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Closure Plan Review Guidance for Rcra Facilities

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Closure Plan Review Guidance for Rcra Facilities CLOSURE PLAN REVIEW GUIDANCE FOR RCRA FACILITIES “THIS POLICY DOES NOT HAVE THE FORCE OF LAW” Ohio Environmental Protection Agency Division of Environmental Response and Revitalization July 2017 http://epa.ohio.gov/derr/RCRA.aspx Ohio EPA Offices Northwest District Office Central District Office Northeast District Office 347 North Dunbridge Road 50 W. Town St. Suite 700 2110 East Aurora Road Bowling Green, Ohio 43402 PO Box 1049 Twinsburg, Ohio 44087 Phone: (419) 352-8461 Columbus, Ohio 43216-1049 Phone: (330) 963-1200 Fax: (419) 352-8468 Phone: (614) 728-3778 Fax: (330) 487-0769 Fax: (614) 728-3898 Southwest District Office Central Office Southeast District Office 401 East Fifth Street 50 W. Town St. Suite 700 2195 Front Street Dayton, Ohio 45402-2911 PO Box 1049 Logan, Ohio 43138 Phone: (937) 285-6357 Columbus, Ohio 43216-1049 Phone: (740) 385-8501 Fax: (937) 285-6249 Phone: (614) 644-2917 Fax: (740) 385-6490 Fax: (614) 728-1245 See also Ohio EPA’s Web-site: http://www.epa.state.oh.us/new/directions.html Table of Contents Table of Contents .................................................................................................. Pg. ii Acronyms ............................................................................................................. Pg. vi Overview and Chapters Overview of the Closure Plan Review Guidance ............................................... Pg. 0-1 Description of the Closure Plan Review Guidance (CPRG) ................................... Pg. 0-1 Difference Between Statements in the CPRG and Ohio EPA Statutory Requirements ............................................................. Pg. 0-2 Origin of the Policies Contained in the CPRG........................................................ Pg. 0-3 Additional Resources Available for Closure ........................................................... Pg. 0-3 Chapter 1 - Regulatory Considerations for Reviewing and Approving Closure and Post-Closure Plans .......................................... Pg. 1-1 1.1 Rules Associated with Closure and Post-Closure Plans ............................ Pg. 1-1 1.2 When, Where, and How to Submit a Closure and/or Post-Closure Plan…. Pg. 1-8 1.3 Closure Plan Designations ....................................................................... Pg. 1-10 1.4 Public Participation in the Closure and Post-Closure Process ................. Pg. 1-11 1.5 Administrative Framework of Closure and/or Post-Closure Plan Review . Pg. 1-12 1.6 Objective of a Closure and/or Post-Closure Plan Review......................... Pg. 1-14 1.7 Notice of Deficiency and Director's Approval/Modification/ Disapproval Letters .................................................................................. Pg. 1-15 1.8 Closure and/or Post-Closure Plan Amendments and Extension of Closure Time Period ............................................................ Pg. 1-19 1.9 Completion of Closure and/or Post-Closure Care .................................... Pg. 1-21 1.10 Generator Closure ................................................................................... Pg. 1-24 Chapter 2 - Other Cleanup Programs ................................................................. Pg. 2-1 2.1 RCRA Corrective Action Program .............................................................. Pg. 2-1 2.2 Corrective Action Management Unit (CAMU) Rule..................................... Pg. 2-1 2.3 Ohio Voluntary Action Program.................................................................. Pg. 2-2 Chapter 3 - Required Components of All Closure Plans .................................. Pg. 3-1 3.1 Description of Facility ................................................................................. Pg. 3-1 3.2 Maps of Facility .......................................................................................... Pg. 3-1 3.3 Description of Hazardous Waste Management Unit to be Closed .............. Pg. 3-1 3.4 Detailed Drawing of Hazardous Waste Management Unit to be Closed ..... Pg. 3-2 3.5 List of Hazardous Waste ............................................................................ Pg. 3-2 3.6 Management of Waste ............................................................................... Pg. 3-3 3.7 Schedule for Closure ................................................................................. Pg. 3-6 3.8 Air Emissions and Wastewater .................................................................. Pg. 3-7 3.9 Personnel Health and Safety ..................................................................... Pg. 3-7 3.10 Decontamination Efforts............................................................................. Pg. 3-8 3.11 Soil Sampling and Analysis ...................................................................... Pg. 3-15 3.12 Ground Water Sampling and Analysis ..................................................... Pg. 3-25 3.13 Surface Water Sampling and Analysis ..................................................... Pg. 3-32 3.14 Sediment Sampling and Analysis ............................................................. Pg. 3-32 3.15 Soil Gas Sampling and Analysis .............................................................. Pg. 3-33 3.16 Background and Soil ................................................................................ Pg. 3-33 Closure Plan Review Guidance 2017 Page ii 3.17 Background and Ground Water ............................................................... Pg. 3-35 3.18 Background and Sediment ....................................................................... Pg. 3-39 3.19 Background and Surface Water ............................................................... Pg. 3-40 3.20 Use of Historical Data .............................................................................. Pg. 3-40 3.21 Financial Assurance Requirements ......................................................... Pg. 3-44 Chapter 4 - Components for Closure by Removal Plans .................................. Pg. 4-1 4.1 Remediation Standards for Soils and Ground Water .................................. Pg. 4-1 4.2 Statistical Evaluation of Soil ....................................................................... Pg. 4-7 4.3 Statistical Evaluation of Ground Water ....................................................... Pg. 4-7 4.4 Description of Removal Efforts and Treatment Processes ......................... Pg. 4-7 4.5 Status of Facility After Closure by Removal ............................................... Pg. 4-9 Chapter 5 - Components for Waste in Place Closure Plans, Post-Closure Plans and Certifications ................................................... Pg. 5-1 5.1 Components for Waste in Place Closure Plans .......................................... Pg. 5-1 5.2 Components of a Closure Certification ...................................................... Pg. 5-3 5.3 Components for Post-Closure Plans .......................................................... Pg. 5-4 5.4 Components of a Post-Closure Certification ............................................ Pg. 5-13 Chapter 6 - Risk Assessment in Closure ........................................................... Pg. 6-1 6.1 Introduction ................................................................................................ Pg. 6-1 6.2 Human Health Risk Assessments .............................................................. Pg. 6-2 6.3 Ecological Risk Assessments .................................................................. Pg. 6-12 Chapter 7 - General Concepts in Human Health Risk Assessments ............... Pg. 7-1 7.1 Data Collection/Evaluation ......................................................................... Pg. 7-1 7.2 Exposure Assessment ............................................................................... Pg. 7-8 7.3 Toxicity Assessment ................................................................................ Pg. 7-20 7.4 Risk Characterization ............................................................................... Pg. 7-24 Chapter 8 - Glossary ........................................................................................... Pg. 8-1 Chapter 9 - References ....................................................................................... Pg. 9-1 Appendices Appendix A: Development of Alternate Metal Standards ................................. Pg. A-1 Appendix B: Guidance for Statistical Evaluation of Hazardous Waste Constituent Levels in Soils .......................................................................................... Pg. B-1 Appendix C: Grid Spacing Determination ......................................................... Pg. C-1 Appendix D: Ground Water Scoring Matrix ....................................................... Pg. D-1 Appendix E: Mobile Laboratory Guidance......................................................... Pg. E-1 Appendix F: Final Covers for Hazardous Waste Surface Impoundments, Waste Piles, and Landfills .................................................................................. Pg. F-1 Appendix G: Soil Permeability Data Evaluation .............................................. Pg. G-1 Closure Plan Review Guidance 2017 Page iii List of Equations Equation 3-1: Decision Rule for Composite Sampling ................................................ 3-20 Equation 3-2: Relative Percent Difference .................................................................. 3-21 Equation 4-1: Calculation of Background Remediation Standard (BRS) ......................
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