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



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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 NotificationForm and confirmation of other general information necessary to maintain accurate files and records.


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### INSPECTOR INFORMATION WDOE Inspector: Phone fj:


### Inspector's Signature: 

# • Office (circle one): NW 

### SW C E IND 

### Date ofTHIS 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: OtherThan Address) Contact Person: Phone II: 

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Business Representatives Present During Inspection: 

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### II:

3. NOTIFICATION FORM REVIEW NotificationForm Filed: Yes No Date: NotificationFormRevisions: Yes No Date: Date: Date: Is the informationprovided in the most recent NotificationForm still accurate? (If not, note any deficiencies in Comments, below.) Yes No

Comments:



### 4. ADDITIONAL INSPECTION INFORMATION Time InspectorEntered Site: Left Site: Were photographs taken during the inspection? Yes No If yes, how many? (Note: Abrief 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:
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### • -

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# • Were samples taken during the inspection? Yes No 

### Ifyes, where and ofwhatwere samples taken:

Were samples splitwith the owner/operator? Yes No 

### Were chain of custodyprocedures follows? Yes No 

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### PART III: TRANSPORTERS This part of the checklist/questionnaire is applicable to any person who transports dangerous waste from a generator to a TSD facility. This part of the checklist/ questionnaire does not apply to persons who only transport dangerous waste on-site, as defined inWAC -040(59). If a transporter is also a generator and/orTSD facility owner/ operator, then other applicable parts of this checklist/questionnaire must also be completed. 

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# * ** ** 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, explainthe Yes evidence onwhich this determination is based under Comments below, and do not complete the remainder of this part of the No checklist/questionnaire.) Comments 

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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)). Doesthe transporter ever:
a. Transport dangerous waste intoWashington State from another country? b. Mix dangerous waste of different U.S. Department of Transportation shipping descriptions bymixing them into a single container? 

### B. Atransporter may keep shipments of dangerous waste for briefperiods (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, andmarked by the generator in accordance withWAC -190(1), (2), and (3)?
c. For ten days or less1 Comments

2. 

### MANIFESTS Yes No 

### A. Does this transporter ever transport moderate riskwaste (MRW) using an alternative manifestmechanism, approved by WDOE, as provided inWAC -170(2)(b)(i)1 

# • Ifyes, is he complyingwith the terms and conditions of the alternative manifest for suchMRW (WAC -240(2))1 (Ifnot, describe under Comments, below, which aspects of the alternative manifest system are beingviolated.) 

### B. Does the transporter ever accept dangerous waste from a generator that is not accompaniedby a manifest prepared and signedby the generator in accordance withWAC -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 cannotbe delivered to the first facility because an emergencyprevents delivery; the next designated transporter; or, the place outside the United States designated by the generator (WAC -250(5)? If dangerous waste cannotbe 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.) belowwhich correspond to each "Yes" answer. 

# • a . 

### Does this transporter ever transport dangerous waste overpublic roads?' If "Yes," complete item E., below. -2­b. Does this transporter ever transport dangerous waste by water (bulk shipments)? If "Yes," 

# o complete itemF., below.
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? itemH., below. transport dangerous If "Yes," complete**w~ste**

E. Transportationby road.
a. Does the transporter keep copies ofmanifests 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 generatorbefore 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»? 

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ii. Retain a copy of the manifest for his (WAC -250(4)(b»)? records
iii. Give the remainingmanifest 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. Transportationby 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 shippingpapers for all wastes which he transported bywater (WAC -260(2)(a))? 

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# • b. When receiving dangerous waste from a generator, does the water transporter sign and date the manifest and return a signed copy to the generator before beginning transport (WAC -250(2))1



# • c. Does the water transporterperform all of the following actions (if not, then he must instead perform the actions specifiedunder d. of this itemF.): i. Is the dangerous waste deliveredbywater to the designated facility (WAC -250(7)(a»1 ii. Does a shippingpaper containing all information required on a manifest, exceptEPA/ State ID #'s, generator certificationand 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 shippingpaper (WAC -250(7)(c»1 ,iv. Does the persondelivering 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 eachwater transporter keep a copy of the manifest or shippingpapers for his records (WAC -250 (7)(e»? d. If the water transporter does notperform 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 themanifest for his records (WAC -250(4)(b». 

# • 3. Give the remainingmanifest copies to the next transporter or facility owner/ operator (WAC -250(4)(c»?
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### iii.Before accepting dangerous waste from a rail transporter, sign and date the manifest and 

# G provide a copy to the rail transporter (WAC -250(8)(e))?
. G. Transportationby rail.
a. Does the rail transporter keep for at least three years after the date waste was acceptedby the initial transporter copies of shippingpapers for all wastes whichhe transportedby rail (WAC -260(2)(a))? b. Whenever he is the initial rail transporter, does he keep copies of the manifests and shippingpapers for at least three years after the date the waste was acceptedby the initial transporter (WAC -206 (2)(b)(i))?
c. Whenever he is the final rail transporter, does he keep a copy of the signedmanifest (or shipping paper if signedby the designated facility in lieu of the manifest) for at leastthree 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 themani­ 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 shippingpaper for his records (WAC -250 (8)(a)(iv))? iii.Forward at least three copies of themanifest 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))? 

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### f. Does the rail transporter ensure that a shipping paper containing all the information required on the manifest, exceptEPA/State ID 

### HIS, generator certification and signatures, accompanies the waste at all times (WAC -250(8)(b))? g. When deliveringwaste 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 deliveringwaste to the designated facility, does the rail transporter: i. Obtain the date of delivery and handwritten signature of the owner/operator on themani­ fest or shippingpaper (if the manifest has notbeen receivedby the facility) (WAC -250(8)(c)(i))'l ii. Retain a copy of the manifest or shippingpaper for his records '-,:\, 

### (WAC-250(8)(c)(ii))? H. Transportation out of the United States.
a. Does the transporter keep copies ofmanifests showing the date the waste left the u.S. for at least three years after the date the wastewas acceptedby the initial transporter (WAC -260(3))? b. Does the transporter indicate on the manifest the date the waste left theu.S. (WAC -250(9)(a))?
c. Does the transporter sign the manifest and retain one copy for his records (WAC -250(9)(b))? d. Does the transporter return a signed copy of the manifest to the generator (WAC -250(9)(c))?



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### Comments 

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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 theNational Response Center (800-424-8802 or 202-426-2675) if requiredby49 CFR 171.15 (WAC -270(2))1

c. 

### For water shipments, notify as requiredby 33 CFR 153.203 for oil and hazardous substances (WAC -270(4))? 

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d. Report inwriting as requiredby 49 CFR 171.16 to the director, Office ofHazardous Materials Regulation, Materials TransportationBureau, 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 ofWDOE (WAC -145(2)(a))? b. Notify all local authorities in accordance with the local emergencyplan (ifnecessary, by checking with the local emergency service coordinator and fire department to determine notification responsibilities under theplan) (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 airpollution control authority if the spill or discharge is inwesternWashington (WAC -270(2)(b))?



### -7­ 

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### b. Notify the appropriate regional office ofWDOE if the spill or discharge is ineasternWashington (WAC -270(b))?
c. Notify all local authorities in accordance with the local emergencyplan (ifnecessary, 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 tobyWDOE: i. Cleanup 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 othermaterials contaminatedby the spill or discharge (WAC -145(3)(a)(ii))? iii.Restore the area impactedby the spill or discharge and replenish resources, if the impactedproperty is not owned by the transporter (WAC -145(3)(a)(iii))? Comments

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

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# * * 1,**..,~** 7, -I, PARTII: GENERATORS This part of the checklist/questionnaire is applicable to any personwhose actions or processes generate dangerous wastes, and are thus identified as generators under Chapter 173-303 WAC. This part of the checklist/questionnairemust be completed for anyperson who is a generator, including transporters or TSD facilities which generated dangerous waste.


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# * Generator Name: EPA/State ID #: Inspectors Name: Date: Has this generator generated dangerous waste since the date of his last inspection, or since the date he was determined to be a generator if this is his first 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 generatorproperly 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? 

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ob. 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 accompanyingmanifests as required under WAC -180? (If "No," do not complete Section 3. Manifests, Section4. Preparing Dangerous Waste for Transport and Section 5. Import/Export ofDangerous Waste.) B. Does the generator ever also transporthis own wastes? (If "YES" be sure to also complete Part III: Transporters of this checklist/questionnaire.) C. Listbelow any "outside" transporters the generator uses to transport his dangerous wastes off-site: TransporterName EPA/State 10 

### fI


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# c Comments

3. MANIFESTS (WAC -180). Yes No A. Does the generator retain a completed copy of eachmanifest signedby 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 threeyears from the date the initial transporter accepted the waste (WAC 210(1))? B.a Does the generator use an alternative manifestmechanism for moderate riskwastes as provided inWAC -170(4)(a)? b.Has this alternative manifest mechanismbeen approved by WDOE?
c.Has the generator complied with the terms and conditions of, and properly implemented the alternative manifest mechanism? (If not, specifywhat failures occurred under Comments, below.) Note: Ifall of the dangerous wastes handledby the generator are moderate risk

# o wastes covered by an alternative manifestmechanism, then complete only items G., H., I" and

### J., below. If only some of the generator's dangerous wastes are moderate riskwastes covered by an alternative manifest mechanism, then do complete all remaining items, below. C. Does the generator use the UniformManifest (WAC -180(l)(b))? Does the generator include the additionalWDOE infor­ mation required for the UniformManifest:
a. In ItemD - the first transport's telephone number (WAC -180(1)(b)(i))? b. In ItemF - the second transporter's telephone number, if a second transporter is used (WAC -180(1)(b)(ii))?
c. In ItemH - the designated rece1v1ng facility's telephone number (WAC -180(1)(b)(iii)? d. In Item I - the dangerous waste number for each correspondingwaste entered and described under Item 11 (WAC -180(1)(b)(iv))? 

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# • D. Is signature of, and date of acceptance by the transporter obtainedprior to transport (WAC -180(3)(a))7 E. Does the generator retain one copy, signedby 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 returnedby the receivingTSD facilities? Wereall of these received within forty-five days after the waste was transported? (If "Yes," do not complete the next item, G., regardingExceptionReports.) G.a.If the generator does not receive a copy of the manifest with the handwritten signature of the designated facility's owner/operatorwithin 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 inwriting toWOOE an ExceptionReport for eachmanifest not signed, dated, and returned by the receivingTSD facility within forty-five days of transport (WAC -220(2»?
c.List the dates during the previous year thatException Reports were submitted:

d.Were the waste shipments described in these Exception Reports finally delivered to a TSD facility? Ifnot, specifywhich shipments were not delivered or not found:

e.Does the generator retain copies of all ExceptionReports 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))?

-4­I. When shipping dangerous waste within the United States solelybywater (bulk shipment), does the generator 

# o sendthree copies of the manifest signed and dated by himself and the initial transporter to either the owner/operator of the designated facility, or to the last water transporter to handle the waste in the U.S. if the waste is exported by water (WAC -180(3)(d))? 

### J. For rail shipments within the United States which originate at the site of generation, does the generator send at least three copies of the manifest signed and datedby himself and the initial transporter to either (WAC -180(3)(e)):
a. The next nonrail transporter, if any? b. The designated facility if transported solelyby rail?
c. The last rail transporter to handle the waste in the U.S. if exportedby 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 withU.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 

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# • police or public safety authority, and the Washington State Department of Ecology or the United States Environmental ProtectionAgency. 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. NotifyEPA inwriting, four weeks before shipping to each country in each calendar year, of the waste's identificationnumber 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 UniformManifest**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 anExceptionReport withEPA ifhe has not received either: 

# • i . Acopy of the manifest signedby the transporter stating the date and place of departure from the United States within 45 days (40 CFR 262.50(c)(I))? -6­ii. Written confirmation from the foreign consignee that the waste was received within 90 days 

# o (40 CFR 262.50(c)(2))?
e. Submit copies ofExceptionReports 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 UniformManifest requirements (including additional WDOE information), except that inplace 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 inplace 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 

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G. TRIPLE RINSING (WAC -230(3), (4) AND -160). Yes No A. Does the generator triple rinse all containers which are empty and which heldERW in accordance withWAC -160? B. Does the generator either reuse rinsate from any rinsing operations (including rinsing of tote tanks, truck or railroad tank cars, WAC -230(4)) in a manner consistent with the original product, or else determine if the rinsate is designated as dangerous waste and, if so designated, handle it in accordance with Chapter 173-303 WAC and Chapter 90.48 RCW? Comments

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### d. If there is everjust 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 ofpersonnel, fire and spill control equipment and decontamination equipment during an emergency (WAC -340(3))? f. Do the hazards posedby 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 partymight respond to an emergency, does the generator have agreements designating primary emergency authority and support services to beprovided (WAC -340(4)(d))? k. Has the generator documented all instances where state or local authorities have declined to enter into the above arrangements (WAC -340(5))? Comments

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# c i. 

### Cleanup 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 impactedby the spill or discharge and replenish resources, if the impactedproperty is not owned by the generator (WAC -145(3)(a)(iii)? Comments



### 8. 

### ANNUAL REPORTS Yes No 

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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 whichwere not reported on his latestAnnual Report andwhich should have been reported? If "Yes," describe these wastes: Quantity Description/Dangerous Waste 

### # EHW/DW (Month/Batch)



# (J
-9­7. 

### NON-PERMITTED SPILLS AND DISCHARGES (WAC -145). Yes No A. Have there beenany nonpermitted spills or discharges on the generator's site whichhave notbeen reported toWDOE? Ifyes, describe what wastes were spilled and approximatelywhat 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 ofWDOE (WAC -145(2)(a))? b. 

### Notify all local authorities in accordance with the local emergencyplan (ifnecessary, 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 generatorhas any nonpermitted spill or discharge which results in emissions to the air, does he:
a. Notify the local airpollution control authority if the spill or discharge is inwesternWashington (WAC -270(2)(b))? b. Notify the appropriate regional office ofWDOE if the spill or discharge is ineasternWashington (WAC -270(b))?
c.**Not~fy** 

### all local authorities in accordance with the'local emergencyplan (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 anynonpermitted spill or discharge, does he:
a. Take appropriate immediate action to protecthuman health and the environment (WAC -145(3))? b. Whenever required by

### WDOE:

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### c. Are there any wastes whichwere reported on his latest Annual Report which the generator is no longer generating? 

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If "yes," provide the waste description andDangerous Waste 

### # as they appeared on the latestAnnual Report:

Comments

9. 

### ADDITIONALREPORTS. Yes No Does the department require the generator to submit any 

# o additional reports as provided underWAC -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



### --------------------------_._------­

-10­10. 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 inWAC -200. To determine whether or not this portion is applicable, first complete itemA., below. If, after completing itemA., it is determined that the generator does accumulate dangerous waste on-site, then complete all of the questions under thisSection 10. Generator Accumulation. If, after completing itemA., 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 orpart of sections WAC -330 through -360. If this is the case for this generator, then complete only itemA. and the remaining applicable items of this section 10. Generator Accumulation.) 

### A. DeterminingWhether Or Not The Generator's Accumulation Yes No Is SubjectTo WAC -200.
a. If the answers to both of the following questions are "Yes," then do not complete the remaining generator accumulation questions (theywill be asked later under Part IV: Facilities). If either or both questions are answered "No," then continue the remaining questions in this itemA. 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 ofWAC -200, and the remaining items of this section 10. Generator Accumulationmust 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 byWDOE to complywith some or all ofWAC -330 through -360? Comments



### B. Ninety-Oay* Accumulation Limit. Yes No 

# *

a. 

### The time limit is one hundred eighty days for moderate riskwastes held in containers or tanks as allowedbyWAC -170(4)(b). Does the generator ship all wastes off-site to, or place them on-site in, a facilitypermitted. (including interim status orpermit-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 withinninety days*, did

### WDOE grant extensions (maximum thirty days) as allowedby WAC -200(1)(a)?
c. How does the generator determine when the·ninety-day* accumulationperiodbegins: 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 2,200pounds 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 writtenpersonnel training plan, kept at the generator's site (WAC -330(2))? b. Does the personnel trainingplan include the following documents and records: i. For eachposition related to the handling of dangerous waste on-site, thejob title, name of employee filling eachjob, and thejob 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 eachposition (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 lastworked 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 shouldbe documented.) d. Does the generatorprovide a trainingprogram that teaches personnel to perform their duties inways that ensures the generator's compliance withWAC 173-303 (WAC -330(1))?
e. Does the trainingprogram involve: Classroom instruction? On-the-job training? 

# • f . 

### Is the trainingprogram 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 trainingprovided in the trainingprogram (WAC -330(1)(b))? h. Is the trainingprogram successfully completed by each employee within sixmonths ofbeing employed at the generator's site, or ofbeing assigned to a new position, whichever is later (WAC -330(1)(c))? i. Are new employees supervised until they complete the trainingprogram (WAC -330(1)(c))? j. Does the trainingprogram: i. Include training relevant to the positions inwhichpersonnel are employed (WAC -330(1)(a))? ii. Instruct personnel on contingencyplan implementation (WAC -330(1))? iii. Familiarize personnelwithemergency equipment and systems, and emergencyprocedures (WAC -330(1)(d))? 

### k. Where applicable, does the trainingprogfam 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 groundwater 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 ormarked with the words "Dangerous Waste" or "Hazardous Waste," and with a label or signwhich 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 canbe demonstrated that the equipment is not necessary (specifywhy not in the Comments, below), or the equipment is not requiredbecause 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 ofproviding immediate emergency instructions (WAC -340(1)(a))? Present? Tested**regu~arly?** Good working order? ii. Adevice 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 withanother employee (WAC -340(2)(a))?
-15­

### E. ContingencyPlan, EmergencyProcedures andEmergencies Yes No 

### (WAC -350 and -360). 

# o

a. Does the generator have a contingencyplan 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 contingencyplan (WAC -350(2))?
c. Are copies of the contingencyplan 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 thatmay provide emergency services (WAC -350(4)(b))? d. Is the contingencyplan 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 contingencyplan include: i. Adescription 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.Acurrent list of emergency coordinators, including names, addresses and twenty-four hourphone numbers (WAC -350(3)(d))? iv. Ifmore than one emergency coordinator is listed, identificationof a primary emergency coordinator, with the others listed in the order that theywill assume responsibility as alternates (WAC -350(3)(d))?
v. Alist 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 evacuationplan (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 contingencyplan assure that the generatorhas taken adequate precautions for reacting to emergency circumstances? (If "No," specifywhat 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. Familiarwith all operations and activities on the generator's site? iii.Familiar with the location and properties of all wastes handled? iv. Familiarwith the location of all records kept on-site?
v. Familiarwith the generator's site layout? vi. Has the authority to commit the resources needed to carry out the contingencyplan? i. Are the following procedures implemented (or, to be implemented) in the event of an emergency:

-18­i. 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 ifhelp 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) thatmay result from the emergency (WAC -360(2)(c))? iv. If the EC/D determines that the emergency could threatenhuman health or the environment outside the facility, does he immediatelynotify and provide an assessment report (whichmust 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 shouldbe 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 ofmaterials involved (WAC -360(2)(e)(iv))? 5. The extent of injuries, ifany (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 contingencyplan 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 inhis 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 ofmaterials involved (WAC -360(2)(k)(iv))? 4. The extent of injuries, if any (WAC -360(2)(k)(v))? 

### 5. An assessment of actual orpotential 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. ADDITIONALREQUIREMENTS FOR GENERATORS ACCUMULATING WASTES IN CONTAINERS. Yes No A. Are all containers ingood condition, and are dangerous wastes transferred to good containers or otherwisemanaged 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 withmaterials that will not react or are otherwise compatible with the wastes being accumulated (WAC -630(4))? (Ifnecessary, request and obtaindocumentation to demonstrate waste/ container compatibility.) D. Are all containers used for accumulating dangerous wastes:
a. Always closed exceptwhen 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, orpersonnel or the public could intentionally or accidentallydamage the containers) inways thatwould 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 leastweekly 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 ofweekly 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 Aor B 

### explosives (49 

### CFR 173.51, 53 or 88) stored equivalent to UFC's "American Table ofDistances for Storage ofExplosives," Table 77-201 (WAC -630(8)(a»? b. Are all other ignitable or reactive waste container storage designed, operated and maintained equivalent to the UniformFire Code, state or local fire codes, orNFPA Pamphlet #30, "Flammable and Combustible Liquids Code" (WAC -630(8)(b»?
c. Are those areas where ignitable or reactive wastes are accumulated inspected at leastyearlyby a professional person familiar with the UniformFire Code, orby 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 whichwastes orwastes 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 Aor

### Bexplosives (49 CFR 173.51, 53 or 88) stored equivalent to UFC's "American Table ofDistances for Storage ofExplosives," Table 77-201 (WAC -630(8)(a»? b. Are all other ignitable or reactive waste container storage designed, operated and maintained equivalent to the UniformFire Code, state or local fire codes, orNFPA Pamphlet 1130, 

### "Flammable and Combustible Liquids Code" (WAC -630(8)(b»?
c. Are those areas where ignitable or reactive wastes are accumulated inspected at leastyearlyby a professional person familiar with theUniformFire Code, orby 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 whichwastes or**wast~s** 

### and materials are incompatible: 

# •
-23­b. Does the generator assure that dangerous wastes are not put in containers whichpreviously held incompatible wastes ormaterials unless the container has beenwashed (WAC -630(9)(b))? 

# o

c. Are containers holding waste that is incompatible withwastes or materials stored nearby separated orprotected 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: orwastes and

e. If incompatible wastes orwastes and materials are 

# o mixed or commingled, are these activities conducted so as not to (WAC -630(9)(a)): i. Generate extreme heat, pressure, fire, explosion or violent reaction (WAC -395(1)(b)(i))? ii. Produce uncontrolled toxic mists, fumes, dusts or gases in sufficient quantities to threaten human health or the environment (WAC -395(1)(b) (ii))? iii.Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosions (WAC -395(1)(b)(iii))? iv. Damage the structural integrity of the facility or containers (WAC -395(1)(b)(iv))?
v. Otherwise threaten human health or the environment (WAC -395(1)(b)(v))? Note: If the generator is treating wastes as they are placed inhis 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 inhis tanks arebeing accumulated for more thanninety days (one hundred eighty days for moderate riskwastes only)? 

### B. Are wastes or othermaterials which are incompatible withthe material of constructionof the tanks ever placed in the tanks? If "Yes," is the tankprotected 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 ormaterials (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 constructionmaterials 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 orprevent anyhazardous 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 shouldbe described inhis contingencyplan.) 

### 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 contaminatedwith dangerous wastes or residues been removed or decontaminated (WAC -640(5))? 

### J. Are ignitable or reactivewastes placed in tanks? If "Yes":
a. Is the tank onlyused 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 thatmay cause the waste to ignite or react (WAC -640(6)(a)(ii))?
c. 

### Is the waste treated, rendered ormixedbefore or immediately afterplacement inthe tank so that (WAC -640(6)(a)(i)): '\ " 

### i. The resultingmixture inthe tank is no longer ignitable or reactive underWAC -090? ii. And, themixing or commingling of the waste does not: generate extreme heat, pressure, fire, explosion orviolent reaction; produce uncontrolled toxic mists, fumes, dusts or gases that threatenhuman health or the environment; produce uncontrolled flammable fumes or gases thatpose 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 treatingwastes as they areplaced 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 requiredby state and local fire codes if these are more stringent (WAC -640(6)(b))?



### -27­e. At least yearly, is the tank storage area inspected by a professional person knowledgeable in the Uniform 

# (j FireCode, orby 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 whichwastes 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 tankwhichpreviouslyheld incompatible waste ormaterials, 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 threatenhuman 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 threatenhuman health or the environment (WAC -395(1)(b)(v))? Note: If the generator is treating incompatible wastes as they are placed inhis 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. Certificationby a qualified engineer that the leakhas 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.]

-29­DANGEROUS WASTE COMPLIANCE CHECKLIST/QUESTIONNAIRE, CHAPTER 173-303WAC
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/questionnairemay 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 shouldbe used in conjunctionwith 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 underWAC -806t 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. Ifyes, then some sections of this Part IV may not be applicable to suchMRW 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 Douglas Kittitas SanJuan Whatcom 

# o Ferry Lewis Skagit Yakima Grantb. Is the facility located within 200 feet of a fault which has had displacement inHolocene times (WAC -420(3)(a))? Note: Existing facilities (i.e., operatingprior 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 onlymoderate 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 contingencyplanprocedures 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 highwater 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))?
-2­b. Is the facility located in an area where the local shoreline management masterprogrampermits 

# C) industrial, navigation, manufacturing, or similar activities (areas classified as natural, conservancy, rural or residential may notbe 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-onlywastes) that is disposing of dangerous waste over a sole source aquifer designated pursuant to section 1424(3) of the Safe DrinkingWaterAct? Comments



## ----------------------------------------

# o
3. SECURITY (WAC -310). Yes No A. Can the facility % demonstrate that:
a. Physical contact withwastes or equipment within the active portionwill not injure persons or livestock (WAC -310(1)(a))? b. Disturbance of wastes bypersons or livestockwill not result in violations of ch. 173-303WAC (WAC -310(1)(b))? B. If the facility % cannot demonstrate both of the above, then does the facility have:
a. Either: i. Abarrier (artificial, natural orboth) 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 inEnglish, "Danger-Unauthorized Personnel Keep Out"? iii. Are legible from a distance of twenty-five feet ormore? C. If the facility has or is a totally enclosed treatment facility or elementary neutralization or wastewater treatment unit, in lieu of itemB., above, does the 0/0 prevent unknowing entry and minimize the possibility of unauthorized entrybypersons 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: 

# •

-4­a. 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 accompaniedby 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 themanifest is not received within thirty daysafter 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 inpiece count (e.g., missing containers orpackages)? 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 shippingpaper to WDOE (WAC -370(4)(b))? List any dates since the last inspection (or since notification if this is the first inspection) that the % submittedmanifest 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 onlyunder the following circumstances (WAC -370(5)(a)): i. His facility is not capable ofproperly managing the waste? ii. There is a significant discrepancybetween 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 orpersonnel? 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))?



### -6­Comments 

# 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, orbiological analyses of wastes adequate to assure safe TSD in accordance with Ch. 173-303WAC, includ­ ing where appropriate: data from existing documents or publications; data onwastes generated from similarprocesses; 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 receivedmatches the identity of the waste specified in the manifest or shippingpaper 

# o (WAC -300(3))1
c. Repeating of analyses to assure accurate information as necessary, including repeat analyses at leastwhen: 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 shippingpaper (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 eachwaste 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
-7­d. The frequency withwhich 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 testingprocedures? iii. Evaluation of personnel performance of sampling/testing? iv. Chain of custodyprocedures?

v. Inspection, calibration, testing, and maintenance of sampling and analysis equipment? 

### g. For facilities receivingwastes from off-site, the procedures for confirming the waste identity specified on the manifest or shippingpaper (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 identificationmethod 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:

-8­a. 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 documentedinformation on similar storage or treatmentof 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 

# cii. 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, orby obtaining written documented information on similar treatment or storage of similarwastes under similar conditions? iii. Determining the compatibility of a waste to otherwastes 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 portionwould 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 eachwaste 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 previouslyheld on the pilebase if it was not decontaminated (unless it canbe 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?

-10­e. Land Treatment (40 CFR 264.273). i. Determining the concentration in the waste of any substances which exceed the EP toxicity concentration limits ofWAC -090(8)(c)? 

# (j

ii. For any waste listed inWAC -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 ofWAC -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 ormaterials 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 portionwould 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 bywaste 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? 

# ()

-11­v. 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 portionwould be designated as a dangerous waste? g. Incinerators (40 CFR 265.341). i. Analyzing any waste notpreviouslyburned in the incinerator to enable the % to establish steady state operating conditions and to determine the types ofpollutants whichmightbe 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** portionwould 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'smaterials 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?

-14­iii. 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 constructionmaterials of the tank at least weekly to detect corrosion or deterioration?


### v. The constructionmaterials 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. SurfaceImpoundments (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 repellingprecipitation 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
-17­h. 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 relevantprocess flow and level controls) at least every 15 minutes? ii. The stackplume (emissions), observed visually at least every hour for normal appearance (color, opacity)? iii. The complete treatmentprocess 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 openburning of waste explosives, the area of openburning to assure that itmeets the minimum distance to the nearest otherproperty 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. Constructionmaterials 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 InspectionRequirements for Specific Waste Management Methods. Yes No Wherethe 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 orReactive 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 yearlyby a professional person familiar with the UniformFire 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 -19­7. 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 trainingplan include the following documents and records:
a. For eachposition related to the handling of dangerous waste on-site, the job title, name of employee filling eachjob, and thejob description, including requisite skills, education, qualifications, and duties for eachposition (WAC -330(2)(a))? b. Written description of type and amount of introductory and continuing training needed for eachposition (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 lastworked 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 shouldbe documented.) D. Does the % provide a training program that teaches personnel to perform their duties inways 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 directedby a person knowledgeable in dangerous waste handlingpractices (WAC -330(1)(a))?

-20­

# c G. Do the O/O's employees participate in an annual review of the trainingprovided in the trainingprogram (WAC -330(1)(b))? H. Is the trainingprogram successfully completedby each employee within sixmonths ofbeing employed at the facility, or ofbeing assigned to a new position, whichever is later (WAC -330(1)(c))? I. Are new employees supervised until they complete the trainingprogram (WAC 

### -330(1)(c))? J. Does the trainingprogram:
a. Include training relevant to the positions inwhich personnel are employed (WAC -330(1)(a))? b. Instructpersonnel on contingencyplan implementation (WAC -330(1)(a))?
c. Familiarizepersonnel with emergency equipment and systems, and emergencyprocedures (WAC -330(1)(d))? K. Where applicable, does the trainingprogram 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 

# l8. PREPAREDNESS AND PREVENTION (WAC -340). Yes No A. Unless it canbe 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. Adevice 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 everjust one employee present on the premises, does he have immediate access to a device (e.g., telephone, two-way radio) capable of summoning external emergencyhelp (WAC -340(2)(b))? -22­

# c D. Is adequate aisle space provided to allow for inspections and unobstructedmovement ofpersonnel, 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 partymight respond to an emergency, does the % have agreements designatingprimary 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) -23­9. 

### 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 contingencyplan (WAC -350(2))? C. Are copies of the contingencyplan and revisions to it:
a. Maintained at thefacility (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 contingencyplan 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. 

### Adescription 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. Acurrent list of emergency coordinators, including names, addresses and 24-hourphone numbers (WAC -350(3)(d))?

-24­d. If more than one emergency coordinator is listed, identification of a primary emergency coordinator, 

# C) withthe others listed in the order that they will assume responsibility as alternates (WAC -350(3)(d))?
e. Alist of all emergency equipment kept on the**site~** including the location, physical description, and brie£ outline of the capability of eachpiece of equipment (WAC -350(3)(e))? f. An evacuationplan (where evacuation couldbe 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 cannotbe managed at the**f~cility** and is not acceptable to the 0/0, but cannot be transported back to the generator or an alternate facilitybecause it is damaged orwould pose a risk to public health or the environment (WAC -350(3)(b))? Do the information and**element~ descr~bed**  in the contingencyplan assure that the % has taken adequate precautions for reacting to emergency circumstances? (If "No," specifywhat 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 contingencyplan? b. Familiar with all operations and activities facility? on the

c. Familiarwith the location and properties of all wastes handled? d. Familiar with the location of all records on-site? kept

e. Familiarwith the facility layout? f. Has the authority to commit the resources to carry out the contingencyplan? 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 allpersonnel (WAC -360(2)(a)(i)) and notify appropriate state or local agencies with designated response roles ifhelp is needed (WAC -360(2)(a)(ii))? b. Does the EC/D immediately identifythe character, exact source, amount and areal extent of any released materials (WAC -360(2)(b))?
c. Concurrently, does theEC/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 threatenhuman health or the environment outside the facility, does he immediately notify and provide an assessment report (whichmust 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 shouldbe 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))?
-26­f. 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., stoppingprocesses 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 % notifyWDOE, 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 inhis operating record the time, date, and details of incidents requiring implementation of the contingencyplan (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))?



### -27­iv. The extent of injuries, (2)(k)(v))? if any (WAC -360

v. An assessment of actual orpotential 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, belowwhat 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))? 

# o D. Does the % document these precautions inhis operating record (WAC -395(1)(c))? Comments:

11. LOADING AND UNLOADING AREAS (WAC -395(4)). Yes No Does the facility receive manifested shipments of liquid dangerous waste for management? 

# ()
-29­If "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. Containwashwaters (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 surfacewaters (WAC -395(4)(d))? Comments:

12. RECORDKEEPING (WAC -380). Yes No A. OperatingRecord.; , 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 contingencyplan (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)?
-30­iv. Monitoring, testing, or analytical data as required under the specific unit requirements

# C~ for interim and final status (e.g., ground watermonitoring 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 ormanages on-site (WAC -380(1)(a)): i. Adescription of eachwaste providing the common name, waste number, and physical form (e.g., liquid, solid) (WAC -380(2)(a) and (b))? ii. Where a waste contains more than one process waste or waste constituent, all applicable waste numbers or else a description of the process which generated the waste (WAC -380 (2)(a))? iii. The weight, orvolume and density, for each 

# o waste using the units specified in Table 1 (WAC -380(2)(c))? Table1 Unit ofMeasure 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 eachwaste, using the handling code(s) specified in Table 2 ofWAC -380(2) (WAC -380(2)(d))? d. Does the % include in his operating record the location of eachwaste within his facility and the quantity at each location, and a cross-reference to specific manifest document numbers for each waste that was accompaniedby 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 inhis operating record to record the location and quantity of eachwaste (WAC -380(1)(b))? 

### B. Does the % 

### evermanage ignitable, reactive, or incompatible wastes athis facility? If "Yes":
a. Does the % 

### include inhis operating record records of the annual inspectionby a Fire Marshall or other professional familiar with the UniformFire Code (WAC -395(1)(d))? (If "No," then these records must be entered inhis inspection log or summary.) b. Does the operating record include documentation that the % 

### manages his ignitable, reactive, or incompatiblewastes in accordance withWAC -395(1)(a) and (l)(b) (e.g., does not cause extreme heat orpressure, toxic mists or fumes, damage facility integrity, etc.) (WAC -395(1)(c))? (Note--This documentation may bebased on references to published scientific or engineering literature, data from trial tests, waste analyses, or the results ofmanaging similarwastes by similarprocesses 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 ofwaste disposal locations and quantities at the time of his facility's closure toWDOE, EPA RegionXAdministrator, and the local land use and planning authority (WAC -380(3)(c))? Comments:


# •
-32­

### 13. REPORTING (WAC -390). Yes No A. UnmanifestedWaste Reports. If the % 

### receives from off-site a shipment ofwaste whichwas notmanifestedbut should have been, then does he submit a Form 6 - UnmanifestedWaste Report to WDOE within 15 days of receiving the shipment (WAC -390(1))? Listthe dates below that such reports were sent:

B. Annual Reports.
a. Does the % submit a Form 5-TSD FacilityAnnual Dangerous Waste Report toWDOE byMarch 1 

### of eachyear reporting the previous calendaryear's waste management activities at the facility (WAC -390(2))? 

### b. If the % ships waste off-site, does he submit a Form 4-GeneratorAnnual Dangerous Waste Report 

# o
to WDOE byMarch 1 

### of eachyear reporting the wastes for which he acted as a generator during the previous calendaryear (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 ofWAC -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 byWDOE (list these reports, if any, and dates submitted under Comments, below)?

-33­

# • Comments:



# •

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


## **

## **

## * **

# **

## *

# **

## * * *

# *

# ***

# *

# **

# * **

# ** *

# *

# **

# *

# **

# *** *

# ** 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 FacilityRequirements 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 Vmay 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'Vof 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 thebad 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 withWAC 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 everplaced in unwashed containers which previously held incompatible wastes? 

# o If "Yes," are these practices conducted in a manner that assures compliance withWAC -395(1)(b)? (Be sure to complete section 10. of Part IV: General TSD FacilityRequirements 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.

-3­Comments:

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

# o A. General operation (265.192).
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 ejther:
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

-5­ii. 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 byWAC -090 (7)(a)(vi), (vii) or (viii)) located with a buffer zone equivalent to the UniformFire 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 tanksJ contained in Tables 2-1 through 2-6 of "The Flammable and Combustible Liquids Code

- 1981?" 

### C. Incompatible wastes (265.199). 

# o If the 

### % conducts the following activities, are these activities conducted so as to complywithWAC -395(1)(b) (Note--If the 

### % conducts these activities and compliance withWAC -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 previouslyheld incompatible wastes or materials? Describe which tanks receive incompatible wastes and what those wastes are. 

# (J
-7­

# • Comments:



# •
-8­3. 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 requirementmay 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 everplaced 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 everplaced in the same**sur~ace** impoundment(s)? If "Yes":
a. Does the % do this in a manner that assures compliance withWAC -395(1)(b)? (Note--Be sure to complete section 10. of Part 

### IV: General TSD FacilityRequirements 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 thewastes in the pile(s) couldbe 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 flow onto the active portion of the pile(s) 

# o during peak discharge from at least a twenty­ 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 anymaterials or conditions which may cause them to ignite or react? b. Or else, treat, render, or mix the wastes before or immediately afterplacement inthe 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 withWAC -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 whichpile(s) (if any) receive ignitable or reactive wastes
. 

# • D. Incompatible wastes (265.257).
a. Are incompatible wastes, or incompatible wastes and materials everplaced in the same pile(s), or are wastes everpiled on the same area(s) where incompatible wastes ormaterials were previously piledwithout the area(s) being decontaminated? If "Yes": i. Does the % 

### do this in a manner that assures compliance withWAC -395(1)(b)? (Note--Be sure to complete section 10. of Part IV: General TSD FacilityRequirements 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 bymeans 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 inmaking 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 duringpeak 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 particulatematter 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 inwriting and does he implement an unsaturated zone monitoringplan? Is theplan 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 similarbut untreated soils nearby? b. Does the % keep the monitoring plan and the rationale used in developing the plan at his facility?
c. Does the monitoringplan 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 activeportions of his facility, does the % demonstrate inhis 

# 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 conditionwhich could cause it to ignite or react? b. Or else, treat, render, ormix the wastes before or immediately after placement in the land treatment unites) so that the wastes are not ignitable or reactive (byWAC -090(5) and (7)), and so that the treating or mixing complies withWAC -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 withWAC -395(1)(b)? (Note--Be sure to complete section 10. of Part IV: General TSD FacilityRequirements 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 underthis item. If "Yes," then continue with the remaining questions.
a. Has the % notifiedWDOE 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 otherwaste constituents identified pursuant to the facility waste analysis planwill 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?



### -17­d. 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 eachwaste application? ii. If the land treatment area is used for production of tobacco, leafyvegetables 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 soilpH 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 CationExchange 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 orgreater? 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 planwhich demonstrates how the animal feed will be distributed to prevent ingestionby humans?
v. Does the facility operating plan describe the measures to be taken to safeguard against possible healthhazards from cadmium entering the food chain, whichmay 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 rates and that food chain crops must not be 

# o grown except in compliance with the actions 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 withWAC -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 dailywith 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 withWAC -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?

-22­b. Does the % place overpacked drums (labpacks) 

# Cj in thelandfill? 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) specifyparticular inside containers for the wastes, are these regulations followed? iii. Are the inside containers overpacked in an open head DOT specificationmetal 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 orbeing 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)

-23­7. 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, inwriting, that the wastes would not reasonablybe expected to contain any of the dangerous waste constituents listed inWAC 173-303­ 9905, and is this documentation retained at his facility?
a. Wastes listed as dangerous solelybecause they are ignitable and/or corrosive, orwastes designated as dangerous solelybecause 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 ofWAC 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 operationhave been achieved (including steady state operating temperature and**~ir** flow)? b. Does the % immediatelymake appropriate corrections, either automatically ormanually, 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 (includingbut 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.)

-24­Comments:

# ---------c~



# o

o

-25­8. 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 othermeans prior to adding dangerous wastes? b. Does the % immediatelymake 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 wasteresidues from the thermal treatmentprocess and equipment (including but not limited to ash, scrubber waters and scrubber sludges) and, if designated as dangerous wastes, manage them accordingly? (Note-­ Thisresponsibility 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 openburn or detonate waste explosives (e.g., military propellants, dynamite, fireworks) which cannotbe safely disposed of through othermodes 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 thatprotects public health and the environment, and in accordance with the following table? Pounds of waste Minimum distance of explosives openburning/detonation to property of others



## oto 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.) -26­Comments:

# ----------(



# o

(**~\** -27­9. 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 orprocess equippedwith a means to stop the inflow (e.g., waste feed cutoff system, bypass system)?
c. When treatingwastes, does the 

### % assure that the treatment is conducted so as not to: i. Generate extreme heat orpressure, 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 withWAC -395(1)(b)? (Note--If 0/0 conducts this activity, be sure to complete section 10. of Part IV: General 

### TSD FacilityRequirements 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 everplaced inunwashed 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 FacilityRequirements of this checklist/ questionnaire.)

-29­b. 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~~~ _nusWlSlE**D'~lS'OM**

# ------- 

# • CLOSURE PLAN CHECKLIST
6.1.GENERAL FACILITY INFORMATION FacilityName: 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 andbiological 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 wouldbe helpful in reviewing the plan, including (Note: regulations do not presently require the inclusion of the following information. However, inclusion of this informationwill aid in the reviewof 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 landuse 

### 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 willbe 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 containingwastes? b. inactive areas openbecause 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: ) IFNO 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 planmust indicate how and when those requirements willbe met.)

Doesthe PARTIAL CLOSURE PLAN describe maintenance activities for partially closed areas, including:
a. 

### visual inspections? 

### b. groundwatermonitoring? c. 

### maintaining cover? 

### d. maintaining diversion structures? e. 

### controlling erosion? 

### f. maintainingvegetation? 

### g. securityreouirements? 

### h. leachate collection? i. 

### gas collection? 

### D. Does the CLOSURE PLAN describe maintenance frequencies for partially closed areas, including:
a. visual inspections? b. groundwatermonitoring? 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» 

# o A. Is there an estimate of the MAXIMUM INVENTORY of wastes in storage or treatment at any time during the life of the facility? (Note: write NA for those cases where there is no storage or treatment prior to disposal.) B. Does the MAXIMUM INVENTORY estimate include the maximum amount of on-site wastes?
a. requiring pre-treatment? b. requiring treatment? c. requiring disposal? C. Does the MAXIMUM INVENTORY estimate include the maximum amount of on-site:


### a. wastes in surface impoundments? 

### b. wastes inpartially-closednon­ disposal surface impoundments? c. 

### wastes in tanks? 

### d. wastes inpiles? e. 

### wastes in drainage pits? 

### f. wastes in containers? 

# C) g. standing liquids?



### - 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 onwaste testing and criteria. Write "NA" for situationswhere 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 beingmanaged 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)) groundwatermonitoring? 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 ofmaterials 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. decontaminationprocedures? method of treatment or disposal of residues? d. testingprogram? E. With respect toMONITORING, closure plan describe: does the

a. b. c. d. details of the groundwater monitoring program during closure? soil testing andmonitoring? maintenance ofmonitoring 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 systemduring 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 themaintenance 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 tobe 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 expectedyear 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 ofwaste 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. 

### plantingvegetation? 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? operatinghistory? other D. Has the cost estimatebeen adjustedby 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 sectionhave been organized into unit specificmodules. 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 allwaste residues, contaminated soils, structures, and equipment, he must close the facility and performpost-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 ofwaste containers for leaks; the procedure for transferring dangerous wastes from leaking containers tonon-leaking containers; 

### B. Rave provisions beenmade for the decontamination of equipment and structures? C. Does the plan describe the testing programneeded tojudge the success of the .decontamination efforts? 

# • D. Does the testing program include:
a. samplingmethods 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 planprovide a detailed plan for the removal of:
a. allhazardous 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 planprovide an estimate of each quantity of material tobe removed from the site? Comments:

- 15

­

### YES NO 

### 4. WASTE PILES (40 CFR 265.258(a» 

# () A. Does the closure planprovide a detailed planfor 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 criteriabeen established to judge the effectiveness of the decontamination procedures? 

### D. Does the closure plan describe a testingprogram 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 theywill be achieved?
a. control ofmigration 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 causedbywind 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 ofwaste. b. mobility and rate ofmigration c. site location, topography, and surrounding land use. d. climate, includingprecipitation. e. characteristics of the cover, includingmaterial, final surface contour, thickness, porosity, permeability, slope, vegetation. f. geological and soilprofiles and surface and subsurface hydrology. g. unsaturated zonemonitoring. h. type, concentration, and depth of hazardous constituentmigration 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 willbe 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 ofmigration c. site location, topography, and surrounding land d.
e. climate, including amount, frequency and pH of precipitation characteristics of the cover, 

# o includingmaterial type, final surface contour, thickness, porosity, permeability, slope, and type of vegetation f. geologic characteristics, soil profiles, and surface and subsurface hydrology g. unsaturated zonemonitoring 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. allwastes b. ash c. scrubberwaters 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 tojudge the success of the decontamination efforts? E. Does the closure plan describe a testing program to determine if the standards of decontaminationhas been met? Comments:

- 19

­

### YES NO 8. 

### THERMAL TREATMENT (40 CFR 265.381) 

# Cj A. Does the closure plan address the disposal of allwastes 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 decontaminationhas 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 allwastes 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 decontaminationhas beenmet? 

# •

•

- 21

­"



### 6.4 VERIFICATION OF CLOSURE COST ESTIMATES

# C~ Sections 1-7 dealwith the verification of cost estimates for various tasks performed during the closure of a dangerous wastemanagement facility. However, some of the informationrequested in the following sectionsmay 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 beloware assigned the appropriate units**(i.e~,** 

### dollars, cubicmeters, 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. fromvisual 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. fromvisual 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 tobe 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 ofwastewater 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 orDisposal 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

­

### ApplicablelNA 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 orDisposal of Contaminated Soil, Wastewater and Residues Generated During Decontamination
a. Volume of soil, wastewater and residues tobe treated/disposal off-site (yd3) 

### i. from cost estimate ii. from closure plan iii.fromvisual 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. bymap reference f. Cost of transport ($) i. from cost estimate g. Total cost of off-site treatment or disposal including transport ($) 

# C) i. from cost estimate



### - 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. CoverMaterial

# ** (40CFR 265.112(a)(4);

265.280(c)(2))
a. Area to be covered (yd2) 

### i. from cost estimate ii. from closure plan iii.fromvisual inspection b. Depth of cover material (yd) i. from cost estimate ii. from closure plan iii.inspector's estimate
c. Volume ofmaterial 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. bymap 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 placingmaterial ($) i. from cost estimate 

# o

B. Top-Soil
a. Area tobe 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 (yd3) 

### 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 BufferMaterial 

# 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 (yd3) 

### 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. bymap reference



# *Includes other materials (other than clay and top-soil) whichmay be (). used alongwith 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 ($) i. from cost estimate
o. Unit cost of acquiring and installing synthetic liner and buffermaterials ($/yd2) 

### i. from cost estimate p. Total cost of acquiring and installing sYnthetic liner and buffermaterials ($) i. from cost estimate D. Total Cover Cost
a. Unit cost of cover ($/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 inNeed of revegetation (yd2)


### a. From cost estimate b. From closureplan c. From visual inspection B. Unit Cost for Acquiring and Placing Seed, Fertilizer, etc. ($/yd2)


### a. From cost estimate C. Total Cost ofAcquiring and Placing Seed, Fertilizer, etc. ($)
a. From cost estimate 6. OTHER (fromcost estimate) ($) 

### $---­ (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 tomodification 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: 

# •

•

-5­7.2 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 itern 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, cubicmeters, 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 ($/hr)
a. From cost estimate C. Total inspection/facilityvisit cost ($/year)
a. From cost estimate REESTABLISHING FINAL COVER AND VEGETATION A. Area involved (yd2)


### a. From cost estimate b. From post-closure plan c. From visual inspection B. Unit cost for reestablishing cover and vegetation ($/yd2)"



### lLoaded with costs for support personnel.



### -9­Applicable/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 (yd2) 

# 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 cost for groundwater monitoring 

# C) ($/well/year) 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 wellto be replaced

replacement component is on annual basis or not. -11­Applicable/NA Arnount/NP

# o i. From cost estimate ii. From post-closure plan iii. Inspector's estimate b. Unit cost for fence replacement ($/yd) i. From cost estimate

c. Cost of fence replacement ($/year) i. From cost estimate C. Total Cost for *aintaining and Replacing Fences ($/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



### 3Total 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~)

-12­ePlicable/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 thoughmany of the questions in these subparts reference final status regulations, they are also required, on a technical basis, to assess interim status ground water monitoringprograms. A ground water assessment checklist (for interim status facilities where ground water contaminationhas 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. Notethat. 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) Amap showing ground waterproduction 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?

( iv ) St1rfac e Wittt>r f{';ttilres and dr aiIIage?

(v) On-site water supply wells? (vi) Pertinent engineered structures and operational units? (vii) Is the scale of the map appropriate? Scale used: 

# _0 (viii) North arrow? (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 contourmaps 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? Whichof 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) Interactionwith 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) Continuitybeneath and adjacent to the site?

(iv) Water-table contourmaps 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? Whichof 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/backgroundmonitoring 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 watermounding 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)

Ifmud 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? Ifyes, explain.

b. Circle the soil samplingmethods 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. MonitoringWell Construction for Wells through (WAC -400(3)(c)(v),**~645(8)(c),** 265.91(c))
a. Was the well construction supervisedby an experienced hydrogeologist, geologist, or soils engineer? Who? 

# o b. Circle the type of completion: 1) singie well 2) nests (or clusters) of wells in separate boreholes, 3) multiple wells in a single borehole, 4) multiport sampler, 5) other (specify)

c. Circle the casingmaterials 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 screenmaterial 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 packmeasured 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? Ifyes, were the pellets hydrated (wetted) theywere installed? after
k. Was the well seal installationmethod appropriate? Remarks:

1. Are the wells properly constructed to prevent contamination of the samples, the sampled waterbearing zones, and between aquifers and waterbearing zones? (WAC -400(3)(c)(v), -645(8)(c) Remarks:



### m. Were samples taken of all materials used inwell 

# o installation (grout, sand pack, bentonite, well material, etc.)? Remarks:

E. Well Development for Wells through
a. Were the monitoring wells developed? b. Circle the well developmentmethod: 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? Ifyes, for whichwells

i. Were drawdowns and recoverymeasured 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 betweenwells? Remarks:

(iii) 

### Depth(s) inwell orborehole from whichwater 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 samplingprocedures clearly identify: (i) Sample containers? (ii) Filteringprocedures? (iii) Preservationprocedures?

(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 eachparameter?

- 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 adequatelyprotected? 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) centrifugalpump, 3) peristalticpump, 4) gas-contact positive displacement pumps, 5) non-gas-contact positive displacement pumps 6) bailer, 7) electric submersiblepump, 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 properlypositioned 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 properlypositioned in the well? Describe the samplingmaterials 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? Ifyes, what is the pumping rate?

Is the purging equipment adequately decontaminated betweenwells? (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-SamplingProcedures 

### (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 samplingmethod 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 decontaminationprocedures Specify metermake and model betweenwells. 

# o (iii) Temperature? Specify'thermometer make and model (iv) Eh (Redox potential)?

.. 

### Specifymetermake and model (ii) Are the decontamination procedures adequate? 

### n. Are the field instruments calibrated? Remarks: Describe the calibrationmethods.



### 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 notebookmaintained to record pertinent sampling events and**proc~dure~~** 

### Remarks Doesthe field notebook record the fo11owl.ng: (i) Well number? ,1f 

# e (ii) Sample number? (iii) Names of s'ample collectors?

(iv) Signature of sampler?

(v) 

### Samplingmethod? (vi) Presampling purging data (e.g. volume and rate of purging)? (vii) Fieldmeasured 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 samplingprocedures consistent withpast**~ampling** 

### procedures? :; q.. Are differences significant? Explain

r. 

### Has the same laboratorybeenused 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 samplebottles properly cleanedprior to sampling? (vi) Tests.tobe 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' 

# o .Ie 

### How many?**-----------.-~,** " 

### (v) Transferblanks? 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. Drinkingwater

### 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 initialbackground concentrations been determined for the following parameters (Table I)?
a. Drinking water parameters? b. Water qualityparameters? Remarks 

# • ----,----------------------­

- 31

­

# cl**.~**

.'J(' i.',·.i"!;

### I:!.:.**~:'i.**-; 'f**~;;** :',**~:: ~.;;/f** **~:'.~; :h7::U6':~·g._~;**  ,-i;iG !;"'::

..**::'<~.~~:"** 

# o

,"; ,**r~·ij t~.** **(ft~·**jO**[(!.~** :)**.~ ·~i.** 

### ;:;.:;**i'~:** :**~I ~~.,'~J:"J'~'** -,..[fe.-: ..**~- .:.~~:** ..)::"':,,,**.~** __.j,**':~~,;.**",::..**~~ :;~:.:**  .'-? .":Y.: :.!.:;'.'**.~.**",:.

. 

## c. For upgradient/background**·'\\iel:llS:··1ia~e;··~th~:":fel~tiWirl-g,·~:·f;** .. beendetermined for the**,~ndicator** :patal1le'ters:

f**:.~ :':~'** 

### ..**t-#..,~~,. ~.~j~**  :'"**;~.~{** /.**~~~.:** :', i**.!.~** (.:. ;.. a'. Initial background arithmetic'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"qualityparameters? Remarks.--",....,...---:-':-.-,-.;.,."...,.--:---:------:---:--------­ ,;I:. .,.:**t~** • \.\.. .',',

.'.
. J.\**~:.** 1": •. ' '.:**~~** ! .**---------------~----------** 

# o

.E. For

### upgr~di~ht/backgro·und wells.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.···replicates ·per:sampl.ing episode? b·

..··;','**VA.ria~ce:.,** based;on:iat**l~as** t 

### 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 a

# ft!';£;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** usedfor,.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,ofpH).,**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
1c ,'.'

## 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?' :~)** "]' (iii) Aground.: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-;;.:'"
....---".f:9:'.\ 

# 0. .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'iii
..:t:**~'.** ": !.:,:-.

.......**'~.;** .. "., ... r


# ._-...'';

...._R

..**···~---~** ; .**~'.**.:'

. -';,**".~.**

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

### ,..**:,<,~.,:.~~,.;~** 

### ....**:~~.::..**

### --::!".' ',;;•.nj'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;nkin9 Water 1.000 ml

..-- -ArS-enie:
..-· T,P:.-:-
...··_·-..···-.-o:;·-:-_..

### ~--_· .._ ..

### -=·f~~~·~~~~e~~~~~--=::.-:--.

# :-..**.::-::.:.:-:~**

# ..**§,~~~~~~~-::..;** ...._::;;:''':.'., 

## Bar-fum HN0
. Cadniium 3

__ '._.**~.,.**__...**~.** ...--:=-:.;=._==-=-..**_~=--=~~A.~.:...:-:~--::::_** ...:=::::.:-:..**_~~.:_._:;**..:;.':**_.~** ..-"-:Cnromfum"-""".-"'''--

_ .

.Lead
.

......Seleniurn.... . ..__.-.. . -::' -_..-:-.::..:::--_._..-:--:::-..**~:_-:::-:;-:**..::;**",::;~,:':::-::-:::-:-";::.':;~::-:.';** ::..: .:.;:,:",.:' .:·::···..: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"~::.~:;**..**·~:**'.'
..:.::';.-" 1000ml 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
..'.;:..:.'._.... . 

### soml**-··Chl~ride** T;P,G 1000ml -'--I;:;m---'--'''-**--~ '"--:::~:-:-:--:--'':T;P'''** **-_.::.~-**::-._..._ ..·····------···Fi-etd:-Ac;:tdi-f:l.ed*···----·---:.-**-:---6-monUl~"----'--'** Manganese to.pH<2 with

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

...._.... "Sod-i-ttm
..,·,:,,,.,.-----..--·--='.·

..·,=c.;·:;,".=::·

. -:::-:..•**~.** HN03':-:::-"':'-:-::-;-":--::"'7'-'::'

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......:.:....**-~'--'** . -'--' .:-: 500 ml

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