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DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE

CHAPTER 173-303 WAC

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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.
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7.1

POST-CLOSURE PLAN CHECKLIST

GENERAL POST-CLOSURE REQUIREMENTS

YES NO

1. WRITTEN PLAN

A. Is there a written POST-CLOSURE PLAN at

the facility? (40 CFR 265.118(a)) If

answer is "N/A" skip to cost estimate

checklists.

B. Does the post-closure plan cover the

MAXIML~ AREA EXPECTED TO CONTAIN

HAZARDOUS WASTE after closure, including:

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C.

a) Landfills?

b) Disposal surface impoundments?

c) Land treatment facilities where

. hazardous waste will remain?

d) Other remaining hazardous wastes?

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 CFR265.118(3).)

How many years of post-closure

care?

D. Does the post-closure plan cover all

areas where hazardous waste will remain

that were active as of Il/19/80?

Comments:

2. POST-CLOSURE PLAN 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 265.1I8(a))

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• C. Do the GROUNDWATER MONITORING Plans (40

CFR 265.117(a)(1); 265.118(a)(1)) include:

a) Number of wells?

b) Sample collection activities?

c) Sample collection frequencies?

d) Sample test activities?

e) Sample test frequencies?

f) Replacement of failed wells?

YES NO

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D. Is there a copy of the GROUNDWATER SAMPLING

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) Maintaining final cover (erosion

damage repair) frequencies?

(40 CFR 265.319(d)(1))

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

tr.eatment?

F. Do MONITORING 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)

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G. Do SECURITY REQUIREMENT plans 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:

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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.

YES NO

c

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»

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B.

C.

What is the amount of the estimate?

Is there documentation supporting the

post-closure cost estimate?

$------

a)

b)

c)

d)

Work-ups?

Contractor bids?

Operating history?

Other

D. Is the annual estimate multiplied by

30 to cover the entire post-closure

care period? (40 CFR 265.144(b»

E.

F.

Has the cost estimate been adjusted

by the 9% inflation factor?

(40 CFR 265.144(b»

Does the cost estimate cover all the

activities in the post-closure plan?

(40CFR 265.118)?--

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(i
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Including labor costs?

As well as the requirements of notice

to local land authorities and in deeds?

(40 CFR 265.119, 265.120)

G. Does the post-closure cost estimate cover

all required post-closure activities?

(40 CFR 265.144(a))

If "NO" spec.ify in comments below.

Comments:

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YES NO
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 impoundment cannot

effectively remove all contaminated soils from the unit during

closure, some post-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

Ii

c

Does the post-closure plan include at

least a narrative statement indicating

that the foilowing factors were

considered?

B.

a.

b.

c.

a.

b.

c.

d.

e.

f.

g.

h.

Control of pollution migration

via groundwater, surface water,

and air.

Control of surface water infiltration, including pr~vention

of polling.

Prevention of erosion.

Type and amount of waste.

Mobility and rate of migration.

Site location, topography, and

surrounding land use.

Climate, include amount, frequency,

and pH of precipitation.

Characteristics of the cover including

material type, final surface contour,

thickness, porosity, permeability,

slope, and vegetation.

Geological conditions, soil profiles,

and surface and subsurface

hydrology.

Unsaturated zone monitoring.

Type, concentration, and depth of

hazardous constituent, migration

as compared to background concentrations.

c

Comments:

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• C. In addition to the items listed in Section

G-2(2)(e), do post-closure maintenance

plans include?

a. Procedures for collecting. removing.

and treating leachate.

b. The frequencies of collecting.

removing. and treating leachate.

c. Gas collection activities.

d. Gas collection frequencies.

YES NO

Comments:

2. LAND TREATMENT (40 CFR 265.288)

Does the post-closure plan address the

following objectives and indicate how

they will be achieved?

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A.

a.

b.

c.

d.

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.

Comments:

B. Does the post-closure plan include at

least a narrative statement indicating that

the following factors were considered

in addressing the closure objectives?

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a.

b •

Type and amount of waste.

Mobility and rate of migration

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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, fi~al surface contour,

thickness, porosity, permeability,

slope, and vegatatian.

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.

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YES NO c

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• 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 "NAil (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 provided) 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

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a.

b •

c.

From cost estimate

From post-closure plan

Inspector's estimate

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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 po s t e-cLo sure plan

c. Frbmvisual inspection

B: Unit cost for reestablishing cover and

~egetation ($/yd 2 )

1Loaded with costs for support personnel.

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Applicable /NA

a. From cost estimate

C. Reestablishing cover and vegp.tation cost

($/year)

a. From cost estimate

3. FERTILIZING

A. Area involved. (yd2 )

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

Amount/NP c

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 estim~te

C. Mowing cost ($/year)

a. From cost estimate

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5. GROUNDWATER MONITORING AND WELL REPLACEMENT

A. Groundwater Monitoring

a. Number of wells

1 From cost estimate

ii. From post-closure plan

iii. From visual inspection

b. Unit cost for groundwater monitoring

($/well/year)

i. From cost estimate

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C)
"

epplicable/NA

c. Groundwater monitoring cost ($/year)

i. From cost estimate

Amount/NP

B. Well Replacement

a. Average annual number of well

replacements

i. From cost estimate

ii. From post-closure plan

iii. Inspector's estimate

b. Unit cost for well replacement

($/replacement)

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 entimate

6. MAINTAINING AND REPLACING FENCES

A. Maintaining Fences

a.

b.

Length of fence required (yd)

i. From cost estimate

ii. From post-closure plan

iii. From visual inspection

Unit cost for maintaining fences ($/yd)

i. From cost estimate

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c. Cost for maintaining fences ($/year)

i. From cost estimate

B. Replacing Fences

a. Length o~ fence to be replaced

annually (yd)

2No t e in comment section whether well replacement component is on

annual basis or not.

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Applicable/NA

i. From cost estimate

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 ~eplacing

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

Amount/NP c

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

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b. Unit cost for off site leachate

disposal ($/gal~)

i. From cost estimate

c. Unit cost for transport of leachate

($ / gal. /mile)

i. From cost estimate

d. Transport distance (miles)

i. From cost estimate

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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 replacement component is on

annual basis or not.

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C)
. ~Plicable/NA 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 leachate ($/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.)

c.

i. From cost estimate

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 FUNCTIONS

A. Hours of management time required to

administer the post-closure plan (hrs/year)

a. From cost estimate

b. From post-closure plan

c. Inspector's estimate

B. Unit cost for management time5 ($/hr)

a. From cost estimate

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C. Total administrative cost ($/year)

5Loaded with costs for support personnel.

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Applicable /NA

a. From cost estimate

.9. OTHER (SPECIFY) ($/YEAR)

A. Local land authority notice ($/year)

(40 CFR 265.119)

B. Notice in deed ($/year)

(40 CFR 265.120)

C.

D.

E.

(Total Other)

10. TOTAL ANNUAL POST-CLOSURE COSTS ($)

A. From cost estimate

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Amount/NP

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COMMENTS

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