(2) Subsurface Exploration Data
D-6d(3) Laboratory Testing Data
D-6d(4) Engineering Analyses
D-6d(4)(a) Settlement Potential
D-6d(4)(b) Bearing Capacity
D-6d(4)(c) Stability of Landfill Slopes
Federal
Regulation
270.21(b)(l);
264.301(a)(l)(ii)
270.21(b)(l);
264.301(a)(l)(ii)
270.21(b)(l);
264.301(a)(l)(ii)
270.21(b)(l);
264.301(a)(l)(ii)
270.21(b)(l);
264.301(a)(l)(ii)
270.21(b)(l);
264.301(a)(l)(ii)
Review
Consideration"
Verify engineering characteristics of liner
system foundation materials through
subsurface explorations. Provide
information to fully describe these efforts.
Provide index testing results to classify site
materials and lab test data to evaluate
engineering properties of foundation
materials. Provide references to standard
test procedures.
Provide engineering analyses based on
subsurface exploration and laboratory
testing data. Include discussion of methods
used, assumptions, copies of calculations,
and appropriate references.
Provide estimates of total and differential
settlement of liner system foundation.
Consider stresses imposed by liner system
and applicable stresses computed in item D-
6c(3).
Provide analysis of allowable bearing
capacity of liner system foundation.
Provide, as appropriate, analyses of stability
of:
• excavated slopes for units constructed
below grade
• embankment slopes for units
constructed with earthen dikes or
berms
• landfill slopes consisting of liner
system or cover system placed on
waste.
Location in
Application15
See Attached
Comment
Number0
D6 LNDFI.WPD
3-B-45
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
D-6d(4)(d) Potential for Excess Hydrostatic
or Gas Pressure
D-6e Liner System, Liners
D-6e(l) Synthetic Liners
D-6e(l)(a) Synthetic Liner Compatibility
Data
D-6e(l)(b) Synthetic Liner Strength
D-6e(l)(c) Synthetic Liner Bedding
D-6e(2) Soil Liners
Federal
Regulation
270.21(b)(l);
264.301(a)(l)(ii)
270.21(b)(l);
264.301(a)(l)(ii),(c
)
270.21(b)(l);
264.301(a)(l)(i)
270.21(b)(l);
264.301(a)(l)(i)
270.21(b)(l);
264.301(a)(l)(ii)
270.21(b)(l);
264.301(a),(c)
Review
Consideration"
Provide estimates of potential for bottom
heave or blow-out of liner system due to
unequal hydrostatic or gas pressures.
For each synthetic liner in system or under
consideration, provide following general
information: thickness; type; material; brand
name; and manufacturer.
Provide summary and discuss test results
and conclusions as to suitability of synthetic
liner based on liner/waste compatibility
testing.
Provide data showing that synthetic liners,
including seams, have sufficient strength
after exposure to waste and waste leachate.
Demonstrate that sufficient bedding will be
provided above and below synthetic liners to
prevent rupture during installation and
operation. Synthetic membrane of bottom
composite liner should be placed directly on
soil portion.
Provide description of soil portion of bottom
composite liner, including its classification,
thickness, hydraulic conductivity, and
material specifications.
Location in
Application15
See Attached
Comment
Number0
D6 LNDFI.WPD
3-B-46
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
D-6e(2)(a) Material Testing Data
270.21(b)(l);
264.301(c)
Provide complete results for index tests,
laboratory and/or in situ permeability tests,
strength tests, consolidation tests, and
shrink-swell properties of soil liner material.
Discuss potential for dispersion and piping
of soil due to flow of liquid through soil
liner layer.
D-6e(2)(b) Soil Liner Compatibility Data
270.21(b)(l);
264.301(a)(l)(i);
264.301(c)(3)(iii)
Provide complete test results of permeability
testing of soil liner material using
representative of leachate from surface
impoundment.
D-6e(2)(c) Soil Liner Strength
270.21(b)(l);
264.301(a)(l)(i);
264.301(c)(3)(iii)
Demonstrate that soil liner has sufficient
strength to support loads/stresses computed
in item D-4c(3).
D-6f
Liner System, Leachate
Collection/Detection Systems
270.21(b)(l);
264.301(a)(2);
264.301(c)(2),(3)
D-6f(l)
System Operation and Design
270.21(b)(l);
264.301(a)(2);
264.301(c)(2),(3)
Describe design features of leachate
detection system and how system will
function to detect any leakage through either
liner in timely manner.
D-6f(2)
Drainage Material
270.21(b)(l);
264.301(a)(2),(c)(3
)
00
Describe leachate detection system drainage
material.
D6 LNDFI.WPD
3-B-47
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
D-6f(3) Grading and Drainage
D-6f(4) Maximum Leachate Head
D-6f(5) Systems Compatibility
D-6f(6) Systems Strength
D-6f(6)(a) Stability of Drainage Layers
D-6f(6)(b) Strength of Piping
D-6f(7) Prevention of Clogging
Federal
Regulation
270.21(b)(l);
264.301(a)(2),(c)(2
),(3)
270.21(b)(l);
264.301(a)(2),(c)(2
)
270.21(b)(l);
264.301(a)(2)(i)(A)
(c)(3)(m)
270.21(b)(l);
264.301(a)(2)(i)(B),
(c)(3)(iii)
270.21(b)(l);
264.301(a)(2)(i)(B),
(c)(3)(iii)
270.21(b)(l);
264.301(a)(2)(i)(B),
(c)(3)(m)
270.21(b)(l);
264.301(a)(2)(ii),
(c)(3)(iv)
Review
Consideration"
Indicate slopes of leachate detection system
and provide contour plan for system along
with plan showing layout and spacing of
piping system and any sumps, pumps, etc.
Demonstrate that leak detection system is
appropriately graded to assure that leakage
at any point in liner system is detected in
timely manner.
Demonstrate that pipe used in piping
systems have sufficient strength to support
loads as computed in item D-6c(3).
Location in
Application15
See Attached
Comment
Number0
D6 LNDFI.WPD
3-B-48
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
D-6f(8) Liquid Removal
D-6f(9) Location Relative to Water
Table
D-6g Liner System, Construction and
Maintenance
D-6g(l) Material Specifications
D-6g(l)(a) Synthetic Liners
D-6g(l)(b) Soil Liners
D-6g(l)(c) Leachate Collection/Detection
Systems
D-6g(2) Construction Specifications
D-6g(2)(a) Liner System Foundation
D-6g(2)(b) Soil Liner
Federal
Regulation
270.21(b)(l);
264.301(c)(3)(v),(4
)
270.21(b)(l)(iii);
264.301(c)(5)
270.21(b)(l);
264.301(a)(l)
270.21(b)(l);
264.301(a)(l)
270.21(b)(l);
264.301(a),(c)
270.21(b)(l);
264.301(a)(l);
264.303(a)
270.21(b)(l);
264.301(a)(l);
264.303(a¥2)
Review
Consideration"
Provide detailed material specifications for
specific synthetic liner or liners to be used.
For soil liners constructed of borrowed
material, provide specifications. For soil
liners using in-place soil, provide
specifications to be used to assure that all
existing materials meet requirements of liner
design.
Provide material specifications for drainage
layer material, filter fabric or filter layer,
piping, and sumps.
Provide construction specifications of
foundation installation procedures. For units
that use in-place material for liner system
foundation, provide construction
specifications for preparation of foundation.
Describe procedures for installing soil liner.
Location in
Application15
See Attached
Comment
Number0
D6 LNDFI.WPD
3-B-49
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
D-6g(2)(c) Synthetic Liners
270.21(b)(l);
264.301(a)(l);
264.303(a)(l)
Provide construction specifications for
placement of synthetic liners.
D-6g(2)(d) Leachate Collection/Detection
Systems
270.31(b)(l);
264.301(a),(c)
Provide construction specifications for
placement of all components of leachate
collection/detection systems.
D-6g(3) Certified Quality Auditor (CQA)
Program
270.21(b)(l);
270.30(k)(2);
264.19;264.303(a)
Provide complete details of CQA program to
be used during construction of liner system
to assure that it is built as designed.
D-6g(4) Maintenance Procedures for
Leachate Collection/Detection
Systems
270.21(b)(l);
264.301(a),(c)
Describe anticipated maintenance activities
that will be used to assure proper operation
of leachate collection/detection systems
throughout landfill's expected life.
D-6g(5)
Liner Repairs During Operations
270.21(b)(l);
264.301 (a)
Describe methods that will be used to repair
any damage to liner that occurs while
landfill is in operation during placement of
waste (such as a dozer ripping the liner).
D-6h
Action Leakage Rate
270.21(b)(l)(v);
264.302
D-6h(l) Determination of the Action
Leakage Rate
270.21(b)(l)(v);
264.302(a)
D-6h(2)
Monitoring the Leakage
270.21(b)(l)(v);
264.302(b)
To determine if action leakage rate has been
exceeded, owner/operator must convert
required leachate flow rate monitoring data
to average daily flow rate for each sump.
This average daily flow rate must be
calculated weekly during active life of
facility and closure period, and monthly
during post-closure care period.
D6 LNDFI.WPD
3-B-50
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
D-6i Leakage Response Action Plan
D-6i(l) Response Actions
D-6i(2) Leak and/or Remedial
Determinations
D-6i(3) Notifications
D-6j Runon and Runoff Control
Systems
D-6j(l) Runon Control System
D-6j(l)(a) Design and Performance
D-6j(l)(b) Calculation of Peak Flow
D-6j(2) Runoff Control System
D-6j(2)(a) Design and Performance
Federal
Regulation
270.21(b)(l)(v);
264.304
270.21(b)(l)(v);
264.304(a)
270.21(b)(l)(v);
264.304(b),(c)
270.21(b)(l)(v);
264.304(b)
270.21(b)(2);
264.301(g)
270.21(b)(2);
264.301(g)
270.21(b)(l);
264.301(g)
270.21(b)(3);
264.301(h)
270.21(b)(3);
264.301(h)
Review
Consideration"
Describe system that will be used to prevent
runon onto active portions of landfills.
Describe runon control system design and
how that design prevents runon from
reaching active portions of site. Provide
plan view.
Identify peak surface water flow expected to
result from 2-year design storm. Provide
copies of calculations and data.
Describe runoff control system to be used to
collect and control runoff from active
portions.
Describe runoff collection and control
system design. Indicate fate of collected
runoff that is considered hazardous waste
until tested and/or treated.
Location in
Application15
See Attached
Comment
Number0
D6 LNDFI.WPD
3-B-51
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
D-6j(2)(b) Calculation of Peak Flow
D-6j(3) Management of Collection and
Holding Units
D-6j(4) Construction
D-6j(5) Maintenance
D-6k Control of Wind Dispersal
D-6L Liquids in Landfills
D-6L(1) Bulk or Noncontainerized Free
Liquids
Federal
Regulation
270.21(b)(3);
264.301(h)
270.21(b)(4);
264.301(i)
270.21(b)(2),(3);
264.301(g),(h)
270.21(b)(2),(3);
264.301(g),(h)
270.21(b)(5);
264.301(0
270.21(h); 264.314
Review
Consideration"
Identify total runoff volume expected to
result from at least a 24-hour, 25-year storm
event. Provide copies of calculations and
data.
Describe how collection and holding
facilities associated with runon and runoff
control systems will be emptied or otherwise
managed expeditiously after storms to
maintain system design capacity. Describe
fate of liquids discharged from these
systems.
Provide detailed construction and material
specifications for runon and runoff control
systems.
Describe any maintenance activities required
to assure continued proper operations of
runon and runoff control systems throughout
active life of unit.
Describe procedures that will be used to
ensure that no bulk or noncontainerized
liquid hazardous waste or waste with free
liquids will be placed in landfill.
Demonstrate, by paint filter test, Method
9095, that no free liquids will be placed in
landfill.
Location in
Application15
See Attached
Comment
Number0
D6 LNDFI.WPD
3-B-52
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
D-6L(2)
Containers Holding Free Liquids
270.21(h);
264.314(d)
For facilities that intend to dispose of
containers holding free liquids, describe how
free liquids will be removed from containers
or stabilized within container before
container is placed in landfill. If liquid is
removed, container must be backfilled or
crushed.
D-6L(3)
Restriction to Small Containers
270.21(h);
264.314(d)(2)
If small containers are to be disposed of in
landfill, demonstrate by indicating container
volume, that containers will be very small
(such as ampules).
D-6L(4)
Nonstorage Containers
270.21(h);
264.314(d)(3)
If nonstorage containers are to be disposed
of in landfill, demonstrate by describing the
containers designed to hold free liquids for
use other than storage (e.g., batteries,
capacitors).
D-6L(5)
Lab Packs
270.21(h);
264.314(d)(4)
Describe how it will be assured that lab
packs to be landfilled containing free liquids
meet requirements for lab packs.
D-6L(5)(a) Inside Containers
270.21(h);
264.314(d)(4);
264.316(a)
D-6L(5)(b) Overpack
270.21(h);
264.314(d)(4);
264.316(b)
Demonstrate that overpacking consists of
metal, Department of Transportation (DOT)
containers, metal DOT containers, with open
heads no larger than 110 gallons; and
sufficient sorbent material determined to be
non-biodegradable to completely sorb all
liquid contents of inside container.
D6 LNDFI.WPD
3-B-53
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LANDFILLS
Section and
Requirement
D-6L(5)(c) Sorbent Material
D-6L(5)(d) Incompatible Wastes
D-6L(5)(e) Reactive Wastes
D-6m Containerized Wastes
D-6n Special Waste Management Plan
for Landfills Containing Wastes
F020, F021, F022, F023, F026,
and F027
D-6n(l) Waste Descriptions
D-6n(2) Soil Description
D-6n(3) Mobilizing Properties
Federal
Regulation
270.21(h);
264.3 14(d)(4),(e)
264.316
270.21(h);
264.3 14(d)(4);
264.316(d)
270.21(h);
264.3 14(d)(4);
264.316(d)
270.21(i); 264.315
270.21(j); 264.317
270.210X1);
264.317(a)(l)
270.21(j)(2);
264.317(a)(2)
270.21(j)(2);
264.317(a)(2)
Review
Consideration"
Demonstrate that sorbent materials used are
no capable of reacting dangerously with,
being decomposed by, or being ignited by
contents of inside containers.
Demonstrate that incompatible waste will not
be placed in same outside containers.
Demonstrate that incompatible waste will not
be placed in same outside containers.
Provide plan for waste management in this
special facility. Plan must address the
following factors.
Identify volume, physical, and chemical
characteristics of waste, including potential
to migrate through soil or volatilize or
escape into atmosphere.
Describe attenuative properties of
underlying and surrounding soils or other
materials.
Describe mobilizing properties of other
materials codisposed of with this waste.
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
D6 LNDFI.WPD
3-B-54
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.: Facility Name:
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
D6 LNDFI.WPD Reviewer:
3 -B - 5 5 Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LAND TREATMENT
Section and
Requirement
D-7 Land Treatment
D-7a Treatment Demonstration
D-7a(l) Demonstration Wastes
D-7a(2) Demonstration Data Sources
D-7a(2)(a) Existing Literature
D-7a(2)(b) Operating Data
D-7a(3) Laboratory /Field Testing
Programs
Federal
Regulation
270.20; 264.270 -
264.283
270.20(a); 264.272
270.20(a)(l);
264.272(a),(c)(l)(i)
270.20(a)(2);
264.272(b)
270.20(a)(2);
264.272(b)
270.20(a)(2);
264.272(b)
270.20(a)(3);
264.272(b),(c)
Review
Consideration"
Describe waste used in demonstration and
waste to be treated during normal
operation. Identify concentrations of all
hazardous constituents reasonably
expected to be present in both wastes.
Describe source of data used for treatment
demonstration and provide available
determinations.
If existing literature is used to demonstrate
treatment, submit brief written review of
scientific literature and previous studies
that contain pertinent information.
Information sources should be properly
referenced. In general, existing literature
will not be acceptable as demonstration
unless it can be shown that site and waste
characteristics are identical to those in
literature.
Provide any operating data gathered from
units to be permitted, including application
rate data and operating records.
Field and laboratory tests to be used for
demonstration must be thoroughly
described. Include interpretive discussions
as appropriate.
Location in
Application15
See Attached
Comment
Number0
D7 LNDFR.WPD
3-B-56
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LAND TREATMENT
Section and
Requirement
D-7a(3)(a) Toxicity Testing
D-7a(3)(b) Field Plot Testing
D-7a(3)(c) Laboratory Testing
D-7b Land Treatment Program
D-7b(l) List of Wastes
D-7b(2) Operating Procedures
D-7b(2)(a) Waste Application Rates
D-7b(2)(b) Waste Application Methods
D-7b(2)(c) Control of Soil pH
Federal
Regulation
270.20(a)(2);
264.272(b)
270.20(a)(2),(3);
264.272(b),(c)
270.20(b)(2),(3);
264.272(b),(c)
270.20(b); 264.271
270.20(b)(l);
264.27 l(b)
270.20(b)(2);
264.273(a)
270.20(b)(2)(i);
264.273(a)(l)
270.20(b)(2)(i);
264.273(a)(l)
270.20(b)(2)(ii);
264.273(a)(2)
Review
Consideration"
Describe acute toxicity test procedures
used to estimate impact of waste
application or waste constituents on soil
biota responsible for waste treatment.
Describe field plot studies used to
demonstrate treatability of waste(s) or
waste constituents.
Describe laboratory test methods used to
demonstrate treatability of waste(s) or
waste constituents.
Describe characteristics and operating
conditions of land treatment unit(s) to be
permitted.
Describe operating procedures used to
assure uniform and complete degradation,
transformation, and immobilization.
Identify rate and frequency of waste
application and concentration of limiting
constituents in waste.
Describe method(s) used to apply and
incorporate waste into treatment zone.
Identify acceptable limits of soil pH and
describe rationale for those limits.
Describe how soil pH will be measured
and adjusted, including a schedule for the
same.
Location in
Application15
See Attached
Comment
Number0
D7 LNDFR.WPD
3-B-57
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LAND TREATMENT
Section and
Requirement
D-7b(2)(d) Enhancement of Microbial or
Chemical Reactions
D-7b(2)(e) Control of Soil Moisture
D-7c Unsaturated Zone Monitoring
Plan
D-7c(l) Soil-Pore Liquid Monitoring
D-7c(l)(a) Sampling Location
D-7c(l)(b) Sampling Frequency
D-7c(l)(c) Sampling Equipment
D-7c(l)(d) Sampling Equipment Installation
D-7c(l)(e) Sampling Procedures
Federal
Regulation
270.20(b)(2)(iii);
264.273(a)(3)
270.20(b)(2)(iv);
264.273(a)(4)
270.20(b)(3);
264.278
270.20(b)(3);
264.278
270.20(b)(3)(ii);
264.278(b), (d)
270.20(b)(3)(i);
264.278(e)
270.20(b)(3)(i);
264.278(e)
270.20(b)(3)(i);
264.278(e)
270.20(b)(3)(i);
264.278(e)(l),(2)
Review
Consideration"
Describe measures used to enhance
treatment, including method and
frequency of such measures (e.g.,
fertilization, microbial inoculations, soil
aeration).
Identify limits on soil moisture content.
Describe how soil moisture will be
monitored and adjusted, if necessary.
Submit unsaturated zone monitoring plan
describing measures used to determine if
hazardous wastes have migrated from
treatment zone.
Describe program for sampling and
analysis of soil-pore liquid to detect
migration of dissolved constituents below
treatment zone.
Identify sampling locations and indicate
that samples will be collected immediately
below treatment zone.
Provide schedule for sampling soil-pore
liquid.
Identify equipment used to obtain soil-
pore liquid samples.
Describe procedures used to install soil-
pore liquid monitoring devices.
Location in
Application15
See Attached
Comment
Number0
D7 LNDFR.WPD
3-B-58
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LAND TREATMENT
Section and
Requirement
D-7c(l)(f) Analytical Procedures
D-7c(l)(g) Chain of Custody
D-7c(l)(h) Background Values
D-7c(l)(i) Statistical Methods
D-7c(l)(j) Justification of Principle
Hazardous Constituents
D-7c(2) Soil Core Monitoring
D-7c(2)(a) Sampling Location
D-7c(2)(b) Sampling Frequency
D-7c(2)(c) Sampling Equipment
Federal
Regulation
270.20(b)(3)(iii);
264.278(e)(3)
270.20(b)(3)(iv);
264.278(e)(4)
270.20(b)(3)(v);
264.278(c)
270.20(b)(3)(vi);
264.278(f)
270.20(b)(3)(vii);
264.278(a)(2)
270.20(b)(3);
264.278
270.20(b)(3)(h);
264.278(b),(d)
270.20(b)(3)(i);
264.278(e)
270.20(b)(3)(i);
264.278(e)
Review
Consideration"
Identify analytical procedures used to
determine concentration of hazardous
constituents in soil-pore liquid samples.
Describe sampling and analytical program
used to establish background soil-pore
liquid concentrations of hazardous
constituents. Provide background data, if
available.
Describe statistical methods that will be
used to determine differences between
background and treatment zone
concentrations of hazardous constituents.
Provide suggested list of 261 Appendix
VIII hazardous constituents to be
monitored for in soil-pore liquids.
Describe program for monitoring soil
cores to detect migration of hazardous
constituents below treatment zone.
Identify sampling locations and indicate
that soil cores will be collected
immediately below treatment zone.
Provide schedule for sampling soil.
Identify equipment used to sample soil
cores.
Location in
Application15
See Attached
Comment
Number0
D7 LNDFR.WPD
3-B-59
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LAND TREATMENT
Section and
Requirement
D-7c(2)(d) Sampling Procedures
D-7c(2)(e) Analytical Procedures
D-7c(2)(f) Chain of Custody
D-7c(2)(g) Background Values
D-7c(2)(h) Statistical Methods
D-7c(2)(i) Justification of Principal
Hazardous Constituents
D-7d Treatment Zone Description
D-7d(l) Horizontal and Vertical
Dimensions
D-7d(2) Soil Survey
D-7d(3) Soil Series Descriptions
Federal
Regulation
270.20(b)(3)(i);
264.278(e)(l),(2)
270.20(b)(3)(iii);
264.278(e)(3)
270.20(b)(3)(iv);
264.278(e)(4)
270.20(b)(3)(v);
264.278(c)
270.20(b)(3)(vi);
264.278(f)
270.20(b)(3)(vii);
264.278(a)(2)
270.20(b)(5);
264.27 l(c)
270.20(b)(5);
264.27 l(c)
270.20(b)(2);
264.272(c)(l)(iv)
270.20(b)(2);
264.272(c¥l¥iv)
Review
Consideration"
Identify analytical methods used to
determine concentration of hazardous
constituents in soil core samples.
Describe sampling and analytical program
used to establish background soil core
concentrations of hazardous constituents.
Provide background data, if available.
Describe statistical methods that will be
used to determine differences between
background and treatment zone
concentrations of hazardous constituents.
Provide suggested list of 261 Appendix
VIII hazardous constituents to be
monitored for in soil core samples.
Identify dimensions of treatment zone.
Provide map or plat plan delineating
horizontal boundaries of treatment zone
and all soil series occurring within
treatment zone.
Submit description of each soil series
identified within treatment zone.
Location in
Application15
See Attached
Comment
Number0
D7 LNDFR.WPD
3-B-60
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LAND TREATMENT
Section and
Requirement
D-7d(4) Soil Sampling Data
D-7d(5) Seasonal High Water Table
D-7e Unit Design, Construction,
Operation, and Maintenance
D-7e(l) Runon Control
D-7e(2) Runoff Control
D-7e(3) Minimizing Hazardous
Constituent Runoff
D-7e(4) Management of Accumulated
Runon and Runoff
D-7e(5) Control of Wind Dispersal
D-7f Food-Chain Crops
D-7f(l) Food-Chain Crop Demonstration
D-7f(l)(a) Demonstration Basis
Federal
Regulation
270.20(b)(2);
264.272(l)(iv)
270.20(b);
264.271(c)(2)
270.20(c); 264.273
270.20(c)(l);
264.273(c)
270.20(c)(l);
264.273(c)
270.20(c)(3);
264.273(b)
270.20(c)(4);
264.273(e)
270.20(c)(6);
264.273(f)
270.20(d); 264.276
270.20(d);
264.276(a)(l)
270.20(d)(l),(2);
264.276(a)(3)(i)
Review
Consideration"
Identify depth to seasonal high water table
and source of that data.
Describe design, construction, operation,
and maintenance of runon, runoff, and
wind dispersal controls.
Submit scale drawing of unit showing any
runon controls used.
Describe runoff collection and control
system.
Describe fate of collected surface water,
including sampling and analysis protocols
for determining contaminant levels.
Demonstrate that there is no substantial
risk to human health or environment
caused by growth of food-chain crops on
unit.
Show that demonstration results will be
representative of unit to be permitted.
Location in
Application15
See Attached
Comment
Number0
D7 LNDFR.WPD
3-B-61
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LAND TREATMENT
Section and
Requirement
D-7f(l)(b) Test Procedures
D-7f(2) Cadmium-Bearing Wastes
D-7f(2)(a) Crops for Human Consumption
D-7f(2)(b) Animal Feed
D-7g Special Waste Management Plan
for Land Treatment Units
Containing Wastes F020, F021,
F022, F023, F026, and F027
D-7g(l) Waste Description
D-7g(2) Soil Description
D-7g(3) Mobilizing Properties
D-7g(4) Additional Management
Techniques
Federal
Regulation
270.20(d)(3);
264.276(a)(3)(ii)
270.20(e);
264.276(b)
270.20(e);
264.276(b)(l)
270.20(e);
264.276(b)(2)
270.20(i); 264.283
270.20(i)(l);
264.283(a)(l)
270.20(i)(2);
264.283(a)(2)
270.20(i)(3);
264.283(a)(3)
270.20(i)(4);
264.283(a)(4)
Review
Consideration"
Describe procedures used in any tests
referenced or conducted.
If crops are to be grown for human
consumption, provide: soil pH; soil pH
controls; cadmium-loading rate; and soil
cation exchange capacity.
If only animal feed is to be grown, provide
soil pH and soil pH controls. Provide
copy of operating plan demonstrating how
animal feed will be distributed to preclude
ingestion by humans, including control of
alternative land use.
Provide plan describing how land
treatment units containing referenced
waste are, or will be, designed,
constructed, operated, and maintained to
protect human health and environment.
Location in
Application15
See Attached
Comment
Number0
D7 LNDFR.WPD
3-B-62
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - LAND TREATMENT
Section and
Requirement
D-7h Incompatible Wastes
Federal
Regulation
270.20(h); 264.282
Review
Consideration"
Indicate that incompatible waste will not
be placed in, or on, the same treatment
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
D7 LNDFR.WPD
3-B-63
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - MISCELLANEOUS TREATMENT
Section and
Requirement
D-8 Miscellaneous Units
D-8a Description of Miscellaneous
Units
D-8b Waste Characterization
D-8c Treatment Effectiveness
D-8d Environmental Performance
Standards for Miscellaneous
Units
D-8d(l) Protection of Groundwater and
Subsurface Environment
Federal
Regulation
270.23; 264.601
270.23(a)
270.23;
264.601(a)(l),
(b)(l),(c)(l)
270.23(d)
270.23(b),(c);
264. 60 Ha)
Review
Consideration"
Identify all miscellaneous units that treat,
store, or dispose of hazardous waste at
facility, but do not fit current definition of
container, tank, surface impoundment, etc.
These units may include:
• geologic repositories
• deactivated missile silos
• thermal treatment units other than
incinerators, boilers, or industrial
furnaces
• units open burning and open
detonating explosive waste
• certain chemical/physical/biological
treatment units.
Provide information on volume and
concentration of waste in order to determine
release potential.
Environmental performance standards must
be established and maintained to protect
human health and environment.
Location in
Application15
See Attached
Comment
Number0
D8 SUBX.WPD
3-B-64
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - MISCELLANEOUS TREATMENT
Section and
Requirement
D-8d(l)(a) Environmental Assessment
D-8d(l)(b) Performance Standards
D-8d(2) Protection of Surface Water,
Wetlands, and Soil Surfaces
D-8d(2)(a) Environmental Assessment
D-8d(2)(b) Performance Standards
D-8d(3) Protection of the Atmosphere
D-8d(3)(a) Environmental Assessment
D-8d(3)(b) Performance Standards
D-8e Monitoring, Analysis,
Inspection, Response, Reporting,
and Corrective Action
Federal
Regulation
270.23(b),(c);
264. 601 (a)
270.23(b); 264.601
270.23(b),(c);
264.601(b)
270.23(b),(c);
264.601(b)
270.23; 264.601
270.23(b),(c);
264.601
270.23(b),(c);
264.601(c)
270.23; 264.601
270.23(a); 264.602
Review
Consideration"
Applicant must conduct assessment of
potential for releases to ground-water or the
subsurface environment. Both saturated and
unsaturated zones must be considered in
evaluating potential for subsurface
migration.
Based on assessments, performance
standards must be developed and
maintained.
Applicant must conduct assessment of
potential for releases to surface water,
wetlands, or soil surface.
Based on assessments, performance
standards must be developed and
maintained.
Applicant must conduct assessment of
potential for release to air.
Based on assessments, performance
standards must be developed and
maintained.
Location in
Application15
See Attached
Comment
Number0
D8 SUBX.WPD
3-B-65
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - MISCELLANEOUS TREATMENT
Section and
Requirement
D-8e(l) Elements of a Monitoring
Program
D-8e(2) Air Monitoring Alternatives
Federal
Regulation
270.23(a); 264.602
270.23(a); 264.602
Review
Consideration"
Monitoring program must include
procedures for sampling, analysis, and
evaluation of data, suitable response
procedures, and a regular inspection
schedule.
For situations in which ambient air
monitoring would be unsafe or impractical,
possible alternatives may include analysis of
waste, emissions measurements, and
periodic monitoring with portable detectors.
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
D8 SUBX.WPD
3-B-66
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - BOILERS/INDUSTRIAL FURNACES
Section and
Requirement
D-9 Boilers and Industrial Furnaces
(BIF)
D-9a Waivers/Exemptions
D-9a(l) Waiver of Destruction and
Removal Efficiency (DRE) Trial
Burn for Boilers
D-9a(2) Low Risk Waste Exemption
D-9a(3) Waiver of Particulate Matter
Standard
D-9a(4) Waiver of Trial Burn for Metals
D-9a(5) Waiver of Trial Burn for
Hydrogen Chloride (HCD/C1,
Federal
Regulation
270.22(a)(2)(i);
266.104(a)(4);
266.110
270.22(a)(2)(i);
266.104(a)(4);
266.110
270.22(a)(2)(ii);
266.104(a)(5);
266.109(a)
270.22(a)(4);
266.109(b)
270.22(a)(3);
266.106(b),(e)
270.22(a)(5);
266.107(b),(e)
Review
Consideration"
If applying for waiver or exemption,
provide information demonstrating
compliance with requirements outlined in
this section.
The DRE standard for a BIF may be waived
provided certain criteria listed in regulatory
citation are met and documented.
The parti culate matter standard of 266.105
and trial burn for particulate matter may be
waived if: the BIF complies with Tier I or
Adjusted Tier I metals feed rate screening
limits under 266.106(b) or (e) and submits
documentation showing conformance with
trial burn waiver under checklist Section D-
9a(4) below; and BIF meets requirements of
low risk waste exemption under checklist
Section D-9a(2) above.
Location in
Application15
See Attached
Comment
Number0
D9 BIF.WPD
3-B-67
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - BOILERS/INDUSTRIAL FURNACES
Section and
Requirement
D-9b Pretrial Burn Requirements for
New BIFs
D-9b(l) Pretrial Burn Requirements for
New BIFs - Organic Emission
Standards
D-9b(2) Pretrial Burn Requirements for
New BIFs - Particle Matter
Emissions Standards
D-9b(3) Pretrial Burn Requirements for
New BIFs - Metal Emissions
Standards
D-9b(4) Pretrial Burn Requirements for
New BIFs - Alternative Metals
Approach
D-9b(5) Pretrial Burn Requirements for
New BIFs - Hydrogen
Chloride/Chlorine Emission
Standards
Federal
Regulation
270.66(b)(l);
266.102(d)(4)(i);
266.102(e)
270.66(b)(l)(i);
266.102(e)(2);
266.104(d),(e)
270.66(b)(l)(i);
266.105
270.66(b)(l)(i);
266.102(e)(4)(i),
(ii); 266. 106
270.66(b);
266.102(e)(4)(iii);
266.106(f)
270.66(b)(l)(i);
266.102(e)(5)(i);
266.107
Review
Consideration"
Time required to bring new BIF to point of
operational readiness for trial burn must be
minimum necessary and cannot exceed 720
hours, or up to 1,440 hours if applicant
shows good cause for requiring an
extension.
For conformance with alternative metals
approach, description of operating
conditions must: describe approach that will
be used to comply; specify how approach
ensures compliance with metals emissions
standards of 266.1 06(c) and (d); specify
how approach can be effectively
implemented and monitored; and provide
such other information as necessary to
ensure that the standards of 266.1 06(c) or
(d) are met.
Location in
Application15
See Attached
Comment
Number0
D9 BIF.WPD
3-B-68
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - BOILERS/INDUSTRIAL FURNACES
Section and
Requirement
D-9b(6) Pretrial Burn Requirements for
New BIFs - Fugitive Emissions
D-9b(7) Pretrial Burn Requirements for
New BIFs - Automatic Waste
Feed Cutoff
D-9b(8) Pretrial Burn Requirements for
New BIFs - Monitoring
Requirements
D-9c Trial Burn Plan Requirements for
All BIFs
D-9d Trial Burn Results
Federal
Regulation
270.66(b)(l)(i);
266.102(e)(7)(i)
270.66(b)(l)(i);
266.102(e)(7)(ii),
(in)
270.66(b)(l)(i);
266.102(e)(8),(10)
270.66(b)(2),(c),
(e);
266.102(d)(4)(ii)
270.22(a)(6);
270.66(d),(f)
Review
Consideration"
Description of operating conditions must
thoroughly describe method by which
fugitive emissions will be controlled.
Results of trial burn, as specified in
regulatory citation, must be submitted
within 90 days of completing trial burn.
The submittal must be certified on behalf of
applicant by signature of a person
authorized to sign a permit application or a
report under 270.11.
Location in
Application15
See Attached
Comment
Number0
D9 BIF.WPD
3-B-69
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - BOILERS/INDUSTRIAL FURNACES
Section and
Requirement
D-9e Post-Trial Burn Requirements for
New BIFs
D-9f Data in Lieu of Trial Burn
D-9g Alternative Hydrocarbons (HC)
Limit for Industrial Furnaces
with Organic Matter in Raw
Materials
Federal
Regulation
270.66(b)(3)(ii);
266.102(d)(4)(iii),(
e)
270.22(a)(6);
270.66(c)(3)
270.22(b);
266.104(f)
Review
Consideration"
Post-trial burn requirements for new BIFs
are the same as pretrial burn requirements
for new BIFs with the following exceptions:
• No documentation of total burn hours
is required; no limit to length of time
for burning.
• Must submit statement identifying
conditions necessary to operate in
compliance.
• Must submit statement specifying that
BIF will stop burning when changes
in combustion properties or feed rates
or BIF design or operating conditions
deviate from approved post-trial burn
period.
A BIF may seek exemption from trial burn
requirements by submitting information
provided by previous compliance testing of
same device, or from compliance testing or
trial or operational burns of similar BIFs
burning similar hazardous waste under
similar conditions.
Location in
Application15
See Attached
Comment
Number0
D9 BIF.WPD
3-B-70
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - BOILERS/INDUSTRIAL FURNACES
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
D-9h
Alternative Metals
Implementation Approach
270.22(c);
266.106(f)
For conformance with an alternative metals
implementation approach, the information
must:
• Describe approach that will be used
to comply.
• Specify how approach ensures
compliance with the metals emissions
standards of 266.106(c) and (d).
• Specify how approach can be
effectively implemented and
monitored.
• Provide such other information as
necessary to ensure that standards are
met.
D-9i
Monitoring Requirements
270.22;
266.102(e)(6),(8)
Various parameters must be continuously
monitored per 266.102(e)(6) while burning
hazardous waste. Data must be maintained
in operating record until closure of facility.
D-9j
Automatic Waste Feed Cutoff
System
270.22(d);
266.102(e)(7)(ii)
All facilities must submit description of
automatic waste feed cutoff system,
including any pre-alarm systems that may
be used.
D-9k
Direct Transfer Standards
270.22(e);266.111;
Part 264 Subparts I
and J
BIFs that directly feed hazardous waste
from a transport vehicle to a BIF without
use of a storage unit must submit a
description of the direct transfer procedures
that will be used, along with other
information as specified in regulatory
citation.
D9 BIF.WPD
3-B-71
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - BOILERS/INDUSTRIAL FURNACES
Section and
Requirement
D-9k(l) Direct Transfer Standards -
Containment System
D-9k(2) Direct Transfer Standards -
Condition of Containers
D-9k(3) Direct Transfer Standards -
Compatibility of Waste with
Container
D-9k(4) Direct Transfer Standards -
Management of Containers
D-9k(5) Direct Transfer Standards -
Special Requirements of
Ignitable or Reactive Waste
D-9k(6) Direct Transfer Standards -
Special Requirements of
Incompatible Wastes
D-9k(7) Direct Transfer Standards -
Closure
D-9k(8) Direct Transfer Standards -
Secondary Containment
Requirements
D-9L Bevill Residues
Federal
Regulation
270.22(e);264.175
270.22(e);264.171
270.22(e);264.172
270.22(e);264.173
270.22(e);264.176
270.22(e);264.177
270.22(e);264.178
270.22(e);
266.111(e)
270.22(f); 266. 112;
Part 266
Appendices VII
Review
Consideration"
In areas where direct transfer vehicles are
located, a complete description of
containment system must be provided.
Provide documentation of location of all
containers holding ignitable/reactive waste.
Provide statement and description of
procedures to ensure compliance with
management standards for incompatible
waste.
Describe how all hazardous waste and
hazardous waste residues will be removed
from containment system at closure.
Owners/operators must submit
documentation demonstrating conformance
with secondary containment requirements
of 265.193(b),(c), and (f) - (h).
Location in
Application15
See Attached
Comment
Number0
D9 BIF.WPD
3-B-72
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.: Facility Name:
Notes:
3 Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
D9 BIF.WPD Reviewer:
3 -B-73 Checklist Revision Date (December 1997)
-------
RCRA ID. No.
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - CONTAINMENT BUILDINGS
Section and
Requirement
D-10 Containment Buildings
D-lOa Containment Building
Description
D-lOa(l) Construction
D-10a(2) Strength Requirements
D-10a(3) Design Requirements for Units
Not Managing Liquids
D-10a(3)(a) Primary Barrier
D-10a(4) Design Requirements for Units
Managing Liquids
D-10a(4)(a) Primary Barrier
Federal
Regulation
270.14(a),(b)
264.1100-
264.1102
270.14(a),(b)
264.1100(a);
264. 11 01 (a)
270.14(a),(b)
264.1100(a);
264. 11 01 (a)
270.14(a),(b)
264.1100(a);
264. 11 01 (a)
270.14(a),(b)
264.1100(b);
264. 11 01 (d)
270.14(a),(b)
264.1100(a),(b);
264.1 101 (a)(4)
270.14(a),(b)
264.1100(c);
264.1101(a)(4),(b)
270.14(a),(b)
264.1100(c)(l);
264.1101(b)m
Review
Consideration"
Provide description of unit, include
dimensions and materials of construction.
Provide results of calculations defining
maximum loads or stresses that will be placed
on containment building system.
Provide detailed description of primary barrier,
and demonstrate that it is sufficiently durable
to withstand movement of personnel, waste,
and handling equipment within unit.
Describe how primary barrier is designed and
constructed to prevent migration of hazardous
constituents into barrier.
Location in
Application15
See Attached
Comment
Number0
D10 CONB.WPD
3-B-74
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - CONTAINMENT BUILDINGS
Section and
Requirement
D-10a(4)(b) Liquid Collection System
D-10a(4)(c) Secondary Containment System
D-10a(4)(c)(i) Leak Detection System
D-10a(4)(C)(ii) Secondary Barrier
D-10a(4)(d) Temporary Variance from
Secondary Containment
Requirements
D-10a(4)(e) Waiver of Secondary
Containment Requirements
D-10a(5) Design of Units Managing Both
Liquids and Nonliquids in the
Same Unit
D- 1 Oa(6) Compatibility of Structure with
Wastes
D-10a(7) Fugitive Dust Emissions
Federal
Regulation
270.14(a),(b)
264.1100(c)(2);
264.1101(b)(3)
270.14(a),(b)
264.1100(c)(3)
270.14(a),(b)
264.1100(c)(3);
264.1101(a),(b)(3)
270.14(a),(b)
264.1100(b)(3);
264.1101(b)(3)
270.14(a),(b)
264.1101(b)(4)
270.14(a),(b)
264.1101(e)
270.14(a),(b)
264. 11 01 (d)
270.14(a),(b)
264.1101(a)(2),
(b)(3)(iii)
270.14(a),(b)
264.1100(d);
264.1101(c)(l)(iv)
; Part 60
Appendix A
Review
Consideration"
Describe in detail liquid collection system that
must be designed and constructed of materials
to minimize accumulation of liquid on primary
barrier.
Describe design and operating features of leak
detection system.
Describe how secondary barrier is designed
and constructed to prevent migration of
hazardous constituents into barrier.
Identify areas of containment building that are
constructed both with and without secondary
containment, if applicable.
Demonstrate that all surfaces in contact with
hazardous waste, collected liquids, or leachate
must be chemically compatible with those
waste.
Location in
Application15
See Attached
Comment
Number0
D10 CONB.WPD
3-B-75
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - CONTAINMENT BUILDINGS
Section and
Requirement
D-10a(8) Structural Integrity
Requirements
D-10a(9) Certification of Design
D-lOb Containment Building
Operations
D-lOb(l) Primary Barrier Integrity
D- 1 Ob(2) Volume of Waste
D- 1 Ob(3) Tracking of Waste Out of Unit
D-10b(4) Liquids Removal
D-10b(5) Management of Incompatible
Wastes
D-10b(6) Management of Liquids and
Nonliquids in the Same Unit
Federal
Regulation
270.14(a),(b)
264.1101(a)(2)
270.14(a),(b)
264.1101(c)(2)
270.14(a),(b)
264. 11 01 (c)
270.14(a),(b)
264.1 101 (b)(2)(ii),
(c)(D(i)
270.14(a),(b)
264.1101(c)(l)(ii)
270.14(a),(b)
264.1100(e);
264.1101(c)(l)(iii)
270.14(a),(b)
264.1101(b)(2)(ii),
(b)(3)
270.14(a),(b)
264.1101(a)(3)
270.14(a),(b)
264.1101(d)(2),(3)
Review
Consideration"
Describe how owner/operator will maintain
level of stored and/or treated hazardous waste
within containment walls of unit so that height
of any containment wall is not exceeded.
Describe sumps and liquid removal methods
for liquids collection and leak detection
systems. Indicate fate of collected liquids and
leachates, which are considered hazardous
waste.
Indicate whether incompatible waste or
treatment reagents will be placed in the unit or
its secondary containment system.
For containment buildings that contain areas
both with and without secondary containment,
describe measures to prevent release of liquids
or wet materials into areas without secondary
containment.
Location in
Application15
See Attached
Comment
Number0
D10 CONB.WPD
3-B-76
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - CONTAINMENT BUILDINGS
Section and
Requirement
D-10b(7) Fugitive Dust Emissions
D- 1 Ob(8) Treatment of Wastes
D-10b(9) Equipment Decontamination
D-lOc Containment Buildings as Tank
Secondary Containment
Federal
Regulation
270.14(a),(b)
264.1100(d);
; Part 60
Appendix A
270.14(a),(b)
270.14(a),(b)
270.14(a),(b)
Review
Consideration"
If treatment of waste is conducted in
containment building, describe how treatment
will be conducted to prevent release of liquids,
wet materials, or liquid aerosols to other
portions of building.
Identify area used to decontaminate equipment
and collect and manage any rinsate from
decontamination. Identify fate of
decontamination residues.
Indicate whether containment building is
intended to serve as a secondary containment
system for a tank placed in the building. The
unit must meet the requirements of
264.193(b), 264.193(c)(l), 264.193(c)(2), and
264.193(d)(l).
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
D10 CONB.WPD
3-B-77
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - DRIP PADS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
D-ll
Drip Pads
270.26; 264.570
.575
D-lla
Drip Pad Description
270.26(c);
264.573(a)
D-lla(l) Construction
270.26(c);
264.573(a)(l) -
(4);264.573(b)(l)
(3)
Provide a description of the unit including
dimensions and materials of construction.
Drip pads must: be constructed of
nonearthen materials; be sloped to free-drain
treated wood drippage, rain and other waters
or wastes to the associated collection system;
and, have a curb or berm around the
perimeter.
D-l la(l)(a) Existing Drip Pads
270.26(c);
264.572(a);
264.573(a)(4)
Existing drip pads must have a hydraulic
conductivity of less than or equal to IxlO"7
centimeters per second. Provide a copy of
the most recent written assessment of the drip
pad. This assessment must be reviewed and
certified by an independent, qualified
registered professional engineer (PE). The
assessment must be reviewed, updated and
recertified annually.
D-lla(l)(b) New Drip Pads
270.26(c);
264.572(b);
264.573(b)
New drip pads must have a synthetic liner
installed below the pad. The liner must be
constructed of materials that will prevent
waste from being absorbed into the liner. A
leakage detection system and a leakage
collection system are also required.
D-llb(l) Preventive Maintenance
270.26(c);
264.573(c)
Drip pads must be maintained to remain free
of cracks, gaps, corrosion, etc., that could
cause a release of hazardous waste.
Dl 1 DP.WPD3 b-a-f.wpd
3-B-78
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION D. PROCESS INFORMATION - DRIP PADS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
D-11 b(2) Prevent Runon and Runoff
270.26(c);
264.573(d), (e), (L)
The drip pad and associated collection system
must be operated to prevent runoff. Unless
protected by a structure, the runon and runoff
control systems must have the capacity to
prevent flow onto the drip pad from a 24-
hour, 25-year storm. All collection systems
must be emptied as soon as possible after
storms to maintain design capacity.
D-llb(3)
Certification
270.26(c);
264.573(g)
Provide certification from a qualified,
registered PE stating the drip pad meets the
requirements of section 264.573.
D-llb(4) Maintaining Collection System
270.26(c);
264.573(h)
Provide plan for removal of drippage and
accumulated precipitation from collection
system as necessary to prevent overflow.
D-l lb(5) Cleaning Drip Pad Surface
270.26(c);
264.573(i),(j)
Drip pad surface must be cleaned
appropriately to allow weekly inspection of
the entire surface and to minimize tracking of
hazardous waste or hazardous waste
constituents off the drip pad.
D-11b(6) Recordkeeping
270.26(c);
264.573(k)
Maintain records sufficient to document that
all treated wood is held on the pad following
treatment in accordance with the
requirements of this section.
Dl 1 DP.WPD3 b-a-f.wpd
3-B-79
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.: Facility Name:
Notes:
3 Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
Dll_DP.WPD3_b-a-f.wpd Reviewer:
3 -B - 8 0 Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION E. GROUNDWATER MONITORING
Section and
Requirement
E-l Exemption from Groundwater
Protection Requirements
E-l a Waste Piles
E-lb Landfill
E-lc No Migration
E-ld Drip Pad
E-2 Interim Status Groundwater
Monitoring Data
E-2a Description of Wells
E-2b Description of Sampling and
Analysis Procedures
E-2c Monitoring Data
E-2d Statistical Procedures
Federal
Regulation
270.14(c)
270.18(b);
264.90(b)(2),
(5)
270.14(c);
264.90(b)(2)
270.14(c);
264.90(b)(4)
270.26(b);
264.90(b)(2)
270.14(c)(l)
270.14(c)(l)
270.14(c)(l);
265.92
270.14(c)(l);
265.92
270.14(c)(l);
265.93
Review
Consideration"
A copy of topographic map provided for
270.14(b) on which location and
identification of each interim status
monitoring well is indicated. Details of
design and construction of each interim
status monitoring well.
A copy of facility's groundwater sampling
and analysis plan.
Provide all interim status monitoring results.
Provide information relating to statistical
procedures.
Location in
Application15
See Attached
Comment
Number0
SECTE.WPD
3-B-81
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION E. GROUNDWATER MONITORING
Section and
Requirement
E-2e Groundwater Assessment Plan
E-3 General Hydrogeologic Information
E-4 Topographic Map Requirements
E-5 Contaminant Plume Description
E-6 General Monitoring Program
Requirements
E-6a Description of Wells
E-6b Description of Sampling and
Analysis Procedures
E-6c Procedures for Establishing
Background Quality
Federal
Regulation
270.14(c)(l);
265.93(d)(2)
270.14(c)(2)
270.14(c)(2),
(3),(4)(i)
270.14(c)(2),
(4),(7)
270.14(c)(5);
264.90(b)(4);
264.97
270.14(c)(5);
264.97(a),(b),(c)
270.14(c)(5);
264.97(d),(e),(f)
270.14(c)(5);
264.97(a)(U(s)
Review
Consideration"
If required, based on statistical comparison
results, provide specific plan for
groundwater quality assessment program
along with results obtained from
implementation of plan.
Include description of regional and site-
specific geologic and hydrogeological
setting.
In some cases, contaminant plumes may be
defined under groundwater quality
assessment programs carried out during
interim status period which may not address
complete list of Appendix VIII constituents
as required under 270. 14(c)(4). Additional
monitoring may be required to identify
concentration of each Appendix VIII
constituent in plume.
Location in
Application15
See Attached
Comment
Number0
SECTE.WPD
3-B-82
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION E. GROUNDWATER MONITORING
Section and
Requirement
E-6d Statistical Procedures
E-6d(l) Parametric Analysis of Variance
(ANOVA)
E-6d(2) Nonparametric ANOVA (based on
ranks)
E-6d(3) Tolerance or Prediction Interval
Procedure
E-6d(4) Control Chart Approach
E-6d(5) Alternative Approach
E-7 Detection Monitoring Program
E-7a Indicator Parameters, Waste
Constituents, Reaction Products to
be Monitored
E-7b Groundwater Monitoring System
Federal
Regulation
270.14(c)(5);
264.97(h),
(i)(l),(5),(6)
270.14(c)(5);
264.97(h)(l),
(i)(2)
270.14(c)(5);
264.97(h)(2),
(i)(2)
270.14(c)(5);
264.97(h)(3),
(i)(4)
270.14(c)(5);
264.97(h)(4),
(i)(3)
270.14(c)(5);
264.97(h)(5),(i)
270.14(c)(6);
264.91(a)(4);
264.98
270.14(c)(6)
(i); 264.98(a)
270.14(c)(6)
(ii); 264.97(a)
(2),(b),(c);
264.98(b)
Review
Consideration"
Identify number, location, and depth of each
well, and describe well construction
materials.
Location in
Application15
See Attached
Comment
Number0
SECTE.WPD
3-B-83
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION E. GROUNDWATER MONITORING
Section and
Requirement
E-7c Background Groundwater
Concentration Values for Proposed
Parameters
E-7d Proposed Sampling and Analysis
Procedures
E-7e Statistically Significant Increase in
any Constituent or Parameter
Identified at any Compliance Point
Monitoring Well
E-8 Compliance Monitoring Program
E-8a Waste Description
E-8b Characterization of Contaminated
Groundwater
E-8c Hazardous Constituents to be
Monitored in Compliance Program
Federal
Regulation
270.14(c)(6)
(iii); 264.97
(g); 264.98(c),
(d)
270.14(c)(6)
(iv); 264.97
(d),(e),(f);
264.98(d),(e),
(0
270.14(c)(6);
264.98(g); Part
264 Appendix
IX
270.14(c)(7);
264.99
270.14(c)(7)(i)
270.14(c)(7)(n)
270.14(c)(7)
(iii); 264.98
(g)(3); 264.99
OOm
Review
Consideration"
Description must include historical records
of volumes, types, and chemical
composition of waste placed in units in
waste management areas.
For each well at point of compliance and for
each background well, provide
concentrations of each constituent in 261
Appendix VIII, major cations and anions,
and constituents listed in Table 1 of 264.94,
if not already mentioned above.
Location in
Application15
See Attached
Comment
Number0
SECTE.WPD
3-B-84
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION E. GROUNDWATER MONITORING
Section and
Requirement
E-8d Concentration Limits
E-8e Alternate Concentration Limits
E-8e(l) Adverse Effects on Groundwater
Quality
E-8e(2) Potential Adverse Effects
E-8f Engineering Report Describing
Groundwater Monitoring Systems
E-8g Proposed Sampling and Statistical
Analysis Procedures for
Groundwater Data
E-8h Groundwater Protection Standard
Exceeded at Compliance Point
Monitoring Well
E-9 Corrective Action Program
Federal
Regulation
270.14(c)(7)
(iv); 264.94,
264.97(g),(h);
264.99(a)(2)
270.14(c)(7)
(iv); 264.94
(b); 264.99
(a)(2)
270.14(c)(7)(iv);
264.94(b)(l)
270.14(c)(7)(iv);
264.94(b)(2)
270.14(c)(7)
(v); 264.95;
264.97(a)(2),
(b),(c);
264.99(b)
270.14(c)(7)
(vi); 264.97
(d),(e),(f);
264.99(c) - (g)
270.14(c)(8);
264.99(h),(i)
270.14(c)(8);
264.99(j);
264.100
Review
Consideration"
Provide justification for establishing
alternate concentration limits. Justification
must address the following two factors.
Provide details supporting representative
nature of groundwater quality at
background monitoring points and
compliance monitoring point.
Location in
Application15
See Attached
Comment
Number0
SECTE.WPD
3-B-85
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION E. GROUNDWATER MONITORING
Section and
Requirement
E-9a Characterization of Contaminated
Groundwater
E-9b Concentration Limits
E-9c Alternate Concentration Limits
E-9c(l) Adverse Effects on Groundwater
Quality
E-9c(2) Potential Adverse Effects
E-9d Corrective Action Plan
E-9e Groundwater Monitoring Program
E-9e(l) Description of Monitoring System
Federal
Regulation
270.14(c)(8)(i)
270.14(c)(8)
(ii); 264.94;
264.100(a)(2)
270.14(c)(8)
(n); 264.94(b);
264.100(a)(2)
270.14(c)(8);
264.94(b)(l)
270.14(c)(8);
264.94(b)(2)
270.14(c)(8)
(iii);264.100
(b)
270.14(c)(8)
(iv); 264. 100
(d)
270.14(c)(7)
(v),(8)
Review
Consideration"
For each well at point of compliance and for
each background well, provide
concentrations of each constituent in 261
Appendix VIII, major cations and anions,
and constituents listed in Table 1 of 264.94,
if not already determined by the above.
Provide justification for establishing
alternate concentration limits. Justification
must address the following two factors.
Provide detailed plans and engineering
report on corrective actions proposed for
facility, including maps of engineered
structures, construction details, plans for
removing waste, description of treatment
technologies, effectiveness of correction
program, description of reinjection system,
additional hydrogeologic data, operation
and maintenance plans, and closure and
post-closure plans.
Location in
Application15
See Attached
Comment
Number0
SECTE.WPD
3-B-86
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION E. GROUNDWATER MONITORING
Section and
Requirement
E-9e(2) Description of Sampling and
Analysis Procedures
E-9e(3) Monitoring Data and Statistical
Analysis Procedures
E-9e(4) Reporting Requirements
Federal
Regulation
270.14(c)(7)
(v),(8)
270.14(c)(7)
(v),(8)
270.14(c)(7);
264.100(g)
Review
Consideration"
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of
the information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this
column.
SECTE.WPD
3-B-87
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION F. PROCEDURES TO PREVENT HAZARDS
Section and
Requirement
F-l Security
F-la Security Procedures and
Equipment
F-la(l) 24-Hour Surveillance System
F-la(2)(a) Barrier
F- 1 a(2)(b) Means to Control Entry
F-la(3) Warning Signs
F-lb Waiver
F-lb(l) Injury to Intruder
F-lb(2) Violation Caused by Intruder
F-2 Inspection Schedule
Federal
Regulation
270.14(b)(4);
264.14
270.14(b)(4);
264.14
270.14(b)(4);
264.14
270.14(b)(4);
264.14
270.14(b)(4);
264.14
270.14(b)(4);
264.14
270.14(b)(4);
264.14
270.14(b)(4);
264.14
270.14(b)(4);
264.14
270.14(b)(5);
264.15
Review
Consideration"
Unless waiver is granted, facility must have
surveillance system or a barrier to entry.
Monitor/camera, guards, or personnel must
continuously monitor or control access to
active parts of facility.
This item required if 24-hour surveillance
system is not feasible. Describe artificial or
natural barrier.
This item required if 24-hour surveillance
system is not feasible.
Signs in english must be posted at each
entrance, and be legible from 25 feet.
Owner/operator must prevent unknowing
entry, and minimize unauthorized entry of
persons or livestock unless can demonstrate:
Assure physical contact with waste,
structure, or equipment will not injure
unknowing intruder.
Assure disturbance of waste or equipment
by unauthorized intruder will not cause a
violation.
Inspection is required for monitoring
equipment, safety emergency equipment,
communication and alarm systems,
decontamination equipment, security
devices, and operating and structural
equipment.
Location in
Application15
See Attached
Comment
Number0
SECTF.WPD
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION F. PROCEDURES TO PREVENT HAZARDS
Section and
Requirement
F-2a General Inspection Requirements
F-2a(l) Types of Problems
F-2a(2) Frequency of Inspections
F-2a(3) Schedule of Remedial Action
F-2a(4) Inspection Log
F-2b Specific Process Inspection
Requirements
F-2b(l) Container Inspection
F-2b(2) Tank System Inspection
F-2b(2)(a) Tank System External Corrosion
and Releases
F-2b(2)(b) Tank System Construction
Materials and Surrounding Area
F-2b(2)(c) Tank System Overfilling Control
Equipment
Federal
Regulation
270.14(b)(5);
264.15(a),(b);
264.33
270.14(b)(5);
264.15(b)(3)
270.14(b)(5);
264.15(b)(4)
270.14(b)(5);
264.15(c)
270.14(b)(5);
264.15(d)
270.14(b)(5)
270.14(b)(5);
264.174
270.14(b)(5);
264.195
270.14(b)(5);
264.195(b)(l)
270.14(b)(5);
264.195(b)(3)
270.14(b)(5);
264.195(a)
Review
Consideration"
Inspection checklist must identify types of
problem.
Based on rate of deterioration of equipment
and probability of environmental or human
health incident.
Owner/operator must immediately remedy
any deterioration or malfunction of
equipment or structures to ensure problem
does not lead to environmental or human
health hazard.
Provide example log or summary.
Inspect at least weekly.
Owner/operator must develop schedule and
inspect at least once daily.
Owner/operator must inspect that
aboveground portion and check for
corrosion.
Observe construction materials and area
around external portion for signs of release
of hazardous waste.
Develop and follow schedule for inspection
of overfill controls.
Location in
Application15
See Attached
Comment
Number0
SECTF.WPD
3-B-89
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION F. PROCEDURES TO PREVENT HAZARDS
Section and
Requirement
F-2b(2)(d) Tank System Monitoring and
Leak Detection Equipment
F-2b(2)(e) Tank System Cathodic Protection
F-2b(3) Waste Pile Inspection
F-2b(3)(a) Runon and Runoff Control System
F-2b(3)(b) Wind Dispersal System
F-2b(3)(c) Leachate Collection and Removal
System
F-2b(4) Surface Impoundment Inspection
F-2b(4)(a) Condition Assessment
F- Overtopping Control System
2b(4)(a)(l)
F- Impoundment Contents
2b(4)(a)(2)
F- Dikes and Containment Devices
2b(4Ka¥3)
Federal
Regulation
270.14(b)(5);
264.195(b)(2)
270.14(b)(5);
264.195(c)
270.14(b)(5);
270.18(d);
264.254(b)
270.14(b)(5);
264.254(b)(l)
270.14(b)(5);
264.254(b)(2)
270.14(b)(5);
270. 1 8 (d);
264.254(b)(3),
(c)
270.14(b)(5);
270.17(c);
264.226(b),(c)
270.14(b)(5);
264.226(b)
270.14(b)(5);
264.226(b)(l)
270.14(b)(5);
264.226(b)(2)
270.14(b)(5);
264.226(b¥3)
Review
Consideration"
Analyze data gathered from monitoring
equipment to ensure tank is operating
according to design.
Inspect according to schedule.
Describe how waste pile will be inspected
daily and after storms.
Inspections should identify deterioration,
malfunction, or improper operation of
control system.
Facility should inspect proper function of
wind dispersal system.
Determine whether there is leachate present
in functioning double liner system.
Describe how each surface impoundment
will be inspected to meet requirements of
monitoring and inspection and waiver
requirement.
Describe how surface impoundment will be
inspected weekly and after storms.
Inspect for deteriorating, malfunction, or
improper operation of control system.
Inspect for sudden drop in level of
impoundment contents.
Inspect for severe erosion in containment
devices.
Location in
Application15
See Attached
Comment
Number0
SECTF.WPD
3-B-90
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION F. PROCEDURES TO PREVENT HAZARDS
Section and
Requirement
F-2b(4)(b) Structural Integrity
F-2b(4)(c) Leak Detection System
F-2b(5)(a) Incinerator and Associated
Equipment
F-2b(5)(b) Incinerator Waste Feed Cutoff
System and Alarms
F-2b(6) Landfill Inspection
F-2b(6)(a) Runon and Runoff Control System
F-2b(6)(b) Wind Dispersal Control System
F-2b(6)(c) Leachate Collection and Removal
System
F-2b(7) Land Treatment Facility
Inspection
F-2b(7)(a) Runon and Runoff Control System
F-2b(7)(b) Wind Dispersal Control System
Federal
Regulation
270.14(b)(5);
264.226(c)
270.14(b)(5);
270.17(c);
264.226(d)
270.14(b)(5);
264.347(b)
270.14(b)(5);
264.347(c)
270.14(b)(5);
264.303(b)
270.14(b)(5);
264.303(b)(l)
270.14(b)(5);
264.303(b¥2)
270.14(b)(5);
264.303(b)(3),
(c)
270.14(b)(5);
264.273(g)
270.14(b)(5);
264.273(g)(l)
270.14(b)(5);
264.273(g)(2)
Review
Consideration"
Specify procedure for assessing integrity of
surface impoundments.
Describe how double liner system and leak
detection system will be inspected.
Describe procedures for daily visual
inspection of incinerator and associated
equipment.
Describe procedure and frequency of testing
emergency waste feed cutoff system.
For operating landfill, describe how it will
be inspected weekly and after storms.
Deterioration, malfunction, or improper
operation of runon and runoff control
system.
Proper functioning of wind dispersal control
systems, where present.
In properly functioning double liner system,
is there a presence of leachate? Leak
detection required under 264.301(c) or
264.301(d) must record amount of leakage
from each system weekly.
Describe how land treatment facility will be
inspected weekly and after storms.
Location in
Application15
See Attached
Comment
Number0
SECTF.WPD
3-B-91
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION F. PROCEDURES TO PREVENT HAZARDS
Section and
Requirement
F-2b(8) Miscellaneous Unit Inspections
F-2b(9) Boilers and Industrial Furnaces
(BIF) Inspection
F-2b(10) Containment Building Inspection
F-2b(l 1) Drip Pad Inspection
F-3 Waiver or Documentation of
Preparedness and Prevention
Requirements
F-3 (a) Equipment Requirements
F-3(a)(l) Internal Communication
Federal
Regulation
270.14(b)(5);
264.602
270.14(b)(5);
264.15;
266.102(a)(2)
(ii),(e)(8);
266.111(e)(3)
270.14(b)(5);
264.1101(c)(3),
(4)
270.14(b)(5);
264.574
270.14(b)(6)
264.32(a) - (d)
270.14(b);
264.32
270.14(b);
264.32(a)
Review
Consideration"
Provide inspection program that ensures
compliance with standards in 264.601 and
270.23.
Demonstrate that BIF will be visually
inspected daily, automatic waste feed cutoff
inspected at least weekly, and direct transfer
area at least once an hour when waste is
being transferred.
Demonstrate owner/operator will inspect
and document at least weekly, monitoring
equipment, leak detection equipment,
containment building, and surrounding
areas for waste releases.
Demonstrate that the drip pad
owner/operator will inspect and document at
least weekly and after storms, the leak
detection and collection equipment, the drip
pad surface, and the runon and runoff
control systems for evidence of
deterioration, malfunction, improper
operation, or leakage of hazardous waste.
Facility must submit justification for any
waiver to requirements of this section.
Describe internal communication or alarm
system used to provide immediate
emergency instruction to personnel.
Location in
Application15
See Attached
Comment
Number0
SECTF.WPD
3-B-92
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION F. PROCEDURES TO PREVENT HAZARDS
Section and
Requirement
F-3(a)(2) External Communication
F-3(a)(3) Emergency Equipment
F-3(a)(4) Water and Fire Control
F-3(a)(5) Testing and Maintenance of
Equipment
F-3(a)(6) Access to Communication or
Alarm System
F-3(b) Aisle Space Requirement
F-3(c) Documentation of Arrangements
with:
F-3(c)(l) Police/Fire Department
Federal
Regulation
270.14(b);
264.32(b)
270.14(b);
264.32(c)
270.14(b);
264.32(d)
270.14(b);
264.33
270.14(b);
264.34
270.14(b);
264.35
270.14(b);
264.37
270.14(b);
264.37(a)(l)
Review
Consideration"
Describe device for summoning emergency
assistance from local police, fire, or
state/local emergency response.
Demonstrate that portable fire extinguishers,
fire control equipment, spill control
equipment, and decontamination equipment
are available.
Demonstrate facility has adequate fire
control systems, water volume and pressure,
foaming equipment, automatic sprinklers,
etc.
Demonstrate communication, alarm, fire
control equipment, spill control equipment,
and decontamination equipment are tested
and maintained.
When waste is being hauled, all personnel
must have access to internal alarm or
communication device.
Aisle space is required for unobstructed
movement of personnel, fire protection
equipment, spill control equipment, and
decontamination equipment in case of
emergency.
Owner/operator must make arrangements,
as appropriate, with type of waste and
hazard potential, for the potential need for
services.
Arrange to familiarize local fire department
and police with facility.
Location in
Application15
See Attached
Comment
Number0
SECTF.WPD
3-B-93
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION F. PROCEDURES TO PREVENT HAZARDS
Section and
Requirement
F-3(c)(2) Emergency Response Teams
F-3(c)(3) Local Hospitals
F-3(c)(4) Document Agreement Refusal
F-4 Prevention Procedures, Structures,
and Equipment
F-4(a) Unloading Procedures
F-4(b) Runoff
F-4(c) Water Supplies
F-4(d) Equipment and Power Failure
F-4(e) Personnel Protection Procedures
F-4(f) Procedures to Minimize Releases
to the Atmosphere
Federal
Regulation
270.14(b);
264.37(a)(2),
(a¥3)
270.14(b);
264.37(a)(4)
270.14(b);
264.37(b)
270.14
270.14(b)(8)(i)
270.14(b)(8)(ii)
270.14(b)(8)
(in)
270.14(b)(8)
(IV)
270.14(b)(8)(v)
270.14(b)(8)
(vi)
Review
Consideration"
Arrange to familiarize local hospital with
properties of hazardous waste and possible
types of injury or illness to expect.
Document refusal to enter into a
coordination agreement.
Describe procedure used to prevent hazards
in unloading operations. Identify possible
loading and unloading hazards, and
document steps taken to minimize or
eliminate possibility of these hazards.
Describe procedure used to prevent runoff
from hazardous waste handling areas.
Describe procedure, structures, equipment
used to prevent contamination of water
supply.
Describe procedure used to mitigate the
effects of equipment failure and power
outages.
Describe procedure, structures, equipment
used to prevent contamination of personnel
to hazardous waste.
Describe procedure, structures, equipment
used to prevent hazardous waste releases to
the atmosphere.
Location in
Application15
See Attached
Comment
Number0
SECTF.WPD
3-B-94
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION F. PROCEDURES TO PREVENT HAZARDS
Section and
Requirement
F-5 Prevention of Reaction of
Ignitable, Reactive, and
Incompatible Waste
F-5a Precautions to Prevent Ignition or
Reaction of Ignitable or Reactive
Wastes
F-5b General Precautions for Handling
Ignitable or Reactive Waste and
Mixing of Incompatible Waste
F-5b(l) Documentation of Adequacy of
Procedures
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 Tank Systems
F-5f Management of Incompatible
Wastes in Tank Systems
Federal
Regulation
270.14(b)(9)
270.14(b)(9);
264.17(a),(b)
270.14(b)(9);
264.17(a)
270.14(b);
264.17(c)
270.15(c);
264.176
270.15(d);
264.177
270.16(j);
264.198
270.16(j);
264.199
Review
Consideration"
Waste must be protected from sources of
ignition or reaction. Describe precautions
taken by facility to prevent actual ignition,
including sources of spontaneous ignition
and radiant heat. Owner/operator must
designate safe areas for smoking and open
flames. Post signs where hazard exists.
Describe precautions taken by facility to
prevent reactions that generate heat,
produce flammable byproducts, cause risk
of fire or explosion, threaten structural
integrity, or pose threat to human life or the
environment.
Published literature, trial test, waste
analyses, or similar processes may be used.
Demonstrate that ignitable containers are at
least 15 meters from facility property line.
Describe procedures that ensure
incompatible wastes and materials are not
placed in same container.
Describe operation procedures and how
facility treats waste so it is no longer
ignitable or how facility stores ignitable or
reactive waste.
Demonstrate that incompatible waste and
materials are not stored in same tank.
Location in
Application15
See Attached
Comment
Number0
SECTF.WPD
3-B-95
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION F. PROCEDURES TO PREVENT HAZARDS
Section and
Requirement
F-5g Management of Ignitable or
Reactive Wastes Placed in Waste
Piles
F-5h Management of Incompatible
Wastes Placed in Waste Piles
F-5i Management of Ignitable or
Reactive Wastes in Surface
Impoundments
F-5j Management of Incompatible
Wastes in Surface Impoundments
F-5k Management of Ignitable or
Reactive Wastes Placed in
Landfills
F-51 Management of Incompatible
Wastes Placed in Landfills
F-5m Management of Ignitable or
Reactive Wastes Placed in Land
Treatment Units
F-5n Management of Incompatible
Wastes Placed in Land Treatment
Units
F-5o Management of Incompatible
Wastes Placed in Containment
Buildings
Federal
Regulation
270.18(g);
264.256
270.18(h);
264.257
270.17(h);
264.229
270.17(h);
264.230
270.21(f);
264.312
270.21(g);
264.313
270.20(g);
264.281
270.20(h);
264.282
270.14(a);
264.1101(a)(3)
Review
Consideration"
If waste is reactive or ignitable, describe
how handling process will render waste pile
nonreactive and/or nonignitable.
Document how hazardous waste piles of
incompatible materials are separated to
render them nonreactive.
If waste is reactive or ignitable, describe
how handling process will render surface
impoundments nonreactive and/or
nonignitable.
Document how hazardous surface
impoundments of incompatible materials are
separated to render them nonreactive.
If waste is reactive or ignitable, describe
how handling process will prevent reaction
or ignition to landfills.
Document how hazardous landfills of
incompatible materials are separated to
render them nonreactive.
If waste is reactive or ignitable, describe
how handling process will render land
treatment units nonreactive and/or
nonignitable.
Document how land treatment unit piles of
incompatible materials are separated to
render them nonreactive.
Subsections include design, primary and
secondary containment, barriers to prevent
migration, leak detection, and facility logs.
Location in
Application15
See Attached
Comment
Number0
SECTF.WPD
3-B-96
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION G. CONTINGENCY PLAN
Section and
Requirement
G-l Contingency Plan
G-2 Emergency Coordinators
G-3 Implementation
G-4 Emergency Actions
G-4a Notification
G-4b Identification of Hazardous Materials
G-4c Assessment
G-4d Control Procedures
G-4e Prevention of Recurrence of Spread
of Fires, Explosions, or Releases
Federal
Regulation
270.14(b)(7)
270.14(b)(7);
264.52(d);
264.55
270.14(b)(7);
264.52(a);
264.56(d)
270.14(b)(7);
264.56
270.14(b)(7);
264.56(a)
270.14(b)(7);
264.56(b)
270.14(b)(7);
264.56(c),(d)
270.14(b)(7);
264.52(a)
270.14(b)(7);
264.56(e)
Review
Consideration"
There must at least be one primary
emergency coordinator available at all times.
Emergency coordinator to determine that
facility has had a release, fire, or explosion
that could threaten human health or the
environment outside facility.
Describe the method for immediate
notification of facility personnel and
necessary state and local agencies.
Observation, records or manifest, or chemical
analysis may be used by emergency
coordinator.
Direct and indirect effects must be
considered.
Contingency plan must describe actions
facility personnel must take in response to
fires, explosions, or any unplanned release of
hazardous waste to air, soil, or surface water.
Measures must include stopping processes
and operations, collecting and containing
release of waste, and removing or isolating
containers.
Location in
Application15
See Attached
Comment
Number0
SECTG.WPD
3-B-90
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION G. CONTINGENCY PLAN
Section and
Requirement
G-4e(l) Monitor for Leaks, Pressure Buildup,
Gas Generation or Ruptures of
Released Material
G-4f Storage, Treatment, and Disposal of
Released Material
G-4g Incompatible Waste
G-4h Post-Emergency Equipment
Management
G-4h(l) Notification of Federal, State and
Local Authorities before Resuming
Operations
G-4i Container Spills and Leakage
G-4j Tank Spills and Leakage
G-4j ( 1 ) Stopping Waste Addition
G-4j(2) Removing Waste
Federal
Regulation
270.14(b)(7);
264.56(f)
270.14(b)(7);
264.56(g)
270.14(b)(7);
264.56(h)(l)
270.14(b)(7);
264.56(h)(2)
270.14(b)(7);
264. 5 6(1)
270.14(b)(7);
264.52;
264.71
270.14(b)(7);
264.196(a)
270.14(b)(7);
264.196(b)
Review
Consideration"
This item applies if facility stops operations.
After emergency, emergency coordinator
must provide for treating, storing, and
disposing of recovered waste.
Until cleanup is complete, assure that
incompatible waste is not stored together.
Decontamination is required for emergency
equipment.
Federal or state authorities must be notified
within 15 days of occurrence.
Specify procedures to be used when
responding to container spills and leakage.
For a tank or containment system from which
there has been a leak or spill:
Document that the owner/operator will
immediately stop the flow of hazardous
waste.
Owner/operator will, within 24 hours after
leak detected, remove waste and allow
inspection and repair of the tank system to be
performed.
Location in
Application15
See Attached
Comment
Number0
SECTG.WPD
3-B-91
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION G. CONTINGENCY PLAN
Section and
Requirement
G-4j(3) Containment of Visible Releases
G-4j(4) Notification Reports
G-4j(5) Provisions of Secondary
Containment, Repair, or Closure
G4-k Surface Impoundment Spills and
Leakage
G4-k(l) Emergency Repairs
G4-k(l)(a) Stopping Waste Addition
G4-k(l)(b) Containing Leaks
G4-k(l)(c) Stopping Leaks
G4-k(l)(d) Preventing Catastrophic Failure
G4-k(l)(e) Emptying the Impoundment
Federal
Regulation
270.14(b)(7);
264.196(c)
270.14(b)(7);
264.196(d)
270.14(b)(7);
264.196(e)
270.14(b)(7);
264.227
270.14(b)(7);
264.227
270.14(b)(7);
264.227(b)(l)
270.14(b)(7);
264.227(b)(2)
270.14(b)(7);
264.227(b)(3)
270.14(b)(7);
264.227(b)(4)
270.14(b)(7);
264.227(b)(5)
Review
Consideration"
Specify that a visual inspection of a release
will be conducted, demonstrate further
mitigation of leak will be prevented, and
visible contamination will be removed and
disposed of properly.
Demonstrate that any release to the
environment will be reported to regional
administrator within 24 hours of detection.
Provision of secondary containment repair,
otherwise closure is required.
Surface impoundments must be removed
from service when:
Describe procedures for removing surface
impoundments from service.
Procedures for stopping waste addition to the
impoundment.
Procedures for containing leak.
Procedures for stopping leak.
Procedures to stop or prevent catastrophic
failure.
Procedures for emptying impoundment, if
necessary.
Location in
Application15
See Attached
Comment
Number0
SECTG.WPD
3-B-92
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION G. CONTINGENCY PLAN
Section and
Requirement
G4-k(2) Certification
G4-k(3) Repairs as a Result of Sudden Drop
G4-k(3)(a) Existing Portions of Surface
Impoundment
G4-k(3)(b) Other Portions of the Surface
Impoundment
G4-1 Containment Building Leaks
G-41(l) Repair of Containment Building
G-41(2) Certification Following Repair
G-4m Drip Pad Spills and Leakage
Federal
Regulation
270.14(b)(7);
264.226 (c);
264.227(d)(l)
270.14(b)(7);
264.227(d)(2)
270.14(b)(7);
264.227(d)(2)(i)
270.14(b)(7);
264.227(d)(2)(ii)
270.14(b)(7);
264.1101(c)(3)
270.14(b)(7);
264.1101(c)(3)
270.14(b)(7);
264.1101(c)(3)(iii
)
270.14(b)(7);
264.573(m)
Review
Consideration"
Procedures for recertifying a dike's structural
integrity if impoundment is removed from
service due to actual or imminent failure.
Procedures to follow if impoundment is
removed from service due to sudden drop in
liquid level of the following:
Installation of liner for any existing portion of
impoundment.
Certification by qualified engineer for other
than existing portions of the impoundment.
Through active life of building if
owner/operator detects condition that could
lead to release of hazardous waste.
Within 7 days of detection, owner/operator
must contact regional administrator. Enter
record of discovery, remove contaminated
portion of building from service, determine
repair steps, and establish schedule for repair.
Upon completion of repairs owner/operator
must notify regional administrator.
Throughout the active life of the drip pad, if a
condition is detected that may have or has
caused a release of hazardous waste, it must
be repaired within a reasonably prompt
period of time.
Location in
Application15
See Attached
Comment
Number0
SECTG.WPD
3-B-93
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION G. CONTINGENCY PLAN
Section and
Requirement
G-4m(l) Stopping Waste Addition
G-4m(2) Determine Appropriate Cleanup and
Repair
G-4m(3) Notification
G-4m(4) Certification
G-5 Emergency Equipment
G-6 Arrangements with Local Authorities
G-7 Evacuation Plan for Facility
Personnel
G-8 Required Report Procedures for
Recordkeeping and Reporting to
Federal Authority
Federal
Regulation
270.14(b)(7);
264.573(m)(l)(ii)
270.14(b)(7);
264.573(m)(l)(iii
)
270.14(b)(7);
264.573(m)(l)(iv
)
270.14(b)(7);
264.573(m)(3)
270.14(b)(7);
264.52(e)
270.14(b)(7);
264.37; 264.52(c)
270.14(b)(7);
264.52(f)
270.14(b)(7);
264.56(j)
Review
Consideration"
Upon detection of leakage in the leak
detection system, immediately remove the
affected portion of the drip pad from service.
Establish a schedule for accomplishing the
repairs.
Within 24 hours after discovery of the
condition, notify the Regional Administrator
or state director. Within 10 working days,
provide written notice and a description of
the repairs to be made to the drip pad.
Upon completing all repairs and clean up,
provide certification signed by an
independent, qualified registered PE.
Police and fire departments, hospitals, and
emergency response teams must be notified
by owner/operator. Document refusal to enter
into a coordination agreement.
Evacuation plans must include evacuation
signals and primary and alternate evacuation
routes.
Owner/operator must note on operation
record the time, date and details of incidents
which require implementation of contingency
plan.
Location in
Application15
See Attached
Comment
Number0
SECTG.WPD
3-B-94
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION G. CONTINGENCY PLAN
Section and
Requirement
G-9 Location and Distribution of
Continsencv Plan
Federal
Regulation
270.14(b)(7);
264.53
Review
Consideration"
Copy of contingency plan must be
maintained at facility and submitted to local
Location in
Application15
See Attached
Comment
Number0
SECTG.WPD
3-B-95
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.: Facility Name:
Notes:
3 Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of
the information in the application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTG.WPD Reviewer:
3 -B-96 Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION H. PERSONNEL TRAINING
Section and
Requirement
H-l Outline of Introductory and
Continuing Training Programs
H-la Job Title/Job Description
H-lb Description of How Training will be
Designed to Meet Actual Job Tasks
H-lc Training Director
H- 1 d Relevance of Training to Job Position
H-le Training for Emergency Response
H-2 Maintenance of Training
Records/Copy of Personnel Training
Documents
Federal
Regulation
270.14(b)(12)
;264.16(a)(l)
270.14(b)(12)
;264.16(d)l),
(d)(2)
270.14(b)(12)
264.16(c),(d)
(3)
270.14(b)(12)
;264.16(a)(2)
270.14(b)(12)
;264.16(a)(2)
270.14(b)(12)
;264.16(a)(3)
270.14(b)(12)
264.16(b),(d)
(4Y(e)
Review
Consideration"
Facility personnel must successfully
complete classroom or on-the-job training
which will allow them to responsibly
perform in their positions.
Owner or operator must maintain records of
job titles, names of employees, job
descriptions, and types and amounts of
training given to employees.
Training must be conducted by a qualified
person; there must also be an annual review
of the training.
Program must be directed by person trained
in hazardous waste procedures.
Training must include instruction on
hazardous waste procedures relevant to each
employee's
position.
Personnel must minimally be familiar with
emergency procedures, emergency
equipment, and emergency systems.
Training records on current personnel must
be kept until closure of facility. Training
must be completed within 6 months after
date of eniDlovment.
Location in
Application15
See Attached
Comment
Number0
SECTH.WPD
3-B-97
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.: Facility Name:
Notes:
3 Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTH.WPD Reviewer:
3 -B-98 Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
1-1 Closure Plans
I- la Closure Performance Standard
I-lb Time and Activities Required for
Partial Closure and Final Closure
Activities
I-lc Maximum Waste Inventory
I-ld Schedule for Closure
I-l(d)(l) Time Allowed for Closure
I-ld(l)(a) Extension for Closure Time
Federal
Regulation
270.14(b)(13)
270.14(b)(13);
264.111
270.14(b)(13);
264.112(b)(l)
through
264.112(b)(7)
270.14(b)(13);
264.112(b)(3)
270.14(b)(13);
264.112(b)(6)
270.14(b)(13);
264.112(b)(2);
264.113(a)
and(b)
270.14(b)(13);
264.113(a)
and(b)
Review
Consideration"
Describe how closure: minimizes the need for
further maintenance; controls, minimizes, or
eliminates the post-closure escape of hazardous
waste, hazardous constituents, leachate,
contaminated run-off, or hazardous waste
decomposition products to the ground or
surface waters or to the atmosphere; and
complies with the closure requirements of
Subpart G and unit-specific closure
requirements.
Describe the time and all activities required for:
partial closure, if applicable; final closure; and
maximum extent of operation that will be
active during life of facility.
Location in
Application15
See Attached
Comment
Number0
SECTI.WPD
3-B-99
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
I-le Closure Procedures
I-le(l) Inventory Removal
I-le(2) Disposal or Decontamination of
Equipment, Structure, and Soils
I-le(3) Closure of Disposal Units/Contingent
Closures
I-le(3)(a) Disposal Impoundments
I-le(3)(a)(i) Elimination of Liquids
I-le(3)(a)(ii) Waste Stabilization
Federal
Regulation
270.14(b)(13);
264.112;
264.114
270.14(b)(13);
264.112(b)(3)
270.14(b)(13);
264.112(b)(4);
264.114
270.14(b)(13)
270.14(b)(13);
264.228(a)(2)
270.14(b)(13)
270.14(b)(13);
264.228(a)(2)
(n)
Review
Consideration"
Discuss methods for removing, transporting,
treating, storing, or disposing of all hazardous
wastes and identify the type(s) of off-site
hazardous waste management units to be used.
Provide a detailed description of the steps
needed to decontaminate or dispose of all
facility equipment and structures. Demonstrate
that any hazardous constituents (i.e., Appendix
VII) left at the unit will not impact any
environmental media in excess of Agency-
established exposure levels and that direct
contact will not pose a threat to human health
and the environment.
Location in
Application15
See Attached
Comment
Number0
SECTI.WPD
3-B-100
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
I-le(3)(b) Cover Design
270.14(b)(13);
264.228(a)(2)
(iii);264.310
(a)
I-le(3)(c) Minimization of Liquid Migration
270.14(b)(13);
264.228(a)(2)
264.310(a)(l)
Draft RCRA Guidance Document entitled
Landfill (Design—Liner Systems and Final
Cover (1982), suggests the following design
for landfill cover systems (from top to bottom):
a vegetated top cover, with a minimum of 24
inches of topsoil; a middle drainage layer (at
least one foot thick with a saturated
conductivity of not less than 1 x 10~3 cm/sec)
overlain by a geotextile filter fabric or graded
granular filter; and a low permeability bottom
layer consisting of two components: an upper
component of at least a 20 mil synthetic
membrane protected above and below by at
least six inches of bedding material, a lower
component of at least 24 inches of low
permeability (maximum hydraulic conductivity
of 1 x 10~7 cm/sec) soil emplaced in lifts not
exceeding six inches. For cover designs
different than EPA-recommended designs,
provide engineering calculations showing the
proposed cover will provide long-term
minimization of liquid migration through the
cover.
SECTI.WPD
3-B-101
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
I-le(3)(d) Maintenance Needs
270.14(b)(13);
264.228(a)(2)
264.310(a)(2)
I-le(3)(e) Drainage and Erosion
270.14(b)(13);
264.228(a)(2)
264.310(a)(3)
The following information should be provided:
data demonstrating that the proposed final
slopes will not cause significant cover erosion;
description of drainage materials and their
permeabilities; engineering calculations
demonstrating free drainage of precipitation off
of and out of the cover; and estimation of the
potential for drainage-layer clogging.
I-le(3)(f) Settlement and Subsidence
270.14(b)(13);
264.228(a)(2)
264.310(a)(4)
Include the following information: potential
foundation compression; potential soil liner
compression; and potential waste consolidation
and compression resulting from waste
dewatering, biological oxidation and chemical
conversion of solids to liquids.
I-le(3)(g) Cover Permeability
270.14(b)(13);
264.228(a)(2)
264.310(a)(5)
I-1 e(3)(h) Freeze/Thaw Effects
270.14(b)(13);
264.228(a)(2)
(in);
264.310(a)
Identity the average depth of frost penetration
and describe the effects of freeze/thaw cycles
on the cover.
SECTI.WPD
3-B-102
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
Closure of Containers
270.14(b)(13);
264.178;
264.112(b)(3);
270.14(b)(13
Address the following: hazardous waste
removal and disposal; container
decontamination and disposal; site
decontamination and disposal including
linings, soil, and washes; maximum inventory.
Closure of Tanks
270.14(b)(13);
264.197;
264.112(b)(3)
The description should address the following:
waste removal from tanks and equipment;
decontamination of all components;
verification of decontamination; disposal of
wastes and residues; and maximum inventory.
Closure of Waste Piles
270.14(b)(13);
270.18(h);
264.258
The description must address the following:
procedure and criteria for determining whether
or not decontamination has been successful;
and sampling and analytical techniques.
Closure of Surface Impoundments
270.14(b)(13);
270.17(f);
264.228(a)(l),
(2), and (b)
Surface impoundments without liners or with
liners that do not meet the requirements must
also provide contingent plans for closure in
place and a contingent post-closure plan,
except for impoundments requesting a liner
exemption in accordance with D-4b.
SECTI.WPD
3-B-103
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
Closure of Incinerators
270.14(b)(13);
264.351
Describe how, at closure, all hazardous waste
and hazardous waste residues (including, but
not limited to, ash, scrubber waters, and
scrubber sludges) will be removed from the
incinerator, associated ductwork, piping, air
pollution control equipment, sumps, and any
other structures or operating equipment such as
pumps, valves, etc., that have come into
contact with the hazardous waste.
Alternatively, describe how the incinerator and
associated units and equipment will be
dismantled and disposed of as a hazardous
waste.
Closure of Landfills
270.14(b)(13);
270.21(e);
264.310(a)
Provide detailed plans and engineering report
that describes the final cover components in
detail. Cover installation and construction
quality assurance procedures should be
thoroughly described.
I-le(lO) Closure of Land Treatment Facilities
270.14(b)(13);
264.280(a);
270.20(f)
I-le(10)(a) Continuance of Treatment
270.14(b)(13);
264.280(a)(l)
through (7)
I-le(10)(b) Vegetative Cover
270.14(b)(13);
270.20(f);
264.280(a)(8)
SECTI.WPD
3-B-104
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
I-le(ll)
Closure of Miscellaneous Units
270.14(b)(13);
270.23(a)(2)
I-le(12) Closure of Boilers and Industrial
Furnaces
270.14(b)(13);
266.102(a)(2)
(vii)
Describe how, at closure, all hazardous waste
and hazardous waste residues (including, but
not limited to, ash, scrubber waters, and
scrubber sludges) will be removed from the
BIF unit, associated ductwork, piping, air
pollution control equipment, sumps and any
other structures or operating equipment such as
pumps, valves, etc., that have come into
contact with hazardous wastes. Alternatively,
describe how the BIF and associated
equipment will be dismantled and disposed of.
If any wastes, waste residues, contaminated
components, subsoils, structures or equipment
remain after closure, provide plans for closing
the BIF unit as a landfill and provide a post-
closure care plan.
I-le(13) Closure of Containment Buildings
270.14(b)(13);
264.1102
Show that at closure all hazardous waste,
hazardous waste residues, contaminated
containment system, contaminated subsoils,
and all structures and equipment contaminated
with waste and leachate will be removed. If
any wastes, waste residues, contaminated
components, subsoils, structures or equipment
remain after closure, provide plans for closing
the containment building as a landfill and
provide a post-closure care plan.
SECTI.WPD
3-B-105
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
1-2
Post-Closure Plans
270.14(b)(13)
I-2a
Inspection Plan
270.14(b)(13);
264.118(a);
264.197(b);
264.197(c)(2);
264.226(d)(2);
264.228(b);
264.228(c)(l)
(ii); 264.258
(b); 264.258
Rationale for determining the length of time
between inspections should be provided.
264.303(c);
264.310(b)
I-2b
Monitoring Plan
270.14(b)(13);
264.118(b)(l);
264.197(b);
264.197(c)(2);
264.226(d)(2);
264.228(b);
264.228(c)(l)
(ii); 264.258
(b); 264.258
264.303(c);
264.310(b)
SECTI.WPD
3-B-106
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
I-2c Maintenance Plan
I-2d Land Treatment
I-2e Post-Closure Care for Miscellaneous
Units
l-2f Post-Closure Security
I-2g Post-Closure Contact
Federal
Regulation
270.14(b)(13);
264.118(b)(2);
264.197(b);
264.197(c)(2);
264.228(b);
264.228(c)(l)
(ii); 264.258
(b);
264.258(c)
264.310
(b)
270.14(b)(13);
264.280(c)
270.14(b)(13);
270.23(a)(3);
264.603
270.14(b)(13);
264.117(b)
and (c)
270.14(b)(13);
264.118(b¥3)
Review
Consideration"
Describe the preventative and corrective
maintenance procedures, equipment
procedures, equipment requirements and
material needs.
Describe the operation, inspection, and
maintenance programs to be used at the closed
facility.
Demonstrate that for property where hazardous
wastes remain after partial or final closure,
post-closure use must never be allowed to
disturb the integrity of the final cover, liner(s),
or any other components of the containment
system, or the function of the facility's
monitoring system.
Location in
Application15
See Attached
Comment
Number0
SECTI.WPD
3-B-107
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
1-3 Notices Required for Disposal
Facilities
I-3a Certification of Closure
I-3b Survey Plat
I-3c Post-Closure Certification
I-3d Post-Closure Notices
1-4 Closure Cost Estimate
1-5 Financial Assurance for Closure
Federal
Regulation
270.14(b)(13)
270.14(b)(13);
264.115;
264.280
270.14(b)(13);
264.116
270.14(b)(13);
264.120
270.14(b)(13);
270.14(b)(14);
264.119
270.14(b)(15);
264.142
270.14(b)(15);
264.143;
264.151
Review
Consideration"
Estimate must equal final cost estimate.
Estimate must be based on third party closing
facility and may use on-site disposal if capacity
will exist over life of facility. Estimate must be
adjusted for annual inflation as stated in
264.142(b). Estimates may not assume zero
cost for hazardous waste handling, and may
not incorporate salvage value, facility
structures/equipment, land, or other facility
assets as offsets.
Location in
Application15
See Attached
Comment
Number0
SECTI.WPD
3-B-108
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
I-5a Closure Trust Fund
I-5b Surety Bond
I-5b(l) Surety Bond Guaranteeing Payment
into a Closure Trust Fund
I-5b(2) Surety Bond Guaranteeing
Performance of Closure
I-5(c) Closure Letter of Credit
I-5(d) Closure Insurance
I-5(e) Financial Test and Corporate
Guarantee for Closure
Federal
Regulation
270.14(b)(15);
264.143(a);
264.151(a)(l)
270.14(b)(15);
264.143(b),
(c); 264. 151
(b),(c)
270.14(b)(15);
264.143(b);
264.151(b)
270.14(b)(15);
264.143(c);
264.1 5 l(c)
270.14(b)(15);
264.143(d);
264.151(d)
270.14(b)(15);
264.143(e);
264.1 5 l(e)
270.14(b)(15);
264.143(f);
264.151(f),(h)
Review
Consideration"
Provide copy of fund agreement.
Must provide bond or standby trust agreement.
Bond must guarantee owner/operator will fund
standby trust fund or provide financial
assurance equal to penal sum.
Guarantee owner/operator will perform closure
required as worded in 246. 151(c) and Subpart
G.
Requires letter of credit for 1 year equal to
amount of closure.
Provide copy of certificate of insurance,
wording requirement found in 264.151(e).
Signed letter by owner/operator or chief
financial officer as specified in 264.151(f),(h)
of applicant financial statement. If a parent
corporation is guaranteeing closure care,
corporate guarantee must accompany.
Location in
Application15
See Attached
Comment
Number0
SECTI.WPD
3-B-109
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
I-5(f) Use of Multiple Financial Mechanism
I-5(g) Use of Multiple Financial Mechanism
for Multiple Facilities
1-6 Post-Closure Cost Estimate
1-7 Financial Assurance Mechanism for
Post Closure Care
I-7a Post-Closure Trust Fund
I-7b Surety Bond
I-7b(l) Surety Bond Guaranteeing Payment
into a Post-Closure Trust Fund
Federal
Regulation
270.14(b)(15);
264.143(g)
270.14(b)(15);
264.143(h)
270.14(b)(16);
264.144
270.14(b)(16);
264.145;
264.151
270.14(b)(16);
264.145(a);
264.151(a)(l)
270.14(b)(16);
264.145(b),(c)
264.151(b),(c)
270.14(b)(16);
264.145(b);
264.1 5 l(b)
Review
Consideration"
Financial assurance instruments must meet
requirements stated in 264.143 (a),(b),(c),(d) or
(e) that include trust funds, surety bonds, letter
of credit, and insurance, respectively.
Provide financial assurance mechanism
showing amount of funds assured.
Estimate must be based on third party closing
facility and may use on-site disposal if capacity
will exist over life of facility. Estimate must be
adjusted for annual inflation as stated in
264.142(b).
Provide copy of post-closure fund agreement.
Wording requirements outlined in
264.151(a)(l).
264.145(b),(c) spells out requests for owner/
operator for adjusting estimates, inflation, and
reporting to regional administrator.
264.151(b),(c) outlines wording for bond
agreement.
Must provide bond or standby trust agreement
before beginning final closure of the facility.
Bond must guarantee owner/operator will fund
a standby trust fund or provide financial
assurance equal to penal sum.
Location in
Application15
See Attached
Comment
Number0
SECTI.WPD
3-B-110
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
I-7b(2) Surety Bond Guaranteeing
Performance of Closure
I-7(c) Post-Closure Letter of Credit
I-7(d) Post-Closure Insurance
I-7(e) Financial Test and Corporate
Guarantee for Post-Closure Care
I-7(f) Use of Multiple Financial Mechanism
I-7(g) Use of Multiple Financial Mechanism
for Multiple Facilities
1-8 Liability Requirements
Federal
Regulation
270.14(b)(16);
264.145(c);
264.151(c)
270.14(b)(16);
264.145(d);
264.151(d)
270.14(b)(16);
264.145(e);
264.151(e)
270.14(b)(16);
264.145(f);
264.151(f),(h)
270.14(b)(16);
264.145(g)
270.14(b)(16);
264.145(h)
270.14(b)(17);
264.147
Review
Consideration"
Guarantee owner/operator will perform closure
required as stated in 246.151(c) and Subpart H.
Requires letter of credit for 1 year equal to
amount of post-closure cost.
Provide copy of certificate of insurance,
wording requirement found in 264.151(e).
Signed letter by owner/operator or chief
financial officer as specified in 264.151(f),(h)
of applicant financial statement. If parent
corporation is guaranteeing post-closure care,
corporate guarantee must accompany.
Provide copy of financial assurance
mechanisms. Combined financial assurance
must be at least equal to post-closure cost
estimate.
Provide copy of financial assurance
mechanisms for more than one facility.
Amount must be no less than sum of funds that
would be available if separate mechanism had
been established and maintained for each
facility.
Location in
Application15
See Attached
Comment
Number0
SECTI.WPD
3-B-lll
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
I-8a
Coverage for Sudden Accidental
Occurrences
270.14(b)(17);
264.147(a)
Coverage must be maintained for sudden
accidental occurrences in the amount of $1
million per occurrence with an annual
agreement of at least $2 million.
Endorsement of Certification
270.14(b)(17);
264.147(a)(l)
Submit original Hazardous Waste Facility
Liability Endorsement wording pursuant to
264.151 (i), or Certificate of Liability wording
pursuant to 264.15l(j).
I-8a(2) Financial Test and Corporate
Guarantee for Liability Coverage
270.14(b)(17);
264.147(a)(2),
264.151(f),(g)
Requires signed letter by owner or chief
financial officer worded as outlined in
264.15l(g) outlining applicant financial
statement. 264.151(g) used if applicant is using
financial test to cover cost for closure or post
closure. Alternatively, owner/operator may
submit corporate guarantee specified in
264.151(h)(2).
I-8a(3)
Use of Multiple Financial Mechanism
270.14(b)(17);
264.147(a)(3)
Submit items demonstrating liability coverage
specified in I-8a(l) and I-8a(2). Amount of
coverage must total at least minimum amount
required by 264.147(a).
I-8b
Coverage for Nonsudden Accidental
Occurrences
270.14(b)(17);
264.147(b)
For high risk storage facilities, surface
impoundments, land disposal, land treatment
facilities, liability coverage must be maintained
in the amount of at least $3 million per
occurrence. Annual aggregate at least $6
million.
SECTI.WPD
3-B-112
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
I-8b(l) Endorsement or Certification
I-8b(2) Financial Test or Corporate
Guarantee for Liability Coverage
I-8b(3) Use of Multiple Insurance
Mechanism
I-8c Requests for Variance
1-9 Use of State Required Mechanisms
I-9a Use of State Required Mechanisms
Federal
Regulation
270.14(b)(17);
264.147(b)(l)
270.14(b)(17);
264.147(b)(2);
264.151(f),(g)
270.14(b)(17);
264.147(b)(3)
270.14(b)(17);
264.147(c)
270.14(b)(18)
270.14(b)(18);
264.149
Review
Consideration"
Submit signed duplicate original of Hazardous
Waste Facility Liability Endorsement.
Requires signed letter by owner or chief
financial officer worded as outlined in
264.1 5 l(g) outlining applicant financial
statement. 264.151(g) used if applicant is using
financial test to cover cost for closure or post
closure. Alternatively, owner/operator may
submit corporate guarantee specified in
264.151(h)(2).
Submit items demonstrating liability coverage
specified in I-8a(l) and I-8a(2). Amount of
coverage must total at least minimum amount
required by 264.147(b).
Request for adjusted level of required liability
must be supported by information which
demonstrates 264.147(a) or (b) are not
consistent with degree and duration of risk
associated with treatment, storage, or disposal
at facility or group of facilities.
When state has regulations equivalent or
greater liability requirements for financial
assurance for closure post-closure submit copy
of state-required financial mechanism.
Location in
Application15
See Attached
Comment
Number0
SECTI.WPD
3-B-113
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION I. CLOSURE POST-CLOSURE PLANS AND FINANCIAL REQUIREMENTS
Section and
Requirement
I-9b State Assumption of Responsibility
Federal
Regulation
270.14(b)(18);
264.150
Review
Consideration"
If state assumes legal responsibility for
compliance with closure, post-closure, or
liability requirements there must be a letter
submitted from state specifying assumption of
responsibilities and amounts of liability.
Location in
Application15
See Attached
Comment
Number0
Notes:
3 Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTI.WPD
3-B-114
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Nc
ime:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION J. SOLID WASTE MANAGEMENT UNITS
Section and
Requirement
J-l Characterize the Solid Waste
Management Unit (SWMU)
J-2 Releases
Federal
Regulation
270.14(d)(l
)
270.14(d)(2
)
Review
Consideration"
Describe methodology used to determine that no
existing or former SWMUs exist at facility if
applicable.
Provide following information concerning releases:
date of release; type, quantity, and nature of
release; groundwater monitoring and other
analytical data; physical evidence of stressed
vegetation; historical evidence of releases; any
state, local, or federal enforcement action that may
address releases; any public citizen complaints that
indicate a release; and any other information
showing the migration of the release. Describe
methodology used to determine that releases from
Location in
Application15
See Attached
Comment
Number0
Notes:
3 Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of
the information in the application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTJ.WPD
1997)
Reviewer:
3-B-115
Checklist Revision Date (December
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION K. OTHER FEDERAL LAWS
Section and
Requirement
K-l Other Federal Laws
Federal
Regulation
270.14(b)(20)
, 270.3
Review
Consideration"
Demonstrate compliance with
requirements of applicable Federal laws
such as the Wild and Scenic Rivers Act,
National Historic Preservation Act of
1966, Endangered Species Act, Coastal
Zone Management Act, and Fish and
Wildlife Coordination Act.
Location in
Application15
See attached
Comment
Number0
Notes:
3 Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTK.WPD
3-B-116
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION L. PART B CERTIFICATION
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
L-l
Part B Certification
270.11
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTL.WPD
1997)
Reviewer:
3-B-117
Checklist Revision Date (December
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION M. SUBPART AA PROCESS VENTS
Section and
Requirement
M-l Definition of Process Vent
M-2 Applicability* Process Vents
Associated with the Following Six
Operations that Manage Hazardous
Waste with Organic Concentrations
of at Least 10 Parts per Million by
Weight if these Operations are
Conducted in; a Unit Subject to the
Permitting Requirements of 270; a
Unit (including a Hazardous Waste
Recycling Unit) that is Not Exempt
from Permitting Under 262.34(a) and
is Located at a Hazardous Waste
Management Facility Otherwise
Subject to Permitting Requirements;
and a Unit that is Exempt from
Permitting Under 262.34(a)
M-2a Distillation* a Batch or Continuous
Operation Which Separates One or
More Feed Stream(s) into Two or
More Exit Streams, Each Exit Stream
Having Component Concentrations
Different from Those in the Feed
Stream(s)
Federal
Regulation
270.14(a);
264.1030;
264.1031
270.14(a);
264.1030(b);
264.1031
270.24(b)(3);
264.1030(b);
264.1031
Review
Consideration"
A process vent is any open-ended pipe
or stack that is vented to atmosphere
either directly, through a vacuum-
producing system, or through a tank.
Concentrations should be determined by
a time-weighted average annually or
when waste or process changes.
Include process description.
Location in
Application15
See Attached
Comment
Number0
SECTM.WPD
3-B-118
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION M. SUBPART AA PROCESS VENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
M-2b Fractionation* a Distillation
Operation or Method Used to
Separate a Mixture of Several
Volatile Components of Different
Boiling Points in Successive Stages
270.24(b)(3);
264.1030(b);
264.1031
Include process description.
M-2c Thin-Film Evaporation* a Distillation
Operation that Employs a Heating
Surface Consisting of a Large
Diameter Tube that May be Either
Straight or Tapered, Horizontal or
Vertical
270.24(b)(3);
264.1030(b);
264.1031
Include process description.
M-2d Solvent Extraction* an Operation or
Method of Separation in Which a
Solid or Solution Contacts a Liquid
Solvent (The Two Being Mutually
Insoluble) to Preferentially Dissolve
and Transfer One or More
Components into the Solvent
270.24(b)(3);
264.1030(b);
264.1031
Include process description.
M-2e Air Stripping* a Desorption
Operation Employed to Transfer One
or More Volatile Components from a
Liquid Mixture into a Gas (Air)
Either with or Without the
Application of Heat to the Liquid
270.24(b)(3);
264.1030(b);
264.1031
Include process description.
SECTM.WPD
3-B-119
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION M. SUBPART AA PROCESS VENTS
Section and
Requirement
M-2f Stream Stripping* a Distillation
Operation in Which Vaporization of
the Volatile Constituents of a Liquid
Mixture Takes Place by the
Introduction of Steam Directly into
the Charge.
M-3a Reduce Total Organic Emission
below 1.4 Kilogram per Hour (3
Pounds per Hour) and 2.8 Million
Grams per Year (3.1 Tons per Year),
or
M-3b Reduce Total Organic Emissions of
95 Percent by Weight with the Use of
a Control Device
M-3c Reduce Emissions for Various
Control Devices with Closed-vent
Systems under the Following
Operational Conditions:
M-3c(l) Control Device Involving Vapor
Recovery (Condenser or Adsorber)
Shall Recover at Least 95 Percent by
Weight of the Organic Vapors
Federal
Regulation
270.24(b)(3);
264.1030(b);
264.1031
270.24(b);
264.1032(a)
(l),(c)
270.24(b);
264.1032(a)
(2),(b)
270.24(b);
264.1032(a-b);
264.1033
(b-j)
270.24(b);
264.1032(a)
(l),(b)
Review
Consideration"
Include process description.
Engineering calculations or performance
tests may be used to determine vent
emissions and emissions reductions or
total organic compound concentrations
achieved by add-on control devices.
Engineering calculations or performance
tests may be used to determine vent
emissions and emissions reductions or
total organic compound concentrations
achieved by add-on control devices.
Closed-vent systems are optional
devices, but shall comply with
regulations if they are used.
A less than 95 percent recovery is
permissible if control devices meet
emission limits set in 264.1032(a)(l).
Location in
Application15
See Attached
Comment
Number0
SECTM.WPD
3-B-120
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION M. SUBPART AA PROCESS VENTS
Section and
Requirement
M-3c(2) Enclosed Combustion Device (A
Vapor Incinerator, Boiler, or Process
Heater) Shall Recover at Least 95
Percent by Weight of Organic
Emissions
M-3c(3) A Flare Shall Operate under the
Following Four Conditions: (l)No
Visible Emissions, (2) a Flame
Present at all Times, (3) an
Acceptable Net Heating Value, and
(4) Appropriate Exit Velocity
M-4 Inspection Readings Shall Be
Conducted at Least Daily. Vent
Stream Flow Information Shall be
Provided at Least Hourly.
M-4a Continuous Monitoring for the
Following Control Devices:
M-4a(l) Thermal Vapor Incinerator (One
Temperature Sensor).
M-4a(2) Catalytic Vapor Incinerator (Two
Temperature Sensor)
Federal
Regulation
270.24(d);
264.1033(c)
270.24(d);
264.1033(d)
270.24(d);
264.1033(f)
(1),(3)
270.24(d);
264.1033(f)(2)
270.24(d);
264.1033(0(2)(i)
270.24(d);
264.1033(0(2)(i)
Review
Consideration"
The device shall achieve 20 parts per
million by weight or 1/2 second
residence time at 760 • C.
Sensor shall have accuracy of ± 1
percent • C or ± 0.5 • C, whichever is
greater.
Sensor shall have accuracy of ± 1
percent • C or ± 0.5 • C, whichever is
greater.
Location in
Application15
See Attached
Comment
Number0
SECTM.WPD
3-B-121
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION M. SUBPART AA PROCESS VENTS
Section and
Requirement
M-4a(3) Flare (Heat Sensing Device)
M-4a(4) Boiler or Process Heater with Heater
Input Capacity Equal or Greater than
44 Megawatts (Recorder Which
Indicates Good Combustion
Practices)
M-4a(5) Condenser (Device with Recorder to
Measure the Concentration of
Organic Compounds in the
Condenser Exhaust Vent Stream or
Temperature Monitoring Device
Equipped with Recorder to Measure
Temperature in the Condenser
Exhaust Vent Stream)
M-4a(6) Carbon Adsoprtion System (Device
to Measure Organic Vapors or a
Recorder that Verifies Predetermined
Regeneration Cycle)
M-4b Alternate Monitoring of Control
Device
M-4c Inspection of the Following Control
Devices:
Federal
Regulation
264.1033(f)(2)(iii
)
270.24(d);
264.1033(f)(2)(v)
270.24(d);
264.1033(f)(2)(vi
)
270.24(d);
264.1033(f)(2)(vi
i)
270.24(c);
264.1033(i)
270.24(d);
264.1033(g-h)
Review
Consideration"
Sensor shall have accuracy of ± 1
percent • C or ± 0.5 • C, whichever is
greater.
Describe measurement of applicable
monitoring parameters.
Location in
Application15
See Attached
Comment
Number0
SECTM.WPD
3-B-122
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION M. SUBPART AA PROCESS VENTS
Section and
Requirement
M-4c(l) Regenerable Carbon Adsorption
System
M-4c(2) Nonregenerable Carbon Adsoprtion
System
M-5 Basic Design and Operation
M-5a The Closed-Vent System Shall be
Designed to Operate According to
Either of the Following:
M-5a(l) With No Detectable Emissions
M-5a(2) At a Pressure below Atmospheric
Pressure
Federal
Regulation
270.24(d);
264.1033(g)
270.24(d);
264.1033(h)
270.24(d);
264.1033(k)
270.24(d);
264.1033(k)(l)
270.24(d);
264.1033(k)(2)
Review
Consideration"
Carbon replacement schedule must be
acceptable.
Carbon shall be replaced when
breakthrough is observed or on an
acceptable schedule.
Emissions shall be less than 500 parts
per million above background.
System shall be equipped with at least
one pressure gauge or other
measurement device that can be read
from a readily accessible location to
verify negative pressure is being
maintained in system during operation.
Location in
Application15
See Attached
Comment
Number0
SECTM.WPD
3-B-123
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION M. SUBPART AA PROCESS VENTS
Section and
Requirement
M-5b Owner/operator Shall Monitor and
Inspect Each System
M-5c Closed-Vent System Shall be
Operated at all Times When
Emissions May be Vented to Them.
M-5d Carbon Adsorption System Used to
Control Air Pollutant Emissions
M-6 Any Components of a Closed-Vent
System that are Designated as Unsafe
to Monitor are Exempt from the
Monitoring Requirements of
1033(l)(l)(i)(B) if Certain Conditions
are Met.
Federal
Regulation
270.24(d);
264.1033(1)
270.24(d);
264.1033(m)
270.24(d);
264.1033(n)
270.24(d);
264.1033(0)
Review
Consideration"
The monitoring and inspection shall be
done: (1) by date the system is subject
to regulation, (2) annually, and (3) other
times requested by the U.S.
Environmental Protection Agency
regional administrator. Various
inspection and monitoring requirements
apply depending upon the type of
closed-vent system employed. All
detected defects shall be repaired
according to the schedule prescribed in
264.1033(1)(3).
Owner/operator must document that all
carbon that is a hazardous waste and
removed from the control device is
managed in one of these approved
manners: 264.1033(n)(l), (2), or (3).
Applies to system if its components are
unsafe to monitor and it adheres to
written plan that requires monitoring
using the procedures in
264.1033(l)(l)(ii)(B) as frequently as
practicable during safe-to-monitor times.
Location in
Application15
See Attached
Comment
Number0
SECTM.WPD
3-B-124
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION M. SUBPART AA PROCESS VENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
M-7a Owner/operator Complies with
Record Keeping Requirements
270.24(d);
264.1033;
264.1035
Depending on the type of control
devices and closed vent systems used,
various records must be maintained in
the facility operating record.
M-7b Semiannual Report is Submitted
According to Subpart AA
Requirements
270.14(a);
264.1036
A semiannual report is only required if a
control device operates outside the
design specifications.
M-7c
Implementation Schedule is Provided
270.24(a);
264.1033(a)(2)
A schedule shall be provided when
facilities cannot install a closed-vent
system and control device to comply
with Part 264 on date facility is subject
to requirements.
M-7d
Performance Test Plan is Provided
270.24(c);
264.1035(b)(3)
A performance test plan shall be
provided where owner/operator applies
for permission to use control device
other than thermal vapor incinerator,
catalytic vapor incinerator, flare, boiler,
process heater, condenser, or carbon
adsorption system, and chooses to use
test data to determine organic removal
efficiency achieved by control device.
Notes:
a Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the information in the
application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTM.WPD
3-B-125
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION N. SUBPART BB EQUIPMENT LEAKS
Section and
Requirement
N-la Applicability
N- 1 b Definition of Equipment
Federal
Regulation
270.14(a);
270.25;
264.1050(b),(d)
270.14(a);
270.25;
264.1031;
264.1051
Review
Consideration"
Except as otherwise specified, this
subpart applies to equipment that
contains or contacts hazardous waste with
organic concentrations of at least 10
percent by weight that are managed in
one of the following: if these operations
are conducted in; a unit subject to the
permitting requirements of 270; a unit
(including a hazardous waste recycling
unit) that is not exempt from permitting
under 262.34(a) and is located at a
hazardous waste management facility
otherwise subject to permitting
requirements; and a unit that is exempt
from permitting under 262.34(a) such as
a 90-day tank or container.
Examples include: valve, pump,
compressor, pressure relief device,
sampling connection system, open-ended
valve or line, or flange.
Location in
Application15
See Attached
Comment
Number0
SECTN.WPD
3-B-126
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION N. SUBPART BB EQUIPMENT LEAKS
Section and
Requirement
N- 1 c Equipment in a Vacuum or
Equipment that Contains or Contacts
Hazardous Waste with an Organic
Concentration of at Least 10 Percent
by Weight for a Period of Less than
300 Hours per Calendar Year is
Excluded from Requirements at
264. 1052 to 264. 1060.
N-2a Monthly Monitoring for Leaks
N-2b Visual Inspection for Pump Seal
Leakage on a Weekly Basis
N-2c Leak Detection
N-2d Leak Repair as Soon as Practicable
N-2e Specific Exceptions to these
Standards
Federal
Regulation
270.14(a);
270.25;
264.1050(f)
270.25(d);
264.1052(a)
(1)
270.25(d);
264.1052(a)(2)
270.25(d);
264.1052(b);
264.1063
270.25(d);
264.1052(c);
264.1059
270.25(d);
264.1052(d-f)
Review
Consideration"
Equipment shall be identified in a log in
facility's operating record as required by
264.1064(g) in order to qualify for
exclusion.
Leak detected if: (1) leak detection
instrument reads 10,000 parts per million
(ppm) or greater, or (2) there are
indications of liquid dripping from the
pump seal.
Repairs are to be made within 15
calendar days after detection. Repair
extensions are allowed under conditions
specified in 264. 1059.
Exceptions to these standards are dual
mechanical seal systems or no detectable
emissions.
Location in
Application15
See Attached
Comment
Number0
SECTN.WPD
3-B-127
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION N. SUBPART BB EQUIPMENT LEAKS
Section and
Requirement
N-3a Barrier Fluid Pressure Greater than
the Compressor Stuffing Box
Pressure
N-3b Barrier Fluid System Connected by a
Closed-Vent System to a Control
Device as Described in Subpart AA
N-3c No Detectable Atmospheric
Emissions of Hazardous
Contaminants from the Barrier
System
N-3d Sensors Checked Daily or an Audible
Alarm Checked Monthly
N-3e Leak Detection
N-3f Leak Repair as Soon as Practicable
N-3g Specific Exceptions to these
Standards
Federal
Regulation
270.25(d);
264.1053(b)
(1)
270.25(d);
264.1053(b)
(2)
270.25(d);
264.1053(b)
(3)
270.25(d);
264.1053(d-c)
270.25(d);
264.1053(f)
270.25(d);
264.1053(g)
(1); 264.1059
270.25(d);
264. 1053(h -i)
Review
Consideration"
A leak is detected if sensor indicates
failure of: (1) seal system, or (2) barrier
fluid system.
Repairs are to be made within 15
calendar days after detection. Repair
extensions are allowed under conditions
specified in 264. 1059.
Exceptions to these standards are certain
closed vent systems or no detectable
emissions.
Location in
Application15
See Attached
Comment
Number0
SECTN.WPD
3-B-128
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION N. SUBPART BB EQUIPMENT LEAKS
Section and
Requirement
N-4a Except During Pressure Releases, No
Pressure Relief Device Shall Release
Detectable Emissions
N-4b Within 5 Calendar Days after a
Pressure Release, No Detectable
Emissions Shall Emanate from
Pressure Released Device
N-4c Specific Exceptions to These
Standards
N-5a Each Sampling Connecting System
Shall Be Equipped with a Closed-
Purge, Closed Loop, or Closed-Vent
System. Closed-Vent Systems and
Control Devices are also Subject to
264.1033
N-5b Exemption for Qualified Sampling
Systems
N-6a Open-Ended Valve or Line
Federal
Regulation
270.25(d);
264.1054(a)
270.25(d);
264.1054(b)
270.25(d);
264.1054(c)
270.25(d);
264.1055(a-b);
264.1060
270.25(d);
264.1055(c)
270.25(d);
264.1056(a), (c)
Review
Consideration"
Emissions shall be less than 500 ppm
above background levels.
Emissions shall be less than 500 ppm
above background levels.
Exceptions to these standards are certain
closed vent systems.
Each closed-purge, closed-loop, or
closed-vent system shall either: (1) return
purged process fluid directly to process
line, (2) collect and recycle purged
process liquid, or (3) be designed and
operated to capture and transport all
purged process fluid to a waste
management unit or control device that
satisfies applicable requirements.
In situ sampling systems and sampling
systems without purges are exempt from
requirements of 264.1055(a),(b).
A double block or bleed system must
comply with the open-ended valve or line
requirements.
Location in
Application15
See Attached
Comment
Number0
SECTN.WPD
3-B-129
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION N. SUBPART BB EQUIPMENT LEAKS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
N-6b
Second Valve
270.25(d);
264.1056(b)
A second valve shall be operated such
that primary valve shall be closed before
second valve is opened.
N-7
Monitoring Schedule Based on
Detection of Leaks and
Predetermined Schedule
270.25(d);
264.1057(a-e)
A reading of 10,000 ppm denotes a
detected leak.
N-7d
Specific Exceptions to the
Monitoring Schedule
270.25(d);
264.0157(f-h);
264.1061;
264.1062
Exceptions to schedule include unsafe-to-
monitor valves, no detectable emissions,
and difficult-to-monitor valves.
N-8a
Monitoring
270.25(d);
264.105 8(a);
264.1063(b)
Monitoring is required within 5 days after
leak is found by sight, sound, smell, or
other detection method.
N-8b
Leak Detection
270.25(d);
264.1058(b)
A leak is detected if a leak detection
instrument reads 10,000 ppm or greater.
N-8c
Leak Repair as Soon as Practicable
270.25(d);
264.1058(c);
264.1059
Repairs are to be made within 15
calendar days after detection. The first
attempt at repair shall be made no later
than 5 calendar days after each leak is
detected. Repair extensions are allowed
under conditions specified in 264.1059.
SECTN.WPD
3-B-130
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION N. SUBPART BB EQUIPMENT LEAKS
Section and
Requirement
N-8d Any Connector that is Inaccessible or
is Ceramic or Ceramic-Lined is
Exempt from the Monitoring
Requirements of 264.1 05 8(a) and
264.1064
N-9 Specific Allowances for Delay of
Repair for Various Types of
Equipment
N-10 When Closed-Vent Systems and
Control Devices are Used, they Must
Comply with the Requirements in
Subpart AA
N-l 1 An Owner/Operator may Elect to
Comply with this Alternative
Monitoring Program
N-l 2 An Owner/Operator may Elect to
Comply with this Alternative Work
Practice
N-l 3 Owner Complies with Recordkeeping
Requirements
Federal
Regulation
270.25(d);
264.1058(e)
270.25(d);
264.1059
270.25(e);
264.1033;
264.1060
270.25(e);
264.1061
270.25(e);
264.1062
270.25(a);
264.1064
Review
Consideration"
Examples of ceramic-lined connectors
include porcelain, glass, or glass-lined
connectors.
No greater than 2 percent of the valves
are allowed to leak per monitoring
period.
Relief of monitoring frequency is allowed
if less than 2 percent of the valves are
leaking.
Depending on the type of requirement,
various records must be maintained in the
facility operating record.
Location in
Application15
See Attached
Comment
Number0
SECTN.WPD
3-B-131
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION N. SUBPART BB EQUIPMENT LEAKS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
N-13a
Semiannual Report
270.25(a);
264.1065
A semiannual report is only required if
leaks from equipment have gone
unrepaired or a control device operates
outside the design specifications.
N-13b
Implementation Schedule
270.25(b)
An implementation schedule shall be
provided if facility cannot install closed-
vent system and control device to comply
with provisions of Part 264, Subpart BB
on the effective date that facility becomes
subject to provisions of Parts 264 and
265.
N-13c
Performance Test Plan
270.25(c)
A performance test plan shall be provided
if the owner/operator applies for
permission to use a control device for
other than a thermal vapor incinerator,
flare, boiler, process heater, condenser,
or carbon adsorption system and chooses
to use test data to determine the organic
removal efficiency achieved by the
control device.
Notes:
3 Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTN.WPD
3-B-132
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-l Standards Apply to All Facilities That
Treat, Store, or Dispose of Hazardous
Waste in Tanks, Surface
Impoundments, or Containers Subject
to 264, Subparts I, J, or K, Except as
Provided Otherwise
O-2 Following is a List of Units that are
Exempt from the 264. 1084-264. 1087
Standards:
O-2a A Tank, Surface Impoundment, or
Container for Which All Hazardous
Waste Entering the Unit Has an
Average Volatile Organic
Concentration at the Point of Waste
Origination of less than 500 Parts per
Million by Weight (ppmw)
O-2b A Tank, Surface Impoundment, or
Container for Which the Organic
Content of all the Hazardous Waste
Entering the Waste Management Unit
has been Reduced by an Organic
Destruction or Removal Process that
Achieves Specified Criteria
Federal
Regulation
270.14(a);
270.27;
264.1080 (a)-
(d)
270.14(a);
270.27;
264.1082(c)
270.14(a);
270.27;
264.1082(c)(l)
270.14(a);
270.27;
264.1082(c)(2)
Review
Consideration"
Exclusions from 264.1080(a) are listed at
264.1080(b) (e.g., a container that has a design
capacity less than or equal to 0. 1 cubic meters
[m3]).
Waste determination procedures are specified at
264.1083.
Waste determination procedures are specified at
265.1084(b)(2)-(b)(9).
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-133
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-2c A Tank Used for Biological
Treatment of Hazardous Waste that
Destroys or Degrades the Organics
Contained in the Hazardous Waste
such that the Requirements of
264.1082(c)(2)(iv)areMet
O-2d A Tank, Surface Impoundment or
Container for Which all Hazardous
Waste Placed in the Unit Meets
Applicable Organic Concentration
Limits or has been Treated by
Appropriate Treatment Technology
O-2e A Tank Located Inside an Enclosure
Vented to a Control Device that is
Used for Bulk Feed of Hazardous
Waste to a Waste Incinerator that
Meets Specified Criteria
O-3 Several Waste Determination
Procedures are Explained in Detail
and Must be Followed in Order to
Demonstrate the Various Subpart CC
Exemptions and/or Control
Requirements
Federal
Regulation
270.14(a);
270.27;
264.1082(c)(3)
270.14(a);
270.27;
264.1082(c)(4)
270.14(a);
270.27;
264.1082(c)(5)
270.14(a);
270.27;
264.1083;
265.1084
Review
Consideration"
Waste determination procedures are specified at
264.1083(b) and264.1083(a).
Waste determination procedures are specified at
Part 268.
Design and operation of the control device and
enclosure shall satisfy Part 61, Subpart FF;
52.741, Appendix B; and other conditions as
specified.
In general, an owner or operator need not
undergo waste determination procedures unless
they are pursuing an exemption from the Subpart
CC regulations.
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-134
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-4 Tanks that Satisfy the Conditions at
264.1084(b)(l)(i-iii) Can Use Tank
Level 1 or Tank Level 2 Controls.
Tanks that do not Satisfy Conditions
Shall Use Tank Level 2 Controls
O-5a The Conditions at 264.108(b)(l)(i-iii)
Provide that Hazardous Waste in the
Tank Shall:
O-5a(l) Have Maximum Organic Vapor
Pressure Which is less than
Maximum Organic Vapor Pressure
Limit for Tank's Design Capacity
Category
O-5a(2) Not be Heated to Temperature
Greater than Temperature at Which
Maximum Organic Vapor Pressure of
Waste is Determined for Purposes of
Compliance
O-5a(3) Not be Treated Using a Waste
Stabilization Process, as Defined in
265.1081
Federal
Regulation
270.14(a);
270.27;
264.1084(b)(l),
(2)
270.14(a);
270.27;
264.1084(b)(l)
270.14(a);
270.27;
264.1084(b)(l)
(1)
270.14(a);
270.27;
264.1084(b)(l)
(11)
270.14(a);
270.27;
264.1084(b)(l)
(in)
Review
Consideration"
A waste stabilization process includes mixing
hazardous waste with binders or other materials,
and curing resulting hazardous waste and binder
mixture.
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-135
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-5b Maximum Organic Vapor Pressure
Determination
O-5b(l) Tank Level 1. Owner/Operator Shall
Equip Tanks with Fixed Roof and
Closure Devices as Needed
O-5b(2) Tank Level 2. Owner/Operator Shall
Use One of the Following Tanks:
O-5b(2)(i) Fixed Roof Tank Equipped with
Internal Floating Roof
O-5b(2)(ii) Tank Equipped with an External
Floating Roof
Federal
Regulation
270.14(a);
270.27;
264.1084(c)(l)
270.14(a);
270.27;
264.1084(c)
(2), (3)
270.14(a);
270.27;
264.1084(d)
270.27(a)(l);
264.1084(d)(l)
(e)
270.27(a)(l);
264.1084(d)(2),
(f)
Review
Consideration"
Must be determined before first time waste placed
in tank, and retested whenever changes could
cause it to increase above the maximum vapor
pressure limit [264.1084(b)(l)(i)].
Fixed roof/closure devices shall form continuous
barrier over entire waste in tank; contain no
visible open spaces between roof section joints or
between interface of roof edge and tank wall;
contain openings with closure devices or closed-
vent system; and be made of suitable materials.
Internal floating roof shall be designed to float on
liquid surface, except when supported by leg
supports; be equipped with continuous seal
between tank wall and floating roof edge; and
meet other design specifications.
External floating roof shall be designed to float on
all liquid surface, except when supported by leg
supports; be equipped with two continuous seals;
and meet other design specifications.
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-136
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-5b(3) Tank Vented Through Closed-Vent
System to a Control Device
O-5c Pressure Tank
O-5d Tank Located Inside an Enclosure
that is Vented Through a Closed-
Vent System to an Enclosed
Combustion Control Device
O-5e Tank Level 1. Owner/Operator Shall:
O-5e(l) Determine Maximum Organic Vapor
Pressure for Hazardous Waste
Initially and Whenever Changes
could Cause the Vapor Pressure to
Increase Above the Maximum
Organic Vapor Pressure Limit
Federal
Regulation
270.14(a);
270.27;
264.1084(d)(3),
(g)
270.14(a);
270.27;
264.1084(d)(4),
(h)
270.14(a);
270.27;
264.1084(d)(5),
(1)
270.14(a);
270.27;
264.1084(c)
(1),(3)
270.14(a);
270.27;
264.1084(c)(l)
Review
Consideration"
Fixed roof/closure devices shall form continuous
barrier over entire liquid surface; be made of
suitable materials; and satisfy 264.1087 standards.
Tank shall be designed not to bend to atmosphere
as result of compression of vapor headspace in
tank, and be equipped with closure devices as
needed.
Tank shall be located in enclosure that is vented
through closed vent system to enclosed
combustion device, and enclosure shall be
equipped with safety devices as needed.
Maximum organic vapor pressure shall be
determined using 264.1083(c) procedures.
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-137
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-5e(2) Ensure that, Whenever Hazardous
Waste is in Tank, the Fixed Roof is
Installed with Each Closure Device
Secured in Closed Position
O-5e(3) Inspect the Air Emission Control
Equipment
O-5f Tank Level 2. Owner/Operators
Shall Adhere to the Following
Operating Procedures for Each Unit
Type:
O-5f(l) Fixed Roof Tank Equipped with
Internal Floating Roof
O-5f(2) Tank Equipped with an External
Floating Roof
Federal
Regulation
270.14(a);
270.27;
264.1084(c)(4)
270.14(a);
270.27;
264.1084(e)(i)
270.14(a);
270.27;
264.1084(e)
(2),(3)
270.14(a);
270.27;
264.1084(f)
(2),(3)
Review
Consideration"
Exceptions are listed at 264.1084(c)(3)(i-iii).
When floating roof is resting on leg supports,
filling, emptying, or refilling shall be continuous
and completed as soon as practical; when roof is
floating, automatic bleeder vents shall be set
closed; and prior to filling, openings in roof shall
be secured. Inspect the floating roof.
When floating roof is resting on leg supports,
filling, emptying, or refilling shall be continuous
and completed as soon as practical; when closure
device is open for access, equipment and devices
shall be closed and secured as specified; and seals
shall provide a continuous and complete cover as
specified. Inspect the floating roof.
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-138
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Application11
See Attached
Comment
Number0
O-5f(3) Tank Vented Through Closed-Vent
System to a Control Device
270.14(a);
270.27;
264.1084(g)
(2), (3)
When hazardous waste is in tank, fixed roof shall
be installed with closure devices secured in closed
position and vapor headspace underneath fixed
roof vented to control device, except as specified.
Inspect and monitor the air emission control
equipment.
O-5f(4)
Pressure Tank
270.14(a);
270.27;
264.1084(h)
(2), (3)
When hazardous waste is in tank, it shall be
operated as closed system that does not vent to
atmosphere, except to avoid an unsafe condition.
O-5f(5) Tank Located Inside an Enclosure
that is Vented Through a Closed-
Vent System to an Enclosed
Combustion Control Device
270.27(a)(3),
264.1084(i)
Enclosure shall be operated in accordance with
52.741, Appendix B, and comply with applicable
closed-vent requirements. Safety devices may be
operated as needed. Inspect and monitor the
system and control device.
O-5f(6) Shall be Conducted Using
Continuous Hard-Piping or Another
Closed System that Does Not Allow
Exposure of Hazardous Waste to
Environment
270.14(a);
270.27;
264.1084(j)(l)
Requirements do not apply under the conditions
specified at 264.1084(j)(2).
O-6a
Owner/Operators Shall Install Either
of the Following Controls:
270.14(a);
270.27;
264.1085(b)(d)
SECTO.WPD
3-B-139
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-6a(l) Floating Membrane Cover
O-6a(2) Cover That Is Vented Through a
Closed-Vent System to a Control
Device
O-6b Owner/Operators Shall Adhere to the
Following Operating Procedures for
Each Control Type:
O-6b(l) Floating Membrane Cover
Federal
Regulation
270.27(a)(4);
264.1085
(b)(l), (c)(l)
270.14(a);
270.27;
264.1085
(b)(2) and
(d)(2)
270.14(a);
270.27;
264.1085
(c), (d)
270.14(a);
270.27;
264.1085(c)
(2), (3)
Review
Consideration"
Floating membrane cover shall float on liquid
surface and form continuous barrier over entire
liquid; be made of synthetic membrane material;
contain no visible open spaces; and be equipped
with closure devices and cover drains as needed.
Cover/closure devices shall form continuous
barrier over entire liquid surface; be equipped
with closure device; be made of suitable material;
and be designed in compliance with 264.1087.
When hazardous waste is in surface
impoundment, floating membrane cover shall
float on liquid, and each closure device shall be
secured in closed position, except as specified.
Inspect the cover.
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-140
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-6b(2) Cover that is Vented Through a
Closed-Vent System to a Control
Device
O-7 Shall be Conducted Using
Continuous Hard-Piping or Another
Closed System
O-8a Container Level 1 Standards Apply
to:
O-8a(l) Container with Design Capacity
Greater than 0. 1 m3 and less than or
Equal to 0.46 m3
O-8a(2) Container with Design Capacity
Greater than 0.46 m3 that is not in
Light Material Service
Federal
Regulation
270.14(a);
270.27;
264.1085(d)
(2), (3)
270.14(a);
270.27;
264.1085(c)
(1)
270.14(a);
270.27;
264.1086(b)(l)
270.14(a);
270.27;
264.1086(b)(l)
(1)
270.14(a);
270.27;
264.1086(b)(l)
(11)
Review
Consideration"
When hazardous waste is in surface
impoundment, cover shall be installed with each
closure device secured in closed position and
vapor headspace underneath the cover vented to
control device, except as specified. Closed-vent
system and control device shall be operated in
accordance with 264.1087. Inspect and monitor
the control device.
Requirements do not apply under conditions
specified at 264. 1085(e)(2).
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-141
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-8ab Container Level 2 Standards Apply
to Container with a Design Capacity
Greater than 0.46 m3 that is in Light
Material Service
O-8c Container Level 3 Standards Apply
to Container with Design Capacity
Greater than 0. 1 m3 that is Used for
Stabilization
O-9 Identify Each Container Area Subject
to Subpart CC
O-9a Container Level 1 . A Container
Using Level 1 Controls is Defined as
One of the Following:
O-9a(l) Container that Meets Department of
Transportation Regulations on
Packaging
O-9a(2) Container Equipped with Cover and
Closure Devices
O-9a(3) Open-Top Container Equipped with
Organic-Vapor Suppressing Barrier
Federal
Regulation
270.14(a);
270.27;
264.1086(b)(l)
(in)
270.14(a);
270.27;
264.1086(b)(2)
270.27(a)(2)
270.27(a)(2);
264.1086(c)
(1)
270.27(a)(2);
264.1086(c)
(l)(i),(f)
270.27(a)(2);
264.1086(c)
(l)(ii),(2)
270.27(a)(2);
264.1086(c)
(l)(iii),(2)
Review
Consideration"
Level 3 standards apply at those times during
waste stabilization process when hazardous waste
in container is exposed to atmosphere.
Container shall meet Part 178 or Part 179 and be
managed in accordance with Parts 107, 172, 173,
and 180.
Container shall be equipped with covers and
closure devices, as needed.
Container shall be equipped with covers and
closure devices, as needed.
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-142
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-9b Container Level 2. A Container
Using Level 2 Controls is Defined as
One of the Following:
O-9b(l) Container that Needs Department of
Transportation (DOT) Regulations on
Packaging
O-9b(2) Container that Operates with No
Detectable Organic Emissions
O-9b(3) Container that has been
Demonstrated Within the Preceding
12 Months to be Vapor-Tight
O-9c Container Level 3. A Container
Using Level 3 Controls is Defined as
One of the Following:
O-9c(l) Container that is Vented Directly
Through a Closed-Vent System to a
Control Device
O-9c(2) Container that is Vented Inside an
Enclosure Which is Exhausted
Through a Closed-Vent System to a
Control Device
Federal
Regulation
270.27(a)(2);
264.1086
(d)(l)(f),(g)
270.27(a)(2);
264.1086(d)(l)
(i),(0
270.27(a)(2);
264.1086(d)(l)
(ii),(g)
270.27(a)(2);
264.1086(d)(l)
(iii) and (h)
270.27(a)(2);
264.1086(e)
(1), (2)
270.27(a)(2);
264.1086(e)
(1)0)
270.27(a)(2);
270.27(a)(3);
264.1086(e)
(l)(ii)
Review
Consideration"
Containers shall meet Part 178 or Part 179, and be
managed in accordance with Parts 107, 172, 173,
and 180.
Owner/operator shall follow the procedures at
264.1086(g) and 265.1084(d) to determine no
detectable organic emissions.
Owner/operator shall follow procedures at
264.1086(h) and Part 60, Appendix A, Method 27
to demonstrate container is vapor-tight.
The closed-vent system and control device shall
be designed in accordance with 264. 1087. Safety
devices may be installed as needed.
The container/enclosure must be designed in
accordance with 52.741, Appendix B and
264.1087. Safety devices may be installed as
needed.
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-143
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-lOa Container Level 1 . Owner/Operators
Shall Install Covers and Closure
Devices for the Container and Secure
and Maintain Each Closure Device in
Closed Position, Except as Specified
O-lOb Container Level 2. Owner/Operator
Shall Install All Covers and Closure
Devices for the Container and
Maintain and Secure Each Closure
Device in Closed Position, Except as
Specified
O-lOc Container Level 3. Owner/Operators
Shall Operate the System in
Accordance with 52.741, Appendix
B; 264.1087; and 265. 1081, as
Needed
O-l la Standards Apply to Each Closed-
Vent System and Control Device
Used to Control Air Emissions under
Part 264; Subpart CC
O-l l(b) Closed-Vent Systems Shall:
O-l lb(l) Route Gases, Vapors, and Fumes to
Control Device
Federal
Regulation
270.14(a);
270.27;
264.1086(c)
(3), (4)
270.14(a);
270.27;
264.1086(d)(2),
(3)
270.14(a);
270.27;
264.1086(e)
(3),(4), (5)
270.14(a);
270.27;
264.1087(a)
270.27(a)(5);
264.1087(b)
270.27(a);
264.1087(b)(l)
Review
Consideration"
The closure device or cover may be opened for
the purpose of adding or removing hazardous
waste or for maintenance or to avoid unsafe
conditions.
Transfer of hazardous waste in or out of container
shall be conducted in such a manner as to
minimize exposure to atmosphere, as practical.
The closure device or cover may be opened for
the purpose of adding or removing hazardous
waste or for maintenance or to avoid unsafe
conditions.
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-144
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-l lb(2) Be Designed and Operated in
Accordance with 264.1033(k)
O-l lb(3) Meet the Requirements for Bypass
Devices, if Applicable
O-12a The Control Device Shall be One of
the Following:
O-12a(l) A Control Device Designed and
Operated to Reduce Total Organic
Content on Inlet Vapor Stream
Vented to the Control Device by at
Least 95 Percent by Weight
O-12a(2) An Enclosed Combustion Device
O-12a(3) A Flare
Federal
Regulation
270.27(a);
264.1087(b)(2)
270.27(a);
264.1087(b)(3)
270.27(a)(5);
264.1087(c)(l)
270.27(a)(5);
264.1087(c)
(l)(i)
270.27(a)(5);
264.1087(c)
(l)(n)
270.27(a)(5);
264.1087(c)
(l)(iii)
Review
Consideration"
The Subpart AA standards for closed-vent systems
must be satisfied.
Each bypass device shall be equipped with either
a flow indicator or a seal or locking device.
Owner/operator shall demonstrate compliance
using either performance test or design analysis,
except as specified.
Owner/operator shall demonstrate compliance
using either performance test or design analysis,
except as specified. Control device shall be
designed and operated in accordance with
264.1033(c).
Owner/operator shall demonstrate compliance
using either performance test or design analysis,
except as specified.
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-145
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O- 1 2b Each Closed-Vent System and
Control Device Shall Comply with
the Operating Requirements of
264.1087(c)(2)
O-12c A Carbon Adsorption System
O-12d Each Control Device Shall be
Operated and Maintained in
Accordance with 264.1033(j), Except
for Certain Devices Identified (e.g.,
Flare)
O- 1 2e The Owner/Operator Shall
Demonstrate that a Control Device
Achieves the Performance
Requirements Using a Performance
Test or Design Analysis, Except for
Specific Devices Identified (e.g.,
flare)
Federal
Regulation
270.27(a)(5);
264.1087(c)
(2)
270.27(a)(5);
264.1087(c)
(3)
270.27(a)(5);
264.1087(c)
(4)
270.27(a)(5);
264.1087(c)
(5)
Review
Consideration"
Planned routine maintenance of control device
shall not exceed 240 hours per year; system
malfunctions shall be corrected as soon as
practicable; and system shall be operated such that
gases, vapors, or fumes are not actively vented to
control device during planned maintenance or
system malfunction, except as specified.
Carbon replacement and removal shall follow
prescribed requirements in 264.1033(g), (h), and
(n).
264.1033(j) requires the owner/operator to
prepare documentation describing the control
device's operation and to identify the process
parameter(s) that indicate its proper operation and
maintenance.
For performance test, owner/operator shall use the
test specified at 264. 103(c). For design analysis,
owner/operator shall use an analysis that meets
requirements specified at 264.1035(b)(4)(iii). In
addition, the U.S. Environmental Protection
Agency (EPA) prescribes unit-specific
performance demonstration requirements for
certain unit types at 264.1087(c)(5).
Location in
Application15
See Attached
Comment
Number0
SECTO.WPD
3-B-146
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Application11
See Attached
Comment
Number0
O-12f If Design Analysis is Not Sufficient,
then a Performance Test is Required
270.27(a)(5);
264.1087(c)(6)
The EPA regional administrator shall determine if
a performance test is required to demonstrate
control device's performance.
O-12h Inspect and Monitor the Control
Device
270.27(a)(5);
264.1087(c)(7)
Control devices shall be inspected and monitored
at least once a day.
O-13
Each Tank, Surface Impoundment
and Container Shall be Inspected,
Monitored, and Repaired in
Accordance with the 264 Subpart CC
Requirements
270.27;
264.1088
Inspection, monitoring and repair requirements
specific to each unit are located in the standards
sections of the regulation 264.1084 through
264.1087. Owner/operator shall develop and
implement written plan and schedule to perform
inspections and monitoring required. The plan
and schedule shall be incorporated into facility's
inspection plan.
O-14
Each Owner/Operator Shall Comply
with the Recordkeeping
Requirements Specified at 264.1089
270.27;
264.1089
Except as specified, records shall be maintained in
facility's operating record for a minimum of 3
years. Various records are required depending on
the type of unit and control device.
O-14a Each of the Following
Owner/Operators Shall Comply with
the Reporting Requirements at
264.1090:
270.27;
264.1090
SECTO.WPD
3-B-147
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION O. SUBPART CC AIR EMISSION STANDARDS
Section and
Requirement
O-14a(l) Each Owner/Operator Managing
Hazardous Waste in a Tank, Surface
Impoundment, or Container
Exempted from Using Air Emission
Controls under 264.1082(c)
O-14a(2) Each Owner/operator Using Air
Emission Controls on a Tank in
Accordance with 264.1084(c)
O-14a(3) Each Owner/operator Using a
Control Device in Accordance with
264.1087
O-14b Each Owner/Operator shall Provide
an Emission Monitoring Plan
O-14c Subpart CC Implementation Plan
Federal
Regulation
270.27;
264.1090(a)
270.27;
264.1090(b)
270.27;
264.1090
(c),(d)
270.27(a)(6)
270.27(a)(7)
Review
Consideration"
Owner/operator shall report to EPA each
noncompliance identified under 264. 1082(c).
Owner/operator shall report to EPA each
noncompliance identified under 264.1084(B).
Owner/operator shall submit semiannual written
report to EPA, except as specified.
Applies to Method 21 and control device
monitoring methods.
Required when facility cannot comply with
Subpart CC by date of permit issuance.
Location in
Application15
See Attached
Comment
Number0
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTO.WPD
3-B-148
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
Note: This checklist may be used for review of a permit application for a postclosure facility with no active hazardous waste management units. It provides a guideline to the basic
requirements of a Part B postclosure permit application. Optional elements (contingency plan and personnel training) are indicated by italics. If a postclosure unit is present
at a facility seeking a permit for active hazardous waste management units, the postclosure unit must be incorporated in the permit application like an operating unit in all
appropriate sections. For elements that may repeat for both operating units and postclosure units, this checklist references elements of the general checklist in parenthesis.
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
P-l General Part A Information
Requirements
P-l a Description of Activities Conducted
which Require Facility to Obtain a
Permit under the Resource
Conservation and Recovery Act
(RCRA) and Brief Description of
Nature of the Business
P-lb Name, Mailing Address, and Location
of Facility for which the Application
is Submitted, including a Topographic
Map
P-lc Up to four Standard Industrial
Classification Codes which Best
Reflect the Products or Services
Provided by the Facility
P-ld Operator/Owner's Name, Address,
Telephone Number, and Ownership
Status
P-le Facility is New, Existing, or Located
on Indian Lands
Federal
Regulation
270.13(a),(m)
270.13(b),(l)
270.13(c)
270.13(d),(e)
270.13(f),(g)
Review
Consideration"
(Section A)
(A-l)
(A-2)
(A-3)
(A-4) Ownership status must include status
as federal, state, private, public, or other
entity.
(A-5) Description must include information
on whether this is a first or revised
application with date of last signed permit
application.
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-149
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
P-lf Description of Processes to be Used
for Treating, Storing, and Disposing
of Hazardous Waste
P- 1 g Specification of the Hazardous
Wastes Listed or Designated Under
261
P-lh Listing of all Permits or Construction
Approvals Received or Applied for
P-2 Part B General Description
P-3 General Requirements
P-3a Topographic Map
Scale and Date
The 100-Year Flood Plain Area
Federal
Regulation
270.13(1)
270.13(j)
270.13(k)
270.14(b)(l)
270.14
270.14(b)(19)
270.14(b)(19)(i)
270.14(b)(19)(ii)
Review
Consideration"
(A-6) Description must include design
capacity for these items.
(A-7) Specifications must include estimate
on quantity of waste to be treated, stored, or
disposed of.
(A- 8) Permits include the following
programs: Hazardous Waste Management
under RCRA; Underground Injection
Control under Solid Waste Disposal Act;
Prevention of Significant Deterioration,
Nonattainment Program, and National
Emissions Standards for Hazardous
Pollutants under the Clean Air Act; ocean
dumping permits under the Marine
Protection Research and Sanctuaries Act;
dredge and fill permits under Section 404 of
the Clean Water Act; or other relevant
environmental permits including state
permits.
(Section B)
(B-l)
(B-2a) Show distance of 1,000 feet around
unit at a scale of 1 inch to not more than 200
feet (multiple maps may be submitted at this
scale), and should be similar to Part A
topographic map.
Other scales may be used if justified.
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-150
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
Surface Waters
Surrounding Land Use
Wind Rose
Map Orientation
Legal Boundaries
Access Control
Injection and Withdrawal Wells (on
site and off site)
Buildings and Other Structures
Drainage and Flood Control Barriers
P-3b Additional Information on the
Topographic Map for Land Disposal
Facilities
Uppermost Aquifer and Hydraulically
Connected Aquifers Beneath Facility
Property
Groundwater Flow Direction
Waste Management Areas
Property Boundaries
Location of Groundwater Monitoring
Wells
Extent of any Groundwater
Contaminant Plume
Federal
Regulation
270.14(b)(19)(iii)
270.14(b)(19)(iv)
270.14(b)(19)(v)
270.14(b)(19)(vi)
270.14(b)(19)(vii
)
270.14(b)(19)(viii
)
270.14(b)(19)(ix)
270.14(b)(19)(x)
270.14(b)(19)(xi)
270.14(c)(3)
270.14(c)(2)
270.14(c)(2)
270.14(c)(3)
270.14(c)(3)
270.14(c)(3);
264.97
270.14(c)(4)(i)
Review
Consideration"
(B-2b)
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-151
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
P-3c Facility Location Information
P-3c(l) Political Jurisdiction in which Facility
is Located
P-3c(2) Flood Plain Requirements
Copy of Federal Insurance
Administration or other Flood Map
Concentration of Hazardous
Constituents Remaining in the Unit
that Would Potentially Affect Surface
Waters as a Result of Washout
Impact of such Concentration on
Current or Potential uses of, and
Water Quality Standards Established
for, the Affected Surface Waters
Impact of Hazardous Constituents on
the Sediments of Affected Surface
Waters, or the Soils of the 100-Year
Flood Plain, that could Result from
Washout
Plan and Schedule for Future
Compliance
P-4a Chemical and Physical Analyses
Federal
Regulation
270.14(b)(ll);
264.18
270.14(b)(ll)(i)
270.14(b)(ll)(iii)
,(iv);264.18(b)
270.14(b)(ll)(iii)
270.14(b)(ll);
264.18(b)(ii)(B)
270.14(b)(ll);
264.18(b)(ii)(C)
270.14(b)(ll);
264.18(b)(ii)(D)
270.14(b)(ll)(v)
270.14(b)(2);
264.13(a)
Review
Consideration"
(B-3)
(B-3a)
(B-3b) Flood plain requirements applicable
if facility is located in 100-year flood plain.
Reference source used to determine whether
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain.
Flood plain requirements applicable if
facility is located in 100-year flood plain
and not in compliance with 264.18(b).
(C-l) Data generated by testing the waste,
published data on the waste, or data
gathered from similar processes may be
used.
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-152
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
P-4b
Waste Analysis Plan
270.14(b)(3);
264.13(b),(c)
266.102(a)(2)(ii);
266.104(a); (2),
268.7
(C-2) Address how for closed units/facilities,
a waste analysis plan is not applicable.
Discuss previous waste stream and/or
current management of the waste, if
applicable. Discuss whether or not leachate
or runoff collection and analysis are
necessary.
P-5
General Hydrogeologic Information
270.14(c)(2)
(E-3) Include description of the regional and
site-specific geologic and hydrogeological
setting.
P-5a
Topographic Map Requirements
270.14(c)(2),(3),
(E-4)
P-5b
Contaminant Plume Description
270.14(c)(2),(4),
(7); Part 261,
Appendix VIII
(E-5) In some cases, contaminant plumes
may be defined under groundwater quality
assessment programs carried out during the
interim status period which may not address
the complete list of Appendix VIII
constituents as required under 270.14(c)(4).
Additional monitoring may be required to
identify the concentration of each Appendix
VIII constituent in the plume.
P-5c
General Monitoring Program
Requirements
270.14(c)(5);
264.90(b)(4);
264.97
(E-6) Describe the monitoring to be
conducted during the post-closure care
period, including as applicable, the
procedures for conducting the following
operations and evaluating the data gathered:
groundwater monitoring; and leachate
collection/detection and removal.
SECTP.WPD
3-B-153
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
P-5d
Description of Wells
270.14(c)(6)(ii);
264.97(a), (b), (c)
(E-6a) Identify the number, location, and
depth of each well, and describe the well
construction materials to be used.
P-5e
Proposed Sampling and Statistical
Analysis Procedures for Groundwater
Data
270.14(c)(7)(vi);
264.97(d), (e),
(f); 264.99(c) -
(g)
(E-6b)
P-5f
Corrective Action Program
270.14(c)(8);
264.99(j);
264.100
(E-a) If hazardous constituents have been
detected in the groundwater, an owner or
operator must submit sufficient information,
supporting data, etc., to establish a
corrective action program that meets the
requirements of 264.100.
P-5g
Characterization of Contaminated
Groundwater
270.14(c)(8)(i)
(E-9a) For each well at point of compliance
and for each background well, provide
concentrations of each constituent in 261
Appendix VIII, major cations and anions,
and constituents listed in Table 1 of 264.94,
if not already determined by the above.
P-5h
Concentration Limits
270.14(c)(8)(ii);
264.94;
264.100(a)(2)
(E-9b) Specify the proposed concentration
limits for each hazardous constituent in
groundwater.
P-5i
Alternate Concentration Limits
270.14(c)(8)(ii);
264.94(b);
264.100(a)(2)
(E-9c) Provide a justification for establishing
alternate concentration limits. This
justification must address each of the
following two factors.
SECTP.WPD
3-B-154
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
P-5j Corrective Action Plan
P-6 Security
P-6a Security Procedures and Equipment
P-6a(l) Warning Signs
Federal
Regulation
270.14(c)(8)(m);
264.100(b);
264.101
270.14(b)(4);
264.14
270.14(b)(4);
264.14
270.14(b)(4);
264.14(c)
Review
Consideration"
(E-9d) Provide detailed plans on the
corrective actions proposed for the facility,
including maps of engineered structures,
construction details, plans for removing
waste, description of treatment technologies,
effectiveness of correction program,
operation and maintenance plans, closure
and post-closure plans, and a schedule for
corrective action requirements. Also,
include plan for corrective action at solid
waste management units (SWMU).
(F-l) Indicate whether hazardous waste
remains exposed after completion of partial
or final closure or access by the public or
domestic livestock may pose a hazard to
human health. Demonstrate that this type of
property post-closure use must never be
allowed to disturb the integrity of the final
cover, liner(s), or any other components of
the containment system, or the function of
the facility's monitoring system.
(F-l a) Unless waiver is granted, facility must
have surveillance system or barrier or other
means to control entry.
(F-la(3)) Signs in English must be posted at
each entrance, and be legible from 25 feet.
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-155
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
P-6b
Inspection Schedule
270.14(b)(5);
264.15
(F-2) Include where applicable, as part of
the post-closure inspection schedule,
specific requirements for each type of
treatment, storage, and disposal facility.
These specific requirements and the
schedule should be included as part of the
post-closure plan.
P-6b(l)
General Inspection Requirements
270.14(b)(5);
264.15(a), (b);
264.33
(F-2a) Describe the inspections to be
conducted during the post-closure care
period, their frequency, the inspection
procedure, and the logs to be kept.
Inspection is required for monitoring
equipment, safety emergency equipment,
communication and alarm systems,
decontamination equipment, security
devices, and operating and structural
equipment. Should be included as part of
post-closure plan.
Types of Problems
270.14(b)(5);
264.15(b)(3)
Inspection checklist should be included as
part of post-closure plan and must identify
types of problem.
Frequency of Inspections
270.14(b)(5);
264.15(b)(4)
The rationale for determining the length of
time between inspections should be
provided as part of the post-closure plan.
Schedule of Remedial Action
264.15(c)
Owner/operator must immediately remedy
any deterioration or malfunction of
equipment or structures to ensure problem
does not lead to environmental or human
health hazard.
SECTP.WPD
3-B-156
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
Inspection Log
P-7a Waiver or Documentation of
Preparedness and Prevention
Requirements
P-7b Emergency Equipment
P-7c Water and Fire Control
P-7d Testing and Maintenance of
Equipment
P-7e Documentation of Arrangements with
Emergency Agencies
P-7f Document Agreement Refusal
P-7g Equipment and Power Failure
P-8 Contingency Plan General
Information
Federal
Regulation
264.15(d)
270.14(b)(6)
264.32(a) - (d)
270.14(a);
264.32(c)
270.14(a);
264.32(d)
270. 14(a); 264.33
270. 14(a); 264.37
270.14(a);
264.37(b)
270.14(b)(8)
(IV)
270.14(b)(7);
264.52
Review
Consideration"
Provide example log or summary. Should
be included as part of the post-closure plan.
(F-3) Facility must submit justification for
any waiver to requirements of this section.
(F-3(a)(3)) Demonstrate that portable fire
extinguishers, fire control equipment, spill
control equipment, and decontamination
equipment are available.
(F-3(a)(4)) Demonstrate facility has
adequate fire control systems, water volume
and pressure, foaming equipment, automatic
sprinklers, etc.
(F-3(a)(5)) Demonstrate communication,
alarm, fire control equipment, spill control
equipment, and decontamination equipment
are tested and maintained.
(F-3(c)) Owner/operator must make
arrangements, as appropriate, with type of
waste and hazard potential, for the potential
need for services.
(F-3(c)(4)) Document refusal to enter into a
coordination agreement.
(F-4(d)) Describe procedure used to mitigate
the effects of equipment failure and power
outages.
(G-l) Provide facility name and location,
operator, site plan, and describe facility
operations.
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-157
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
Actions to Take in Case of Emergency
P-8a Emergency Coordinators
P-8b Implementation
P-8c Emergency Actions
P-8c(l) Notification
P-8c(2) Identification of Hazardous Materials
P-8c(3) Assessment
P-8c(4) Control Procedures
P-8c(5) Storage, Treatment, and Disposal of
Released Material
Federal
Regulation
270.14(b)(7);
264.52(a)
270.14(b)(7);
264.52(d);
264.55
270.14(b)(7);
264.52(a);
264.56(d)
270.14(b)(7);
264.56
270.14(b)(7);
264.56(a)
270.14(b)(7);
264.56(b)
270.14(b)(7);
264.56(c),(d)
270.14(b)(7);
264.52(a)
270.14(b)(7);
264.56(g)
Review
Consideration"
(G-4(d)) Describe actions to be taken in
response to any unplanned release of
hazardous waste to air, soil, or surface
water.
(G-2) There must at least be one primary
emergency coordinator available at all
times.
(G-3) Emergency coordinator to determine
that facility has had a release, fire, or
explosion that could threaten human health
or the environment outside facility.
(G-4)
(G-4a) Describe the method for immediate
notification of facility personnel and
necessary state and local agencies.
(G-4b) Observation, records or manifest, or
chemical analysis may be used by
emergency coordinator.
(G-4c) Direct and indirect effects must be
considered.
(G-4d) Contingency plan must describe
actions facility personnel must take in
response to fires, explosions, or any
unplanned release of hazardous waste to
air, soil, or surface water.
(G-4f) After emergency, emergency
coordinator must provide for treating,
storing., and disposing, of recovered waste.
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-158
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
P-8c(6) Incompatible Waste
P-8c(7) Post-Emergency Equipment
Management
P-8d Evacuation Plan for Facility
Personnel
P-8e Notification of federal, State and
Local Authorities before Resuming
Post-Closure Care
P-8f Notification Reports
P-9 Outline of Introductory and
Continuing Training Programs
P-9a Job Title/Job Description
P-9b Description of How Training will be
Designed to Meet Actual Job Tasks
P-9c Training Director
Federal
Regulation
270.14(b)(7);
264.56(h)(l)
270.14(b)(7);
264.56(h)(2)
270.14(b)(7);
264.52(f)
270.14(b)(7);
264.56(i)
270.14(b)(7);
264.1 9 6(d)
270.14(b)(12);
264.16(a)(l)
270.14(b)(12);
264.16(d)l),
(d)(2)
270.14(b)(12);
264.16(c),(d)
(3)
270.14(b)(12);
264.16(a)(2)
Review
Consideration"
(G-4g) Until cleanup is complete, assure
that incompatible waste is not stored
together.
(G-4h) Decontamination is required for
emergency equipment.
Evacuation plans must include evacuation
signals and primary and alternate
evacuation routes.
Federal or state authorities must be notified
within 15 days of occurrence.
Demonstrate that any release to the
environment will be reported to regional
administrator within 24 hours of detection.
(H-l) Facility personnel must successfully
complete classroom or on-the-job training
which will allow them to responsibly
perform in their positions for post-closure
care. The training program is limited to
post-closure activities.
(H-la) Owner or operator must maintain
records of job titles, names of employees,
job descriptions, and types and amounts of
training given to employees.
(H-lb) Training must be conducted by a
qualified person; there must also be an
annual review of the training.
(H-lc) Program must be directed by person
trained in hazardous waste procedures.
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-159
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
Federal
Regulation
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
P-9d
Relevance of Training to Job Position
270.14(b)(12);
264.16(a)(2)
(H-ld) Training must include instruction on
hazardous waste procedures relevant to
each employee's position.
P-9e
Training for Emergency Response
270.14(b)(12);
264.16(a)(3)
(H-le) Personnel must minimally be familiar
with emergency procedures, emergency
equipment, and emergency systems.
P-9f
Maintenance of Training
Records/Copy of Personnel Training
Documents
270.14(b)(12);
264.16(b),(d)
(H-lf) Training records on current
personnel must be kept until the post-closure
care period is completed. Training must be
completed within 6 months after date of
employment or assignment to the facility,
whichever is later.
P-10
Closure Plans
270.14(b)(13);
264.112(a)(l),(2)
(1-1) Include an approved closure plan
consistent with the requirements of 264.112.
This plan is included for post-closure
facilities as a description of how the facility
was closed.
P-ll
Post-Closure Plan
270.14(b)(13)
(1-2) Submit a copy of the approved post-
closure plan.
P-lla
Post-Closure Care Contact
270.14(b)(13);
264.118(b)(3)
(I-2g) Provide the name, address, and phone
number of the person or office to contact
about the hazardous waste disposal unit or
facility during the post-closure care period.
P-12
Notices Required for Disposal
Facilities
270.14(b)(14)
(I-3a through d) Provide a certification of
closure, a survey plat, and a post-closure
certification. Also include a statement that
the post-closure notices required by
270.149(b)(14) will be filed and submitted
appropriately.
SECTP.WPD
3-B-160
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
P-13 Post-Closure Cost Estimate
P-14 Financial Assurance Mechanism for
Post-Closure Care
P-15 Use of State Required
Mechanisms
Federal
Regulation
270.14(b)(16)
264.144
270.14(b)(16);
264.145; 264.151
270.14(b)(18);
264.149
Review
Consideration"
(1-6) Provide a copy of the most recent post-
closure cost estimate, calculated to cover the
cost, in current dollars, of post-closure
monitoring and maintenance of the facility
in accordance with the applicable post-
closure plan. Estimate must be based on
third party performing the post-closure
activities. The cost estimate must be
adjusted annually for inflation pursuant to
264.144(b).
(1-7) Provide a copy of the established
financial assurance mechanism for post-
closure care of the facility. The mechanism
must be one of the following:
• trust fund
• surety bond
• letter of credit
• insurance
• financial test and corporate guarantee
for post-closure care
• use of multiple financial mechanisms
• use of financial mechanism for
multiple facilities.
(1-9) When state has regulations equivalent
or greater liability requirements for financial
assurance for closure post-closure submit
copy of state-required financial mechanism.
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-161
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
P-16 State Assumption of
Responsibility
P-17 SWMUs
P- 1 7a Characterize the S WMU
P-17b No SWMUs
P-17c Releases
Federal
Regulation
270.14(b)(18);
264.150
270.14(d)(l);
264.101
270.14(d)(l)
270.14(d)(2)
Review
Consideration"
(I-9b) If state assumes legal responsibility
for compliance with closure, post-closure, or
liability requirements there must be a letter
submitted from state specifying assumption
of responsibilities and amounts of liability
coverage assured by state.
(J-l) Identify all SWMUs at the facility
including hazardous and nonhazardous
waste units, as well as active and inactive
units, if known.
(J-l) Submit SWMU information including:
type of each unit; location on a topographic
map; engineering drawings, if available,
dimensions; dates of operation; description
of wastes in each unit; and quantity or
volume of waste, if known.
(J-l) Describe methodology used to
determine that no existing or former
SWMUs exist at the facility.
(J-2)
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-162
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION P. POST-CLOSURE FACILITY REQUIREMENTS
Section and
Requirement
P-17c(l) Characterize Releases
P-17c(2) No Releases
P-18 Part B Certification
P-19 Information on the
Potential for the
Public to be Exposed
to Releases. At a
Minimum, this must
include:
• reasonably foreseeable potential
releases
• potential pathways of human
exposure
• potential magnitude and nature
Federal
Regulation
270.14(d)(3)
270.11
270.10(j)
Review
Consideration"
(J-2) Provide following information
concerning releases: date of release; type,
quantity, and nature of release; groundwater
monitoring and other analytical data;
physical evidence of stressed vegetation;
historical evidence of releases; any state,
local, or federal enforcement action that
may address releases; any public citizen
complaints that indicate a release; and any
other information showing the migration of
the release.
(J-l) Describe methodology used to
determine that releases from SWMUs are not
present.
(L-l)
(Q-l) The federal requirement is for surface
impoundments and land disposal units.
Location in
Application15
See Attached
Comment
Number0
SECTP.WPD
3-B-163
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.: Facility Name:
Notes:
3 Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTP.WPD Reviewer:
3 -B -164 Checklist Revision Date (December 1997)
-------
RCRAI.D. No.:
Facility Name:
CHECKLIST FOR REVIEW OF FEDERAL RCRA PERMIT APPLICATIONS
SECTION Q. EXPOSURE INFORMATION
Section and
Requirement
Federal
Regulatio
n
Review
Consideration"
Location in
Applicationb
See Attached
Comment
Number0
Information on the Potential for the
Public to be Exposed to Releases. At
a Minimum, this must include:
• reasonably foreseeable
potential releases
• potential pathways of human
exposure
• potential magnitude and nature
of exposure
270.10(j)
The federal requirement is for surface
impoundments and land disposal units.
Notes:
Considerations in addition to the requirements presented in the regulations.
For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of the
information in the application.
If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this column.
SECTQ.WPD
3-B-165
Reviewer:
Checklist Revision Date (December 1997)
-------
RCRAI.D. No.: Facility Name:
Notes:
3 Considerations in addition to the requirements presented in the regulations.
b For each requirement, this column must indicate one of the following: NA for not applicable, IM for information missing, or the exact location of
the information in the application.
0 If application is deficient in an area, prepare a comment describing the deficiency, attach it to the checklist, and reference the comment in this
column.
SECTF.WPD Reviewer:
3 -B-97 Checklist Revision Date (December 1997)
-------
ATTACHMENT C
PERMIT PROCESS STEPS FOR INTERIM STATUS
AND NEW HAZARDOUS WASTE COMBUSTION FACILITIES
(6 Sheets)
-------
EPA530-F-94-036
PERMIT PROCESS STEPS
For Interim Status Hazardous Waste
Combustion Facilities
* Represents proposed new requirements from the RCRA Expanded
Public Participation and Revisions to Combustion Permitting
Procedures; Proposed Rule (June 2, 1994).
1.* Pre-Application Meeting. The facility would give notice to
the public and hold a meeting with the affected community
prior to submitting their RCRA permit application. This
meeting is the first opportunity for the facility to have a
dialogue with the community.
2. Submit Part A. The applicant submits a Part A permit
application, which includes such information as the name and
location of the facility, its owner, type of waste accepted,
maximum capacity, and other environmental permits governing
the facility. This step is required to obtain interim
status. Existing facilities are required to submit the Part
A permit application as a condition for obtaining interim
status.
3. Submit Part B. The applicant submits the Part B permit
application, which includes the trial burn plan, closure
plan, waste analysis plan, and other facility documents.
This detailed facility-specific information enables the
permitting authority to evaluate the proposed design and
operation of a combustion facility.
4.* Application Notice. When an application is received by the
permitting authority, a notice will be published. This
notice will allow the public the opportunity to review and
comment on the permit application at the same time as the
permitting authority.
5. Review of Application. The permitting authority reviews the
application. The application must adequately describe how
the combustion facility will be operated to comply with the
RCRA permitting requirements and protect human health and
the environment. The trial burn plan is evaluated to see if
it would adequately test the performance of the unit.
During this period, the permitting authority may ask for
more information in a "Notice of Deficiency".
3-C-l
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6.* Information Repository. The permitting authority would make
a case-by-case determination on whether to require the
applicant to establish and maintain an information
repository. This determination can occur anytime during the
permitting process. The repository would contain all public
information that is determined to be relevant to public
understanding of permitting activities at the facility. The
repository would be open for public viewing throughout the
permitting process.
7.* Trial Burn Notice. Prior to a trial burn, the permitting
agency would publish a public notice announcing that a trial
burn will be conducted, along with the proposed schedule of
the burn.
8. Trial Burn. The applicant conducts the trial burn with
representatives from the permitting authority in attendance.
Emissions and operating conditions are monitored to
determine if performance standards are met.
9. Trial Burn Analysis and Raviav. The applicant submits data
and information on the facility's performance during the
trial burn. The permitting authority reviews the
information, and may request additional data from the
applicant. The applicant submits a risk assessment, which
includes the emissions data from the trial burn.
10. Preparation of Draft Permit Determination, if a facility
conducts a successful trial burn and the risk assessment
shows no adverse impacts to human health or the environment,
the permitting authority will prepare a draft permit. The
permit will include operating conditions based on the
results of the trial burn and risk assessment. If it
appears that the facility is unable to meet statutory or
regulatory standards, a "Notice of Intent to Deny" will be
issued.
11. Public comment on Draft Permit Determination. The
permitting authority provides notice to the public that the
draft permit is available for public comment. The comment
period is at least 45 days. If requested, a public hearing
is held. The permitting authority formally responds to
comments received in writing and at the public hearing.
12. Permit Determination. The final permit will be issued or
denied depending on public comment and the facility's
ability to meet RCRA regulations. The final permit will
describe operating conditions for the facility, and is
effective for up to ten years. If denied a permit, a
facility must comply with closure requirements.
3-C-2
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13. Permit Appeal. After a permit decision is made, any person
who filed comments on the draft permit or participated in
the public hearing on the draft permit may petition the
Environmental Appeals Board (EAB) to review any condition of
the permit decision. Petitions for review are to be filed
within 30 days of the permit decision. For interim status
facilities, the permit conditions under appeal are stayed
pending a decision by the EAB.
14. Judicial Appeal. Once the administrative permit appeals
process has been completed, the petitioner could then seek
judicial review in federal court. The decision of the EAB
is final pending a final decision by the federal court.
However, the petitioner has the right to request a stay of
the EAB's decision pending a final decision.
3-C-3
-------
PERMIT PROCESS STEPS
For New Hazardous Waste
Combustion Facilities
* Represents proposed new requirements from the RCRA Expanded
Public Participation and Revisions to Combustion Permitting
Procedures; Proposed Rule (June 2, 1994).
1.* Pre-Application Keating. The facility would give notice to
the public and hold a meeting with the affected community
prior to submitting their RCRA permit application. This
meeting is the first opportunity for the facility to have a
dialogue with the community.
2. Submits Parts A and B. The applicant submits Parts A and B
of the permit application including a preliminary risk
assessment. Part A includes such information as the name
and location of the facility, its owner, type of waste
accepted, maximum capacity, and other environmental permits
governing the facility. Part B contains detailed facility-
specific information that enables the permitting authority
to evaluate the proposed design and operation of a
combustion facility. The Part B permit application includes
the trial burn plan, closure plan, waste analysis plan, and
other facility documents.
3.* Application Notice. When an application is received by the
permitting authority, a notice will be published. This
notice will allow the public the opportunity to review and
comment on the permit application at the same time as the
permitting authority.
4. Review of Application. The permitting authority reviews the
application. The application must adequately describe how
the combustion facility will be operated to comply with the
RCRA permitting requirements and protect human health and
the environment. The trial burn plan is evaluated to see if
it would adequately test the performance of the unit.
During this period, the permitting authority may ask for
more information in a "Notica of Deficiency".
5.* Information Repository. The permitting authority would make
a case-by-case determination on whether to require the
applicant to establish and maintain an information
repository. This determination can occur anytime during the
permitting process. The repository would contain all public
information that is determined to be relevant to public
understanding of permitting activities at the facility. The
repository would be open for public viewing throughout the
permitting process.
3-C-4
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6. Preparation of Draft Permit Determination. If the
application is complete and acceptable and the preliminary
risk assessment shows no adverse impacts to human health or
the environment, the permitting authority will prepare a
draft permit that includes a trial burn plan and facility
design specifications. The draft permit also includes
operating conditions under which the facility is expected to
meet the performance standards. If the permitting authority
determines that the facility will be unable to meet
statutory or regulatory standards, a "Notice of Intent to
Deny" will be issued.
7. Public Comment on Draft Permit Determination. The
permitting authority provides notice to the public that the
draft permit is available for public comment. The comment
period is at least 45 days. If requested, a public hearing
is held. The permitting authority formally responds to
comments received in writing and at the public hearing.
8. Four-Phase Permit. After the public comment period has
ended, the permitting authority will either issue a four-
phase permit or a "Notice of Intent to Deny". The four-
phase permit would establish the facility design and the
conditions to be met by the facility following construction.
9. Permit Appeal. After a permit decision is made, any person
who filed comments on the draft permit or participated in
the public hearing on the draft permit may petition the
Environmental Appeals Board (EAB) to review any condition of
the permit decision. Petitions for review are to be filed
within 30 days of the permit decision. For new facilities,
the entire permit is stayed pending a decision by the EAB.
10. Judicial Appeal. Once the administrative permit appeals
process has been completed, the petitioner could then seek
judicial review in federal court. The decision of the EAB
is final pending a final decision by the federal court.
However, the petitioner has the right to request a stay of
the EAB's decision pending a final decision.
11. Start-Op/Shake-Down period (Phase One). This phase allows
limited burning of wastes to help stabilize the new
facility's operation.
12.* Trial Burn Notice. Prior to a trial burn, the permitting
agency would publish a public notice announcing that a trial
burn will be conducted, along with the proposed schedule of
the burn.
13. Trial Burn (Phase Two). The applicant conducts the trial
burn with representatives from the permitting authority in
attendance. Emissions and operating conditions are
monitored to determine if performance standards are met.
3-C-5
-------
14. Post-Trial Burn (Phase Three). In this phase, the facility
may operate under specified permit limits, while trial burn
results are reviewed. The permitting authority may request
additional data from the applicant. The risk assessment is
revised to include the emissions data from the trial burn.
15. Final operating Conditions (Phase Four). If a facility
conducts a successful trial burn and the risk assessment
shows no adverse impacts to human health or the environment,
the facility is allowed to operate under the final operating
conditions in the permit. In some cases, modifications to
these permit conditions may be necessary based on the trial
burn or risk assessment results. If the facility does not
pass the trial burn, the permitting authority may initiate
proceedings to terminate the permit, or may modify the
permit to allow a trial burn retest. A significant
modification of the permit, such as the addition of a second
trial burn, would require a new public comment period.
3-C-6
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ATTACHMENT D
DRAFT GUIDANCE ON INCINERATOR CLOSURE
(14 Sheets)
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MEMORANDUM
OFFICE OP
SOLID WASTE ANO SMERGENCr RESPONSE
8OBJHCT: Draft Guidance on Incinerator Closure
PROK:
TO;
Lionel Vega, Chemical Engineer
Alternative Technology Section
Addressees
Attached ia the draft guidance on incinerator closure for
your review and comment. As deecribed in the agenda, I win be
asking for your comments on this eight-page draft guidance in our
workgroup meeting scheduled for November 7-9 in Denver, Colorado!
Attachment
Addreeseea:
Stephen Yee, Region I
John Brogard, Region II
Gary Cross, Region III
Betty Willis, Region rv
Glen May, Region IV
Hugh Hazen, Region iv
Y.J. Kim, Region V
Kardi Klevs, Region V
Stan Burger, Region VI
Joe Galbraith, Region VII
Nat Hiullo, Region VHI
Larry Bowerman, Region IX
Cathy Massimino, Region X
cot Lionel Vega
Sonya Sasseville
Bob Holloway
Shiva Garg
Dwight Hlustick
Kate Anderson, OWPE
Charles Perry, OWPE
Winston Lue, OTS
Criatina Gainea, OWEP
Larry Johnson, ORD
Joe McSorley, ORD
C.c. Lee, ORD
Donald Oberacker, ORD
George Huffman, ORD
Justice Manning, ORD
Bob Mourlngham, ORD
PrtattJ at faq/cltd Poptr
3-D-l
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DRAFT OF GUIDANCE
OF INCINERATOR CLOSURE
Draft Final Report
For U.S. Environmental Protection Agency
Submitted by:
Midwest Research Institute
5109LeesburgPike
Suite 414
Falls Church, Virginia
EPA Contract No. 68-01-7310
Work Assignment 134
MRI Project No. 8962-34
June 29, 1990
3-D-2
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PREFACE
This draft document was prepared by Midwest Research Institute (MRI) for
the U.S. Environmental Protection Agency (EPA) under subcontract to NUS
Corporation on EPA Contract No. 68-01-7310. The document was developed by
Bruce Boomer.
MIDWEST RESEARCH INSTITUTE
Andrea C. Hall, Ph.D.
Program Manager
June 29, 1990
3-D-3
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DRAFT
GUIDANCE OH CLOSURE PROCEDURES FOR
HAZARDOUS HASTE INCINERATOR FACILITIES
IHTRODUCTION
This memo provides RCRA permit writers with recommended procedures for
the 1nc1nerator-spec1f1c portion of a closure plan. Owners and operators of a
hazardous waste Incinerator facility must develop a plan for closing the
facility and must keep the plan on file at the facility until closure 1s com-
pleted and certified. The closure plan 1s a required portion of a RCRA Part B
permit application and is thus subject to the approval of RCRA permit
writers.
This memo addresses closure of the Incinerator and ancillary equipment.
Issues addressed below Include Initial decontamination and burnout of any
residual organic contamination, further decontamination methods, confirmatory
sampling methods, and Criteria for closure certification. This memo does not
address tank closure or other general facility closure requirements such as
the cleanup of any spills or contaminated soils.
Typically, the closure of a permitted RCRA Incinerator Is not an issue
with significant environmental Impact. If the facility had been operating In
compliance with permit conditions prior to closure, the amount and extent of
residual contamination within the incinerator and ancillary equipment is
expected to be minimal; the recommendations discussed 1n this memo address
this expectation of minimal contamination.
3-D-4
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EPA PRECEDENT
An issue associated with Incinerator closure Is defining an "acceptable"
level of residua! contamination to allow material previously 1n contact with
hazardous wastes to be recycled or disposed as a nonhazardous waste. In a
letter to Mr. Thomas Jorllng dated June 19, 1989, Jonathan Cannon, Acting
Assistant Administrator of EPA {see Attachment 1), noted that contaminated
environmental media must be managed as If they were hazardous until they no
longer contain the listed wastes. Options mentioned 1n the letter Include:
(1) dellstlng, (2) removing the contamination by treatment, or (3) decontam-
ination to an acceptable minimal level of contamination. The letter notes
that for the third option, EPA Is Investigating de minimus levels for
hazardous constituents, below which materials (such as contaminated
environmental media) would no longer have to be managed as hazardous wastes.
The sections below provide a closure approach for potentially
contaminated Incinerator media that Involves, to some extent, options number
two and three above.
APPROACH TO INCINERATOR CLOSURE
Residual contamination of environmental concern within an Incineration
system win result from the organic and metals content of the wastes fed to
the incinerator. The following steps (summarized 1n Table 1) provide a basis
for organic decontamination and determination of residual metal contamina-
tion.) The first step of Incinerator Closure Involves the Incineration of all
existing hazardous waste inventories and proper treatment, disposal, or
removal of residual wastes such as Incinerator ash. scrubber effluents, and
baghouse ash. For most facilities, this step effectively removes the most
significant source of residual contamination for closure.
The second step Involves the active decontamination of waste feed
mechanisms by use of chemical and/or physical action. This step may be
coordinated with affiliated storage tank or drum closure activities, which
parallel and Inter-relate to incinerator closure.
3-D-5
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During the second step, feed mechanisms (e.g., liquid/sludge feed lines,
solid feed mechanisms) are rinsed with kerosene or other appropriate solvents
to remove surface contaminants. Table 2 provides a general guide to the
solubility of several contaminant categories 1n water, dilute adds, dilute
bases, and organic solvents. Feed mechanisms also may be scrubbed or scraped
using brushes, scrapers, or sponges and water-ccmpatable solvent cleaning
solutions. All Mnsate Is to be collected and Incinerated prior to Step 3,
The third step Is a burnout of any residual organic contamination within
the Incinerator. Following the completion of step 2, the Incinerator will be
operated with only auxiliary fuel for an appropriate time period not less than
4 hr, maintaining at least the minimum temperature specified 1n the permit for
each combustion chamber. This is expected to combust any remaining organic
contaminants within the Incinerator system.
After the completion of step 3, the Incinerator and Its ancillary equip-
ment may be considered to be organically decontaminated. Organic contamina-
tion 1s not expected downstream from the combustion chambers (e.g., air
pollution control devices). However, residual contamination with metals
remains a concern. Step 4 addresses the decontamination and wipe sampling of
Incinerator components 1n regard to metals. The following are examples of
components of concern:
• Feed mechanisms (piping, pumps, conveyors, etc.);
• Refractory of combustion chambers;
• Gas ducts;
• Ash handling system;
• Internal surfaces of air pollution control equipment; and,
• Stack.
{Excluded from the decontamination procedures are fabric filter bags and
scrubber packing materials which can be disposed as hazardous wastes.)
The recommendations for step 4 Include:
• Optional rinse/scrub of above equipment with detergent;
• Wipe sampling (minimum 10 locations scattered throughout above).
3-D-6
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The optional rinse/scrub may Involve a combination of both physical and
chemical means to remove contaminants. As previously discussed for step 2,
Individual components (detached as appropriate) may be scrubbed or scraped
using brushes, scrapers or sponges, and water-compatible solvent cleaning
solutions. Contaminants may be removed with a water or solvent rinse using
pressurized or gravity flow, or using steam jets. On metal surfaces, pres-
surized cleaning may present problems with metals etching compounding the
effective removal of contaminants. In addition, caution should be exercised
to ensure that pressurized or steam cleaning sprays/emissions are appropri-
ately contained (I.e., curtains, enclosures, or spray booths may be necessary
to reduce or eliminate cross-contamination).
Wipe sampling Kill Involve sampling surfaces exposed to either hazardous
wastes or the exhaust gases/residuals derived from waste Incineration In the
above equipment. Samples .are collected by applying delonlzed water or a
detergent (e.g., household liquid cleaner) to a piece of ll-cm diameter filter
paper (e.g., Whatman 40 ashless, Whatman "50" smear tabs, or equivalent) or
gauze pad. This moistened filter paper or gauze pad 1s used to thoroughly
swab a lOO-cm' area, as can be measured, by a sampling template.
The use of a template can assist the sampler in the collection of a
100-craJ sample. Different templates may be used for the variously shaped
areas which must be sampled (e.g., a 10 era x 10 cm square). When a template
is used, it should be thoroughly cleaned between samples to prevent
contamination of subsequent samples by the template.
The wipes and the liquid used to wet the wipes should be tested for
residual metals before use 1n taking samples from the incinerator. The wipe
samples should be stored 1n precleaned glass Jars and stored no longer than
the allowable holding times stated 1n SW-846. Samples will be digested and
analyzed for As, Be, Cd, Cr, Sb, Ba, Hg, Pb, Tl, and Ag (the metals regulated
1n Incinerator emissions). Samples can be composited if desired, but
compositing reduces opportunities for Identifying localized contamination
areas. At least one blank sample per sampling day must be prepared. Wiping
only gives an indication of surface contamination which can easily be
removed. Incinerator components with a large amount of strongly entrained
3-D-7
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residuals might need to be scraped with a paint scraper and the scrapings
analyzed. Criteria for acceptable levels of residual contamination are
discussed below.
As an alternative to step 4, an incinerator owner may elect to dispose
all Incineration equipment as a hazardous waste.
CERTIFICATION OF ADEQUATE CLOSURE
The effectiveness of the closure decontamination process for organic
contamination may be estimated by visual observation of any discoloration*,
stains, or gross pockets of apparent organic solids. This visual assessment
1s anticipated to be a suitable measure of possible organic contamination when
followed by a rinse or cleanup of the affected areas with an appropriate
solvent.
Effectiveness of metals decontamination may be determined by wipe
sampling (as previously discussed), or by analyzing rlnsate for contaminants
left 1n the solvent solution. However, analysis of rlnsate should be
evaluated with regards to the total amount of rlnsate 1n contact with the
total area of the Incinerator surfaces. Rlnsate values could be elevated due
to a leaching effect on the metallic surfaces of the incinerator. Evidence of
elevated levels of contaminants 1n the wipe samples (as discussed below) sug-
gest that additional cleaning and rinsing 1s necessary. Elevated contaminate
concentrations also may Indicate that an alternative contaminate removal
method (e.g., sand-blasting, surface sealing, etc.) 1s necessary to remove or
permanently contain contaminates.
Until EPA develops de minimus levels for the metals of concern, a
suggested guide 1s to compare the results of Incinerator wipe sampling with
background levels as indicated by taking wipe samples of exterior building
surfaces on or near the Incineration site. This wipe sample should reflect
background ambient air quality, Including the Impact of local mineralogy. An
Incinerator wipe sample that demonstrates a surface concentration at least 100
times greater than the background value for any metal should serve as an
Indicator that additional decontamination 1s needed prior to closure. Failure
3-D-8
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to meet the criteria would require a repeat of the optional rinse/scrub of
equipment (In step 4) followed by a repeat of wipe sampling; disposal of
contaminated material as a. hazardous waste 1s another alternative. Care
should be taken In selecting areas for background sampling since such mate-
rials as painted surfaces and stainless steel may contain significant levels
of some of the analytes.
The Incinerator owner/operator will submit full documentation of the
closure process to the permitting agency to receive certification of
closure. A report should be submitted to the Agency describing each step of
closure activities and the results of wipe sampling. Certification will allow
the owner/operator to recycle the Incinerator materials or dispose of the
materials as a nonhazardous waste. Alternatively, closure certification may
note the adequate disposal of Incinerator equipment as a hazardous waste.
DELAY OF CLOSURE
The above approach assumes that the incineration facility 1s being closed
and dismantled. If a facility is being closed as a RCRA facility but will
either continue to operate as a nonhazardous waste facility or remain intact
1n storage for Indefinite future operation, step 4 above could be delayed
until dismantling occurs. However, the incineration facility will be subject
to RCRA security requirements and, ultimately, RCRA closure requirements.
3-D-9
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Table 1. SUWARY OF RCRA INCINERATOR CLOSURE RECOMMENDATIONS
Step 1 Incineration of all remaining waste feeds and
removal of all ash and scrubber effluent wastes
Step 2 Flush waste feed lines and mechanisms with kerosene
or an equivalent solvent and Incinerate rlnsate
Step 3 Operate Incinerator for at least 4 hr at the minimum
permitted temperature with auxiliary fuel only, to
provide burnout of any organic residues
Step 4 Optional decontamination of Incinerator components
with detergent, followed by mandatory wipe sampling
of surfaces potentially contaminated with toxic
metals (additional decontamination and wipe sampling
would be conducted 1f needed)
Step 5 Certification of adequate closure based upon
analytical results
3-D-10
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Table Z. GENERAL GUIDE TO SOLUBILITY OF CONTAMINANTS
IN FOUR SOLVENT TYPES
Solvent Soluble contaminants
Water Low-chain hydrocarbons.
Soluble Inorganic compounds.
Salts.
Some organic adds and other polar
compounds.
Aqueous Detergents Many water soluble contaminants and
Insoluble partlculates.
Dilute Adds Basic (caustic) compounds.
Amines.
Hydrazlnes.
Dilute fia$«s Acidic compounds.
For example: Phenols.
-detergent Thlols.
-soap Some nltro and sulfonlc compounds.
Organic Solvents Many nonpolar or polar organic
For example: compounds.
-alcohols
-ethers
-ketones
-aromatlcs
-straight-chain
alkanes (e.g., hexane)
-common petroleum
products (e.g., fuel
oil, kerosene)
-chlorinated solvents
3-D-ll
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Attachment 1
3-D-12
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THIS LETTER WAS REKEYED TO BE ELECTRONICALLY AVAILABLE
*i
* I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
/ WASHINGTON, B.C. 20460
June 19, 1989
Mr. Thomas C. Jorling
Commissioner
Department of Environmental Conservation
State of New York
Albany, New York 12233-1010
Dear Mr. Jorling:
I am writing in response to your letter of May 5, 1989, in which you ask numerous questions
concerning the regulatory status, under the Resource Conservation and Recovery Act (RCRA), of
environmental media (ground water, soil, and sediment) contaminated with RCRA-listed hazardous waste.
As you point out in your letter, it is correct that the Agency's "contained-in" interpretation is that
contaminated environmental media must be managed as if they were hazardous wastes until they no
longer contain the listed waste, or are delisted. This leads to the critical question of when an
environmental medium contaminated by listed hazardous waste ceases to be a listed hazardous waste. In
your letter, you discuss three possible answers (based on previous EPA positions and documents) which
you believe address this question, and request the Agency to clarify its interpretation. Each of these is
discussed below.
The first possible answer you cite would be that the contaminated media would be a hazardous
waste unless and until it is delisted, based on the "mixture" and "derived-from" rules. As you correctly
state in your letter, a waste that meets a listing description due to the application of either of these rules
remains a listed hazardous waste until it is delisted. However, these two rules do not pertain to
contaminated environmental media. Unlike our regulations, contaminated media are not considered solid
wastes in the sense of being abandoned, recycled, or inherently waste-like as those terms are defined in
the regulations. Therefore, contaminated environmental media cannot be considered a hazardous waste
via the "mixture" rule (i.e., to have a hazardous waste mixture, a hazardous waste must be mixed with a
solid waste per 40 CFR 261.3(a)(2)(iv). Similarly, the "derived" from" rule does not apply to
contaminated media. Our basis for stating that contaminated environmental media must be managed as
hazardous wastes is that they "contain" listed hazardous waste. These environmental media must be
managed as hazardous waste because, and only as long as, they "contain" a listed hazardous waste, (i.e.,
until decontaminated).
The second possibility you mention is that environmental media contaminated with a RCRA listed
waste no longer have to be managed as a hazardous waste if the hazardous constituents are completely
removed by treatment. This is consistent with the Agency's "contained-in" interpretation and represents
the Agency's current policy.
3-D-13
-------
THIS LETTER WAS REKEYED TO BE ELECTRONICALLY AVAILABLE
The third possibility you discuss comes from Sylvia Lawrence's January 24, 1989, memorandum
that you cited in your letter. This memorandum indicates that OSW has not issued any definitive guidance
as to when, or at what levels, environmental media contaminated with listed hazardous waste are no
longer considered to contain that hazardous waste. It also states that until such definitive guidance is
issued, the Regions may determine these levels on a case-specific basis. Where this determination
involves an authorized State, such as New York, our policy is that the State may also make such a
determination.
Related to such a determination, you ask whether a risk assessment approach that addressed the
public health and environmental impacts of hazardous constituents remaining in treatment residuals would
be acceptable. This approach would be acceptable for contaminated media provided you assumed a
direct exposure scenario, but would not be acceptable for "derived-from" wastes under our current rules.
Additionally, consistent with the statute, you could substitute more stringent standards or criteria for
contaminated environmental media than those recommended by the Federal EPA if you determined it to
be appropriate.
The Agency is currently involved in a rulemaking effort directed at setting de minimis levels for
hazardous constituents below which eligible listed wastes, treatment residuals from those wastes, and
environmental media contaminated with those listed wastes would no longer have to be managed as
hazardous wastes. This approach being contemplated in the De Minimis program would be similar to that
used in the proposed RCRA Clean Closure Guidance in terms of the exposure scenario (direct ingestion),
the management scenario (not in a waste management unit), and the levels (primarily health-based).
Your final question related to whether the "remove and decontaminate" procedure set forth in the
March 19,1987 Federal Register preamble to the conforming regulations on closing surface impoundments
applies when making complete removal determinations for soil. These procedures do apply when one
chooses to clean close a hazardous waste surface impoundment by removing the waste. The preamble
language states that the Agency interprets the term "remove" and "decontaminate" to mean removal of
all wastes, liners, and/or leachate (including ground water) that pose a substantial present or potential
threat to human health or the environment (52 FR 8706). Further discussion of these requirements is
provided in a clarification notice published on March 28, 1988, (53 FR 1144) and in OSWER Policy
Directive # 9476.00-18 on demonstrating equivalence of Part 265 clean closure with Part 264
requirements (copy enclosed).
I hope that this response will be helpful to you in establishing and implementing New York's
hazardous waste policies on related issues. Should you have additional questions, please contact Bob
Bellinger, Chief of the Waste Characterization Branch at (202) 475-8551.
Sincerely yours,
(original letter was signed by a
representative of Jonathan Cannon)
Jonathan Z. Cannon
Acting Assistant Administrator
3-D-14
-------
ATTACHMENT E
PART A PERMIT APPLICATION
(33 Sheets)
-------
ATTAC'IIMK Yf f.
A APPLICATION
(33
-------
RCflA Pin A P«nmtt Applleatieo
State ^overrtments may be authorized by EPA to administer hazardous
•vi -r? -r.an-J2':rr.er': ^n-enms :n "Jcu ~.i Lhe F-deral RCRA crciBHur, Y:u
determine whether your Slate ts authorized !s«8 Table 11. If so, ysu v.nll
nesct '.a coEnpi1/ "*~th the specu'ic permit application requirements oi that
State,
The *r.c!c^2'*i ",r3tr"ict:eits sncw the ?ceci!lc steps on how to apply !cr a
RCRA pentuc, L.' reaaing Hie jnatrucacna you .15 ve a.ny qucsucr,s
fee permit mpplica,tion process, please contact the EPA
Office to yoyr for assistance Table 2}.
3-E-2
-------
Part A Permit Application
1. Who Must File a RCRA Permit Application
The Resource Conservation Recover/ Act or 1S7S (RCRA). as
amended, requires each person owning sr operating a facility for the
treatment storage, or disposal of hazardous waste to have a permit. This
includes individuals, trusts, flrms. joint stock companies, corporations
.; including government ecrporatjcnsj. partnerships, aaseejaiians,. State,
authorised Indian cnbe organization!. Federal Agencies, IF you treat,
scare, or of hazardous waste wi.th.out obtaining a permit, you may
be- subject to a civil or criminal penalty.
II. How to Determine if You Handle Hazardous
Waste
OFF-SITE FACILITIES. Owners and operators of off-site treatment,
storage, or disposal facilities are encouraged to obtain waste information
from the generators, they serve-. If the generators will not supply this
.information, yOu ^^ stm re5po,rls5^];e for determining if you a
hazardous waste and should follow the procedures below for on-site
facilities,
OPf-SlTE FACILITIES. Solid who treat, store, or
of their own waste an-site should follow the following procedures
for determining if their waste is a hazardous waste. This determination is
niadc as follows;
1. First, determine if the solid waste handled is excluded from
regulation as a hazardous waste. The list of exclusions can be found
in the rcfuiatJori titled Identification and Listing of Hazardous
Waste." 40 CFR Sections 261.4 and 261.5. If the waste
handled Is excluded, a RCRA hazardous waste permit is not needed
to treat, store, or dispose of these wastes,
2. If the solid waste handled is not excluded by Sections 261.4 or
261,5. determine if the waste Is listed in Subpart D of Lists of
Hazardous Wastes. Persons owntof or operating facilities where
hazardous waste is treated, stored, or disposed are subject to
regulation, and must file a RCRA permit application.
3, If the waste handled is not listed in Subpart O of Lists of
Wastes, the waste may still be hazardous because it
3-EO
-------
RCRA Part A Permit Application
Identification and Listing of Hazardous Waste." A rietermmaucr
that a waste these characteristics cr cantarairiani^ may
be made either on:
iai Your Knowledge of the hazard characteristic of the in light
of the raatsnals or the processes used: or fbl Trie results of testing
the -A-aste according to the methods in Subpart C Q!" "Ideniil'ication
and Listing cf Hazardous Waste,,'
Certain persons who handle hazardous waste are not required to obtain a
RCRA permit, "TTiey are:
L Generators who accumulate their own hazardous waste on-site for
than 9O days as provided in 40 CFR 262,. 34;
2. Farmers who dispose of hazardous waste pesticides from (heir own
use as provided to 40 CFR 262,70; and
3. Owners and operators of totally enclosed treatment facilities as
in 40 CFR 260.10,
111. What information Should be Filed and
When
'There .are two pans to the RCRA permit application -- Part A and Part 8.
Part A defines the processes to be used for treatment, storage, and
of hazardous wastes; the design capacity of such processes; and
the specific hazardous 'wastes to be handled at a facility. Part B requires
detailed site specific information such as geologic, hydrologic, and
engineering data,. 40 CFR Section 270, Subpart B, specifies 'the
information that wiE be required from hazardous waste management
facilities in Pan B of the permit application,
A, Operation During Interim Status
As provided in 40 CFR 270.13, Part A of the application defines the
processes to be far treatment, storage, and disposal of hazardous
wastes; the design capacity of sych processes: 'and the specific hazardous
wastes to be handled at a facility during the interim status period. Once
Part A is submitted to EPA. changes In the hazardous wastes handled.
3-E-4
-------
RCRA Part A Permit Application
in design of facilities, changes in prec^st^s. and changes in
j"-T;i~.-;C -" :::ira:::;r;..,i ccr.'-;i -: L :'iCLlty /_""g ::.*- ^irrtrn 5-5 r. r
pcnod may only be in accordance with the procedures in 40 CFR
270,71. Changes in capacity and changes in require
poor EPA approval. Changes in the quantity of waste currently specified
on the Part A can be made 'without submitting a revised Part A. provided
the quantity does not exceed the design capacities of the processes
specified to Part A of the permit application. Failure to furnish all
Information required to process a permit application Is grounds for
tcrtninacion of interim status.
B. How Many Applications Should be Filed
You need submit only one RCRA permit application [Part A and Part B|
per site or location, provided that you describe aH of the activities at that
site or location. If you conduct hazardous waste activftyliesi at more' than
one site or location, you must submit a, separate application for each site
or location,
C. Where to File
The application forms should be mailed to the EPA Office whose
Region includes the In which the is located tsee Table 2).
If the State in which the facility Is located administers a Federal permit
program under which you need m permit, you should contact 'the
appropriate agency far the correct forms [see Table 1). Your EPA
Regional Office (Tabie 21 can tell you to whom to apply and can provide
the appropriate address and phone number,
D. When to File
As required by 40 CFR 270,1 fb|. the deadlines for applications are
as follows;
Existing fmeiMty: six months following publication of
regulations listing hazardous wastes.
New facility: ISO days before commencing physical
construction.
Page 5
3-E-5
-------
Part A Pwmtt Application
. Confidential Information
Ail miormauon jucrmnea IT, :r*:s ;crm -wi^ ie iucjcc: :j puei^ -isc.cijr?.
la the extent provided by the Freedom of Information Act, 5 U.S.C.
Section 552, and E?A"s Business Confidentiality Regulations. 40 CFR Part
2 and 40 CFR 270,12. Claims of confidentiality for the name and address
ii" ir»y permit a~pLeant or permit: .re will be denied. Persons "Hjng this
form may make claims of confidentiality for certain information. Such
must be tjeariy indicated by submitting an attachment listing the
specific information for which confidential treatment is requested at the
time of fltog. This attachment must Include a written substantiation of
the claim for confidentiality, thai answers the following questions:
I, Which sections of the Part A form contain the information you claim
is entitled to confidential treatment?
2. For how long is confidential treatment desired for the information?
3. What have you taken to guard against undesired
disclosure of the information ID others?
4. To what extent the information disclosed to others, and
what precautions have been laJcen In connection with that
disclosure?
EPA or any other Federal agency made a pertinent
confidentiality detcraanation? If so, include a copy of such
detennmatton or reference to it. If available.
6. Will disclosure of the information be likely to result to. substantial
harmful effects on your competitive position? If so, what would
those hannfuJ effects be and why should they be viewed as
substantial? Explain the causal relationship between disclosure and
the harmful effects.
Information covered by a confidentiality claim and the above
substantiation will be disclosed by EPA only to the extent and by rneaiw
of the procedures set forth in 40 CFR Part 2 and 40 CFR 270,12.
If no claim of confidentiality or no substantiation accompanies she
information when it is submitted, EPA may make the infonfta.tion
available to the public without further notice to the submitter.
Pag»6
3-E-6
-------
RCRA -Part A Permit Application
Ta«« 1
Alabama
Obtain information of forms from, njid «ail
completed forms to:
Urti Dtvs,.~n
Alabama Department ot"
P.O. 8ox3€JH«63
Montgomery. Alabama 36 1 30- 1 463
1334 J 27 1 -7700
Alaska
Obftan information or Joirms from:
Department ot Envtrwwwental Coiwenatian
4 1 0 Wttougfsby Avenue
Suite I OS
J uneau , Alaska 1 - 1 795
[907) 465-5 1 3<§
Mail cmnplfifAj&rma to;
U-S- SPA Rcftoo SO
Waste Management Branch. HW-3dS
120O SWth Avenue
Semttte, Waihmgton 98101
S33-J2S3
ift/wnmtton or Jbrma/ram. and
a»np4«{«l Jbrmi to:
U.S. EPA Kegjefl §
KxMuTdous WattC Manmgcroctil Division
7S HmwthO'me Street, Attn: H-2-J
San Fiwiusc*. California §4 105
[41,S|-495-i8i5
Arlxona
tn/brmoCion er/on?is from, and mad
Office of W»te
of
Envtronrnental
3O33 N. CeflOTJ
PhoeftUc. Arttona,
207-4146
af /orms/rom, and
epartir.enl of Pollution
i and i
? O, 3o* 8S13
LitUr Rock. Arkansas 72209
1.5011 6A2-0833
Obmiin ln^/ammOon. or Jorms from:
CA lt«9lan 1
Department of To*c Substances Cano-ot
13 LSI Croydon Way. Suaie 3
Sacramento. CA rdflB27
|t*:5) 255-36 IS
•C^ Sefien 2
Department of Tascc Substar.ees Control
700 Heinz Avert uc Saitc 200
Skrtatiey, CA 947 LO
15101 340-3953
CA flayiftn J
[>epartinent of Tone Sut-s.tjLr.ces Qsnltai
;o 1 1 North Granview
G;endaJe. CA 93201
•8JS) 551-2S30
CA Re§ifl
-------
RCflA Part A Permit Application
Table 1 (continued)
t in, ormai wn jf J&rms j.rz-r* d.r,c
to:
Hazardous Material Management Unit
Department of Environmental Protection
State Giles Building
:65 CaD;tai Aver.ue
Karrford. Connecticut OeiC-<5
ro:
Hazardous Waste Reguiauon Section
Department of Eovtroftraental Regulation
Twin Towers Office Building
26CO Blair Stone
Tallahassee, ?1oirda 22399-24CC
Deiawaxe
Obtain, mf&rmaimn or forms from, and. mad
Oeorjli
Obtoin B^bonatton or forms from, and mail
Delaware Depitftiwsit srf Natuml Rcscwr«»
and Envtronmental Csntpal
Division of Air and Waste Mtnmg etnenl
Hazardous Waste Management Branch
P.O. B« 1*01, 89 KJrtf* Wfhwmy
Dover, Delaware 19903
739-3689
739-3672
U.S. EPA ftegMm 3
RCRA Pfofrmms Branch 13 tfW50)
841 Chcitnyt Street
Philadelphia. PA 19107
121 SI (PA. DC}
12151 397-3070 (VA. WV. MD, DEI
District of Columbia
Q&tam information or farms /ram. and
completed forms to:
Department of Ccwmuinef'
Regulatory Aflkir*
Environment*! Regulation Administration
Hazaxdeus Waste Brands
21QG- Mmnin Luther Steg Jr. Ave, S..E.
Waahinglon. D.C- 2^0020
S4S-6Q8Q
Send cottfTfi'Sii -copy to."
U.S.. EPA Revert 3
RCRA Prepmns B'Cmnch (3 HW50I
S41 Chestnut Street
Pfwiadelp-him. PA 191O7
(PA. DC)
315) 566-3070 (VA. WV, MD. DEI
Land Protection BrmncJi
InfSur.tr.Ai and Hazard en-is
Waste
1154 East Tower
205 Sutler Street. S,E,, Suite 1 154
Atlanta, Georgia .30334
I4G4J
ObEawi ift/errnoiton of forms jrom. and,
ttxnplttfd forms to:
Guam Environmental Protection Agency
HJUrmon Plaza
CompLeJi Unit B- 107
103 Qrjm Street
Harmon. Guam 1
Obtain
Hawaii Depmrttnerit of Health
and Haaardou.* Waste Brmnch
Five Waterfront Plaza, Suite 25O
$00 Ala Moan* Boulevard
Honolulu, Hawaii 9S813
to;
U.S. EPA RegUm 9
Hazardooa Waste Management Division
AtUX: H-2-3
T5 Hawthorne Street
San Fraoeisco, Cmllfom.la §4105
(4 1 SI 495-8895
3-E-8
-------
RCRA Part A Permit Application
Table 1 (continued)
forms cor
of Environmental Quality
3410 N. Hilton. Third .Floor
Boise. Idaho 837O6
Otiiam tnfoTTnaiion or forms fratn, and mail
catm^tewd forms to:
Illinois Environmental Protection Agency
Division of Land Pollution Control
Churchill Itoa4
Springfield. Illinois §2706
[2171 712-6761
Obtain ut/ormauan wJiar»Tis/nowL and mail
corripte'{«d /OrntS to:
Indiana Department of
Environmental Management
I GO North Senate Avenue
P.O. Bo* $01 5
Indianapolis. Indiana 46206
1317] 232-3242
low*
Obtain Jri/armartwn & farms from, ontt
COfnptttfd forms to:
U.S. EPA Region 7
RCRA Branch, Permitting Seelion
Actn; WSTM/RCRA./PRMT
726 Minnesota Avenue
Kansas City. Kansas 66101
(9131 551-7O20
Obcain tn/ormotton or farms from, and
.comptoed/orms to;
Department of Health and Environment
Aitn: Hazardous Waaie Sec'Uon
Forbes Field, Buikting 74O
Topeka. Kansas 36620
(9131
ard. .T»a.
/arms for
of Wasic Mmnagemem
Department of Environmental Proiec*jo«
Cabiftei for Natural Resources
and ER'/iranETsentai J^-eieeiicn
Fort Scone Maza. Building No. 2
LJ. ^et!!y Road
Frmnktbrt, Kentucky 4C6OI
Louiaiana
Ofolcun injonnafton or/orms/rom. and
».•
Dcpartmenl of
Environmental QuaJlty
Departmefii of Solid and Hazardous Waste
P.CL 8c«83l7&
Baton Rouge. Louisiana 70684-2178
1504] 765-0261
in/ormatiotn of forms from. and. mail
ieid forms to;
Sureay ol* Oil afld Kazardous
MaienmJa Control
Department of £ftvtfonm*ntal Pr-oteclion
Stale Mouse Station * 1 7
Augusia. Maine 04333
287-2651
Itaiytaiid
Obtain in/brmaiion orjormsfrom. and' mad
compweed forrns co-
Maryland Department 21" the Environment
Waste Management Ad;nttiisi«n.ton
Haxardaiu Waste Proi
-------
RCHA Part A Permit Application
Table 1 (continued)
- -•
. tn/brmorcon or forms from, mtd
d forms to:
Division of Solid and Hazardous Waste
Massachusetts Department Of
One Winter Stretrt. 5th floor
•Ml 71 232-5354
MIcMgaa
Obtain informal ton or/amu/rom. afl^ .*nail
Manai|eiTiertl Division
Michigan Department of Natural Re*ay«*s
Sox 3024 1
Lansing. Michigan 48909
(5171 373-2730
Minnesota
Obtain information ar forms from, afsd
Solid and Hazardous Waste Division
V!inne»e»'.;» Pollution Conirol Agency
520 LafayffUs Rand .North
5i Paul. Vlinnesola 35H55
16121 397-8330
Obtain in/ormaiiort of jorms Jrotn. and. maul
eat«p(*ted Jorms to:
Department of Environmental Quality
P.O. Box 10385
Jackson. Mississippi 392§3'Q385
16051 tSl-5171
m/ormaaefi or forms /ram. and
so:
Waste Management Profram
OepMrf^menl of Natural Resource
Jefferson Building
205 Jeffertom Street (13/14 floor!
P.O. Box 176
Jefferson City. Missouri 65102
1314) 751-3176
JIPJI«I-"'JI /rum. anrf f
;a-
Solid and Hazardous Waste Bureau
Department ol Health
"- —\ 'i1 r tr.j. -'"^-
{4063 444- 1430
tnjormatton or/ormj from, and mail
tor
Hazardous W«ie Manafefncnt Section
Depanmenl of EnvtronmentaJ QuaUty
Sutte House Suulon
P.O.
Lincoln, Nebraska &8509-§922
[4021471-4218
Nevada
Obtain cnjfbrmacian or /arm* from, and. mail
ftd Jbnns for
Management Program
Division oC Envlf»nffteniaJ Protection
333 West Nye Lane
Carson Oty. Nevada fl97SO
Hampshire
information or Jurms from, and matt
to:
Division of Public HealUi Services
Office of Waste Management
Bureau 0f Hazardous Waste
ClaasiflcaUon & Manifest*
Department of Health and Welfare
Health and Welfare Building
5 H«en Drive
Concord. New H*«p*hl« 03301
IB03J 271-2900
Obtain
.^ew Jency Depafiment of
Eovironmenlal Protection
Aim: Environmental
Bureau of Hazardous Waste Eng ineenng
120 South Sioetoon
Trenton, New Jersey 08625
Page 10
3-E-10
-------
RCRA Part A Permit Application
Tabfe 1 (continued)
U.S. EPA Segi.cn 2
Air and Waste Vlar-aG^ment Division
Hazardous Waste Facilities Branch
29O Broadway. 2 1st Floor
i2l2i §37-4100
Lfi/brmatLort ar/arms J'fam,-
ous Waste Bureau
525 Cammo DC Marques
Same Fe. New Mexico 87801
15051827-1557
.Wad ejjfnjjteted/otrtns ».-
U.S. EPA Region 6
Hazardous Waste Management Division
First Interstate Bank Tower
1445 Roas Avenue. Suite IlOO
Dallas, TX 75202-2733
1214] 665-72OO
Vew York
Obtain in/ormarlon from:
.W ftepflrw I -5:
New York De|»riM enactment »i Human Res
P.O. 3o.< 27637
RaJogh, Norrh Cartsiina 27g
North Dakota
Obtain tnformaiifin 'af-Jafmn/fom, and mat!
campltteti Jorrra to.-
Divisjan of W&sie Managentent
Department of Health and
C'Onsolidaied Laboraioncs
1 20*0 Ml«*o«n Avenue
P.O. Box
Bismarck, North Dakota 51506-5520
(7011 328-5165
Northern Mnj-tvia Islands
Obrain in/onruutan or forms from, and rruul
.comptewd Jb'ffna tor
U.S. EPA aettan 9
Hfaxardous Waste Managemenl Division
Attn; H-2-3
75 Hawthorne Streci
San Ff-ajieiseo . CaJlfo-ntta 94 1 05
[4 3 51 495-8095
Ohio
IA/orma(iort or form* from, and TOIL!
Ohio Env^ronraenta] Proiection Agency
] 8OO WaterMark Drive
Columbus, Ohio 43215-1099
16141 844-2977
Obtain in/oTTno(ion or forms from:
Ctepartmeni of Environmental Quality
Hazardous Waste Management Service
I OCX) N-orthea « 1 Oth Si,re«i
Oklahoma City. Oklahoma 73117-1212
(4O5I271.5338
Pag* 11
3-E-M
-------
RCRA Part A Permit Application
Tab-to 1 (continued)
•'J S- EPA
Haurdnus Waste Manai*«Tien t Division
"trsi .iruersiace Bank Tower
I 445 Ro*nt Avrnue. Suite 12CO
Dallas, TX "5202- 2 73 J
,2141 663-72OO
Or agon
m/br!Tuu:cMi or f 787 1 I -3O87
I.S 1 2]
Page 12
3-E-I2
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RCHA Part A Permit Application
Table 1 (continued)
Obfam information or farms from, and mail
completed forms t&
Division of Solid an Hazard MIS Waste
Department oJT Environmental Quality
'5 •"» 3f»v " ,i-l'a'3"'i
5«it luute Clr/, Utah 341 i 4-4880
Vczaunt
Obtain ui/ortnofWR or forms from, and maJ
asmpteed /brms to;
Waste Mafimfement Division
Agency of Environmental Conservation
!O3 Sauth Main Street
Wa,tertaury. Vermont 05676
241-3S88
Otuoin m/ormatton from;
Virgin Islands Department of
Planning and Natural Hesourees
Division af Environmental Protection
179 AJtwrta and WeLgunst
St. Thomas, Virgin tslAftd*
693-0114
Obtain, Jorrfit Jrsm
cwnpttifd forms to;
U,S, EPAReponl
Air and Waste Management
Hazardous Waste Fmrfitt^ Branch
2§0 Brcadwmy. 21st Floer
Xew York, New York ICMJ07.
(2121 §37-4100
and
or forms Jtom, ortd! m
-------
Notification of Regulated Waste Activity
U,S, =?A
Table 2
Ccfitaets ?crth« Fart A
U.S, EPA Region 1
RCRA Support Section
JFK Federal Building
3-oiton. MA 02203-221 1
,6171 SaS-3420
, .V^ru; Hampshire.
Rhode /stand. Vermont
U.S. EPA Region 2
Air and Waste Management Division
Alto; RCRA Notifications
29O Broadway
2; at Floor
New York. NY 1QQQ7-I866
•2121 S37.4JQG
lVeu.i Jersey. .Vruc Vbrfc fti*rto
Rico, Virgin: Islands
U.S. EPA Region 3
RCRA Programs Branch 13 HW50J
B4 1 Chestnul Street
Philadelphia. PA 19107
12151 SfrS-SQi&a fpA. DO
12 LSI f/A. WV« OE. MO]
District O/ Columbia,
J%ruTs^^li,iaiiiia. Virginia.
West Virginia
U.3. EPA ItcgioB 4
Hazardous Wa«ie Management Division
SCRA Permirani Section
345 CourtJand Street. ME
A dan la. GA 3O36S
1404.1 347-3433
Alabama, fiends,
Kentucky, Mississippi.
Cawlina. South Carolina.
Tennessee
U.S. EPA teflon S
HCRA AccMUes
P O. BoxA3Sa7
Chicago. IL 6G69O
1312! 886-4001
JlisnoLs. Indiana, \Hcntgan,
3ttinnts®ta. Ohio. Wisconsin
U.S. EPA Region 6
Hazardous Waste Management Division
First Interstate Bank Tower
1445 Ross Avenue. Suite 1200
Dallas, TX 75202-2733
5- '2CO
Arkansas, Lou.Lsto.no,
Oklahoma,
0.8, BPA Region 7
HCRA 8nutch, Pfrmittlng Section
726 Minnesota. Avenue
Atm- WSTW/RCRA/PRMT
Kansas CHy. KS 66101
19 i 31 S5 3 -7020
JQIHCL Kansas. Mttseurt,
U.S. EPA
Wmsie Management Division
I Sill Street. Suite 5OO
Denver. CO 8-0202-2405
(3O3J 312-6319
Co4orado. Moniana,
US EPA Region 9
Matardau* Waste .Management Dlvtslon
75 Hawthorne Street, H-3-4
Sac FfmncJscs, CA 54 105
Hi 5)
, ArR*rican
.Vorthem Mariana
U.S. EPA Regloa 1O
Waste Management Branch. HW- tOl
1 2(K3 Sixth Avenue
Seattle. WA98101
I206ISS3-12S3
Alaska. Idaho, Gr«y»n.
Pmgm 14
3-E44
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RCflA Part A Permit Application
V. Part A - Line-By-Line Instructions
This form must be completed by ail applicants.
Please type or pnm in the unshaded area only leaving a blank box
K^v«?*r. -.vcrds. The boxes art soacr-i a: i/-i" intervals which
accommodate elite type ,12 cnarccrers per inch;. When typing, hit the
spnce bnr fvici be'.'v^-r. characters !f vcu pnn:, place each character in
* box, Anbreviate if necessary to stay within the number of boxes allowed
for fach item. If you must use additional sheets, indicacc clearly the
number of the Item on the form to which the information on the separate
sheet applies.
Unless otherwise specified In the instructions to the form, each item muse
be answered. To indicate that each item has been considered, enter "MA"
for not applicable if a particular item does not fit the circumstances or
characteristics of your facility or activity,
If you have previously submitted information to EPA or to an approved
State agency which answers a question, you may either repeat the
information in the space provided or attach a copy of the previous
submission.. Some items in the form require narrative explanation. If
more is necessary to answer a question, attach a sheet
entitled "Additional Information."
Note: When submitting a revised application, applicants must resubrmt
in. their entirety each item on the application for which changes are
requested, [n addition. Items L n. IIL VI, VTI, VTH and XVTI1 must be
completed, All other sections may be left blank.
Estimated Btyrden; Public reporting burden for this collection of
information is estimated to be 27.1 hours, including time for reviewing
instructions, searching data sources, gathering and maintaining
the data needed, and completing and reviewing the collection of
information. Send comments regarding the burden estimate or any other
aspect of this collection of infoirmatjon, including suggestions for
reducing this burden, to Director, Regulatory Information Division. 2136.
U S. Environmental Protection Agency, 401 M St., S.W.. Washington.
D.C. 20460; and to the Office of Information and Regulatory Affairs.
Office of Management and Budget. Washington. D.C. 70503.
Pag* 15
3-E-J5
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RCRA Part A Permit AppieatJen
Item I - ID Numbers):
A, First Fare A Submission: Place an "X" in box if uns is r_he
facility's first Part, A submission under a current or previous
ownership.
21. Fart A Amendment: P«a« an "X" in this box if this is an
ime'-drr.ent to a rrror Pan A application for this factli
amendment number. II* known.
-
C. EPA ID riasBber; Space la provided on Form A for Insertion of your
EPA Identiflcattan Number, ff you have an existing facility, enter
your Identification Number. If you don't know your EPA
rdentfficatton Number, please contact your EPA Regional Office [see
Table 2), which will provide you with your number, or send you an
application fNotificatiGn of Regulated Waste Activity (EPA Form
8700- 12J] to apply for an EPA Identification Number, If your facility
is new (not yet constructed) or you do not have an Identification
Number, leave this item blank,
D. Secondary ID Number: Enter any non-EPA ID number that your
facility has been issued. For example, for wastes regulated by a
State or authority, give the ID number that the other authority
issued,
Item II - Name of Facility:
Enter the facility's official or legal name. Do not use a colloquial flame.
Item 111 - Facility Location:
A. Location: Give the address or location of the facility in
Item II of this form. Please note that the address you give for Item III
must be a physical address, not a post office box or mum number. If
the facility lacks a street name give the roost accurate alternative
geographic Information (e.g.. section number or quarter section
number from county records or at intersection of Rts, 425 and 22],
County Name and Co4«: Give the county code, if known.. If you do
not know the county code, enter the county, township, borough,
parish, or other local government entity name, from which EPA can
automatically generate the county code. To obtain a list of
codes, contact the National Technical Information Service. U.S.
16
3-R-I6
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flCRA Part A P«ranlt Application
Deoarcr.er.t. cf Cso-jrierce, Springfield. '/irgirja, 22161 or at !?03l
Processing Standards Publication (F1PS PUB} nuir.ser 6-3,
B. Land Type: Using the codes listed, below, indicate in IIL B. the code
which best the current legal status of the land on which
the facility is located:
P «
S =
I = Indian
P » Private
C » County
M » MutUcipal"
O = Oisblct
O = Other
•Note: If the Loral TVpe is fceajLdesc>lfoed as Iruiten, Councy or
use eoctes. Ottenuis*;. u5C MununpoL
C. G«op»pWc Location; Enter the latitude and longitude of the
facility in. degrees, minutes, and seconds. For larger facilities, enter
Hie latitude and longitude at the approximate mid-point of the
facility. You may use the map you provide for Item XV to determine
latitude longitude. Latitude and ten^tude information is
available from Regional Offices of the U.S. Department of Interior,
Geological Survey, and from State Natural Resource or
Environmental Agencies,
D. Facility &dM«ac« Date: Enter the appropriate date that applies
your facility from the following:
1 .. The date that hazardous waste operations at the facility
commenced;
2. The date construction on the facility commenced; or
3. The date operation is expected to begin,
17
3-E-I7
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RCRA Part A Permit Application
Item IV - Facility Mailing Address:
enter the Facility Mailing Address. If the Address and the
Facility Location (Item III) are the same, you 'same* in the space
for Item IV.
Item V - Facility Contact:
G»ve die na_—c. ;itl<*, wcrit telephone number cfa person who is
thoroughly familiar with the operaUoa of the facility and with the facts
reported an this application and who can be contacted by reviewing offices
if necessary.
Item VI - Facility Contact Address:
A* Code: If the contact address is die same as the facility location
address listed in Item in or the facility mailing address listed in Item
IV. place an "X" to the appropriate box to Indicate where the corttacc
may be reached. If the facility location address, the facility mailing
address, and the facility contact address are aJJ the same, mark the
"Location" box If the contact ts not the same as those addresses in
either Item III or IV. place an 'X" in the "Other" and complete
Item VLB. If an "X™ is entered, in cither the location or mailing
VI. B, should be left Wank,
B. Address: Enter the facility contact only if the contact
address is different from either the facility location address [Item 111)
or the facility maHtag address (Item IV) and VI.A., -was left
blank,
Item VII • Operator Information:
A. Nam«: Give the name, as It is legally referred to. of the person,
flrm, public organization, or any other entity which operates the
facility described in this application. This may or may not be the
same name as the facility. 'The operator of the facility ts the legal
entity which controls the facility's, operation rather than the plant or
site manager. Do not use a colloquial name, Also enter the
telephone number and address where the operator can be
contacted.
Page 18
3-E-1S
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BCRA Part A Permit Application
B. Operator Type: Using the codes listed below, indicate in VII. B. the
the facility:
F = Federal
S = State
1 = Indian
? = Private
M = Municipal"
D = District
O = Other
"Note; If the Operator Type is frggf otg^gtg»ec| as Indian. County or
ptease use chose codes. Otherwise* use MuntcfpaL
C, Operator ladicmtor: (If this is your installations jtrsi Part .A
application VII, C. Manic and skip to Item vm. (/"this Is a
subsequent Part A appteatfanu eomptet* Item Vff.C. as dlrecteci
If the operator of this facility has changed since the facility's
previous Part A was submitted, place an "X" in the box marked "Tes"
and enter the date the operator changed.
If the operator of this facility has not changed since the facility 5
previous Part A was submitted, place an 'Xs* in the box marked "Mo"
.and skip to Item. VTTI,
If any additional operators have been added or replaced since the
facility's previous Part A was submitted, place an "X" in the box
marked "Yea/* Use the comment section in .3GX to list any additional
operators, the dates they became operaborm. and which operatorls}
lH any) they replaced. If necessary attach a separate sheet of paper,
Item Vill - Facility Owner:
A. Ifute: Enter the naroc of the legal ownerlsl of the Installation.
Including the property owner. Also enter the address and phone
number where this individual can be reached. Use 'the comment
section or additional sheets if necessary to tot more than one
owner.
Pag* if
3-E-19
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HCflJI Part A Ptfffllt Application
B. Owner Type: Using the codes listed below, indicate m VtJI.B, the
the facility:
F = Federal
I = Indian
P = Private
C = County
M = Municipal"
D * District
O = Other
•Note: If the Operator Type is test described as Indian. County or
District, please use those codes, Otherwise, use Municipal.
C, Owner Indicator: (If this is your tnstaltaEtoas Jirst Part A application,
teawe vm C. btetJc artd statp to ft«rm DC If this is a subsequent Part A
application, complete Item VKT.C. as directed below.)
If the owner of this facility has changed since the facility's previous
Part A was submitted, place an "X* in the box marked "Yes" and
enter the date the owner changed.
If the owner of this facility has not changed since the facility's
previous Part A was submitted. an "X" in the box marked ™W
and skip to Item DC.
If any additional owners have been added or replaced since the
facility's previous Part, A was submitted, place an "X" in, the box
marked, "Tes," Use the comment section to XDC to list any additional
ownerfs). the dates they became owners, and which owners) (if anyj
they replaced. If necessary attach a separate sheet of paper,
Item IX - SIC Codes:
List, in descending order of significance, the foyr digit standard industrial
classification (S1C| codes which best describe your facility in terras of the
principal products or services you produce or provide. Also, specify each
classification in words. These classifications may differ from the SIC codes
describing the operation generating the hazardous wastes.
SIC code numbers are desertptions which may be found in the Standard
Industrial ClassiflcaHon Manual prepared by the Executive Office of the „
Pig* 20
3-E-20
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RCRA P«rt A Permit Application
President. Office of Management and Budget, which is available from the
i Prr.t;«if Office *.V^shjr.5P..-n. D,C, Use the "urr-.it eciitirn cf
code for your facility, comae: your EPA (see Taole 21.
A. Permit Type; Using the codes listed below, enter a letter on the
form for all e'Jisr er.vir:rjmer-tal permits the facility has received, cr
for which the facility has an application, even if the permit has
not yet 'been, received,
N = NPDES (National Poilucant Discharge EliminaUon System,
Clean Water Act)
P - PSD (Prevention of Significant Deterioration, Clean Air Act)
R = RCRA (Resource Conservation and Recovery Act)
U » UIC (Underground Injection Control, Safe DnnMng
Water Act]
F * EPA 404 (Dredge or Fill Permits under Sec ton 4O4 of the
Clean Water Act)
E = Other relevant environmental permits. List any other
relevant Federal (e.g.. permits under the Ocean Dumping
Act]. State (e.g.. Slate permits for new air emission sources
in nonattainment under Pan D of the Clean Air .Act
or State permits under Section 404 of the Clean Water Act},
or local environmental permits or applications,
B. P*nnit Number: Give the number of each presently effective permit
issued to the facility for each program., or if you have previously fled
an application, but have not yet received a permit, give the number
of the application, tf you have more than one currently effective
permit for your facility under a particular permit program, you may
list additional permit numbers on a separate sheet of paper,
C.
DeflcripCioti: Use the space provided for any additional Information
identifying or describing the permits,
Page 21
3-E-21
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RCflA P»rt A Permit Application
Item XI - Nature of Business:
Snedy describe the nature of your [e.g.. predicts produced or
services provided). If more space ts needed. attach additional
Item XII - Process Codes and Design Capacities;
The information in Item XII describes aU the processes that wtU be used
to treat, store, or of hazardous waste ac the facility. The design
capacity of each process must be provided as part of the description. The
design capacity of injection wells and landfills at easting facilities should
be measured as the remaining, unused capacity. Tank storage should
refer to each tank, not each tank farm. Please indicate the location of
each process listed in Item XII on either the map provided for Item XV or
the photographs provided! for Item XVH, Use the line number from Item
XII to Indicate where the process(es) are located. See the form for the
detailed Inatruc to ftem XII.
Mote: Process codes TSO-TS3 are desigpntated for Boilers Industrial
Furnaces (BlFsf as regulated under 40 CFR Part 266. Subpart H,
Item XIII - Other Processes:
this space to describe oilier processes that did not have a specific
process code listed In Item XII.A. of the form. Follow the tostryctions in
Item XII.A. on the form for other process codes (i.e.. D99. S99, T04. and
X99 process codes).
Item XIV - Description of Hazardous Wastes:
The information in Item XTV describes ail the hazardous waste that will be
created, stored, or disposed at the facility. In addition, the processes that
will be used to treat, store, or dispose of each waste and the estimated
annual quantity of each, waste must be provided. See the form for the
detailed instructions to Item XIV.
Item XV - Map:
Provide a topographic map or maps of the area extending to at least one
mile beyond the property boundaries of the facility. The map must clearly
show the following:
Page 22
3-£-22
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RCRA Part A Permit Applfeattan
The legal boundaries of the facility:
* Ths Iccauon and scna* number ci' each os'your existing ar.c
proposed intake and discharge structures;
Location of all processes listed in Items XII and XIII identified
**$•* f f*^ip"r^ j^-a*e s. if >#*•,/~% A *
*^j ^Jk rfV-.SOi \._i™C,
Each well, where you inject fluids underground:
• All springs and surface water bodies in the area, plus all
draiMng water wells within 1/4 mile of the facility which are
identified in the public record or otherwise known to you.
If an Intake or discharge structure, hazardous waste disposal site, or
injection well associated with the facility is located more than one mile
from the plant, include It on the map, tf possible. If not, attach additional
sheets describing the location of the structure, disposal site, or well, and
identify the U.S. Geological Survey {or other] maps corresponding to the
location.
On each map« include the map scale, a meridian arrow showing north.
and latitude and longitude at the nearest whole second, On all maps of
rivers, show the direction of the current,, and in tidal -waters, show the
directions of the and flow tides. Use a 7-1/2 minute series map
published by the U.S. Geological Survey, which may be obtained through
Ehe U.S. Geological Survey Office listed below. If a 7-1 /2 minute series
map has not been published for your facility site, then you may use a 15
minute .series map from the U.S. Geological Survey. If neither a 7-1 /2 nor
15 minute series map has been published for your facility site, use a
plant map or other appropriate map,, and include all the requested
information; in this case, briefly describe land uses in the map area (e.g..
residential, commercial).
You may trace your map from a geological survey chart, or other map
meeting the above specifications. If you do, your map should bear a note
showing the number or of the map or chart it was traced from.
Include the names of nearby towns, water bodies, .and other prominent
points.
Page 23
3-E-23
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Part A Permit Application
TQ obtam map indexes contact one of the foUowtng Earth Science
Salt Lake City - ES1C
9105 Federal Building
Salt Lake Citv. LT 84 138
i 975-3742
Anchorage - ESIC
4230 University Dr., RJTL 101
.^c^rsTe, ,*_•; *rJ£0£-4Sc4
I9O7) 786-7011
Fairtanks -
Box 12, New Federal Building
101 Twelfth Avenue
Fairbanks, AX 1
f9G7) 474-7487
1907} 474-7598
Lakewood - ESIC
Box 25046. MS 504
Denver F'ederal Center
Denver, CO 80225
1303)
Menlo Park - ESIC
Room 3128,, Bonding 3, MS 532
345
Menlo Park, CA 94O25
Fteston - ESIC
507 National Center
Reston. VA
[703) 648-6045
- ESIC
1400 Independence Road,. MS 231
Rolla. MO 65401
308-3500
Item XVI - Facility Drawing;
All existing facilities must 'include a drawing showing the general layout of
the facility. This drawtng should be approximately to scale and fit on an 8
1 /2" x 11" sheet of paper. This drawing should show the following;
Sioux Falls - ESIC
EROS Center
Stoux FaJJa, SD 57198-0001
Spokane - ESIC
U.S. Post Office Building. Room
135
West 9O4 Riverside Avenue
Spokane. WA 1 - 1 088
353-2524
Stennis Space Center - ESIC
Building 3 101
Stennis Center, MS 39529
[601] 688-3541
Washington, D.C. -
Department of the Interior
Building
1,8th & C Streets, NW, Room 265O
Washington. D.C. 20240
208-4047
1,
The property boundaries of the facility:
Page 24
3-E-24
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HCHA Part A PwrnH Applieatton-
3, TIic nair.e 01 each operation (e.g., multiple hear-Ji mc:neracor. drura,
,\reas 3i~ past storage, treatment, or disposal operations;
Areas ox ."uture stsrage. t,reatrr:enL or disposal operations;
6. Th« approximate dimensions of the property boundaries and all
storage, treatment, and area*- (Note: where applicable, use
the process codes listed in Items XII and XIII to Indicate the location
of all, storage, treatment, and disposal areas.]
Mew facilities do not have to complete Item XVI,
Item XVII - Photographs:
Ail existing facilities must include photographs that clearly delineate aH
existing structures, all ejdstinjf areas for storing., treating, or disposing of
hazardous waste: and all known sites of future storage, 'treatment, or
disposal operations, Photographs may be color or black and white,
ground-level or aerial. Indicate the date the photograph was taJcen on the
back of each photograph. Use the process codes listed in Items XJ1 and
to indicate One location of all storage, treatment, and disposal areas.
Item XVIII - Certifications):
All facility owners must sign Item XVU1. If the facility will be operated by
someone other than the owner, then the operator must sign Item
XVI U. Federal regulations require the certification to be signed as follows:
A. For a corporation,, by a principal executive officer at least the level of
vice president:
B. For a partnership or sole proprietorship, by a general partner or the
proprietor^ respectively: or
C. For a municipality. State, Federal, or other public facility, by either
a principal executive officer or ranking elected official,,
The Resource Conservation and Recovery Act provides for severe penalties
for submitting false information on this application form,
Page 25
3-E-25
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RCRA Part A Permit Application
of the Conservation Recovery Aci provides
ihzi ",lr,y person *yr.-3 *cr,,c<*tr.|ly rji^j^s iir/ fail-* so,:-—eru CT
in any application. ...shall, upon, convic'don be subject to a
of not ihan for day of violation, or to
imprisonment noi to «ce?d one '/ear, or both,"
Page 25
3-E-26
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3-E-33
-------
ATTACHMENT F
LOGIC DIAGRAM FOR DETERMINING APPLICABILITY OF SUBPART CC
STANDARDS
(2 Sheets)
-------
Is the facility an interim status or permitted TSD facility that
treats, stores, or disposes hazardous waste in tanks, containers,
or surface impoundments?
No
Is the facility a large quantity generator of hazardous waste that
accumulates waste for up to 90 days in tanks or containers?
Facility and/or waste management units are not subject to
Subpart CC air emission contro standards
Do any of the facility's waste management units consist of:
• Waste management units into which no hazardous wastes are added on or after 6/5/95?
• Tanks and surface impoundments into which hazardous waste addition has stopped and which are closing?
• Containers with a capacity < 0 1m3?
• Waste management units that are used only for onsite treatment or storage of remediation wastes?
• Waste management units that are used only for treatment or storage of mixed wastes?
• Waste management units excluded from regulation under §§264 l(g) or 265 l(c)?
• Waste management units operating with air emission controls according to requirements of an applicable CAA regulation
under 40 CFR Parts 60, 61, or 63?
• Tanks equipped with process vents as defined in 40 CFR 264 1031
Yes
No
§264 1080(a),(b)
§265 1080(a),(b)
Do hazardous wastes managed in the waste management units
contain an average volatile organic concentration of ^ 500
ppmw at the point of waste origination?
Yes
Are hazardous wastes treated to remove or destroy organics to
levels specified in §§264 1082(c)(2) or 265 1083(c)(2); or do the
wastes meet the concentration units specified in the LDR,
§268 40; or have the wastes been treated by the treatment
technologies in §268 42(a) or an equivalent EPA-approved
treatment method?
|
W
Is the unit a tank used for biological treatment of a hazardous
waste as specified in §264 1 082(c)(2)(iv) or §265 1 083(c)(2)(iv)?
NO
Is the unit a tank used for bulk feed of hazardous waste to a
waste incinerator where the tank is located in an enclosure
vented to a control device as specified in §264 1 082(c)(5) or
§265 1083(c)(5)?
No
To next page
Source: Elsevier Science Inc
Waste management units are exempt from air emission control requirements Make initial waste determination by 12/6/96
Maintain documentation of waste determinations with complete description of method employed; either direct measurement
or by knowledge of the waste Prepare site sampling plan
§264 13, §265 13
§264 1082(c)(l)
§265 1083(c)(l)
§264 1083(a)
§265 1084(a)
Waste management units downstream of hazardous waste treatment are exempt from air emission control requirements
Implement treatment or place implementation schedule in operating record by 12/6/96 Prepare site sampling plan
§264 13, §265 13
§264 1082(c)(2)
§265 1083(c)(2)
Note: Waste Management unit = tank, container, or surface impoundment
LOGIC DIAGRAM FOR DETERMINING APPLICABILITY
OF RCRA SUBPART CC AIR EMISSION CONTROL
STANDARDS TO WASTE MANAGEMENT UNITS
3-F-l
-------
From previous page J
Implement air emission control requirements or
place implementation schedule in operating record
by 1 2/6/96
Does the hazardous waste managed in the tank meet all of the
following criteria?:
1 The maximum organic vapor pressure is less than the vapor
pressure limit for the following tank design capacity
categories:
• if capacity >. 151m3, vapor pressure limit = 5 2 kPa
• if capacity >. 75m3 but < 151m3, vapor pressure limit =
27 6 kPa
• if capacity < 75m3, vapor pressure limit =766 kPa
2 The hazardous waste is not heated
3 The hazardous waste is not treated using a waste stabilization
process
Yes
Tank Level 1 Controls
• determine maximum
organic vapor pressun
• use fixed-roof design
§264 1084(c)
§265 1085(c)
§264 1084(b)
§265 1085(b)
Tank Level 2 Controls
Use one of the following:
• fixed roof tank equipped
with an internal floating
roof
• external floating roof
tank
• tank vented through a
closed vent system to a
control device
• pressure tank
• tank located inside an
enclosure vented
through a closed-vent
system to an enclosed
combustion control
device
§264 1084(d)
§265 1085(d)
J
Containers
Surface Impoundments
„
Is capacity > 0 1m3?
F J
-^
, , ,
Subpart CC does not apply
l l l J
Use one of the following to control air pollutant
. . r
emissions
Is the container used for treatment
using a waste stabilization process?
§264 1086(b)(2)
§265 1087(b)(2)
I Is capacity > 0 1m3 but < 0 46 m3?
)JTNo §2641086(b)(l )(i)
[
]
"
Is container in light material
service as defined in 265 1 081
N°
Container Level 1 Standards
Use one of the following:
• DOT container packaging
and handling
• Covered container (non-
DOT)
• Open-top container with
suppressing barrier
Yes
U-
§264 1086(b)(l )(n) and (hi)
§265 1087(b)(l)(n) and (hi)
Container Level 2 Standards
Use one of the following:
1 DOT container packaging
and handling
1 Container that operates
with no detectable
emissions as defined in
§265 1081
1 Container demonstrated to
be vapor-tight
§264 1086(d)(l)
§265 1087(d)(l)
as applicable
Note: Waste Management unit = tank, container, or surface impoundment
Source: Elsevier Science Inc
ting membrane
cover
^
1 —
Cover vented through
a closed-vent system to
a control device
§
§265 1086(b)(l) and(c)
§264 1085(b)(2) and (d)
§265 1086(b)(2)and(d)
Container Level 3 Standards
Use one of the following:
• Container vented directly
through a closed-vent system
to a control device as
specified in §264 1087 and
§265 1088
• Container vented inside an
enclosure exhausted through a
closed-vent system to a
control device as specified in
§264 1086(e)(2) and
§265 1087(e)(2)
Control device must be one of
the following:
• Control device that
achieves 95% reduction
of total organic content;
• Enclosed combustion
device designed and
operated according to
§264 1033(c)and
§265 1033(c)
• A flare operated
according to
§264 1033(d)and
§265 1033(d)
§264 1086(e)(l)
§265 1087(e)(l)
I
§264 1087(c)(l)
§265 1088(c)(l)
LOGIC DIAGRAM FOR DETERMINING APPLICABILITY
OF RCRA SUBPART CC AIR EMISSION CONTROL
STANDARDS TO WASTE MANAGEMENT UNITS
3-F-2
-------
ATTACHMENT G
EXAMPLE CLOSURE PLAN AND FINANCIAL REQUIREMENTS
(20 Sheets)
-------
ATTACHMENT G
AND
{20
-------
, Ki PUM Ei*A SO #KSI>*-?iJ*-.'>
SECTION I
CLOSURE PLAN AND FINANCIAL REQUIREMENTS
The information in this section is submitted in accordance with, 40 CFR
27U.14(b){ 13), The purpose of this Closure Plan is 10 ensure that the Lafarge Fredonia
plant BIF uruts wiJt be dosed pursuant to 40 CFR 2644 11 through 264,115, 266.102, and
KLA.R. 23-3t-Sa. Two waste handling units: the pyrolyzer and the dry fuels
have been closed under a separate plan, Soil sampling for these mil be
covered in this plan. The discussion of financial requirements is in accordance with 40
CFR 264,142, 264.143, 264.147. and K.A.R, 28-31-Sa, The Closure Plan t$ designed to
thai, after closure,, the Lafarge Fredonia plant will;
» Not require further maintenance and control:
* Minimize or eliminate threats to human health and the
environment; and
» Prevent the escape of hazardous waste, hazardous waste
constituents, or contaminated! runoff to soil groundwater, surface
water, or the atmosphere.
The subjects discussed in this section include the:
• Closure Plan;
* Closure cost estimate;
• Financial assurance mechanism for closure; and
• Test for financial responsibility.
A copy of this Closure Plan, and all revisions to it, will be maintained at
the piant until completion of closure certification has been submitted and accepted, in
accordance with 4CJ CFR 264.112(c), Lafarge will submit a written notification to EPA
April 1*1* Pcrnui ApplwatHM SCCUIMI 3 - Oohirt PlMt ami FIIMJKMI Rc^iuncmcAt* Ftp I-1
RTF,.Ml
U1KWJ1 rpf
-------
L-if.tf(t t'ofporaiioft ffedonu. KS Plinl EPA ID *K5DtW"i4*OJ-i
Region VII in obtain authorization so amend the closure plan if I| changes in the
operation plans or facility design affect the plan: 2) the year of expected closure changes,
or 3} modifications to the plan become necessary because of partial or final closure
activities. Alt requests for modifications 10 the Closure Plan will be made in writing to
EPA Region VII..
The Plant Manager, or his/her destgn.ee, is responsible for ensuring that
the Closure Plan is updated. He/she will ensure that all copies, of the Closure Plan are
as necessary by sending out any amendments that have incorporated into
the copies of the Plan.
EPA Region VII and the Kansas .Department of Health and Environment
(KDHE) will he notified in writing of the intent to close the Lafarge BIF units at least
45 days before the initial date of final closure activities. In accordance with 41} CFR Pan
264, Subpart G and K.A.R, 28-3 1 -8a, within 60 days of completion of final closure,
Corporation and an independent, registered Professional Engineer will
certification to EPA Region VII and the KDHE that the Lafarge Fredonia plant BIF
units have been closed in accordance with the specifications in the approved Closure
Plan-
A Post-Closure Plan is not required since the waste management activities
at ihc plant do not include the land disposal of hazardous waste. The kiln and all
ancillary equipment would be decontaminated, and all waste residues would be removed
from the premises, Therefore, no waste inventory would remain at the plant following
closure,
If the Systech facility is to be closed simultaneously, then closure of that
facility will occur according to the closure plan, in the Systech permit.
"if>*!, i'ff. Ptmtit Applicaiior! Semen I • OWWP? Pun vat FwHUKuii Req««r«nent»
3-G-;
-------
TD
The procedures for final closure of the kiln, a! ihe Lafarge pi
including waste removal, cleanup, and decontamination activities, arc described in this
Plan TTie closure cost estimates are based on wing third-parry, outside contractors^
However, it is more reasonable to assume that (he majority of the activities would be
conducted by plant employees.. The closure procedures and cost estimates have been
established for both Joins currently operating at the Lafarge FredOOJa plant,
I-U Disposal of Maximum Inventory of Hazardous Liquid Waste-Derived Fuel
All hazardous liquid waste-derM fuels burned in the Lafarge Fredonia
plant's mm are stored ai an adjacent storage facility operated by Systecl) under RCRA
per™ #KSD98Q633259. At closure, Lafarge will receive no additional waste fuels from
Systech so that no inventory of hazardous waste mil remain on Lafarge property, The
of the m«imu« inventory of hazardous liquid w»M.derived fuel is covered in
the Systech Closure Plan and closure COM estimate for that Facility,.
No hazardous waste will be burned dunng shut down. The kilns will burn
only coal for 4 hoyrs ted then be shut down o« at a time so that ihe refractory brick
from the closed fain can be processed .as raw material in the other loin. The refraciory
brick from the remaining kiln will be contract-hay led to another Lafarge plant, where '
the brick wUJ be utilized as raw material If no other Lafarge kiln is ava.kble to burn
the brick, ihe material wilt be hauled to a properly permitted disposal faciliiy. The
inside of the kiln and all ancillary equipment in contact with hazardous waste will be
decontaminated by steam cleaning. Mi waste residues will be rented from the
Therefore, no hazardous waste inventory will rematti at the plant following
closure
ft ft IO
»
qpf
3-C-3
-------
f.1.2 Sampling and Analysis of Contaminated Soil
'Die Lafarge Fredonia plant was designed and is operated to eliminate the
possibility of soil contamination in the event of a spill or leak. However, should a iptlj
or leak affect unprotected soil, samples will be and analyzed to determine the
extent of contamination.
II necessary at the time of closure, a detailed soil sampling and analysis
plan will be prepared and submitted to the fCDME and EPA Region VII for review,
comment, and approval. The plan will be prepared in accordance with the prevailing
regulations applicable to the identification of soil contamination at the plant, to
determine appropriite remedial actions, if any, that will need to be completed before
certification of closure, II necessary, soil sampling for the pyrolyzer and. dry fuels facility
will be incorporated into the soil sampling and analysis plan.
The soil sampling, analysis, and remedial activities will, tnclude, but not be
limited to, the following general procedures:
Soil core sampling to a depth of approximately 2 feet from 10
locations;
Sample analysis by a certified laboratory for approximately 10
analytical parameters x 30 samples (3 samples per boring site);
Removal or on-sitc treatment of approximately 100 cubic yards {100
tons) of soil: and
Resampling and analysis to verify effectiveness of remedial activities
(assuming 10 samples IE ID analytical parameters).
*% fermi! Applicants Se«i«a I - r>ti*rr l*j« ind Fiuacul fctnuiremenu Pif» 1-
)
fp(
3-G-4
-------
. KS J»l«n( KFA ID
A1J le clinical details are subject to approval by the KBHE and EPA
Region VII before initiation of any remedial activities.
1.2 Closure Schedule
The KDHE and EPA Region VII will be ooiified of the intent to close che
Lmfaige Fredonia plant BIF units at least 45 days before the beginning of final closure
activities. Within 90 days after receipt of the final shipment of waste matenaJs, all
hazardous waste inventories will have been treated or disposed. Within 180 clays after
receipt of the final shipment of waste materials, all closure activities will have been
completed in accordance with the approved Closure Plan, In accordance with 4
-------
KS flint
EPA ID *KSB
Table M
Projected Schedule of Closure Activities
Closure Activity - Kiln $1
1 Disposal of existing waite
I Decontamination of eemen! kilnh
'
3. Decontamination of ancillary equipment
Start Date
Dav 30
Day "JO
Completion Date
Dav 'JO '
Da> 12>i
Dav '.20
«— • "U— m — •
I 4 Disposal of decD'Oiaminancn residuals and
rimes
^ Completion of closure and submission of
certification to K.DHE and EPA Region VII
I Day m Day 120
1 Dav :20
1
i)
!|
Day 180
Closure Activity - KJln #2
I.
Disposal of existing wa.ste
2. Decontamination of cement kilns
V
i.
Decontamination of ancillary* equipment
Disposal of decontamination residuals and
rinses
5. Completion of closure and submission of
certification to KDHE and EPA Region VII
Start Date
Day I
Day 30
Day 90
Day 60
Day 120
Completion Date
Day 90
Day 120
Day 120
Day 120
Day ISO
Permit Application' Section I • Ctawin flan Md Fsa»*
-------
Lsfaifi Corporation
Fndonia. KS Flan!
EPA 10
Table 1-2
Projected Closure Costs (1994 Dollarsj
CnaCrscM Ktfr*ctot> Biiti Dupr>»l •
1 Rtrmtittv Bnck Rf/WMl
; rranspdrwici" for fncmeraitcfl
Re?f»fitirv Bnrt Oitpmal
Subtotal
L sou in M DttffiMaBtiBaitiiQ. StrncM:
Sieam Oti*.»n|
Sunplisf und AMJIVSU
Sutucdl
Sod teiftet ««d Aia^i
Oupoiinon «f C tFatiuunjipd $>i;
Uter
Toftipan
U-if^ul
SrjOiOUl
Clo«ir* Ctftifk^it:
Uihcr
Ex^nses
S^MUI
SUBTOTAL
int. AdmnwniiM
H« CHIIWIIKIM
TOTAL
Q^^
2
I IDO mile»
I
2
\
;ijj h«
!OD ions
IQOlm
»hn
I0d^»
C«MMi
ILJJM
U*0 * WlS/siile
si0.no
tSJOO
1S1JM
SSI
»
$£yf
Si'fir?
STI^
c*«
S34,«B
IS 241
S2I.4CC
HOMO
151.300
ss. too
KJ.TV)
SSSM
iittia
ToUJ
*y»wi
SJUW
B 1.293
561.-W
W580
si^ais
^ IS 401
MX*!
JJSJSII
fhcnui
I - Cte»u« nm ind Rai*c«il
3-6-7
-------
&n»rrt!on Fcedo**. KS Flint
The costs for removal of tie refractory brick and transportation of ihe
brick to another Lafarge plant, or outside contractor for incineration, as well as
contractor decontamination of the kilns and ancillary equipment, have been generously
estimated. Contractor decontamination costs include decontamination activities, and
samp ling, analysis, transportation, and disposal of decontamination residuals and rinse
waters. Table 1-2 details these costs and the balance of the associated with soil
sampling, analysis, and removal of any contaminaie-d soil, as well as administrative costs
and contingency hinds. The closure cost estimate is on a low-probability, worst-
case scenario.
L4 Financial Test for FinancMl Responsibility
Lafarge Corporation has chosen the Financial Test and Corporate
Gymrantee for Closure option specified in 40 CFR 264.143(1) and K.A.R. 28-31-Sa to
establish financial assurance for closure of the Lafarge Fredooia plant BIF units,
Lafarge has chosen the Financial Test for Liability Coverage specified in 40 CFR
264.147(0. 264.l5l(g); and K.A.R. 21-31-ga, to the liability requirements for
sudden accidental occurrences. Financial assurance and compliance with liability
requirements for closure of the Lafarge Fred.onia plant kilns are demonstrated by the
documents included in Attachment I-L
Ptraiii AftpliaiM*: Scciifti t - Oman Hm 1*4 PriMMKMI Reqvimwtt* Pap 14
3-G-8
-------
Ltfirp Carporuuhi Pfcdond, KS ?!*«
EPA 10 f
Attachment [-1
FINANCIAL AND LIABILITY
perm* Afpfctwon: t - PMUR TJMI anmp IA
-------
CORPORATION
March 31. 1996
Dr. Stanley C. Grant, Secteury
Kansas Department of Health and Environment
Attention: Mr. Iota Ramsey
Hazardous Waste Section
Bureau of Air and Waste Management
Forbes Field, Building 470
Topela, Kansas 66620
Subject: Updated Firemen] Assurance Documents
Lafirge Corporation
U.S. EPA I.D. No. KSPQO?i48034
Dear Dr. Grant:
an ihe documents » ctenonscia firnndaj icaonsibiliiv
for closure co« a* also an Irrevocable Standby Lette of Credit for our
cownued responsibility for liability and dnnue costs. Aim encL«l is a
**"* COT™ ABnwI Rep°rt aKl a *" of
& CampAny concerning their
Please contact me at (703) 264-3600 if you have any questions.
Sincerely,
LAFARGE COI
Ca
fice resident Eiivironmenial & Governroenia] Affairs
Enclosure
cc: Horace Compion - Lafarge
Mr. Dennis Grams- USEPA
WPICt
»V*ll«y
Q*h«*' PCJJ JC4-JCOD Fa*:
3-G-IO
-------
CORPORATION
January 25. 1996
Or Stinky C. Grant Secretary
Kansas Bepunnenc of HeaitA and Environment
Attention; Mr. John Ramsey
Hazardous Waste Section
of Air and Waste Management
Field, Building 470
Topeka, KS 6662Q-Q002
Subject- Letter from Chief Fiaaacwl Officer
To Etentanarae 8«h Liability Covenge
and Atturance of Ctoiure or Pose-Closure Cwt
U.S. EPA I.D. No. JCSD00714S034
Dew Dr. Grant:
b.
Sysiech Environment!! Corporation
Systcch EnvironmenlaJ
US. EPA I.D. Not K5DUQ633239
P.O. Be* 111
Soyth Cement Road
Fredotti*. Kansas 66736
Systech EnvirtMimental Corporation
Los Robles Resource Recovery' Facility
U.S. EPA LD. No. CATSIW3 1621
P.O. Box S37
Causey Road 131
Lebee, California 93243
^
(7B3J
R«im Virpn,*
3-G-ll
-------
ftm rferafied:
*
guaranteed are
Systtdi Environmental Corporation
Alpena Waste Fuel facility
U S EPA l.D. No MtD98l20083S
P.O Box ill
Ford Avenue
Alpena. Michigan 497Q7
Laiargc Corporation
Ffsdonia PUnt
U.S. EPA l.D. No. JCSD007I48034
P.O. Box 419
Sauiti Cement Read
Frttlenii, Kartsis 66?36
Lafarge Corporation
AJpem Plant
U.S. EPA LO. No. MID005379607
P.O. Box 3M
14 JO Fonf Avenue
Alpema. Michigan 4970?
Laferge Corporation
Pauldmg Piaat
U.S. iPA l.D. No. OHD 48704*733
P.O. Box 160
County Road 176
Pau.ld;iflg, Ohio 45179
B tht d,r«t or hi^her-cier pir«nt corporation of fte owatr w opcmor.
IOI*re care
H
eon
facility: None..
ta S«« where EPA i. not idmiiusiemt ,hc fi«e«,| nqiiirements
'M a'
H tf 40 CFR Pats
of*.
H
-* ,h r
st are shown for
3-G-12
-------
2, SyKeth L'nviranjneniJi Carpmnmon
D=fnowi!s Wast?. Derived rye,' Facility
US EPA ID No ALD98 I 019045
PO BO* :m~
Arcola
Alabama 367.32
Current Closure C« Estimate is: t{.737,
-------
Lafirgc CorporatHwi
Fredonia Plant
U 5 EPA |.D. Mo, KSDf»7l4tfl34
P.O. BOJS «*?
Cement Raid
. Kansas
Cunrenz Closure Cost Estimate is; S5l7.»4fi
Current Pon-CJasure Cost .Estimate.
Inert LtndfiJI
CKD Landfill Cwrau Chuure Cost Estimae ,s: S3 12.60?
CKD iffldfiJl PoH-Closure Cost Eatmtn «;
Letter of Credit: 5296.600 *«4JME
g- Lafsrge Corporifioft
AIj«na Plant
U.S. EPA LD, No.. MIO005379fi07
P.O.
Alpena, Michigan
Current Closure Cosi Esnma:e is:
Cim«ntPQ«.Clos4treCostEiiimaie:
Men LandfitJ
CKD LffldfiJl Cuf«nl cr«ure Cost Estimwe is: SI.7W.400
CKD' Landfill ftMi^tonjft Cost EstJinBte «; ».703.jM
Lcner of Credit mu«d in J904;
h, Lafar je
U.S. EPA I.D. N
P.O. Sox 160
County Roa4 |7fi
Paujding, dtio 4517?
Current Cloton Cost Estun«e is: ..
Current PojK;ioaure CQH Estimate is: Mane.
CKD LandfiJI Cottemt Ctaurc Cost Estimate is: Sfi39_goo
CK0 LwdfiU PftsiClowe Cosi Estmite t>- I9t6.400
•
3-G-14
-------
(MO for
The TiseaJ
firm
3-G-I5
-------
ALTERNATIVE I
Sum oFcufirat ctoCTre and pga-clonre COK
of iw.naJ aggregate liabiJicy covens;t to be demonstrated
S
3 Syra oj tines I and 2
' 4 Tour l«b,!,t,« lif my portion of your eon csumass is induded » vow uuJ labile* yw
deduct diu portion from thi, line md add dut WICWM » fa« 5 «nd 6) ll«JIJ't'«. >«
" S^ Tanf ibl* net worth
1 6, Ner worth
Lurrent assets
* i. Cunreni liabilities
S269.92t.oqn
9. Met working capital (line 7 mums line 1)
S-4.4g.57j.oon
10. The sum of BK income plus depreciuion. depletion, mi imortizUHMi
1J Total assets « U.S. (required only «f tesi ihin M% of useis a* tanuA m die U.S.)
12. t$ (me S at fcasl SIQ miltioa?
13. Is lux S ai lenst 6 limet tine 3
*. Js line f u least 6 lime line 3
15. Are « feast 90% of MseB (
r« Is tine 3 i at ItMi § rimes line 3?
17. Is Ik* 4 divided by fine 6 less than 2,0?
IS Is line li divided by line 4 greater than 0. \"*
It Is line ? divided by line i greater than 1.5?
SS61..3?* oon
YES NO
« she dait shown inmediMeiy below.
Larry
Sensor Vice fresideni and
CJiief Financial Officer
January 25.
3-G-16
-------
Independent Public Accountant's Report
on Applying Agreed Upon Procedures
To Lafarg* Corporation.
«,Ui«d bv e ^*
* "Wy ***
the ™ttMd " the
Washington., DC
January 25,
3-G-17
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1*9*
-
OUanvevocABLc
KS Mm AS
*«* OF YOURSELVES flY™JS0X£?m*0f CREDIT
•w-"^^^K5ES5i
.OC3
3-G-18
-------
ATATK OF
-
6, i»S3
ixm or omit MO, , J/fol
coRPOMATioir ruooirzA
IFECIAL
3-G-19
-------
MEW
-JCAZ,
AJfO If
two or TWO
3-G-20
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