Cenco_ FILE DOKET P 94-OCR

Mr. Simpson
July 30
page 2 of2
6. Personnel should use adequate handling and short term storage procedures and
equipment decontanrination procedures when handling contaminated media to prevent
the release of hazardous constituents and the possible creation of additional SWMUs.
These procedures should be documented for CTI's field staff to review prior to beginning
work, and for future review by the Section.
Section personnel from the Mooresville Regional Office may visit the site during the excavation
procedure. Please inform the Section one week in advance (if possible) ofbeginning excavation
so that personnel may schedule the visit.
If you have any questions concerning this or other issues, please contact Mark Wilkins of my
staff at [phone], Ext. 224.
Sincerely,
~~z:L~
Sharron E. Rogers /
Remediation Branch Head
Hazardous Waste Section
cc: G. Alan Farmer, US EPA, Region IV
Robin Hedden
Mark Wilkins
re: Sharron Rogers*
Jill Burton i-(J
Surabhi Shah 9!J!P
(;:\wpfil~\n!thlmaw\notifysm. u22
.,
'
Mr. Mark Wilkins
Hazardous Waste Section
NCDEHNR
P 0 Box27687
Raleigh, NC 27611
Re: Central Transport, Inc.
NCD 046 148 540
Dear Mr. Wilkins,
July 23, 1996
l''-
r:l LE: p
( £wrflrl 1R,/l'f'JSP8fl1'"""
Jl(P IJ1b 11/'5 51{C
0J
The purpose ofthis correspondence is to advise your office of additional voluntary environmental
activity either recently conducted or planned in regard to the RF A Report for the Central Transport
facility in Charlotte.
Confirmatory sampling of the following SWMU's (2, 3, 4, 8, 12, 13, & 16) identified in the RFA
Report was conducted by AquaTerra from April 22 to April 24, 1996, with a Site Assessment Report
received July 16, 1996. AquaTerra had previously conducted soil assessment activities at eight
different SWMU's (5, 7, 9, 10, 22, 23, 24, & 27) in April, 1995, with the results presented in a Soil
Assessment report dated September 8, 1995. These results were included in the Part B Permit
Application submitted by Rust E & I.
Based on the results of the confirmatory soil sampling performed on SWMU 22 -Abandoned
Trenches by AquaTerra and additional soil assessment by Rust, including trench location,
identification, and survey documentation, Central plans to excavate and dispose of the contmninated
soil from Trench# I during the week of August 26 -30, 1996.
Sincerely,
<jk7---(-;h_ · .... ,.-;;::04, 7---------------
.. / v -,. --
Glen Simpson
Environmental Director
GS/PS
2829 Uwharrie Road• Archdale, NC 27263 •Mailing Address: P.O. Box 7007 •High Point, NC 27264
910/431-9186 •FAX: [phone]
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
.William L. Meyer, Director
March 11, 1996
.H;Aev
DEHNR
CeniraL 1Yer0pv-C, :Jr.c.
NCJ> o4 u 1 lf g situ Mr. Glen Simpson
Central Transport, Inc.
PO Box 7007
High Point, NC 27263-7007 h\e: f~rm1{-h1'
Reference: Receipt of Post-Closure Grotmdwater
Monitoring Annual Report for 1995
EPA ID# NCO 046 148 540
Dear Mr. Simpson,
The Hazardous Waste Section (Section) has received a copy of the Post-Closure
Grotmdwater Monitoring Annual Report for 1995 for Central Transport, Inc. (CTI). The
Section has the following comments on the report:
1. The detection limit for antimony by SW-846 method 7040 is listed as 200 ppb.
The detection limit for antimony by SW-846 method 7041 is 3 ppb. The values
for antimony were reported in Table 4.7 as <50 or <10. The primary drinking
water standard for antimony is 6 ppb. In subsequent analyses, CTI should use
method 7041 or equivalent to analyze for antimony in order to determine whether
the metal is present above primary drinking water standards.
2. In accordance with 40CFR 265.94 (b) (2) (as adopted in lSA NCAC 13A .0010),
the facility shall submit an annual report containing the results of the grotmdwater
assessment program until final closure The Section has accepted certification of
final closure of the Hazardous Waste Management Units (HWMU). CTI is currently
tmdergoing post-closure care at the site. Accordingly, submittal of an annual
report of the facility's grotmdwater assessment program is no longer required.
Please note that this does not affect the submittal of required semiannual
monitoring reports.
3. In accordance with 40CFR 265.144 (c) (as adopted in ISA NCAC 13A .0010),
the facility shall submit annually an updated post-closure cost estimate to the
Section. Note that the cost estimate is due within sixty (60) days prior to the
anniversary date of the establishment of the financial instrument used to comply
with 40CFR 265.145.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer poper
Mr. Glen Simpson
March 11, 1996
Page2
If you have any questions on this issue, please contact Mark Wilkins of my staff at
[phone], Ext. 224.
Sincerely,
~~z~~
Sharron E. Rogers . -~ ()
Head, Remediation Branch
Hazardous Waste Section
cc: Robin Hedden
Mark A. Wilkins
re: Sharron Ro~~ftifl-­
Jill Bwton 'ty.D
Surabhi Shah 8iU
REGULATORY COMPLETENESS CHECKLIST FOR HAZARDOUS WASTE STORAGE, TREATMEINT AND DISPOSAL FACILITIES
Facility Name Central Transport
Address Charlotte , NC
contact Name Glen Simpson
Contact Phone Number 910 431-9186
S1:¥(ject Requirement
PART A -APPLICATION
1. ID Number Isl
0 EPA ID number
D Secondary number
II. Neme of F~cility
Ill. Facility Location
D Facility address
D Land type
0Geographic location
(Latitude and longitude)
D Facility existence date
IV. facility Mailing Address
V. Facility Contact
DName and title
D Telephone number
VI. Facilit~ Conta~t Address
VII. Operator Information
DName
DAddress
0Telephone number
00Gla
'
EPA I.D. Number NCD 046 148 540
Permit Review Team Surabhi Shah. Mark Wilkins
Date Application Received 218/96
Date Review Completed
40 CFR Location in
Section Nos. Application Comments
270.11 (a) and (bl Part A
N/A
Part A
Part A
~(JJ ~ N/A
(£ .. -~-~~ Part A ~~w
Part A
Part A
Part A
Part A
Part A
Part A
Part A
Part A
v
Modules A-C
Revised 1/ 94
\J
Modules A-C
40 CFR Location in
Subject Requirement Section Nos. Application comments
0 Operator type Part A
0 Change of operator N/A
VIII. Owner Information CENCO should be listed as
O'Wil.er of facility
0 Name
0Address " "
DTelephone number " "
0 Owner type " "
Ochange of owner
IX. SIC Code (s) Part A
0 Four digits
x. Existing Environmental Permits Part A
0 Permit type
0 Permit number Part A
0 Description Part A
XI. Nature of the Business Part A
XII. Process -Codes and Design Cagacities Surface Impoundments were
closed as a D80 landfill.
D Process codes
0 Amount " "
Dunit of measure " "
D Process total number of units " "
XIII. Additional Treatment Processes N/A
D Line number
DAmount N/A
OOOla Revised 1/94
I
Modules A-C
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D Unit of measure N/A
D Process total number of units N/A
XIV. Descrintion of Hazardous Wastes N/A
0 EPA hazardous waste number
D Estimated annual quantity N/A
0 Unit of measure N/A
D Process code N/A
XIV. (continued) N/A
D Process description.
xv. Map PART A; FIGURES
D One mile beyond property line
Doutline of facility PART A; FIGURES
D Location of existing and proposed PART A; FIGURES
intake and discharge structures
D Hazardous waste treatment1 storage~ and CHANGE TO DSO AND OUTLINE
disposal facilities UNIT
D Underground injection wells N/A
D Wells, springs, rivers, and other
surface water bodies
DDrinking water wells within 1/4 mile of SHOW LOCATION OF DRINKING
the facility property boundary. WATER WELLS IN VICINITY
XVI. Facilit:J::: Drawing OUTLINE UNIT
XVII. Facilit~ Photogragh PART A
XVIII. Certifications NEED ORIGINAL SIGNATURE
Downer Certification
(Name 1 signature, titler date)
Modules A-C
40 CFR Location in
Subject Requirement Section Nos. Application Comments
0 Operator Certification NEED ORIGINAL SIGNATURE
{Name, signature1 titler date)
PART B -FACILITY DESCRIPTION INDICATE THE SURFACE
IMPOUNDMENTS ARE NOW
B-1 General Descrigtion 270.14 (bl I 1 l CLOSED AS A LANDFILL;
Guidance
A general description of the facility.
Include the nature of the business. Off-
site facilities should identify the types of
industry served; on-site facilities should
briefly describe the process(es) involved in
the generation of hazardous waste.
B-2 Topographic Map 270 .14 (bl (19) FIGURE B-1
B-2a General Requirements
A topographic map showing the facility
and a distance of 1000 feet around it.
The following information is required:
D Scale 1 in = 200 ft.
D Contours sufficient to show surface FIGURE B-1
water flow
D Extend 1000 ft. beyond property FIGURE B-1
D Map scale FIGURE B-1
D Map date FIGURE B-1
D 100-yr floodplain FIGURE B-2
D Surface waters FIGURE B-2
D Surrounding land use PROVIDE A MAP SHOWING
ZONING AROUND FACILITY
D Wind rose FIGURE B-3
D Map orientation FIGURE B-1
D Legal boundaries FIGURE B-1
Modules A-C
40 CFR Location in
Subject Requirement Section Nos. Application Comments
0Location of access control PROVIDE A MAP LEGEND;
INDICATE PROPERTY FENCE
D Injection and withdrawal wells PROVIDE LOCATION OF OFF-
-on-site SITE DRINKING WATER WELLS
-off-site RES. AND INDUSTRIAL
D Buildings FIGURE B-1
D Structures FIGURE B-1
D Sewers ITEM XVI PART A
0Loading and unloading areas N/A
D Fire control facilities N/A
D Flood control or drainage barriers N/A
D Run-off control systems N/A
D Location of hazardous waste units PROVIDE OUTLINE OF
LANDFILL
D Location of solid waste management SECTION L
units
0Access and internal roads~ ITEM XVI PART A
B-2b Additional Togogra~hic Regyirements for 270 .14 (cl (3) , FIGURE E-1; SHOULD DELINEATE THE
Land S to rag:e 1 Treatment and Dis~osal and [cl (4) (i), SECTION E CLOSED LANDFILL; SHOULD
Facilities 264.95, 270 .14 (cl (4) lil INDICATE THE POINT OF
264.97 IS N/A COMPLIANCE; SHOULD
(See Section E-3 -Topographic Map INDICATE THE PROPOSED
Requirements.) LOCATION OF MONITOR WELLS
B-3 Location Information 2 7 0-1-4 (b) ( 11) N/A
B-3a Seismic Considerations 270. 1-4 (b) (11)
(i) and (ii)
264.18(a)
264 Appendix VI
Modules A-C
40 CFR Location in
Subject Requirement Section Nos. Application Comments
B-3b Floodglain Standard 270 .14 (bl (ll) (iii)' FIGURE B-2
264 .18 (bl
Documentation of whether or not the
facility is located with a 100-yr
floodplain including the source of date
{Federal Insurance Administration Map or
other maps and calculations) . If map
other than FIA map is used demonstration
of equivalent mapping technique should be
provided. If located in 100-yr
floodplain include:
B-3b (Continued)
D 100-yr floodplain level
D Other special flooding factors {e.g.'
wave action) that must be considered to
prevent washout.
B-4 Traffic Information 270 .14 (b) {10) N/A
A description of the means of transporting
hazardous wastes.
All facilities should describe movement of
waste on the facility. Description must
include:
D Estimated volume
D Traffic pattern N/A
D Traffic control N/A
D Access road (s) surfacing and load-bearing N/A
capacity.
Off-site facilities (only should also Guidance N/A
describe movement of waste to the facility
from the point to where it leaves nearest
major highway.
Modules A-C
40 CFR Location in
Subject Requirement Section Nos. Application Comments
P~_RT C -WASTE CHARACTERISTICS SECTION C;
TABLES C-1
C-1 Chemical and Physical Analysis 270.14(b) {2) THROUGH C-7
264 .13 (a)
For each hazardous waste treated1 stored or 111/7/86, 6/4/87)
disposed at the facility, the following Guidance
information should be provided:
D General description of the waste Guidance
D Hazardous characteristics Guidance
D Basis for hazard designation Guidance
D Laboratory report on analyses results
D Existing published or documented data on
hazardous waste or hazardous waste from a
similar process (new facilities only).
At a minimum, the analyses should include PROVIDE A LISTING OF
all the information which must be known to BREAKDOWN {DAUGHTER)
treat, store, or dispose of the waste in PRODUCTS OF THE KNOWN SITE
accordance with Part 264 and 268 CONTAMINANTS
requirements or conditions of a permit
issued under Part 270.
C-1e Landfills 264.314 N/A
D Results of the Paint Filter Liquids
Test (Method 9095 in SW-846) showing
that containerized or bulk wastes do
not contain for free liquids.
Modules A-C
40 CFR Location in
Subject Requirement Section Nos. Application Comments
C-2 Waste P.nalysis Plan 270 .14 (b) {3) N/A
264 .13 (bl and { c} J
A copy of the waste analysis plan required [11/7 /86' 6/4/87)
by 264.13{b) and, of applicable, 264 . 13 (cl . 268.7
The Waste Analysis Plan should describe the [11/7 /86' 6/4/87,
procedures used to obtain chemical and 7 /8/87' 8/17 /88)
physical information and data on the wastes
to insure proper storage, treatment, and
disposal and compliance with the land
disposal restriction program. Minimum
requirements include:
C-2a Parameters and Rationale 264 .13 {b) (1) N/A
A list of parameters chosen for analysis
and an explanation of the rationale for
their selection.
C-2B Test Methods 264 .13 {b) (2) N/A
A description of the best methods used to
test for parameters chosen.
C-2c Sanroling Methods 264 .13 {b) (3)' N/A
Part 261,
A list of the sampling methods used to Appendix I
obtain a representative sample of each
waste to be analyzed.
C-2d Fregyenc~ of Anal~sis 264 .13 {b) (4) N/A
Guidance
A description of the frequency at which
the analyzes will be repeated. The
frequency must be sufficient to ensure
that the analysis is accurate and up-to-
date. (For an on-site facility this will
be as often as required to verify
consistency of the waste feed.}
Modules A-C
40 CFR Location in
Subject Requirement Section Nos. Application Comments
C-3a Waste Characteristics N/A
Analytical data must be submitted by the 264 .13 (al (1)
generator to the owner/operator for each 268.7
waste stored~ treated, or disposed at the [11/7 /86' 6/4/87]
facility1 or information from knowledge
of the waste can be used$ to determine if
the waste is restricted under the 40 CFR
Part 268. If generator knowledge is
used, all supporting data must be
maintained in the operating record.
C-3e Regyirgments for Land Disposal Facilitie§ 270. J.4 (bl (21) N/A
With an Approved Exemption or Extension [J.1/17 /86]
If a case-by-case extension has been
approved under 26845 or a petition has
been approved under 268.6, provide a copy
of the Notice of Approval.
REGULATORY COMPLETENESS CHECKLIST FOR HAZARDOUS WASTE STORAGE, TREATMENT AND DISPOSAL FACILITIES
Facility Name CENTRAL TRANSPORT
Address CHARLQTTE
Contact Name GLEN SIMPSON
Contact Phone Number
Subject Requirement
PART E -GROUNDWATER MONITORING
E-1 Inte~im Status monitoring Data
Summary of groundwater monitoring data
obtained during interim status period.
E-la Description of Wells
D Number of wells;
D Locationsi
D Depths and screened intervals;
D Casing description;
D Other well construction details;
D Identifications of upgradient wells and
downgradient wellsi and
D Water levels at time of drilling and
any changes within 24 hours~
E-lb D~scrigtiou of Samgling{Anal~sis
Procedures
D Sample Collection;
D Sample preservation and shipment;
D Analytical procedures; and
EPA I.D. Number NCD 046 148 540
Permit Review Team S. SHAH. t4. WILKINS
Date Application Received 2/8/96
Date Review Completed ----------------
GroW1dwater Monitoring -Module E
40 CFR Location in
Section Nos. Application Comments
E-1; TABLE E-1;
FIGURE E-1;
270 .14 {c) {1) APPENDIX E-1
265.90-265.94
265.91 " "
" "
TABLE E-1
APPENDIX E-1
APPENDIX E-1
UPGRADIENT WELLS ID IN
SECTION E-la; FOUR WELLS
DESIGNATED AS DOWNGRADIENT
WELLS DURING INTERIM
STATUS, THESE WELLS ARE
NOT DOWNGRADIENT DURING
NATURAL GROUNDWATER FLOW
CONDITIONS AT SITE
APPENDIX E-1
265. 92 E-lb (1) ; *DEFICIENCIES IN S&A PLAN
IN APPENDIX E-l.
E-lb(2) " "
E-lb(3) " "
Groundwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos+ Application Comments
0 Chain-of-custody control. E-lb(4] " "
E-lc Monito~ing Data 265.92 MUST INCLUDE LAB DATA
SHEETS FROM ALL PREVIOUS
All interim status monitoring results must SAMPLING EVENTS, NOT JUST
be provided1 including the following: SUMMARY SHEETS
0 Copies of each quarterly (from first 265. 92 {c) (1)
year) analytical results for each \.,-rell;
E-lc (continued) " "
0 Copies of subsequent {annual or semi-265.92 (d)
annual] analytical results for each
well;
0 Results of groundwater surface 265.92{e) Tables E-1 and
elevation measurements for each E-9
sampling event; and
0 Initial background arithmetic mean and 265.92(c) N/A
variance for each indicator parameter
based on replicate measurements form
upgradient wells during first year.
E-ld Statistical Procedures 265.93 N/A
0 Description of the statistical
procedures employed to make the
required statistical comparisons; and
0 Results of statistical comparisons N/A
between upgradient and downgradient
well sampling results and first year
background values for each indicator
parameter.
-----,
Groundwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
E-le Groundwater Assessment Plan 265.93/dl (2) E-le
If required, based on statistical
comparison results, the specific plan for
a grolli1dwater quality assessment program,
along with the results obtained from
implementation of the plan. include
results of the following determinations,
considering (at a minimum} the hazardous
constituents listed in Appendix VIII to 40
CFR Pa~t 261.
D Whether hazardous waste or hazardous
constituents have entered the
groundwater;
D The rate and extent of migration of DETERMINE THE RATE AND
hazardous waste or hazardous waste EXTENT OF MIGRATION OF
constituents in the groundwater; and HAZARDOUS CONSTITUENTS IN
THE GROUNDWATER
D Concentrations of hazardous waters or E-le
hazardous waste constituents in the
groundwater.
E-2 Qgneral Hydrogeologic Into~mation 270.l4(c] (2) PERFORM AQUIFER PUMP TEST,
INSTALL WELL NESTS, NEED
Identification of uppermost aquifer and CROSS SECTIONS, SLUG TEST
aquifers hydraulically interconnected FIELD DATA
beneath facility, including:
0Groundwater flow direction and rate; and
DBasis for identification. " "
Groundwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
E-3 To~Qgraghic Ma~ Re!:lllirements 270.14(c) (2) Map flow direction does
(3)' (4)' lil not agree with text
Unless exempt from groundwater monitoring description of flow.
requirements, surface impoundments, waste
piles, land treatment, and landfill
facilities must include the following
information on the topographic map:
0 Groundwater flow direction and rate
(isometric graph) ;
0 Point of compliance; NOT SHOWN
0Groundwater monitoring wellsr FIGURE E-l
DThe extent of any plume (horizontal and PLUME SOUTH OF UNITS MUST
vertical); BE DEFINED
0Hazardous waste management area; and FIGURE E-1
D P~operty boundary. " "
The following required information may be MUST PERFORM AQUIFER PUMP
incorporated into the topographic map if TEST
possibler or at least should be discussed in
the text:
DGroundwater flow rate;
D Boundaries of uppermost aquifer; SECTION E-2
Dunderlying interconnection between SECTION E-2
uppermost aquifer and lower aquiferi
0Hydraulic downgradient; NOT ACCURATE ON FIGURE E-4
THROUGH E-8
Owaste management areai and SECTION E-2
D Uppermost aquifer. SECTION E-2
Grou_~dwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
E-3 (continued)
{Although many of these items can be shown
on a single map$ it is allowable to use
additional maps to display some of the
information. Presentation of all of this
information on a single map may sacrifice
clarity.)
E-4 Contaminant Plume Descrigtion 270. l4 (cl (4) SOUTHERN PART OF PLUME IS
261, Appendix INACCURATE
Description of any plume of contamination VIII
that has already entered groundwater from a
regulated unit:
Doelineation of extent of the plume on the
topographic map;
D Identification and concentrations of NOT SHOWN
Appendix VIII constituents throughout the
plume or maximum concentrations of these
constituents in the plume; and
Doelineation of the vertical extent of the 270 .14 (cl (2), MUST DELINEATE PLUME ON
plume in a cross-section. 270.14 (c) (7) {ii) CROSS SECTIONS
E-5 General Monitoring Prggram Regyirements 270 .14 (c) {5) SECTION E-5
264.97
Waiver request -applicant must certify that 264. 90 {b) (4)
there will be no migration of liquid to
uppermost aquifer during active life and
postclosure. If waiver is not requested1
applicant must provide detailed plans and an
engineering report describing proposed
groundwater monitoring program to meet
general groundwater monitoring requirements+
The following information is required:
E-Sa Descri~tion of Wells 264. 97 (al , lb)
264.97(c)
0 Number of wells;
0 Locations; FIGURE E-1
Groundt1.~a ter Mani to ring -l-iodule E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D Depths; APPENDIX E-1
D Casing descriptioni M\JST USE STAINLESS OR
TEFLON
D Assurance of unaffected background SECTION E-5
water measurement; and
E-Sa (continued) NEED WELLS AT THE
COMPLIANCE POINT
D Assurance of compliance point ground-
water measurement.
E-5b Descrigtion of SamglingLAnal~sis 264.97(d) SEVERAL DEFICIENCES NOTED
Procedures 264.97(e) IN SAMPLING AND ANALYSIS
PLAN
D Sample collection methods 264.97(f)
D Sample preservation/shipment; " "
D Analytical procedures; " "
D Chain-of-custody control; " "
D Documentation of proper sampling and " "
analysis proceduresi and
D Procedure for determination of ground-" "
water elevation with each sample.
E-Sc PrQcedures for Establishing Bsckgroung 264. 97 {a) (1) MUST HAVE A PLAN TO SAMPLE
Duality 264.97(9) WELLS AND PERFORM
[10/ll/88] STATISTICS OR USE PQLS AS
D Representative of background quality EVIDENCE OF CONTAMINATION
not affected by the unit;
D Each hazardous constituent~ or " "
monitoring parameters and other
constituentsi
Groundwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
0 May include wells not hydraulically " "
upgradient of the waste management area
where:
1. upgradient cannot be determined due
to hydrogeologic conditions, and
2. other wells provide background
groundwater quality that is
representative or more
representative of background than
upgradient wells.
E-Sd Q~a~istical Procedures 2 6 4. 97 (h] • MUST SPECIFY A STATISTICAL
264. 97 {i) (1)' (5) PROCEDURE
Use one of following statistical methods and (6)
(E-5d (1) -ts J I to evaluate groundwater [10/ll/88]
monitoring data for each hazardous
constituent, consistent with the
following:
0 Conduct test separately for each
hazardous constituent in each well;
E-Sd (continued) " "
0 Appropriate for distribution of
chemical parameters or hazardous
constituents~ More than one method
necessary if distributions differi
0 Account for data below the detection " "
limit;
0 Any practical quantification limit " "
(PQL) shall be lowest concentration
level within levels of precision and
accura~y for routine lab operations;
and
0 Procedures to control or correct for " "
seasonal and spatial variability and
temporal correlation in data.
Ground-l'later Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
E-5d(l) Param~tric Aoal~sis of Variance 264. 97 {h) (1) " "
{ANOVAI: 264. 97 (i) (2)
[10/11/$8]
ANOVA followed by multiple
comparisons procedures:
D Include estimation and testing of
contrasts between each compliance
wellrs mean and the background mean
levels for each constituent.
D If using individual well comparison " "
procedurer Type 1 error level of no
less than 0.01 shall be maintained.
If using multiple comparison
procedure1 Type 1 error level no
less than 0.05 for each testing
period must be used.
E-5d(2) Non-gargmetrjc ANQVA (Based on 2 6 4. 97 (h) (2) , " "
Ranks!: 264. 97 (i) (2)
[10/11/88]
ANOVA based on Ranks followed by
multiple comparisons procedures;
DEstimation and testing of each
compliance well•s median and
background median levels for each
constituent-
E-Sd (2) (continued) " "
D If using individual well comparison
procedurer Type 1 error level of no
less than 0.01 shall be maintained.
If using multiple comparison
procedure1 Type 1 error level no
less than 0.05 for each testing
period must be used.
GroW1dwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Corrunents
E-Sd ( 3) Tolerance or PredictioD Interval 264. 97 (h) (3)' " "
E:rocedure: 264.97(i) (4)
[10/11/B B]
D Establish interval for each
constituent based on distribution
of background data.
D Compare level of each constituent " "
in each compliance well to the
upper tolerance or prediction
limit.
D Prepare levels of confidence and/or " "
percentage of the population that
the interval must contain
considering number of samples in
the background data base, data
distributionz and range of
concentration values for each
constituent of concern.
E-Sd (4) Control Chart Am;;!roach: 264. 97 (h) {4)' " "
264.97(i){3)
D Control limits for each [10/11/88]
constituent;
D Specify type of control chart and " "
associated parameter values.
E-Sd (5) Alternative Aooroach: 264. 97 (h) (5), " "
264. 9 7 (i) (3)
An alternative approach can be [10/11/88]
proposed which complies with all
performance standards set in
264. 97 (i) .
Groundwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
E-6 Descrigtion of Detection Monitoring ~rQgram 270 .14 (cl (6) N/A
for Facilities not Detecting tile Pre§ence gf 264.91(a) (4)
Hazardous Constituents. Including: 264.98
E-6a List of Indicator Parameters 1 waste 270 .14 {c) {6) (i l
Constituents, Reaction Products to be 264.93
Monitored for1 Incl udir.g ~ ">t:.11. ao f:::i~ ....,,_.....,. ......... \ ....... /
D Type, quantities I concentrations
expected wastes;
D Mobility, stability, persistence in N/A
unsaturated zone;
CJ' Detectability in groundwater; and N/A
D Concentration or values and N/A
coefficients of variation of proposed
parameters in the groundwater
background.
E-6b De2crigtion of Groundwater Monitoring 270 .14 (c) (6) N/A
System (ii)
264. 98 (b)
D Hydraulic downgradient limit; 264.95, 264.97
D Waste management area; and (a) (2), (b), (c) N/A
D Uppermost aquifer. N/A
E-6c Backgroung Groundwater Concentration 270 .14 (c) (6) N/A
Vgl1ies fo~ PrOQQsed Parameters (iii)
264.9S(c),
D Use of an appropriate groundwater 264. 97 (g) (1)' (2)
monitoring system, to establish [10/11/88)
background per E-Sd specifying number
and type of samples for each hazardous
constituent appropriate to form of
statistical test employed;
Groundwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D Sampling procedure shall be a sequence N/A
of at least four samples from each well
in the entire system at an interval
assuring an independent sample relative
to the uppermost aquifer1 s effective
porosity, hydraulic conductivity~
hydraulic gradient and fate and
transport characteristics of the
potential contaminants but at least
semi-annually; or
E-6c (continued) N/A
D Alternative sampling procedure to be
approved.
E-6d Descri~tion of groggsed Samgling and 2'10 .14 {cl {6) {iv) N/A
Analysis Procedures 264.97{f)
264.9B(f]
D Documentation of proper sampling and 264.98(d)
analysis procedures; [10/ll/88]
D Procedures for deterrnin-ing groundwater 264. 98 (e) N/A
elevation;
0 Procedures for determining N/A
statistically significant increase for
any monitored parameter;
D At least four samples from each N/A
compliance and background well semi-
annually
D Procedure for annual determination of 264.9B(e) N/A
uppermost aquifer flow rate and
direction.
E-6e P~ocedure to be Iroi;ilemented if a 270 .14 (cl (7) N/A
Statisticall~ Significant Increase in Anv 264.9B(g)
Cgnstituent or Parameter is Identified at [10/ll/88'
Any Compliance Point Monitoring Well 6 ! 22 I a 7 l
D Notify RA within seven days;
Groundwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
0 Sample all wells for Appendix IX list N/A
(Part 264) constituents;
D Establish compliance monitoring N/A
program;
D Submit engineering feasibility plan for N/A
a corrective action program or request
RA approval to submit permit schedule
for development of plan.
D May demonstrate that a source other N/A
than the regulated unit caused the
contamination.
E-7 Caffi!2Jiancg Monitoring Prosram for Facilities 270.14{c) (7) MUST INCLUDE A COMPLIANCE
Which Have Detected Presence of Hazardous 264.99 MONITORING PROGRAM
Constituents
E-7a Description of Monitoring Prosram
E-7a{l) Descri£tion of Wastes Previoysl~ 270 .14 (c) (7) (i)
Handled at Facilit~
E-7a(2) Char~cterization of Contaminated 270 .14 (c) (7) {iii " "
Groundwater
DHazardous constituents identifiedi
0 Hazardous constituents " "
concentrations.
E-7a (3) List of Haz~rdous Constituents to be 270 .14 (c) {7) (iii) " "
Monitored in ~o~liance PrQgram 264. 99 (a) ( 1)
264. 98 (g) (3)
May resample within one month and [10/11./88]
repeat analysis for compounds
detected. Constituents identified in
both analysis will form basis for
compliance monitoring plan.
Groundwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
E-7a(4) Progosed Concentration Limits for 270 .14 {c) {7) {iv) " "
Each Constituent 264. 99 {a) {2)
D Justification for establishing 264.94
alternative limits;
D conditions warranting special " "
sampling procedures;
D Importance of statistically " "
significant values; and
D Procedures for establishing 264. 99 (c) (3) " "
background concentration values for 264. 97 (g)' {h)
constituents that are based on:
-use of any appropriate ground-
water monitoring system;
-data that is available prior to
permit issuance;
-data that accounts for
measurement errors in sampling
analysis;
-data that accounts for seasonal
groundwater quality fluctuations;
and
E-7a (4) {continued) " "
-data from a minimum of four
samples per well collected at
least semiannually.
E-7a (5) Detailed Plans of an Engineering 270 .14 {c) {7) {v) MUST INCLUDE A COMPLIANCE
Re~ort Describing Groundwater 264. 99 {b) MONITORING PLAN
Monitoring System
DRepresent quality of groundwater 264. 97 (a) (2)
passing point of compliance;
D Proposed compliance point; 264.95 " "
DNumber of wells; 264.97(a) (2) " "
DLocation and depths of wells; and 264.97(a) (2) n n
Groundwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D Casing and construction of wells. 264. 97 (c) " "
E-7a(6) Descrigtion Qf Prouosed SamQling and 270 .14 (c) ( 7) (vi) " "
Statistical Anglysis Procedures for 264. 99 (c), (d), {e),
Groundwater Data {f), (g)
[10/11/88]
D Compliance period
D Sample collection methods 264. 97 (d) " "
D Sample preservation/shipment 264. 97 (d) " "
DAnalytical procedures 264. 97 (d) " "
D Chain-of-custody control 264. 97 (d) " "
DDocumentation of proper sampling 264.97{e) " "
and analysis procedures
D Procedures for determining ground-264. 97 (fl " "
water elevation
D Procedures for annual determination 264. 99 (el " "
of uppermost aquifer flow rate and
direction
DAnnual testing procedures for 264. 99 (g) " "
Appendix IX constituents. [10/11/88]
Procedures for determining a 264. 99 (d) and ( f) " "
statistically significant increase [10/11/88]
for any monitored parameters or
hazardous constituent:
E-7a(6) (continued) " "
D Comparing compliance point using
the procedure in 264.97{h) to the
concentration limit developed in
accordance with 264.94.
D At least four samples from each " "
well {compliance and background)
must be collected at least semi-
annually.
Groundwater Monit.oring -:Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
E-7a(7) Proced11res to be Ir!:!:alemented if 264. :99 iil SECTION E-7, E-
Groundwater P~otection StanQard is 264. 99 (hi 8
Exceed~d at Comgliance Point [10/ll/88]
Monitoring Well
Owritten notification to Regional
Administrator
0An application for permit N/A
modification to establish a
corrective action program1
including details of the program to
comply with groundwater protection
standard and details of groundwater
monitoring to demonstrate
effectiveness of the corrective
action program1 or
D Submit demonstration that N/A
concentration limits were exceeded
due to source other than regulated
uni tr or due to statistical error.
E-/b An ~nginee~ing Fe~sibilit~ Plan for 270 .14 (c) (7) PROVIDE EVIDENCE THAT
Corre~tive Action Program 270 .14 (c) (8) (v) NATURAL ATTENUATION WILL
[6/22/87] ACCOMPLISH REQUIREMENTS OF
0 Engineering feasibility plan for a 264. 98 (g) {5) {ii) 264.100
corrective action program to meet
requirements of 264.100 1 or
D Request authorization from RA to submit N/A
schedule for a submittal plan.
E-8 Co~rective Action Program 270 .14 (cl (8) (il TABLES E-2, -3,
-4, AND
E-Ba Characterization of Contamination APPENDIX E-2
D Identification of hazardous
constituents detected in groundwater
E-8a {continued) " "
D Concentrations of hazardous
constituents.
Groundwater I"1oni to ring -J.1odule E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
E-Bb Concentration Limits 270. H (c) (B) {ii) SHOULD USE DRINKING WATER
264 .100 {a) STANDARDS NOT 2L
E-Bb (1) Concentration Limit§ Established 264.97(a)
Under 264.94(al
E-Sb (2) Alternate Concentration Limits 264. 94 (b) SECTION B-SB
D Proposed alternate concentration
limits
DJustification for proposed N/A
alternate limitsI including
assessment of potential adverse
effects on groundwater quality and
on the quality of hydraulically
connected surface waters1 and
assessment of the potential for
health risks caused by human
exposure to waste constituents.
E-8c Corrective Action Plan 270 .14 (c) (8) (iii) NEED TO ID COMPLIANCE
264.100 POINT
A corrective action program must prevent
hazardous constituents from exceeding
their respective concentration limits at
the compliance pointI and between the
compliance point and the down.gradient
facility property boundary. The
corrective action plan must consist of
detailed engineering plans and report 1 and
must address the following:
D Identification of compliance point
D Plans for removing and handling of N/A -NATURAL
hazardous wastes (if proposed) ATTENUATION
D Design and construction plans and N/A
specifications for any proposed
features to contain groundwater or
redirect its flow (e.g.' drains1
engineered barriers, wells)
Groundwater Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
E-8c (con tinuedl SECTION E-8
D A description of the treatment
technologies to be employed to remove
hazardous constituents from
contaminated groundwater
D Description of the operation and N/A
maintenance plans for the corrective
action measures
D Description of any additional MUST PROVIDE SITE SPECIFIC
hydrogeologic data collected for use in HYDROLOGIC DATA TO SHOW
designing the corrective action NATRAL ATTENUATION WILL
measures WORK
D Schedule for implementation the N/A
corrective action measures.
E-Sd Groundwater Monitoring Program 270 .14 (c) (8) MUST INCLUDE OFFSITE
264 .100 (d) WELLS; SHOW THAT WELLS MW-
In conjunction with a corrective action 13 AND MW-16 ARE TRULY
program1 a groundwater monitoring program DOWNGRADIENT WELLS
must be implemented to determine
compliance with the concentration limits
established under 264.94, and to determine
the effectiveness of the corrective action
program.
E-8d (1) Descri~tion of Monitoring S~stem 270 .14 (c) (8) " "
270 .14 le) (7) (vi
DNumber of wells
D Locations " "
0 Depths and screened intervals " "
Dcasing descriptions " "
Dother well construction details " "
DDescription of how the groundwater " "
monitoring program will demonstrate
the adequacy of the corrective
action.
Ground~,,...a ter Monitoring -Module E
40 CFR Location in
Subject Requirement Section Nos. Application Comments
E-8d(2) Descrigtion of Samgling and Anal~sis 270 .14 (c) {8) MUST INCLUDE A S&A PLAN
Procedures 270 .14 (c) {7) ivil FOR NEW WELLS
D Sampling frequency
D Sample collection " "
E-8d(2) (continued] " "
D Sample preservation and shipment
0Analytical procedures " "
D Chain-of-custody control " "
D Procedures for determining ground-APPENDIX E
water elevations
D Procedures for annual determination SECTION E-BD
of growidwater flow rate and
direction.
E-Bd (3) Monitoring D2ta and Statistical 270 .14 (cl (8) MUST PROVIDE PROCEDURES
Analysis Procedures 270 .14 (c) (7) (vi) FOR STATISTICAL ANALYSIS
DURING THE COMPLIANCE
D Procedure for establishing PERIOD
background concentration values
D Statistical procedures for " "
comparing compliance point data to
the concentration limits
D Statistical procedures for SECTION E-8D
evaluating effectiveness of the
corrective action program between
the compliance point and the
property boundary.
E-8d ( 4) Reporting Requirements 264 .100 (g) MUST REPORT SEMIANNUALLY
D Semi-annual report to Regional
Administrator evaluating the
effectiveness of the corrective
action program.
REGULATORY COMPLETENESS CHECKLIST FOR HAZARDOUS WASTE STORAGE, TREATMl!NT AND DISPOSAL FACILITIES
Faci 1 i ty Name _,C~T._I=---------------­
Address
Contact Name
Contact Phone Number
Subject Requirement
PART F -PROCEDURES TO PREVENT HAZARDS
F-1 Sec,1rity
F-la S~curit~ Procedure~ and Egy.iDment
Unless a waiver is granted1 the Part B
must include a description of the security
procedures and equipment required by
264.14:
F-la (1) 24-Hour Surveillance System
A 24-hour surveillance system {e.g.1
television monitoring or surveillance
by guards or facility personnel) that
continuously monitors and controls
entry onto the active portion of the
facility:
D Procedures and personnel to be used
D Location and description of
equipment.
F-la{2) Barrier and Means to Control Entry
(In lieu of a 24-hour surveillance
system1 the applicant may elect to
use a barrier and other means to
control entry. l
EPA I.D. Number ~N~C~D~0~4~6~1~4~8~5~4~0~----------------­
Permit Review Team
Date Application Received
Date Review Completed
40 CFR Location in
Section Nos. Application
SECTION F
264 .14
270.14(b) (4)
264 .14 (b) (1) F-la (1)
Guidance
Guidance F-la (1)
264 .14 (b) (2) (i) F-la(2)
Hazard Prevention -Module F
Comments
-,
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Corrunents
F-la (2) (a) Barrier 264 .14 (b) (2) {i) F-la (2)
An artificial or natural barrier
(e.g.' a fence in good repair or
a fence combined with a cliff)
that completely surrounds the
active portion of the facility:
0 Height Guidance
F-la (2) (a) (continued) F-la(2)
0 Material of construction Guidance
F-la (2) (b) Means to Control Entry 264 .14 (b) {2) {ii) F-la (2)
A means to control entry, at all
times, through the gates or other
entrances to the active portion
of the facility (e.g., an
attendant1 television monitors,
locked entrance, or controlled
roadway access to the facility) :
D Procedure and personnel to be
used Guidance
0 Location and description of Guidance F-la (2)
equipment.
F-la(3) Warning Signs 264 .1.4 (c) F-J.a(J)
The facility must have a sign with
the legend, •rnanger -unauthorized
Personnel Keep Out, 11 which must:
DBe posted at each entrance to the
active portion of the facility
D Be in sufficient numbers to be seen F-la (3)
from any approach to the active
portion of the facility
-----
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D Legend must be in English and any F-lal3)
other language predominating in the
area
DBe legible from a distance of at F-la(3)
least 25 feet.
Existing signs with a legend other F-la {3)
than 11 Danger -Unauthorized Personnel
Keep Out" may be used if the legend
on the sign indicates that only
authorized personnel are allowed to
enter the active portion and that
entry onto the active portion can be
dangerous.
F-lb Waiver 264.14(a) N/A
If a waiver of these requirements is
requested, the owner or operator must
demonstrate the following:
F-lb (1) Injury to Intruder 264.l4(a) (1) N/A
Physical contact with the waste,
structure1 or equipment within the
active portion of the facility will
not injure unknowing or lUlauthorized
persons or livestock that may enter
the active portion of a facility; and
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
F-lb (2) Violation Caused by Intruder 264 .14 (a) (2) N/A
Disturbance of the waste or equipment
by the Wlknowing or unauthorized
entry of persons or livestock onto
the active portion of a facility will
not cause a violation of the
requirements of 40 CFR Part 264.
Note! To address F-lb(l) and
F-lb (2), the applicant should Guidance
include:
D Nature and duration of hazard
potential from wastes Guidance
D Equipment and structures to Guidance N/A
minimize potential for an intruder
to 1) cause a spill; 2) mix
incompatible wastes; 3) ignite
ignitable or reactive wastesi 4)
damage containment or monitoring
systems
D Features that prevent contact with Guidance N/A
waste.
F-2 Ins~ection Schedule 270 .14 (bl (5) F-2; I-2
264.15
A copy of the general inspection schedule
required by 264.15(b) including, where
applicable, specific requirements of
264.174, 264 .194, 264.226, 264.254, 264. 273,
264.303, and 264.347.
F-2a General Ins~ection Regyirements 2?0.14(b) (5) F-2; I-2
264 .15 (a) and (b)
A description of the facility inspection
schedule (schedule must be kept at the
facility) for the following equipment:
D Monitoring equipment 264.lS(a) and {b)
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
0 Emergency and safety equipment N/A
D Security devices F-2; 1-2
D Operating and structural equipment that F-2; 1-2
are vital to prevent, detect1 or
respond to environmental or human
health hazards
D Testing as necessary of communications N/A
or alarm systems1 fire protection
equipment1 and decontamination
equipment. 264.33
Examples of monitoring equipment that Guidance N/A
should be inspected at treatment, storager
and disposal facilities are:
0 Scales
D Flow and liquid level monitors N/A
0 Hazardous gas detectors N/A
0 pH monitors N/A
D Leachate monitors N/A
0 Pressure sensors N/A
0 Temperature gauges. N/A
Examples of monitoring equipment that Guidance N/A
should be inspected at facilities with
incinerators are:
0 Waste flow monitors and recorders
0 Auxiliary fuel flow monitors N/A
D Combustion air flow monitors N/A
0 Temperature monitors N/A
0 Flame sensors N/A
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
Examples of operating and structural Guidance N/A
equipment at TSD facilities are:
D Spill detection devices
D Spill control and collection equipment N/A
D Fire and explosion barriers N/A
D Ventilation equipment N/A
F-2a (continued) N/A
0 Sump pumps
D Dikes, bases, and foundations. N/A
In addition1 areas such as waste storage 1 N/A
mixing, loading1 and unloading areasr
which are subject to spills, must be
inspected.
F-2a (1) Tvnes of Probl~ms 26 4 .15 (b) ( 3) F-2; I-2;
TABLE I-1
The schedule must identify the types
of problems to look for during the
inspection (e.g.' leaksr
deterioration, readings out of
specified range, missing items or
materialsr inoperative equipment1
etc. J •
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
F-2a ( 2) Frequency of Inspection 264.15(b)(4) N/A
A description of the inspection
frequency must be provided for items
on the schedule. The frequency of
inspection should be based on the
rate of possible deterioration of
equipment and the probability of an
environmental or human health
incident if the deterioration,
malfunction, or operator error goes
undetected between inspections.
Areas subject to spills, such as
loading and unloading areas, must be
inspected daily when in use.
All emergency waste feed cut-off 264. 34 7 {c)
valves must be inspected at least {incinerators
weekly to verify proper operation. only)
All system alarms must also be tested
weekly.
F-2b S~ecific Prgcess Ins~egtiQil Regyir§megts 270 .14 {b) (5) N/A
264 .15 (b) (4)
At a minimum~ the inspection schedule must
include the terms and frequencies called
for in 264.174, 264.194, 264.226, 265.253,
264.254, 264.303, and 264.347, where
applicable.
F-2b (1) Container Inspection 264.174 N/A
A description of the weekly
inspection of containers and
container storage areas for leaks in
containers or deterioration of
containers and the containment system
caused by corrosion or other factors.
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
F-2b (2) Tank S~tem Insgection 264.195 N/A
[ 7/14 /8 6]
DA description of the inspection
each operating day of overfilling
control equipmentr monitoring
equipment and levels of waste in
uncovered tanks.
DA description of the daily N/A
inspection of tank construction
materials and the area surrounding
the tank including secondary
containment system {e.g., dikes) .
DA schedule describing the N/A
monitoring of each operating day of
monitoring equipment (e.g.,
pressure and temperature gauges)
where present to ensure that the
tank is operated according to
design specifications .
..
DA schedule showing the level of N/A
waste in uncovered tanks is
inspected each operating day.
DA schedule and procedure for N/A
assessing the condition of the
tankr including detection of leaks,
cracks, or wall thinning to less
than minimum shell thickness.
DA procedure for emptying a tank to N/A
allow entry and inspection when
necessary to detect corrosion or
erosion of the tank sides and
bottom.
D Confirm proper operation of N/A
cathodic protection system (if
present) within six months after
installation and at least annually
thereafter.
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos, Application Comments
F-2b(2) (continued) N/A
D Schedule showing all sources of
impressed current are inspected
and/or tested at least bimonthly.
F-2b (3) Waste Pilg Jns~eQtion 270 .14 (b) (SJ N/A
270.18(d)
The application must provide a 254.254
description of the procedures to:
D Inspect liners and covers during
construction and immediately after
installation for:
-uniformityr damage, and N/A
imperfections, holes~ cracks,
thin spots, bulges, root holes,
tight seams and joints,
permeability, and compaction
0Remove the waste pile and N/A
periodically inspect liners for
deterioration, cracks, and other
imperfections
DPerform weekly inspections and N/A
after storms to detect:
-deterioration, malfunctionsr or
improper operation of run-on and
run-off control systems
-the presence of liquids in leak N/A
detection systems, where
installed
-proper functioning of wind N/A
dispersal control systems, where
present
-the presence of leachate in and N/A
proper functioning of leachate
collection and removal systemsr
where present.
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
F-2b(4) Surfgce Inwoundmgnt Ins~ectiQn 270 .14 (b) (5) N/A
270.J.7(cl
The application must provide a 264.226(b)
description of how each surface
impoundment, including the liner and
cover systems and appurtenances
F-2b {4) I continued) N/A
for control of overtopping, will be
inspected weekly and after storms to
detect evidence of any of the
following:
0 Deterioration$ malfunctions1 or
improper operation of overtopping
topping control systems
D Sudden drops in the level of the N/A
impoundment 1 s contents
DThe presence of liquids in leak N/A
detection systems, where installed
.
D Severe erosion or other signs of N/A
deterioration in dikes or other
containment devices.
For new facilities, a description of 264.226(a) N/A
how the liners will be inspected
during construction and immediately
after installation to detect
nonuniformity1 damages1 and
imperfections {holes, cracks1 thin
spots1 bulges, root holes1 tight
seams and joints1 permeability, and
compaction) .
See Item D-4b(2) concerning
inspection of dikes for structural
integrity.
~
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
F-2b (5) Incinerator Inspection 264.347 N/A
D Incinerator and associated
equipment must be inspected
visually at least daily for leaks,
spillsj fugitive emissions and
signs of tampering.
D Emergency waste feed, cut-off N/A
system and associated alarms must
be tested weekly unless the
applicant demonstrates that weekly
frequency is unduly restrictive and
that less frequent inspection will
be adequate. At minimum,
operational testing must be
conducted monthl~.
F-2b (6) Landfill ln:§i;;iection 270.21(d) N/A
264.lS(a)
Landfill owners or operators must 264.303
provide a description of procedures
for:
0 For new facilities 1 inspection of
liners/covers during and
irrunediately after installation
D Inspections weekly and after storms N/A
for:
-operation of run-on/run-off
controls
-liquids in leak detection system
-proper functioning of wind
dispersal controls
-leachate in and proper operation
of leachate collection/removal
system.
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
F-2b (7) Land ~rggtment Insgection 270. 20 (cl (5) N/A
264. 273 (g)
A description or the inspection
procedures. Specifically the unit
must be inspected weekly and after
storms for;
0Deterioration1 malfunctions, or
improper operation of run-on and
run-off control systems
D Improper functioning of wind N/A
dispersal control measures
F-2b (BJ MiscellgueQus Unit Ins~gctions 270 .14 {b) (5) N/A
[ll/7 /86]
Provide an inspection program which 264.602
ensures compliance with the standards
specified in F-2b(l) through
F-2b 0), where applicable.
F-2c Remedial Action 264.lS(c) N/A
A description of procedures for taking
remedial actions when inspections reveal
problems or when problems are imminent.
These may alternately be described in the
contingency plan {[see 264 .194 (c),
264. 227' 264 .1 71] .
F-2d Ins~ection Log 264. 73 (b) (5) TABLE I-1
264.15 (d)
A copy or description of the inspection
log or summary form including the
following:
D Dates and times of inspections
D Name (s) and inspector (s) TABLE I-1
D Observations made TABLE I-1
D Date and nature of repairs or remedial TABLE I-1
actions taken.
Hazard Pre-..ren ti on -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
F-3 Waiver of Pregaredness and Prevention 270 .14 (b) (6) N/A
Reauirements
A justification of any request for a waiver
of preparedness and prevention requirements
of Part 264, Subpart c.
F-Ja Equipment Requirements 264.32
Unless it can be demonstrated that none of
the hazards posed by waste handled at the
facility would require a particular kind
of equipment specified below~ the facility
must have the following equipment: (These
requirements are not specifically listed
in 270.14-270.29 for inclusion in a Part
BJ .
F-3a (1) Internal Communications 264.32(2) F-3a{l)
An internal communications or alarm
system capable of providing immediate
emergency instruction {voice or
signal) to facility personnel.
F-3a{2) External Communications 264. 32 (b) F-3a(2)
A device such as telephone
(immediately available at the scene
of operations) or a handheld two-way
radio, for summoning emergency
assistance from local police
departments1 or state or local
emergency response teams.
F-3a(3) Emergency Equipment 264. 32 (cl F-3a(3)
D Fire control equipment {including
special extinguishing equipment,
such as that using foarn1 inert gas,
or dry chemicals1 and portable fire
extinguishers)
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D Spill control equipment " "
D Decontamination equipment. " "
F-Ja (4) Water for Fire Control 264.32{d) N/A
One of the following:
Owater at adequate volume and
pressure to supply water hose
streams, or
0Foam-producing equipment, or N/A
D Automatic sprinklers or water spray N/A
systems
F-3b Aisle Space Requirements 264.35 N/A
Requests for a waiver of the aisle space
remiirement must be accompanied by a
demonstration that aisle space is not
needed to allow the unobstructed movement
of personnel1 fire protection equipment1
or spill control equipment to any area of
facility operation in an emergency.
F-4 Preventivg Erocedure§1 Structures c 270.14{b) (8)
and Eauipment
A description of procedures, structures1 or
equipment used at the facility for the
following must be included:
F-4a Unloading Operations 270 .14 (b) {8) (i) N/A
Prevention of hazards in unloading
operations (e.g.' use of ramps or special
forklifts) .
Hazard Prevention -:Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
F-4b Run-Off 270 .14 {b) (8) (ii) N/A
Prevention of runoff from hazardous waste
handling areas to other areas of the
facility or environment, or prevention of
flooding (e.g.' berms, dikes, trenches) .
F-4c Water Sunplies 270 .14 (b) (8) (iii) SECTION E
Prevention of contamination of water
supplies.
F-4d Equipment and Power Failure 210 .14 (b) {8) Ii vi N/A
Mitigation of effects of equipment failure
and power outages.
F-4e Personal Protection Equipment 270 .14 (b) (8) {v) N/A
Prevention of undue exposure of personnel
to hazardous waste {e.g.' protective
clothing) .
F-5 Prevention of Reaction of ignitable, N/A
Reactive and Incompatible wastes
F-Sa P;[eca1itions to Prevent Ignition or 270 .14 (b) (9)
Reaction of Ignitable or Reactive Wastes 264.l7(a) and ( c)
A description of the precautions taken by
a facility that handles ignitable,
reactive~ or incompatible waste to
demonstrate compliance with 264.17
including documentation demonstrating
compliance with 264.17{c). Precautions to
prevent actual ignition. including
separation from sources of ignition such
as:
D Open flames
D Smoking N/A
D Cutting and welding N/A
---···--
Hazard PrevenLion -Module F
40 CFR Location in
Subject Requirement section Nos. Application Conune..71 ts
D Hot surfaces N/A
D Frictional heat N/A
D Sparks (static, electricalr or N/A
mechanical)
F-Sa (continued) N/A
D Spontaneous ignition (heat producing
chemical reactions)
D Radiant heat. N/A
Demonstrations that when ignitable or N/A
reactive waste is being handled1 the owner
or operator confines smoking and open
flames to specially designated locations.
11 No Smoking•1 signs must be conspicuously
placed wherever a hazard exists for
ignitable or reactive waste.
Subject Requirement
F-Sb General Precautions for Handling Ignitable
or Reactive Waste and Mixing of
Incompatible Waste
A description of the precautions taken by
a facility that treats, storesI or
disposes of ignitable or reactive waste,
or accidentally mixes incompatible waste
or incompatible wastes or other materials,
to prevent reactions which: (1} generate
extreme heat or pressure, fire or
explosions, or violent reactions; {2)
produce uncontrolled flammable fumes,
dusts, or gases in sufficient quantities
to threaten human health or the
environmenti (3) produce uncontrolled
flammable fumes or gases in sufficient
quantities to pose a risk of fire or
explosions; (4) damage the structural
integrity of the device or facility; {5)
by similar means threaten human health or
the environment.
Documentation to meet requirements of
264.17(a) or (b) may be based on
references to published scientific or
engineering literature$ data from trial
tests, waste analyses, or results of
treatment of similar wastes by similar
treatment processes and under similar
operating conditions.
F-Sc Mgnaqement of Ignitable or Reactive Wastes
in Containers
Sketches$ drawings$ or data demonstrating
that containers of ignitable or reactive
waste are located at least 15 meters {50
feet) from the facility's property line.
40 CFR
Section Nos.
270 .14 (b) (9)
264.17(b) and le)
264.17(c)
270.lS(c)
264.176
Location in
Application
N/A
N/A
-----,
Hazard Prevention -Module F
Comments
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
F-Sd M~nagem~t of Inco!!!I;!etible Wastes in 270. 15 ldl N/A
Containers 264.177
A description of procedures to demonstrate
compliance with 264.177(a) and (b) and
264 .17 (b) and ( c) :
0 The procedures used to ensure that 264.177 (a)
incompatible wastes and materials are 264.J.77{b)
not placed in the same container
(unless 264.17{b) is complied with) or
in an unwashed container that
previously held compatible waste
D Dikes, berms, wallsr or other devices 264 .177 (c) N/A
used to separate containers1 holding
wastes which are incompatible with
wastes or materials stored nearby.
F-Se Manag~m~nt Qf Ignita~le or R~active 270 .16 (f) N/A
Wastes in Tanks 264.198
A description of the procedures for
handling incompatible, ignitable, or
reactive wastes, including the use of
buffer zones. 264 requirements include:
D Waste must be treated, rendered1 or
mixed before or immediately after
placement in the tank so that it is no
longer considered ignitable and
complies with 264.17(b); or the waste
is stored or treated in such a way that
it is protected from any material or
conditions th.at may cause the waste to
react or ignite; or the tank is used
solely for emergencies
D Facilities that treat or store N/A
ignitable or reactive waste in covered
tanks must comply with the National
Fire Protection Association 1 s buffer
zone requirements for tanks.
Hazard Prevention -Module F
40 CFR Location in
subject Requirement Section Nos. Application Comments
F-Sf Incom2atible Wastes in Tanks 270.16 lfl N/A
264.199
A statement that incompatible wastes and
materials are not stored in the same tank
or in an unwashed tank that previously
held an incompatible waste or material
{unless 264.17(b) is complied with) .
F-Sg Ignitable or Reactive Wastes in 270.18(f) N/A
Waste Piles 264.256
The application must include a description
of the procedures for handling ignitable
or reactive wastes, including the use of
buffer zones. Waste must be treated,
rendered$ or mixed before or immediately
after placement in the waste pile so that
it is no longer considered ignitable and
complies with 264.17(b); or the waste is
stored or treated in such a way that it is
protected form any material or conditions
that may cause the waste to react or
ignite.
F-Sh Incom!2atible Wastes in W2st~ Piles 270.18 (g) N/A
264.257
The applicant must include:
D A statement that incompatible wastes
and materials are not stored in the
same waste pile or on the same base
that previously held an incompatible
waste or material unless 264.17(b) is
complied with
D A description of the procedures (dikes, N/A
beamsr walls, distances} utilized to
separate a waste pile of hazardous
waste that is incompatible with any
waste or other material stored nearby.
Hazard Prevention -Module F
40 CFR Location in
Subject Requirement Section Nos. Application Comments
F-5i Ignitable or Reactive Wastes in Surface 270.17(g) N/A
Impo11ndments
D The application must include a
description of the procedures for
handling ignitable or reactive wastes,
including the use of buffer zones.
Waste must be treated, rendered, or
mixed before or immediately after
placement in the waste pile so that it
is no longer considered ignitable and
complies with 264.17(b); or
D The waste is stored or treated in such N/A
a way that it is protected from any
material or conditions that may cause
the waste to react or ignite;
D The impoundment is used only for N/A
emergencies.
F-Sj InCQfill2atible W~stes in Surface 270.17{h) N/A
Impoupdments 264.230
The application must include:
D A statement that incompatible wastes
and materials are not stored in the
same surface impoundments or in the
impoundments that previously held an
incompatible waste or material unless
264.17(b) is complied with.
F-Sk I911itable or Reactive Wastes in Langfills 270.21(f) N/A
264.312
Documentation of procedures for:
D Rendering wastes nonreactive or prior
to or immediately after placement in
the landfill
D Preventing reactions N/A
-----,
Hazard Prevention -Module P
40 CFR Location in
Subject Requirement Section Nos. Application comments
D Protecting ignitable wastes in N/A
containers from materials or conditions
that may cause them to ignite.
F-51 Incompatible 1'1astes in Landfills N/A
Applicant must provide procedures for
insuring that incompatible wastes will not
be disposed of in the same landfill cell1
unless 264.17(b) is complied with.
F-Sm TgnitaQle or Reactive Wastes in Land 270. 20 (g) N/A
Treatment
A description of the management of
ignitable or reactive wastes which will be
placed in or on the treatment zone1 if
applicable, and an explanation of how the
following requirements will be complied
with:
D The waste is immediately incorporated N/A
into the soil so that the resulting
waste, mixture, or dissolution of
material no longer meets the definition
of ignitable or reactive waste and the
requirements of 26.17(b) are complied
with, or
D The waste is managed in such a way that N/A
it is protected from any material or
conditions which may cause it to ignite
or react.
F-Sn Incomsatible Wastes in Land Treatment 270.20{h) N/A
264.282
A description of the management of
incompatible wastes must be submitted if
incompatible wastes~ or incompatible
wastes and materials, will be placed in or
on the same treatment zone, including an
explanation of how the requirements of
264 .17 (bl are complied with.
REGULATORY COMPLETENESS CHECKLIST FOR HAZARDOUS WASTE STORAGE, TREATMENT AND DISPOSAL FACILITIES
Facility Name C I EPA I.D. Number NCD046i4854D
Address Permit Review Team
Contact Name Date Application Received
Contact Phone Number Date Review Completed
Contingency Plan -Module G
40 CFR Locatio11 in
Subject Requirement Section :r:-.ios . Application Comments
PART G -CONTINGENCY PLAN 270 .14 (bl (7) G-1
264.50 through
A copy of the contingency plan required in Part 264.56
264, Subpart D. Include, where applicable,
specific requirements in 264.227 and 264.225.
An existing spill prevention control plan can be 264.52(b)
amended to incorporate hazardous waste
management provisions sufficient to comply with
264, Subpart D requirements.
G-1 General Informatign 264.52
264.53
D Facility name and location and owner or 265.37
operator name
D Site plan G-i
Dnescription of facility operations. G-1
G-2 Emergenc~ Cgordinators 264.52(d) G-2
264.55
D Names, addresses1 off ice and home phone
numbers 1 and duties of primary and
alternate coordinators in sequences as
alternates
DA statement authorizing designated G-2
coordinators to commit the necessary
resources to implement the contingency
plan
D Can reach facility in short period of G-2
time.
40 CFR Location in
Subject Requirement section f..Tos . Application Comments
G-3 Imulementation 264. 52 (a) G-3
264. 56 (d)
Criteria for implementation of contingency
plan for any potential emergency:
D Fires/explosions
G-3 (continued) G-3
Dunplar~~ed sudden or non-sudden release of
hazardous waste or hazardous waste
constituents to air, soil, or surface
water
G-4 Emergency Response Procedures G-4a
G-4a Notification 264.56(a)
Methodology for immediate notification of
facility personnel and necessary state or
local agencies.
G-4b Identification of Hazardous Materials 264. 56 (bl G-4b
Available data and/or procedures for
identification of hazardous materials
involved in the emergency and quantity and
areal extent of release. Include
information on:
D Characteristics of waste
D Exact source G-4b
D Amount G-4b
D Areal extent of release G-4b
G-4c Hazard 8SS§ssment 264. 56 (c) G-4c
264.56{d)
D Procedure for assessment of possible
hazards to the environment and human
health
40 CFR Location in
Subject Requirement Sect ion Nos. Application Comments
D Procedures for determining the need for G-4c
evacuation and notification of
authorities. The authorities to be
notified must include the On-Scene-
Coordinator for that area or the
National Response Center~
G-4d Control Procedures 264. 52 (a) G-4d
D Specific responses and control
procedures to be taken in the event of
a fire, explosion, or release of
hazardous waste to air, land1 or water.
G-4e Prevention of Recurrence or Sgread of 264.56{e) G-4d
Fires. Explosions. or Releases
During an emergency situation, a
description of the necessary steps to be
taken to ensure that fires 1 explosions, or
releases do not occur, reoccur, or spread
to other hazardous waste at the facility.
Steps must include1 where applicable:
D Shut-down of processes and continued
monitoring of them
D Collecting1 containing, and treating G-4d
released wastes
D Removing and isolating containers G-4d
D proper sue of fire control structures Guidance G-4d
(e.g. ' fire doors) r systems (e.g.'
sprinkler systems), and equipment
(e.g.' extinguishers) .
G-4f Storage and Treatment of Released Material 264.56(f) G-4f
264. 56 (g)
D Provisions to monitor for leaks,
pressure buildup1 gas generation, or
ruptures as appropriate if operations
at the facility are stopped in response
to a release 1 fire, or explosion
40 CFR Location_ in
Subject Requirement Section N"os. Application Comments
0 Provisions for treatment1 storagei or G-4f
disposal of any hazardous waste
resulting from a releaser fire1 or
explosion at the facil it)"'
0 Equipment available Guidance G-4f
0 Procedures for deployment of these Guidance G-4f
resources
D Methods to contain1 treat1 and clean up Guidance G-4f
a hazardous release and decontaminate
the affected area.
G-4g Incompatible Waste 264. 56 (h} (1) G-4g
Provisions for preventing waste which is
incompatible with the released material
from being treated~ stored, or located in
the affected areas until cleanup
procedures are completed.
G-4h PQst-Emergen~~ E9JJ:igment Maintenance 264.56(h) (2) G4-h
264. 56 (i)
Procedures for ensuring that all emergency
equipment listed in the contingency plan
is cleaned and fit for its intended use
before operations are resumed. (This
includes advising authorities.)
G-4i Container Spills and Leakage 264. J. 7J. G-4i
Procedures for responding to container
spills or leakage including removal of
spilled waste and repair or replacement of
containers.
G-4j Tank Sgills and Leaka~e 264 .194 (c), G-4j
264. 200 (a) (2),
D Procedures and responding to tank 264 .194 (c) (2)
spills or leakage including removal of
spilled waste and repair of tank
40 CFR Locat.ion in
Subject Requirement Sect.ion Nos. Application Comments
D Procedures for resounding to leaks or 264. 200 (a) (2), G-4j
spills from tanks containing hazardous 264 .1S4 (cl (2)
wastes F02 O, F021, F022, F023, F026,
and F027; and procedures for immediate
removal of these wastes from the
containment systems and replacement or
repair of the leaking tank.
G-4k Surface IIDJ2oundments Sgillsj Leakag:e. and 270 .14 (bl (7)' N/A
Sudden Drops 264.227
D Procedures for stopping waste additions 264. 227 (bl (1)
D Procedures for containing any leakage 264. 227 (b) (2) N/A
D Procedures for stopping leaks and 264. 227 (b) {3) N/A
preventing sudden drops and preventing 264. 227 {b) (4)
catastrophic failure
D Procedures and criteria for emptying 264. 227 (b) (5) N/A
impoundment
D Procedures for installing a liner in 264.227(d) (2) N/A
existing portions of the impoundrnent or
procedures for certification of the
liner in other than existing portions
when the impoundment is removed form
service as the result of a sudden drop
in liquid level
.·
D Obtain qualified engineers N/A
certification of repairs and
probability of leakage or failure.
G-5 Emergenc~ Eg:yigment 264. 52 (e) PROVIDE A COMPLETE LIST OF
ALL EMERGENCY EQUIPMENT
Location1 descriptionr and capabilities of AVAILABLE
emergency equipment. This should include:
D Spill control equipment
D Fire control equipment " "
D Personal protective items such as Guidance " "
respirators and protective clothing
D First aid and medical supplies " "
40 CFR Location in
Subject Requ_irement Section Nos. Application Comments
D Emergency decontamination equipment " "
D Emergency communication and alarm systems. " "
G-6 Coordination Agreements MUST INCLUDE A COPY OF THE
COORDINATION AGREEMENTS
DA description of coordination agreement 264.37 WITH OUTSIDE AGENCIES
with local police and fire departments, 264.52(c)
hospitals, contractors, and state and
local emergency response teams to
familiarize them with the facility and
actions needed in case of emergency
DA statement indicating that a copy of the 264. 53 (bl MUST SEND A COPY OF
contingency plan has been submitted to CONTINGENCY PLAN TO
these organizations OUTSIDE AGENCIES
D If applicable, document of refusal to 264.37{b) N/A
enter into a coordination agreement~
G-7 Evacuation Plan 264.52{f) N/A
The plan must include:
0 Criteria for evacuation
DA description of signal ls) to be used to N/A
begin evacuation
D Primary and alternate evacuation routes. N/A
G-8 Reffilired Reports 264.56(j) SECTION G-8
0Provisions for submission of reports of
emergency incidents within 15 days of
occurrence
0Notation of such incidents in the SECTION G-B
operating record identifying the time,
date, and details of these emergency
incidents.
REGULATORY COMPLETENESS CHECKLIST FOR HAZARDOUS WASTE STORAGE, TREATMENT AND DISPOSAL FACILITIES
Facility Name ~C~T~I....._ ______________ _
Address
Contact Name
Contact Phone Number
Subject Requirement
PART H -PERSONNEL TRAINING
H-1 Outline of Training Program
An outline of both the introductory and
continuing training programs by owners or
operators to prepare the personnel to
operate and maintain the facility in a safe
manner as required to demonstrate compliance
with 264.16. Include a brief description of
how training will be designed to meet actual
job tasks in accordance with requirements in
264.16 (a) (3).
(Note: On-the-job training may be used to
comply with these requirements) .
H-la Job Titles and Duties
For each employee whose position at the
facility is related to hazardous waste
management, the following must be
maintained at the facility:
D Job title
D Job duties
D Job description.
EPA I. D. Number N=C~D"'0"'4"6~l~4"-"8-"5"'4~0'-----------------­
Permi t Review Team-------------------
Date Application Received
Date Review Completed
40 CFR Location in
Section Nos. Application
270 .14 (b) (12)'
270 .16
264 .16 (d) {l)'
264 .16 (d) (2)
Personnel Training -Module H
Comments
NEED TO INCLUDE JOB
DUTIES AS RELATED TO THE
HWMU
" "
" "
Personnel Training -Module H
40 CFR Location in
Subject Requirement Section Nos. Application Comments
H-ib Training Content~ Fregyenc:J::i and 264 .16 (a) (3) , SECTION H-lb
Technigyes 264.16 (c),
264.16(d) (3)
In both introductory and continuing
training (including an annual review of
the initial training) for each employee$
describe:
0 Training content SECTION H-lb
0 Frequency of training SECTION H-lb
D Technique(s) used in training. SECTION H-lb
H-lc Training Director 2 64 .16 {a) (2) H-lc
Demonstration that the program is directed
by a person trained in hazardous waste
management:
D Credentials of training director+ Guidance
H-ld Relevance of Training to Job Position 2 64 .16 {A) (2 I MUST TRAIN IN
CONTINGENCY PLAN
A brief description of how instructions of
facility personnel in hazardous waste
management procedures (including
contingency plan implementation) is
relevant to their positions. [To
demonstrate compliance with 264 .16 (a) (2 J • ]
H-le Training for Emergency Response 264.16{a) (3) SECTION H-le
Documentation that the training program
trains facility personnel to respond
effectively to emergencies and trains them
to be familiar with emergency procedures,
emergency equipment, and emergency
systems1 include where applicable:
D Procedures for usingI inspecting, 264 .16 lal (3 I (ii
repairing1 and replacing facility
emergency and monitoring equipment
Personnel Training -:Module H
40 CFR Location in
Subject Requirement Sect ion Nos . Application Comments
D Key parameters for automatic waste feed 264 .16 (a) (3) (ii) N/A
cut-off systems
D Communications or alarm systems 264 .16 [a) (3) {iii) SECTION H-le
D Response to fires or explosions 264 .16 {a) (3) (iv) SECTION H-le
D P.esponse to grou...11.dwater contarninatio1:i 264 .16 (a) i3i iv) SECTION H-le
incidents
D Shutdown of operations. 264 .16 {a) (3) (vi) N/A
H-2 Imglementation of Training Program 264.16(d) [4) SECTION H-2
264 .16 (b)
D Indication that training has been and will
be successfully completed by facility
personnel within 6 months of their
employment or assignment to a facility1 or
transfer to a new position at a facility 1
whichever is later. [Note: Employees
hired after the effective date of these
regulations must not work in unsupervised
positions until they have completed the
training requirements) .
D Records documenting that the required SECTION H-2
training has been given to and completed
by facility personnel must be maintained.
REGULATORY COMPLETENESS CHECKLIST FOR HAZARDOUS WASTE STORAGE, TREATMENT AND DISPOSAL FACILITIES
Facility Name ~C~T~Ic_~~~~~~~~~~~~~~~­
Address
Contact Name
Contact Phone Number
EPA I.D. Number __.,N~C±D~0~4~6"-"'1~4~B~5~4Ll0'-~~~~~~~~~~~~~~~~­
Permit Review Team
Date Application Received
Date Review Completed
Closure/Post-Closure and Financial Requirements -Module I
II I 40 CFR I Location in I I!
Subject Requirement I Section Nos. I Application I Comments
PART I -CLOSURE PLANS, POSTCLOSURE PLANS, AND
FINA..~CIAL REQUIREMENTS
I-L Closure Plans
A copy of the written closure plan
required by 264.112 and consistent with
Items I-la through I-le.
I-la Closure Performance Standard
A description of how closure:
D Minimizes the need for further
maintenance
270 .14 {b) {13)
[12/10/87]'
270 .14 (b) (15)
[5/02/86]
270.14(b) (16)
[ 5 /02 /8 6] '
270.l4(b) (17)'
270 .14 (b) (18) •
264.110-264.151,
264 .1 78'
264. 197'
264.228,
264.25B,
264.280,
264.310,
264.351
270 .14 {b) {13)'
264.112
[5/02/86]
264. lll
{264.112 requires
consistency with
264.lll)
[ 5 /02 /86]
N/A
Include a copy of the
closure plan in the Part B
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D Controls, minimizes, or elicninates N/A
post-closure escape of hazardous waste,
hazardous constituents~ leachate,
contaminated run-offI or hazardous
waste decomposition products to the
ground or surface waters or to the
atcnosphere.
D Complies with the closure requirements N/A
of Subpart G and unit-specific closure
requirements.
I-la (continued) N/A
D Estimated expected year of closure for
facilities that use trust funds to
establish financial assurance and that
are expected to close prior to the
expiration of the permit.
I-lb Partial Closure and Final ~losure 264. 112 (bl ' N/A
Activities {264.112 {b) (1)
through
Fully describe time and all activities 264 .112 (bl (7)
required for: outline minimum
acceptable plan
D Partial closurez if applicable elements)
D Final closure [5/02/86] N/A
D Maximum extent of operation which will N/A
be active during life of facility.
Description must identify how requirements N/A
of 264.111, 264.113, 264 .114, 264.115 and
applicable requirements of 264.178,
264.197, 264.228, 264. 258, 264.280,
264. 310, and 264.351 will be met.
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-le Maximum Waste Inventor~ 264 .112 (b) (J] N/A
[5/02/B6)
A description of the maximum inventory of
wastes that could be in storage,
treatment$ and disposal at any time during
the life of the facility.
Methods for removing1 transporting1
treating, storing I or disposing of all
hazardous wastes. Identification of the
type (s) of off-site hazardous waste
management units to be used.
1-ld Schedule for Closure 264 .112 {b) (6) N/A
[ 5 /02 /B 6 J
A schedule for final closure including:
D Each HWMU and final closure of the
facility
0 Closure schedule with total time to N/A
close, time for intervening closure
activities, and inspection schedule
during closure.
1-ld {continued) N/A
D Estimated expected year of closure for
facilities that use trust funds to
establish financial assurance and that
are expected to close prior to the
expiration of the permit+
I-dl (1) Time Allowed for Closu~e 264 .112 (b) (2) • N/A
264 .113 (a) and (bl
The schedule for closure must show: [5 /02 /B 6]
0All hazardous wastes will be
treated, removed off-site$ or
disposed of on-site within 90 days
from receipt of final volume of
waste at the unit or facility
Closure I Post-Closure and Financial Requirements -Ji.1odule I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D All closure activities will be N/A
completed within l80 days from
receipt of final volume of waste at
the unit or facility.
1-ld (1) (a) Extensions for Closure Time 264 .113 (a), N/A
264 .113 (b)
A petition made to the Regional [ s I 02/ s 6 J
Administrator for a schedule for
closure which exceeds the 90 days
for treatment I removalr or
disposal of wastes and/or the 180
days for completion of closure
activities made to the Regional
Administrator. One of the
following must be demonstrated.
D Closure activities require
longer than 90 or lBO days,
Dunit or facility has capacity N/A
to receive additional wastesr
D There is a reasonable N/A
likelihood that another person
other than owner or operator
will recommence operation of
the site within one year 1 and
D Closure would be incompatible N/A
with continued operation.
I-ld (1) (a) (cont inued I N/A
Demonstrate that all steps have
and will be taken to prevent
threats to human health and
environment from unclosed but
inactive facility.
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-le Closure Procedures 264.112, N/A
264 .114
!5/02/86]
I-le (1) Inventory gemgval1 Disgos9l 1 or 264.114
Decontamination of Equipment [5/02/86]
A description of how all facility 264.112{b) (4)
equipment and structures will be [5 / 02 /86]
decontaminated or disposed of when
closure is completed. The following
should be included:
0 Decontamination procedures
D Criteria for determining N/A
decontamination
D List of equipment, structuresr and N/A
soils
D Disposal of contaminated soil and N/A
residues
0 Decontamination of clean-up N/A
materials and equipment
0Demonstrate decontamination has N/A
been effective.
A demonstration that any hazardous 264 .111 (b) N/A
constituents left will not impact [5/02/86]
environmental media in excess of Guidance (Preamble
agency established exposure levelsr 51 FR 16444,
and direct contact will not pose a May 2, 1986)
threat to human health and the
environment.
I-le(2) Clgsure of Disgos~l Units 270 .14 (b) (13) • N/A
270.17(f).
Closure plans for all piles~ 270.18 (h),
landfills, surface impoundments, and 270.21(e),
miscellaneous disposal units in which 264. 228 {a) (2) ,
wastes or contaminated materials are 264. 228 (c) (1) I ii,
to remain at closure must describe 264. 258 (c) ,
Closure/PosL-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-le (2) (continued} N/A
how the unit will be closed, 264. 310 {a),
including a description of the final 264.601
cover to be established and its
expected performance. Contingent
closure plans for tanks 1 surface
impoundments1 and waste piles also
must provide these descriptions.
I-le(3) Closure of Containers 264.178 N/A
A description of how at closure~ all
hazardous waste residues will be
removed from the containment system1
and how remaining containers~ bases,
and soil containing or contaminated
with hazardous waste or hazardous
waste residues will be decontaminated
or removed.
The description should address the
following:
0Hazardous waste removal and Guidance
disposal
D Container decontamination and Guidance N/A
disposal
D Site decontamination and disposal Guidance N/A
including linings, soil, and washes
Dverification of decontamination Guidance N/A
0Maximum inventory 264 .112 (b) (3) N/A
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-le(4) Closure of N/A
Tanks
264 .197 {a)
A description of how at closure1 all
hazardous waste residues will be
removed from tanks 1 discharge control
equipment 1 and secondary containment
structures~ and the facility will be
decontaminated. The description
should address the following:
Guidance
D Waste remov·al from tanks and
equipment
I-le (4) (continued) N/A
0 Decontamination of all components Guidance
D Verification of decontamination Guidance N/A
D Disposal of wastes and residues Guidance N/A
0Maximum inventory 264. ll2 (b) {3) N/A
If not all contaminated soils can be 264.197(b) N/A
removed or decontaminated at closure1 [ s I 02 /86 l
a closure and post-closure plan for a 264.197(c)
landfill must be included. If the
tank systems do not have secondary
containment or are not exempt, then a
contingent closure and post-closure
plan for a landfill must be provided.
Subject Requirement
I-le(S)
I-le (5)
Closure of Waste Piles
The application must describe how all
hazardous waste residuesr
contaminated containment system
components {liners, etc.)r
contaminated subsoils, and structures
and equipment contaminated with waste
and leachate will be removed or
decontaminated at closure and managed
as hazardous waste.
If any wastes, waste residues, or
contaminated materials or soils will
remain after closure, provide plans
for closing the pile as a landfill
[I-lf(6)) and provide postclosure
plan [I-2] . Piles without liners or
with liners that do not meet the
requirement of D-3e must also provide
contingent plans for closing the
facility as a landfill {I-ld(6JJ and
a contingent post-closure (I-2],
except for dry, enclosed piles
meeting the requirements of D-3b or
piles for which a liner exemption is
sought in accordance with D-3c.
{continued)
The description should address the
following:
DProcedure and criteria for
determining whether or not
decontamination has been successful
D Sampling and analytical techniques
Closure/Post-Closure and Financial Requirements -l-1odule I
40 CFR
section Nos.
270 .18 {h)
264.258
264 .112 {b) {4)
Location in
Application
N/A
N/A
N/A
Comments
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-le (6) Closure of Surface ll.!Jl20undments 270.17(f) N/A
264. 228 (al (1), (2 I
A description of how all hazardous 264.228(b)
waste residues, contaminated
containment system components
(liners$ etc. ) , contaminated
subsoils, and str~ctures and
equipment contaminated with waste and
leachate will be removed or
decontaminated at closure and managed
as hazardous waste~
The description should address the N/A
following,
D Procedure and criteria for Guidance
determining whether or not
decontamination has been successful
0 Sampling and analytical techniques Guidance N/A
Ocontinuance of treatment during Guidance N/A
closure (if appropriate) .
If any wastes, waste residues or N/A
contaminated materials or soils will
remain after closure, provide plans
for closing the surface impoundment
in place and provide post-closure
plans [I-2] . Plans for closing a
surf ace impoundment in place must
address the following'
0Elimination of liquids by removal
or solidification
D Stabilization of wastes to N/A
sufficient bearing capacity
Subject Requirement
I-le (6 I
I-le(7)
(continued)
D Final cover designed and
constructed to provide long-term
minimization of migration of
liquids through the closed
impoundrnentI function with minimal
maintenance, promote drainageI and
minimize erosion of final coverI
accommodate settling and
subsidence, and have a permeability
less than or equal to that of the
bottom liner system or natural
subsoils present~
Surface impoundments without liners
or with liners that do not meet
requirements of D-4c must also
provide contingent plans for closure
in place and a contingent post-
closure plan [I-2], except for
impoundments requesting a liner
exemption in accordance with D-4b~
Closure of Incinerators
Description of how at closure all
hazardous waste and hazardous waste
residues including ash, scrubber
waters, and scrubber sludges will be
removed from the incinerator,
associated duct work, piping, air
pollution control equipment, sumps,
and any other structures or operating
equipment such as pumpsj valves,
etc., that have come into contact
with the hazardous waste.
Alternatively, a description of how
the incinerator and associated units
and equipment will be dismantled and
disposed of as a hazardous waste will
suffice.
Closure/Post-Closure and Financial Requirements -Module I
40 CFR
Section Nos.
264.351
L-ocat. ion in
Application
N/A
N/A
N/A
Comments
Closure/Post-Closure and Financial Requirements -Module I
4Q CFR Location in
Subject Requirement Section Nos. Application Comments
I-le (8) Closure fo~ Landfills 270.2l{e), N/A
264. 310 (a),
Provide detailed plans and an 264. 280 {bl
engineering report which describes
the final cover components in detail.
Cover i:n.stallation and ccnstr"..J.Ction
quality assurance procedures should
be thoroughly described. These
I-le{8) (continued) N/A
detailed plans and engineering
reports must describe how the final
cover will:
D Provide long-term minimization of
migration of liquids through closed
landfill
D Function with minimum maintenance N/A
D Promote drainage and minimize N/A
erosion/abrasion
D Settle/subside without losing N/A
integrity
D Be less permeable than bottom N/A
liners or subsoils
Dwithstand freeze/thaw cycles. N/A
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-le{9} Closure of Land Treatment 270. 20 (f)' N/A
264. 280 {a]
During closure of land treatment
facilities I the oi;.imer or operator
must comply with the following:
Dcontinue all operations (including
pH control] necessary to maximize
degradation, transformation, or
immobilization of hazardous
constituents within the treatment
zone as requiredI except to the
extent such measures are
inconsistent with 2 6 4 . 28 O I a) ( 8 J
D Continue all operations in the N/A
treatment zone to minimize run-off
of hazardous constituents
DMaintain the run-on control system N/A
DMaintain the run-off management N/A
system
Dcontrol wind dispersal of hazardous N/A
waste if required
I-le (9) (continued) N/A
0 Continue to comply with any
prohibitions or conditions
concerning growth of food-chain
crops
D Continue unsaturated zone N/A
monitoring except that soil-pore
liquid monitoring may be terminated
90 days after the last application
of waste to the treatment zone
Subject Requirement
D Establish a vegetative cover on the
portion of the facility being
closed at such time that the cover
will not substantially impede
degradation$ transformation$ or
immobilization of hazardous
constituents in the treatment zone.
The vegetative cover must be
capable of maintaining growth
without extensive maintenance.
When closure is complete the owner-
operator may submit to the Regional
Administrator certification by an
independent qualified soil scientist 1
in lieu of na independent registered
professional engineer that the
facility has been closed in
accordance with the specifications in
the approved closure plan.
I-le{lO) Closure of Miscellaneous Units
Show that at closure$ all hazardous
waste and hazardous waste residues
will be removed from the treatment
process or equiprnent1 discharge
control equipment1 and discharge
confinement structures~ and that the
facility will be decontaminated.
Description of the sampling/test
procedures or other means used to
ensure that no contamination remains
on$ in1 or around the units and
associated equipment and structures.
If any wastes, waste residues1 or
contaminated materials or soils will
remain after closure, provide plans
Closure/Post-Closure and Financial Requirements -Module I
40 CFR
Section Nos.
264.601
270. 23 (a) (2)
[12/10/87]
Location in
Application
N/A
N/A
N/A
Comments
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-le(lO) (continued) N/A
for closing the miscellaneous unit as
a disposal unit [I-le (2)) and provide
post-closure plans [I-2] .
I-2 Post-Closure Plan 270 .14 (bJ {13}'
270.17(f),
An owner/operator of a disposal facility 270.lB{h),
must have a written post-closure plan, or, 270.20{f),
if applicable, a contingent post-closure 270.21 (e),
plan. A copy of the approved plan and all 270. 23 (a) {3),
revisions to the plan must be kept at the 264.118
facility until the post-closure care begins. [5/02/86] •
Landfill, surface impoundmentr waste piler 264.197(bl'
and tank post-closure plans should address 264 .197 (cl (21,
items I-2a, b, c, f, g, h; land treatment 264.228(b),
unit post-closure plan, items l-2d f, g, and 264. 228 (c) (1) (ii),
h; miscellaneous units should address items 264. 258 {b)'
I-2a1 b, c, e, f, g, and h. 264. 258 {c) {1) {ii),
264. 280 (c),
264. 3l0 (b)'
264.603.
I-2a Ins~ection Plan 264. 118 {a) , TABLE I-1
[5/02/86]
A description of the inspections to be 264 .197 (b)'
conducted during the post-closure care 264 .197 (c) {2),
periodr their frequency, the inspection 264. 228 (bl '
procedurer and the logs to be kept. The 264. 228 (cl (1) (ii),
following items, as applicabler should be 264. 258 {b)'
included in the inspection plan: 264. 258 {c) (1) (ii),
264.310(b)
D security control devices
D Erosion damage TABLE l-1
.
D cover settlement, subsidence, and TABLE l-1
displacement
D Vegetative cover condition TABLE I-1
D Integrity of run-on and run-off control TABLE l-1
measures
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D Cover drainage system function TABLE I-1
D Leachate collection/detection and N/A
removal system maintenance
D Gas venting system N/A
n Well condition TABLE I-1 ~
I-2a (continued) TABLE I-1
D Benchmark integrity
The rationale to be used to determine the
need for corrective maintenance
activities.
1-2b Monitoring Plan 264.118(b) (1) INCLUDE METHODS FOR
[5 I 02 /a6 J , QUARTERLY INSPECTION OF
A description of the monitoring to be 264. 228 (b)' COMPLIANCE MONITORING
conducted during the post-closure care 264 .197 {b)' WELLS
period1 including, as applicable 1 the 264 .197 (c) (2) ,
procedures for conducting the following 264. 228 (cl (l) (ii),
operations and evaluating the data 264.258(b),
gathered should include: 264. 258 (c) (1) {ii),
264. 310 {b)
D Groundwater monitoring
D Leachate collection/detection and
removal~
I-2c Maintenance Plan 264 .118 {b) (2)' STATE THAT REPAIRS WILL BE
[5/02/86] MADE AS SOON AS
A description of preventative and 264 .197 (b) • TECHNICALLY FEASIBLE
corrective maintenance procedures1 264 .197 (cl (2),
equipment procedures 1 equipment 264.228(b),
requirements, and material needs. Include 264. 228 le) {1) (ii I,
the following items in the maintenance 264. 258 (b)
plan, as applicable: 264. 258 (cl (1) (ii),
264.310(b)
D Repair of security control devices
D Erosion damage repair " "
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requ_irement Section Nos. Application Comments
D Correction of settlementr subsidencer " "
and displacement
D Mowing~ fertilizationz and other " "
vegetative cover maintenance
D Repair of ru,,~-on and r •. 1n-off control " 11
structures
D Leachate collection/detection system n/a
maintenance
D Well replacement " "
D The rationale to be used to determine " "
the need for corrective maintenance
activities.
I-2d Land Treatment 264.2BO(c) N/A
A description of the operation,
inspectionz and maintenance programs to be
used at the closed facility. Include
descriptions of the procedures for
conducting the following activities and
identify frequencies at which they are to
be conducted:
D Continuance of land treatment
D Vegetative cover maintenance N/A
D Maintenance of run-on control systems N/A
and run-off management systems
D Wind dispersal control N/A
D Control of food chain crops N/A
D Unsaturated zone monitoring N/A
Closure/PosL-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-2e Post-Closure Care for Miscellaneous Units 270. 23 (al (JI, N/A
264.603
A detailed description of the plans to [ 12 /10 / 8 7)
ensure protection of human health and the
environment. Include the prevention of
any releases to groundwater or subsurface
environment; surface water or wetlands or
on the soil surface; or to air. This will
include providing related information form
[D-B] .
I-2f Post-Closure Securit~ 264 .117 {bl SECTION 12-f
[5 / 02 / 8 6)
Indicate which security provisions will
continue during closure when hazardous
waste will remain exposed after completion
of partial or final closure or access by
the public or domestic livestock may pose
a hazard to human health.
I-2g Post-Closure Contact 264 .118 (bl (3 I SECTION 12-g
[5/02/86]
Provide the name1 address 1 and phone
number of the person or office to contact
about the hazardous waste disposal unit or
facility during the post-closure care
period.
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-3 Notices Re9.l!ired for Disgosal Facilities 264 .115 SECTION I-Ja,
[5/02/86]' APPENDIX I-2
I-3a Certification of Closure 264.2BO(b)
A statement by the applicant which
indicates that within 60 days of
completion of closure of each hazardous
waste surface impoundment, waste pile 1
land treatment1 and landfill unit1 and
within 60 days of the completion of final
closure, closure certification will be
submitted to the Regional administrator.
The certification must certify that the
hazardous waste management unit or
facility, as applicable1 has been closed
in accordance with the specifications of
the approved closure plan. The
certification must be signed by the
owner/operator and by an independent
registered professional engineer {or by an
independent qualified soil scientist in
the case of a land treatment closure) .
Subject Requirement
I-3b Survey Plat
A statement by the applicant which
indicates that no later than the
submission of certification of closure of
each hazardous waste disposal unit, a
survey plat indicating the location and
dimensions of landfill cells or other
disposal units with respect to permanently
surveyed benchmarks, will be submitted to
the local zoning authority (or authority
with jurisdiction over local land use) and
to the Regional Administrator. The plat
must be prepared and certified by a
professional land surveyor and must
contain a note, prominently displayed,
which states the owner-operator 1 s
obligation to restrict disturbance of the
disposal unit in accordance with
applicable 40 CFR 264 Subpart G
regulations.
I-Jc Notice to Local and Authority
Documentation by applicant that within 60
days after closure, a record of the type,
location, and quantity of hazardous waste
within each cell or disposal area will be
submitted to the appropriate local land
use authority and to the Regional
Administrator.
Closure/Post-Closure and Financial Requirements -Module I
40 CFR
Section Nos.
264 .116
[ 5 / 02 / 86]
264 .119
[5/02/86]
Location in
Application
SECTION I -3b;
APPENDIX I-2
SECTION I-3c;
APPENDIX I-2
Comments
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-3d Post-Closure Certification 264.120 SECTION I-3d
[5/02/86]
Provide a statement which indicates that
within 60 days of completion of the post-
closure care period for each hazardous
waste disposal unit! certification will be
submitted to the Regional Administrator.
The certification must certify that the
post-closure care period for the hazardous
waste disposal unit was performed in
accordrulce with the specifications of the
approved post-closure plan. The
certification must be signed by the owner/
operator and by an independent registered
professional engineer.
l-3e NotiQe in Deed to Pro~erty 270 .14 {b) (14)' SECTION 1-3e;
264.119 APPENDIX I-2
Documentation by applicant that s/he has [5/02/86]
or will record a notation on the facility
deed, or other instrument examined during
a title search1 that notifies any
potential purchase of the property that:
D The property has been used to manage
hazardous wastes
D Use of the land is restricted to SECTION I-3e;
activities that will not disturb APPENDIX l-2
integrity of final cover system, or
monitoring system during post-closure
care period
D Requirements stated under I-3a above APPENDIX I-2
have been complied with.
Closure/PosL-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-4 Closure Cost N/A
Estimate
270 .14 (b) (15)
A copy of the most recent closure or [5 / 02 J s 6 J
contingent closure cost estimate~ prepared
in accordance with 264.142.
264 .142 {a) {2)
Dcost estimate based on third party costs
D Fully loaded (most costly) Guidance N/A
DNo salvage credits 264 .142 {a) (3), (4) N/A
D Current year costs 264 .142 {a) N/A
0 Cost adjusted annually from anniversary 264.142{b) N/A
date of first cost estimate
DBased on point in operating life when 264 .142 {a) N/A
extent and manner of operation would make [5/02/86)
closure most expensive.
I-5 Financial Assurance Mechanism for Closure 270 .14 (b) (15) N/A
264.143
A copy of the established financial 264.151
assurance mechanism for facility closure [5/02/86]
adopted in compliance with 264.143. The
mechanism must be one of the following [I-
5 (a) through I[5{f)] and include due dates
and use standard wording.
I-5a Closure Trust Fund 264.143(a), N/A
264 .151 (a) (1)
A copy of the closure trust fund agreement
with the wording required in 2 6 4. 151 (a) ( 1)
and a formal certification of
acknowledgement.
D Bank or approval institution
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
0 Mechanics: N/A
-pay-in period; life of permit or
remaining life of facility1 whichever
is shorter,
-annual payment; unfunded liability
divided by years left in pay-in
period.
I-Sb Surety Bond N/A
A surety bond from a federally acceptable 264.143(b) and{c),
surety company meeting one of the 264.lSl{b) and (cl
following requirements! [5/02/86)
0 Surety bond guaranteeing payment into a 264. l43 {b)'
closure trust fund. A copy of the 264.lSl{b)
surety bond with the wording required [5/02/86]
in 264.lSl{b), a copy of the standby
trust fund agreement
0 Surety bond guaranteeing performance of 264 .143 (c), N/A
closure. A copy of the surety bond 264 .151 (c)
with the wording required in Part
264 .151 {c), Guaranteeing that the
D1Nller/operator will perform closure
according to the closure plan and the
requirements of Subpart G.
I-Sc Closure Letter of Credit 264. l43 (d)' N/A
264.lSl(d)
A copy of a closure letter of credit with
the wording required in 264.lSl(d):
0 Irrevocable letter of credit
0 At least one year period1 automatic N/A
renewal
0 Standby trust fund N/A
0 Amount reflects current cost estimate. N/A
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-5d ClQsure Insurance 264.143[e) N/A
264.lSllel
To demonstrate that the owner/operator has
closure insurance, s/he must submit to the
Regional Administrator 60 days before
hazardous waste is received a certificate
of insurance worded as specified in
264 .151 {el .
D Non-cancelable policy, automatic
renewal
D Insurer 1 icensed or_ eligible surplus N/A
lines carrier
D Certificate of insurance N/A
I-5d (continued) N/A
0 Funds available whenever final closure
occurs.
I-5e Financial Test and Co!J;;!orat~ Guarante§ for 264.143[f). N/A
Closure 264 .151 [f).
264 .151 [h)
To demonstrate that this test is met~ an [5/02/86)
owner/operator must submit a letter signed
by the company 1 s chief financial officer
that is worded as specified in 264.lSl(f)
and meets the following criteria:
D Tangible net worth $10 million
D Tangible net worth 6 x all closure and N/A
post-closure costs
D U.S. assets at least 90~ of total N/A
assets or at least six times all
closure and post-closure costs
0 Bond rating requirement or alternative N/A
financial ratio tests
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D Application must include: N/A
-copy of a report from the 0"1D.er 1 s/
operator,s independent CPA to the
owner/operator stating that s/he has
examined the data in the letter from
the chief financial officer and that
it is consistent with the amounts in
the independently-audited year-end
financial statements for the latest
fiscal year and that no matters came
to attention to cause her/him to
believe that the data should be
adjusted.
In lieu of the above items, the owner/ 264.143(f) (10) N/A
operator may submit a corporate guarantee
worded as required by 264.151(h). This
guarantee provides that the guarantor must
be the parent company of the owner/
operator. A copy of these items should be
submitted with the Part B for review by
the permit writer.
Subject Requirement
I-5f Combinations
I-5f Ill Use of Multiple Financial Mechanisms
A copy of a combination of trust fund
agreements 1 surety bond guaranteeing
payment into a closure trust fund,
letter of credit1 or insurance, and
state assumption of responsibility,
which provide financial assurance for
the amount of closure. Combined
financial assurance must be at least
equal to the adjusted closure cost
estimate. Financial assurance
instruments must meet requirements
264 .143 (a), (bl , (d) , or (e) which
include closure trust fund, surety
bond guaranteeing payment into a
closure trust fund 1 closure letter of
credit1 and closure insurance1
respectively.
I-5f(2) Use of Financial Mechanism for
Multiple Facilities
A copy of a financial assurance
mechanism for more than one facility
showing for each facility, the EPA ID
number, name 1 address, and amount of
closure funds assured by the
mechanism~
Total funding must be no less than
the sum required for each facility
considered separately. Documents
must be submitted to each Region
where facilities are located.
Financial test applies to sum of
closure and post-closure costs for
all facilities.
Closure/Post-Closure and Financial Requirements -Module I
40 CFR
Section Nos.
264.143(g)
264.143{h)
264 .143 lh)
N/A
Location in
Application
N/A
Comments
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-6 Post-Closure Cost Estimate 270 .14 (bl (16) ' REVISE TO INCLUDE ALL
264.144 CHANGES NECESSITATED BY
If landfill, land treatmentr surf ace [5/02/86] THIS NOD
impoundments r or waste piles are utilizedr
the application must include a post-closure
or a contingent post-closure cost estimate
prepared in accordance with 264.144~
D Fully loaded labor rate (third party) Guidance
I-6 (continued) " "
DNo salvage values Guidance
DNo operation credits (gas, cropsr Guidance " "
livestock)
D Current year Guidance " "
DBased on the extent of operation most Guidance " "
likely to make post-closure most expensive
D Inspection costs Guidance " "
DAdministration Guidance " "
D Transportation Guidance " "
I-7 Financial Assurance Mechanism for ~ost-270 .14 (b) (16) N/A
Closure 264.145
264.151
A copy of the established financial [ 5 / 0 2 /8 6]
assurance mechanism for post-closure care
adopted in compliance with 264.145. The
mechanism must be one of the following:
[I-7{a) through I-7 (fl J and include due
dates and use standard wording.
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
I-7a Post-Closure Trust Fund 264 .l45 {a), N/A
264 .151 (a) {1)
A copy of the post-closure trust fund
agreement with the wording required in
264.lSl{a) (l) and a formal certification
of acknowledgement:
D Bank or approval institution
D Mechanics N/A
-pay-in period; life of permit or
remaining life of facilityI whichever
is shorter
-annual payment; unfunded liability
divided by years left in pay-in
period.
I-7b Suret~ Bond 264.l45(b) and { c) ' N/A
264.l51(b) and {c)
A surety bond from a federally acceptable [S/02/86]
surety company meeting one of the
following requirements:
D Surety bond guaranteeing payment into a 264 .145 (bl'
post-closure trust fund. A copy of the 264 .151 {bl
surety bond with the wording required [5/02/B6)
in 264.lSl(bl, a copy of the standby
trust fund agreement.
D Surety bond guaranteeing performance of 264.l45(c), N/A
post-closure activities. A copy of the 264.lSl(c)
surety bond with the wording required
in Part 264.lSl(c), guaranteeing that
the owner/operator will perform post-
closure plan and the requirements of
Subpart H.
I-7c Post-Closure Letter of Credit 264. :l.45 (di ' N/A
264 .151 (di
A copy of post-closure letter of credit
with the wording required in 264.l51(dl;
D I rre·;,rocabl e letter of ere di t
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D At least one year period, automatic N/A
renewal
D Standby trust fund APPENDIX 1-3
D Amount reflects current cost estimate N/A
I-7d Po§t-Closure In~urance 264 .145 (eJ , N/A
264 .151 (el
To demonstrate that the owner/operator has
post-closure insurancer s/he must submit
to the Regional Administrator 60 days
before hazardous waste is received a
certificate of insurance worded as
specified in 264.151(e):
D Noncancellable policy, automatic
renewal
D Insurer licensed or eligible surplus N/A
lines carrier
D Certificate of insurance N/A
I-7d (continued l N/A
D Funds available whenever final post-
closure occurs.
I-7e Financial Test and Co;(J2orate GJ:!erantee for 264 .145 (fl N/A
Post-Closure [5/02/86] '
264.lSl{f)
To demonstrate that this test is met, an 264 .151 (h)
owner/operator must submit a letter signed [11/18/87]
by the company•s chief financial officer
that is worded as specified in 264.151(f)
and meets the following criteria:
D Tangible net worth $10 million
D Tangible net worth 6 x all closure and N/A
post-closure costs
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Comments
D U.S. assets at least 90 percent of N/A
total assets or at least six times all
closure and post-closure costs
D Bond rating requirements or alternative N/A
D Application must include: N/A
-copy of a report on the company 1 s
latest financial statements drafted
by an independent certified public
accountant {CPA)
-copy of a report from the owner 1 s/ N/A
operator,s independent CPA to the
owner/operator stating that s/he has
examined the data in the letter from
the chief financial officer and that
it is consistent with the amounts in
the independently-audited year-end
financial statements for the latest
fiscal year and that no matters came
to attention to cause him to believe
that the data should be adjusted.
I-7e (continued] N/A
In lieu of the above items 1 the owner/ 264 .145 (fl {10)
operator may submit a corporate
guarantee worded as required by
264 .151 (h). This guarantee provides
that the guarantor, which must be the
parent company of the owner/operator,
will perform post-closure activities in
accordance with the post-closure plan
it the owner/operator fails to do so or
will establish a post-closure trust
fund for the owner/operator. A copy of
these items should be submitted with
the Part B for review by the permit
writer.
Subject Requirement
I-7f Combinations
I-7f(l) Use of Multiple Financial Mechanisms
A copy of a combination of trust fund
agreements, surety bond guaranteeing
payment into a post-closure trust
fund or letters of creditr insuranceI
and state assumption of
responsibilityr which provide
financial assurance for the amount of
post-closure~ Combined financial
assurance must be at least equal to
the adjusted post-closure cost
estimate. Financial assurance
instruments must meet requirements of
264. J.43 {a), (b), (d), or (e) which
include post-closure trust fund~
surety bond guaranteeing payment into
a post-closure trust fund, post-
closure letter of credit, and post-
closure insurance_ respectively.
I-7f(2) Use of Financial Mechanism for
Multiple Facilities
A copy of a financial assurance
mechanism for more than one facility
showing for each facility, the EPA ID
number, name1 address, and amount of
closure funds assured by the
mechanism. Total funding must be no
less than the sum required for each
facility considered separately.
Documents must be submitted to each
Region where facilities are located.
Financial test applies to the sum of
closure and post-closure costs for
all facilities.
Closure/Post-Closure and Financial Requirements -Module I
40 CFR
Section Nos.
264.145 lg)
264.145(h)
Location in
Application
N/A
N/A
Comments
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. Application Conunents
I-8 Liabilit~ Rem;iremeuts 270.147 (b) (l7)' N/A
264.147 (al and (b)
Where applicable, a copy of the insurance
policy or other documentation which comprise
compliance with the requirements of 264.147.
(Coverage is for all facilities owned and
operated and applies until certification for
closure and post-closure is completed. For
facilities in Phase I authorized statesr
originally signed duplicates of executed
instruments or certificates of insurance are
not required until the time of permit
issuance1 except as required by state law.)
I-8a Sudden Insuran~e 264.147(a), N/A
264.l47(g),
Hazardous waste treatment, storage1 or 264.lSl(g, i, j)
disposal facilities must demonstrate [5/02/86]
financial responsibility for bodily injury
and property damage to third parties
caused by sudden accidental occurrences. .
D Amount of at least $l million per
occurrence
D An annual total of at least $2 million, N/A
exclusive of legal costs
D A signed duplicate original of the N/A
Hazardous Waste Facility Liability
Endorsement worded as specified in
?????
I-Sa (continued) N/A
D A Certificate of Liability Insurance
worded as specified in 264.lSl(j), or
Closure/Post-Closure and Financial Requirements -Module I
40 CFR Location in
Subject Requirement Section Nos. ~l!i...ppl i cation Comments
D Financial test N/A
-letter from CFO
-auditor report
-auditor opinion
-other information requested by R.A.
-acceptable ratios
-notification to EPA by Attorneys
General or insurance commissioner of
guarantor 1 s state and facility state
that corporate guarantee is legally
valid and enforceable.
D A combination of endorsement of N/A
certification and financial test or a
combination of endorsement or
certification and corporate guarantee.
Amounts of coverage must total at least
the minimum amounts required by
264.147 (a).
I-Sb Nonsudden Insurance 264.147(b) N/A
and {d) '
This applies to high risk storage 264.lSl(i)
facilities (designated by Regional and {j),
Administrator} 1 surface imp0Wldments 1 land 264.147 (f)
disposal and land treatment.
D A least $3 million per occurrence
D An annual total of at least $6 million N/A
is required1 exclusive of legal costs
D Same endorsement or certification N/A
requirements as for sudden insurance
coverage1 or
D Financial test N/A
-letter from CFO (264 .151 (g) I
-auditor•s report
-auditor•s opinion
-other information requested by R.A.
Closure/Post-Closure and Financial Requirements -1'1odule I
40 CFR Location in
Subject Requirement Section Nos. Application comments
D Corporate guarantee 26 4 . 14 7 (b I (2 I N/A
-guarantor must be parent corporation 264 .l47 (g) (2) (i)'
-certified copy of corporate guarantee 264 .1s1 (hl (2 I
with wording as specified in [ll/lB/87]
264 .151 (h) { 2)
-financial test for g-uarantcr
I-8c Variance Procedures and R.A. Adjustments 264.147(c) and (d] N/A
Evaluation of degree and duration of risk
sufficient to allow R.A. to make a
judgment on reduction of required
liability. The financial responsibility
levels specified above for liability
insurance for sudden accidental
occurrences may be adjusted downward if
the owner/operator can prove to the
Regional Administrator that these levels
are not consistent with the degree and
duration of risk at the owner 1 s/operator1 s
facility. Conversely, the Regional
Administrator may adjust the levels of
financial responsibility up or down~ based
on the adrninistrator•s assessment of the
degree and duration of risk associated
with the facility.
I-9 State Financial Mechanism 270 .14 (bl (18) N/A
Where appropriate1 proof of coverage by a
state financial mechanism in compliance with
264.149 or 264.150.
Subject Requirement
1-9a Use of State-Required mechanjsms
Where a state has hazardous waste
regulations with equivalent or greater
liability requirements for financial
assurance for closure and post-closure
care1 evidence of establishment of the
state-required financial mechanisms,
including the facility EPA ID number,
name, address 1 and required mechanism do
not satisfy amount of funds requiredr
funds may be made available through the
state-required mechanisms or by using
additional mechanisms specified in
264.143.
I-9b State Assumption of Responsibility
If a state assumes legal responsibility
for compliance with closure, post-closure 1
or liability requirements or the state
assures that state funds are available to
cover those requirements1 then facility is
in compliance and must include a copy of a
letter from the state describing the state
assumption of responsibility and a letter
from the owner/operator requesting that
the state•s assumption of responsibility
be considered acceptable in meeting the
financial coverage requirements, and
including the facility EPA ID number,
name1 address, and amounts of liability
coverage or funds for closure or post-
closure care that are assured by the
state.
Closure/Post-Closure and Financial Requirements -Module I
40 CFR
Section Nos.
264 .149 (a)
264.149(b)
264.150
N/A
Location in
Application
N/A
Comments
REGULATORY COMPLETENESS CHECKLIST FOR HAZARDOUS WASTE STORAGE, TREATMENT AND DISPOSAL FACILITIES
Facility Name ~C~T""'I ________________ _
Address
Contact Name
Contact Phone Number
EPA I. D. Number ,,N,_,c ... D"0"'4"-6"-""l"4"'8"'5"'4~D'-----------------­
Perrni t Review Team
Date Application Received--------------
Date Review Completed
Other Federal Laws -Module J
II _ , . _ l _ 40 CFR__ I Loc~~ion in I _ II
Subject Requirement Section Nos. Application Comments ..
PART J -OTHER FEDERAL LAWS 270 .14 {b) (20) SECTION J
270.3
Demonstration of compliance with the
requirements of other applicable federal laws
such as the Wild and Scenic Rivers Act, National
Historic Preservation Act of 1966 1 Endangered
Species Act$ Coastal Zone Management Act, Fish
and Wildlife Coordination Act.
REGUr.ATORY COMPLETENESS CHECKLIST FOR HAZARDOUS WASTE STORAGE, TREATMENT AND DISPOSAL FACILITIES
Facility Name .C~T~I~----------------
Address
Contact Name -----------------~ Contact Phone Number
Subject Requirement
PART K -CERTIFICATION
D Certification of application by a principal
executive of the company of at least the
level of vice president.
D Certification by a general partner or
proprietor for a partnership or sole
proprietorship, respectively.
D Certification by a principal executive
officer or ranking elected official for a
municipality1 state1 federal, or other
public agency.
EPA I.D. Number ~N~C~D~0~4~6~1~4~B~5~4~0"-~~~~~~~~~~~~~~~~-
Permit Review Team-------------------
Date Application Received
Date Review Completed
40 CFR Location in
Section Nos. Application
270 .11 SECTION K
Certification -Module K
Comments
- l
REGULATORY COMPLETENESS CHECKLIST FOR HAZARDOUS WASTE STORAGE, TREATMENT AND DISPOSAL FACILITIES
Fae ility Name ~c~T~I~----------------­
Address
Contact Name
Contact Phone Number
EPA I . D. Number NCD04 6148 54 O _________________ _
Permit Review Team
Date Application Recei >;,red
Date Review Completed-----------------
Corrective Action -Module L
~--·---. . I .. 40 CFR Location in
Subject Requirement Section Nos. Application Comments
PART L -INFORMATION REQUIREMENTS FOR SOLID WASTE App_endix L,
MANAGEMENT UNITS Figures
L-1 Descrigtion of Solid Waste Management 27D.14(d) (1)
Units: [ 12 fl/ 8 7]
A description of each solid waste management
unit at the facility including:
D Location of the unit on the topographic map
required under 2 70 .14 (bl ( 19)
D Type of unit Appendix L-2
0General dimensions and structural " "
description (provide drawings if available)
0Dates of operation of the unit " "
0Description of all wastes that have been " "
managed at the unit.
L-2 Information Pertaining to Releases: 270 .14 (d) (2) Lots of deficiencies in
[l2/l/87] SWMU information; See
The applicant must provide all available in-NOTI
formation pertaining to releases of hazardous
wastes or hazardous constituents from solid
waste management units at the facility.
40 CFR Location in
SubjecL Requirement Section Nos. Application Comments
L-3 Samgling and J!mal~sis: 270 .14 (di (3) Lots of deficiencies in
[ 12 /1/8 7] SWMU information; See
The applicant must provide the results of NOTI
sampling and analysis of groundwater, land
surface and subsurface strata1 surface water1
and air which has been conducted
{voluntarily, or) at the request of the
Agency to complete a RCRA Facility
Assessment.
REGUr.ATORY COMPLETENESS CHECKLIST FOR HAZARDOUS WASTE STORAGE, TREATMENT AND DISPOSAL FACILITIES
Facility Name -~C~T~--------------­
Address CHARLOTTE
Contact Name
Contact Phone Number
Subject Requirement
PART M -CLOSURE EQUIVALENCY DETERMINATION
Owners/operators of surface impoundmentsI
landfills land treatment units 1 and waste piles
that received wastes after July 26 1 1982 or
certified closure according to 265.115 after
January 26, 1983 must do one of the following:
D Obtain post-closure permits for those units.
D Demonstrate closure by removal in accordance
with 260.l(c) (5) and ( 6) .
M-1 ClQsure Q::t: Removal
Basic information requirements:
DList of contaminants managed in the closed
unit
D List of cleanup levels for each contaminant
D List of 40 CFR Part 264 acceptable cleanup
levels for each contaminant.
EPA I.D. Number NCD 046 148 540
Permit Review Team -~M~A~~W~I~L~K=I~N~S~----------------
Date Application Received ~2~9~6~------------­
Date Review Completed
Closure Equivalency Determination -Module M
40 CFR Location in
Section Nos. Application Comments
NA
270.l(c)
(12/1/87]
NA
270 .1 (c) (S) NA
[12/1/87]
270 .1 (cl 95)
NA
NA
40 CFR Location in
Subject Requirement Section Nos. Application Comments
M-la Re@i;i;:ement fat: Clos11re Em:i:i valency NA
Determination:
Demonstrate that the closure met the
standards for closure by removal or
decontamination in 264. 228' 264.258, or
264.280(e]:
D If a Part B application for a post-closure
permit has been submitted$ the applicant
may request a determination$ based on
information in the application, that the
264 closure standards were met.
M-la (continued) NA
Or
D If a Part B application for a post-
closure permit has not been submitted,
the owner/operator may petition the R.A.
for a determination that the closure met
the 264 standards and a permit is not
required. The petition must include:
-data demonstrating closure standards NA
were met
Qi;: NA
-data demonstrating that the unit
closed under equally or more stringent
state requirements.
M-lb Denial of Closure E!I1!ivalency 270. l (c) {6) (iii) NA
[l2/l/B7]
If the R.A. determines that closure does
not meet 264 standards$ the owner/operator
must submit a Part B application for a
post-closure permit.
Subject Requirement
Subject Requirement
Note: If an equivalency determination is
requested 1 a very tight regulatory schedule
applies:
1. RA determines with 90 days whether Part 265
closure met 264 closure by removal or
decontamination requirements with 90 days.
2. If the RA finds the Part 265 closure did
not meet Part 264 standards, owner/operator
has 30 days to submit additional supporting
information after receipt of notice.
3. The RA will review additional submittal and
make final determination within 60 days.
M-2 Post-~losure Permit A~glication Reggirements
D Checklist items I-2, I-6, and 1-7, post-
closure requirements
Dchecklist item E, groundwater monitoring
requirements.
40 CFR
Section N"os.
40 CFR
Section Nos.
270 .1 (cl {6) {iii]
[12/1/B7]
Closure Equivalency Determination -Module M
NA
NA
NA
NA
NA
Location in
Application
Location in
Application
Comments
Comments
d. unusual site conditions (for example: damaged well casing, well cover was missing, etc.).
APPENDIX E-3, SECTION 1.0; FIGURE E-3-1
e. the following items should be documented for each well:
1. equipment used for water level and well depth measurements; APPENDIX E-3,
SECTION 1.1
2. depth to the water level below the measuring point; APPENDIX E-3, SECTION 1.1:
must remoye well cap and allow Water level in the well to equilibrate under ambient
atmospheric pressure_
3. depth to the bottom of the well below the measuring point; APPENDIX E-3,
SECTION 1.2
4. elevation of the water level; SHOULD INCLUDE STATEMENT THAT WATER
LEVEL ELEVATIONS WILL BE RECORDED IN LOGBOOK
5. well puirging time and date; APPENDIX E-3. SECTION 1.3; FIGURE E-3-1
6. equipment used for purging; APPENDIX E-3. SECTION 1.3; FIGURE E-3-1
7. amount of water removed during purging; APPENDIX E-3. SECTION l.2;
FIGURE E-3-1
8. sample collection time and date; APPENDIX E-3, SECTION 1.5; FIGURE E-3-1
9. equipment used for sample collection; APPEN E-3. SECTION 1.5: FIGURE E-3-1
10. field measurements; and APPENDIX E-3. SECTION 1.0
J 1. types and number of sample containers filled at each well and any special handling
procedures (i.e. preservation procedures, etc.)_ APPENDIX E-3. SECTION 1.5;
III. Water Lew! Monitoring
The description of the water level monitoring procedure should including the following items:
a. a statement specifying that static water level measurements from all wells are obtained
prior to beginning the well purging procedure at any well (static water level measurements
in this case are those measurements taken after the water in the well has been allowed to
reach equilibrium or more than 24 hours has passed since any water has been removed
from or injected into the well, whichever is greater). APPENDIX E-3. SECTION 1.1
~: if well caps with air/water tight seals are used on the wells then the caps should be
removed and the water level in the well should be allowed to equilibrate with the
ambient atmospheric pressure prior to obtaining the water level measurement. MUST
INCI,UDE STATEMENT IN APPEN. E. SEC. l.1.
b. a description of the equipment used to obtain the water level measurements, and how this
equipment will be decontaminated between each well. APPENDIX E-3, SECTION 1.!;
SECTION 2.1 FOR DECON
2
NQk: It is recommended that probes/tapes be cleaned with:
-phosphate-free soap and water wash
-organic-free water rinse
c. a statement specifying tbat well depths are confirmed ANNUALLY. APPENPIX E-3,
SECTION l.2.
d. a statement specifying that all measurements are accurate to 0.01 feet. APPENDIX E-3,
SECTION LI
e. a statement specifying that tbe water level and well deptb measurements are documented
in tbe field logbook. APPENDIX E-3. SECTIQN 1.2
f. a statement specifying tbat clean protective/nonreactive gloves will be worn at each well
throughout the water level monitoring procedure. APPENDIX E-3, SECTION 1 .0
g. a statement that water level measurements will proceed from the least to the most
contaminated wells based on the most recent historical analytical data. APPENDIX E-3.
SECTION .Lll
IV. Ground Water Sample Collection Procedure
A discussion of tbe well purging and sampling procedure should be included in tbe S&A plan.
The description of the procedures should be as specific as possible and include a description
of: the equipment used at each well; tbe handling procedures for the contaminated water
generated during sample collection; the equipment cleaning procedures; and tbe frequency of
equipment cleaning. Any specialized sample collection procedures should also be specified in
the S&A plan.
a. The description of tbe well purging procedure should specify tbe following items.
l. the equipment used in well purging. APPEN,E-3, SECT, 1.3
2. how the well purging equipment is used. For example: tbe pump intake is maintained
at tbe top of the water column in order to remove all of tbe standing water in the well
casing.APPEN,E-3. SECT. 1.3
3. volume of water to be removed in order to determine that a representative sample has
been obtained. For example: 3-5 weJI volumes are removed; or well is purged to
dryness; APPEN.E-3, SECT. 1.3 , WHAT WILL BE DONE WITH PURGE
WATER?
~: field parameters should be obtained periodically throughout tbe purging
procedure; once the field parameters stabilize, tbe samples can be collected.
4. field measurements are obtained.APPEN.E-3. SECT. 1.3
5. clean protective/nonreactive gloves are worn at each well throughout the well purging
procedure. APPENDIX E-3. SECTION 1 .0
3
N.Qk: lit is recommended that each facility use equipment constructed of stainless
steel and/ or teflon during all phases of the ground water sample collection
procedure. If any facility chooses to use equipment constructed of other
material, the facility must demonstrate through the inclusion of
manufacturer's specifications and field testing that the sampling equipment is
constructed of materials which will not affect the quality of the sample.
b. A description of the well sampling procedure should include the following items.
1. the equipment used in sample collection.
2. how the sample collection equipment is used.INCLUDE A DESCRIPTION OF
HOW WELLS ARE SAMPLED WITH BAILERS
3. the field measurements (pH, specific conductance, temperature, etc.) obtained.
4. the order in which sample containers are filled. IMPROPER ORDER, CORRECT
IN REVISION
5. the type and number of sample containers used. SHOULD INCLUDE USE OF
TEFLON LINED CAPS
6. the sample preservation procedures. IMPROPER PRESERVATION METHODS,
CORRECT IN REVISION
7. the type and number of QA/QC samples.
8. any special sample collection procedures (for example -sample bailers are lowered
into the well slowly in an effort to prevent degassing of the sample). APPENDIX fi:-
3. SECTION 1.0;
9. a statement specifying that clean protective/nonreactive gloves will be worn at each
we!l throughout the sampling procedure.
,l'iQk: It is recommended that each facility use equipment constructed of stainless
steel and/or teflon during all phases of the ground water sample collection
procedure. If any facility chooses to use equipment constructed of other
material, the facility must demonstrate through the inclusion of
manufacturer's specifications and field testing that the sampling equipment is
constructed of materials which wHI not affect the quality of the sample.
c. A list of the equipment used during the ground water sampling event should be included.
Also, the cleaning procedures and frequency of cleaning of the equipment should be
included. It is recommended that the following cleaning procedures be used.
Stainless Steel Equipment
removt: excess soil/ sludge as necessary
phosphate-free soap and hot tap water wash
hot tap water rinse
deionized water rinse
isopropyl alcohol rinse
4
organic-free water rinse [if organic-free water is not available, allow equipment to
fully dry)
air dry
wrap equipment with non-reactive material prior to transport into the field
Teflon or Glass Equipment
remove 1:xcess soil/sludge as necessary
phospha1te-free soap and hot tap water wash
hot tap water rinse
10% nitric acid rinse
deionized water rinse
isopropyl alcohol rinse
organic-free water rinse [if organic-free water is not available, allow equipment to
fully dry]
air dry
wrap equipment with non-reactive material prior to transport into the field
~ Substituting a higher grade water (deionized or organic-free water) for tap water
is acceptable.
d. A list of any specialized sample collection procedures should be included. For example:
voe sampli:s should be collected in a glass bottle with a teflon covered septum top. voe
samples should be collected with no headspace in order to prevent volatilization. Samples
to be analyzed for organic compounds are transferred from the sample collection
equipment directly into the sample containers without filtering.
V. Sample Identification and Shipment
The S&A plan should include a description of the sample containers, an example of a sample
container label, and shipment procedure. The description should include the following items.
a. how the containers are labeled.
b. the items to be included on a sample label, specifically:
1. place of collection;
2. sample identification number;
3. date and time of sample collection;
4. param<:ters requested;
5. type of preservative; and
6. name of sample collector.
c. the procedure used to transport the samples from the she to the laboratory for analyses.
5
d. use of permanent ink so labels remain legible when wet.
VJ. Chain of Cu~
The S&A plan should include a description of the chain of custody procedure and a sample
chain of custody form. The chain of custody form should include the following items.
a. sample and well identification.
b. signature(s) of the sample collector, transporter, and lab person receiving the sample.
c. inclusive dates of sample possesion.
d. date and time of sample collection.
e. number of containers.
f. requested parameters.
g. special requests.
h. laboratory number.
VII. Analytical Methods
The S&A plan must specify an EPA approved analytical method found in EPA publication
SW-846 for each constituent specified in the sample collection schedule.
VIII. Quality Assurance/Quality Control
The S&A plan must describe a QA/QC program that will be used to ensure the reliability of
the data obtained from the ground water samples. The QA/QC program should include the
collection and analysis of trip blanks, field blanks (e.g., equipment rinseate blanks), and
duplicates. It is highly recommended that each facility employ a laboratory certified in
analyzing their site-specific parameters.
IX. Schedule for Sample Reporting
The S&A plan must include a schedule for the collection of ground water samples. The
6
schedule must specify the following items.
a. the dates (specific months during the year) for sample collection. MUST SPECIFY
SCHEDULE
b. the wells to be sampled. SECTION E-8; MUST SPECIFY COMPLIANCE WELLS
c. the parameters to be analyzed. TABLES E-6, E-7
d. the dates (specify the number of days, usually sixty (60), after sample collection) for
submission of the analytical data. NEED TO SPECIFY DATES
GUIDANCE.S&A
7
-::_:.·~~-·-·.'.
PitC'l l l ty Nil•• r·~ '!T[/Jt --fE.· 1~-r-: S j~T.t'
JD: Ho. _ . Ne p . ~~r,, l-'IK ;;?IC
!".X "OSU R r. ! "ron .PUriT 10N R ! PO Rr 11 J.R , :A EOU f:Ril!: HENT C'H IC'IL I S1'
A· Central lntor .. t1on
Nll•b•.r• Jnfollllatlon ~1reaent
A-1. tntor.atlon tn P•rt B Applle•tlo"
A-1• C•••••l d•acrtptlOll of f•ctltty
A-lb Ol••lc•l and pllyatc•l 1n1ly111 of vo•t••
A-le -":Cea• eontrol and •ecurttr
de•crlptlon of •Ctlve portlOll
A•ld Gonerli tnopectlon 1cl>1duh &Rd procedur ..
A•le f"r-e-partdnea1 and pr-•••ntton docu"n.tatlan
A·I! Contingency plan
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--------··----· ·---
.RECORD OF COMMUNICATIO.
TO: File
FROM: Mark Wilkins
SUBJECT: CTI
DATE/flME: 10/31/95 8:45
_X_Plione Call _Discussion _Flt!ld Trip _Conference _Other (Specify)
SUMMARY OF COMMUNICATION:
I talked with Bill Hocutt of the Solid Waste Section concerning disposal of waste with hazardous
constituents into solid waste landfills. Bill said that as long as the soil to be disposed of was not a
hazardous waste (ie a representative sample passed TCLP) then it was up to the landfill to determine
whether or not they would accept the waste. I let Bill see a copy of the soil analysis report from
confirmatory sampling at SWMU 10. I pointed out that most of the contaminants in the soil would not be
detected in a TCLP test. He stated that I should call the landfill and make sure they are aware of the
previous sampling and that there are some constituents in the soil that will not show up on TCLP.
I called the CMS (formerly BFI) landfill in Charlotte to discuss the disposal of soil from CTl's SWMU 10.
I asked the facility if they were aware of the previous sampling results. Cindy Poll of CMS landfill stated
that they had received a copy of the confirmatory sampling results. She stated that she had asked CTI
to perform a TCLP analysis of the soil scheduled for excavation. Based on these results, CMS would
deny or accept the soil. I told Cindy that most of the semi-volatile constituents detected in the soil
would not show up in the TCLP. Cindy said that CMS was not that concerned with these constituents. I
then informed Cindy that many of these constituents were listed in Appendix VIII of RCRA and were
considered hazardous constituents_ Cindy asked "Does this mean they are hazardous wastes?" I told
her that by definition, the col'lstituents were not a hazardous waste, but were 'hazardous constituents'.
Cindy then stated that she would do more research into the nature of these constituents and would let
me know of CMS landfill's decision whether to accept soil from SWMU 10 at CTI.
re: Sharron Rogers
Jill Burton
Surabhi Shah
Mark Wilkins
I
I
I
I
I
I
I
I-
I ~ I
a
~
I
·'
'i'ablll 6 Laboridory Ad•._l Rtlutt81 SWMtJ 10 (Ab~ndQlllil Concrete· Llned
BllHn) -Cl\iilttd'ffhn~pbrl Fttcllltt1 Cbttrlottl\, North cW:itlritt, Aprll 1995.
Pantnteters
Compoultds Detected
Volntile Orgnnics (µ.g/kg)
Methylene Chloride
Acetone
2-Butanone
4-Methyl-2-Pentanone
Toluene
Ethylbem:ene
Xylene (total)
Semfrolatile Organics (µ.g/kg)
bis(2-Ethylhexyl) Phthalate
Phenol
4-Methylphenol
2-Methynaphthalehe
01-ti-OCtyl Fhthalate
Butyl Benzyt Phthalate
Naphthalene
Ftuotene
Phenanthrene
01-n-Butyl Phthalate
ktRA. Metals (mg/kg)
At~enit
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
µg/l<g micrograms per kilogram
mg/kg mflllgrnllis per kitogronl
:Borldl ID No.
(Depth)
HA~s
(8.0--8.5)
200B
36013
89
321
19J
311
170
1,800,000E
37,000
27,000J
7,8001
76,000
150,000
4,4001"
2,4001
3,4001
43,000
<0.72
35.SB
1.8
189
67.7
<0.23
4.6
<0.11
RCRA Retourct Collsen•atloll 1111d Ruovey Act » tdiitpo!ll!d dttecttd Iii rftt 1m&:laled method blank -for vol atilt and sen1/vofatile organics » 111it11ytt tollctllirntloll tipatltd tk kH tlmll rftl CRQL ·for .RCRA ltttMT.t
J contpollnd t-tpoHtd al 1111 tstilllllttd Vdlu~ fbJ t1idn tlil CltQL but gre11ter tholi zero
'
1 tftlt !dntpft wa.t rer1111 drJ~ Id Ii low fllleHillT ttalldahl recavtry. TM redlllllysis btd/c111ed tht prestnct of
ddditlonat compowufs (su Apptl!dlx C) ·
E ccuds lnsfrtlnttnt calibratloll 1-angt
Dqith In fed below ground Sllrface
AqiMinrll Job NrJ. 5203000
Rrport No. 521JO
'"""''"-.......... -·1
.. ..: ' .~ ,..
I
.)
State of North c&lina Department of Environment,
Health ond Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
Mr. Glen SimJPson
Ceritral Trans]port, Inc.
Post Office Box 7007
High Point, North Carolina 27263-7007
October 24, 1995
Reference: Notification ofVoluntary
Corrective Action at SWMU 10
EPA ID# NCD 046 148 540
Dear Mr. Simpson:
• • .AVA ®
DEHNR
The North Carolina Hazardous Waste Section (Section) has received the notification Jetter from
Central Transport, Inc. (CTI) concerning the upcoming voluntary corrective action for SWMU
10. The Section has the following comments:
I) All sampling, analytical, decontamination, etc. procedures used should be well
documented. This voluntary woik will be reviewed at a later time to meet part of
CTI's corrective action requirements.
2) CTI should be consistent with methods described in the EPA Standard Operating
Procedures Manual (SOP) when performing sampling, decontamination, etc. The
SOP is available from EPA. You can call the EPA Environmental Services
Division at [phone] or fax them the request at [phone].
3) CTI should request the laboratory perform analyses per methods in SW-846 Final
Update II.
4) When performing confirmatory sampling to delineate contamination, it should be
noted that Subpart S action levels have not been approved and can not be used as
deanup goals. Section policy requires cleanup of metals to background levels.
Remediation to MCL or PQL (where MCL's do not exist) is required for organic
<:onstituents. CTI may request a risk based dean up standard in lieu of clean up to
PQLs or MCLs. A risk assessment must be approved by the state toxicologist.
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equol Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
• •
5) Penwnnel should use adequate handling and short tenn storage procedures and
equipment decontamination procedures when handling contaminated media to
prevent the release of hazardous constituents and the possible creation of
additional SWMUs. These procedures should be documented for CTI's field staff
to r1eview prior to beginning work, and for future review by the Section
6) CTI should perform Appendix IX analysis on a sample of the contaminated soil to
completely characterize the hazardous constituents in SWMU 10. Analysis of
co1111irmatory samples should include those constituents detected in the Appendix
IX sample.
7) The Section encourages the voluntary remediation efforts proposed by CTI. The
Secl:ion is available for guidance discussions, meetings, and other support functions
during the voluntary phase of the clean up process
If you have any qut1Stions concerning this or other issues, please contact Mark Wilkins of my staff
at [phone], Ext. 297.
Sincerely,
~~Ft~~
Sharron E. Rogers, Heiiif
Remediation Branch
Hazardous Waste Section
cc: John Johnstmi, EPA Region IV
Robin Hedden
Mark Wilkins
re: Sharron Rogers~
Jill BurtOil"Ji~
Surabhi Shahw.£
• •
September l4, l995
Mr. Mark Wilkins
Hazardous W;3.ste Section
P. O. Box 27687
Raleigh, NC 2761l-7687
Re: Confirmatory Soil Assessment
SWMU's #5, 7, 9, 10, 22, 23, 24, 27
Central Transport, Inc.
EPA ID No. 046 148 540
Dear Mr. Wilkins,
hl-£: p
Uf'l r£.ftt ~sfl/P r
flc.J) O!.fb 1'1'6~'10
A copy of the Soil Assessment Report prepared by AquaTerra was sent
by Federal Express to your office for delivery on Thursday,
September 14, 1995, so that you would have an opportunity to
evaluate the report prior to our meeting, if you wished to. One of
our objectives of the meeting is to discuss the incorporation of
the RFA Report into the Part B Permit Application.
Thanks for all your help in arranging the meeting on short notice
and we look forward to seeing you on Monday, September 18th.
Sincerely,
<J·lrh-·-·-.5;-77~-~
Glen Simpson
Environmental Director
GS/PS
2829 Uwharrie Road. Archdale, NC 27263 •Mailing Address: P.O. Box 7007 •High Point, NC 27264
910/431-9186 • fAXo 910/431-0048
• •
The original and seven (7) copies of the Application must be
submitted to the North Carolina Hazardous Waste Section (Section)
at the following mailing address:
Mr. James A. Carter, Chief
Hazardous Waste Section
Post Office Box 27687
Raleigh, North Carolina 27611-7687
Alternatively, the Application may be delivered to the following
location:
Division of Solid Waste Management
401 Oberlin Road, Suite 150
Raleigh, North Carolina 27605
Attention: Mr. James A. Carter
In accordance with 40 CFR 2 as incorporated by 15A NCAC 13A
.0004, you may claim confidentiality for certain information in
your Part B Application if such claim can be substantiated. In
order to claim that information is confidential you should:
1. Determine whether or not the claim of confidentiality
can be substantiated, then substantiate Lt (concerning
each type of information claimed) by addressing the
applicable element of 40 CFR 2.208 as incorporated by
15A NCAC 13A .0004;
2. Precisely describe which information is claimed as
confidential or stamp each page that contains such
information with the words "CONFIDENTIAL" or
"CONFIDENTIAL BUSINESS INFORMATION";
3. Package all pages containing confidential information
separately from your total Part B Application package.
This means that your Part B submittal will consist of
two packages: (a) the Part B Application without
confidential information, and (b) the portion of your
Part B Application that has been claimed as
confidential; and
4. State clearly in your transmittal letter that
confidential information is included.
•
Mr. Mark Wilkins
Hazardous Waste Section
NC DEHNR
P. 0. Box 27687
Raleigh, NC 27611
May 10, 1995
Re: central Transport: NCD 046148540
Voluntary RFA Sampling
Dear Mr. Wilkins,
•
The purpose of this correspondence is to advise you that Central
Transport is undertaking the voluntary confirmatory sampling of the
following SWMU's at its facility in Charlotte: 5, 7, 9, 10, 22, 23,
24, and 27.
The soil sampling conducted by AquaTerra was performed during the
week of April 24 -28, and Central is waiting for the analytical
results.
In the development of the work plan, AquaTerra confirmed to
Central, that the work performed would be in accordance with the
Confirmatory Sampling Work Plan Guidance document provided by your
office.
Upon receipt of the sampling report from AquaTerra, which is
expected within 3-4 weeks, we will share the results with the
Hazardous Waste section.
If you have any questions, please call me at 910-431-9186.
Sincerely,
-•' / --·· .(I ?-c---· s-· •. ""~. -·· / '/" -·V--D·~
Glen Simpson
Envi.ronmental Director
GS/PS
2829 Uwharrie Road• Archdale, NC 27263 •Mailing Address: P.O. Box 7007 •High Point, NC 27264
910/431-9186 •FAX: [phone]
1
• •
RCRA PRIORITIZATION SYSTEM SCORING SUMMARY
FOR
CENTRAL TRANSPORT INC.
EPA SITE NUMBER: NCO 046 148 540
CHARLOTTE, NC
SCORED BY: WILKINS/OLSZEWSKI
OF NC HAZ, WASTE SECTON
ON 04/11/95
GROUNDWATER SCORE
SURFACE WATER SCORE:
AIR ROUTE SCORE
ONSITE SCORE
MIGRATION SCORE
35.65
36.42
21. 63
28.57
31.15
•
WS-1 GROUNDWATER ROUTE
IS THERE AN OBSERVED RELEASE? Y
ROUTE CHARACTERISTICS
DEPTH TO AQUIFER (FT.) NA
NET PRECIPITATION (IN.) NA
PHYSICAL STATE: NA
CONTAINMENT:
WASTE CHARACTERISTICS
EPA ID NO. : NCD 046 148 540
CENT~RANSPORT INC .
CHEMICAL NAME OR WASTE CODE NUMBER: VINYL CHLORIDE
TOXICITY/PERSISTANCE VALUE: 15
QUANTITY KNOWN? NO
CUBIC YARDS OR TONS: 0
DRUMS 0
AMOUNT IS LIKELY TO BE LARGE
TARGETS
GROUNDWATER USE: QUALITY IMPACTED
DISTANCE TO WELL (MILES): 0.4
•
ws-2 SURFACE WATER ROUTE
RELEASES
IS THERE AN OBSERVED RELEASE? N
IS THERE A PE!'MITTED OUTFALL? N
EPA ID NO. : NCD 046 148 540
CENT~RANSPORT INC .
HAVE THERE BEEN PE!'MIT VIOLATIONS? Y
ROUTE CHARACTERISTICS
FACILITY LOCATION: OTHER
24-HOUR RAINFALL: 3.1
DISTANCE TO SURFACE WATER (MILES): 0.20
PHYSICAL STATE: LIQUID, GAS, SLUDGE
CONTAINMENT: FAIR
WASTE CHARACTERISTICS
CHEMICAL NAME OR WASTE CODE NUMBER: DI-N-BUTYLPHTHLATE
TOXICITY/PERSISTANCE VALUE: 18
QUANTITY KNOWN? NO
CUBIC YARDS OR TONS: 0
DRUMS 0
AMOUNT IS LIKELY TO BE SMALL
TARGETS
SURFACE WATER USE: POSSIBLE DRINKING WATER OR RECREATION
DISTANCE TO INTAKE OR CONTACT POINT (MILES): 0.4
DISTANCE TO SENSITIVE ENVIRONMENT (MILES): 1.5
• EPA ID NO. : NCD 046 148 540
CENT~RANSPORT INC .
WS-3 AIR ROUTE
RELEASES
IS THERE AN OBSERVED, UNPERMITTED, ON-GOING RELEASE? N
DOES THE FACILITY HAVE AN AIR OPERATING PERMIT(S)? N
HAVE THERE BEEN ANY PERMIT VIOLATIONS OR ODOR COMPLAINTS BY RESIDENTS? Y
CAN CONTAMINANTS MIGRATE INTO AIR? Y
CONTAINMENT: POOR
WASTE CHARACTERISTICS
CHEMICAL NAME OR WASTE CODE NUMBER: VINYL CHLORIDE
TOXICITY/PERSISTANCE VALUE: 3
QUANTITY KNOWN? NO
CUBIC YARDS OR TONS: 0
DRUMS 0
AMOUNT IS LIKELY TO BE SMALL
TARGETS
POPULATION: RESIDENCES ARE LOCATED WITHIN FOUR MILES
DISTANCE TO SENSITIVE ENVIRONMENT (MILES): 1.5
'·
•
ws-4 ON SITE CONTAMINATION
ACCESS TO SITE: LIMITED ACCESS
EPA lD NO. : NCD 046 148 540 CENT~RA.NSPORT !NC .
IS THERE AN OBSERVED SURFACE SOIL CONTAMINATION? Y
CONTAINMENT: FAIR
WASTE CHARA.CTERISTICS
CHEMICAL NAME OR WASTE CODE NUMBER: DI-N-BUTYLPHTHLATE
TOXICITY/PERSISTANCE VALUE: 3
TARGETS
DISTANCE TO RESIDENTIAL AREAS (MILES): 0.40
IS THERE AN ON-SITE SENSITIVE ENVIRONMENT: N
Mr. Glen Simpson
January 23, 1995
Page 2
• •
area and in the former location of the wash water
sump. Resubmitting existing data is not necessary
at this time. The Permit will contain guidelines ,
and schedules for performing confirmatory sampling.
CTI may proceed with "voluntary" sampling or
corrective action at any time recognizing the
conditions stated in Item 2 above.
5. SWMUs 6 and 17. At this time, no further action is
required at these units.
6. SWMU 2. Confirmatory sampling will be necessary at
this unit as a sediment sample taken from the bottom
of the pond revealed the presence of hazardous
constituents.
7. SWMU 16. Confirmatory sampling will be necessary at
this SWMU. As discussed in our phone conversation
of January 18, sampling around the permeter of the
wash building, and under any internal areas of the
building will be necessary to determine the nature
of a release, if any. A confirmatory sampling plan
will be developed to satisfy conditions of the Post-
Closure Permit. Alternatively, CTI could conduct
"voluntary" sampling and/or corrective action at
this unit prior to permit issuance under the
conditions in Item 2 above.
8. SWMU 22. A CSWG is enclosed ta assist the planning
of any sampling at this unit.
9. SWMU 14. As discussed in our phone conversation of
January 18, no further action will be required at
this SWMU at this time.
10. SWMUs 8, 12, and 13. As discussed in our phone
conversation of January 18, confirmatory sampling is
necessary to determine the nature of a release, if
any, from these units. Confirmatory sampling will
be addressed as a condition of the Permit. CTI may
perform "voluntary" corrective action prior to
Permit issuance with the conditions listed in Item 2
above.
•
Mr. Glen Simpson
January 23, 1995
Page 3
•
If you have any questions concerning this document or the
Permit process, please contact Mark Wilkins at [phone].
Sincerel~ ~~ ~ H. Rhodes, Chie~
Hazardous Waste Section
JHR/MAW/4.wpS{l-3)
cc: William F. Hamner
James A. Carter
Keith Masters, Asheville Regional Office
Mark A. Wilkins
•
William F. Hamner, Ph.D.
January 4, 1995
Page -2-
•
wholly owned by Gary Honbarrier and his sister, Linda Honbarrier Embler. Both Gary
Honbarrier and Linda Embler own 12 percent of CTI. However, 51 percent of CTI is owned
by Archie Honbarrier, who owns none of CENCO. The two entities have always operated on
an arms length basis. Central Transport has never owned, or leased any part of the railsiding.
We are pleased that you understand the potential significance of the lack of common ownership,
which is clearly recognized in RCRA and guidance documents issued pursuant to RCRA. We
would also reiterate that the "environmental violations" which Mecklenberg County has noted
for these areas are predominantly odor-related, and there is no indication of any continuing
problem in this regard. To the extent there were accidental spills from product storage areas,
we believe a SWMU designation is inappropriate.
3. SWMU's 5, 7, 9, JO, and 27. We appreciate and agree with your proposal for
confirmatory sampling. We are prepared to begin this immediately, and would like to discuss
that possibility with you as soon as possible.
4. SWMU's 1, 3, and 4. We are prepared to resubmit all existing data, including
stream sampling, surface water sampling, groundwater sampling, and soil sampling, to the
Department, and are satisfied to the extent this will be all that is necessary. However, we
continue to object to any redundant requirement that we repeat work undertaken in conjunction
with the lagoon closure and post-closure obligations. We thought the question of a down
gradient release was addressed in the Groundwater Assessment Phase and post-closure
monitoring addresses potential releases. Perhaps we could resubmit the data at this time in order
to ascertain whether the Department believes that the questions raised have been addressed.
5. SWMU's 2, 6, 16, and 17. We concur with the conclusion that no further action
is necessary. The possibility of confirmatory sampling is particularly troublesome in connection
with SWMU 16 because a drill rig cannot be put in a location to conduct such sampling.
Therefore, we request further discussion of this matter.
6. SWMU 22. We concur with confirmatory sampling at this location, and are
prepared to begin this work as soon as possible.
7. SWMU's 8, 12, 13, and 14. We do not believe confirmatory sampling should
be necessary at SWMU 8, SWMU 12, and SWMU 14 due to the lack of evidence of a release.
The possibility of overflows during storms has not been substantiated. SWMU 14, which was
originally designed as a weir box for wastewater discharge to the sewer, presently houses the
wastewater meter for measurement of wastewater flow prior to sewer discharge. SWMU 14
does not store wastewater. The treated wastewater flowed through the meter, across tl1e weir
box, and out the 6-inch PVC pipe to the sewer as shown in Photo #15 in the RFA Report. Since
the photo was taken on August 4, 1993, Central Transport has modified the wastewater meter
and piping configuration in the weir box, such that wastewater no longer comes in contact with
the weir box. Because the connection of the weir box to the sewer is continuously open, and
Mr. Glen Si.mpson
November 17, 1994
Page 2
• •
the EPA. Confirmatory sampli.ng underneath and on the peri.meter
of the truck wash area will be necessary to assess possible
releases.
6. The section agrees to a change in status from RFI required to
confirmatory sampling for SWMU 22 as requested by CTI pending
concurrence from the EP.A.
7. SWMUs 8, 12, 13, and 14 -sWMUs 8 and 12 should be sampled for
releases from possible overflows during storms. These SWMUs
are also a concern due to possible releases to the atmosphere.
The area at SWMU 13 should be assessed to determine the
possibility of buried drums/wastes here. The Section agrees
that there is insufficient evidence to support or deny a
release but there is sufficient evidence that a SWMU area
existed. The nature of this SWMU (i.e., alleged buried drums
and waste) suggests a probability of environmental release and
should be investigated. SWMU 14 should be i.nvestigated to
determine releases due to basin overflows during rainfall
events and for releases to the atmosphere.
If you have any questions concerning this or other issues, please contact
Mark Wilkins Of the Section at [phone].
Sincerely, ~?£~
Permitting Branch
Hazardous Waste section
WF!l/MAW/66.wp4
cc: James A. carter
Robi.n lledden
Mark A. Wilkins
Mr. Mark Wilkins
September 6, 1994
Page -2-
5,7,9,10,27*
• •
These overlapping SWMU' s occur in an area
approximately SO feet wide and 100 feet long
(Figure 3). Central Transport, Inc. believes
the most practical approach given the small
area under consideration, is to simultaneously
investigate these overlapping SWMU' s by
conducting confirmatory sampling in this area
rather than attempt to investigate each SWMU
individually. Samples will be taken
specifically in the area of SWMU 27.
*SWMU #27 is shown as #28 on Figure 3.
1,3,4
2,6,16,17
22,23,24
8,12,13,14
The lagoon remediation including confirmatory
soil sampling, and post-closure obligations
preclude the need for additional
investigations of SWMU #1. SWMU #3 and #4 are
located within the SWMU #1 boundary and were
addressed by the lagoon remediation. Central
Transport, Inc. will resubmit the results of
the confirmatory soil sampling and risk
assessment for these SWMU's.
Central Transport, Inc. proposes to submit
existing data from previous sampling efforts
in lieu of conducting additional sampling.
Based on the evidence that some operations
were performed in the area of these SWMU' s,
Central Transport, Inc. plans to conduct
confirmatory sampling of these SWMU's. SWMU
22 will be sampled separately. Due to the
physical proximity of the SWMU's, Central
Transport, Inc. believes that simultaneous
sampling of the three SWMU's is a practical
alternative to generating information rapidly
for all three SWMU's.
Central Transport, Inc. believes that there is
insufficient evidence of a release from these
SWMU's to justify any type of investigation.
The RFA Report does not describe any releases
from these SWMU' s. Central Transport, Inc.
proposes to take no further action regarding
these SWMU's.
We welcome the opportunity to discuss our response to the RFA
Report with you and we are willing to meet with you at your
convenience if you feel a meeting would be helpful.
Mr. Mark Wilkins
September 6, 1994
Page -3-
• •
If you have any questions, please call me at 910-431-9186.
Sincerely,
c{A~~ cF:~r-___-
Glen Simpson
Environmental Director
GS/PS
Attachments
cc: Marc Fleischaker
Table 1, Proposed activity by Central Transport for S'WMU's from RFA Report.
SWMU No. Unit Name Action Proposed Response
Required
smru 1 Closed L-agc-on RFI Post closure obligatione; preclude RFI.
#1 and #2 Conf. soil sampling I Ri:e k As a.es sment
resubmitted _
SWMU 2 Pond #3 RFI Submit existing sediment and surface
water data from Pond #J-
SWMU ) True k Wash Rack {abandoned} Confirmatory sampling Sluiceways within boundary of closed
lagoons. Submit sidewall soil data.
SWMU ' Truck Wash Rack Collection Sump Confirmatory sampling Sump location within boundary of c1oeed
lagoons. • SWMU 5 Sewer Line (Excavated} from Confirmatory aampling See # 10.
boiler room to wastewater Trough
SWMU 6 Lagoon Sludge Stabilization Confirmatory sampling Submit data from soil sampling by
{Treatment) Area Westinghoua.e.
SWMU 7 Abandoned Concrete Trough Confirmatory sampling See #10.
SWMU • Concrete Wastewater Trough Confirmatory sampling C'TI does. not propose to investigate these
area& based on a lack of evidence regard-
ing any releaa.es.
SWMU 9 Exiating Sanitary Sewer Confirmatory sampling See #10.
SWMU 10 Concrete Block Lined Basin Confirmatory sampling The physical proximity of #5, 7, 9, 10, &
{Unknown Use} 27 preclude need for separate aampling.
C'TI will conduct conf. sampling to address
this area.
SWMU 11 Waa.tewater Storage Tanks No Further Action -
SWMU 12 Rineewater Collection Sump RFI See #8.
SWMU lJ Waa.tewater Treatment Building RFI See #8. • SWMU 14 Treatment Plant/Sludge Confirmatory sampling See #8.
Drying Bed Drain
Co.llection Area
SWMU 15 Solids/Sludge Drying Beds No Further Action -
sm.m 16 Truck Wash Area Confirmatory sampling Submit soil sample reeults collected during
UST cl oeure _
sw.r.m 11 lOrOOa Gallon Underground Fuel Confirmatory sampling Submit eoil sample results from UST Closure.
Storage Tank (Removed)
Unit Name Action Required Proposed Response
S'ri-"MU Ne.
S'WMU 18 Underground Oil Storage Tanks No Further Action -
(Removed)
S"i'i"MU 19 Fuel and Oil Storage Tanks No Further Action -
S'f'l"MU 20 Parts Washer No Further Action
S'"'"MU 21 Rail Car Unloading Area RFI The railsiding and storage tanks are not on
property owned or operated by CTI. There is no
evidence of systematic releases, and err
therefore proposes no further action.
SV.'J.'IU 22 Unlined trenches (Filled} (CENCO) RFI Due to the physical proximity of #22, 23, and
24, CTI will conduct Con£. sampling of theae • areas.
SWMU 23 Drum Storage Area (CENCO) Con£irmatory sampling See # 22.
SWlifU 24 Fi1led in Gulley Area (CENCO) Confirmatory sampling See # 22.
.S'WMU 25 Product Storage Area (CENCO) RPI See # .21 ..
SWMU 26 Rail Car Unloading Area (CENCO) RPI See # 21 ..
SWMU 27 Wastewater Treatment P1ant (Removed) RFI See # 10-
SWMU 28 Underground S torq.ge Tank No Further A~tion -
•
GS/PS (8-.9-9'4)