RCRA REVISION CHECKLIST 82

Wood Preserving Listings
55 FR 50450-50490
December 6, 1990 
(RCRA Cluster I, HSWA and Non-HSWA Provisions)

1)  This Revision Checklist adds three broad categories of wastes from wood preserving processes that use chlorophenolic, creosote, and/or inorganic (arsenical and chromium) preservatives to the list of wastes from non-specific sources.  These wastes, F032, F034 and F035, include wastewaters, process residuals, preservative drippage and spent formulations.  The listing of F032 and the permitting and interim status standards applicable to drip pads handling this waste are promulgated pursuant to HSWA.  The listings of F034 and F035, the permitting and interim standards for drip pads that handle F034 and F035 wastes, and the addition of a test method to Appendix III of Part 261 are non-HSWA provisions.  EPA will implement the addition of F032 to the list of hazardous wastes from non-specific sources in authorized States until the States modify their programs and such modifications are approved by EPA.  The non-HSWA requirements are applicable only in those States that do not have interim or final authorization.  In authorized States, the non-HSWA requirements will not be applicable until the States revise their programs to adopt equivalent requirements under State law, unless the wastes are designated as hazardous due to the Toxicity Characteristic, which would allow an owner or operator to comply with the drip pad standards administered under Federal law.

2)  Note that on June 13, 1991 (56 FR 27332), an administrative stay was published affecting this final rule.  Because the Federal code was changed, a checklist was developed, Revision Checklist 91.  The changes addressed by that checklist are all optional.

3)  Technical corrections were made to this rule on July 1, 1991 (56 FR 30192; Revision Checklist 92).  States are strongly encouraged to adopt those technical corrections at the same time that Revision Checklist 82 provisions are adopted.

				STATE ANALOG IS:	
		     ANALOGOUS	  EQUIV-	   MORE	BROADER
   FEDERAL REQUIREMENT     | 	FEDERAL RCRA CITATION    |	   STATE CITATION	| ALENT  |	STRINGENT |	IN SCOPE	

PART 260 - HAZARDOUS WASTE MANAGEMENT SYSTEM:  GENERAL

SUBPART B - DEFINITIONS

DEFINITIONS 	 
add "drip pad" in
alphabetical order	260.10	

PART 261 - IDENTIFICATION AND LISTING OF HAZARDOUS WASTE

SUBPART A - GENERAL

EXCLUSIONS	 
	†	add new paragraph 
which excludes as a 
solid waste spent 
wood preserving 
solutions that have
been used and are
reclaimed and reused
for their original
intended purpose	261.4(a)(9)	

SUBPART D - LISTS OF HAZARDOUS WASTES

HAZARDOUS WASTES FROM NON-SPECIFIC SOURCES	 
add the waste codes
"F032", "F034" and
"F035" in alpha-
numeric order to list
as shown below	261.31(a)	

Industry and EPA hazardous						Hazard
         waste No.			Hazardous waste		 	 code	  	 

       *              *            *             *            *            *            *            *       
F032 . . .	Wastewaters, process residuals, preservative drippage, and spent formula- 	(T)
		tions from wood preserving processes generated at plants that currently use or have previously used chlorophenolic formulations (except potentially cross-contaminated wastes that have had the F032 waste code deleted in accordance with §261.35 of this chapter and where the generator does not resume or initiate use of chlorophenolic formulations).  This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote and/or pentachlorophenol.
F034 . . .	Wastewaters, process residuals, preservative drippage, and spent formula-	(T)
		tions from wood preserving processes generated at plants that use creosote formulations.  This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote and/or pentachlorophenol.
F035 . . .	Wastewaters, process residuals, preservative drippage, and spent formula-	(T)
		tions from wood preserving processes generated at plants that use inorganic preservatives containing arsenic or chromium.  This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote and/or pentachlorophenol.

       *              *            *             *            *            *            *            *     
	
DELETION OF CERTAIN HAZARDOUS WASTE CODES FOLLOWING EQUIPMENT CLEANING AND REPLACEMENT	 
wastes from wood
preserving processes
at plants that do not
resume or initiate
use of chlorophenolic
preservatives will not
meet the listing 
definition of F032
once the 261.35(b)
and (c) requirements
are met; wastes may
continue to meet
another hazardous
waste listing descrip-
tion or exhibit one or
more characteristics	261.35(a)	
generators must 
either clean or 
replace all specified
process equipment 
that may have come 
into contact with 
chlorophenolic 
formulations or
constituents;
generators must 
either:	261.35(b)	
prepare and sign
a written equipment
cleaning or replace-
ment plan and con-
duct cleaning and/or 
replacement of equip-
ment in accordance
with plan; manage 
discarded equipment
as F032 waste	261.35(b)(1)	
removal of all visible
residues from process
equipment and rinsing
process equipment
with appropriate 
solvent to meet
specified criteria when
tested in accordance
with SW-846 Method
8290; management
of all residues
as F032 waste	261.35(b)(2)	
document that 
previous equipment 
cleaning or replace-
ment was performed
in accordance with
261.35 requirements
and occurred after a
change in
preservative	261.35(b)(3)	
documentation that 
must be maintained 
as part of the 
facility's
operating record	261.35(c)	
name and address of
the facility	261.35(c)(1)	
formulations 
previously used and
the date on which
their use ceased 
in each process
at the plant	261.35(c)(2)	
formulations currently
used in each process
at the plant	261.35(c)(3)	
equipment cleaning
or replacement plan	261.35(c)(4)	
name and address of
any persons who
conducted the 
cleaning and 
replacement	261.35(c)(5)	
dates on which 
cleaning and 
replacement were 
accomplished	261.35(c)(6)	
dates of sampling
and testing	261.35(c)(7)	
description of sample 
handling and prep-
aration techniques	261.35(c)(8)	
description of the
tests performed, the
date, and the results
of the tests	261.35(c)(9)	
name and model 
numbers of the
instrument(s) used in
performing the tests	261.35(c)(10)	
QA/QC 
documentation	261.35(c)(11)	
signed certification 
statement	261.35(c)(12)	

APPENDIX III TO PART 261

CHEMICAL ANALYSIS TEST METHODS	 
add the compound,
"Benzo(k) 
fluoranthene", in
alphabetical order, 
to Table 1	Table 1, Appendix III	

TABLE 1. --ANALYSIS METHODS FOR
ORGANIC CHEMICALS CONTAINED IN SW-846

					Method
		Compound			  Nos.

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

                                        Benzo(k) fluoranthene ............... 8100,8250,
	 	   			    8270,8310

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

APPENDIX VII TO PART 261

BASIS FOR LISTING HAZARDOUS WASTE	 
add "F032", "F034", 
and "F035" to list
in alphanumeric order
as shown below:	Appendix VII	

	EPA hazardous	Hazardous constituents for
	   waste No.	      which listed

	       *         *         *         *         *         *              
	F032.........................	Benz(a)anthracene, benzo(a)pyrene,
		  dibenz(a,h)-anthracene, 
		  indeno(1,2,3-cd)pyrene, pentachlor-
		  ophenol, arsenic, chromium, tetra-,
		  penta-, hexa-, heptachlorodibenzo-
		  p-dioxins, tetra-, penta-, hexa-, hep-
		  tachlorodibenzofurans.
	F034.........................	Benz(a)anthracene,
		  benzo(k)fluoranthene,
		  benzo(a)pyrene,
		  dibenz(a,h)anthracene,
		  indeno(1,2,3-cd)pyrene, naphtha-
		  lene, arsenic, chromium.
	F035.........................	Arsenic, chromium, lead.
	       *         *         *         *         *         *

APPENDIX VIII TO PART 261

HAZARDOUS CONSTITUENTS	 
add the specified
hazardous 
constituents in
alphabetical order
as shown below:	Appendix VIII	

		Chemical	Chemical
	Common name	abstracts	abstracts	Hazardous
		name	No.	waste No.

                     *            *             *            *            *            *                

Benzo(k)fluoranthene	     Same         207-08-9    	

                     *            *             *            *            *            *                  

Heptachlorodibenzofurans	   	   	   	
Heptachlorodibenzo-p-dioxins	   	   	   	

                     *            *             *            *            *            *                 

	 

PART 262 - STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTE

SUBPART C - PRE-TRANSPORT REQUIREMENTS

ACCUMULATION TIME	 
	†	redesignate paragraph
(a)(2) as (a)(3);
add new paragraph
requiring placement
of waste on drip pads,
generator compliance
with Subpart W of 
Part 265 and
maintenance of the
following records
at the facility:	262.34(a)(2)	
	†	description of 
procedures to ensure
wastes are removed
from drip pad and
associated collection
system at least once
every 90 days	262.34(a)(2)(i)	
	†	documentation of 
each waste removal,
including quantity,
date and time of 
removal; generator
exemption from Sub-
parts G and H of  
Part 265 require-
ments, except for
265.111 and 265.114	262.34(a)(2)(ii)	
redesignate
"262.34(a)(2)" as
"262.34(a)(3)"	262.34(a)(3)	
redesignate
"262.34(a)(3)" as
"262.34(a)(4)"	262.34(a)(4)	
redesignate 
"262.34(a)(4)" as
"262.34(a)(5)"	262.34(a)(5)	

PART 264 - STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE
TREATMENT, STORAGE AND DISPOSAL FACILITIES

SUBPART J - TANK SYSTEMS

APPLICABILITY	 
add reference to
paragraph (c) 	264.190	
add new paragraph
subjecting tanks, 
sumps and other
collection devices
used in conjunction
with Subpart W-
regulated drip pads to
Part 264, Subpart J
requirements	264.190(c)	

SUBPART W - DRIP PADS

APPLICABILITY	 
Subpart W applies 
to owners and
operators of facilities
that use new or 
existing drip pads
to convey treated
wood drippage to an
associated collection
system; existing drip 
pads defined	264.570(a)	
owner or operator
of certain drip pads
inside or under
a structure
not subject to
264.572(e) or 
264.572(f) 
regulations, as 
appropriate	264.570(b)	

ASSESSMENT OF EXISTING DRIP PAD INTEGRITY	 
evaluation of existing
drip pads; by June 6, 
1991, written 
assessment obtained
and kept on file;
annual review, update 
and recertification 
required until 264.572 
standards are met, 
except 264.572(b)
standards for liners
and leak detection
systems; documen-
tation of drip pad age 	264.571(a)	
development of 
written plan for up-
grading, repairing and
modifying drip pad
to meet 264.572(b)
requirements;
submittal of plan to
Regional Adminis-
trator no later than
2 years before 
completion of modi-
fications; written plan
documentation, re-
view and certification 
requirements; 
conditions for
completion of
upgrades, repairs
and modifications 	264.571(b)	
for existing drip
pads of known and
documentable age,
upgrades, repairs
and modifications
completed within 
two years of
June 6, 1991, or
when the drip pad 
has reached 
15 years of age,
whichever comes
later	264.571(b)(1)	
for existing drip pads
with no documentable
age, upgrades, repairs 
and modifications
must be completed
within 8 years of
June 6, 1991; if 
facility is over 7 years
old, completion
by the time facility
reaches 15 years or 
by two years after 
June 6, 1991, which-
ever comes later	264.571(b)(2)	
conditions under which
owner or operator 
may petition 
Regional Adminis-
trator for extension
of deadline; petition 
granted if drip pad 
meets all 264.572 
requirements, except
those for liners and 
leak detection systems 
specified in
264.572(b)	264.571(b)(3)	
submittal of 
required drawings 
and certification to 
Regional Adminis-
trator or State Director
upon completion of all
repairs and
modifications	264.571(c)	
if drip pad found to 
be leaking or unfit 
for use, compliance 
with 264.572(m) provi-
sions or close drip
pad in accordance
with 264.574	264.571(d)	

DESIGN AND OPERATING REQUIREMENTS	 

drip pads must:	264.572(a)	
be constructed of
non-earthen 
materials, excluding
wood and non-
structurally supported
asphalt	264.572(a)(1)	
be sloped for free-
drainage to the
associated collection
system	264.572(a)(2)	
have a curb or berm
around the perimeter	264.572(a)(3)	
be impermeable
as specified 	264.572(a)(4)	
be of sufficient 
structural strength
and thickness to meet
specified conditions	264.572(a)(5)	
a drip pad must 
have:	264.572(b)	
a synthetic liner that
meets certain design,
construction and instal-
lation specifications	264.572(b)(1)	
specific requirements 
for liner construction 
materials	264.572(b)(1)(i)	
foundation or base
requirements	264.572(b)(1)(ii)	
liner must cover all
surrounding earth that
could come into 
contact with the
waste or leakage	264.572(b)(1)(iii)	
leakage detection
system immediately
above the liner;
detection system
must be:	264.572(b)(2)	
constructed of 
materials that are:	264.572(b)(2)(i)	
chemically resistant
to relevant waste
and leakage	264.572(b)(2)(i)(A)	
of sufficient strength
and thickness to 
prevent collapse	264.572(b)(2)(i)(B)	
designed and operated
to function without 
clogging through the
scheduled closure of
the drip pad	264.572(b)(2)(ii)	
designed to detect
drip pad failure or the
release of hazardous 
waste or accumulated
liquid at the earliest
practicable time	264.572(b)(2)(iii)	
maintenance of drip 
pads; note regarding
remedial action	264.572(c)	
convey, drain, and 
collect liquid resulting
from drippage or
precipitation in order
to prevent run-off	264.572(d)	
run-on control
system requirements,
unless control
system is protected
by a structure, as
described in 
264.570(b)	264.572(e)	
run-off management 
system requirements,
unless system is 
protected by a 
structure, as
described in 
264.570(b)	264.572(f)	
evaluation of drip pad
for compliance with
264.572(a) - (f) 
requirements; design
certification required	264.572(g)	
removal of drippage
and accumulated
precipitation from
associated collection
system as necessary 
to prevent overflow
onto the drip pad	264.572(h)	
thorough cleaning of
drip pad surface at 
least once every 
seven days to meet 
specified conditions; 
documentation of date,
time and cleaning 
procedure in facility's
operating log	264.572(i)	
minimize tracking of 
hazardous waste or 
constituents off the
drip pad	264.572(j)	
after removal from 
treatment vessel, 
treated wood from
pressure and non-
pressure processes
must be held on pad
until drippage has
ceased; documen-
tation required	264.572(k)	
collection and holding 
units for run-on and
run-off control systems
emptied or otherwise
managed as soon as 
possible after storms
to maintain design
capacity	264.572(l)	
throughout the active
life of the drip pad
and as specified in
the permit, repair of
detected condition 
that could lead to 
or has caused a 
release of hazardous 
waste within a 
reasonable period
of time, in accordance
with the following
procedures:	264.572(m)	
upon detection of a
condition that has
led or could lead to
a release of 
hazardous waste, the
owner must:	264.572(m)(1)	
enter discovery in 
the facility operating
log	264.572(m)(1)(i)	
immediately remove
from service 
affected portion of
drip pad	264.572(m)(1)(ii)	
determine steps
to repair drip pad
and clean up any 
leakage; establish 
schedule for repairs	264.572(m)(1)(iii)	
notify Regional
Administrator within
24 hours after 
discovery; provide 
written notice as 
specified within 10
working days	264.572(m)(1)(iv)	
review, determination
and notification by
Regional Administrator	264.572(m)(2)	
1		written notification to
Regional Administrator
and certification of
compliance with 
264.572(m)(1)(iv) after
repairs and clean up	264.572(m)(3)	
should a permit be
necessary, Regional
Administrator will
specify in the permit
all design and 
operating practices 
necessary to ensure 
that 264.572 require-
ments are met	264.572(n)	
documentation in 
operating log, as
specified, of 
past operating and
waste handling 
practices	264.572(o)	

INSPECTIONS	 
inspection of liners 
and cover systems 
for uniformity, damage
and imperfections 
during construction or
installation; inspection
and certification of 
liners to meet
264.572 requirements;
maintenance of 
certification as part
of the facility 
operating record;
inspection of liners 
and covers after
installation	264.573(a)	
drip pad must be 
inspected weekly and
after storms to detect
evidence of any of
the following:	264.573(b)	
deterioration,
malfunctions or
improper operation
of run-on and run-off
control systems	264.573(b)(1)	
presence of leakage
in and proper
functioning of leak
detection system	264.573(b)(2)	
deterioration or
cracking of drip
pad surface;
note regarding
remedial action	264.573(b)(3)	

CLOSURE	 
at closure, removal
and decontamination
requirements; manage-
ment as hazardous
waste	264.574(a)	
conditions under  
which owner or 
operator must close 
facility and perform 
post-closure care in 
accordance with 
264.310 requirements;
for permitted units,
permit requirement
continues throughout
post-closure period;
drip pad is con-
sidered a landfill and
must meet Subparts 
G and H require-
ments of Part 264	264.574(b)	
owner or operator
of an existing drip
pad that does not 
comply with the
264.572(b)(1) liner
requirements must:	264.574(c)(1)	
include in closure 
plans for drip pad
under 264.112, a plan
for 264.574(a) com-
pliance and a 
contingent plan for
264.574(b) compliance 	264.574(c)(1)(i)	
prepare a contingent
post-closure plan
under 264.118 for
complying with 
264.574(b) in case
not all contaminated
subsoils can be 
practicably removed
at closure	264.574(c)(1)(ii)	
cost estimates 
calculated under
264.112 and 264.144
for closure and post-
closure care of drip
pad subject to 
264.574 must include
the cost of complying
with the contingent
closure plan and the
contingent post-
closure plan; cost of 
expected closure 
under 264.574(a)
need not be included	264.574(c)(2)	

DESIGN AND INSTALLATION OF NEW DRIP PADS	 
owners and 
operators of drip pads
must ensure that the
pads are designed,
installed and 
operated in 
accordance with all
applicable 264.572, 
264.573 and 
264.574 requirements	264.575	

PART 265 - INTERIM STATUS STANDARDS FOR OWNERS AND OPERATORS OF
HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIES

SUBPART J - TANK SYSTEMS

APPLICABILITY	 
add reference to
paragraph (c) 	265.190	
add new paragraph
subjecting tanks, 
sumps and other
collection devices
used in conjunction
with Subpart W-
regulated drip pads
to Part 265, Subpart J
requirements	265.190(c)	
SUBPART W - DRIP PADS

APPLICABILITY	 
Subpart W applies 
to owners and
operators of facilities
that use new or 
existing drip pads
to convey treated
wood drippage to an
associated collection
system; existing drip 
pads defined	265.440(a)	
owner or operator
of certain drip pads
inside or under
a structure
not subject to
265.443(e) or 
265.443(f) 
regulations, as 
appropriate	265.440(b)	

ASSESSMENT OF EXISTING DRIP PAD INTEGRITY	 
evaluation of existing
drip pads; by June 6,
1991, written 
assessment obtained
and kept on file;
annual review, update 
and recertification 
required until 265.443
standards are met,
except for 265.443(b)
standards for liners
and leak detection
systems;
documentation
of drip pad age 	265.441(a)	
development of
written plan for up-
grading, repairing and
modifying drip pad
to meet 265.443(b)
requirements;
submittal of plan to
Regional Adminis-
trator no later than
2 years before 
completion of modi-
fications; 
written plan docu-
mentation, review and
certification require-
ments; conditions for
completion of 
upgrades, repairs
and modifications 	265.441(b)	
for existing drip
pads of known and
documentable age,
upgrades, repairs and
modifications com-
pleted within two years
of June 6, 1991; or
when the drip pad has 
reached 15 years of 
age, whichever comes
later	265.441(b)(1)	
for existing drip pads
with no documentable
age, upgrades, repairs
and modifications 
must be completed
within 8 years of June
June 6, 1991; if
facility is over 7 years
old, completion by the 
time facility reaches
15 years or by two 
years after June 6, 
1991, whichever 
comes later	265.441(b)(2)	
conditions under
which owner or 
operator may petition 
Regional Adminis-
trator for extension
of deadline;
petition granted if
drip pad meets all
265.443 requirements,
except those for 
liners and leak 
detection systems 
specified in
265.443(b)	265.441(b)(3)	
submittal of 
required drawings 
and certification to 
Regional Administrator
or State Director
upon completion of
all repairs and
modifications	265.441(c)	
if drip pad found to
be leaking or unfit for
use, comply with
265.443(m) provi-
sions or close drip
pad in accordance
with 265.445	265.441(d)	

DESIGN AND INSTALLATION OF NEW DRIP PADS	 
owners and operators
of new drip pads
must ensure that the
pads are designed,
installed and 
operated in 
accordance with all
applicable 265.443, 
265.444 and
265.445 requirements	265.442	

DESIGN AND OPERATING REQUIREMENTS	 

drip pads must:	265.443(a)	
be constructed of
non-earthen 
materials, excluding
wood and non-
structurally supported
asphalt	265.443(a)(1)	
be sloped to free-
drain wastes to the
associated collection
system	265.443(a)(2)	
have a curb or berm
around the perimeter	265.443(a)(3)	
be impermeable
as specified	265.443(a)(4)	
be of sufficient 
structural strength
and thickness to
meet specified condi-
tions; note regarding
structural integrity
standards	265.443(a)(5)	
a new drip pad or an
existing drip pad, 
after the 265.441(b) 
deadline, must have:	265.443(b)	
a synthetic liner
that meets certain
specifications	265.443(b)(1)	
specific requirements 
for liner construction 
materials	265.443(b)(1)(i)	
foundation or base
requirements	265.443(b)(1)(ii)	
liner must cover 
all surrounding
earth that could 
come into contact
with the waste
or leakage	265.443(b)(1)(iii)	
leakage detection
system immediately
above the liner;
detection
system must be:	265.443(b)(2)	
constructed of 
materials that are:	265.443(b)(2)(i)	
chemically resistant
to relevant waste 
and leakage	265.443(b)(2)(i)(A)	
of sufficient strength
and thickness to 
prevent collapse	265.443(b)(2)(i)(B)	
designed to detect the 
failure of the drip
pad or the presence
of hazardous waste 
release or 
accumulated liquid at
the earliest
practicable time 	265.443(b)(2)(ii)	
maintenance of drip
pads; note regarding
remedial action	265.443(c)	
convey, drain, and 
collect liquid resulting
from drippage or
precipitation in order
to prevent run-off	265.443(d)	
run-on control
system requirements,
unless drip pad
is protected
by a structure, as
described in 
265.440(b)	265.443(e)	
run-off management 
system requirements,
unless drip pad
is protected by a 
structure, as
described in 
265.440(b)	265.443(f)	
evaluation of
drip pad for 
compliance with
265.443(a) - (f) 
requirements;
design certification
required	265.443(g)	
removal of drippage
and accumulated
precipitation from
associated collection
system as necessary 
to prevent overflow
onto the drip pad	265.443(h)	
thorough cleaning of
drip pad surface at 
least once every 
seven days to meet 
specified conditions; 
documentation of
date, time and 
cleaning procedure in
facility's
operating log	265.443(i)	
minimize tracking of
hazardous waste or 
constituents off the 
drip pad	265.443(j)	
after removal from 
treatment vessel, 
treated wood from 
pressure and non-
pressure processes
must be held on pad
until drippage has
ceased; documen-
tation required	265.443(k)	
collection and holding 
units for run-on and
run-off control systems
emptied or otherwise 
managed as soon as 
possible after storms
to maintain design 
capacity	265.443(l)	
throughout the active
life of the drip pad
and as specified in
the permit, repair of
detected condition
that could lead to 
or has caused a 
release of hazardous 
waste within a 
reasonable period
of time, in accordance
with the following
procedures:	265.443(m)	
upon detection of a
condition that has led
or could lead to a 
release of hazardous 
waste, the owner
must:	265.443(m)(1)	
entry of discovery in
the facility operating
log	265.443(m)(1)(i)	
immediate removal
from service of 
affected portion of
drip pad	265.443(m)(1)(ii)	
determination of steps
to repair drip pad,
remove any leakage, 
and establish schedule
for clean up and 
repairs	265.443(m)(1)(iii)	
notify Regional
Administrator within
24 hours after dis-
covery; provide written
notice as specified 
within 10 working days	265.443(m)(1)(iv)	
review, determination
and notification by
Regional Administrator	265.443(m)(2)	
	2	written notification to
Regional Adminis-
trator and 
certification of
compliance with 
265.443(m)(1)(iv)
after repairs and 
clean up	265.443(m)(3)	
documentation in 
operating log, as
specified, of 
past operating and
waste handling 
practices	265.443(n)	

INSPECTIONS	 
inspection of liners 
and cover systems 
for uniformity, damage
and imperfections 
during construction or
installation; inspection
and certification of 
liners to meet
265.443 requirements;
maintenance of 
certification as part
of the facility 
operating record;
inspection of liners 
and covers after
installation	265.444(a)	
drip pad must be 
inspected weekly and
after storms to detect
evidence of any of
the following:	265.444(b)	
deterioration,
malfunctions or
improper operation
of run-on and run-off
control systems	265.444(b)(1)	
presence of 
leakage in and proper
functioning of leak
detection system	265.444(b)(2)	
deterioration or
cracking of drip pad
surface; note regar-
ding remedial action	265.444(b)(3)	

CLOSURE	 
at closure, removal
and decontamination
requirements; manage-
ment as hazardous
waste	265.445(a)	
closure and post-
closure care of drip
pad as a landfill under
265.310, if some 
contaminated subsoils
cannot be removed or
decontaminated;
for permitted 
units, permit require-
ment continues 
throughout post-
closure period	265.445(b)	
owner or operator
of an existing drip
pad not in compliance
with the 265.443(b)(1)
liner requirements
must:	265.445(c)(1)	
include in the closure
plan for the drip pad
under 265.112, a plan
for 265.445(a) com-
pliance and a contin-
gent plan for 
265.445(b) compliance	265.445(c)(1)(i)	
prepare contingent 
post-closure plan 
under 265.118 for
complying with 
265.445(b) in case 
not all contaminated
subsoils can be 
practicably removed
at closure	265.445(c)(1)(ii)	
cost estimates cal-
culated under 265.112
and 265.144 for clos-
ure and post-closure 
care of drip pad sub-
ject to 265.445(c) must 
include cost of comply-
ing with contingent 
closure plan and con-
tingent post-closure 
plan; cost of expected
closure under 
265.445(a) need
not be included	265.445(c)(2)	

PART 270 - EPA ADMINISTERED PERMIT PROGRAMS:
THE HAZARDOUS WASTE PERMIT PROGRAM

SUBPART B - PERMIT APPLICATION

3		SPECIAL PART B INFORMATION REQUIREMENTS FOR DRIP PADS	 
additional information
to be provided by
owners and operators
of hazardous waste
treatment, storage,
or disposal facilities
that collect, store, or
treat hazardous waste
on drip pads, except
as otherwise provided
by 264.1	270.22	
list of hazardous 
wastes placed or to be
placed on
each drip pad	270.22(a)	
detailed plans and
an engineering report
describing how 
264.90(b)(2) will
be met, if an 
exemption is sought
to Subpart F of 
Part 264	270.22(b)	
detailed plans and
an engineering report
describing the design,
construction, opera-
tion and maintenance
of drip pad to meet 
264.572 require-
ments; submission 
must address 
264.571 items	270.22(c)	
design characteristics
of the drip pad	270.22(c)(1)	

liner system	270.22(c)(2)	
leakage detection
system	270.22(c)(3)	
practices designed
to maintain drip
pads	270.22(c)(4)	
associated collection
system	270.22(c)(5)	
control of run-on
to the drip pad	270.22(c)(6)	
control of run-off
from the drip pad	270.22(c)(7)	
removal intervals and
demonstration of
sufficiency to prevent
overflow	270.22(c)(8)	
procedures for 
cleaning drip pad at 
least once every 
seven days;
provisions for
documentation of  
date, time and 
cleaning procedure	270.22(c)(9)	
operating practices
and procedures to 
minimize tracking of 
hazardous waste
or waste constituents
off the drip pad	270.22(c)(10)	
procedures for 
ensuring that
treated wood from
pressure and non-
pressure processes is
held on the drip pad
until drippage has
ceased; recordkeeping 
practices	270.22(c)(11)	
provisions for 
ensuring that 
collection and
holding units for
run-on and run-off
control systems
are emptied or 
managed as soon as
possible after storms
to maintain design
capacity 	270.22(c)(12)	
if treatment is carried
out on the drip pad,
details of process
equipment used, and 
the nature and quality
of residuals	270.22(c)(13)	
description of drip
pad inspections to
meet 264.572 require-
ments; include in
270.14(b)(5) 
inspection plan	270.22(c)(14)	
certification that drip
pad design meets 
264.571(a) - (f)
requirements	270.22(c)(15)	
description of removal
procedures at closure
under 264.573(a);
for waste not removed
at closure, submittal
of detailed plan and 
engineering report to
describe compliance
with 264.310(a) 
and (b); information
should be included 
in closure plan
and, where applicable,
270.14(b)(13)
post-closure plan	270.22(c)(16)