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

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, r 

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

.•*.,~ * * .,'( * * * * * * * * .,'c * * ..,'r 'k * .,'( * ,.. * .,'r * ,'r 

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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. 

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

1.	 INSPECTOR INFORMATION 

WDOE	 Inspector: Phone fj: 

Inspector's Signature: 

• 

Office (circle one): NW SW C E IND
 

Date of THIS Inspection:
 

Date 9£ LAST Inspection:
 

Other Inspectors Present:
 

Name:	 Agency: Phone II: 

2.	 BUSINESS INFORMATION 

Business Name EPA/State ID II: 

Address: 

Zip Code: County:
 

Business Location (If:
 

Other Than Address)
 

Contact Person:	 Phone II: 

• 
-----------

, .
 

Business Representatives Present During Inspection: 

Name:	 Title: Phone II: G

3. NOTIFICATION FORM REVIEW 

Notification Form Filed: Yes No Date: 

Notification Form Revisions: Yes No Date: 

Date: 

Date: 

Is the information provided in the 

most recent Notification Form still 

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

Yes 

No 

Comments: 

4. ADDITIONAL INSPECTION INFORMATION 

Time Inspector Entered Site: 

Left Site: 

Were photographs taken during the inspection? Yes
 

No
 

If yes, how many?
 

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

in~inspection report.) 

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:
 

-2­

c 
• -. 

• 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 

• 

• -3­
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 of this checklist/questionnaire must also be 

completed. 

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

Transporter Name	 EPA/State IDft 

Inspector's Name ___________________ 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 Yes 

evidence on which this determination is based under Comments 

below, and do not complete the remainder of this part of the No 

checklist/questionnaire.) 

Comments 

-----------0
 

1.	 APPLICABILITY OF GENERATOR OR FACILITY REQUIREMENTS Yes No 

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

then the transporter is also subject to the requirements
 

for generators (WAC -240(3)).
 

Does	 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)).
 
• 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 less1 

Comments 

2.	 MANIFESTS Yes No 

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)1 

• 

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

the alternative manifest for such MRW (WAC -240(2))1 

(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 transporter 

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 d1rections 

(WAC -250(6»1 

D.	 Complete the following questions. For each question 

answered "Yes," complete the items (E., F., G., and/or 

H.) below which correspond to each "Yes" answer. 

• 

a . Does this transporter ever transport dangerous 

waste over public roads?' If "Yes," complete 

item E., below. 

-2­
b.	 Does this transporter ever transport dangerous 

waste 

complete 

by water 

item F., 

(bulk 

below. 

shipments)? If "Yes," o

c. Does this transporter ever transport dangerous 

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

waste 

d. Does this transporter ever 

out of the United States? 

item H., below. 

transport dangerous 

If "Yes," complete 

w~ste

E. 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»? 

o 

ii. Retain a copy of the manifest for his 

(WAC -250(4)(b»)? 

records 

iii. 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))? 

o
 

-3­
• 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))1 

•
 

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»1 

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»1 

,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)1 

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»1 

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 remaining manifest copies to
 

the next transporter or facility owner/
 

operator (WAC -250(4)(c»?
 

-4­
iii.	 Before accepting dangerous waste from a rail 

provide 

transporter, 

a copy 

sign 

to 

and 

the 

date 

rail 

the 

transporter 

manifest and G

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

G.	 Transportation by rail. 

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 trans­


porter (WAC -260(2)(b)(ii))?
 

d.	 When receiving dangerous waste from a generator,.
 

does the rail transporter sign and date the mani­


fest and return a signed copy to the generator
 o 

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 -250(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 ship­


ment 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))? 

o
 

-5­
f.	 Does the rail transporter ensure that a shipping
 

paper containing all the information required on
 

the manifest, except EPA/State ID HIS, 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 mani­


fest or shipping paper (if the manifest has
 

not been received by the facility) (WAC
 

-250(8)(c)(i))'l
 

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))?
 

-6­
Comments C) 

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

Yes No 

A. If the transporter has 

during transport, does 

a discharge of dangerous 

he: 

waste 

a. Notify the generator of the waste 

has occurred (WAC -270(1))1 

that a discharge 

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

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

(WAC -270(2))1 

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

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

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))1 

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 is in western Washington 

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

-7­

c 
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))? 

iii.	 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 

-8­
C

.' 

DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE, CHAPTER 173-303 WAC \ .,'r \ .,~ -k 7( * -k * 7, -k 'k -:, -:, -:, 7,	 -:, * * 1, * * .,~ * * * * .,', -:, * .,'r * * * * * * .,', ..,'r * 1, * * 1, -I, ..,~

PART	 II: 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. 

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

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 

inspection? (If "No," explain how the generator assures 

that no dangerous wastes are generated in the Comments 

section, below, and do not complete the remainder of 

this part of this checklist/questionnaire.) 

Yes 

No 

Comments: 

1.	 DESIGNATION (WAC -170(1)). Yes No 

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 wastes:
 

a.	 Does the generator have on-site, or have ready 

access to, equipment for obtaining and preserving 

waste samples for tests? 

o
 

o
 
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 

2.	 SHIPPING DANGEROUS WASTE OFF-SITE Yes No 

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:
 

Transporter Name EPA/State 10 fI 

• 

-2­
c Comments 

3.	 MANIFESTS (WAC -180). Yes No 

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 copy 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 moderate 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 Comments, below.)
 

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

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(l)(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(1)(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 I - the dangerous waste number for each
 

corresponding waste entered and described under
 

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

o
 

-3­
• D. Is signature of, and date of acceptance by the transporter 

obtained prior to transport (WAC -180(3)(a))7 

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

transporter, and give remaining copies to the transporter at time 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 WOOE 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»? 

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))? 

-4­
I.	 When shipping dangerous waste within the United States 

solely 

send	 three 

by water 

copies 

(bulk 

of the 

shipment), 

manifest 

does 

signed 

the 

and 

generator 

dated by o

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)): 

a.	 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). 

Yes No 

A.	 Does the generator package his dangerous waste for
 

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

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

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

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

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

C.	 Does the gf'nerat.or mark each package containing 110
 

gallons or less of dangerous waste, and display in
 

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
 

o
 

o
 

-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 placards, in accordance with U.S. DOT 

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

Comments 

5.	 IMPORT/EXPORT OF DANGEROUS WASTE (WAC -230). Yes No 

•
 

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

(If "No," 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 r~quirements (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))? 

-6­
ii.	 Written confirmation from the foreign consignee 

that 

(40 CFR 

the 

262.50(c)(2))? 

waste was received within 90 days o

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 

-----------0
 

G.	 TRIPLE RINSING (WAC -230(3), (4) AND -160). Yes No 

A.	 Does the generator triple rinse all containers which are
 

empty and which held ERW 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 

-~------c~
 -7­
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? 

(If "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))? 

'r 

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 

-16­
c 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 Yes No o 

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: 

Quantity 

Description/Dangerous Waste # EHW/DW (Month/Batch) 

(J
 

-9­
7.	 NON-PERMITTED SPILLS AND DISCHARGES (WAC -145). Yes No 

A.	 Have there been any nonpermitted spills or discharges
 

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.	 Not~fy 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
c.	 Are there any wastes which were reported on his latest 

Annual Report which the generator is no longer generating? (j 

If "yes," provide the waste description and Dangerous
 

Waste # as they appeared on the latest Annual Report:
 

Comments 

9. ADDITIONAL REPORTS. Yes No 

Does the department require the generator to submit any o 

additional reports as provided under WAC -220(3)1 

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 

--------------------------_._------­

-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 Yes No 

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 under 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? 

ii.	 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 lbs. (1,000 kg) of dangerous waste in 

a month or batch, or ever accumulate more 

than 2,200 lbs. (1,000 kg) on-site at any 

time? 

ii.	 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 p·roducts (WAC -081)? 

-11­
iii.	 Does the generator ever hold dangerous wastes 

on-site for more than ten days after the date 

the waste quantity first 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? 

Comments 

B. Ninety-Oay* Accumulation Limit. Yes No 

* 

a. 

The time limit is one hundred eighty days for 

moderate risk wastes held in containers or tanks 

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

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))? 

o 

b. 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)? 

c. How does the generator determine when the·ninety-day* 

accumulation period begins: 

i. When the waste 

-200(2)(a))1 

is first generated (WAC 

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 -20U(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.) 

o 

-12­
• Comments 

C.	 Personnel Training (WAC -330). Yes No 

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
c 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 progfam include 

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

i. Procedures for using, inspecting, repairing 

and replacing emergency and monitoring equipment. 

o 

ii. Key parameters 

systems. 

for automatic waste feed cut-off 

iii. Communications or alarm systems. 

iv. Response to fires or explosions. 

v. Response to ground water contamination. 

vi. Shutdown of operations. 

Comments: 

___________c
 

-14­
• D. Preparedness and Prevention (WAC -340). Yes No 

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 good working 

order: 

i.	 Internal communications or alarm system 

capable of providing immediate emergency 

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

Present?
 

Tested regu~arly?
 

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?
 

iii.	 Portable fire extinguishers, fire control 

equipment, spill control equipment, and 

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

Present?
 

Tested regularly?
 

Good working order?
 

iv.	 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?
 

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
E.	 Contingency Plan, Emergency Procedures and Emergencies Yes No 

(WAC -350 and -360). o 

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 

to it: 

revisions 

i. Maintained at the generator's site (WAC 

-350(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: 

ii. 

i. 

The plan fails in an emergency (WAC 

-350(5)(b))? 

Applicable regulations are revised (WAC 

-350(5)(a))? o 

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(S)(c))? 

iv. The list of emergency coordinators changes 

(WAC -3S0(5)(d))? 

v. The list of emergency equipment changes 

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

e. Does the contingency plan include: 

i. A description of the actions personnel must 

take in the event of an emergency circumstance 

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

ii. 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

c 
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(1))? 

h.	 Is the emergency coordinator (and his alternates, 

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

i.	 Familiar with all aspects of the contingency 

plan? 

ii.	 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 records 

kept on-site? 

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 o 

(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))?
 

ii.	 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))?
 o 

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 reporter
 

(WAC -360(2)(e)(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, 

the site, that: 

in the affected areas on 

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.l. 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
c 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 

recovered material that resulted from the 

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

Comments 

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)? 

o
 

(Complete Section 14., below.) o 

-21­
• 12. ADDITIONAL REQUIREMENTS FOR GENERATORS ACCUMULATING 

WASTES IN CONTAINERS. Yes No 

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))? 

c.	 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
G.	 Are containers used for accumulating ignitable or 

reactive dangerous waste? G 

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 #30, "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)?
 o 

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 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:
 

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 wast~s 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))? 

o 

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, 

and materials put in the 

or incompatible wastes 

same container? 

Describe which incompatible wastes 

materials are involved: 

or wastes and 

e.	 

mixed 

If incompatible 

or commingled, 

wastes 

are 

or 

these 

wastes 

activities 

and materials 

conducted
 

are o

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
Comments 

13.	 ADDITIONAL REQUIREMENTS FOR GENERATORS ACCUMULATING 

WASTES IN TANKS. Yes No 

A.	 Does the generator maintain a system of records which
 

assure that no wastes held in his tanks are being
 

accumulated 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)? 

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

corrosion inhibitors) (WAC -640(3)(a)(ii))? 

C.	 Does 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
D.	 Does the generator inspect at least once each operating 

day: o 

a. Overfilling control equipment to ensure 

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

it is in 

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)? o 

b. Observations of any conditions which could cause 

tank to leak or fail as specified in the written 

schedule? 

the 

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 

once 

the generator have records 

each operating day he: 

showing that at least 

a. Gathered data from monitoring equipment to ensure 

the tank was operated 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»? c 

-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, contain­


ment 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 (j 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)? 

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? 

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 human 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)? 

o
 

C)
 

-28­
iVa	 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. Yes No 

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 notifi.cations
 

sent to WDOE that there have been leaks into the leak
 

detection system (if any?)
 

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

-29­
DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE, CHAPTER 173-303 WAC 

i', * * 

PART IV: GENERAL TSD FACILITY REQUIREMENTS 

This part of the checklist/questionnaire applies 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.	 MODERATE RISK WASTE MANAGEMENT. Yes No 

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

which the % has sought and obtained from WDOE reduction in
 

the regulatory requirements applicable to such MRW (such
 

reductions must be specified either in the facility permit
 

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

modification issued under WAC ,-805(8))1
 o 

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 manage­


ment. 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).
 

2.	 FACILITY SITING (WAC -420). Yes No 

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
 

asked.)
 

Chelan Grays Harbor Mason Skamania
 

Clallam Jefferson Okanogan Snohomish
 

Clark King Pacific Thurston
 

Cowlitz Kitsap Pierce Wahkiakurn 

Ferry 

Douglas Kittitas 

Lewis Skagit 

San Juan Whatcom 

Yakima o

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

which has had displacement in Holocene times (WAC 

-420(3)(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 

-420(3)(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))? (If 

"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)(f). ("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
b.	 Is the facility located in an area where the 

local shoreline management master program permits C) 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 

----------------------------------------o 

3.	 SECURITY (WAC -310). Yes No 

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 violations of ch. 173-303 WAC (WAC
 

-310(1)(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
• 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 

•	 , .':'... 

4.	 MANIFEST SYSTEM (WAC -370). Yes No 

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
a.	 Sign and date each copy of the manifest to certify 

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

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 (M/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)(b))?
 

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 M/SP to the generator (WAC
 

-370(3)(d))?
 o 

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 sh1pments
 

he receives and the shipment described on
 

the manifest?
 

b.	 Detect the following types of significant
 

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

i.	 Variations in quantities of greater
 

than ten percent for bulk shipments?
 

ii.	 Variations in piece count (e.g., missing
 

containers or packages)?
 

iii.	 Variations in waste type, discovered by
 

inspection or waste analysis (e.g., acid
 

substituted for solvent)?
 

o
 

-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 

faciliti operations or personnel? 

b.	 If 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
Comments C) 

5.	 WASTE ANALYSIS (WAC -300). Yes No 

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

kept at the facility (WAC -300(5))1
 

B.	 Does the 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, includ­


ing where appropriate: data from existing documents
 

or publications; data on wastes generated from
 

similar processes; or, data from actual testing
 

(WAC -300(2))1
 

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
 o 

(WAC	 -300(3))1 

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))1
 

C.	 Does the waste analysis plan assure that the areas
 

described under item B., above, are adequately satis­


fied 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))1
 

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))?
 

o
 

-7­
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? 

ii.	 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)(f))? 

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 o 

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

c 
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? 

iVa	 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 th~ 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. 

iVa	 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). 

i. Determining the concentration in the waste of 

any substances which exceed the EP toxicity 

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

(j 

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

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

iii. 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? 

iv. If food chain crops are grown, procedu~es for 

determining the concentrations of arsenic, 

cadmium, lead and mercury, unless the 0/0 

has written, documented data showing the 

constituent is not present? 

v. Procedures to determine the compatibility of 

a waste to any raw materials or other wastes 

potentially applied in a given treatment zone? 

vi. Determining the compatibility of a waste to 

other wastes or materials held or treated 

nearby? o 

vii. Procedures for analyzing ignitable/reactive 

wastes to be treated? 

viii. Determining whether or not runoff collected 

from the active portion would be designated 

as a dangerou~ 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? 

iii. 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 

other wastes potentially disposed in the 

to any 

landfill? () 

-11­
v.	 Analyzing ignitable/reactive wastes to be 

disposed? 

vi. Sampling and analyzing leachate collected and 

managing the leachate if dangerous? . 

vii.	 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 ~ctive portion would be designated 

as a dangerous waste? 

h.	 Thermal Treatment (40 CFR 265.375). 

i.	 Analyzing any waste not previously treated 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
c 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). 

i.	 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 treat­


ment of similar wastes under similar condi­


tions?
 o 

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?
 

iv.	 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?
 

o
 

-13­
• E. Final Status Waste Analysis Requirements for Specific 

Waste Management Methods. 

[Reserved] 

Comments 

•
 

6.	 INSPECTIONS (WAC -320). Yes No 

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
iii. Notations of observations 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? 

c. 

iv. Operating and structural equipment that help 

prevent, detect or respond to hazards to 

public health or the environment? 

Areas subject to spills (to be inspected daily when 

in use)? 

o 

d. The 

are 

frequencies with which 

to be inspected? 

these areas and items 

e. The types of problems 

inspections? 

to be looked for during 

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 

·Management Methods. 

for Specific Waste 

Yes No 

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? 

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
• i i . 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 gathered 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., di~es) 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? 

ii.	 The surface impoundment, including dikes and 

vegetation surrounding the dike for signs of 

leaks, deterioration or failures at least 

weekly? 

d.	 Waste Piles. 

i.	 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
c 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?
 o 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). 

i.	 Existing instruments which relate to combustion
 

and emission control at least every 15 minutes
 

(e.g., instruments measuring waste feed, auxil­


iary 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 emis­


sions and deterioration?
 

iii.	 All emergency shutdown controls and alarm
 

systems at least daily to assure proper operation?
 

o
 

-17­
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 CFR
 

265.403).
 

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

cut-off and bypass systems) at least once each 

operating day? 

ii.	 Data gathered fro~ 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 weekly for signs of 

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

cracks, wet spots, dead vegetation)? 

F.	 Final Status Inspection Requirements for Specific Waste 

Management Methods. Yes No 

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
, G.	 Ignitable or Reactive Waste Storage Inspections. Yes No 

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.)
 

Comments ---------0 

o 

-19­
7.	 PERSONNEL TRAINING (WAC -330). Yes No 

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, or 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 cbntinued
 

employment should be documented.)
 

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 person knowledgeable in dangerous waste handling practices (WAC -330(1)(a))?
 

-20­
c 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, repa1r1ng, and
 

replacing emergency and monitoring equipment.
 o 

b.	 Key parameters foraut~matic 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: 

(J 

-21­

l 
8.	 PREPAREDNESS AND PREVENTION (WAC -340). Yes No 

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 

(l)(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) Cd) )? 

Present?
 

Tested regularly?
 

Good working order?
 

B.	 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))?
 

• 

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
c D.	 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))7 

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 Comments, 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 o 

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: 

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

-----------------------------------C)
 

-23­
9.	 CONTINGENCY PLAN, EMERGENCY PROCEDURES AND EMERGENCIES 

(WAC -350 AND -360). Yes No 

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(5)(a))?

•	 b. The plan fails in an emergency (WAC -350(5)(b))? 

c. The facility changes in a way that increases the 

potential for fires, explosions or releases, or that 

changes the necessary emergency respons~s (WAC 

-350(5)(c))? 

d.	 The list of emergency coordinators changes (WAC 

-350(5)(d))? 

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

(5)(e))? 

E.	 Does the contlngency plan include: 

a.	 A description of the actions personnel must take 

in the event of an emergency circumstance (WAC -350 

(3)(a))1 

b.	 A description of the arrangements agreed to by local 

police and fire departments, hospitals, contractors, 

and state and local response teams to coordinateemergency services (WAC -350(3)(c))? 

c.	 A current list of emergency coordinators, including 

names, addresses and 24-hour phone numbers (WAC 

-350(3)(d))? 

-24­
d.	 If more than one emergency coordinator is listed, 

identification of a primary emergency coordinator, C) 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 

brie£ 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))? 

F. 

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

waste shipment is received which cannot be managed 

at the f~cility 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))? 

Do the information and element~ descr~bed 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.) 

o 

G. Is 

or 

an emergency coordinator on the premises at all times 

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

H. Is the emergency coordinator (and his alternates, 

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

if any) 

a. Familiar with all aspects of the contingency plan? 

b. Familiar with all operations and activities 

facility? 

on the 

c. Familiar with the location and properties of all 

wastes handled? 

d. Familiar with the location of all records 

on-site? 

kept 

e. Familiar with the facility layout? 

f. Has the authority to commit the resources 

to carry out the contingency plan? 

needed (j 

-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))? 

ii. WDOE and either the government official designated 

as on-the-scene coordinator, or the National 

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

e. Does the assessment 

include: 

report (covered under d., above) 

i. Name and telephone number of reporter (WAC 

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

ii. Name and address of the facility (WAC 

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

iii. Time and type of emergency 

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

(e.g., fire, release) 

iv. Name and quantity of materials involved 

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

(WAC 

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 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))? 

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 

site, that: 

ensure, in the affected areas on the 

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))? 

j . 

ii. All emergency equipment listed in the contingency 

plaQ is cleaned and fit for its intended use 

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

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))? 

o 

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))? 

1. 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, time, and type of emergency 

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

(WAC 

iii. Name and quantity of materials involved 

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

-27­
iv. The extent of injuries, 

(2)(k)(v))? 

if any (WAC -360 

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)). Yes No 

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)):
 

a.	 Separating and protecting the waste from sources 

of ignition or reaction (e.g., open flames, smoking, 

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

-28­
c b. Confining smoking 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.	 Is 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 (WA~ -395(1)(b)(iv))?
 

e.	 Otherwise threaten human health or the environment
 

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

D.	 Does 

record 

the 

(WAC 

% 

-395(1)(c))? 

document these precautions in his operating o

Comments: 

11.	 LOADING AND UNLOADING AREAS (WAC -395(4)). Yes No 

Does the facility receive manifested shipments of liquid 

dangerous waste for management? () 

-29­
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). Yes No 

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(1)(c))? 

ii.	 Summary 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
iv. Monitoring, testing, or analytical data as
 

required under the specific unit requirements C~
 for interim and final status (e.g., ground 

water	 monitoring data, incinerator stack 

emission analyses, 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. 

waste 

The weight, 

using 

or 

the 

volume 

units 

and 

specified 

density, 

in Table 

for each 

1
 o

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

Table	 1 

Unit of Measure Symbol Density 

Pounds P 

Short tons (2000 lbs) . . T 

Gallons (U.S.).. .. G P/G 

Cubic yards . . .. . Y T/Y 

Kilograms . . . . . . . . K 

Tonnes (1000 kg).. . M 

Liters. . . . . L K/L 

Cubic meters. . .. . C M/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(1)(b))? 

-31­
e.	 If this is a disposal facility, does the % 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(1)(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))1 

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). Yes No 

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 Dangerous Waste Report
 o 

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
• 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 interim status, except for those facilities or portions of facilities which are 

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

totally enclosed treatment or wastewater treatment as these processes are defined 

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

and (5) if certain conditiollsare met. These conditions are certain general facility 

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

questionnaire. If these conditions are not met and WDOE has revoked the permit by 

rule, then some or all of this Part V may be applicable]. 

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

questionnaire and stands for t.he words "owner and/or operator." 

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

Facilit.y Name EPA/State ID/! 

Inspector's Name Date 

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

the sect.ions of this Part' V of the checklist/questionnaire identified for each type 00f 

unit. 

Containers (complete section 1.)
 

Tanks (complete section 2.)
 

Surface Impoundments (complete section 3.)
 

Piles (complet.e section 4.)
 

Land Tn~atm(-,Ilt (compJt>te section 5.)
 

LandfilJ~ (complet.e section 6.)
 

Incinerators (complete section 7.)
 

Thermal Treatment (complete section 8.)
 

Chemical, Physical, and Biological Treatment
 

(complete section 9.) 

o
 
• 1. ~~~~INERS (40 CFR Part 265 SUBPART I).	 Yes No 

A.	 Condition of containers (265.171). 

a.	 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 (describe 

these procedures under Comments, below)? 

B. Management of containers (265.173). 

a.	 Are all containers holding wastes kept closed 

during storage except when adding or removing 

wastes? 

b.	 Are all waste containers being: 

i.	 Stored in a manner that prevents leaks 

or ruptures? 

ii.	 Handled in a manner that prevents leaks or 

ruptures? 

iii.	 Opened in a manner that prevents leaks or 

ruptures? 

•
 

-2­
c.	 rgnitable or reactive wastes (265.176). 

a.	 Are containers holding reactive wastes that are
 

capable of detonation or explosion (designated by
 

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

a buffer zone equivalent to the Uniform Fire
 

Code's "American Table of Distances for Storage
 

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

-440(1)(b))?
 

b.	 Are containers holding ignitable wastes and
 

reactive 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 containers made of or lined with materials
 

which will not react with and are otherwise com­


patible 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," are these practices conducted in a
 

o

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.)
 

c.	 If wastes in containers are stored near any
 

wastes or materials that are incompatible, are
 

the waste containers protected from these
 

incompatible wastes or materials by means of
 

a dike, herm, wall, or other device?
 

If "Yes," describe the device. 

-3­
Comments: 

-4­
2.	 TANKS (40 CFR PART 265 SUBPART J). Yes No 

A.	 General operation (265.192). o

a.	 Is each tank: 

i.	 In good operating condition? 

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

fixture weaknesses, and any other problems 

that could lead to loss of wastes due to 

structural failures? 

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

o 

b.	 Does the % ever add wastes or treatment reagents 

to a tank which could cause the tank or its inner 

liner to rupture, leak, corrode, or otherwise 

fail hefore the end of its intended life? 

l'. •	 For any uncovered tanks, is each 'tank ej ther: 

1.	 Operated to ensure at least two feet (sixty
 

centimeters) of freeboard?
 

ii.	 Or else, equipped with a containment
 

structure (e.g., dike or trench), a drain­


age 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 cm) of the tank? (Note for calcu­


lation purposes: 1 cubic foot = 7.48 gallons;
 

] cubic meter =264.2 gallons.)
 

d.	 Are any tanks operated with continuous waste feed? 

If "Yes": 

] .	 Descrihe which tanks and wastes are continuous 

feed systems (i.f all, just writ.e "All"). (J 

-5­
ii.	 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 conditions which may cause ignition or 

reaction? 

.ii-i.	 Or f>lse, treat, render, or mix the wastes 

before or immediately after placement in 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)? (Note--If % conducts this 

activity, be sure to complete section 10. of 

Part IV: General TSD Facility Requirements 

of this checklist/questionnaire.) 

Describe which tanks, if any, receive ignitable or 

reactive wastes. 

-6­
Cj
 

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 Storage of Explosives,"
 

Table 77-201, 1979 Edition (WAC -440(1)(b))?
 

c.	 Are covered tanks used for holding ignitable or
 

reactive wastes located with a buffer zone
 

equivalent to the National Fire Protection Asso­


ciation's requirements for tanks J 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 o

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 Require­


ments of this checklist/questionnaire):
 

3.	 Treatment or storage of wastes in tanks? 

b.	 Placement 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.
 

(J 

-7­
• Comments: 

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

No C~

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 impoundment(s) solely for 

emergencies? -0 

b.	 Or else, treat, render, 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. 

C~)

-9­
• C. Incompatible wastes (265.230)
 

Are incompatible wastes or incompatible wastes and
 

materials ever placed in the same sur~ace impoundment(s)? 

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.) 

b. Describe which surface impoundments receive 

incompatible wastes and what those wastes are . 

• Conunents:

• 

-10­
4.	 WASTE PILES (40 CFR PART 265 SUBPART L). Yes No 

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). 

Is 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 

during 

flow onto 

peak 

the 

discharge 

active portion 

from at 

of 

least 

the pile(s) 

a twenty­ o

five 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 maintain 

design capacity of the systems? (Note--Collected 

run-off should be checked to determine if it 

is dangerous waste and, if so, managed 

accordingly.) 

c.	 Ignitable or reactive wastes (265.256). 

Are ignitable or reactive wastes ever placed in the
 

pile(s)?
 

If "Yes," does the % either: 

-11­
• 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 % 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.) 

ii.	 Describe which pile(s) receive incompatible 

wastes and what those wastes are . 

• 

-12­
c 

b.	 If a pile of waste is incompatible with any waste 

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. 

c 

Comments: 

-13­
..
 

5.	 LAND TREATMENT (40 CFR PART 265 SUBPART M). Yes No 

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 syste~ 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 method(s) does he use? 

-14­
c B.	 Unsaturated zone monitoring (265.278). 

a.	 Does the % have in writing and does he implement 

an unsaturated zone monitoring plan? 

Is the	 plan designed to: 

i.	 Detect the vertical migration of waste and
 

waste constituents under the active portions?
 

ii.	 Provide information on the background
 

concentrations of the waste and waste con­


stituents 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 c~res?

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 o 

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?
 

ii.	 The number of soil and soil-pore water samples
 

to be taken is based on the variability of:
 

1.	 The waste constituents (as identified
 

in the facility waste analysis plan)
 

in the waste and soil?
 

2.	 The soil types? 

iii.	 The frequency and timing of soil and soil-pore
 

water sampling is based on the frequency,
 

time, and rate of waste application, proximity
 

to ground water, and soil permeability?
 

e.	 Does the % analyze the soil and soil-pore water 

samples for the waste constituents that were found 

in the waste during analysis under his waste 

analysis plan? 

o
 

-15­
C.	 Ignitable and reactive wastes (265.261). 

Are ignitable or reactive wastes ever land treated? 

If "Yes," does the % either: 

~.	 Manage the waste in such a way that it is protected 

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/ 

questionnaire.) 

b.	 Describe which land treatment units receive 

incompatible wastes and what those wastes are. 

-16­
(J
 

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:
 o 

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.	 When making either of the demonstrations described
 

under b., above, is the information used to make
 

the demonstration:
 

i.	 Kept at the facility? 

ii.	 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 occur: 

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 Maximum Cumulative 

Capacity (meq/100g) Application (kg/ha) 

Less than 5 5 

5 to 15 10 

Greater than 15 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
{ .	 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 describe the
 

measures to be taken to safeguard against
 

possible health hazards from cadmium entering
 

the food chain, which may result from alter­


native 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
 

grown 

rates 

except 

and that 

in 

food 

compliance 

chain crops 

with 

must 

the actions 

not be
 o

described in f. i. through vi., above? 

Comments: 

(J 

-19­
• 6. LANDFILLS (40 CFR PART 265 SUBPART N). Yes No 

A. General operation (265.302). 

a.	 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? 

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 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.) 

• 

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 . Treat, render, or mix the wastes before or 

immediately after placement in the landfill so 

that the wastes are not ignitable or reactive (by 

-20­
c 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: 

i.	 Landfill the wastes only in nonleaking
 

containers?
 

i{.	 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?
 

iii.	 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-


I~

c 
• 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," is this waste either: 

• 

b. 

i. 

ii. 

Does 

free 

Solidified or chemically fixed to be a solid 

prior to disposal? 

Mixed with absorbent and placed in containers 

for disposal? 

the % ever landfill containers which hold 

liquids? 

:t' 

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) Cj in the	 landfill? 

If "Yes," does the % observe the following
 

requirements:
 

i.	 Are all inside containers sealed tightly,
 

nonleaking, and made of materials that will
 

not react with or be ignited or decomposed
 

by the wastes they contain?
 

ii.	 If DOT regulations (49 CFR Parts 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 o 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 wa~tes, other than cyanide or
 

sulfide bearing reactive wastes, treated or
 

rendered nonreactive prior to overpacking?
 

Comments: 

C)
 

-23­
7. INCINERATORS (40 CFR PART 265 SUBPART 0). Yes No 

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 corrosivity; 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 and 347(a)). ":,e 

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 ~ir 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
Comments: 

---------c~

o 

o 

-25­
8.	 THERMAL TREATMENT (40 CFR PART 265 SUBPART P). Yes No 

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 O/O'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.	 If "Yes," does the % conduct such open burning
 

or detonation in a manner that protects public
 

health and the environment, and in accordance
 

with the following table?
 

Pounds of waste Minimum distance of 

explosives open burning/detonation 

to property of others 

o to 100 670 feet (204 m.) 

101 to 1,000 1,250 feet (380 m.) 

1,001 to 10,000 1,730 feet (530 m.) 

10,001 to 30,000 2,260 feet (690 ro.) 

-26­
Comments: ----------( 

o
 

( ~\
 

-27­
9.	 CHEMICAL, PHYSICAL, AND BIOLOGICAL TREATMENT (40 CFR PART 265 

SUBPART Q). Yes No 

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? 

ii.	 Produce uncontrolled toxic mists, fumes, 

dusts, or gases in sufficient quantities 

to threaten human 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
c/
 

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:
 

o 

C.	 Incompatible wastes (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(1)(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 has) the % remove all 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: 

I' • 

-30­
• DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE 

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 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. 

~§:~n~~~

_nus WlSlE D'~lS'OM
-------

•	 CLOSURE PLAN CHECKLIST 

6.1.	 GENERAL FACILITY INFORMATION 

Facility Name: EPA/State I.D.: #

Inspectors Name: Date: 

Check the type(s) of unit operations that the % manages at his 

facility (refer to 6.3 for Unit Specific Requirements): 

Page No. 

0 Containers · . . · 13 

0 Tanks. . . · · 14 

0 Surface Impoundments 15 

• · · · · · 0 Piles. . . · · 16 

0	 Land Treatment . . . . 17 · · · · · 0 Landfills.	 18 · · 0 Incinerators	 19 · . · · · ·
 0 Thermal Treatment.	 . 20 · · · 0	 Chemical, physical and biological 

treatment. · . . · · · . . · . . . 21

· 

•
 

- 2 ­
•	 

YES NO 

6.2.	 GENERAL CLOSURE REQUIREMENTS 

1.	 WRITTEN PLAN 

A.	 Is there a WRITTEN CLOSURE PLAN kept 

at the facility? (40 CFR 261.112(a)) 

B.	 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 ­
----------

YES NO 

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 

a.	 surface impoundments? 

b.	 landfills? 

c.	 tanks? 

d.	 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 ­

o
 
YES NO
 

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 inspections? 

b.	 groundwater monitoring? 

c.	 maintaining cover? 

d.	 maintaining diversion structures? 

e.	 controlling erosion? 

f.	 maintaining vegetation? 

g.	 security reouirements? 

h.	 leachate collection? 

i.	 gas collection? 

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? 

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 ­
YES NO 

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-­

i. waste removal? 

ii. waste stabilization? 

iii. waste treatment? 

iv. waste disposal? 

v. placement of cover? 

vi. vegetation? 

vii. decontamination? 

viii. other (specify: -----) 

Comments: 

4.	 MAXIMUM INVENTORY (40 CFR 265.112(a)(2» 

A.	 Is there an estimate of the MAXIMUM
 o

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 non­


disposal surface impoundments?
 

c.	 wastes in tanks? 

d.	 wastes in piles? 

e.	 wastes in drainage pits? 

g.	 

f.	 wastes 

standing 

in 

liquids? 

containers? C)

- 6 ­
YES NO 

C. Does the MAXIMUM INVENTORY 

include the maximum amount 

(continued) 

estimate 

of on-site: 

h. 

i. 

j. 

k. 

1. 

m. 

sludge? 

contaminated soil from land 

treatment fields? 

contaminated soil from around 

tanks, containers, piles? 

contaminated soil from around 

tanks, containers, piles? 

process residues? 

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. 

.. '.:"'j 

a. 

b. 

c. 

whether soil is contaminated? 

whether decontamination residues 

are hazardous? 

whether process residues are 

hazardous? 

i', ' 

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 

B. Do the STEPS TO CLOSE in the plan include: 

a. 

b. 

c. 

d. 

removal of wastes? (40 CFR 265.113(a)) 

treatment of wastes? (40 CFR 265.113(a)) 

waste disposal? (40 CFR 265.113(a)) 

waste containment? 

e. 

f. 

g. 

h. 

i. 

j. 

k. 

cover? (40 CFR 265.310(b)) 

decontamination of equipment 

and structures? (40 CFR 265.112(a)(3)) 

groundwater monitoring? 

closure certification? (40 CFR 265.115) 

maintenance of leachate program? 

maintenance of gas collection 

program? 

security requirements? 

C. With respect to the REMOVAL, TREATMENT, 

OR DISPOSAL of waste, does the plan 

identify: 

a. 

b. 

c. 

the source and type of materials 

and equipment needed? 

the amount of labor required? 

the capacity, number, and location 

of trenches or cells needed? 

d. the area required for landspreading? o 

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, 

structures requiring disposal or 

decontamination? 

and 

b. 

c. 

decontamination procedures? 

method of treatment or disposal of 

residues? 

d. testing program? 

E. With respect to MONITORING, 

closure plan describe: 

does the 

a. 

b. 

c. 

d. 

details of the groundwater 

monitoring program during closure? 

soil testing and monitoring? 

maintenance of monitoring equipment 

during closure? 

other (specify: 

C) 

- 8 ­
YES NO 

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: 

a.	 describe leachate removal, treatment,
 

and disposal during closure?
 

b.	 identify the approximate volume of
 

leachate collected?
 

c.	 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 ­
YES NO
 

B.	 Is there a SCHEDULE for final closure 

activities? (40 CFR 265.112(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 265.112(a)(I))
 

b.	 total time required to close? 

c.	 the time for intervening closure
 

activities? (40 CFR 265.112(a)(4))
 

d.	 time required for key steps: 

i.	 waste inventory treatment?
 

(40 CFR 265.112(a)(4))
 

ii.	 waste inventory disposal?
 

(40 CFR 265.112(a)(4))
 

iii.	 removal of waste inventory
 

and residues?
 

iv.	 decontamination' of facility
 

equipment and structures?
 o 

v.	 installation of containment
 

and diversion structures?
 

vi.	 placement of final cover? 

(40 CFR 265.112(a)(4))
 

V11. planting vegetation?
 

viii.closure certification?
 

ix.	 other (specify: 

D. Does 

a. 

b. 

Comments: 

the SCHEDULE for final closure:
 

encompass more than 90 days for treatment,
 

removal, or disposal of hazardous wastes
 

after receipt of final volume of wastes?
 

(40 CFR 265.113(a))
 

encompass more than 180 days for
 

completion of closure plan activities
 

after receipt of final volume of wastes?
 

(40 CFR 265.113(b))
 

- 10 ­
• YES 'NO 

7 • GENERAL CLOSURE COST ESTIMATE 

A. Is there a written closure cost estimate? 

B. What is the 

estimate? 

amount of the closure cost $---

C. Is there documentation supporting the 

estimate? 

cost 

a. 

b. 

c. 

d. 

work-ups? 

contractor bids? 

operating history? 

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 

required closure activities? 

(40 CFR 265.142(a» 

If "NO" specify in comments below: 

all 

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. 

o
 

. - 12 ­
• 1. CONTAINERS 

A. Does the closure plan describe 

the following: 

YES NO 

a. 

b. 

c. 

the procedure for removing 

hazardous waste containers 

from the facility; 

inspection of waste containers 

for leaks; 

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. Doe$ the closure plan describe procedures 

for removing hazardous wastes from the 

tank? 

C) 

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. 

b. 

c. 

sampling methods 

testing parameters 

analytical procedures 

Comments: 

o 

- 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: 

- 15 ­
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? 

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: 

o
 

(J 

- 16	 ­
YES NO
 

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) c 

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. 

e. 

climate, including amount, 

frequency and pH of precipitation 

characteristics of the cover, 

o 

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 ­

c 
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) Cj 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 ­

c 
•	 

YES NO 

9.	 CHEMICAL, PHYSICAL AND BIOLOGICAL TREATMENT 

(40 CFR 265.404) 

A. 

B. 

C. 

Comments: 

Does the closure plan address the disposal 

of all wastes and residues? 

Does the closure plan describe the 

procedures for decontamination of the 

thermal treatment equipment and 

surrounding structures? 

Does the closure plan describe a testing 

program to determine if the standard 

of decontamination has been met? 

•
 

•
 - 21 ­
" 

6.4 VERIFICATION OF CLOSURE COST ESTIMATES 

C~ 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 " " 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.). 

o
 

- 22 ­
.­

•

Applicable!NA 

1. TREAMENT, DISPOSAL OR REMOVAL OF INVENTORY 

(40 CFR 265.112(a)(2)) 

A. On-Site 

a. Amount of inventory and residues 

*

to be disposed on-site (yd3 ) 

Amount!NP 

i. from cost estimate 

ii. from closure plan 

iii. from visual inspection 

b. Unit cost for on-site 

or disposal ($!yd3 ) 

treatment 

i. from cost estimate 

c. Total cost of on-site 

disposal ($) 

treatment 

i. from cost estimate 

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	 Amount/NP 

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 

Comments: 

------------c·
 

- 24 ­
Applicable/NA	 Amount/NP 

2. DECONTAMINATION 

A.	 Soil Excavation (40 CFR 265.280(c)(1)) 

a.	 Volume of soil to be removed (yd3 ) 

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 

(yd3 ) 

i. from cost estimate 

ii. from closure plan tll----­ 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 (yd3 ) 

i. from cost estimate 

ii. from closure plan 

iii.	 inspector's estimate 

- 25	 ­
Applicable lNA	 Amount/NP 

b.	 Unit cost for treatment/disposal
 

($/yd3 )
 

i. from cost estimate 

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 (yd3 )
 

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 -0 

c.	 Cost of off-site treatment/
 

disposal ($) excluding
 

transportation
 

i. from cost estimate 

d.	 Unit cost for transport
 

($/yd3 /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 C)

- 26	 ­
Applicable/NA Amount/NP 

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 

F. Total Cost of Decontamination ($) 

a. From cost estimate 

Connnents: 

e----------­

- 27 ­
Applicable/NA	 Amount/NP 

3.	 CERTIFICATION c: Applicable/NA	 A. Professional Engineer Hours (hrs) Amount/NP 

(40 CFR 265.115) 

a.	 from cost estimate 

b.	 from closure plan 

c.	 inspector's estimate 

B.	 Unit Cos~ for Professional 

Engineer ($/hr.) 

a.	 from cost estimate 

C.	 Total Certification Cost ($) 

a. from cost estimate 

Comments: 

o
 

*Loaded with costs for support personnel.	 () 

- 28 ­
Applicable/NA	 Amount/NP 

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 (yd3 ) 

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 ($/yd3 ) 

i. from cost estimate 

g. Unit cost of transporting 

material ($/yd3 /mile) 

i. from cost estimate 

ii. by map reference 

**

Include materials to be used for cover, for example gravel or clay, 

except for top-soil. 

- 29 ­
Applicable/NA Amount/NP 

h. Transport distance (miles) 

i. from cost estimate 

ii. by map reference 

c 

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 o 

B. Top-Soil 

a. Area to be covered (yd3 ) 

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 

o
 

- 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 ($/yd3 ) 

i. from cost estimate 

h. Transport distance (miles) 

• i. 

i. from cost estimate 

ii. by map reference 

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 ­
Ap~licable/NA Amount/NP 

c. Synthetic Liner and Buffer Material o 

a. Area to be covered (yd2 ) 

i. from 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 

on-site (yd3 ) 

to be obtained 

i. from cost estimate 

ii. from closure plan 

iii. inspector's estimate 

d. Volume of sand 

off-site (yd 3 ) 

to be obtained 

e. 

i. from cost estimate 

ii. from closure plan 

iii. inspector's estimate 

Unit cost of excavating sand 

on-site ($/yd3 ) 

-0 

i. from cost estimate 

f. Unit cost of purchasing sand 

off-site ($/yd3 ) 

i. from cost estimate 

g. Unit 

sand 

cost of transporting 

($/yd3 /mile) 

i. from cost estimate 

h. Transport distance (miles) 

i. from cost estimate 

ii. by map reference 

*

Includes other materials (other than clay and top-soil) which may be (). 

used along with the snythetic liner. 

- 32 ­
•

Applicable/NA	 Amount/NP 

i.	 Total cost of acquiring sand ($) 

i. from cost estimate 

j.	 Unit cost of spreading and 

compacting sand ($/yd3 ) 

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 ($/yd2 ) 

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 Amount/NP 

Comments: -----------c; 

o
 

o
 

- 34 ­
Applicable/NA	 Amount/NP 

5.	 REVEGETATION (40 CFR 265.280(c)(2)(ii)) 

A.	 Area in Need of revegetation (yd2 ) 

a.	 From cost estimate 

b.	 From closure plan 

c.	 From visual inspection 

B.	 Unit Cost for Acquiring and Placing
 

Seed, Fertilizer, etc. ($/yd2 )
 

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. 

\?i§I:~n~s~lDJ \\WRU6U~ WU1t \l\1\~\\l"
• 

POST-CLOSURE PLAN CHECKLIST 

7.1 GENERAL POST-CLOSURE REQUIREMENTS 

1. WRITTEN PLAN 

YES NO 

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 

MAXIMUM AREA EXPECTED TO CONTAIN 

HAZARDOUS WASTE after closure, including: 

a) 

b) 

c) 

d) 

Landfills? 

Disposal surface impoundments? 

Land treatment facilities where 

hazardous waste will remain? 

Other remaining 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 will remain 

that were active as of 11/19/80? 

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 265.118(a)) 

-2­
•
 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?
 

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 

treatment? 

F.	 Do MONITORING EQUIPMENT MAINTENANCE plans 

(40 CFR 265.118(a)(2)(ii)) include: 

a) Activities? (40 CFR 265.118(a)(2)(ii)) 

b) Frequencies? (40 CFR 265.118(a)(2)(ii) 

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)) 

YES NO
 

•	 

Comments: 

-3­
3.	 OTHER REQUIREMENTS o 

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 

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))
 

B.	 What is the amount of the estimate? $-------

C.	 Is there documentation supporting the
 

post-closure 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. 

F. 

Has the cost estimate been adjusted 

by the 9% inflation factor? 

(40 CFR 265.144(b)) 

Does the cost estimate cover all the C) 

activities in the post-closure plan? 

(40 CFR 265.118)? 

-4­

.0 
• YES NO 

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 crR 265.144(a)) 

If "NO" spec.ify in comments below. 

Comments: 

•
 

•
 

-5­
7.2 UNIT 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. 

o 

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 infilc. 

tration, including prevention 

of polling. 

Prevention of erosion. 

B. Does the post-closure plan include at 

least a narrative statement indicating 

that the following factors were 

considered? 

o 

a. 

b. 

c. 

d. 

e. 

f. 

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 

g. 

h. 

hydrology. 

Unsaturated zone monitoring. 

Type, concentration, and depth of 

hazardous constituent, migration 

as compared to background concentrations. 

Comments: 

o
 

-6­
YES NO 

C.	 In addj.tion 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. 

Comments: 

2.	 LAND TREATMENT (40 CFR 265.288) 

A.	 Does the post-closure plan address the 

following objectives and indicate how 

they will be achieved? 

a.	 Control of migration of hazardous 

wastes and constituents into the 

groundwater. 

b.	 Control of the release of contamination runoff in surface water. 

c.	 Control of the release of airborne 

particulate contaminants caused 

by wind erosion. 

d.	 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? 

a.	 Type and amount of waste. 

b.	 Mobility and rate of migration 

-7­
YES NO 

(~ c. Site location, topography, and 

surrounding land use. 

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 vegatativn. 

f. Geological characterization, 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: 

o
 

()
 

-8­
7.3
 

1. 

Applicable/NA 

er---­

2. 

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 

i tern 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 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.). 

INSPECTION/FACILITY VISITS 

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 costlfor professional level 

personnel ($/hr) 

a.	 From cost estimate 

C.	 Total inspection/facility visit cost 

($/year) 

a.	 From cost estimate 

REESTABLISHING FINAL COVER AND VEGETATION 

A.	 Area involved (yd 2 ) 

a.	 From cost estimate 

b.	 From post-closure plan 

c.	 From visual inspection 

B.	 Unit cost for reestablishing cover and 

vegetation ($/yd 2 )" 

lLoaded with costs for support personnel. 

-9­
Applicable/NA	 Amount/NP 

a.	 From cost estimate 

C.	 Reestablishing cover and vegptation 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 ($/yd2 ) 

a.	 From cost estimate 

C.	 Total fertilizing cost ($/year) 

a.	 From cost estimate 

4.	 MOWING 

A. Area involved (yd 2 )	 o 

a.	 From cost estimate 

b.	 From post-closure plan 

c.	 From visual inspection 

B.	 Unit cost for mowing ($/yd2 ) 

a.	 From cost estimate 

C.	 Mowing cost ($/year) 

a.	 From cost estimate 

5.	 GROUNDWATER MONITORING AND WELL REPLACEMENT 

A.	 Groundwater Monitoring 

a.	 Number of wells
 

i From cost estimate
 

ii. From post-closure plan 

iii.	 From visual inspection 

b.	 Unit 

($/well/year) 

cost for groundwater monitoring C)

i. From cost estimate 

-10­
~licable/NA Amount/NP 

c. Groundwater monitoring cost ($/year) 

i. From cost estimate 

B. Well Replacement 

a. Average annual number 

replacements 

of well 

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 

tt_ 

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) 

i. 

ii. 

iii. 

From cost estimate 

From post-closure plan 

From visual inspection 

b. Unit cost for maintaining fences ($/yd) 

i. From cost estimate 

c. Cost for maintaining fences ($/year) 

i. From cost estimate 

B. Replacing Fences 

• 2Note in comment 

a. Length o~ fence 

annually (yd) 

section whether well 

to be replaced 

replacement component is on 

annual basis or not. 

-11­
Applicable/NA	 Arnount/NP 

i. From cost estimate o

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 si.te 

disposal facilities (gal./year) o 

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 

($/gal./mile) 

i. From cost estimate 

d.	 Transport distance (miles) 

i. From cost estimate 

3

Total length of fence to be replaced over the entire post-closure 

period divided by 30 to obtain an annual average. 

4 . Note in cpmrnent section whether fence replacement component is on 

annual basis or not. C~)

-12­
ePlicable/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 

(gal.) 

of leachate disposed of on-site 

i. From cost estimate 

ii. From post-closure plan 

b. Unit cost 

($/gal.) 

of on site leachate disposal 

e----­

c. 

i. From cost estimate 

Cost of on-site leachate disposal 

($/year) 

i. From cost estimate 

D. Total Cost for Collection, Removal, 

and Disposal of Leachate 

Treatment, 

a. From cost estimate 

8. ADMINISTRATIVE FUNCTIONS 

A. Hours of management time required to 

administer the post-closure plan (hrs/year) 

a. 

b. 

c. 

From cost estimate 

From post-closure plan 

Inspector's estimate 

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

a. From cost estimate 

C. Total administrative cost ($/year) • 

SLoaded with costs for support personnel. 

-13­
Applicable/NA	 Amount/NP <==J 

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 

-14­

-0 
• COMMENTS 

•
 

•
 

-15­
fl. 

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 

3.	 Monitoring Well Installation and Construction 

4.	 Field Inspection 

5.	 Water Quality Results 

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 a 

detection monitoring program under final 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, a facility may have three different kinds of 

well constructions, thus, three monitoring well installation and construction 

checklist/questionnaires may he approlJriate. Subpart 4, Field Inspection is filled 

out at the facility during the compliance inspection. 

Whenever possible copies of drawings and figures listed in the checklist/questionnaire 

should be obtained and attached. These may include but are not limited to: 

1.	 An as-built drawing and geologic log (on one figure) for each 

monitoring well. 

2.	 Water table and potentiometric maps 

3.	 Hydrogeologic profiles 

4.	 Site maps such as topographic maps, well location maps, surface water 

and drainage maps, etc. 

5.	 Tabulated wate-r quality data. 

Note	 that. the federal regulations are reterenced in the checklist/questionnaire for 

interim status facilities and state regulations are referenced for final status 

facilities. 

Space for ad'ditional remarks is available at the end of the checklist. 

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * 
,~ .• 

(J Yes No 

1.	 HYDROGEOLOGIC CHARACTERIZATION 

A.	 Regional Hydrogeology (WAC -806(4)(xx)(B)) 

a.	 Is the regional hydrogeology and its relationship 

to the facility characterized? 

If yes, what data sources have been used to 

characterize the regional hydrogeology? 

(i) Published and other technical reports? 

Specify the reports used: 

(ii) 

(iii) 

Water well logs? 

Geotechnical borings? o 

'(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 use 

characterized? 

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) 

(xviii)(I) 

(it) Well logs for all wells (if availaldp)? 

(iii) Use and use rates for all production wells? 

- 2 ­
(iv) Pumping and static water levels? 

(v)	 Effect of on-site and off-site pumping. on 

the ground water flow direction? 

c.	 Does the regional hydrogeologic characterization 

include the following: 

(i) Identification of the principal aquifers 

(i.e. aquifers being used or which havf> 

potential use) that may be potentially 

affected by the site? (WAC -806(4)(x)(B) 

Remarks: 

(ii) Hydrogeologic profiles showing the relationship 

of the facility to the principle aquifers? 

Remarks: 

(iii)	 Water table contour and/or potentiolJlptric maps 

for the principle aquifprs? 

Remarks: 

B.	 Site Hydrogeology 

a.	 List the pertinent hydrologic and geologic
 

investigations ongoing or completed at the
 

facility:
 

Description of Work Ongoing 

Month/Year or Completed (Obtain copies of all reports) 

- 3 ­
tlL	 ~.

Cj 

b.	 Is a site map (or site maps) available that shows 

the following: (WAC -806(4)(a)(xviii) 

(i)	 Waste management areas? 

(ii)	 Monitoring well locations? 

(iii)	 Site topography? 

( i v )	 St1 r fa c e Wit t t> r f {';t til res and d r a i II age? 

(v)	 On-site water supply wells? 

(vi)	 Pertinent engineered structures and operational
 

units?
 

(vii)	 Is the scale of the map appropriate?
 

Scale used:
 

(viii) North arrow? _0

(ix)	 Legal boundaries? 

(x) Access controls (e.g. roads, fences)
 

(Xl) Surface and buried utilities?
 

(xii)	 Barriers to drainage'! 

c.	 Are the following characteristics of the uppermost 

aquifer (uppermost monitorable saturated zone) 

defined: (WAC 806(4)(x)(B) 

(i)	 Aquifer materials (sand, sandy gravel, sand­


stone, etc.)
 

Specify 

(ii) Thickness and lateral extent? 

Remarks: 

- 4 ­
(iii) Continuity beneath and adjacent to the site? 

Remarks: 

(iv)	 Water-table contour maps and potentiometricmaps 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 following methods were used 

to determine hydraulic conductivity/ 

transmissivity 

a)	 Estimates from grain size analyses 

Describe 

•
 

- 5 ­
o 

b)	 Laboratory tests (permeameter tests) 

Describe 

c) Slug tests 

Describe 

d) Pumping tests 

Describe 

e)	 Other -0 

Describe 

(viii)	 Methods used to evaluate slug tests, pumping 

tests, etc. 

Remarks: 

(ix) Effective porosity? 

(x) Storage coefficient including lateral 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» -(J 

- 6 ­
d . 

•	 If not., explain 

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? 

Remarks: 

• (iii) Relative hydraulic heads of the uppermost 

aquifer and the underlying aquifers? 

Remarks: 

f.	 Have the underlying aquifers been characterized? 

(WAC -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 sandstone, etc.)? 

Describe: 

• 

- 7 ­
C)
 

(ii)	 Thickness and lateral extent? 

(iii)	 Continuity beneath and adjacent 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: 

o
 

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, Yes No 

-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? -0 

Describe: 

d.	 Are the wells placed so they are not affected 

by the active portion? 

Describe: 

e.	 If ground water mounding is known to occur 

beneath the facility, could this influence the 

water quality of upgradient/background wells? 

Describe: 

f.	 Are wells downgradient of other activities 

(i.e. non OW) that are known to have 

affected ground water quality? 

- 10	 ­
c.	 Downgradient monitoring wells. (265.91(a)(2), 

~AC -645(8)(a)(ii)) 

a.	 Specify the number of downgradient wells installed 

at each management unit? 

b.	 Are the downgradient wells screened in 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 contaminant 

migration? 

If not, where should additional wells be
 

installed?
 

e. Is the ground water flow direction verified at 

least annually to ensure that the wells are 

adequately placed? (265.93(f), WAC -645(9)(e)) 

f. Do the monitoring wells show water level 

variations due to seasonal or hydraulic (e.g. 

tidal) fluctuations? 

Remarks: 

- 11 ­
c 

( ]	 .. a.,

3.	 MONlTORING WELL INSTALLATION AND CONSTRUCTION Yes No 

(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: 

o
 

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? 

C~

- 12	 ­
,l 

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 decon method. 

f.	 Were the drill, drilling equipment, and temporary 

casing decontaminated between borings? 

- 13	 ­
Describe the 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) singie well o

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 materials 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) 

o - 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 seals were 

installed? 

Remarks: 

i.	 Were well seals installed? 

If yes, describe the type of seal and the method of 

installation. (For cement grouts specify the 

water/cement ratio, bentonite/cement ratio, etc.) 

- 15 ­
01
 

o
 . j. Were bentonite pellets placed in the unsaturated 

zone? 

If yes, were the pellets hydrated (wetted) 

they were installed? 

after 

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 

installation 

samples taken 

(grout, 

of 

sand 

all materials 

pack, bentonite, 

used in 

well
 

well o

material, etc.)?
 

Remarks: 

E. Well Development for Wells through 

a. Were the monitoring wells developed? 

b. Circle the well development method: 1) Air 

2) pumping, 3) overpumping, 4) bailing, 5) 

block, 6) raw hiding, 7) other (specify) 

lift, 

surge 

c. Describe the equipment used for development. 

- 16 ­

c 
l1.1 

d.	 Describe the duration of development. 

----_._--... _._­

e. What was the volume of water and sediment removed 

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 

i.	 Were drawdowns and recovery measured during water 

yield determinations? 

If yes, specify: 

• - 17	 ­
.L-J
 

o
 

4.	 FIELD INSPECTION Yes No 

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: o 

d.	 Do these procedures adequately identify: 

(i)	 The equipment that will be used for evacuation? 

Remarks: 

(ii) Method of decontaminating equipment between wells? 

Remarks: 

(iii)	 Depth(s) in well or borehole from which water will 

be evacuated? 

Remarks: 

(iv)	 Pumping rate and duration (or amount as 

appropriate)? 

Remarks: 

- I B ­

c 
d . 

• (v) Special procedures as necessary for evacuation 

prior to sampling separate phases of immiscible 

contaminants? 

Specify: 

e.	 Are these procedures 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) in 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 ­
o 

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 o 

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 ­
n. 

1.	 Are these procedures appropriate? 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 

adequate and require correction? 

are not 

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 sea~s sloped away from the well? 

e. Does the integrity of the surface seal appear 

adequate? 

f. Are the wells clearly labeled? 

Remarks: 

------_._---------------------­

- 21	 ­
o
 

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-contact 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. o 

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	 ­

c 
CJ ~,

. t .iJ 

• g. 

h. 

Is the depth of the sampling intake measured to 

verify that it is properly positioned in the well? 

Describe the sampling materials that the sample 

water comes in contact with. (e.g. PVC, teflon, 

stai~less, etc.) 

(i) Suction tubing/piping 

(ii) Discharge tubing/piping 

• f. 

g. 

Is the pumping/removal rate measured? 

If yes, what is the pumping rate? 

Is the purging equipment adequately decontaminated 

between wells? 

(i) Describe decon methods 

Ciii).. Pump/baler 

(ii) Describe decon methods that require correction 

• 1. 

j . 

Remarks 

Are special methods used to prevent sample aeration? 

Remarks 

Are the samples field filtered for: 

(i) metals? 

(ii) others (specify) 

If yes, what is the filter pore size and which 

brand of filters are used? 

1 D. Field Inspection-Sampling Procedures (WAC -645(8)(d) and 

a. Are the samples obtained immediately after purging? 

If "No," specify the time that elapses between 

puroging and sampling 

Is this elapsed time appropriate for the parameters being tested? 

Remarks: 

b. Are the samples obtained by the same personnel 

during each sampling episode? 

Remarks: 

(3)) 

• ..1
 

- 25 - ­ - 23 ­
----------------

c 

Cl (j 

c 

c.	 Circle the sampling method used: 1) air lift, . k.	 Are all samples sediment free? 2) centrifugal pump, 3) peristaltic pump, 

4) electric submersible pump, 5) gas-contacl If not, specify the wells with sediment positive displacement pump, 6) non-gas-conlact
 

positive displacement pump, 7) bailer, 8) other
 

(specify)
 

1.	 Are the types~',of bottles used consistent with d.	 Describe the make and model of the sampling the parameters to be tested (see Tabl~' I)? equipment.
 

Remarks
 

e.	 Is the sampling procedure consistent with the 

parameters to be tested? Remarks 

m.	 What parameters are tested in the field: 

(i)	 pH? 

Specify' meter make and model 

£ . Is the sampling equipment dedicated to the weJI? 

(ii) Specific conductance? 

(i)	 If not, describe the decontamination procedures Specify meter make and model between wells. o 

(iii)	 Temperature? 

Specify' thermometer make and model 

(iv) Eh (Redox potential)? 

..	 Specify meter make and model (ii) Are the decontamination procedures adequate? 

Remarks:
 n.	 Are the field instruments calibrated?

Describe the calibration methods.
 

f.	 Are water levels measured: 

(265.92(3), WAC -645(8)(£)) 

(i)	 prior to sampling? o.	 Are the field sampling procedures consistent with 

the sampling and analysis plan? (ii)	 during sampling?
 

Describe the method
 

c 

- 24	 ­ - 26	 ­
tl.
 

d.	 Are the samples labeled with the following: 

(i)	 Sample number 

(ii)	 Well number 

(iii)	 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 proc~dure~~

Remarks 

Does	 the field notebook record the fo11owl.ng: 

(i)	 Well number? ,1 f e (ii)	 Sample number? 

(iii)	 Names of s'ample 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 maint~lned?

If "Yes," does it record the following: 

(i)	 Well number? 

(ii)	 Sample number? 

(iii)	 Date and time collected? 

(iv)	 Signature of sampler? 

- 29	 -

Describe inconsistencies 

p. Are the current sampling procedures consistent 

with past ~ampling procedures? :; 

q.. Are differences significant? 

Explain 

r.	 Has the same laboratory been used for al~. sampling 

episodes? 

If not, list the laboratories as follows: 

Sampling 

Episode; Testing.. 

(Month/Year) Laboratory 

'. 

. :~.

", 

Remarks 

.', 'L~.

- 27 ­
(1.
 

...:}, c C) E. - Field Inspection - QA/QC Procedures (WAC -645(8)(d)~iv))

a.	 Are the sample bottles properly cleaned prior to
 

sampling? (vi) Tests .to be conduc'ted?,.
 

f~f~	 i 

Remarks (vii)	 Signatures of all i~termediate liandlers and
 

time and <i,ate ()f .,~a,~~~_:l.~g?
 :r" r~

(viii)	 Sign~ture of receiving laboratory representative 

and'time and-'tt"ate"':re-ceived?--" 

b.	 'What kinds of QA/QC samples' are used·:·- h. Are the chain-of-cust<)dy- 'i)'rocedures adequat'e to
 

maintain s,am~le integrity~ :,
 

(i)	 Duplicates?
 Remarks
 

How many? 

'I"	 ',~. . "1 ' 

(ii)	 Sam~le preser~itive blanks? 

Lt ,-

How many? .]j . 

How many? 

(iv)	 Spikes? -c I'	 

How many? 

.Ie o -----------.-~," 

(v)	 Transfer blanks? L
 

How many -' _
 

(vi)	 Othe,r "
 

Describe
 

c.	 Are the appropriate sample holding times observed?
 

(See Table 1)
 

Remarks 

-J,:, 

c
 - 28	 ­ - 30	 ­
5.	 WATER QUALITY RESULTS (INTERIM stAtus) (265.9Z(f>j) Yes No 

A.	 Does the water quality data obt~trtE!d·~tihdcite;iriclude:

a.	 Drinking water parameter~5ti~~~~~1);oh~yearof 

quarterly samples? 

'r ::)t'h,~~~+:0jtrJ.	 U:,:·<,~'.... 

Remarks	 ':,' :,~.} ~:}..;:\;f' :,":~',.',/",: ,," C' 

.t.... 

. .~.

, ,

b.	 Ground water quality par~ril~'ter's'iCTable 1),
 

(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, 

each sampling episode? 

four replicates 

(ii) Semiannual samples thereafter, 

for each sampling episode? 

four replicates 

Remarks 

B.	 Have initial background concentrations been determined 

for the following parameters (Table I)? 

a.	 Drinking water parameters? 

b.	 Water quality parameters?
 

Remarks
 

•	 

----,----------------------­

- 31	 ­
cl	 .~
 

.'J 

," 

(' 

; , r~·ij

i. 

t~.

',·.i"!;

(ft~·

I: 

jO [(!.~

! .:. ~:'i.

:) .~ ·~i.

-; 

;:;.:; 

'f ~;;

i'~:

:', ~::

:~I

~.;;/f

~~.,'~J:"J'~'

~:'.~;

-,..[fe.-

:h7::U6':~·g._~;

:..~- .:.~~: ..) ::"':,,, .~

,-i;i 

__ .j, ':~~,;.

G !;

",: 

"'::

:..~~

.. 

:;~:.:

::'<~.~~:"

.'-? .": Y.: :.!.: ;'.' .~. ",:. . o

c.	 For upgradient/background ·'\\iel:llS:··1ia~e;··~th~:":fel~tiWirl-g,·~:·f; .. 

been	 determined for the ,~ndicator :patal1le'ters: :.~ :':~' .. t-#..,~~,. ~.~j~ f :'" ;~.~{ /. ~~~.: :', i .!.~ (.:.	 ; .. 

a'. Initial background a rithmetic 'me:an? 

..-.:j . .....,. ... --... ..... ----.
 ... -_... ..;.;..... -"-.--. ..... _.. _.. - ... _.... -.~._-.- _._~ ..­

"Remarks 

. r :;. . "!l '.. '~"'~/ :".) .;.:",,; :: ., 

·D. Have initial background 'Ci·6nceri·tr.a,tions been determined '" 

for the following parameters'(Table 1). 

a.	 'tirinking water-para~eters?

b.	 Water"quality parameters?
 

Remarks.
 

--",....,...---:-':-.-,-.;.,."...,.--:---:------:---:--------­ ,;I:. .,.: t~ • 

\.\ .. . ',', 

. '. . J .\	 ~:. 1": •. ' '.: ~~ ! . 

---------------~----------

o . E.	 For upgr~di~ht/backgro·undwells .have' the· following " 

been determined> for the indicator paranie't>ers: f •.'!',' 

a. 

" Remarks 

.;.....	 t: ".: '." ... 

F.	 ..For ea'ch \of,·:the· downgradient 'welTs.:-:after t.he first :'year 

'of . quarterly samples wereth~:'ftifl·t>wingt';·(;letermined for 

'the indic:ator p.~r~meters:

a.	 Arit:hinet"ie ":-mean .:based·'·on~: ~t' ~least· fout.···rep lica tes 

·per:sampl.ing episode? 

b·..·· ;',' VA.ria~ce:., based; on:iat l~ast fout.'"' tepl1J:~ t'es~;! per 

sampling episode? 

'.," 

- ...-..... -. .-, 

.:.' Remarks. ------.;.;;...,;.~--"'---------------

C~)

- 32 ­
"r~
 

G.	 'Were the initia1' ibackgr'ound va'i:~e,~ (o,r' t~e :~~dic~,_t9,r parameters statist'ical1y comp~r.e,d JO ,:t:h:e ~~~,~;~~~~l

samples aft!';£;ithe:.~~:c~:~~~lMle~~,:Lr~r:;:'!~'i;:::~:i,}~,~' ';':" .: ," 

,a. The upgradient/bac,lt,ground ,wells?' 

.\:: r~·..f;.~~:G .. :. ~::J:.i\:; "! ~-~. n:::~ i~~~I"~':J'~~~~~'~~'~' .... .~:~,-..; . 

b.	 The downgradientwells?
 

:Remarks
 

"~'';' •• - .... :...~:: ';0••:-- ._-_.'.-.~~'

," :--....;:_.._,. -;....;:; .. ''::':':;.':.:.: 

H.	 Was the student t-test at"rhe"- '~--O'l-+~VeT~9f'::':s'~gj'fificance

used	 for,.the statistical ,comp:~~j.~Jl:?>,r~'~'·L::'r~~~';,i' L,:", 

,':: ;,: (\~: or J ;,~ '+';~:.; ~',:~f.~:j~::¢.;}(I,:/,:'".. '" "': -"J :I " 

'Remarks 

" 'j.-;" 'j :: ", - , : ' ,.; • .'~t·1

~, • I . C .~

I.	 Have the comparisons shown-'a statistlc'a'! :::in'crea-'s'~'~;'(ri~

decrease, of pH)., ove~ _,,~n.~_,~,ial backgro~~d, for: 

, a.	 ' The ',l~p'~:radient:,_.~~~.:l_~?. 

If 'ye,.$,; ',.lNa's"thi.$,<,j.nf().rmatj.9;I1_suR~i~~,~,d "wi ~~lJ' ~~~':" ':~

annual, reported ,d,at~? " ,: ;:fii: '"fJj~;: ,:h)::-' , r: :,:::: ,.,: ~,(~.::'7L ,,"t.';<':' 

, Remarks 

b. .­ ...... ,'.:...~ ..•• .:;:...~ ...I'.- .•--=-~ . 

.;(i), .. :,were' w~11s. s'l)()W~qg,~~in9~e..~~~-'~l'~,9,:f~,!~pn,.';9,e~J·i·'~!~~~)", ~\:, ',1 

1 c , '.' resamp);t!\Ii!lId",~c:s~'ld?,d";;".;:;-';,;~~i:;~~; \, i;: i~;j{;::~

(ii) Ecology was~notified wi~hiq s~~~~fda~s:~ft~i

';,", ~he(in<::t:f;lase::(9.f;:pH"i 4e'<;:t;4j~~~J;;iW~~:·,~Q~,f.~,~m7q? '," , 5: 

;..:-;~ ~~ ~": t~:.~: ~~ ::, t'j ."~. ~.~ (,; ~~ ~J.;~' ~'~j?' :~) "]' 

(i ii) A ground .:wat,er ;assesslllen~ i p.lan.,~,ias slibmi~ted

. -,:.to,~ Ecolog~", ~iJ,h:~~: J'?~~.4~Y~. ~~f,~e:\~:,t.~:~4,.p..~;~Jf±~-~t;ion?_;

R~marks

. ~';"':"':.'- ,-- \,", . :. 1',':'---:;.:--;:' -::.. 

"- :'33 -;;.: '" ....-- -".
 
0. f:9:'.\ .t.".J 

r ~!tl&1

::·1-.' .i~ "~'

i.~;!XJ:i.;.::.·~:;~i:~:";~tJ.I~~~~·~:·-(~:~~:~~:~~:·i:::;: r:: :~~~~:~~::,\~r~:;;:~~~:<;B:.: .. ·AdditionalRematks: 

. ,;. .•.... _:~:...:... ..._-. .. . 

I .:. r"[.): • ',;.: 

\c:', .. , ~.'

..)~:: .~;, . 

, '.-.-'.:.!l.:." 

, _ ~J r ~)

,; 

" 

;'C.: -;~ ':. 

• •• :.01 '.:' •.,1..... 

J. :,:·,5~.!:'?< ..11. 

"I',.!: ~, ...: 

2". ;'; ':'. 

II!" 

;.~ :.. .... 

.' ':" ,,' .,:j . 

i:"" .;', r.. o' 

.:. .,.. 

....:.... 

-.:: : 

, ..: 

'... ·1; .... 

I'" f'~~

. !~·,t;. ,?:1C ~,::,: '-.: ".""1 ~"'l: '.. ~: " ?:'i:: ..Jf .. ;.... :.:.:~.... ·.:.~·~~·ir~ ..'!~::: ", ;':'~..... ': :; ;~i.\. :;
 r'~:1 C"":c ~.,~ :"i.": ·~S::t "-' '); :,..;'1:-:···. " 'l·.~~.· . ...,:.1-.. -'2 '." ,. "
 

....... : t.~~i.~, : ....
 :"·£,1\1:: :. t/" ~:t:;:? ..-:~; h'i ii..:t: ~'. ": !.:, :-. .......'~.; .. "., ... r 

._-...''; ···~---~ ...._R..


; .~'. .:' . -';, ".~.

."/l.~:." ";.:' ;~"~ "~:..: 

,.. :,<,~.,:.~~,.;~ ....:~~.::.. --::!".' 

',; ; •. n j' rt:t ; \' .,': .~ !".: r: 0 

~.',:, "':: \.':,: i! 

- 34 ­
tl. I 

..
 Table 1 

SAMPLING AND PRESERVATION PROCEDURES INTERIM STATUS PARAMETERS • ., _.. ,..,.. __...._. _." _. :... _.' _. __ .. _... _.. .__... ... .'.;'~~:;0h,J~i1!~':~'. :.. :::·:A ~:, :"".'.:~~~.:;:., ;.·t.1:",:·~; .• _,_ .•.. .', 1'. 

Contai"er Preser.vation Maximtl'!' Holdi~g ·.Mini~um Volume Parameter _.,. ~" •. _.."" .....:.-_._-_..---:-.._ .._-:.......-..• ···7_:·:;·::..·:~::·':" ..---=::·.-:.~-:-:-:;.:-.::.:;· ..:..·:.~:-:-'..-~:::: ~}:,T7:.:-~ '.::7 .:"- :-:.',':-'-'


Dr; nki n9 Water 1.000 ml .. -- -ArS-enie: .. -· T,P:.-:-...··_·-..···-.-o:;·-:-_..~--_· .._..-=·f~~~·~~~~e~~~~~--=::.-:--. :-...::-::.:.:-:~ ..§,~~~~~~~-::..; .... _: :;;:''':. '.,

Bar-fum HN0 . Cadniium 3 __ '._. ~.,. __... ~. ...--:=-:.;=._==-=-.._~=--=~~A.~.:...:-:~--::::_ ...:=::::.:-:.. _~~.:_._:;..:;.': _.~

..- "-:Cnromfum "-""" .-"'''-- _ .
 

. Lead .
 

. .....Sel eni urn. ... . .. __ . -.. . -::' -_.. -:-.::..:::--_._..-:--:::-.. ~:_-:::-:;-:..::; ",::;~,:':::-::-:::-:-";::.':;~::-:.'; ::.. : .:.;:,:",.:' .: ·::···.. :tf)·--····__ ··..
 silver' ­ Fi.eld .Aci.dif.i.ed P = 13. days(2) Mercury . 200 ml (2) ... :. _..... _._t.o.pt\..:S.2._~j.~h. __._..__._ .._.....,g .-,.2:~., ~a.y~ ._ .. _. _..._.. . .'- HN0 ' . 

3 .300 ml 

----Fl-uoride- -----' -'" ... .. __ :~; ~: ~~~ ~:~. ~~~~~~~.~_ "c.-.~~-~_.~ . ". :...' 8.d.~r.;.,: -....-... ,"'"'' 

HN0 . 3 100ml 

Nitrate .~~-:-: 1.,p'~{f:,-_ .... .. ' ...:-_. -.:.-.:..... :.... .. :4~-:--;:-:=::-:-:;::;::.::::-:·:::· -:: . ..:-"'.:" .:::~~:-;::hout"~::.~:;..·~: '.'..: .::';.-" 

1000 ml T,G ·Fiel~Acidiffed 24 hours .. EJ1Qr-i.l:.l... ..._... _ ...._.... . :.~q:' .pH·-<2.w.i.~h-::::-:::::: ..:. Lindane .HN0 ' Methoxychlor 3
 -lox-aph~ne...
 2,4 D ...
 

,~.~~~.s__J.p. ...~! 1vex .. :'-:-6..;months· .. 1 gallon 

Radium -·fiela.:AcHHfieet.:., . 

. .to .pH <2' wi.th Gross Alpha
 

"ero.s·s· B.eta ...... --.. ":;--..--:::-:-'-' ..:- .~~. :._-:-.~·HN03·:·,:·_· -.~:'.:::-:.~:." ...:-­

200 ml Pro,G (sterili.zed) Cool 4°C 

...-'" ...~r.ound .Water..OualJ.ty ..'.;:..:.' ._.... . so ml -··Chl~ride T;P,G 

1000 ml -'--I;:;m---'--'''- --~ '"--:::~:-:-:--:--'':T;P'''-_.::.~- ::-._... _ .. ·····------···Fi-etd:-Ac;:tdi-f:l.ed*···----·--- :.- -:---6-monUl~"----'--'

Manganese to. pH <2 wi th - ..... .. .... .. , . 

...._ .... "Sod-i-ttm..,· ,:,,,.,. -----..--·--='.·..·,=c.;·:;,".=::· . . -:::-:..•~. -'--' HN0.:-: 3':-:::-"':'-:-::-;-":--::"'7'-'::'..-:-"-:-"--'--;'.':'=-:-' ......:.:.... -~'--'

500 ml ~_~,~~~~_~. G 4°C/H2S04 to 28 days • C ..,:" - ... - '--' -'''''.' ':. ':':'.:'..::'__ • .. .... '.: .pH -e:=Z.:..._... --..-.-:----::... -::..-- -.-"-'._-~" '-:~:'. '.--~"'"

SO ml .....~I,l.Lf.!l.~~. T,P,G Cool, 4°C 28 days --.---' ;_.... ....._.. :.....~:~~ ...;=_..-:-_..,._....... ."'--".'_...- .~. -"-'-"--'- ....


Ground Water Co~tamination 2.5 ·ml -.-= ":":. :·..·T,P;G :. '::.~- -:~ .: .~:.:.- _ ".:: ::-:.~~:;~~~~:.:::::::..:: :.~.:- .. --~ JJQ.~.L~ :~.: . 

100 ml _..... '.-- 'SpedJ.i c . _::....,._P ,G .';"_;:-.. . None~E.i.eJ.sL.. .._ .. .... ~one Det-ermi ned'" .... . -. .-- .. --. -::-.-::'::-. _... 

conductance 

40 ml(2) 

TOC ..... , G~ r:efl.6n--:l.tne-~·.· .--:-'; -:'~:. coo.l-:4:-q.t~·2-S9J+(~'.J:....·:-. -.. --:-... ~-:. ~iEL~~y.s: ... _....- ':.7"
 

cap, no he~d space to pH <2 .... . .. . .. .
 

500 ml(2) . G, ··Anib~:f~--::. -.-. ~.;:..-"- ::':-."" '''Coo r::4~C ~~-aCRI ..:...:. :::-...:-....-.-:---'- ---"'-r":'days-" --lOX Teflon lined cap, 1'ml of 0.1 M 

".: .. .,..--- "" "::::..::.-' ·n() he.i;I.d.-~e.~.- .~~i.UI1l.S.UJ fjJ~@ .-_.. - . _ -'" ._ --- -._.-_ . 

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