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DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE, CHAPTER 173-303 WAC

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PART I: COVER INFORMATION

This part of the checklist/questionnaire is applicable to all persons who handle

dangerous waste. This cover information includes a review of the Notification Form and

confirmation of other general information necessary to maintain accurate files and

records.

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1. INSPECTOR INFORMATION

WDOE Inspector:

Inspector's Signature:

Office (circle one): NW

Date of THIS Inspection:

Date of LAST Inspection:

Other Inspectors Present:

SW C E IND

Phone II:

Name: _________ Agency: Phone #:

2. BUSINESS INFORMATION

Business Name

Address:

______________ EPA/State ID II:

Zip Code: County:

Business Location (If:

Other Than Address)

Contact Person: Phone If:
\........... .

Business Representatives Present During Inspection:

Name:

3. NOTIFICATION FORM REVIEW

Notification Form Filed: Yes

Notification Form Revisions: Yes

Title:

No

No

Date:

Date:

Date:

Date:

Phone 1/:

Is the information provided in the

most recent Notification Form still

accurate? (rf not, note any deficiencies in Comments, below.)

Comments:

4. ADDITIONAL INSPECTION INFORMATION

Time Inspector Entered Site:

Left Site:

Yes

No

Were photographs taken during the inspection? Yes

No

If yes, how many?

(Note: A brief description of the pictures should be prepared and included

inthe inspection r epo r t . )

Were any problems encountered regarding:

Permission to enter the site:

Permission to have access to any areas on the site:

Permission to have access to any records:

Other:

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-. .

Were samples taken during the inspection? Yes

No

If yes, where and of what were samples taken:

Were samples split with the owner/operator? Yes

No

Were chain of custody procedures follows? Yes

No

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DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE, CHAPTER 173-303 WAC

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PART III: TRANSPORTERS

This part of the checklist/questionnaire is applicable to any person who transports

dangerous waste from a generator to a TSD facility. This part of the checklist/

questionnaire does not apply to persons who only transport dangerous waste on-site, as

defined in WAC -040(59). If a transporter is also a generator and/or TSD facility owner/

operator, then other applicable parts o f this checklist/questionnaire must also be

completed.

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

Transporter Name

Inspector's Name

EPA/State IDlt

Date

Has this transporter transported dangerous waste since the last

time he was inspected (or since he was determined to be a transporter, if this is his first- inspection)? (If no, explain the

evidence on which this determination is based under Comments

below, and do not complete the remainder of this part of the

checklist/questionnaire.)

Comments

Yes

No

1. APPLICABILITY OF GENERATOR OR FACILITY REQUIREMENTS

A. If the answer to either of the following questions is "Yes,"

then the tr.ansporter is also subject to the requi~ements

for generators (WAC -240(3)).

~oe~ the transporter ever:

a. Transport dangerous waste into Washington State from

another country?

b. Mix dangerous waste of different U.S. Department of

Transportation shipping descriptions by mixing them

into a single container?

B. A transporter may keep shipments of dangerous waste for

brief periods (generally ten days or less) under certain

conditions. If the answer to any of the following

conditions is "No," then the transporter is subject to

all applicable TSD facility requirements (WAC -240(5)).

Yes No
2.

Does the transporter only keep shipments of dangerous

waste:

a. Which are manifested?

b. Which are packaged, labeled, and marked by the

generator in accordance with WAC -190(1), (2),

and (3)?

c. For ten days or less?

Comments

_._--,----------------

MANIFESTS

A. Does this transporter ever transport moderate risk waste

(MRW) using an alternative manifest mechanism, approved by

WDOE, as provided in WAC -170(2)(b)(i)?

If yes, is he complying with the terms and conditions of

the alternative manifest for such MRW (WAC -240(2))?

(If not, describe under Comments, below, which aspects of

the alternative manifest system are being violated.)

B. Does the transporter ever accept dangerous waste from a

generator that is not accompanied by a manifest prepared

and signed by the generator in accordance with WAC -180

(WAC -250(1))?

C. Does the transporter deliver the entire quantity of

dangerous waste accepted from a generator or t r ans po r t e r

to either: the designated facility listed on the manifest; the alternate facility, if the dangerous waste

cannot be delivered to the first facility because an

emergency prevents'delivery; the next designated transporter; or, the place outside the United States

designated by the generator (WAC -250(5))?

If dangerous waste cannot be delivered to one of the

places described above, does the transporter contact

the generator for further directions, and revise the

manifest according to the generator's directions'

(WAC -250(6))?

Yes No

D. Complete the following questions.

answered "Yes," complete the items

H.) below which correspond to each

For each question

(E., F., G., and/or

"Yes" answer.

a. Does this transporter ever transport dangerous

waste over public roads? If "Yes," complete

item E., below.

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b. Does this transporter ever transport dangerous

waste by water (bulk shipments)? If "Yes,"

complete item F., below.

c. Does this transporter ever transport dangerous waste

by rail? If "Yes," complete item G., below.

d. Does this transporter ever transport dangerous waste

out of the United States? If "Yes," complete

item H., below.

~. Transportation by road.

a. Does the transporter keep copies of manifests for

at least three years after the date the initial

transporter accepted waste for transport (WAC

-260(1))?

b. Before transporting a dangerous waste, does the

transporter sign and date the manifest and return

a signed copy to the generator before beginning

transport (WAC -250(2))?

c. Does the transporter ensure that the manifest

accompanies the shipment (WAC -250(3))?

d. When delivering the shipment to another transporter

or the designated facility, does the transporter:

i. Obtain the date of delivery and the handwritten signature on the manifest of the

next transporter or facility owner/operator

(WAC -250(4)(a))?

ii. Retain a copy of the manifest for his records

(WAC -250(4)(b))?

Ill. Give the remaining manifest copies to the

next transporter or facility owner/operator.

(WAC -250(4)(c))?

e. Before accepting dangerous waste from a rail

transporter, does the (nonrail) transporter sign

and date the manifest and provide a copy to the

rail transporter (WAC -250(8)(e))?

F. Transportation by water (bulk shipment).

a. Does the water transporter keep for at least three

years after the date waste was accepted by the

initial transporter copies of shipping papers for

all wastes which he transported by water (WAC

-260(2)(a))?

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b. When receiving dangerous waste from a generator,

does the water transporter sign and date the manifest and return a signed copy to the generator

before beginning transport (WAC -250(2»?

c. Does the water transporter perform all of the

following actions'(if not, then he must instead

perform the actions specified under d. of this

item F.):

i. Is the dangerous waste delivered by water to

the designated facility (WAC -250(7)(a»?

ii. Does a shipping paper containing all information required on a manifest, except EPA/

State ID #'s, generator certification and

signatures, accompany the waste shipment

(WAC -250(7)(b»?

iii. Does the delivering transporter obtain the

date of delivery and facility owner/operator's

handwritten signature on either the manifest

or shipping paper (WAC -250(7)(c»?

iv. Does the person delivering the waste to the

initial water transporter obtain the date

of delivery and signature of the water

transporter on the manifest and forward it to

the designated facility (WAC -250 (7)(d»?

v. Does each water transporter keep a copy of

the manifest or shipping papers for his

records (WAC -250 (7)(e»?

d. If the water transporter does not perform the

actions specified in c., above, does he instead:

i. Ensure that the manifest accompanies the

waste shipment (WAC -250(3»?

ii. When delivering the shipment to another

transporter or the designated facility:

1. Obtain the date of delivery and the

handwritten signature on the manifest

of the next transporter or facility

owner/operator (WAC -250(4)(a»?

2. Retain a copy of the manifest for his

records (WAC -250(4)(b».

3. Give the rema1n1ng manifest copies to

the next transporter or facility owner/

operator (WAC -250(4)(c»?

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iii. Before accepting dangerous waste from a rail

transporter, sign and date the manifest and

provide a copy to the rail transporter

(WAC -250(8)(e))?

G. Transportation by r aiL,

a. Does the rail transporter keep for at least three

years after the date waste was accepted by the

initial transporter copies of shipping papers

for all wastes which he transported by rail

(WAC -260(2)(a))?

b. Whenever he is the initial rail transporter, does

he keep copies of the manifests and shipping papers

for at least three years after the date the waste

was accepted by the initial transporter (WAC -206

(2)(b)(i))?

c. Whenever he is the final rail transporter, does he

keep a copy of the signed manifest (or shipping

paper if signed by the designated facility in lieu

of the manifest) for at least three years after the

date the waste was accepted by the initial transporter (WAC -260(2)(b)(ii))?

d. When receiving dangerous waste from a generator,

does the rail transporter sign and date the manifest and return a signed copy to the generator

before beginning transport (WAC -250(2))?

e. As the initial rail transporter accepting dangerous

waste from a nonrail transporter, does the rail

transporter:

i. Sign and date the manifest and return a

signed copy of the manifest to the nonrail

transporter (WAC -~50(8)(a)(i) and (ii))?

ii. Retain one copy of the manifest and rail

shipping paper for his records (WAC -250

(8)(a)(iv))?

iii. Forward at least three copies of the manifest

to either: the next nonrail transporter,

if any; the designated facility, if the shipment is delivered to the facility by rail; or,

the last rail transporter designated to handle

the waste in the United States (WAC -250(8)

(a)(iii))?

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f. Does the rail transporter ensure that a shipping

paper containing all the information required on

the manifest, except EPA/State ID #'s, generator

certification and signatures, accompanies the waste

at all times (WAC -250(8)(b»?

g. When delivering waste to a nonrail transporter,

does the rail transporter:

i. Obtain the date of delivery and handwritten

signature of the next nonrail transport on the

manifest (WAC -250(8)(d)(i»?

ii. Retain a coy of the manifest for his records

(WAC -250(8)(d)(ii»?

h. When delivering waste to the designated facility,

does the rail transporter:

i. Obtain the date of delivery and handwritten

signature of the owner/operator on the manifest or shipping paper (if the manifest has

not been received by the facility) (WAC

-250(8)(c)(i»?

ii. Retain a copy of the manifest or

shipping paper for his records

(WAC -250(8)(c)(ii»?

H. Transportation out of the United States.

a. Does the transporter keep copies of manifests showing

the date the waste left the U.S. for at least three.

years after the date the waste was accepted by the

initial transporter (WAC -260(3»?

b. Does the transporter indicate on the manifest the

date the waste left the U.S. (WAC -250(9)(a»?

c. Does the transporter sign the manifest and retain

one copy for his records (WAC -250(9)(b)?

d. Does the transporter return a signed·copy of the

manifest to the generator (WAC -250(9)(c))?

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Comments

3. SPILLS OR DISCHARGES, DURING TRANSPORT AND ON THE TRANSPORTER'S OWN PROPERTY.

Yes No

A. If the transporter has a discharge of dangerous waste

during transport, does he:

a. Notify the generator of the waste that a discharge

has occurred (WAC -270(1»?

b. Notify the National Response Center (800-424-8802

or 202-426-2675) if required by 49 CFR 171.15

(WAC -270(2»?

c. For water shipments, notify as required by 33 CFR

153.203 for oil and hazardous substances (WAC -270(4»?

d. Report in writing as required by 49 CFR 171.16 to

the director, Office of Hazardous Materials Regulation, Materials Transportation Bureau, Department of

Transportation, Washington, D.C., 20590 (WAC -270(3»?

B. If the transporter has any nonpermitted spill or discharge

to ground or to surface or ground waters, does he:

a. Notify the appropriate regional office of WDOE

(WAC -145(2)(a»)?

b. Notify all local authorities in accordance with

the local emergency plan (if necessary, by checking

with the local emergency service coordinator and

fire department to determine notification responsibilities under the plan) (WAC -145(2)(a))?

C. If the transporter has any nonpermitted spill or

discharge which results in emissions to the air, does he:

"a. Notify the local air pollution control authority

if the spill or discharge i~ in western Washington

(WAC -270(2)(b»?

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b. Notify the appropriate regional office of WDOE if

the spill or discharge is in eastern Washington

(WAC -270(b))?

c. Notify all local authorities in accordance with

the local emergency plan (if necessary, by checking

with the local emergency service coordinator and

fire department to determine notification responsibilities under the plan) (WAC -270(2)(b))?

D. When the transporter has any nonpermitted spill or

discharge, does he:

a. Take appropriate immediate action to protect human

health and the environment (WAC -145(3))?

b. Whenever required to by WDOE:

i. Clean up all released wastes or take such

other actions as may be required or approved

by federal, state, or local officials acting

within their responsibilities (WAC -145(3)

(a)(i))?

ii. Designate and treat, store, or dispose of

all soils, waters or other materials contaminated by the spill or discharge

(WAC -145(3)(a)(ii))?

1.11. Restore the' area impacted by the spill or

discharge and replenish resources, if the'

impacted property is not owned by the

transporter (WAC -145(3)(a)(iii))?

Comments

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DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE, CHAPTER 173-303 WAC

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PART I I : GENERATORS

This part of the checklist/questionnaire is applicable to any person whose actions or

processes generate dangerous wastes, and are thus identified as generators under Chapter

173-303 WAC. This part of the checklist/questionnaire must be completed for any person

who is a generator, including transporters or TSD facilities which generated dangerous

waste.

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Generator Name: EPA/State ID #:

Inspectors Name: Date:

Has this generator generated dangerous waste since the

date of his last inspection, or since the date he was

determined to be a generator if this is his first Yes

inspection? (I f "No," explain how the generator assures

that no dangerous wastes are generated in the Comments No

section, below, and do not complete the remainder of

this part of this checklist/questionnaire.)

Comments:

1. DESIGNATION (WAC -170(1)).

A. Does the generator properly designate his dangerous

wastes as DW and/or EHW?

B. Does the generator have adequate information to perform

these designations?

C. If designation involves performing tests and analyses

of his waslps:

a. Does the gene r a t.o r have ou-is i t.e , or have ready

access to, equipment for obtaining and preserving

waste samples for tests?

Yes No
'\.

2.

b. Do the waste analyses and test results provide

enough information to accurately designate the

generator's dangerous wastes (WAC -170(1)(a))?

c. Does the generator retain copies of all waste

analyses used to designate his dangerous wastes

for a minimum of three years (WAC -210(3))?

Comments

SHIPPING DANGEROUS WASTE OFF-SITE

A. Does the generator ship any dangerous wastes off-site

that must have accompanying manifests as required under

WAC -180? (If "No," do not complete Section 3. Manifests,

Section 4. Preparing Dangerous Waste for Transport and

Section 5. Import/Export of Dangerous Waste.)

B. Does the generator ever also transport his own wastes?

(If "YES" be sure to also complete Part III: Transporters

of this checklist/questionnaire.)

C. List below any "outside" transporters the- generator uses

to transport his dangerous wastes off-site:

Yes No

Transporter Name EPA/State ID II

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3.

Conunents

MANIFESTS (WAC -180).

A. Does the generator retain a completed copy of each manifest

signed by the initial transporter for at least three years,

or until he receives a signed copy from the designated

facility indicating receipt of the waste which cppy he

keeps for at least three years from the date the initial

transporter accepted the waste (WAC 210(1))?

B.a Does the generator use an alternative manifest mechanism

for moderat~ risk wastes as provided in WAC -170(4)(a)?

b. Has this alternative manifest mechanism been approved

by WDOE?

c. Has the generator complied with the terms and conditions

of, and properly implemented the alternative manifest

mechanism? (If not, specify what failures occurred

under Conunents, below.)

Yes No

Note: If all of the dangerous wastes handled by the generator are moderate risk

wastes covered by an alternative manifest mechanism, then complete only items

G., H., I" and J., below. If only some of the generator's dangerous wastes are

moderate risk wastes covered by an alternative manifest mechanism, then do

complete all remaining items, below.

C. Does the generator use the Uniform Manifest

(WAC -180(1)(b))?

Does the generator include the additional WDOE infor.-

mation required for the Uniform Manifest:

a. In Item D - the first transport's telephone

number (WAC -180(l)(b)(i))?

b. In Item F - the second transporter's telephone

number, if a second transporter is used (WAC

-180(1)(b)(ii))?

c. In Item H - the designated rece1v1ng facility's

telephone number (WAC -180(1)(b)(iii)?

d. In Item 1 - the dangerous waste number for each

cor.responding waste entered and described under

Item 11 (WAC -180(1)(b)(iv))?

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..

D. Is signature of, and date of acceptance by the transporter

obtained prior to tr.ansport (WAC -180(3)(a))7

E. Does the generator retain one copy, signed by the

transporter, and give remaining copies to the transporter at ti.me of transport (WAC -180(3)(a) and (b))?

F. Has the generator received copies of all his manifests,

signed, dated, and returned by the receiving TSD

facilities?

Were all of these received within forty-five days after

the waste was transported? (If "Yes," do not complete

the next item, G., regarding Exception Reports.)

G.a. If the generator does not receive a copy of the manifest

with the handwritten signature of the designated facility's

owner/operator within thirty-five days after the initial

transporter accepted the waste, does he contact the

transporter(s) and/or facility to determine the status

of the dangerous waste shipment (WAC -220(2)(a))?

b. Has the generator submitted in writing to WDOE an

Exception Report for each manifest not signed, dated,

and returned by the receiving TSD facility within

forty-five days of transport (WAC -220(2))1

c. List the dates during the previous year that Exception

Reports were submitted:

d. Were the waste shipments described in these Exception

Reports finally delivered to a TSD facility?

If not, specify which shipments were not delivered

or not found:

e. Does the generator retain copies of all Exception Reports

for a minimum of three years (WAC -210(2))?

H. If the transporter is unable to deliver the dangerous

waste shipment .to either the designated or alternate

facility, does the generator either designate another

facility for delivery or instruct that the shipment

be returned to him when contacted by the transporter for

further instructions (WAC -180(3)(c))?

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...

I. When shipping dangerous waste within the United States

solely by water (bulk shipment), does the generator

send three c0pies of the manifest signed and dated by

himself and the initial transporter to either the

owner/operator of the designated facility, or to the

last water transporter to handle the waste in the U.S.

if the waste is exported by water (WAC -180(3)(d))?

J. For rail shipments within the United States which

originate at the site of generation, does the generator

send at least three copies of the manifest signed and

dated by himself and the initial transporter to either

(WAC -180(3)(e)):

3. The next nonrail transporter, if any?

b. The designated facility if transported solely by

rail ?

c. The last rail transporter to handle the waste

in the U.S. if exported by rail?

Comments

4. PREPARING DANGEROUS WASTE FOR TRANSPORT OFF-SITE (WAC -190).

A. Does the generator package his dangerous waste for

transport in accordance witn U.S. DOT rules, 49 CFR

Parts 173, 178 and 179 (WAC -190(1))?

B. Does the generator label arid mark each of his packages

for shipment in accordance with U.S. DOT rules, 49 CFR

Parl 172 (WAC -190(2) and (3)(a))?

C. Dot's t.hr- gf'I\{' r a t.o r ma rk each package c o nt.a in i ug 110

ga I I 0 II S () r I {' S s 0 fda 11g(' r 0 U S was l e , illld dis P Jay i 11

accordance with 49 CFR 172.304, the following or

equivalent words and information (WAC -190(3)(b)):

HAZARDOUS WASTE - State and Federal Law Prohibits

Improper Disposal. If found, contact the nearest

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Yes No
5.

police or public safety authority, and the Washington

State Department of Ecology or the United States

Environmental Protection Agency.

Generator's Name and Address

Manifest Document Number

D. Does the generator placard, or offer to the transporter

all appropriate placa~ds, in accordance with U.S. DOT

rules 49 CFR Part 172 Subpart F (WAC -190(4))?

Comments

IMPORT/EXPORT OF DANGEROUS WASTE (WAC -230).

A. Does the generator import or export any dangerous waste?

(I f "No, It skip the remainder of the questions in this

item. )

B. If the generator exports dangerous waste to other

countries, does he:

a. Notify EPA in writing, four weeks before shipping

to each country in each calendar year, of the waste's

identification number and DOT description, and of

the name and address of the foreign consignee (40 CFR

262.50 (b)(I))?

b. Require the foreign consignee to confirm delivery

of the waste in the foreign county (40 CFR

262.50(b)(2))?

c. Meet the Uniform Manifest requirements (including

additional WDOE information), except that he uses

the name and address of the foreign consignee in

place of the designated facility's, and he identifies the point of departure from the United States

(40 CFR 262.50(b)(3))?

d.. File an Exception Report with EPA if he has not

received either:

i. A copy of the manifest signed by the transporter

stating the date and place of departure from the

United States within 45 days (40 CFR 262.50(c)(I))?

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Yes No
G.

ii. Written confirmation from the foreign consignee

that the waste was received within 90 days

(40 CFR 262.50(c)(2))?

e. Submit copies of Exception Reports sent to EPA to

WDOE as well (WAC -230(1)(b))?

C. If the generator imports waste from foreign countries,

does he:

a. Comply with all other requirements for generators

(WAC -230(2))?

b. Comply with the Uniform Manifest requirements

(including additional WDOE information), except that

in place of the generator's name, address, and

ID # he enters the name and address of the foreign

generator and the importer and the importer's ID #,

and in place of the generator's signature on the

certification the importer or his agent signs

and dates the certification and obtains the transporter's signature (WAC -230(2)(b))?

Comments

TRIPLE RINSING (WAC' -230(3)! (4) AND -160).

A. Does the generator triple rinse all containers which are

empty and which held EHW in accordance with WAC -160?

B. Does the generator either reuse rinsate from any rinsing

operations (including rinsing of tote tanks, truck or

railroad tank cars, WAC -230(4)) in a manner consistent

with the original product, or else determine if the

rinsate is designated as dangerous waste and, if so

designated, handle it in accordance with Chapter 173-303

WAC and Chapter 90.48 RCW?

Comments

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Yes No
d. If there is ever just one employee present on the

premises, does he have immediate access to a device

(e.g., telephone, two-way radio) capable of summoning external emergency help (WAC -340(2)(b))?

e. Is adequate aisle space provided to allow for

inspections and unobstructed movement of personnel,

fire and spill control equipment and decontamination

equipment during an emergency (WAC -340(3))?

f. Do the hazards posed by the wastes handled by the

generator require arrangements with local authorities?

(l f "Yes," complete the remaining questions, g.

through k, below. If "No," document under Comments,

below, why the hazards are not such as to warrant

these arrangements.) .

g. Has the generator arranged to familiarize police,

fire departments and emergency response teams with:

the layout of his site; properties of wastes handled

and associated hazards; places where personnel

would normally be working; entrances to and roads

on the site; and possible evacuation routes (WAC

-340(4) (a))?

h. Has the generator arranged to familiarize local

hospitals with the properties of dangerous wastes

handled and the types of injuries or illnesses

which could result from fires, explosions or waste

releases (WAC -340(4)(b))?

i. Does the generator have agreements with state

emergency response teams, emergency response

contractors and equipment suppliers (WAC -340(4)(c))?

j. Where more than one party might respond to an

emergency, does the generator have agreements

designating primary emergency authority and support

services to be provided (WAC -340(4)(d))?

k. Has the generator documented all instances where

state or local authorities have declined to enter

into the above arrangements (WAC -340(5))?

Comments

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i. Clean up all released wastes or take such

other actions as may be required or approved

by federal, state, or local officials acting

within their responsibilities (WAC -145(3)(a)(i))?

ii. Designate and treat, store, or dispose of all

soils, waters or other materials contaminated

by the spill or discharge (WAC -145(3)(a)(ii))?

iii. Restore the area impacted by the spill or

discharge and replenish resources, if the

impacted property is not owned by the generator

(WAC -145(3)(a)(iii)?

Comments

8. ANNUAL REPORTS

A. Does the generator retain copies of Annual Reports for

a minimum of three years (WAC -210(2))?

. B. Is the generator generating any wastes which.were not

reported on his latest Annual Report and which should

have been reported?

If "Yes," describe these wastes:

Yes No.

Description/Dangerous Waste n

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EHW/DW

Quantity

(Month/Batch)
7. NON-PERMITTED SPILLS AND DISCHARGES (WAC -145).

A. Have there been any nonpermitted spills or disctarges

on the generator's site which have not been reported

to WDOE?

If yes, describe what wastes were spilled and

approximately what quantities:

B. If the generator has any nonpermitted spill or discharge

to ground or to surface or ground waters, does he:

a. Notify the appropriate regional office of WDOE

(WAC -145(2)(a))?

b. Notify all local authorities in"accordance with

the local emergency plan (if necessary, by checking

with the local emergency service coordinator and fire

department to determine notification responsibilities

under the plan) (WAC -145(2)(a))?

C. If the generator has any nonpermitted spill or discharge

which results in emissions to the air, does he:

a. Notify the local air pollution control authority

if the spill or discharge is in western Washington

(WAC -270(2)(b))?

b. Notify the appropriate regional office of WDOE if

the spill or discharge is in eastern Washington

(WAC -270(b))?

c. Nolify all local authorities in accordance with

the local emergency plan (if necessary, by checking

with the local emergency service coordinator and

fire department to determine notification responsibilities under the plan) (WAC -270(2)(b))?

D. When the generator has any nonpermitted spill or

discharge, does he:

a. Take appropriate immediate action to protect human

health and the environment (WAC -145(3))?

b. Whenever required by WDOE:

-8-

Yes No
9.

C. Are there any wastes which were reported on his latest

Annual Report which the generator is no longer generating?

If "yes," provide the waste description and Dangerous

Waste # as they appeared on the iatest Annual Report:

Comments

ADDITIONAL REPORTS.

Does the department require the generator to submit any

additional reports as provided under WAC -220(3)?

If "Yes," were these reports accurate and submitted in a

timely manner? (Specify what additional reports are required

and note any deficiencies under Comments, below.)

Comments

Yes No

-------------------------------------------------------

-10-
10. GENERATOR ACCUMULATION (WAC -200).

This portion of the generator checklist/questionnaire is only applicable to

generators who accumulate dangerous waste on-site as allowed for in WAC -200.

To determine whether or not this portion is applicable, first complete item A. ,

below. If, after completing item A., it is determined that the generator does

accumulate dangerous waste on-site, then complete all of the questions under

this Section 10. Generator Accumulation. If, after completing item A., it is

determined that the generator does not accumulate dangerous wastes, then do not

complete the remaining questions under this section 10. Generator Accumulation.

(Note: Under certain circumstances, WAC -200(1)(e)(ii) allows an accumulating

generator who keeps his waste less than ten days to be exempt from all or part of

sections WAC -330 through -360. If this is the case for this generator, then

complete only item A. and the remaining applicable items of this section 10.

Generator Accumulation.)

A. Determining Whether Or Not The Generator's Accumulation

Is Subject To WAC -200.

a. If the answers to both of the following questions

are "Yes," then do not complete the remaining

generator accumulation questions (they will be

asked later unde r Part IV: Facilities). If

either or both questions are answered "No," then

continue the remaining questions in this item A.

i. Does the generator operate an on-site

dangerous waste management facility?

11. Are all of the generator's dangerous wastes

placed in and managed (including stored,

treated or disposed) at his on-site facility

as soon as they become subject to regulation?

b. If the answer to any of the following questions

is "Yes," then the generator is subject to the

generator accumulation standards of WAC -200,

and the remaining items of this section 10. Generator

Accumulation must be completed. If the answer to

all of the following questions is "No," then the

generator is not subject to WAC -200.

i. Does the generator ever generate more than

2,200 l b s . (l,000 kg) of dangerous waste in

a month or batch, or ever accumulate more

than 2,200 lbs. (l,000 kg) on-site at any

ti.me?

11. Does the generator ever generate (per month

or per batch) or accumulate on-site at anytime

more than 2.2 lbs. (1.0 kg) of EHW discarded

chemical products (WAC -081)?

-11-

Yes No
iii. Does the generator ever hold dangerous wastes

on-site for more than ten days after the date

tile waste quantity fir s t exceeds the applicable

quantity exclusion limit?

iv. Even though the generator removes all wastes

in less than ten days, has he been required

by WDOE to comply with some or all of WAC

-330 through -360?

Conunents

B. Ninety-Oay* Accumulation Limit.

The time limit is one hundred eighty days for

moderate risk wastes held in containers or tanks

as allowed by WAC -170(4)(b).

Yes No

a.

b.

c.

Does the generator ship all wastes off-site to, or

place them on-site in, a facility permitted (including

interim status or permit-by-rule) to manage dangerous

wastes within ninety days* or less (WAC -200(1)(a))?

In those cases where wastes were not sent to a

facility within ninety days*, did WDOE grant

extensions (maximum thirty days) as allowed by

WAC -200(1)(a)?

How does the generator determine when theninety-day*

accumulation period begins:

1. When the waste is first generated (WAC

-200(2)(a))?

ii. If he is a small quantity generator, when his

aggregated quantity first exceeds the exclusion

limit (WAC -200(2)(b))?

iii. When each container is full (WAC -200(2)(c))?

(Note: This method may not be used if on-site

waste quantity ever exceeds 2,200 pounds

before the container is full, or anyon-site

wastes are EHW discarded chemical products.)

-12-
Conunents

C. Personnel Training (WAC -330).

a. Does the generator have a written personnel training

plan, kept at the generator's site (WAC -330(2))?

b. Does the personnel training plan include the

following documents and records:

i. For each position related to the handling of

dangerous waste on-site, the job title, name

of employee filling each job, and the job

description, including requisite skills,

education, qualifications and duties for each

position (WAC -330(2)(a))?

ii. Written description of type and amount of

introductory and continuing training needed

for each position (WAC -330(2)(b))?

iii. Records documenting that employees have

received and completed the necessary training

(WAC -330(2)(c))?

c. Are training records retained for at least three

years after an employee last worked for the

generator, or until the generator closes his site,

whichever occurs first (WAC -330(3))? (Note:

Records may have been transferred within the

company to follow an employee. This is permissible,

but some record of the employee's transfer and

continued employment should be documented.)

d. Does the generator provide a training program

that teaches personnel to perform their duties

in ways that ensures the generator's compliance

with WAC 173-303 (WAC -330(1))?

e. Does the training program involve:

Classroom instruction?

On-the-job training?

f. Is the training program directed by a person

knowledgeable in dangerous waste handling practices

(WAC -330(1)(a))?

-13-

Yes No
g. Do the generator's employees participate in an

annual review of the training provided in the

training program (WAC -330(1)(b))?

h. Is the training program successfully completed

by each employee within six months of being employed

at the generator's site, or of being assigned to

a new position, whichever is later (WAC ~330(1)(c))?

i. Are new employees supervised until they complete

the training program (WAC -330(1)(c))?

j. Does the training program:

i. Include training relevant to the positions

in which personnel are employed (WAC

-330(1)(a))?

ii. Instruct personnel on contingency plan

implementation (WAC -330(1))?

iii. Familiarize personnel with emergency equipment

and systems, and emergency procedures (WAC

-330(1)(d))?

k. Where applicable, does the training prog~am include

the following parameters (WAC -330(1)(d))?

i. Procedures for using, inspecting, repairing

and replacing emergency and monitoring equipment.

ii. Key parameters for automatic waste feed cut-off

systems.

iii. Communications or alarm systems.

iv. Response to fires or explosions.

v. Response to ground water contamination.

vi. Shutdown of operations.

Comments:

-14-
D. Preparedness and Prevention (WAC -340).

a. Is each container and tank used for accumulation

labeled or marked with the words "Dangerous Waste"

or "Hazardous Waste," and with a label or sign which

identifies for employees, emergency response personnel

and the public the major risk(s) associated with the

waste in the container or tank (WAC -200(1)(e))?

b. Unless it can be demonstrated that the equipment

is not necessary (specify why not in the Comments,

below), or the equipment is not required because

wastes are held less than ten days (as allowed

by WAC -200(1)(e)), are the following equipment

present, tested regularly, and kept in g60d working

order:

i , Internal communications or alarm system

capable of providing immediate emergency

instructions (WAC -340(1)(a))?

Present?

Tested regularly?

Good working order?

ii. A device capable of summoning police or fire

departments or emergency response teams (e.g.,

telephone, two-way radio) (WAC -340(1)(b))?

Present?

Tested regularly?

Good working order?

111. Portable fire extinguishers, fire control

equipment, spill control equipment, and

decontamination equipment (WAC -340(l)(c))?

Present?

Tested regularly?

Good working order?

iv. Water at adequate volwne/pressure to supply

hose streams, foam equipment, sprinklers or

spray systems (WAC -340(1)(d))?

. Present?

tested regularly?

Good working order?

c. Whenever dangerous waste is being handled, do all

personnel involved have immediate access to an

internal alarm or emergency communication system,

either directly or through visual or voice contact

with another employee (WAC -340(2)(a))?

-15-

Yes No
E. Contingency Plan, Emergency Procedures and Emergencies

(WAC -350 and -360).

Yes No

a. Does the generator have a contingency plan designed

to lessen the potential impacts of a fire, explosion

or unplanned sudden or nonsudden release of dangerous

wastes or dangerous waste constituents to air, soil,

surface or ground water (WAC -350(1))7

b. Does the generator have a Spill Prevention Control

and Countermeasures (SPCC) plan amended to include

a contingency plan (WAC -350(2))?

c. Are copies of the contingency plan and revisions

to it:

i. Maintained at the generator's site (WAC

- 35 0 (4)(a) ) ?

ii. Submitted to all local police departments,

fire departments, and hospitals, and state

and local emergency response teams that may

provide emergency services (WAC -350(4)(b))?

d. Is the contingency plan amended whenever:

i. Applicable regulations are revised (WAC

-350(5)(i:J))?

ii. The plan fails in an emergency (WAC

-350(5)(b))?

iii. The generator's site changes in a way that

increases the potential for fires, explosions,

or releases, or that changes the necessary emergency responses (WAC -350(5)(c))?

iv. The list of emergency coordinators changes

(WAC -350(5)(d))?

v. The list of emergency equi.pment changes

(WAC -350(5)(e))?

e. Does the contingency plan include:

1 . A description of the actions personnel must

take in the event of an emergency circumstance

(WAC -350(3)(a))?

11. A description of the arrangements agreed to

by local police and fire departments, hospitals,

contractors, and state and local response teams

to coordinate emergency services (WAC -350(3)(c))?

-17-
iii. A current list of emergency coordinators,

including names, addresses and twenty-four

hour phone numbers (WAC -350(3)(d»?

iv. If more than one emergency coordinator is

listed, identification of a primary emergency

coordinator, with the others listed in the

order that they will assume responsibility

as alternates (WAC -350(3)(d»?

v. A list of all emergency equipment kept on the

site, including the location, physical description and brief outline of the capability of

each piece of equipment (WAC -350(3)(e»?

vi. An evacuation plan (where evacuation could

be necessary) for personnel, which describes

signals to begin evacuation, evacuation routes,

and alternate routes (WAC -350(3)(f»?

f. Do the information and elements described in the

contingency plan assure that the generator has

taken adequate precautions for reacting to emergency

circumstances? (If "No," specify what inadequacies

exist in the Comments section, below.)

g. Is an emergency coordinator on the premises at.

all times or available on-call at all times

(WAC - 360 (l) )?

h. Is

if

i.

ii.

the emergency coordinator (and his alternates,

any) capable in the following areas (WAC -360(1»:

Familiar with all aspects of the contingency

plan?

Familiar with all operations and activities

on the generator's site?

iii. Familiar with the location and properties

of all wastes handled?

iv. Familiar with the location of all rpcords

kept on-s ite ?

v. Familiar with the generator's site layout?

vi. Has the authority to commit the resources

needed to carry out the contingency plan?

i. Are the following procedures implemented (or, to

be implemented) in the event of an emergency:

-18-
i. Does the emergency coordinator or his designee

(EC/D) immediately activate internal alarms or

communication systems to notify all personnel

(WAC -360(2)(a)(i)) and notify appropriate

state or local agencies with designated response

roles if help is needed (WAC -360(2)(a)(ii))?

11. Does the EC/D immediately identify the character,

exact source, amount and areal extent of any

released materials (WAC -360(2)(b))?

iii. Concurrently, does the EC/D assess possible

hazards to human health and the environment

(including direct, indirect, immediate and

long-term effects) that may result from the

emergency (WAC -360(2)(c)}?

iv. If the EC/D determines that the emergency

could threaten human health or the environment

outside the facility, does he immediately notify

and provide an assessment report (which must

include the information described under v.,

below) to:

1. The appropriate local authorities if

evacuation of local areas may be advisable;

and remain available to help appropriate

officials decide if local areas should be

evacuated (WAC -360(2)(d)(i))?

2. WDOE and either the government official

designated as on-the-scene coordinator, or

the National Response Center (WAC

-360(2) (d) (ii)?

v. Does the assessment report (covered under iv.,

above) include:

1. Name and telephone number of r.eporter

(WAC -360(2)(~)(i))?

2. Name and address of the generator's site

(WAC -360(2)(e)(ii))?

3. Time and type of emergency (e.g., fire,

release) (WAC -360(2)(e)(iii))?

4. Name and quantity of materials involved

(WAC -360(2)(e)(iv))?

5. The extent of injuries, if any

(WAC -360(2)(e)(v))?

-19-

.,.,.
6. Possible hazards to human health and the

environment off the site (WAC -360(2)(e)

(vi) )?

vi. During an emergency, does the EC/D take all

measures necessary to ensure that fires, explosions, and releases do not occur, recur, or

spread to other dangerous wastes (e.g., stopping

processes or operations, collecting and containing releases, removing or isolating containers,

etc.) (WAC -360(2)(f))?

vii. If operations stop in response to an emergency,

does the EC/D monitor for leaks, pressure

buildup, gas generation or ruptures wherever

appropriate (WAC -360(2)(g))?

viii. Immediately after an emergency, does the EC/D

provide for treating, storing or disposing

wastes and materials resulting from the emergency

(WAC -360(2)(h))?

ix. Does the EC/D ensure, in the affected areas on

the site, that:

1. No waste that may be incompatible with the

released material is treated, stored or

disposed until cleanup procedures are

completed (WAC -360(2)(i)(i))?

2. All emergency equipment listed in the

contingency plan is cleaned and fit for

its intended use before operations resume

(WAC -360(2)(i)(ii))?

x. Does the generator notify WDOE, and appropriate

local authorities, that his site satisfies the

conditions described under ix.I. and 2., above,

before operations resume in the affected areas

of his site (WAC -360(2)(j))?

xi. Does the generator note in his operating record

the time, date, and details of incidents requiring implementation of the contingency plan

(WAC -360(2)(k))?

xii. Within fifteen days after the emergency, does

the generator submit a written report of the

incident to WDOE which includes:

1. Name, address, and telephone number of

the generator (WAC -360(2)(k)(i)) and of

the site (WAC -360(2)(k)(ii))?

-20-
2. Date, time, and type of emergency (WAC

-360(2)(k)(iii))?

3. Name and quantity of materials involved

(WAC -360(2)(k)(iv))?

4. The extent of injuries, if any (WAC

-360(2)(k)(v))?

5. An assessment of actual or potential

hazards to human health or the environment,

where this is applicable (WAC -360(2)(k)(vi))?

6. Estimated quantity and disposition of

recove~ed material that resulted from the

incident (WAC -360(2)(k)(vii))?

Conunents

11. METHOD OF ACCUMULATION

How does the generator accumulate his dangerous wastes:

A. In containers?

(Complete Section 12., below.)

B. In; tanks?

(Complete Section 13., below.)

C. In piles (Note: This option is only available for

moderate risk wastes)?

(Complete Section 14., below.)

-21-
12. ADDITIONAL REQUIREMENTS FOR GENERATORS ACCUMULATING

WASTES IN CONTAINERS.

A. Are all containers in good condition, and are dangerous

wastes transferred to good containers or otherwise managed

if the original container leaks (WAC -630(2))?

B. Are all containers marked with the date accumulation

began (WAC -200(1)(c))?

C. Are all containers made of or lined with materials that

will not react or are otherwise compatible with the

wastes being accumulated (WAC -630(4))? (If necessary,

request and obtain documentation to demonstrate waste/

container compatibility.)

D. Are all containers used for accumulating dangerous

wastes:

a. Always closed except when wastes are added or

removed (WAC -630(5)(a))?

b. Not opened, handled, or stored (e.g., left in

areas of heavy traffic where collisions could

occur, or personnel or the public could intentionally or accidentally damage the containers)

in ways that would rupture the containers or cause

them to leak (WAC -630(5)(b))?

t. Stored in a manner which allows the generator to

inspect each container for leaks, ruptures or

deterioration?

E. Does the generator inspect at least weekly the areas

where containers are used to accumulate wastes, looking

for leaking containers and for deterioration from corrosion

and other factors (WAC -630(6))?

F. Does the generator keep records of weekly inspections

of his container storage area which describe (WAC -630(6)):

a. The dates of inspection and name(s) of inspector(s)?

b. Observations of any leaks or container deterioration

detected?

c. Measures taken to correct leaks or deteriorated

containers (if any)?

-22-

Yes No
G. Are containers used for accumulating ignitable or

reactive dangerous waste?

If "Yes":

a. Are containers holding reactive wastes (if any)

capable of detonation or explosion, or that are

forbidden explosives or Class A or B explosives (49 CFR

173.51, 53 or 88) stored equivalent to UFC's "American

Table of Distances for Storage of Explosives," Table

77-201 (WAC -630(8)(a»?

b. Are all other ignitable or reactive waste container

storage designed, operated and maintained equivalent

to the Uniform Fire Code, state or local fire codes,

or NFPA Pamphlet 1130, "Flammable and Combustible

Liquids Code" (WAC -630(8)(b»?

c. Are those areas where ignitable or reactive wastes

are accumulated inspected at least yearly by a

professional person familiar with the Uniform Fire

Code, or by a federal, state, or local fire marshal

(WAC -630(8)(b), -395(1)(d»?

d. Does the generator keep records of these fire

inspections which describe:

1. The dates of inspection and name(s) of

inspector(s)?

ii. Observations of any unsafe or improper

ignitable or reactive waste handling?

iii. Measures taken to correct any unsafe or

improper ignitable or reactive waste handling?

H. Are incompatible wastes or incompatible wastes and

materials accumulated or held on-site (e.g., corrosives

with ignitables, chlorinateds with ignitables)?

If "Yes":

a. Describe which wastes or wastes and materials are

incompatible:

-23-
G. Are containers used for accumulating ignitable or

reactive dangerous wasle?

If "Yes":

a. Are containers holding reactive wastes (if any)

capable of detonation or explosion, or that are

forbidden explosives or Class A or B explosives (49 CFR

173.51, 53 or 88) stored equivalent to UFC's "American

Table of Distances for Storage of Explosives," Table

77-201 (WAC -630(8)(a))?

b. Are all other ignitable or reactive waste container

storage designed, operated and maintained equivalent

to the Uniform Fire Code, state or local fire codes,

or NFPA Pamphlet 1130, "Flammable and Combustible

Liquids Code" (WAC -630(8)(b))?

c. Are those areas where ignitable or reactive wastes

are accumulated inspected at least yearly by a

professional person familiar with the Uniform Fire

Code, or by a federal, state, or local fire marshal

(WAC -630(8)(b), -395(1)(d))?

d. Does the generator keep records of these fire

inspections which describe:

i. The dates of inspection and name(s) of

inspector(s)?

ii. Observations of any unsafe or improper

ignitable or reactive waste handling?

iii. Measures taken to correct any unsafe or

improper ignitable or reactive waste handling?

H. Are incompatible wastes or incompatible wastes and

materials accumulated or held on-site (e.g., corrosives

with ignitables, chlorinateds with ignitables)?

If "Yes":

a. Describe which wastes or wastes and materials are

incompatible:

-23-
b. Does the generator assure that dangerous wastes are

not put in containers which previously held incompatible wastes or materials unless the container

has been washed (WAC -630(9)(b))?

c. Are containers holding waste that is incompatible

with wastes or materials stored nearby separated

or protected from such wastes or materials by a

dike, berm, wall or other device, and are containment systems (if any) for incompatible wastes

separate (WAC -630(9)(c))?

d. Are incompatible wastes, or incompatible wastes

and materials put in the same container?

Describe which incompatible wastes or wastes and

materials are involved:

€. If incompatible wastes or wastes and materials are

mixed or commingled, are these activities conducted

so as not to (WAC -630(9)(a)):

i. Generate extreme heat, pressure, fire, explosion

or violent reaction (WAC -395(1)(b)(i))?

ii. Produce uncontrolled toxic mists, fumes, dusts

or gases in sufficient quantities to threaten

human health or the environment (WAC -395(1)(b)

(ii))?

iii. Produce uncontrolled flammable fumes or gases

in sufficient quantities to pose a risk of fire

or explosions (WAC -395(1)(b)(iii))?

iv. Damage the structural integrity of the facility

or containers (WAC -395(1)(b)(iv))?

v. Otherwise threaten human health or the

environment (WAC -395(1)(b)(v))?

Note: If the generator is treating wastes as they are placed in his .containers

(other than simple mixing with an absorbent), he may be operating a dangerous

waste treatment facility.

-24-
Conunents

13. ADDITIONAL REQUIREMENTS FOR GENERATORS ACCUMULATING

WASTES IN TANKS.

A. Does the generator maintain a system of records which

assure that no wastes held in his tanks are being

accumu~ated for more than ninety days (one hundred

eighty days for moderate risk wastes only)?

B. Are wastes or other materials which are incompatible

with the material of construction of the tanks ever

placed in the tanks?

If "Yes," is the tank protected from corrosion, erosion

or abrasion through use of:

a. An inner liner, free of leaks, cracks, holes or

other deterioration, which is compatible with the

waste or materials (WAC -640(3)(a)(i)?

h. Alternative protection (e.g., cathodic protection,

co rro s ion inh i b i tors) (WAC -640 (3)(a)( ii))?

C. Doe s the generator use appropriate measures to prevent

overfilling and overtopping, including:

a. Controls to prevent overfilling (e.g., waste feed

cut-off systems, by-pass to a standby tank)

(WAC -640(3)(b)(i))?

b. For uncovered tanks, maintenance of at least two

feet of freeboard (WAC -200 (l)(b), -640(3)(b)(ii))?

-25-

Yes No
D. Does the generator inspect at least once each operating

day:

a. Overfilling control equipment to ensure it is in

good working order (WAC -640(4)(a)(i))?

b. Data gathered from monitoring equipment where

present, to ensure each tank is operated according

to its design (WAC -640(4)(a)(ii))?

c. For uncovered tanks, the level of waste in each

tank to ensure the freeboard is at least two feet

(WAC -640(4)(a)(iii))?

E. Does the generator inspect at least weekly:

a. The construction materials of the above ground

portions of each tank to detect corrosion, erosion

or leaking of the tank, fixtures and seams (WAC -640(4)

(a)(iv))? .

b. The area immediately surrounding each tank to

detect obvious signs of leakage (e.g., wet spots,

dead vegetation) WAC -640(4)(a)(v))?

F. Does the generator have a written schedule for inspecting

his tanks which includes records describing (WAC -640(4)(b)):

a. The dates of inspections and name(s) of inspector(s)?

b. Observations of any conditions which could cause the

tank to leak or fail as specified in the written

schedule?

c. Measures taken to correct or prevent any hazardous

conditions identified during the inspection?

G. Does the generator have records describing dates that

spills or leaks (if any) from his tanks occurred and

measures taken to clean up and decontaminate the spiLls

or leaks (WAC -640(4)(c))? (Note: The measures to be

taken to respond to spills or leaks should be described in his contingency plan.)

H. Does the generator have records showing that at least

once each operating day he:

a. Gathered data from monitoring equipment to ensure

the tank was uperated according to its design

(WAC -640(4)(a)(ii))?

b. Checked the level of waste in uncovered tanks (if

any) to ensure that a m1n1mum freeboard of two feet

was maintained (WAC -640(4)(a)(iii), -200(1)(b))?·

-26-
I. Have any tanks been closed and removed from dangerous

waste service since the last inspection?

If "Yes":

a. Have all dangerous wastes and residues been removed

from the tanks, discharge control equipment, containment systems and bases (where present) and discharge

confinement structures (WAC -640(5))?

b. Have all tanks, bases, liners and soils containing

or contaminated with dangerous wastes or residues

been removed or decontaminated (WAC -640(5))?

J. Are ignitable or reactive wastes placed in tanks?

If "Yes":

a. Is the tank only used for emergencies (WAC

-640(6)(a)(iii))?

b. Is the waste stored in such a way that it is

protected from any material or conditions that may

cause the waste to ignite or react (WAC

-640(6)(a)(ii))?'

c. Is the waste treated, rendered or mixed before or

immediately after placement in the tank so that

(WAC -640(6)(a)(i)):

i. The resulting mixture in the tank is no longer

ignitable or reactive under WAC -090?

ii. And, the mixing or commingling of the waste

does not: generate extreme heat, pressure,

fire, explosion or violent reaction; produce

uncontrolled toxic mists, fumes, dusts or

gases that threaten human health or the

environment; produce uncontrolled flammable

fumes or gases that pose a risk of fire or

explosion; damage the structural integrity

of the tank or equipment; otherwise threaten

human health or the environment (WAC -395(1)(b))?

Note: If the generator is treating wastes as they are placed

in his tanks, he may be operating a dangerous waste treatment

facility.

d. Are the tanks located in a manner equivalent to the

NFPA's buffer zone requirements for tanks (Tables 2-1

through 2-6 of the "Flammable and Combustible Liquids

Code - 1981"), or as required by state and local fire

codes if these are more stringent (WAC -640(6)(b))?

-27-
e. At least yearly, is the tank storage area inspected

by a professional person knowledgeable in the Uniform

Fire Code, or by a local, state or federal fire

marshal (WAC -640(6)(b), - 395(1)(d))?

f. Does the generator keep records of this annual

inspection describing:

i. The dates of inspection and name(s) of

inspector(s)?

11. Observations of any unsafe or improper

ignitable or reactive waste handling?

iii. Measures taken to correct any unsafe or

improper ignitable or reactive waste handling?

K. Are incompatible wastes or incompatible wastes and

materials placed in the same tank?

If "Yes":

a. Describe which wastes or wastes and materials

are incompatible:

b. If incompatible wastes or wastes and materials are

placed in the same tank, or if dangerous waste is

placed in an unwashed tank which previously held

incompatible waste or materials, are these activities

conducted so as not to (WAC -640(7)):

i. Generate extreme heat, pressure, fire, explosion

or violent reaction (WAC -395(1)(b)(i))?

ii. Produce uncontrolled toxic mists, fumes, dusts

or gases that threaten h~an health or the

environment (WAC -395(1)(b)(ii))?

iii. Produce uncontrolled flammable fumes or gases

that pose a risk of fire or explosion (WAC

-395(1)(b)(iii)?

-28-
iv. Damage the structural integrity of the tank

or equipment (WAC -395(1)(b)(iv))?

v. Otherwise threaten human health or the

environment (WAC -395(1)(b)(v))?

Note: If the generator is treating incompatible wastes as they

are placed in his tanks, he may be operating a dangerous waste

treatment facility.

Comments

14. ADDITIONAL REQUIREMENTS FOR GENERATORS ACCUMULATING

WASTES IN PILES.

Note: This section is applicable to only those moderate risk

wastes a generator may be accumulating.

A. Does the generator keep records of any leaks of liquids

into the leak detection system that have occurred,

describing (WAC -660(3)(b)):

a. Dates and times leaks were detected?

b. Measures taken to remove accumulated liquids and

stop leakage that is occurring?

c. Certification by a qualified engineer that the

leak has been stopped?

B. Does the generator keep records of any notifications

sent to WDOE that there have been leaks into the leak

detection system (if any?)

C. [Remainder to be added at a later date. 1

-29-

Yes No
'-

DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE, CHAPTER 173-303 WAC

* * * * * * * * * * * * * * * .'." * * * * * * * * * * *

* *-!(

PART IV: GENERAL TSD FACILITY REQUIREMENTS

This part of the checklist/que~tionnaireapplies to all facilities which treat, store,

or dispose (TSD) dangerous waste, including interim status and final status facilities,

and permit-by-rule and emergency permit facilities (except that in such cases, only

some of this part of the checklist/questionnaire may be applicable). This part of the

checklist/questionnaire covers those facility requirements which apply to all TSD

facilities regardless of the specific type of unit operations (e.g., containers, tanks,

incinerators). Other parts of this checklist/questionnaire address the specific unit

operating requirements for interim and final status facilities, and should be used in

conjunction with this more general part. The abbreviation "0/0" is used frequently

throughout the TSD facility parts of this checklist/questionnaire and stands for the

words "owner and/or operator."

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

1.

2.

MODERATE RISK WASTE MANAGEMENT.

Does the facility manage any moderate risk wastes (MRW) for

which the % has sought and obtained from WDOE reduction in

the r.egulatory requirements applicable to such MRW (such

reductions must be specified either in the facility permit

issued under WAC -806, or else in a notice of interim status

modification issued under WAC -805(8))?

If not, then all sections of this Part IV of the checklist/

questionnaire are applicable. If yes, then some sections

of this Part IV may not be applicable to such MRW management. Notes should be made in the appropriate Comments area

where there may be discrepancies between .the requirements on

MRW and on any other dangerous wastes managed at the facility

(e.g., fire control equipment may be checked as present and

in good operating condition except for MRW, with a note under

comments that such equipment was not present in the MRW

management areas because it is not necessary).

FACILITY SITING (WAC -420).

A. Earthquake Fault Criteria (WAC -420(3)).

a. Is the facility located in anyone of the following

counties (WAC -420(3)(c))? (If "No," the facility

is automatically in compliance with the earthquake

fault criteria and no further questions need to be

a s ke d . )

Yes

Yes

No

No

Chelan

Clallam

Clark

Cowlitz

Douglas

Ferry

Grant

Grays Har.bor

Jefferson

King

Kitsap

Kittitas

Lewis

Mason

Okanogan

Pacific

Pierce

San Juan

Skagit

Skamania

Snohomish

Thurston

Wahkiakum

Whatcom

Yakima
" ..

b. Is the facility located within 200 feet of a fault

which has had displacement in Holocene times (WAC

-4200) (a))?

Note: Existing facilities (i.e., operating prior

to November 19, 1980 for EPA wastes and prior to

August 9, 1982 for state-only wastes) may be

located within 200 feet of such faults. New

facilities may not.

c. If the facility manages only moderate risk wastes,

and is a new facility located within 200 feet of

a fault, is the facility engineered against earthquakes and has WDOE approved the engineering (WAC

-4200)(a) )?

B. Floodplain Criteria (WAC -420(4)).

a. Is the facility located in a one hundred year

floodplain (WAC -420(4)(a))? (If "No," then the

facility is automatically in compliance with the

floodplain criteria and no further questions

need to be asked.)·

b. Is the facility designed, constructed, operated,

and maintained to prevent washout of any dangerous

waste by a one hundred year flood (WAC -420(4)(a)

and (b))? (Describe the washout precautions under

Comments, below.)

c. If the facility manages DW only and never manages

EHW, in lieu of washout precautions has the facility

0/0 included in his contingency plan procedures for

safely removing the DW, before floodwaters reach

the facility, to another facility that is not

vulnerable to floodwaters (WAC -420(4)(a))? (~f

"Yes," these provisions will be addressed in the

Contingency Plan section, below.)

C. Shoreline Criteria (WAC -420(5)).

a. Is the facility disposing of dangerous waste in an

area defined as a "wetland" under RCW 90.58.030

(2)(0. ("Wetlands" or "wetland areas" means those

lands extending landward for two hundred feet in

all directions as measured on a horizontal plane

from the ordinary high water mark; floodways and

contiguous floodplain areas landward two hundred

feet from such floodways; and all marshes, bogs,

swamps, and river deltas associated with the

streams, lakes, and tidal waters which are subject

to the provisions of this chapter; the same to be

designated as to location by the department of

ecology.) (WAC -420(5)(a))?

-2-
3.

b. Is the facility located in an area where the

local shoreline management master program permits

industrial, navigation, manufacturing, or similar

activities (areas classified as natural, conservancy, rural or residential may not be used for

dangerous waste management: WAC -420(S)(b))?

D. Sole Source Aquifer Criteria (WAC -420(6)).

Is this a new facility (constructed and operating

after November 19, 1980 for EPA wastes, after

August 9, 1982 for state-only wastes) that is disposing of dangerous waste over a sole source aquifer

designated pursuant to section 1424(3) of the Safe

Drinking Water Act?

Comments

SECURITY (WAC -310).

A. Can the facility % demonstrate that:

a. Physical contact with wastes or equipment within the

active portion will not injure persons or livestock

(WAC -310(1)(a))?

b. Disturbance of wastes by persons or livestock will

not result in viol.ations of ch. 173-303 WAC (WAC

-JIO( I )(b))?

B. If the facility % cannot demonstrate both of the above,

then does the facility have:

a. Either:

i. A barrier (artificial, natural or both) which

completely surrounds the active portion, with

a means to control access through gates or

other entrances to the active portion at all

times (WAC -310(2)(c))?

-3-

Yes No
..

4.

ii. Or, a twenty-four hour surveillance system to

monitor and control entry to the active portion (WAC -310(2)(b))?

b. And, signs which (WAC -310(2)(a)):

i. Are posted at each entrance to the active

portion, and at other locations in sufficient

numbers to be seen from any approach?

ii. Bear the legend (or an equivalent one), written

in English, "Danger-Unauthorized Personnel Keep

Out"?

iii. Are legible from a distance of twenty-five

feet or more?

C. If the facility has or is a totally enclosed treatment

facility or elementary neutralization or wastewater

treatment unit, in lieu of item B., above, does the 0/0

prevent unknowing entry and minimize the possibility of

unauthorized entry by persons or livestock onto those

portions of his facility (WAC -310(3))?

Comments

MANIFEST SYSTEM (WAC -370).

A. Does the facility receive any manifested shipments of

dangerous waste from off-site?

If "No," then do not complete the rest of the questions

in this section 4. Manifest System. If "Yes," complete

the remaining questions.

B. Does the % retain copies of all manifests and shipping

papers at the facility for at least three years after

shipments are delivered (WAC -370(2)(e) and (3)(e))?

C. When a shipment is received accompanied by a manifest,

does the % or his agent:

-4-

Yes No
a. Sign and date each copy of the manifest to certify

receipt (WAC -370(2)(a))?

b. Note any significant discrepancies on each copy

of the manifest (WAC -370(2)(b))?

c. Immediately give the transporter at least one copy

of the signed manifest (WAC -370(2)(c))?

d. Within thirty days after delivery, send a copy of

the signed manifest to the generator (WAC -370(2)(d))?

D. When a shipment accompanied by a manifest or shipping

paper (H/SP) is received from a rail or water transporter,

does the % or his agent:

a. Sign and date each copy of the M/SP to certify

receipt (WAC -370(3)(a))?

b. Note any significant discrepancies on each copy

of the M/SP (WAC -370(3)(h))?

c. Immediately give the rail or water transporter

at least one copy of the M/SP (WAC -370(3)(c))?

d. Within thirty days after delivery, send a copy

of the signed H/SP to the generator (WAC

-370 (3)(d))?

If the manifest is not received within thirty

days after delivery, send a copy of the signed

and dated shipping paper to the generator (WAC

-370 (3) (d))?

E. Does the 0/0:

a. Have procedures which he follows to identify

significant discrepancies between the shipments

he receives and the shipment described on

the manifest?

b. Detect the following types of significant

discrepancies (WAC -370(4)(a)):

~. Variations in quantities of greater

than ten percent for bulk shipments?

~l. Variations in piece count (e.g., missing

containers or packages)?

i ii. Variations in waste type, discovered by

inspection or waste analysis (e.g., acid

substituted for solvent)?

-5-
c. Attempt to resolve significant discrepancies

(if any) with the transporter or generator (WAC

-370(4)(b))?

d. If a significant discrepancy is not resolved

within fifteen days of its discovery, immediately

submit a manifest discrepancy report and a copy

of the manifest or shipping paper to WDOE (WAC

-370(4)(b))?

List any dates since the last inspection (or since

.notification if this is the first inspection) that

the % submitted manifest discrepancy reports (if

any) to WDOE.

F. Under certain circumstances the % may refuse acceptance

of a waste shipment and send it on to another facility.

a. Does the % deny receipt of a shipment only under

the following circumstances (WAC -370(5)(a)):

i. His facility is not capable of properly

managing the waste?

ii. There is a significant discrepancy between

the shipment and the manifest or shipping

paper?

iii. The shipment has arrived in a condition which

would present an unreasonable hazard to his

facility operations or personnel?

b. [f the % chooses to deny receipt of the shipment

but the containers are damaged or the waste is in

a condition that would pose a hazard if transported,

does the % implement the provisions of his contingency plan designed to address such situations

(WAC -370(5)(c))?

c. When he denies receipt of the shipment, does the

0/0 either send the shipment on to the alternate

facility designated on the manifest or shipping

paper, or contact the generator to identify another

facility and provide for the shipment's delivery

to that facility (WAC -370(5)(b))? .

-6-
5.

Comments

WASTE ANALYSIS (WAC -300).

A. Does the facility % have a waste analysis plan which is

kept at the facility (WAC -300(5))?

B. Does ~he waste analysis plan cover the following areas:

a. How the % shall obtain detailed chemical, physical,

or biological analyses of wastes adequate to assure

safe TSD in accordance with Ch. 173-303 WAC, including where appropriate: data from existing documents

or publications; data on wastes generated from

similar processes; or, data from actual testing

(WAC -300(2))?

b. For facilities rece1v1ng waste shipments from

off-site, how the % shall confirm that each

waste received matches the identity of the waste

specified in the manifest or shipping paper

(WAC -300(3))?

c. Repeating of analyses to assure accurate

information as necessary, including repeat

analyses at least when: the % has been

notified or has reason to believe that the

process generating the waste has significantly

changed; and, a waste received from off-site

does not match the identity specified on the

manifest or shipping paper (WAC -300(4))?

C. Does the waste analysis plan assure that the areas

descrihed under item B., above, are adequately satisfied by inclusion of at least the following:

a. The parameters for which each waste will be

analyzed and rationale for these parameters

(WAC -300(5)(a))?

b. The methods of obtaining or testing for these

parameters (WAC -300(5)(b))?

c. The methods for obtaining representative waste

samples (WAC -300(5)(c))?

-7-

Yes No
d. The frequency with which analyses will be reviewed

or repeated to assure accurate and current information(WAC -300(5)(d))?

e. The waste analyses which generators have agreed

to provide (WAC -300(5)(e))?

f. The procedures for quality assurance and quality

control, including at least:

i. Measures to prevent sample contamination

during sampling?

11. Certification/documentation of sampling

and testing procedures?

iii. Evaluation of personnel performance of

sampling/testing?

iv. Chain of custody procedures?

v. Inspection, calibration, testing, and

maintenance of sampling and analysis

equipment?

g. For facilities receiving wastes from off-site,

the procedures for confirming the waste identity

specified on the manifest or shipping paper

(WAC -300(5)(g))?

Do these procedures include at least:

i. Procedures for identifying each waste

movement at the facility?

ii. Methods for obtaining representative waste

samples, if the identification method

involves sampling?

h. Methods for meeting the additional waste analysis

requirements for specific waste management methods

as specified for interim and final status TSD

under items D. and E., below (WAC -300(5)(£))?

D. Interim Status Waste Analysis Requirements for Specific

Waste Management Methods.

Where appropriate, does the waste analysis plan include

procedures for the following interim status management

methods:

-8-
a. Containers.

i. Determining compatibility of a waste to a

container (if not determined when containers

were first selected)?

ii. Determining compatibility of a waste to other

wastes or materials stored nearby?

iii. Determining compatibility of a waste to wastes

previously held in reused containers that were

not decontaminated?

iv. Analyzing ignitable/reactive containerized

wastes?

v. Analyzing liquids that are collected in a

storage area?

vi. Determining whether or not runoff collected

from the active portion would be designated

as a dangerous waste?

b. Tanks (40 CFR 265.193).

i. Determining compatibility of a waste to a tank

(if not determined when tank was first selected)?

ii. Determining compatibility of a waste to any raw

materials or other wastes potentially or previously held in the tank by conducting analyses

or trial treatment or storage tests (e.g., bench

scale, pilot plant) or by obtaining written documented information on similar storage or treatment of similar wastes under similar conditions?

iii. Determining the compatibility of a waste to other

wastes or materials held or treated nearby?

iv. Analyzing ignitable/reactive wastes managed in

tanks?

v. Determining whether or not runoff collected

from the active portion would be designated

as a dangerous waste?

c. Surface Impoundments (40 CFR 265.225).

i. Determining compatibility of a waste to the

impoundment's materials of construction (if

not determined when materials were first

selected)?

-9-
ii. Determining the compatibility of a waste to

any raw materials or other wastes potentially

previously held in the impoundment by conducting analyses or trial treatment or storage

tests, or by obtaining written documented information on similar treatment or storage of

similar wastes under similar conditions?

iii. Determining the compatibility of a waste to

other wastes or materials held or treated nearby?

\

iv. Procedures for analyzing ignitable/reactive

wastes managed in impoundments?

v. Determining whether or not runoff (if any)

collected from the active portion would be

designated as a dangerous waste?

d. Waste Piles (40 CFR 265.252).

i. Determining the compatibility of a waste to

the pile's materials of construction (if not

determined when materials were first selected)?

ii. Determining the compatibility of each waste to

be added to the pile (including visual comparison of color and texture) to assure that inadvertent mixing of incompatible wastes does not occur,

unless the % can show that either: the only

wastes to be added to the pile are compatible;

or, the waste received is compatible with the

waste in the pile to which it is added?

iii. Determining the compatibility of a waste to other

wastes or materials potentially held or treated

nearby.

iv. Determining the compatibility of a waste to

wastes previously held on the pile base if it

was not decontaminated (unless it can be

proven the wastes are the same)?

v. Analyzing ignitable/reactive wastes managed

in waste piles?

vi. Sampling and analyzing leachate collected

beneath the pile, and managing the leachate

if hazardous?

vii. Determining whether or not runoff collected

from the active portion would be designated

as a dangerous waste?

-10-
e. Land Treatment (40 CFR 264.273).

l ..

11.

iii.

iv.

v.

vi.

vii.

viii.

Determining the concentration in the waste of

any substances which exceed the EP toxicity

concentration limits of WAC -090(8)(c)?

For any waste listed in WAC -081 or -082,

determining the concentrations of any substances which caused the waste to be listed?

For any waste mixture designated under WAC

-084 or the criteria of WAC -101 through -103,

determining the concentrations of any substances

which caused the waste to be designated?

If food chain crops are grown, procedures for

determining the concentrations of arsenic,

cadmium, lead and mercury, unless the 0/0

has written, documented data showing the

constituent is not present?

Procedures to determine the compatibility of

a waste to any raw materials or other wastes

potentially applied in a given treatment zone?

Determining the compatibility of a waste to

other wastes or materials held or treated

nearby?

Procedures for analyzing ignitable/reactive

wastes to be treated?

Determining whether or not runoff collected

from the active portion would be designated

as a dangerous waste?

f. Landfills.

i. Inspecting containers for free liquids before

disposal and for handling any unacceptable free

liquids that may appear?

ii. Inspecting containers for 90% volume by waste

and for handling any containers of waste that

are unacceptable by the facility that may appear?

Lll. Determining the compatibility of a waste to

landfill liner(s) and leachate collection system

materials (if not determined when materials were

first selected)?

iv. Determining the compatibility of a waste to any

other wastes potentially disposed in the landfill?

-11-
v.

vi.

vii.

Analyzing ignitable/reactive wastes to be

disposed?

Sampling and analyzing leachate collected and

managing the leachate if dangerous?

Determing whether or not runoff collected

from the active portion would be designated

as a dangerous waste?

g. Incinerators (40 CFR 265.341).

i. Analyzing any waste not previously burned in

the incinerator to enable the % to establish

steady state operating conditions and to determine the types of pollutants which might be

emitted?

Do these analyses include determining at least:

1. Heating value of the waste?

2. Halogen and sulfur content of the waste?

3. Concentrations of lead and mercury in the

waste, unless the % has written, documented data showing that the element is

not present?

ii. Determining the compatibility of wastes to be

mixed in the incinerator, and the compatibility

of wastes to be burned with the incinerator's

materials of construction?

iii. Determing whether or not runoff collected

from the active portion would be designated

as a dangerous waste?

h. Thermal Treatment (40 CFR 265.315).

i. Analyzing any waste tlOt previously treaLed in

the thermal treatment unit to enable the 0/0

to establish steady state operating conditions

and to determine the types of pollutants which

might be emitted?

Do these analyses include determining at least:

1. Heating value of the waste?

2. Halogen and sulfur content of the waste?

3. Concentrations of lead and mercury in the

waste, unless the % has written, documented data showing that the element is

not present?

-12-
ii. Determining the compatibility of wastes to be

mixed in the thermal treatment unit, and the

compatibility of wastes to be burned with the

unit's materials of construction?

iii. If open burning of wastes is conducted, analyzing

the wastes to assure that only explosive wastes

with the capability of detonation are being

open burned?

vi. Determing whether or not runoff collected

from the active portion would be designated

as a dangerous waste?

i. Chemical, Physical and Biological Treatment

(40 CFR 265.402).

1. Whenever substantially different wastes are to

be treated or substantially different treatment

processes are to be used:

1. Procedures for conducting waste analyses

and trial treatment tests (e.g., bench

scale, pilot plant)?

2. Or else, procedures for obtaining written,

documented information on similar treatment of similar wastes under similar conditions?

ii. Procedures to determine the compatibility of a

waste to process structure (if not determined

when structure was first selected)?

iii. Procedures to determine the compatibility of a

waste to any raw materials or other wastes

potentially or previously held in the process

structure?

LV. Procedures to determine the compatibility of a

waste to other wastes or materials held or

treated nearby?

v. Procedures for analyzing ignitable/reactive

wastes managed in the process structure?

vi. Determing whether or not runoff collected

from the active portion would be designated

as a dangerous waste?

-13-
6.

E. Final Status Waste Analysis Requirements for Specific

Waste Management Methods.

[Reserved]

Comments

INSPECTIONS (WAC -320).

A. Does the facility % have a written inspection schedule

which is kept at the facility (WAC -320(2))?

B. Does the facility % keep a written inspection log or

summary (WAC -320(2)(d)):

a. Which shows that the inspection schedule is being

followed?

b. Including at least:

I. The time, date, and nature of the inspection?

ii. The printed name and handwritten signature of

the inspector?

-14-

Yes No
iii. Notations of observitions made?

iv. Date and nature of any repairs or remedial actions?

c. For at least three years from the date of inspection?

C. When the facility % discovers any problems during an

inspection, does he remedy the problems on a schedule

which prevents hazards to the public health and the environment (immediately where a hazard is imminent or has already

occurred) (WAC -320(3))?

D. Does the inspection schedule identify (WAC -320(2)):

a. The areas of the facility to be inspected?

b. The equipment to be inspected, including at least all:

i. Monitoring equipment?

ii. Safety and emergency equipment?

iii. Security devices?

iv. Operating and structural equipment that help

prevent, ~etect or respond to hazards to

public health or the environment?

c. Areas subject to spills (to be inspected daily when

in use)?

d. The frequencies with which these areas and items

are to be inspected?

e. The types of problems to be looked for during

inspections?

f. And the additional Inspections to be conducted for

specific waste management methods as specified for

interim and final status TSD under items E. and F.,

below?

E. Interim Status Inspection Requirements for Specific Waste

Management Methods.

Where the following types of management methods are

employed, does the inspection schedule specify the additiona 1 items to be inspected, inspect ion frequency and

typps of problems to be looked for?

a. Containers (40 CFR 265.174).

i. Areas where containers are held, at least

weekly, to detect leaks and deterioration

caused by corrosion and other factors?

-15-

Yes No
ii. Areas where containers are held to assure that:

1. Maximum storage capacity is not exceeded?

-2. Incompatible wastes are not stored together?

3. Ignitable or reactive waste containers are

not stored near sources of heat, ignition

or reaction?

4. Proper containers are used for holding wastes?

b. Tanks (40 CFR 265.194).

Wherever present:

i. Discharge control equipment (e.g., bypass systems)

at least once each operating day?

ii. Data ~athered from monitoring equipment (e.g.,

pressure gauges) at least once each operating day?

iii. The level of waste in the tank at least once each

operating day?

iv. The construction materials of the tank at least

weekly to detect corrosion or deterioration?

v. The construction materials of, and the area

immediately surrounding, discharge confinement

structures (e.g., dikes) for signs of erosion

or leakage (e.g., cracks, wet spots) at least

weekly?

c. Surface Impoundments (40 CFR 265.226).

i. The freeboard level at least once each operating

day?

11.. The surface impoundment, including dikes and

vegetation surrounding the dike for signs of

leaks, deterioration or failures at least

weekly?

d. Waste Piles.

1. Run-on and run-off control systems (if any) for

signs of leaks, failure or deterioration?

ii. Covers, buildings or other mechanisms (if any)

for repelling precipitation and run-on for

leaks, deterioration, or failure?

iii. Covers or other methods (if any) to prevent

wind dispersal?

-16-
e. Land Treatment.

i. Run-on and run-off control systems for signs

of leaks, deterioration or failure?

ii. Wind dispersal control measures (if any)?

iii. The land treatment area, to assure that:

1. Waste and/or material (e.g., water)

application rates are not exceeded?

2. Ignitable, reactive and/or incompatible

wastes are protected from sources of

ignition or reaction?

f. Landfills.

i. Run-on and run-off control systems for signs

of leaks, deterioration or failure?

ii. Wind dispersal control measures (if any)?

iii. Covers over any closed cells or parts of the

landfill to detect signs of erosion, leaks,

deterioration or failure of the cap?

iv. Active cells to assure that incompatible wastes

are not disposed together?

v. Cells in which ignitable wastes in containers

are disposed (if any) to assure that they are

not being exposed to materials or conditions

that could cause them to ignite?

g. Incinerators (40 CFR 265.347).

L. Existing instrumertts which relate to combustion

and emission control at least every 15 minutes

(e.g., instruments measuring waste feed, auxiliary fuel feed, air flow, temperature, scrubber

flow, scrubber pH and relevant level controls)?

ii. The complete incinerator and associated equipment

at least daily for leaks, spills, fugitive emissions and deterioration?

L1J. All emergency shutdown controls and alarm

systems at least daily to assure proper operation?

-17-
F.

h. Thermal Treatment (40 CFR 265.377).

i. Existing instruments which relate to temperature

and emission control (e.g., instruments measuring

waste feed, auxiliary fuel feed, temperature,

and relevant process flow and level controls) at

least every 15 minutes?

ii. The stack plume (emissions), observed visually

at least every hour for normal appearance (color,

opacity)?

iii. The complete treatment process and associated

equipment at least daily for leaks, spills,

fugitive emissions and deterioration?

iv. All emergency shutdown controls and alarm systems

at least daily to assure proper operation?

v. For open burning of waste explosives, the area

of open burning to assure that it meets the

minimum distance to the nearest other property

limits?

i. Chemical, Physical and Biological Treatment (40 CrR

265.403).

i. Discharge control and safety equipment (e.g.,

cut-off and bypass systems) at least once each

operating day?

ii. Data gathered from monitoring equipment at least

once each operating day?

iii. Construction materials of the treatment process

or equipment at least weekly for signs of

corrosion, leaks, deterioration, or failure?

iv . Construction materials of and areas immediately

surrounding discharge confinement structures

(e.g., dikes) at least week~y for signs of

erosion, leakage, deterioration or failure (e.g.,

cracks, wet spots, dead vegetation)?

Final Status Inspection Requirements for Specific Waste

Management Methods.

Where the following types of management methods are

employed, does the inspection schedule specify the

additional items to be inspected, inspection frequency

and types of problems to be looked for?

[Reserved. ]

-18-

Yes No
G. Ignitable or Reactive Waste Storage Inspections.

Does the % ever store ignitable or reactive wastes

at the facility?

If "Yes":

a. Are those areas where ignitable or reactive wastes

are stored inspected at least yearly by a professional

person familiar with the Uniform Fire Code, or by a

federal, state, or local fire marshal (WAC -395(1)(d))?

b. Does the % keep records of these fire inspections

which describe:

i. The dates and times of inspection and name(s)

of inspector(s)?

ii. Observations of any unsafe or improper ignitable

or reactive waste handling?

iii. Measures taken to correct any unsafe or improper

ignitable or reactive waste handling?

c. Are records of these inspections entered in the

inspection log or summary? (If "No," then these

records must be entered in the operating record.)

Yes No

Comments

-19-
7. PERSONNEL TRAINING (WAC -330).

A. Does the facility % have a written training plan, kept

at the facility site (WAC -330(2»?

B. Does the training plan include the following documents

and records:

a. For each position related to the handling of

dangerous waste on-site, the job title, name of

employee filling each job, and the job description,

including requisite skills, education, qualifications,

and duties for each position (WAC -330(2)(a»?

b. Written description of type and amount of introductory

and continuing training needed for each position

(WAC -330(2)(b»?

c. Records documenting that employees have received

and completed the necessary training (WAC -330(2)(c»?

C. Are training records retained for at least three years

after an employee last worked at the facility, 6r until

the facility closes, whichever, occurs first (WAC -330(3»?

(Note: Records may have been transferred within the

company to follow an employee. This is permissible, but

some record of the employee's transfer and continued

employment should be ~ocumented.)

D. Does the % provide a training program that teaches

personnel to perform their duties in ways that ensures

the facility's compliance with WAC 173-303 (WAC -330(1»?

E. Does the training program involve:

Classroom Instruction?

On-the-job training?

F. Is the training program directed by a perion knowledgeable in dangerous waste handling practices (WAC -330(1)(a»?

-20-

Yes No
D. Is adequate aisle space prov~ded to allow for inspections

and unobstructed movement 0f personnel, fire and spill

control equipment and decontamination equipment during

an emergency (WAC -340(3))?

E. Do the hazards posed by the wastes handled at the facility

require arrangements with local authorities? (If "Yes,"

complete the remaining questions, F. through J. below.

If "No," document under Conunents, below, why the hazards

are not such as to warrant these arrangements.)

F. Has the % arranged to familiarize police, fire

departments, and emergency response teams with: the

layout of his site; properties of wastes handled and

associated hazards; places where personnel would normally

be working; entrances to and roads on the site; and

possible evacuation routes (WAC -340(4)(a))?

G. Has the % arranged to familiarize local hospitals

with the properties of dangerous wastes handled and

the types of injuries or illnesses which could result

from fires, explosions, or waste releases (WAC -340(4)(b))?

H. Does the % have agreements with state emergency response

teams, emergency response contractors, and equipment

suppliers (WAC -340(4)(c))?

I. Where more than one party might respond to an emergency,

does the % have agreements designating primary emergency

authority and support services to be provided (WAC -340

(4)(d))?

J. Has the % documented all instances where state or local

authorities have declined to enter into the above arrangements (WAC -340(5))?

-Comments:

-------- -._-------------------------------------

---_._-- -- -..-- _._----------------------------------------------

-23-
9. CONTINGENCY PLAN, EMERGENCY PROCEDURES AND EMERGENCIES

(WAC -350 AND -360).

A. Does the % have a contingency plan designed to

lessen the potential impacts of a fire, explosion,

or unplanned sudden or nonsudden release of dangerous

wastes or dangerous waste constituents to air, soil,

surface, or ground water (WAC -350(1))?

B. Does the % have a Spill Prevention Control and

Countermeasures (SPCC) plan amended to include a

contingency plan (WAC -350(2))?

C. Are copies of the contingency plan and revisions to it:

a. Maintained at the facility (WAC -350(4)(a))?

b. Submitted to all local police departments, fire

departments and hospitals, and state and local

emergency response teams that may provide emergency assistance (WAC -350(4)(b))?

D. Is the contingency plan amended whenever:

a. Applicable regulations are revised (WAC -350 (S)(a))?

b. The plan fails in an emergency (WAC -3S0(5)(b))?

c. The facility changes in a way that increases the

potential for fires, explosions or releases, or that

changes the necessary emergency responses (WAC

-3S0(S)(c))?

d. The list of emergency coordinators changes (WAC

-3S0(S)(d))?

e. The list of emergency equipment changes (WAC -350

(S)(e))?

E. Docs Lhe contingency plan include:

a. A description of the actions pe r s onne I must Lake

in the event of an emergency circumstance (WAC -350

(3)(a))?

b. A description of the arrangements agreed to by local

police and fire departments, hospitals, contractors,

and state and local response teams to coordinate

emergency services (WAC -350(3)(c))?

c. A current list of emergency coordinators, including

names, addresses and 24-hour phone numbers (WAC

-3S0(3)(d))?

-24-

Yes No
d. If more than one emergency coordinator is listed,

identification of a primary emergency coordinator,

with the others listed in the order that they will

assume responsibility as alternates (WAC -350(3)(d))?

e. A list of all emergency equipment kept on the site,

including the location, physical description, and

brief outline of the capability of each piece of

equipment (WAC -350(3)(e))?

f. An evacuation plan (where evacuation could be

necessary) for personnel, which describes signals

to begin evacuation, evacuation routes, and alternate routes (WAC -350(3)(f))?

g. Provisions for removal of dangerous waste from the

facility in the event of a flood if the facility

is located in a 100-year floodplain (WAC -420(4)(a))?

h. Actions to be taken in the event that a dangerous

waste shipment is received which cannot be managed

at the facility and is not acceptable to the 0/0,

but cannot be transported back to the generator or

an alternate facility because it is damaged or would

pose a risk to public health or the environment

(WAC -350(3)(b))?

F. Do the information and elements described in the

contingency plan assure that the % has taken adequate

precautions for reacting to emergency circumstances?

(If "No," specify what inadequacies exist in the

Comments section, below.)

G. Is an emergency coordinator on the premises at all times

or available on-call at all times (WAC -360(1))?

II. Is the emergency coordinator (and his alternates, if any)

c ap ah l e in the foI.lowing areas (WAC -360(1)):

a. Familiar with all aspects of the contingency plan?

b. Familiar with all operations and activities on the

facility?

c. Familiar with the location and properties of all

wastes handled?

d. Familiar with the location of all records kept

on-site?

e. Familiar with the facility layout?

f. Has the authority to commit the resources needed

to carry out the contingency plan?

-25-
I. Are the following procedures implemented (or, to be

implemented) in the event of an emergency:

a. Does the emergency coordinator or his designee

(EC/D) immediately activate internal alarms or

communication systems to notify all personnel

(WAC -360(2)(a)(i)) and notify appropriate state

or local agencies with designated response roles

if help is needed (WAC -360(2)(a)(ii))?

b. Does the EC/D immediately identify the character,

exact source, amount and areal extent of any

released materials (WAC -360(2)(b))?

c. Concurrently, does the EC/D assess possible hazards

to human health and the environment (including

direct, indirect, immediate and long-term effects)

that may result from the emergency (WAC -360(2)(c))?

d. If the EC/D determines that the emergency could

threaten human health or the environment outside

the facility, does he immediately notify and

provide an assessment report (which must include

the information described under e., below) to:

i. The appropriate local authorities if evacuation

of local areas may be advisable; and remain

available to help appropriate officials decide

if local areas should be evacuated (WAC -360

(2)(d)(i))?

11. WDOE and either the government offi.cial designated

as on-the-scene coordinator, or the National

Response Center (WAC -360(2)(d)(ii))?

e. Does the assessment report (covered under d., above)

include:

i. Name and telephone number of reporter (WAC

-360(2)(e)(i))?

ii. Name and address of the faci.lity (WAC

-360(2)(e)(ii»)?

Ill. Time and type of emergency (e.g., fire, release)

(WAC -360(2)(e)(iii))?

iv. Name and quantity of materials involved (WAC

-360(2)(e)(iv))?

v. The extent of injuries, if any (WAC -360(2)(e)(v))?

vi. Possible hazards to human health and the environment off the site (WAC -360(2)(e)(vi))?

-26-
f. During an emergency, does the EC/D take all measures

necessary to ensure that fires, explosions, and

releases do not occur, recur, or spread to other

dangerous wastes (e.g., stopping processes or operations, collecting and containing releases, removing

or isolating containers, etc.) (WAC -360(2)(f))?

g. If ~perations stop in response to an emergency, does

the EC/D monitor for leaks, pressure buildup, gas

generation or ruptures wherever appropriate (WAC

-360 (2)(g))?

h. Immediately after an emergency, does the EC/D provide

for treating; storing, or disposing wastes and

materials resulting from the emergency (WAC -360

(2)(h))?

i. Does the EC/D ensure, in the affected areas on the

site, that:

i. No waste that may be incompatible with the

released material is treated, stored, or

disposed until cleanup procedures are completed (WAC -360(2)(i)(i))?

ii. All emergency equipment listed in the contingency

plan is cleaned and fit for its intended use

before operations resume (WAC -360(2)(i)(ii))?

j. Does the % notify WDOE, and appropriate local

authorities, that his site satisfies the conditions

described under i. and ii. above, before operations

resume in the affected areas of his site (WAC

-360(2)(j) )?

k. Does the % note in his operating record the time,

date, and details of incidents requiring implementation of the contingency plan (WAC -360(2)(k))?

I. Within 15 days after the emergency, does the 0/0

submit a written report of the incident to WDOE

which includes:

i. Name, address, and telephone number of the

0/0 (WAC -360(2)(k)(i)) and of the facility

(WAC -360(2)(k)(ii))?

II. Date, lime, and type of emergency (WAC

-360(2)(k)(iii))?

Ill. Name and quantity of materials involved

(WAC -360(2)(k)(iv))?

-27-
iv. The extent of injuries, if any (WAC ~360

(2)(k)(v))?

v. An assessment of actual or potential hazards

to human health or the environment, where this

is applicable (WAC -360(2)(k)(vi))?

vi. Estimated quantity and disposition of recovered

material that resulted from the incident (WAC

-360(2)(k)(vii))?

Comments:

10. PRECAUTIONS FOR IGNITABLE, REACTIVE OR INCOMPATIBLE WASTES

(WAC -395(1)).

A. Does the % ever manage ignitable, reactive or

incompatible wastes at his facility? (If "No," describe

under Comments, below what measures the % takes to

assure that no ignitable, reactive, or incompatible

wastes are managed. Do not complete the remaining

questions in this section.)

B. Does the % take precautions to prevent accidental

ignition or reaction of ignitable or reactive wastes,

including but not limited to (WAC -395(1)(a)):

.1. Scpa r a t i ng and p r o t.e c t i I1R the was t c fr.om sources

of ignition or r.eaction (e.g., open flames, smoking,

cutting and welding, hot surfaces, sparks, spontaneous ignition, and radiant heat?

-28-

Yes No
b. Confining 3moking and open flames to designated

areas· where ignitable or reactive waste is handled?

c. Posting "No Smoking" signs in conspicuous places

wherever there is a hazard from ignitable or reactive

waste?

C. [s the management of ignitable or reactive waste, and the

mixture or commingling of incompatible wastes or incompatible wastes and materials conducted so that it does

not:

a. Generate extreme heat, pressure, fire, explosion,

or violent reaction (WAC -395(1)(b)(i))?

b. Produce uncontrolled toxic mists, fumes, dusts or

gases that threaten human health or the environment

(WAC -395(1)(b)(ii))?

c. Produce uncontrolled flammable fumes or gases that

pose a risk of fire or explosion (WAC -395(1)(b)(iii))?

d. Damage the structural integrity of the tank or

equipment (WAC -395(1)(b)(iv))?

e. Otherwise threaten human health or the environment

(WAC -395(1)(b)(v))?

D. Does the % document these precautions in his operating

record (WAC -395(1)(c))?

Comments:

11. LOADING AND UNLOADING AREAS (WAC -395(4)).

Does the facility receive manifested shipments of liquid

dangerous waste for management?

-29-

Yes No
G. Do the O/O's employees participate in an annual review

of the training provided in the training program (WAC

-330(1)(b))?

H. Is the training program successfully completed by each

employee within six months of being employed at the facility,

or of being assigned to a new position, whichever is later

(WAC -330(1)(c))?

I. Are new employees supervised until they complete the

training program (WAC -330(1)(c))?

J. Does the training program:

a. Include training relevant to the positions in which

personnel are employed (WAC -330(1)(a))?

b. Instruct personnel on contingency plan implementation

(WAC -330(1)(a))?

c. Familiarize personnel with emergency equipment and

systems, and emergency procedures (WAC -330(1)(d))?

K. Where applicable, does the training program include the

following parameters (WAC -330(1)(d))?

a. Procedures for using, inspecting, repairing, and

replacing emergency and monitoring equipment.

b. Key parameters for automatic waste feed cut-off

systems.

c. Communications or alarm systems.

d. Response to fires or explosions.

e. Response to ground water contamination.

f. Shutdown of operations.

Comments: - ...----------_._--_._---------------------------_._---

----- - -- . - - --_._-_....__ ._---_.__•._- - _..__ ._------------------------

-21-
8. PREPAREDNESS AND PREVENTION (WAC -340).

A. Unless it can be demonstrated that the equipment is not

necessary (specify why not in the Comments, below), are

the following equipment present, tested regularly, and

kept in good working order:

a. Internal communications or alarm system capable of

. providing immediate emergency instructions (WAC -340

(1) (a))?

Present?

Tested regularly?

Good working order?

b. A device capable of summoning police or fire

departments or emergency response teams (e.g.,

telephone, two-way radio) (WAC -340(1)(b))?

Present?

Tested regularly?

Good working order?

c. Portable fire extinguishers, fire control equipment,

spill control equipment, and decontamination equipment

(WAC -340(1)(c))?

Present?

Tested regularly?

Good working order?

d. Water at adequate volume/pressure to supply hose

streams, foam equipment, sprinklers or spray systems

(WAC -340(1)(d))?

Present?

Tested regularly?

Good working order?

B. Whenever dangerous waste is being handled, do all

personnel involved have immedi.ate access to an i.nternal

alarm or emergency communi.cation system, either directly

or through vi.sual or voice contact with another employee

(WAC -340(2)(a))?

C. If there is ever just one employee present on the

premises, does he have immediate access to a device

(e.g., telephone, two-way radio) capable of summoning

external emergency help (WAC -340(2)(b))?

-22-

Yes No
I

I

I

If "Yes":

A. Has the % provided an area (or areas) for loading and

unloading waste shipments?

B. Is each loading/unloading area designed, constructed,

operated and maintained to:

a. Contain spills and leaks that might occur during

loading/unloading (WAC -395(4)(a))?

b. Prevent release of wastes or waste constituents

to ground or surface waters (WAC -395(4)(b))?

c. Contain washwaters (if any) from the cleaning and

decontamination of transport vehicles and load/

unload equipment (WAC -395(4)(c))?

d. Allow for removal, as soon as possible, of collected

wastes from spills, leaks and equipment washwaters

(if any) in a manner to prevent releases to ground

or surface waters (WAC -395(4)(d))?

Comments:

12. RECORDKEEPING (WAC -380).

A. Operating Record.

a. Does the % keep a written operating record at his

facility which he maintains until his facility is

closed (WAC -380(1))?

b. Does the operating record include the following

information:

i. Records and results of waste analyses (WAC

-380(l)(c))?

11. Summar.y reports and details of all incidents

that required implementing the contingency plan

(WAC -380(1)(d))?

iii. Records and results of all inspections (WAC

-380(1)(e)) (Note--This information need only

be kept for three years)?

-30-

Yes No
iv. Monitoring, testing, or analytical data as

required under the specific unit requirements

for interim and final status (e.g., ground

water monitoring data, incinerator stack

emission anaiyses, etc.) (WAC -380(1)(f))?

v. All closure and post-closure cost estimates

(WAC -380(1)(g))?

vi. For off-site facilities, copies of notices to

generators informing them the facility has all

appropriate permits (WAC -380(1)(h))?

c. Does the % keep in his operating record the

following information regarding the types of wastes

he receives or manages on-site (WAC -380(1)(a)):

i. A description of each waste providing the

common name, waste number, and physical form

(e.g., liquid, solid) (WAC -380(2)(a) and (b))?

ii. Where a waste contains more than one process

waste or waste constituent, all applicable

waste numbers or else a description of the

process which generated the waste (WAC -380

(2)(a))?

iii. The weight, or volume and density, for each

waste using the units specified in Table 1

(WAC -380(2)(c))?

Table 1

Unit of Measure

Pounds. . . . . . . .

Short tons (2000 Ibs)

Gallons (U.S.).

Cubic ya r d s". . .

Ki lograms . . . .

Tonnes (1000 kg).

Liters. . . .

Cubic meters ...

Symbol

P

T

G

Y

K

H

L

C

Density

PIG

T/Y

K/L

H/C

iv. The date and method of management for each waste,

using the handling code(s) specified in Table 2

of WAC -380(2) (WAC -380(2)(d))?

d. Does the % include in his operating record the

location of each waste within his facility and the

quantity at each location, and a cross-reference

to specific manifest document numbers for each

waste that was accompanied by a manifest (WAC

-380 (l)(b))?

-31-
e. If this is a disposal facility, does the a/a include

a map or diagram of each cell or disposal area in his

operating record to record the location and quantity

of each waste (WAC -380(1)(b))?

B. Does the % ever manage ignitable, reactive, or incompatible wastes at his facility?

If "Yes":

a. Does the % include in his operating record records

of the annual inspection by a Fire Marshall or other

professional familiar with the Uniform Fire Code

(WAC -395(l)(d))? (If "No," then these records must

be entered in his inspection log or summary.)

b. Does the operating record include documentation that

the % manages his ignitable, reactive, or incompatible wastes in accordance with WAC -395(1)(a) and

(l)(b) (e.g., does not cause extreme heat or pressure, toxic mists or fumes, damage facility integrity,

etc.) (WAC -395(1)(c))? (Note--This documentation

may be based on references to published scientific or

engineering literature, data from trial tests, waste

analyses, or the results of managing similar wastes

by similar processes and operating conditions.)

C. Does the % provide copies of all records, including

plans, to WDOE upon request and make them available

for inspection at all reasonable times (WAC -380(3)(a))7

D. Will the % be sending copies of records of waste

disposal locations and quantities at the time of his

facility's closure to WDOE, EPA Region X Administrator,

and the local land use and planning authority (WAC

-380(3) (c))?

Comments:

-32-
13. REPORTING (WAC -390).

A. Unmanifested Waste Reports.

If the % receives from off-site a shipment of waste

which was not manifested but. should have been, then

does he submit a Form 6 - Unmanifested Waste Report to

WDOE within 15 days of receiving the shipment (WAC -390(1))?

List the dates below that such reports were sent:

B. Annual Reports.

a. Does the % submit a Form 5-TSD Facility Annual

Dangerous Waste Report to WDOE by March 1 of

each year reporting the previous calendar year's

waste management activities at the facility (WAC

-390(2))?

b. If the % ships waste off-site, does he submit

a Form 4-Generator Annual IDangerous Waste Report

to WDOE by March 1 of each year reporting the

wastes for which he acted as a generator during

the previous calendar year (WAC -390(2))?

C. Additional Reports.

Does the % provide the following additional reports

to WDOE (WAC -390(3)):

a. Reports of releases, fires, and explosions as

required by the emergency procedures of WAC

-360(2)(k)?

b. Interim status ground water monitoring data, as

specified in 40 CFR 265.94(a)(2) and (b)(2) (if

applicable)?

c. Any other reports required by WDOE (list these

reports, if any, and dates submitted under

Comments, below)?

-33-

Yes No
Comments:

-34-
DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE, CHAPTER 173-303 WAC

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

PART V: INTERIM STATUS TSD FACILITY UNITS

This part of the checklist/questionnaire is applicable to all TSD facilities operating

under i.n t.e r i.rn status, except for those facilities or portions of facilities 'which are

pul)licly owned treatment works (POTW), or are conducting elementary neutralization,

t.o t a l Ly e nc l os ed t.rea trneu t. or ....-a s t.ewa ce r treatment as these processes are de f i.ne d

ill WAC -040 [Nole--These processes are provided a permit by rule under WAC -802(4)

and (5) if certain cond i ti.ou s are met. These conditions are certain general facility

requiremetlts covered under Part IV: General TSD Facility Requirements of this checklist

questionnaire. If these cond it Lon s are not met and WDOE has revoked the permit by

rule, then saint' or all of thi.s Part V may be applicable].

The abbreviation "0/0" is used frequently throughout this part of the checklist/

questionnaire and stands for the words "owner and/or oper.ator."

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

Fac i lit.y Name

Lns pe c t.o r ' s Name

EPA/State lOfl

Date

Check the type(s) of unit operations that the % conducts at his facility and complete

the sections of this Part V of the checklist/questionnaire identified for each type of

unit.

Containers (complete section 1.)

Tanks (complete section 2.)

Su r fa co Impoundments (complet.e section 3.)

Pi I(,s (cumplt'le s e c t IOU 4.)

1..lllet TI'l':Illllt'lll (complt'lt' sect i on S,)

1,,'11<11 ills tcoml'l('lt' s e-vt i o n b,)

l nc i ue r a t o r s (complele section 7.)

The rma l Tr-eatment (complete section 8.)

Chemical, Physical, and Biological. Treatment

(complete section 9.)
r:

1.

A. Condition of containers (265.171).

3. Are all containers holding wastes in good condition

and free of leaks?

If "No," describe the number, quantity, and contents

of the bad or. leaking containers, and describe the

specific condition of these containers

b. If a container is not in good condition or begins

to leak, does the % either:

i. Transfer the waste from the bad containers

to a container in good condition?

ii. Or else manage the waste in same other way

that complies with WAC 173-303 (de~cribe

these procedures under Comments, below)?

B. Management of containers (265.173).

a. Are all containers holding wastes kept closed

during storage except ....-hen adding or removing

....-a s t.e s ?

h. Ar« all wasL(' con t.a i ne r s being:

I. Stored ill a manner thal prevenls leaks

or r-uplures?

11. Handled in a manner t.ha t, prevents leaks or

ruptures?

iii. Opened in a manner that prevents leaks or

ruptures'?

-2-

Yes No
C. Ignitable or reactive wastes (265.176).

a. Ar-e container-s holding r-eactive wastes that ar-e

capable of detonation or- explosion (designated by

WAC -090(7)(a)(vi), (vii) or (viii)) stored with

a buffer- zone equivalent to the Unifor-m Fir-e

Code's "Amer-ican Table of Distances for Storage

of Explosives," Table 77-201, 1979 Edition (WAC

-440(1) (b))?

b. Are container-s holding ignitable wastes and

r-eactive wastes (other than those cited in a.

above) stored at least fifty feet from the

facility's property line?

D. Container compatibility (265.172) and incompatible

wastes (265.177).

a. Are all container-s made of or lined with materials

which will not react with and are other-wise compatible with the waste to be stored, so that the

ability to contain the waste is not impaired?

b. Are incompatible wastes or incompatible wastes

and materials ever placed in the same container,

or are wastes ever placed in unwashed containers

which previously held incompatible wastes?

If "Yes," ar-e these practices conducted in a

manner that assures compliance with WAC -395(1)(b)?

(Be sure to complete section 10.~of Part IV:

General TSD Facility Requirements of this

checklist/questionnaire.)

r. I f wastes in container-s are stor-ed near- a ny

wastes or- mater-ials that ar-e incompatible, are

the waste containers protected fr-om these

incompatible wastes or mater-ials by means of

a dike, herm, wal I, or other cievice?

If "Yes," descr-ibe the device.

-3-
Comments:

--_._--- _._._--- -----_._--------------------

_._- _. __ ._- _._----_._-------------_.

------------------------------

-4-
2. TANKS (40 CFR PART 265 SUBPART J).

A. General operation (265.192).

a. Is each tank:'

1. Tn good operating condition?

11. Free of leaks, cracks, ruptures, seam and

fixture weaknesses, and any other prohlems

that could lead to loss of wastes due to

structural failures?

If "No," describe any problems that were observed.

b. Does the % ever add wastes or treatment reagents

to a tank which could cause the tank or its inner

liner to rupt~re, leak, corrode, or otherwise

ta i i he f'o r e the e nd of its intended life?

c: . • For any un cov e r e d tanks, is each tank e- i t he r :

i. Operated L.U ensure at least two feet (s i.x t y

centimeters) of freeboard?

i i . Or else, equipped with a containment

structure (e.g., dike or trench), a drainage control system, or a diversion structure

(e.g., standby tank), with a capacity that

equals or exceeds the volume of the top two

feet (60 em) of the tank? (Note for calculation purposes: 1 cubic foot = 7.48 gaLlons;

1 c-ub i c meter = 264.2 gallons.)

d. Ar.e any tanks operated with continuous waste feed?

If "Yes":

I. Des c r i he- which tanks and was t.e s are continuous

feed systems (if all, just write "I\U").

-5-

Yes No
J 1. Are these tanks equipped with a means to stop

the waste inflow?

Describe the means (e.g., feed cutoff, bypass

to standby tank,etc.).

B. Ignitable or reactive wastes (265.198).

a. Are ignitable or reactive wastes ever placed in

tanks?

If "Yes," does the % either:

i. Use these tanks solely for emergencies?

ii. Or else, store or treat the wastes in such

a way that they are protected from materials

or condiLions which may cause igniLi.on or

reaclion?

iii. Or plsf', t r e-a t. , r e nde r , or mix the wastes

before 01' immediaLely after placement i.n the

tank so that the wastes are not ignitable or

reactive (by WAC -090(5) and (7)), and so

that treating or mixing complies with WAC

-395(1)(b)? (NoLe--If % conducts this

"a c t i.v i t y , be sure Lo complete section 10. of

Part IV: General TSD Facility Requirements

of this checklist/questionnaire.)

Describe whi r h tanks, if any, receive ignitable or

reaclive wastes,

-6-
-- _._-_._.._- '---'--- .. ------------ ------------

b. Are tanks holding reactive wastes that are capable

of detonation or explosion (designated by WAC -090

(7)(a)(vi), (vii) or (viii)) located with a buffer

zone equivalent to the Uniform Fire Code's "American

Table of Distances for St.ora ge of Explosives,"

Table 77-201, 1979 Edition (WAC. -440(l)(b))?

c. Are covered tanks used for holding ignitable or

reactive wastes located with a buffer zone

equivalent to the National Fire Protection Association's requirem~nts for tanks, contained in

Tables 2-1 through 2-6 of "The Flammable and

Combustible Liquids Code - 1981?"

C. Incompatible wastes (265.199).

If the % conducts the following activities, are these

activities conducted so as to comply with WAC -395(1)(b)

(Note--If the % conducts these activities and compliance

with WAC -395(1)(b) is required, be sure to complete

section 10. of Part IV: General TSD Facility Requirements of this checklist/questionnaire):

a. Tre<ltment. or storage of wastes in tanks?

h. Pl<lcement. of incompatible wastes, or incompatible

wastes and materials in the same tank?

c. Placement of wastes in an unwashed tank which

previously held incompatible wastes or materials?

Describe which tanks receive incompatible wastes and

what those wastes are.

-----------.----

-7-
Comments:

-8-
3. SURFACE IMPOUNDMENTS (40 CFR PART 265 SUBPART K).

A. Operation and containment (265.222 and 223).

a. Does the % maintain each surface impoundment's

freeboard to:

i. Be at least two feet (sixty centimeters)?

ii. Prevent any overtopping of the dike due to

overfilling, wave action or a storm (Note--

This requirement may result in the need for

more than two feet of freeboard.)?

b. Do all earthen dikes (if any) have a protective

cover (e.g., grass, shale, rock) to minimize wind

and water erosion and to preserve structural

integrity?

B. Ignitable or reactive wastes (265.229).

Are ignitable or reactive wastes ever placed in the

surface impoundment(s)?

If "Yes," does the % either:

a. Use the surface impou~dment(s) solely for

emergencies?

b. Or else, treat, r.ender, or. mix the wastes before

or immediately after. placement in the surface

impoundment(s) so that the wastes are not ignitable or. reactive (by WAC -090(5) and (7)), and

so that the treating or mixing complies with WAC

-395(1)(b)? (Note--If % conducts this activity,

be sure to complete section 10. of Part IV: General

TSD facility Requirements of this checklist/

questionnaire.)

Describe which surface impoundments (if any) receive

ignitable or reactive wastes.

-------------------------

------------------------------

-9-

Yes No
C. Incompatible wastes (265.230)

Are incompatible wastes or incompatible wastes and

materials ever placed in the same surface impoundment(s)?

If "Yes";

3. Does the % do this in a manner that assures

compliance with WAC -395(1)(b)? (Note--Be sure

to complete section 10. of Part IV: General TSD

Facility Requirements of this checklist/

questionnaire.)

b. Describe which surface impoundments receive

incompatible wastes and what those wastes are.

Comments:

-.- _- _ _-_._--_.._-_._.._--------------

-10-
4. WASTE PILES (40 CFR PART 265 SUBPART L).

A. Wind protection (265.251).

If the wastes in the pile(s) could be subject to wind

dispersal, does the % cover or otherwise manage the

pile(s) to prevent wind dispersal?

B. Containment (265.253).

[s leachate or runoff from the pile(s) a dangerous

waste?

If "Yes," then does the % either:

a. Protect the pile(s) from precipitation and run-on,

and prevent the addition of liquids or wastes

containing free liquids to the pile(s)?

b. Or else, perform all of the following actions:

i. Place the pile(s) on an impermeable base that

is compatible with the wastes under the

conditions of treatment or storage?

ii. Design, construct, operate, and maintain a

run-on control system capable of preventing

flow onto the active portion of the pile(s)

during peak discharge from at least a twentyfive year storm?

iii. Design, construct, operate, and maintain a

run-off management system to collect and

control at least the water volume resulting

from a twenty-four hour, twenty-five year

storm?

iv. Empty or otherwise manage run-on and run-off

collection and holding facilities (e.g., tanks,

basins) as quickly as possible to maLntain

~esign capacity of the systems? (Note--Collected

run-off should be checked to determine if it

is dangerous waste and, if so, managed

accordingly. )

C. 19niLable or reactive wastes (265.256).

Are ignitable or reactive wastes ever placed in the

pile(s)?

If "Yes," does the a/a either:

-11-

Yes No
a. Manage the wastes in such a way that they are

protected from any materials or conditions which

may cause them to ignite or react?

b. Or else, treat, render, or mix the wastes before

or immediately after placement in the pile(s) so

that the wastes are not ignitable or reactive (by

WAC -090(5) and (7)), and so that the treating or

mixing complies with WAC -395(1)(b)? (Note--If

0/0 conducts this activity, be sure to complete

section 10. of Part IV: General TSD Facility

Requirements of this checklist/questionnaire.)

Describe which pile(s) (if any) receive ignitable or

reactive wastes.

D. Incompatible wastes (265.257).

a. Are incompatible wastes, or incompatible wastes

and materials ever placed in the same pile(s), or

are wastes ever piled on the same area(s) where

incompatible wastes or materials were previously

piled without the area(s) being decontaminated?

If "Yes":

i. Does the D/O do this in a manner that assures

compliance with WAC -395(1)(b)? (Note--Be sure

to complete section 10. of Part IV: General

T80 Facility Requirements of this checklist/

'lues t i anna i.r e . )

ii. Describe which pile(s) receive incompatible

wastes and what those wastes are.

-12-
b. If a pile of waste is incompatible with any was~e

or other material stored nearby in other containers,

piles, open tanks, or surface impoundments, then

does the % separate the pile from the other incompatible wastes or materials or otherwise protect

them by means of a dike, berm, wall, or other

device?

Describe the device(s) used to separate and protect

the incompatible wastes or materials.

Comments:

-13-
~. LAND TREATMENT (40 erR PART 265 SUBPART M).

A. General operation (265.272).

a. Is the land treatment unit effective in making the

applied wastes less hazardous or nonhazardous by

biological degradation or chemical reaction occurring in or on the soil?

If "No," describe the basis for this determination.

b. Has the % designed, constructed, operated, and

maintained a run-on control system capable of

preventing flow onto active portions during peak

discharge from at least a twenty-five year storm?

c. Has the % designed, constructed, operated, and

maintained a run-off management system capable of

collecting and controlling a water volume at least

equivalent to a twenty-four hour, twenty-five

year storm?

d. Are collection and holding facilities (e.g., tanks,

basins) associated with run-on and run-off control

systems emptied or otherwise managed expeditiously

after storms to maintain design capacity of the

systems? (Note--Run-off may be a dangerous waste

and, if designated, must be managed appropriately.)

e. If the treatment zone contains particulate matter

which may be subject to wind dispersal, does the

0/0 manage the unit to control wind dispersal?

What methodes) does he use?

-14-

Yes No
B. Unsaturated zone monitoring (265.278).

a. Does the % have in w~iting and does he implement

an unsaturated zone monito~ing plan?

Is the plan designed to:

i. Detect the vertical migration of wasle and

waste constituents under the active portions?

11. Provide information on the background

concentrations of the waste and waste constituents in similar but untreated soils

nearby?

b. Does the % keep the monitoring plan and the

rationale used in developing the plan at his

facility?

c. Does the monitoring plan include, at a minimum:

i. Soil monitoring using soil cores?

ii. Soil-pore water monitoring using devices such

as lysimeters?

d. In order to detect the vertical migration of waste

and waste constituents below the active portions

of his facility, does the % demonstrate in his

monitoring plan that:

i. The depth at which soil and soil-pore water

samples are to be taken is below the depth to

which waste is incorporated into the soil?

11. The number of soil and soil-pore water samples

to be taken is based on the variability of:

l. The waste constituents (as identified

in the facility waste analysis plan)

in the waste and soil?

2. The soil types?

Ill. The fre4uency and timing of soil and soil-pore

watf'[ sampling is based on the f~e4lJency.

time, and rate of waste application, p~oximity

to g~ound wate~, and soil permeability?

e. Does the % analyze the soil and soil-pore water

samples fo~ the waste constituents that we~e found

in the waste during analysis under his waste

analysis plan?

-15-

~.
C. Ignitable and reactive wastes (265.261).

Are ignitable or reactive wastes ever land treated?

If "Yes," does the % either:

a . Hana ge t he waste in s uch a ...·ay that it is p r o t.e c t.r-d

from any material or condition which could cause

it to ignite or react?

b. Or else, treat, render, or mix the wastes before

or immediately after placement in the land treatment

unites) so that the wastes are not ignitable or

reactive (by WAC -090(5) and (7)), and so that

the treating or mixing complies with WAC -395(1)(b)?

(Note--If % conducts this activity, be sure to

complete section 10. of Part IV: General TDS Facility

Requirements of this checklist/questionnaire.)

Describe which land treatment units (if any) receive

ignitable or reactive wastes.

D. Incompatible wastes (265.282).

Are incompatible wastes or incompatible wastes and

materials ever placed in the same land treatment unites)?

If "Yes":

a. Does the % do this in a manner that assures

compliance with WAC -395(1)(b)? (Note--Be sure

to complete section 10. of Part IV: General TSD

Facility Requirements of this checklist/

questi.onnaire.)

b. Describe which land treatment units receive

incompatible wastes and what those wastes are.

-16-
E. Food chain crops (265.276).

Does the % grow food chain crops on the treated areas

of any of his land treatment units?

If "No," then do not answer the remaining questions

under this item. If "Yes," then continue with the

remaining questions.

a. Has the % notified WDOE that he is growing

food chain crops on his land treated areas?

b. Can the % demonstrate, based on field testing,

that any arsenic, lead, mercury, or other waste

constituents identified pursuant to the facility

waste analysis plan will either:

i. Not be transferred to the food portion of

the crop by plant uptake or direct contact,

and will not otherwise be ingested by food

chain animals?

ii. Or else, not occur in greater concentrations

in the crops grown on the land treatment

facility than in the same crops grown on

untreated soils under similar conditions in

the same region?

c. Whe!1 making either of the demonstrations described

under b., above, is t.he information us e d to make

t.he demonst.ration:

1. Kept a t the f a c i l Lty?

ll. Based on tests for the specific waste and

application rates being used at the facility?

iii. Inclusive of descriptions of crop and soil

characteristics, sample selection criteria,

sample size determination, analytical methods,

and statistical procedures?

-17-
d. Does the waste applied to treatment areas where

food chain crops are grown contain cadmium?

If "Yes," does the % satisfy the requirements

of either e. or f., below?

e. Does the % perform or assure that all of the

following actions oc-cur:

i. Unless the waste contains two mg/kg (dry

weight) cadmium or less, is the pH of the

waste and soil mixture 6.5 or greater

at the time of each waste application?

ii. If the land treatment area is used for

production of tobacco, leafy vegetables or

root crops for human consumption, is the

annual application of cadmium from waste

less than 0.5 kilograms per hectare (kg/ha)?

(Note--One hectare equals 10,000 square

meters, and equals 2.741 acres.)

iii. For any other food chain crops, is the annual

application of cadmium from waste less than:

1. 1.25 kg/ha from July 1, 1984 to

December 31, 1986?

2. 0.5 kg/ha beginning January 1, 1987?

iv. If the background soil pH is greater than

6.5, or if the pH of the waste and soil

mixture is adjusted to and maintained at

6.5 (even though the background soil pH is

less than 6.5) while crops are grown, then

is the cumulative application of cadmium

from waste less than the amounts shown in

the following table?

Soil Cation Exchange

Capacity (meq/lOOg)

Less than 5

5 to 15

Greater than 15

Maximum Cumulative

~cation (kg/ha)

5

10

20

v. If the background soil pH is less than 6.5 (and

the waste/soil mixture pH is not adjusted to

6.5 or greater while crops are grown), is the

cumulative application of cadmiUm from waste

less than 5.0 kg/ha?

-18-
f. Or, does the % perform or assure that all of the

following actions occur:

i. Is animal feed the only food chain crop produced?

ii. Is the pH of the waste and soil mixture at the

time of waste application or at the time the

crop is planted, whichever occurs later, at

6.5 or greater?

iii. Is a pH of 6.5 or greater in the waste and

soil mixture maintained whenever food chain

crops are grown?

iv. Is there a facility operating plan which

demonstrates how the animal feed will be

distributed to prevent ingestion by humans?

v. Does the facility operating plan descr.ibe the

measures to be taken to safeguard against

possible health hazards from cadmium entering

the food chain, which may result from alternative land uses?

vi. Is there a stipulation in the land record or

property deed which states that the property

has received waste at high cadmium application

rates and that food chain crops must not be

grown except in compliance with the actions

described in f. i. through vi., above?

Comments:

-------------------------------------------

----------------------------------------------------

-19-
6. LANDFILLS (40 CFR PART 265 SUBPART N).

A. General operation (265.302).

a. Has the % designed, constructed, operated, and

maintained a r.un-on control system capable of

preventing flow onto active portions during peak

discharge from at least a twenty-five year storm?

b. Has the % designed, constructed, operated, and

maintained a run-off management system capable of

collecting and controlling a water volume at least

equivalent to a twenty-four hour, twenty-five

year storm?

c. Are collection and holding facilities (e.g., tanks,

basins) associated with run-on and run-off control

systems emptied or otherwise m~naged expeditiously

after storms to maintain design capacity of the

systems? (Note--Run-off may be a dangerous waste

and, if designated, must be managed appropriately.)

d. If the landfill contains particulate matter which

may be subject to wind dispersal, does the 0/0

manage the unit to control wind dispersal?

What methodes) does he use?

e. Does the % assure that wastes which are designated

as organic carcinogens or EHW are never disposed of

in his landfill (WAC -400(3)(b)(ii))?

B. Ignitable or reactive wastes (265.312).

Are ignitable or reactive wastes ever placed in the

landfill?

If "Yes," does the % either:

a. Tr.eat, render, or mix the wastes before or

immediately after placement in the landfill so

that the wastes are not ignitable or reactive (by

-20-

Yes No
WAC -090(5) and (7)), and so that the treating

or mixing complies with WAC -395(1)(b)? (Note--

If % conducts this activity, be sure to complete

section 10. of Part IV: General TSD Facility

Requirements of this checklist/questionnaire.)

h. Or else, for ignitable wastes only:

1. Landfill the wastes only in nonleaking

containers?

ii. Dispose the wastes in such a way that they

are protected from materials and conditions

(e.g., heat, sparks, rupture) that may cause

the wastes to ignite?

111. Cover the wastes daily with soil or other

noncombustible material to minimize ignition

potential?

iv. Prevent disposal of the wastes in cells that

contain or will contain other wastes which

may generate heat sufficient to cause ignition

of the wastes?

Describe which landfill cells (if any) receive

ignitable or reactive wastes.

C. Incompatible wastes (265.313).

Are incompatible wastes or incompatible wastes and

materials ever placed in the same landfill cell?

If "Yes":

a. Does the % do this in a manner that assures

compliance with WAC -395(1)(b)? (Note--Be sure

to complete section 10. of Part IV: General TSD

Facility Requirements of this checklist/questionnaire.)

-21-
b. Describe which landfill cells (if any) receive

incompatible wastes and what those wastes are.

D. Liquid waste (265.314).

a. Does the % ever receive (or generate, if disposing

of his own wastes) bulk or noncontainerized liquid

wastes for disposal in his landfill?

If "Yes," i.s this waste either:

i. Solidified or chemically fixed to be a solid

prior to disposal?

ii. Mixed with absorbent and placed in containers

for disposal?

b. Does the % ever landfill containers which hold

free liquids?

If "Yes," are all such containers either:

I. Very small, such as an ampule?

ii. Or, designed to hold free liquids for use

other than storage (e.g., battery, capacitor)?

iii. Or, labpacks (overpacked drums)?

be sure to complete the questions

below. )

(If "Yes,"

for labpacks,

iv. Or, managed so that all free-standing liquid

has been: removed (decanted or drained); mixed

with absorbent or solidified; or otherwise

eliminated?

E. Containers and labpacks (265.315 and 316).

a. Are empty containers crushed flat, shredded, or

similarly reduced in volume before burial?

-22-
b. Does the % place overpacked drums (labpacks)

in the landfill?

If "Yes," does the % observe the following

requirements:

1. Are all inside containers sealed tightly,

nonlpaking, and made of materials that will

not react with or be ignited or de~omposed

by the wastes they contain?

II.. If DOT regulations (49 CFR Pa r t s 173, 178,

and 179) specify particular inside containers

for the wastes, are these regulations followed?

iii. Are the inside containers overpacked in an

open head DOT specification metal shipping

container (49 CFR Parts 178 and 179) of no

more than 110 gallons (416 liters) capacity?

iv. Is the overpack container filled with absorbent

material sufficient to absorb the liquid contents

of all inside containers and to completely fill

the overpack container (i.e., no partially full

overpack containers may be landfilled; extra

space must be filled with absorbent)?

v. Are the absorbent materials used not capable

of reacting with or being ignited or decomposed

by the contents of the inner containers?

vi. Does the % assure that incompatible wastes

are not enclosed in the same overpack container?

vii. Are all reactive wastes, other than cyanide or

sulfide bearing reactive wastes, treated or

rendered nonreactive prior to overpacking?

Comments:

---------------------------------------------

-23-
7. INCINERATORS (40 CFR PART 265 SUBPART 0).

A. Exemption from incinerator standards (265.340).

Does the % burn only the wastes described below, and

has he documented, in writing, that the wastes would

not reasonably be expected to contain any of the

dangerous waste constituents listed in WAC 173-303-

9905, and is this documentation retained at his facility?

a. Wastes listed as dangerous solely because they are

ignitable and/or corrosive, or wastes designated

as dangerous solely because of the characteristics

of ignitability and/or corrosivitYi and

b. Wastes listed as dangerous or designated by the

characteristics as dangerous solely due to the

reactivity characteristics of WAC 173-303-090

(7)(a)(i), (ii), (iii), (vi), (vii), or (viii),

provided that these wastes are not burned when

other dangerous wastes are present in the combustion zone.

If "Yes," then the % is exempt from all interim status

incinerator requirements except 265.351, Closure. Complete

only those questions under item C. Closure, below.

B. Operation (265.345 ~nd 347(a)).

a. . During startup and shutdown of the incinerator,

does the % assure that wastes are not fed to

the incinerator unless steady state conditions of

operation have been achieved (including steady

state operating temperature and air flow)?

b. Does the % immediately make appropriate corrections,

either automatically or manually, to maintain

steady state combustion conditions whenever necessary?

C. Closure (265.351).

At closure, will (or has) the % remove all wastes and

waste residues from the incinerator (including but not

limited to ash, scrubber waters, and scrubber sludges)

and, if designated as dangerous wastes, manage them

accordingly? (Note--This responsibility and measures for

accomplishing associated actions must be specified in

the O/O's closure plan.)

-24-

Yes No
Comments:

-25-
8. THERMAL TREATMENT (40 CFR PART 265 SUBPART P).

A. Operation (265.373 and 377(a)(1) and (2)).

a. Unless his process is a noncontinuous (batch)

thermal treatment process which requires a complete

thermal cycle to treat discrete quantities, does

the % bring his process to steady state (normal)

conditions of operation using auxiliary fuel or

other means prior to adding dangerous wastes?

b. Does the % immediateLy make appropriate corrections,

either automatically or manually, to:

i. Maintain steady state or other appropriate

thermal treatment conditions whenever necessary?

ii. Return any visible air emissions to their

normal appearance whenever changes in appearance occur?

B. Closure (265.381).

At closure, will (or has) the % remove all wastes and

waste residues from the thermal treatment process and

equipment (including but not limited to ash, scrubber

waters and scrubber sludges) and, if designated as

dangerous wastes, manage them accordingly? (Note--

This responsibility and measures for accomplishing

associated actions must be specified in the a/a's

closure plan.)

C. Open burning of waste explosives (265.382).

a. Does the % ever open burn or detonate waste

explosives (e.g., military propellants, dynamite,

fireworks) which cannot be safely disposed of

through other modes of treatment? (Note--Open

burning of any other types of dangerous wastes is

prohibited.)

b. I f "Yes," does the a/a conduct such open burning

or detonation in a manner that protects public

health and the environment, and in accordance

with the following table?

Yes No

Pounds of waste

explosives

o to 100

101 to 1,000

1 ,00 1 to 10,000

10,001 to 30,000

Minimum distance of

open burning/detonation

to property of others

670 feet (204 m.)

1,250 feet (380 m.)

1,730 feet (530 m.)

2,260 feet (690 ro.)

-26-
Comments:

-27-
9. CHEMICAL, PHYSICAL, AND BIOLOGICAL TREATMENT (40 CFR PART 265

SUBPART Q).

A. Operation (265.401).

a. Does the % assure that wastes or treatment

reagents are not introduced to the treatment

process or equipment if they could cause ruptures,

leaks, corrosion, or other failures?

Describe how the % makes these assurances:

b. Where waste is continuously fed into the treatment

process or equipment, is the equipment or process

equipped with a means to stop the inflow (e.g.,

waste feed cutoff system, bypass system)?

c. When treating wastes, does the % assure that

the treatment is conducted so as not to:

i. Generate extreme heat or pressure, fire,

or explosion or violent reaction?

11. Produce uncontrolled toxic mists, furnes ,

dusts, or gases in sufficient quantities

to threaten hl~an health or the environment?

iii. Produce uncontrolled flammable fumes or gases

in sufficient quantities to pose a risk of

fires or explosions?

iv. Damage the structural integrity of the facility

or device containing the wastes?

v. Through other like means, threaten human

health or the environment?

Describe how the % makes these assurances:

-28-

Yes No
B. Ignitable or reactive wastes (265.405).

If ignitable or reactive wastes are placed in a

treatment process or equipment, does the % treat,

render, or mix the wastes before or immediately after

placement in the treatment process or equipment so

that the wastes are not ignitable or reactive (by

WAC -090(5) and (7)), and so that the treating or

mixing complies with WAC -395(1)(b)? (Note--If 0/0

conducts this activity, be sure to complete section 10.

of Part IV: General TSD Facility Requirements of this

checklist/questionnaire.)

Indicate which treatment units receive ignitable or

reactive wastes:

C. Incompatible waste: (265.406).

Are incompatible wastes or incompatible wastes and

materials ever placed in the same treatment process

or equipment, or are wastes ever placed in unwashed

treatment equipment which previously held incompatible

wastes or materials?

If "Yes":

a. Does the % do this in a manner that assures

compliance with WAC -395(l)(b)? (Note--Be sure

to complete section 10. of Part IV: General TSD

Facility Requirements of this checklist/

questionnaire.)

-29-
b. Describe which treatment processes or equipment

receive incompatible wastes and what those wastes

are.

D. Closure (265.404).

At closure, will (or ha~) the % remove ~ll wastes and

waste residues from treatment processes or equipment,

discharge control equipment, and discharge confinement

structures and, if designated as dangerous wastes,

manage them accordingly? (Note--This responsibility and

measures for accomplishing associated actions must be

specified in the O/O's closure plan.)

Comments:

--------------

-30-

•
DANGEROUS WASTE COMPLIANCE CHECKLIST/QCFSTIONNAIRE

CHAPTER 173-303 WAC

* * * * * * * * * * '!: * * *

Part 6: Closure

This part of the checklist/questionnaire is applicable

to all dangerous waste management facilities operating

under interim status. Dangerous waste facilities may

include containers, tanks, surface impoundments, waste

piles, thermal treatment, chemical, physical and

biological treatment, land treatment, incinerators, and

landfills.

The abbreviation "0/0" is used frequently throughout

this checklist/questionnaire and stands for the words

"owner and/or operator."

The questions in the checklist have been written in a

manner such that they can be answered either "Yes" or

"No." However, the answers to some questions may

require additional explanation. The space provided for

comments at the end of each se.ction may be used for

explanations. If a question does not apply t o a

particular facility, simply write "NA" (not applicable)

next to the question.

~§:~o~~~

KWR\mUS W~li DW\S\OK
CLOSURE PLAN CHECKLIST

6.1. GENERAL FACILITY I~FOR}~TION

Facility Name:

Inspectors Name:

EPA/State I.D.: #

-------

Date:

Check the type(s) of unit operations that the % manages at his

facility (refer to 6.3 for Unit Specific Requirements):

Page No.

o

o

o

o

o

o

o

o

o

Containers

Tanks ...

Surface Impoundments .

Piles. • . . .

Land Treatment

Landfills. . .

Incinerators

Thermal Treatment.

Chemical, physical and biological

treatment. . . .. . ...•.

- 2 -

13

14

15

16

17

18

19

20

21
6.2. GENERAL CLOSURE REQUIREMENTS

1. WRITTEN PLAN

YES NO

A.

B.

Is there a WRITTEN CLOSURE PLAN kept

at the facility? (40 CFR 261.112(a»

Does the closure plan cover all areas

and facilities that were ACTIVE as of

11/19/80?

C. Does the closure plan include general

information about the facility which

would be helpful in reviewing the plan,

including (Note: regulations do not

presently require the inclusion of the

following information. However, inclusion

of this information will aid in the

review of the plan.):

a. facility size(s)

b. facility type(s)

c. descriptions of all on-site

equipment

d. topography

e. waste characterization

f. soil type

g. description of surrounding land use

h. surrounding population

i. size of facility (acres)

j. volume of impoundment

k. type(s) of treatment/processing

1. description of liner

m. leachate collection system

n. gas collection system

o. dredging procedures/schedules, etc.

p. incinerator specifications

q, other (specify )

Comments:

- 3 -
2. MAXIMUM EXTENT OF OPERATION (40 CFR 265.112(a)(1))

A. Does the plan identify the MAXIMUM EXTENT OF

OPERATION which will be unclosed during the

life of the facility?

B. Is the MAXIMUM EXTENT OF OPERATION estimate

exceeded by current operations?

C. Does the MAXIMUM EXTENT OF OPERATION estimate

include:

a. the maximum area of landfill or land

treatment ever containing wastes?

b. inactive areas open because of

operating problems or contingencies?

c. maximum area of land ever used for

land spreading?

d. the most extensive treatment required

for land spreading?

e. the maximum area used for storage?

Explain each "NO" answer.

Comments:

3. PARTIAL CLOSURE (40 CFR 265.112(a))

A. Does the plan identify the steps for

PARTIAL CLOSURE, at any time during the

intended operating life, of

YES NO

r ••••••

a.

b.

c.

d.

surface impoundments?

landfills?

tanks?

other (specify: ) ---------- IF NO PARTIAL CLOSURE PLAN, WRITE N/A AND

SKIP TO SECTION 5.

B. Does the PARTIAL CLOSURE Plan identify

a. the size of areas partially closed

b. procedures for partial closure?

c. maintenance program?

d. frequency of partial closures?

e. source of cover materials?

- 4 -
C. Does the plan for PARTIAL CLOSURE

demonstrate the adequacy of the cap,

etc. to meet the closure requirements?

OR

Are these areas or activities otherwise

included in the extent of operations of

the closure plan? (Note: If PARTIAL

CLOSURE operations would not satisfy

closure requirements, the plan must

indicate how and when those requirements

will be met , )

Does the PARTIAL CLOSURE PLAN describe

maintenance activities for partially

closed areas, including:

a. visual ipspections?

b. groundwater monitoring?

c. maintaining cover?

d. maintaining diversion structures?

e. controlling erosion?

f. maintaining vegetation?

g. security requirements?

h. leachate collection?

i. gas collection?

YES NO

D. Does the CLOSURE PLAN describe

maintenance frequencies for partially

closed areas, including:

a. visual inspections?

b. groundwater monitoring?

c. maintaining the cover?

d. maintaining diversion structures?

e. controlling erosion

f. maintaining vegetation?

g. security requirements?

h. leachate collection?

i. gas collection?

-,

i

I

I

i

F. Is there a SCHEDULE FOR PARTIAL CLOSURE?

If "NO" SKIP TO SECTION 5. Note: the

regulations do not require that plans

contain schedules for partial closure,

only for final closure.

- 5 -
G. If a schedule is included, does the

SCHEDULE FOR PARTIAL CLOSURE include:

a. date(s) of partial closure(s)?

b. total time required for each

partial closure?

c. time required for key steps--

YES NO

----)

Comments:

i.

ii.

iii.

iv.

v.

vi.

vii.

viii.

waste removal?

waste stabilization?

waste treatment?

waste disposal?

placement of cover?

vegetation?

decontamination?

other (specify:

4. MAXIMUM INVENTORY (40 CFR 265.112(a)(2»

A. Is there an estimate of the MAXIMUM

INVENTORY of wastes in storage or

treatment at any time during the life

of the facility? (Note: write NA for

those cases where there is no storage or

treatment prior to disposal.)

B. Does the MAXIMUM INVENTORY estimate

include the maximum amount of on-site

wastes?

a. requiring pre-treatment?

b. requiring treatment?

c. requiring disposal?

C. Does the MAXIMUM INVENTORY estimate

include the maximum amount of on-site:

a. wastes in surface impoundments?

b. wastes in partially-closed nondisposal surface impoundments?

c. wastes in tanks?

d. wastes in piles?

e. wastes in drainage pits?

f. wastes in containers?

g. standing liquids?

- 6 -
C. Does the MAXIMUM INVENTORY estimate

include t he i maxLmum amount of on-site':

(continued)

h. sludge?

i. contaminated soil from land

treatment fields?

j. contaminated soil from around

tanks, containers, piles?

k. contaminated soil from around

tanks, containers, piles?

1. process residues?

m. decontamination residues?

D. Does the plan discuss the type(s) of

TESTING AND CRITERIA to be used to

determine: Note: the regulations do

not require closure plans to include

information on waste testing and criteria.

Write "NA" for situations where soil

contamination, decontamination residues, or process residues are not

relevant.

a. whether soil is contaminated?

b. whether decontamination residues

are hazardous?

c. whether process residues are

hazardous?

E. Are INCOMPATIBLE WASTES identified

and provisions described for keeping

them separate during closure (Note:

write "NA" only if there are no

incompatible wastes being managed

at the facility.)

Comments:

5. FINAL CLOSURE

A. Does the plan clearly identify the

STEPS TO CLOSE

a. at any point during the intended

operating life? (40 CFR 265.112(a»

b. at the end of the intended operating

life? (40 CFR 265.112(a))

- 7 -

YES NO
~~~- ---------~- ------- -~~~----

YES NO

B. Do the STEPS TO CLOSE in the plan include:

a. removal of wastes? (40 CFR 265.113(a))

b. treatment of wastes? (40 CFR 265.113(a))

c. waste disposal? (40 CFR 265.113(a))

d. waste containment?

e. cover? (40 CFR 265.310(b))

f. decontamination of equipment

and structures? (40 CFR 265.112(a)(3))

g. groundwater monitoring?

h. closure certification? (40 CFR 265.115)

i. maintenance of leachate program?

j. maintenance of gas collection

program?

k. security requirements?

C. With respect to the REMOVAL, TREATMENT,

OR DISPOSAL of waste, does the plan

identify:

a.. the source and type of materials

and equipment needed?

b. the amount of labor required?

c. the capacity. number. and location

of trenches or cells needed?

d. the area required for landspreading?

D. Does the plan describe the DECONTAMINATION

(40 CFR 265.112(a)(3); 265.114) of facility

equipment and structures, including:

a. a list of equipment, containers, and

structures requiring disposal or

decontamination?

b. decontamination procedures?

c. method of treatment or disposal of

residues?

d. testing program?

E. With respect to MONITORING, does the

closure plan describe:

a. details of the groundwater

monitoring program during closure?

b. soil testing and monitoring?

c. maintenance of monitoring equipment

during closure?

d. other (specify:

- 8 -
F. With respect to CERTIFICATION of closure

(40 CFR 265.115), does the closure plan

describe scheduled or estimated number

of inspections?

G. If a system for COLLECTING LEACHATE is

present, does the closure plan:

YES NO

a.

b.

c.

describe leachate removal, treatment,

and disposal during closure?

identify the" approximate volume of

leachate collected?

provide for maintenance of the leachate

collection system during closure?

H. If a GAS COLLECTION SYSTEM is required

during operation, does the closure plan?

a. describe procedures for collecting

gas during closure?

b. describe monitoring samples and

analysis during closure?

c. describe maintenance of gas collection

system during closure?

I. If SECURITY (ex: fencing) is required,

does the closure plan:

a. describe the maintenance of security

equipment during the closure. period?

b. describe the installation of appropriate

equipment at closure?

c. state the dimensions of the fence and

the area to be enclosed?

Comments:

6. FINAL CLOSURE: SCHEDULE

A. Does the plan identify the YEAR when

final closure is expected to occur?

(40 CFR 265.112(a)(4))

o What is the expected year of closure?

- 9 -
B. Is there a SCHEDULE for final closure

activities? (40 CFR 265.II2(a)(4»

IF "NO" SKIP TO COMMENTS SECTION.

C. Does the SCHEDULE for final closure

include (Note: regulations require the

closure schedules to include, at a

minimum, both the total time required

to close the facility as well as the

time required for intervening activities.):

a. date closure is expected to begin?

(40 CFR 265.II2(a)(I»

b. total time required to close?

c. the time for intervening closure

activities? (40 CFR 265.II2(a)(4»

d. time required for key steps:

i. waste inventory treatment?

(40 CFR 265.II2(a)(4»

ii. waste inventory disposal?

(40 CFR 265.II2(a)(4»

iii. removal of waste inventory

and residues?

iv. decontamination of facility

equipment and structures?

v. installation of containment

and diversion structures?

vi. placement of final cover?

(40 CFR 265.I12(a)(4»

V11. planting vegetation?

viii.closure certification?

ix. other (specify:

D. Does the SCHEDULE for final closure:

a. encompass more than 90 days for treatment,

removal, or disposal of hazardous wastes

after receipt of final volume of wastes?

(40 CFR 265.1I3(a»

b. encompass more than ISO days for

completion of closure plan activities

after receipt of final volume of wastes?

(40 CFR 265.II3(b»

Comments:

- 10 -

YES NO
7. GENERAL CLOSURE COST ESTIMATE

A. Is there a written closure cost estimate?

YES NO

B. ~~at is the amount of the closure cost

estimate?

$---

C. Is there documentation supporting the cost

estimate?

a. work-ups?

b. contractor bids?

c. operating history?

d. other

D. Has the cost estimate been adjusted by

the 9% inflation factor?

(40 CFR 265.142(b»

E. Does the cost estimate cover all the

activities in the closure plan

including costs of labor?

F. Does the closure cost estimate cover all

required closure activities?

(40 CFR 265.142(a»

If "NO" specify in comments below:

Comments:

- 11 -
6.3 UNIT SPECIFIC REQUIREMENTS

This section addresses requirements which

are specific to individual TSD units. In

an effort to simplify the checklist, the

requirements in this section have been

organized into unit specific modules.

This enables the inspector to select only

those requirements which are specific to

the particular facility under investigation.

Please note that with respect to surface

impoundments, waste piles and land treatment

units, if if % either cannot or elects not

to remove all waste residues, contaminated

soils, structures, and equipment, he must

close the facility and perform post-closure

care in accordance with the closure and

post-closure requirements that apply to

landfills.

- 12 -
I

i

I

I

1. CONTAINERS

A. Does the closure plan describe

the following:

a. the procedure for removing

hazardous waste containers

from the facility;

b. inspection of waste containers

for leaks;

c. the procedure for transferring

dangerous wastes from leaking

containers to non-leaking

containers;

B. Rave provisions been made for the

decontamination of equipment and

structures?

c. Does the plan describe the testing

program needed to judge the

success of the decontamination

efforts?

D. Does the testing program include:

a. sampling methods

b. testing parameters

c. analytical procedures

Comments:

- 13 -

YES NO
2. TANKS (40 CFR 265.197)

A. Does the closure plan describe procedures

for removing hazardous wastes from the

tank?

B. Does the plan describe procedures for

decontaminating the tank, discharge

control equipment, and discharge

confinement structures?

C. Have criteria been established to

determine the effectiveness of the

decontamination process?

D. Have test procedures been included

to determine the effectivenss of the

decontamination procedures?

E. Does the testing procedure include:

a. sampling methods

b. testing parameters

c. analytical procedures

Comments:

- 14 -

YES NO
3. SURFACE IMPOUNDMENTS (40 CFR 265.228)

A. Upon closure, does the % plan to

remove the impoundment:

a. standing liquids

b. waste and waste residue

c. underlying and surrounding

contaminated soil

B. Does the closure plan provide a

detailed plan for the removal of:

a. all hazardous wastes

b. the containment system

(if applicable)

c. contaminated soil

C. Does the closure plan describe a

testing program to determine if

the site is clean?

D. Does the closure plan provide an

estimate of each quantity of material

to be removed from the site?

Comments:

- 1~ -

YES NO
4. WASTE PILES (40 CFR 265.258(a))

A. Does the closure plan provide a detailed

plan for the removal of:

a. all hazardous wastes

b. the contaminated system

(if applicable)

c. contaminated soil

B. Does the closure plan describe the

procedures to be used to decontaminate

equipment and structures?

YES NO

I

I"

I

I

C. Have criteria been established to

judge the effectiveness of the

decontamination procedures?

D. Does the closure plan describe a

testing program to determine if the

site is clean?

Comments:

- 16 -
5. LAND TREATMENT (40 CFR 265.280)

A. Does the closure plan address the

following objectives and explain

how they will be achieved?

a. control of migration of

hazardous wastes and

constituents into groundwater.

b. control of the release of

contaminated run-off into

surface water.

c. control of the release of

airborne particulate

contaminants caused by wind

erosion.

d. protection of food chain crops.

B. Does the closure plan include at

least a narrative statement indicating

that the following factors were considered

in addressing the closure objectives?

a. type and amount of waste.

b. mobility and rate of migration

c. site location, topography, and

surrounding land use.

d. climate, including precipitation.

e. characteristics of the cover,

including material, final surface

contour, thickness, porosity,

permeability, slope, vegetation.

f. geological and soil profiles and

surface and subsurface hydrology.

g. unsaturated zone monitoring.

h. type, concentration, and depth

of hazardous constituent migration as compared to background

concentrations.

Comments:

- 17 -

YES NO
6. LAND DISPOSAL (40 CFR 265.310)

A. Does the closure plan address the

following objectives and explain

how they will be achieved?

a. control of pollution

migration from the facility

via groundwater, surface

water, and air.

b. control of surface water

infiltration, including

prevention of pooling.

c. prevention of erosion.

B. Does the closure plan include at

least a narrative statement

indicating that the following

factors were considered in

addressing the closure objectives?

a. type and amount of waste

b. mobility and rate of migration

c. site location, topography, and

surrounding land

d. climate, including amount,

frequency and pH of precipitation

e. characteristics of the cover,

including material type, final

surface contour, thickness,

porosity, permeability, slope,

and type of vegetation

f. geologic characteristics, soil

profiles, and surface and subsurface hydrology

g. unsaturated zone monitoring

h. type, concentration, and depth

of hazardous constituent migration

as compared to background

concentrations

Comments:

- 18 -

YES NO
7. INCINERATORS (40 CFR 265.351)

A. Does the closure plan address the

removal of:

a. all wastes

b. ash

c. scrubber waters

d. scrubber sludges

B. Are procedures for decontaminating

the incinerator, ash collection

equipment, and emission control

equipment, described or referenced

in the closure plan?

C. Does the closure plan address the

disposal of all contaminated equipment, residues, solvents, and

contaminated cleaning agents?

D. Has the plan included criteria to be

used to judge the success of the

decontamination efforts?

E. Does the closure plan describe a

testing program to determine if the

standards of decontamination has been

met?

Comments:

- 19 -

YES NO
8. THERMAL TREATMENT (40 CFR 265.381)

A. Does the closure plan address the

disposal of all wastes and residues?

B. Does the closure plan describe the

procedure for decontamination of the

thermal treatment equipment and

surrounding structures?

C. Does the closure plan describe a

testing program to determine if the

standard of decontamination has been

met?

Comments:

- 20 -

YES NO
9. CHEMICAL, PHYSICAL AND BIOLOGICAL TREATMENT

(40 CFR 265.404)

A. Does the closure plan address the disposal

of all wastes and residues?

B. Does the closure plan describe the

procedures for decontamination of the

thermal treatment equipment and

surrounding structur;s?

C. Does the closure plan describe a testing

program to determine if the standard

of decontamination has been met?

Comments:

- 21 -

YES NO
--- ~------- ._--- -- --- -- --- ..

6.4 VERIFICATION OF CLOSURE COST ESTIMATES

Sections 1-7 deal with the verification of cost estimates for various

tasks performed during the closure of a dangerous waste management

facility. However, some of the information requested in the following

sections may not be applicable to a particular facility. If an item

does not apply, mark "NA" (not applicable) on the line located to the

left of that item. If the requested information is applicable, simply

place a ," v" "on the line and enter the estimated figure on the line

located to the right of the item. On the other hand, if the requested

information is applicable and yet' the facility has not provided an

estimate for the particular item, enter "NP" (not provided) on the

line in the right column.

Be sure that all estimates entered below are assigned the appropriate

units (i.e., dollars, cubic meters, years, etc.).

- 22 -
1. TREAMENT, DISPOSAL OR REMOVAL OF INVENTORY

(40 CFR 265.112(a)(2))

Applicable/NA A. On-Site

a. Amount of inventory and residues

*

to be disposed on-site (yd 3 )

i. from cost estimate

ii. from closure plan

iii. from visual inspection

b. Unit cost for on-site treatment

or disposal ($/yd3 )

i. from cost estimate

c. Total cost of on-site treatment

disposal ($)

i. from cost estimate

Amount/NP

B. Off-Site

a. Amount of inventory and residues

to be disposed off-site (yd3 )

i. from cost estimate

ii. from closure plan

iii. from visual inspection

b. Unit cost for off-site treatment

or disposal ($/yd3 )

i. from cost estimate

c. Total cost for off-site disposal

excluding transportation

i. from cost estimate

d. Unit cost for transport of

inventory ($/yd3/mile)

i. from cost estimate

*

Residues here refer to residues existing at initiation of closure.

- 23 -
Applicable/NA

Comments:

e. Transport distance (miles)

i. from cost estimate

ii. by map reference

f. Cost of transport ($)

i. from cost estimate

g. Cost of off-site treatment

or disposal including transport ($)

i. from cost estimate

ii. inspector calculation

C. Total cost of Treating, Disposing or

Removing Inventory ($)

a. From cost estimate

- 24 -

Amount/NP
Applicable/NA

2. DECONTAHINATION

A. Soil Excavation (40 CFR 265.280(c)(1))

a. Volume of soil to be removed (yd 3 )

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

b. Unit cost for soil excavation ($/yd3 )

i. from cost estimate

c. Total cost of contaminated soil

excavation ($)

i. from cost estimate

B. Wastewater Removal

a. Volume of wastewater to be removed

(yd 3 )

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

b. Unit cost for wastewater

removal ($/yd3 )

i. from cost estimate

c. Total cost of wastewater

removal ($)

i. from cost estimate

C. On-Site Treatment or Disposal of

Contaminated Soil, Wastewater and

Residues Generated During

Decontamination

a. Volume of soil, wastewater and

residues to be treated/disposed

on-site (yd 3 )

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

- 25 -

Amount/NP

i - I
Applicable/NA

b. Unit cost for treatment/disposal

($/yd 3 )

i. from cost estimate

Amount/NP

c. Cost of on-site treatment/disposal

($)

i. from cost estimate

D. Off-Site Treatment or Disposal of

Contaminated Soil, Wastewater and

Residues Generated During

Decontamination

a. Volume of soil, wastewater and

residues to be treated/disposal

off-site (yd 3 )

i. from cost estimate

ii. from closure plan

iii. from visual inspection

b. Unit cost for off-site

treatment/disposal ($/yd3 )

i. from cost estimate

c. Cost of off-site treatment/

disposal ($) excluding

transportation

i. from cost estimate

d. Unit cost for transport

($/yd 3/mile)

i. from cost estimate

e. Transport distance (miles)

i. from cost estimate

ii. by map reference

f. Cost of transport ($)

i. from cost estimate

g. Total cost of off-site

treatment or disposal

including transport ($)

i. from cost estimate

- 26 -
Applicable/NA

E. Equipment Decontamination

(40 CFR 265.112(a)(3))

a. Amount of equipment to be

decontaminated (tons)

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

b. Unit cost for equipment

decontamination ($/ton)

i. from cost estimate

c. Cost of equipment decontamination ($)

i. from cost estimate

Amount/NP

Comments:

F. Total Cost of Decontamination ($)

a. From cost estimate

- 27 -
Applicable/NA

3. CERTIFICATION

Amount/NP

Applicable/NA A. Professional Engineer Hours (hrs)

. (40 CFR 265.115)

a. from cost estimate

b. from closure plan

c. inspector's estimate

Amount/NP

Comments:

B. Unit Cos~ for Professional

Engineer ($/hr.)

a. from cost estimate

C. Total Certification Cost ($)

a. from cost estimate

*Loaded with costs for support personnel.

- 28 -
Applicable/NA

4. VERIFICATION OF COST ESTIMATE FOR COVER

A. Cover Material

**

(40 CFR 265.112(a)(4);

265.280(c)(2))

a. Area to be covered (yd 2 )

i. from cost estimate

ii. from closure plan

iii. from visual inspection

b. Depth of cover material (yd)

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

c. Volume of material to be

obtained on-site (yd3 )

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

d. Volume of material to be

obtained off-site (yd 3 )

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

e. Unit cost of excavating

material on-site ($/yd3 )

i. from cost estimate

f. Unit cost of purchasing

material off-site ($/yd 3 )

i. from cost estimate

g. Unit cost of transporting

material ($/yd3/mile)

i. from cost estimate

ii. by map reference

Amount/NP

**

Include materials to be used for cover, for example gravel or clay,

except for top-soil.

- 29 -
Applicable/NA

h. Transport distance (miles)

i. from cost estimate

ii. by map reference

Amount/NP

i. Transport cost ($)

i. from cost estimate

j. Total cost of acquiring

material ($)

i. from cost estimate

k. Unit cost of spreading and

compacting material ($/yd3 )

i. from cost estimate

1. Cost of spreading and compacting

material ($)

i. from cost estimate

m. Total cost of acquiring and

placing material ($)

i. from cost estimate

B. Top-Soil

a. Area to be covered (yd 3 )

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

b. Depth of top-soil. allowing for

appropriate grading (yd)

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

c. Volume of top-soil to be

obtained on-site (yd3 )

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

- 30 -
Applicable/NA

d. Volume of top-soil obtained

off-site (yd 3 )

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

Amount/NP

e. Unit cost of excavating

top-soil on site ($/yd3 )

i. from cost estimate

f. Unit cost of purchasing

top-soil off-site ($/yd3 )

i. from cost estimate

g. Unit cost of transporting

top-soil off-site ($/yd 3 )

i. from cost estimate

h. Transport distance (miles)

i. from cost estimate

ii. by map reference

i. Transport cost ($)

i. from cost estimate

j. Total cost of acquiring

top-soil ($)

i. from cost estimate

k. Unit cost of spreading and

compacting top-soil ($/yd3 )

i. from cost estimate

1. Cost of spreading and

compacting top-soil ($)

i. from cost estimate

m. Total cost of acquiring

and placing top-soil ($)

i. from cost estimate

- 31 -
Apflicable/NA

c. Synthetic Liner and Buffer Material

a. Area to be covered (yd 2 )

i. fr.om cost estimate

ii. from closure plan

iii. visual estimate

b. Depth of sand

*

buffer (yd)

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

c. Volume of sand to be obtained

on-site (yd3 )

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

d. Volume of sand to be obtained

off-site (yd 3 )

i. from cost estimate

ii. from closure plan

iii. inspector's estimate

e. Unit cost of excavating sand

on-site ($/yd 3 )

i. from cost estimate

f. Unit cost of purchasing sand

off-site ($/yd3 )

i. from cost estimate

g. Unit cost of transporting

sand ($/yd3/mile)

i. from cost estimate

h. Transport distance (miles)

i. from cost estimate

ii. by map reference

Amount/NP

*

Includes other materials (other than clay and top-soil) which may be

used along with the snythetic liner.

- 32 -
Applicable/NA

i. Total cost of acquiring sand ($)

i. from cost estimate

Amount/NP

j. Unit cost of spreading and

compacting sand ($/yd 3 )

i. from cost estimate

k. Cost of spreading and

compacting sand ($)

i. from cost estimate

1. Total cost of acquiring and

placing sand ($)

i. from cost estimate

m. Unit cost of acquiring and

installing synthetic liner ($)

i. from cost estimate

n. Cost of acquiring and installing

synthetic liner ($)

i. from cost estimate.

o. Unit cost of acquiring and

installing synthetic liner and

buffer materials ($/yd 2 )

i. from cost estimate

p. Total cost of acquiring and

installing synthetic liner

and buffer materials ($)

i. from cost estimate

D. Total Cover Cost

a. Unit cost of cover ($/yd2 )

i. from cost estimate

b. Total cost of cover ($)

. i. from cost estimate

- 33 -
-------- -- --- - ---

Applicable/NA

Comments:

- 34 -

Amount/NP
Applicable/NA

5. REVEGETATION (40 CFR 265.280(c)(2)(ii»

A. Area in Need of revegetation (yd 2 )

a. From cost estimate

b. From closure plan

c. From visual inspection

Amount/NP

B. Unit Cost for Acquiring and Placing

Seed, Fertilizer, etc. ($/yd 2 )

a. From cost estimate

C. Total Cost of Acquiring and Placing

Seed, Fertilizer, etc. ($)

a. From cost estimate

6. OTHER (from cost estimate) ($)

(specify)

(specify)

7. TOTAL CLOSURE COSTS ($)

A. From cost estimate

- 35 -

$----

$----
DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE

CHAPTER 173-303 WAC

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

Part 7: Post-Closure

This part of the checklist/questionnaire is applicable to all hazardous

waste disposal facilities operating under interim status at which dangerous

waste will remain after closure. In addition to landfills and land

treatment units, post-closure requirements may also apply to surface

impoundments and waste piles.

The abbreviation "0/0" is used frequently throughout this

checklist/questionnaire and stands for the words "Owner and/or operator."

The questions in the checklist have been written in a manner such that they

can be answered either "Yes" or "No". However, the answers to some

questions may require additional explanation. The space provided for

comments at the end of each section may be used for explanations. If a

question does not apply to a particular facility, simply write "NA" (not

applicable) next to the question.

\5)§~§U~~@:\I] iM\\( 8 \.;J;

~WR~U' 'l~1i. U\~\~\ott
POST-CLOSURE PLAN CHECKLIST

7.1 GENERAL POST-CLOSURE REQUIREMENTS

1. WR ITTEN PLAN

A. Is there a written POST-CLOSURE PLAN at

the facility? (40 CFR 265.118(a» If

answer is "t\/A" skip to cost estimate

checklists.

B. Does the post-closure plan cover the

MAXINeM AREA EXPECTED TO CONTAIN

HAZARDOUS WASTE after closure, including:

YES NO

a)

b)

c)

d)

Landfills?

Disposal surface impoundments?

Land treatment facilities where

hazardous waste will remain?

Other re~aining hazardous wastes?

C. Does the post-closure plan provide for

30 years of post-closure care?

(40 CFR 265.117(a» (NOTE: The postclosure period of 30 years is subject

to modification during the post-closure

care period. See 40 CFR 265.118(3).)

How many years of post-closure

·care?

D. Does the post-closure plan cover all

areas where hazardous waste ~ill remain

that ~ere active as of 11/19/80?

Comments:

2. POST-CLOSURE PLA:\ REQUIREMENTS

A. Does the plan clearly identify the

ACTIVITIES required in post-closure

care? (40 CFR 265.118(a»

B. Does the plan clearly identify the

FREQUENCIES for post-closure activities?

(40 CFR 265.118(a»

-2-
C. no the GROUNDWATER· MONITORING Plans (40

CFR :2 6 5 • 117 (a) (l); 2. 6.5• 11 8 ( a) (l)) inclu de:

YES NO

a)

b)

c)

d)

e)

f)

Number of wells?

Sample collection activities?

Sample collection frequencies?

Sample test activities?

Sample test frequencies?

Replacement of failed wells?

D. Is there d copy of the GROUNDWATER SAMPLI~G

AND ANALYSIS PROGRAM attached to the plan?

E. Do the MAINTENANCE PLANS for waste containment structures (40 CFR 265.118(a)(2))

include?

a) Inspection activities?

b) Inspection. frequencies?

c) Maintaining final cover (erosion

damage repair) activities?

d) Maintainin~ final cover (erosion

damage repair) frequencies?

(40 CFR 265.319(d)(l))

e) Vegetation and fertilizing activities?

f) Vegetation and fertilizing frequencies?

(40 CFR 265.118(a)(2)(i))

g) Mowing activities?

h) Mowing frequencies?

i) Collection and treatment of runoff?

j) Frequencies of runoff collection and

treatment?

F. Do MONITORUIC EQUIPMENT MAINTENANCE plans

(40 CFR 265.118(a)(2)(ii)) include:

a)

b)

Activities?

Frequencies?

(40 CFR 265.118(a)(2)(ii))

(40 CFR 265.118(a)(2)(ii)

G. Do SECURITY REQCIREMENT plars include:

a) Activities?

b) Frequencies?

H. Does the plan identify the name, address

and phone number of the POST-CLOSURE PERIOD

CONTACT? (40 CFR 265.118(a)(3))

Comments:

-3-
3. OTHER REQUIREMENTS

Note: Check the post-closure cost estimate for

inclusion of costs for the following activities;

such costs are to be included (see 40 CFR 265.144

(a)) even if the post-closure plan does not

discuss these activities.

A. Does the plan address the requirement for

notice to the local land authority?

(40 CFR 265.119)

B. Does the plan address the requirement for

notice in the dead? (40 CFR 265.120)

C. Does the plan address the protection and

maintenance of surveyed benchmarks?

Comments:

4. GENERAL POST-CLOSURE COST ESTIMATE

A. Is there a written post-closure cost

estimate? (40 CFR 265.144(a))

YES NO

B. What is the amount of the estimate? $------

C. Is there documentation supporting the

post-clcsure cost estimate?

a) Work-ups?

b) Contractor bids?

c) Operating history?

d) . Other

D. Is the annual estimate multiplied by

30 to cover the entire post-closure

care period? (40 CFR 265.144(b))

E. Has the cost estimate been adjusted

by the 9% inflation factor?

(40 CFR 265.144(b))

F. Does the cost estimate cover all the

activities in the post-closure plan?

(40 CFR 265.118)?--

-4-
G.

Including labor costs?

As well as the requirements of notice

to local land authorities and in deeds?

(40 CFR 265.119, 265.120)

Does the post-closure cost estimate cover

all required post-closure activities?

(40 CfR 265. 144(a))

If "NO" specify in comments below.

YES NO

Comments:

-5-
7.2 UNI! SPECIFIC REQUIREMENTS

NOTE: Although unit specific requirements apply primarily to

landfills and land treatment units, situations may arise where

post-closure requirements also apply to surface impoundments and waste

piles. For example, if an % of a surface Lmp oun.dmen t cannot

effectively remove all contaminated soils from the unit during

closure, some p6st-closure requirements may apply. In this situation,

the % would close the impoundment and provide post-closure care as

if the unit were a landfill..

YES NO

1. LANDFILLS (40 CFR 265.310)

A. Does the post-closure plan address the

following objectives and indicate how

they will be achieved

a. Control of pollution migration

via groundwater, surface water,

and air.

b. Control of surface water infiltration, including prevention

of polling.

c. Prevention of erosion.

B. Does the post-closure plan include at

least a narrative statement indicating

that the following factors were

considered?

a. Type and amount of waste.

b. Mobility and rate of migration.

c. Site location, topography, and

surrounding land use.

d. Climate, include amount, frequency,

and pH of precipitation.

e. Characteristics of the cover including

material type, final surface contour,

thickness, porosity, permeability,

slope, and vegetation.

f. Geological conditions, soil profiles,

and surface and subsurface

hydrology.

g. Unsaturated zone monitoring.

h. Type, concentration, and depth of

hazardous constituent, migration

as com~nred to background concentrations.

Comments:

-6-

._--- ~----~
C. In addition to the items listed in Section

G-2(2)(e), do post-closure maintenance

plans include?

YES NO

a.

b.

c.

d.

Comments:

Procedures for collecting, removing,

and treating leachate.

The frequencies of collecting,

~emoving, and treating leachate.

Gas collection activities.

Gas collection frequencies.

2. LAND TREATMENT (40 CFR 265.288)

A. Does the post-closure plan addr.ess the

following objectives and indicate how

they will be achieved?

a.

b.

c.

d.

Comments:

Control of migration of hazardous

wastes and constituents into the

groundwater..

Control of the release of contamination runoff in surface water.

Control of the release of airborne

particulate contaminants caused

by wind erosion.

Protection of food chain crops.

B. Does the post-closure plan include at

least a narrative statement indicating that

the following factors were considered

in addressing the closure objectives?

a. Type and amount of waste.

b. Mobility and rate of migration

-7-
--~--_.__ . ---~--_._- ---~------ - - ~--- -~

---~- ---. - ~_._--

c.

d.

e.

f.

g.

h.

Comments:

Site location, topography, and

surrounding land use.

Climate, including amount, frequency

and pH of precipitation.

Characteristics of the cover including

material type, final surface contour,

thickness, porosity, permeability,

slope, and vegatation.

Geological characterization, soil

profiles,.and surface and subsurface

hydrology.

Unsaturated zone monitoring.

Type, concentration, and depth

of hazardous constituent migration

as compared to background

concentrations.

-8-

YES NO
7.3 VERIFICATION OF COST ESTI~~TES

Sections 1-10 deal with the verification of cost estimates for

required work performed during the post-closure period.

However, some of the information requested in the following

sections may not be applicable to a particular facility. If an

item does not apply, mark "NA" (not appliable) on the line

located to the left of that item. If the requested information

is applicable, simply place a" "on the line and enter the

estimated figure on the line located to the right of the item.

On the other hand, if the requested information is applicable

and yet the facility has not provided an estimate for the

particular item, enter "NP" (not provide.d) on the line in the

right column.

Be sure that all estiamtes entered below are assigned the

appropriate units (i.e., dollars, cubic meters, years, etc.).

1. INSPECTION/FACILITY VISITS

Applicable /NA

A. Total hours of professional level personnel (hrs/year)

Amount/NP

a. From cost estimate

b. From post-closure plan

c. Inspector's estimate

B. Unit cost 1for professional level

personnel ($/hr)

a. From cost estimate

C. Total inspection/facility visit cost

($/year)

a. From cost estimate

2. REESTABLISHING FINAL COVER AND VEGETATION

A. Area involved (yd 2 )

a. From cost estimate

b. From post-clo~ure plan

c. From visual inspection

B. Unit cost for reestablishing cover and

vegeta~ion ($/yd 2 )

1Loaded with costs for support personnel.

-9-
Applicab Le/NA

a. From cost estimate

Amount/NP

C. Reest8blishing cover and ve?ptation cost

($/year)

a. From cost estimate

3. FERTILIZING

A. Area involved (yd 2 )

a. From cost estimate

b. From post-closure plan

c. From visual inspection

B. Unit cost for fertilizing ($/yd 2 )

a. From cost estimate

C. Total fertilizing cost ($/year)

a. From cost estimate

4. MOWING

A. Area involved (yd 2 )

a. From cost estimate

b. From post-closure plan

c. From visual inspection

B. Unit cost for mowing ($/yd 2 )

a. From cost estimate

C. Mowing cost (S/year)

a. From cost estimate

5. GROUNDWATER ~~ONITORING AND WELL REPU.CEMENT

A. Groundwater ~onitoring

a. Number of wells

i From cost estimate

ii. From post-closure plan

iii. From visual inspection

I

\-------

I

b. Unit cost for groundwater monitoring

($/well/year)

1. From cost estimate

-10-
Applicable/NA

c. Groundwater monitoring cost ($/year)

i. From cost estimate

B. Well Replacement

a. Average annual number of well

replacements

i. From cost estimate

ii. From post-closure plan

iii. Ip.spector's estimate

b. Unit cost for well replacement

($ /replacemen t )

i. From cost estimate

c. Cost for well replacement ($/year)

i. From cost estimate

C. Total groundwater monitor~ng and well

replacement cost ($/year)

a. From cost estimate

6. MAINTAINING AND REPLACING FENCES

A. Maintaining Fences

a. Length of fence required (yd)

Amount/NP

b.

i. From cost estimate

ii. From post-closure plan

iii. From visual inspection

Unit cost for maintaining fences ($/yd)

i. From cost estimate

c. Cost for maintaining fences ($/year)

i. From cost estimate

B. Replacing Fences

a. Length 05 fence to be replaced

annually (yd)

2

Note in comment; section whether well replacement component is on

annual basis or not.

-11-
Applicable/NA

i. From cost esti~ate

ii. From post-closure plan

iii. Inspector's estimate

b. Unit cost for fence replacement ($/yd)

i. From cost estimate

c. Cost of fence replacement ($/year)

i. From cost estimate

C. Total Cost for ~aintaining and Replacing

Fences ($/year)

7. COLLECTION, REMOVAL AND TREATMENT OF LEACHATE

A. Amount of leachate collected (gal./year)

a. From cost estimate

b. From post-closure plan

B. Off Site Disposal

a. Amount of leachate removed to off site

disposal facilities (gal./year)

i. From cost estimate

ii. From post-closure plan

b. Unit cost for off site leachate

disposal ($/gal.)

i. From cost estimate

c. Unit cost for transport of leachate

($/~d. /mile)

i. From cost estimate

d. Transport distance (miles)

i. From cost estimate

Amount/NP

3

Total length of fence to be replaced over the entire post-closure

period divided by 30 to obtain an annual average.

4No t e in comment section whether fence replncement component is on

annual basis or not.

-12-
Applicable/~A Amount/NP

ii. From post-closure plan

iii. By map reference

e. Cost of transport ($/year)

i. From cost estimate

f. Total cost of off-site treatment/

disposal of lenchate ($/year)

i. From cost estimate

C. On Site Disposal

a. Amount of leachate disposed of on-site

(gal.)

i. From cost estimate

ii. From post-closure plan

b. Unit cost of on site leachate disposal

($/gal. )

i. From cost estimate

c. Cost of on-site leachate disposal

($/year)

i. From cost estimate

D. Total Cost for Collection, Removal, Treatment,

and Disposal of Leachate

a. From cost estimate

8. ADMINISTRATIVE FU~CTIONS

A. Hours of management time req~ired to

adminjster the post-closure r~an (hrs/year)

a. From cost estimate

b. From post-closure plan

c. Inspector's estimate

B. Unit for management time 5 cost ($/hr)

a. From cost estimate

C. Total administrative cost ($/year)

5

Loaded with costs for support personnel.

-13-
Applicable/NA

a. From cost estimate

Amount/NP

9. OTHER (SPECIFY) ($/YEAR)

A. Local land authority notice ($/year)

(40 CFR 265.119)

B. Notice in deed ($/year)

(40 CFB. 265.120)

C.

D.

E.

(Total Other)

10. TOTAL ANNUAL POST-CLOSURE COSTS ($)

A. From cost estimate

-14-
COHHENTS

-15- .
PART 8 GROUND WATER MONITORING

This part of the checklist/questionnaire is applicable to any person who owns or

operates a surface impoundment, landfill, land treatment or water pile (final status)

facility which is used to manage hazardous waste and therefore is required to maintain

a ground water monitoring network. The ground water monitoring checklist/questionnaire

consists of five subparts listed as follows:

1. Hydrogeologic Characterization

2. Ground Water Monitoring Network

J. Nonitoring w'ell Installation and Construction

4. Field Inspection

5. Water Qua l i t y tRes u l t s

All five subparts apply to interim status facilities and detection monitoring programs

under final status. The technical information requirements to assess the adequacy of

a ground water monitoring program are the same for an interim status facility and

detection monitoring program under finai status. Therefore, even though many of the

questions in these subparts reference final status regulations, they are also required,

on a technical basis, to assess interim status ground water monitoring programs. A

ground water assessment checklist (for interim status facilities where ground water

contamination has been detected) and additional subparts for final status ground water

monitoring requirements will be added later.

Note that in many instances more than one of each subpart may be required for a

facility inspection. For example, 3 facility may have three different kinds of

well constructions, thus, t.h r e-e monitoring well i.ns ta l l a t i on and construction

checklisl/'ju('slionnaires may hf' a pp r o p r i a t.e . Subp a r t, 4, Fi(·ld l ns pe c t i ou is filled

out at the facility during the corup l i n nc e i us pe rt i o n .

Whenever pos s i b l e copies of d r aw i ngs and figures listed in i.he clll"cklist/'jucstionnaire

should be obtained and attached. These may include but a r e not limited to:

1. An as-buill d r awi.n g and geologic log (on one figure) for each

monitoring we l l .

2. ""ater table and potentiometric maps

3. Hydrogeologic profiles

4. Site maps such as t opo g r a ph i c maps, well location maps, surface water

and drainage lIIaps, etc.

S. Tabulated .....a t e r quality data.

Note t ha t the

i.nterim s t a t us

facilities.

federal r e gu Lr t t o ns a r e r e le r en ced

facilities and state regulations

in Lhe ('hecklist/questionnaire for

are referenced for final status'

Space for additional remarks is available at the 'end of the checkl.ist.

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
.......---,

_.'

1. HYDROGEOLOGIC CHARACTERIZATION

A. Regional Hydrogeology (WAC -806(4)(xx)(B))

a. Is the regional hydrogeology and its relationship

to the facility characterized?

I f yes, what, data SOil rces have been us eo t.o

characterize the regional hydrogeology?

(i) Puhlished and other technical reports"

Specify the reports used:

(ii) Water well logs?

(iii) Geotechnical horings?

(iv) Climatic records?

(v) Surface water records?

(vi) On-site geologic mapping?

(vii) Other (specify)?

b. Is the on-site and off-site ground water ilse

chi! racter i zed?

If yes, does the characterization include the

following:

(i) .A map showing ground water production wells

and other wells (e.g. neighboring monitoring

wells) relative to the site? (WAC -806(4)(a)

(xv i i i)( 1)

( i i ) Wp I 1 I ()g s f ()r ;11 I we I I s (i f avai I a I, II' ).,

liii) Use and use rales for all production wells?

- 2 -

Yes No

....
"~"

(iv) Pumping and static wat e r levels'!

(v ) Effect uf on-site and off-site pumping 011

the ground wat.e r flow d i rection?

c. Does the regional hydrogeologic characterization

include the following:

(i) Identification of the principal aquifers

(i.e. aquifers heingused or which have

potential us o ) that may he potentially

a f f e c t.ed by the site? (WAC -i306(4)(x){B)

Remarks:

(ii) Hydrogeologic profiles showing the relationship

of the facility to the principle aquifers?

Remarks:

(iii) Water t ab l e contour and/or po t e nt i ome-t r i c maps

fur the principle aqu ife r s ?

Remarks: ._-----------_.

---------------

B. Site Hydrogeology

a. List the pertinent hydrologic and geologic"

investigat~ons ongoing or completed at the

facility:

Month/Year

Description of Work Ongoing

or Completed (ObLain copies of all reports)

- 3 -
»<

---------------------- - - -----

b. Is a s i t e map (or site maps) available that shows

the following: (WAC -R06(4)(a)(xviii)

(i) Waste management areas?

(ii) Hon ito r i ng well locations?

(iii) Site topography?

(iv) Su r ta cr- w.r t r- r ft':ILllr{'S and d r a i na gr-?

(v) On-site water supply wells?

(vi) Pe r t. i ne nt engineered s t r uc t.u r e s and operational

un i t s ?

(vii) Is the scale of the map appropriate?

Scale used:

(viii) North arrow?

(ix) Legal boundaries?

(x ) Access controls (e.g. roads, f e nce s )

(xi) Su r f a ce 'Inti bu r i e d u t i l i t i e s ?

c. Are the following characteristics of tile up pe rmost

aquifer (uppermost monitorable saturated zOlle)

defined: (WAC 806(4)(x)(B)

(i) Aquifer materials (sand, sandy g r a ve l , sandstone, etc.)

Specify

------------------"-------

(ii) Thickness and lateral extent?

Remarks:

- 4 -
(iii) Continuity beneath and adj a ce nt to the s i t.e ?

Remarks:

(iv) Water-table contour maps and potentiometric

maps that show ground water flow directions?

Remarks:

(v) Seasonal variation of ground water flow

directions?

Remarks:

(vi) Effect of ground water use on the ground

water flow directions?

Remarks:

---------_._-----------

(vii) Hydraulic conductivity/transmissivity

including lateral and vertical variations?

Which of the follo....·ing methods were us ed

to determine hydraulic conductivity!

transmissivity

a) Estimates from grain size aualyses

Describe

- 5 -
b) Laboratory tests (permeameter tests)

Describe

c) Slug tests

Describe

d) Pumping tests

Describe

e) Other

Describe

(viii) Methods used to evaluate slug tests, pumping

tests, etc.

Remarks:

(ix) Effective porosity?

(x) Storage coefficient including lalerdl and

vertical variations?

(xi) Interaction with surface water?

e. Has the relationship of the uppermost aquifer to

underlying aquifers been characterized? (WAC

-806(4)(xx)(B))

•

- - -- -------------

- 6 -
---".

."" .

If not, l'xplain

If yes, does the characterization include the

following:

(i) Thickness and extent of low permeability

layers separating the aquifers?

Remarks:

(ii) Hydraulic conductivity of the low permeability

layers?

. Rema rks:

(iii) Relative hydraulic heads of the uppermost

aquifer and the underlying aquifers~

Remarks:

f. Have the underlying aquifers been charact~rized?

lWAC -806(4)(xx)(B)

If yes, does the characterization of the underlying

aquifers include the following:

(i) Description of aquifer materials (e.g. sandy

gravel, fractured s a nd s t cne , etc.)?

Describe:

---_._._- ..._-----

- 7 -
(ii) Thickness and lateral extent?

(iii) Continuity beneath and ad.jacent to the site?

(iv) Water-table contour maps and potentiometric

maps that show ground water flow directions?

(v) Seasonal variation of ground water flow

directions?

(vi) Effect of ground water use on ground water

flow directions?

(vii) Hydraulic conductivity/transmissivity

including lateral and vertical variations?

Which of the following methods were used to

determine the hydraulic conductivity/

transmissivity.

a) Estimates from grain size analyses

Describe:

b) Laboratory tests (permeameter tests)

Describe:

c) Slug tests

Describe:

d) Pump tests

Describe:

------.... _.- - - -

- 8 -

•
e) Other

Describe:

(viii) Methods used to evaluate slug tests, pumping

tests, etc.?

(ix) Effective porosity?

(x) Storage coefficient or specific yield including

lateral and vertical variations?

(xi) Interaction with surface water?

- 9 -
..... : ....

'-"-'" "-" -----

2. GROUND WATER MONITORING NETWORK (265.91, WAC -806(4)(xx)E,

-645(8)

A. Is a site map available that shows the location of

the monitoring wells relative to the waste management

areas?

B. Upgradient/background monitoring wells. (265.91(a)(1),

WAC -645(8)(a)(i))

a. Are upgradient/background monitoring wells

designated to determine background water

quality?

How many background wells?

b. Are these wells hydraulically upgradient from

the facility?

If not, how were the well locations

determined?

c. Are the wells screened over the appropriate

saturated zone?

Describe:

d. Are the wells placed so they are not affected

by the active portion?

Describe:

e. If ground water mounding is known to o c cu r

beneath the facility, could this influence the

water quality of upgradient/background hells?

Describe:

Yes No

f. Are wells downgradient of other activities

(i.e. non DW) that are known to have

.afTec I:eo'ground- wa't"er-'qua-!-i'ty'? ..

- 10 -
c. Downgradient monitoring wells.

WAC -645(8)(a)(ii»

(265.91(a)(2),

.:-"",

a. Specify the number of downgradient wells installed

at each management unit?

b. Are the downgradient wells screened 1n the same

zone as the upgradient wells?

Remarks:

c. Are all downgradient monitoring wells screened

over the appropriate saturated intervals?

(e.g. at the appropriate depth within the uppermost monitorable zone)

Describe:

d. Is the well spacing adequate to detect cont ami nan't,

migration?

If not, where should additional wells be

installed?

e. Is the ground wat e r flow d i r e c t i on veri f i e.l at

least annually to ensure that the wells are

adequately placed? (265.93(f), wAC -645l9)(e»

f. Do the monitoring wells s how water leveL

variations due to seasonal or hydraulic (e.g.

tidal) fluctuations?

Remarks:

--_.._---------------

- 11 -
,--------------------------

-r-.

..'

----,

3, MONXTORING WELL INSTALLATION AND CONSTRUCTION

(WAC -645(8)(a) and (c), 265,91(c))

A. Are separate as-built drawings and geologic logs

available for each monitoring well?

Remarks:

B. Were all monitoring wells installed and constructed

similarly?

If not, a separate well installation and

construction checklist should be filled out

for each type of installation and construction method.

Remarks:

C. Well installations for wells __ through __

a. Circle the drilling method used to install the

monitoring wells: 1) hollow-stem auger, 2) cable

tool, 3) top-drive air rotary, 4) downhole air

rotary, 5) mud rotary, 6) solid-stem auger,

7) jetting, 8) driving, 9) other (specify)

If mud rotary was used specify the kind of

drilling fluid used.

If air rotary was used, were in-line filters

installed to remove oil from the compressed air?

Yes No

-- - _..-_._---------------

- 12 -
-.

Remarks:

for other drilling methods, were any fluids added

to the hole at any time during drilling or

installation?

If yes, explain.

b. Circle the soil sampling methods used during drilling.

1) grab, 2) split-spoon sampler, 3) shelby tube,

4) D&M sampler, 5) other, explain

c. Describe the soil sampling interval.

d. was the well logged by an experienced geologist,

hydrogeologist, or soils engineer?

who?

e. Was the drilling equipment decontaminated prior

to arriving on-site?

Describe the deeon method.

f. Were the drill, drilling equipment, and temporary

casing decontaminated between borings?

- 13 -
Describe th~ decon method.

g. Was the sampling equipment decontaminated between

samples?

Describe the decon method.

D. Monitoring Well Construction for Wells through

(WAC -400(3)(c)(v), -645(8)(c), 265.91(c))

a. Was the well construction supervised by an

experienced hydrogeologist, geologist, or soils

engineer?

Who?

b. Circle the type of completion: 1) single well

2) nests (or clusters) of wells in separate

boreholes, 3) multiple wells in a single borehole, 4) multiport sampler, 5) other (specify)

c. Circle the casing mateiials used: 1) teflon,

2) stainless steel 304, 3) SCH 40 PVC, 4) SCH 80

PVC, 5) ABS, 6) carbon steel, 7) other (specify)

d .. Circle the type of coupling used: 1) flush-threaded

2) bell, 3) regular pipe, 4) other (specify)

- 14 -

----- --~-------~~~

•
e. Circle the screen material used: 1) teflon.

2) stainless steel 304, 3) SCH 40 PVC, 4) SCH 80

PVC, 5) ABS, 6) carbon steel, 7) other (specify)

f. Describe the type of bottom plug used.

g. Were any glues or solvents used in the well

construction?

If yes, specify

h. Was a gravel pack installed?

If yes,

(i) Describe the material, its source, and

the method of installation.

(ii) Is a grain size distribution of the gravel

pack available?

(iii) Was the top of the gravel pack measured

before the backfilling or the well sCJls were

installed?

Remarks:

I. Were well seals installed?

If yes, describe the type of seal and the method of

installation. (For cement g r ou t s specify t he

water/cement ratio, bentonite/cement ratio, etc.)

- 15 -
·...-....,

. j. Were bentonite pellets placed in the unsaturated

zone?

If yes, were the pellets hydrated (wetted) after

they were installed?

k. Was the well seal installation method appropriate?

Remarks:

1. Are the wells properly constructed to prevent

contamination of the samples, the sampled waterbearing zones, and between aquifers and waterbearing zones? (WAC -400(3)(c)(v), -645(8)(c)

Remarks:

m. Were samples taken of all materials used in well

installation (grout, sand pack, bentonite, well

material, etc.)?

Remarks:

E. Well Development for Wells through

a. Were the monitoring wells developed?

b. Circle the well development method: 1) Air lift,

2) pllffiping, 3) overpumping, 4) bailing, S) surge

block, 6) raw hiding, 7) other (specify)

c. Describe the equipment used for development.

- 16 -
.'

d. Describe the duration of development.

P. ~lat was the volume of water and sediment removerl

during development?

f. Was the development continued until the purged

water at all wells was sediment free?

If not, explain

g. Was the well development adequate?

If not, explain

h. Were well yields measured?

If yes, for which wells

1. Were drawdowns and recovery measured during water

yield determinations?

If yes, specify:

- 17 -
4.

'. :.

FI ELD I NSPECT I ON

A. Sampling and Analysis Plan (265.92(a), WAC -645(8)

(d) and (e))

a. Are all wells to be sampled identified in the

plan?

Remarks:

b. Are all the appropriate parameters to be sampled

and tested identified in the plan?

Remarks:

c. Are procedures for purging the wells prior to sample

collection specified?

Remarks:

d. Do these procedures adequately identify:

(i) The equipment that will be used for evacuation?

Remarks:

(ii) Method of decontaminating equipmenl hetween wells?

Yf>S No

Remarks: -------~--

(iii) Depth(s) in well or borehole from ~hich water will

be evacuated?

Remarks:

(iv) Pumping rate and duration (or amount as

appropriate)?

Remarks:

~---------------------

- IH -
~.

(v) Special procedures as necessary for evacuation

prior to sampling separate phases of in@iscible

contaminants?

Specify:

e. Are these p r ocedu r e s identified for well

evacuation appropriate?

If not, what aspects of the specified procedures are

not appropriate and require correction?

f. Do the procedures specified for actual collection

of ground water samples from the well adequately

identify:

(i) Equipment that will be used to collect the

sample from the well?

(ii) Method of decontaminating equipment between

wells?

(iii) Depth(s) ill the well from which the sample

will be taken?

(iv) Time between well evacuation and sample

collection?

(v) Special procedures as necessary for collecting

samples from separate phases of immiscible

contaminants?

g. Are appropriate procedures and equipment identified

for the collection of samples?

- 19 -
,----------------- -------- ------- ----

If not, what aspects of the identified procedures

are not appropriate and require correction?

h. Do the sampling procedures clearly identify:

(i) Sample containers?

(ii) Filtering procedures?

(iii) Preservation procedures?

(iv) Chain of Custody?

(v) Transfer and transport blanks?

(vi) Other

i. Are these procedures adequate?

If not, what aspects of these procedures are

not adequate and require correction? __

j. Do the sampling and analysis procedures identify

analytical procedures?

k. Do these analytical procedures specify analytical

methods for each parameter?

- 20 -
1. Are these procedures app r op r i a t e ? If not, what

aspect of the procedures are .not adequate and

require correction~

m. Are QA and QC procedures described?

n. Are these procedures adequate?

If not, what aspect of the procedures are not

adequate and require correction?

B. Field Inspection - Well Appearance

a. Are the wells adequately protected?

Describe:

b. Are the wells locked?

c. Are the wells vented?

d. Are the surface seals sloped away from the well?

e. Does the integrity of the surface seal appear

adequate?

f. Are the wells clearly labeled?

Remarks:

---_. - ----- - --_._----

- 21 -
---,

c. Field Inspection - Well Purging

a. Specify the method of purging: 1) air lift,

2) centrifugal pump, 3) peristaltic pump,

4) gas-contact positive displacement pumps,

5) non-gas-coniact positive displacement

pumps 6) bailer, 7) electric submersible pump,

8) other

•

------------

b. Is this method of purging suitable for the

parameters to be tested?

Remarks:

c. Describe the make and model of the purging

equipment.

d. Is the depth of the intake measured to verify

that it is properly positioned in the well?

Remarks:

e. Is the volume of water removed measured?

Specify the volume of water removed

- 22 -
f 0 I s the pumping/ remova I r a t e me a s u r ed?

If yes, what is the pumping rate?

g. Is the purging equipment adequately decontaminated

between wells?

(i) Describe decon methods

(ii) Describe decon methods that require correction

D. Field Inspection-Sampling Procedures (WAC -645(8)(d) and (3))

a. Are the samples obtained immediately after purging?

If "No," specify the time that elapses be twe en

purging and sampling

Is this elapsed time appropriate for the parameters being tested?

Remarks: _________________0 _

b. Are the samples obtained by the same pers011nel

during each sampling episode?

Remarks:

- 23 -
c. Circle the sampling method used: 1) air lift,

2) centrifugal pump, 3) peristaltic pump,

4) electric submersible pump, 5) gas-contacl

positive displacement pump, 6) 1l01l-gas-conlacl

positive displacement pump, 7) bailer, 8) other

(specify)

d. Describe the make and model of the sampling

equipment.

e. Is the sampling procedure consistent with the

parameters to be tested? Remarks

f. Is the sampling equipment dedicated to the well?

(i) If not, describe the decontamination procedures

between wells.

(ii) Are the decontamination procedures 3dequate?

Remarks:

f. Are water levels measured:

(265.92(3), WAC -645(8)(f))

(i) prior to sampling?

(ii) during sampling?

Describe the method

- 24 -

•
g. Is the depth of the sampling intake measured to

verify that it is properly positioned in the well?

h. Describe the sampling materials that the sample

water comes in contact with. (e,g. PVC, teflon,

stainless, etc.)

(i) Suction tubing/piping

(ii) Discharge tubing/piping

(iii) Pump/baler

Remarks

l. Are special methods used to prevent sample aeration?

Remarks

J. Are the samples field filtered for:

(i) metals?

(ii) others (specify)

If yes, what is the filter pore size and which

br~nd of filters are used?

- 25 -

•
.---.

k. Are all samples sediment free?

If not, specify the wells with sediment

1. Are the types of bottles used consistenc with

the parameters to be tested (see Table I)?

Remarks

m. What parameters are tested in the field:

(i) pH?

Specify meter make and model

(ii) Specific conductance?

Specify meter make and model

(iii) Temperature?

Specify thermometer make and model

(iv) Eh (Redox potential)?

Specify meter make and model

n. Are the field instruments calibrated?

Describe the calibration methods.

o. Are the field sampling procedures consislenl with

the sampling and analysis plan?

- 26 ...

•
Describe inconsistencies

p. Are the current ~ampling procedures consistent

with past sampling procedures?

q. Are differences significant?

Explain

r. Has the same laboratory been used for all sampling

episodes?

If not, list the laboratories as follows:

Sampling

Episode

(Month/Year)

Remarks

Testing

Laboratory

- 27 -
-- - - -------

.~

E. Field Inspection - QA/QC Procedures (WAC -645(8)(d)(iv»)

a. Are the sample bottles properly cleaned prior to

samp1ing?

Remarks

b. What kinds of QA/QC samples are used:

(i) Duplicates?

How many?

(ii) Sample preservative blanks?

How many?

(iii) Transport blanks?

How many?

. (Lv ) Spikes?

How many?

(v) Transfer blanks?

How many

(vi) Other

Describe

c. Are the appropriate sample holding times observed?

(See Table 1)

Remarks

-_._._------

-----------------------------

- 28 -
.----

d. Are the samples labeled w i th the fo llowing:

(i) Sample number

(i i ) Well number

(i i i ) Data and time sampled

(iv) Name of. sample collector

(v) Preservatives

Remarks

e. Is a bound field notebook maintained to record

pertinent sampling events and procedures?

Remarks

f. Does the field notebook record the following:

(i) Well number?

(ii) Sample number?

(iii) Names of sample collectors?

(iv) Signature of sampler?

(v) Sampling method?

(vi) Presampling purging data (e.g. volume and

rate of purging)?

(vii) Field measured parameters (pH, specific

conductance, Eh, temperature)?

(viii) Water level measurements?

g. Is a chain-of-custody record maintained?

I f "Yes," does it record the following:

(i) We 11 number ?

(ii) Sample number?

(iii) Date and time collected?

(iv) Signature of sampler?

- 29 -
(v) Signature. of wito~ss?

(vi) Tests to be conducted?

(vii) Signatures of all intermediate handlers and

time and date of handling?

(viii) Signature of receiving laboratory representative

and time and date received?

h. Are the chain-of-custody procedures adequate to

maintain sample integrity?

Remarks

- 30 -
5. WATER QUALITY RESULTS (INTERIM STATUS) (265.92(b))

A. Does the water quality data obtarned to dat~ include:

a. Drinking water parameters:(T~ble 1), one year of

quarterly samples?

Remarks

b. Ground water quality parameters (Table I),

(i) One year of quarterly samples?

(ii) Annual samples after the first year?

Remarks

c. Indicator parameters (Table 1)

(i) One year of quarterly samples, four replicates

each sampling episode?

(ii) Semiannual samples thereafter, four replicates

for each sampling episode?

Remarks

B. Have initial background concentrations been determined

for the following parameters (Table I)?

a. Drinking water parameters?

b. Water quality parameters?

Remarks

--_.--_.. -_._-------

- 31 -

Yes No

•
------ ----- ---------- ---------------

., -_ .. •

•: ;' . c, ' : '.:' .

. ' . i '.r:j". ;;' '-, .

<': '.

. : .

.-!"\'.-,

C. For upgradient/background wetHr nave .t.he :.foll!owing· .

been determined for the indicator parameters:

a. Initial background arithmetic mean?

b. Initial background variance?

Remarks

D. Have initial background concentrations been determined

for the following parameters (Table 1).

a. Drinking water parameters?

b. Water quality parameters?

Remarks

E. For upgradient/batkgr6und wells have the following

been determined for the indicator parameters:'

a. Initial background arithmetic mean?

b. Initial background variance?

Remarks

F. For each of the downgradient wells 'after the first year

'of quarterly samples were the foltowing determined for

the indicator parameters:

a. Arithmetic mean based on at least fOur replicates

per sampling episode?

b. VAriance based on.at l~ast four· replicates per

sampling episode?

Remarks

- 32 -
G. Were the initial background values for the indicator

parameters statistically compared to the semiannual

samples after <thefirst·'ye~l1.fp:r::' ",~/ ,•.'.:,

': .

a. The upgradient/background wells?

b. The downgradient wells?

Remarks

H. Was the student t-test at the .01 level of s~gnificance

used for .the statistical cOlI)pa);~i~on?' '.-:, , ;";:'

Remarks

<, •

I. Have the comparisons shown a statistical increase' (or

decrease of pH) over initial background for:

a. The upgradient wells?

If yes~ was this information submitte~.with the

annual reported .dat.a " "'·',',',:.;t'.: r'~ "'."""'" . ,

:'_.~ '0 } 'J" .

Remarks

-: .• 1 1," ... -, ••••• : •

• • 'l._ ~. • ..... .- _ ••

b. Thedowngradient wells?

I~ yes, were the following com~leted?

(L) ,Were wells s how i ng i.i nc re.as e (o r..'pH (,1ecrease),

; res amp Led ~nQ ,:tested?,. : .,.~:_ . .. " '.

( it)

(i i i )

Remarks

• - ," ~: • .., -. • 'C ,..

Etology was notified within ~ev~ndays after

-the,inG~~as~.(or pH 4ecrea&e) • "." .~aS "; "1••.••••.co~fi~med?'

A ground water assessment~ plan was s~bmitted

to Eco l ogy , wit..hi-P 15,:9aY5 aft.e.r, the not i f i ca t i on? . . - ..,• !. I. t •.:' . • ..... : ". -.

. '. . .i'; . I: .; -
.' .'; :.,.

Additional Remarks:

... --", ."

"::."':.-" - t":"···

_ J •

II

.-

:: ..

• '.;-1

.'',r.

r: ;.4' ..

... ';'- .

.: 'J!

;,. .'

:[1' _

-"f

.,.- - ..-- ..

·s -: ' ... ''''. -

:.... ..... », ":iJI\.

---._---.~~- . -. ---- ~~_.. -----:-:--._-~~~_._~- --- -------.,--:-;--;-:";.'-

34 -
.J

I

Table'

SAMPLING AND PRESERVATION PROCEDURES INTERIM STATUS PARAMETERS

; .. '11 ,.~ .. "

Pro,e (sterilized)

Maximum Holding .... Time .

300 ml

200 ml(2)

200 ml

1 gallon

100 ml

'000 ml

'000 ml

Minimum Volume

30hours(2)(3)

6..:months· .

28 days

6 months

"24--hours'"

24 hours

.- -_.. .._~ .. ..

. Fiela. Aci.dified·

to pH<2 with

r: HN03

Preservation

Field Acidified

.... t.o pH <2wjth., .. HN03

Field Acidified ., --to·iil·j''<Twitti·-

HN0 3 .. , 4-&e-' _. _._- .

Field Acidifi.ed

to pH<2 withHN03

.... _. ", ... ,..FicJd.Ac.i.d'Lf5.~q .. to pH <2 with

HN03

T,P,G'

T,e

T,Pro

P,G

G p(2) ,

T,P ,

Container

Coliform ."-'baderi a

"-Fluoride

Parameter

Nitrate

.. Endrif:l

Lindane

Methoxychlor

-Ioxephene

2,4 D

. .~4 !S..!P.S! I vex

Radium

Gross Alpha

. Cross- Beta

Drinking Water

... 'ArsenicBarium

Cadmium

""'''CnrOniium

Lead .....Sel eni urn

Silver

Mercury

-- --. . _. "_.. _. . T,P

28 days

. - ..Cround Water- .Oua lHy

·Chloride

Iron

Manganese ..._ ... '~od-H:!ffl'

Phenols

T,p,e

G

"'" '--F'i'eld 'Acidi'fied*' _ ... -. -- ·_..6-..month~. ---. _

to pH <2 with

.. _ ..J:lNO,3 __ ...._." .""_"'."__... ""_"_.' .'__ .......

4°C/H2S04 to

pH <.2.: .. __._._._

50 ml

1000 ml

500 ml

. T,p,e 28 days 50 ml

Ground Water Contamination ..·-·- ..pW···

"'Spec'Hic

conductance

.,..roc ._- ...

-TOX .

·T ,p,e·

P,G

e, Tef 1on Itrrect

cap, no head space

G, Amber~' .... -

Teflon lined cap, no heed spue -. ,.

.. None~ He.teL

DetermineCl

. None-:.Fi e.td.

Determined

Cool--4~CTtl2S0t+(21.

to pH <2

'Cool '4°C; "add

, ml of 0.' M

._s.odium sulfi~~

None

... -.. " 28...days.

.._..._- ......-r-d~" ......- .-.. --

25'ml

100 ml

40 ml(2)

500 ml(2)

_. .e..__- Polyethlene C .: Glass'" ...

Pro· Polypropylene

·.r ....~._.Teflon ...

*In the event·that HNO cannot be used because of s.hipping restrictions the ... 'sample should -be' ref.r~qerat-ed·-to 4-~C,-shippe.d·imneDi.aU!.l)' and...a.cidi.f.ie~ on receipt at the laboratory. The container should be ringed with HN03• - .- .. - -~--~

**For' samples from nonchlorinated drinki~g ~a'ter"suppHes"concfir;t'r=iitecnf,S04

should be added to lower sample pH to less than 2. Analyze sample witnin 14 days.

(' )

nr- ~~~:;"'samPl-E!" ~'e'q;;i;-;;~~nts (Rev'.''', 2/84',

Standard Methods, 16th Ed., 1985 .

.~ \ ..