Facility:__________________________
Date:____________________________
DRIP PAD CHECKLIST
(40 CFR Part 264 and 265, Subpart W)
Records [262.34(a)(1)(iii)]
1. Described procedures that will be followed to ensure that all wastes are
removed from the drip pad and associated collection system at least once every
90 days [262.34(a)(1)(iii)(A)]
Y____
N____
2. Is each waste removal, including the quantity of waste removed from the drip
pad and the sump or collection system and the date and time of removal
documented? [262.34(a)(1)(iii)(B)]
Y____
N____
1. Is the drip pad constructed of non-earthen materials, excluding wood and
non-structurally supported asphalt? [265.443(a)(1)]
Y____
N____
2. Is the drip pad sloped to free-drain treated wood drippage, rain and other
waters, or solutions of drippage and water or other waste to the associated
collection system.? [265.443(a)(2)]
Y____
N____
3. Does the drip pad have a curb or berm around the perimeter?
[265.443(a)(3)]
Y____
N____
Design and Operating Requirements [264.573 & 265.443]
The requirements of question number 4 apply only to existing drip pads and those drip pads for which the owner or
operator elects to comply with 265.442(a) instead of 265.442(b). [265.443(a)(4)(i)]
4. Does the drip pad have a hydraulic conductivity of less than or equal to 1 x
10-7 centimeters per second. ?
a. Is surface material maintained free of cracks and gaps that could
adversely affect its hydraulic conductivity?
Y____
N____
b. Is the material chemically compatible with the preservatives that
contact the drippad?
Y____
N____
5. Is a written assessment of the drip pad certified by an independent, qualified
registered professional engineer on file at the facility?
Y____
N____
a. Has this assessment been reviewed, updated and re-certified
annually?
Y____
N____
b. Does the evaluation document the extent to which the drip pad meets
the design and operating standards of this section, except for subsection (b)?
[265.443(a)(4)(ii)]
Y____
N____
6. Is the drip pad of sufficient structural strength and thickness to prevent
failure due to physical contact, climatic conditions, the stress of installation, and
the stress of daily operations? [265.443(a)(5)]
Y____
N____
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DRIP 1 of 4
Facility:__________________________
Date:____________________________
If an owner/operator elects to comply with 265.442(b) instead of 265.442(a), the drip pad must have a synthetic
liner installed below the drip pad that is designed, constructed, and installed to prevent leakage from the drip pad
into the adjacent subsurface soil or groundwater or surface water at any time during the active life (including the
closure period) of the drip pad. Is the liner:
8. Constructed of materials that have appropriate chemical properties and
sufficient strength and thickness to prevent failure due to pressure gradients
(including static head and external hydrogeologic forces), physical contact with
the waste or drip pad leakage, climatic conditions, the stress of installation, and
the stress of daily operation (including stresses from vehicular traffic on the drip
pad)? [265.443(b)(1)(i)]
Y____
N____
9. Placed upon a foundation or base capable of providing support to the liner
and resistance to pressure gradients above and below the liner to prevent failure
of the liner due to settlement, compression or uplift? [265.443(b)(1)(ii)]
Y____
N____
10. Installed to cover all surrounding earth that could come in contact with the
waste or leakage? [265.443(b)(1)(iii)]
Y____
N____
11. Chemically resistant to the waste managed in the drip pad and the leakage
that might be generated? [265.443(b)(2)(i)(A)]
Y____
N____
12. Of sufficient strength and thickness to prevent collapse under thepressures
exerted by overlaying materials and by any equipment used at the drip pad?
[265.443(b)(2)(i)(B)]
Y____
N____
13. Is it designed and operated to function without clogging through the
scheduled closure of the drip pad? [265.443(b)(2)(ii)]
Y____
N____
14. Is it designed so that it will detect the failure of the drip pad or the presence
of a release of hazardous waste or accumulated liquid at the earliest practicable
time? [265.443(b)(2)(iii)]
Y____
N____
15. Is the date, time, and quantity of any leakage collected in this system and
removed documented in the operating log? [265.443(b)(3)]
Y____
N____
16. Are the drip pads maintained such that they remain free of cracks, gaps,
corrosion, or other deterioration that could cause hazardous waste to be released
from the drip pad.? [265.443(c)]
Y____
N____
17. Is the drip pad and associated collection system designed and operated to
convey, drain, and collect liquid resulting from drippage or precipitation in order to
prevent run-off? [265.443(d)]
Y____
N____
Is the leakage detection system constructed of materials that are:
18. Has the owner or operator designed, constructed, operated and maintained
a run-on control system capable of preventing flow onto the drip pad during peak
discharge from at least a 24-hour, 25-year storm unless the system has sufficient
excess capacity to contain any run-on that might enter the system, or the drip pad
is protected by a structure or cover, as described in 265.440(b) of this subpart.?
[265.443(e)]
Y____
19. If not protected by a structure or cover, as described in 265.440(b) of this
subpart, has the owner or operator designed, constructed, operated and
Rev. 4-12-94
DRIP 2 of 4
N____
Facility:__________________________
Date:____________________________
maintained a run-off management system to collect and control at least the water
volume resulting from a 24-hour, 25-year storm? [265.443(f)]
Y____
20. Has the owner or operator obtained a statement from an independent,
qualified registered professional engineer certifying that the drip pad design
meets the requirements of this section.? [265.443(g)]
21. Has the drippage and accumulated precipitation been removed from the
associated collection system as necessary to prevent overflow onto the drip pad.?
[265.443(h)]
Y____
N____
Y____
N____
N____
22. Is the drip pad surface cleaned thoroughly so as to allow weeklyinspections
of the entire drip pad surface without interference or hindrance from accumulated
residues of hazardous waste or other materials on the drip pad?
Y____
N____
Has the owner or operator documented the date and time of each
cleaning and the cleaning procedure used in the facility's operating log?
[265.443(i)]
23. Are the drip pads operated and maintained in a manner to minimize tracking
of hazardous waste or hazardous waste constituents off the drip pad as a result
of activities by personnel or equipment? [265.443(j)]
Y____
Y____
N____
N____
24. After being removed from the treatment vessel, is the treated wood from
pressure and non-pressure processes being held on the drip pad until drippage
has ceased?
Y____
N____
Has the owner or operator maintained records sufficient to document that
all treated wood is held on the pad following treatment in accordance with this
requirement? [265.443(k)]
Y____
N____
25. Are the collection and holding units associated with run-on and run-ff control
systems emptied or otherwise managed as soon as possible after storms to
maintain design capacity of the system? [265.443(k)]
Y____
N____
Y____
N____
28. Entered a record of the discovery in the facility operating log?
[265.443(m)(1))(i)]
Y____
N____
29. Immediately removed the portion of the drip pad affected by the condition
from service;? [265.443(m)(1))(ii)]
Y____
N____
30. Determined what steps must be taken to repair the drip pad, remove any
leakage from below the drip pad, and establish a schedule for accomplishing the
clean up and repairs? [265.443(m)(1))(iii)]
Y____
N____
26. Throughout the active life of the drip pad, has the owner or operator detected
a condition that may have caused or has caused a release of hazardous waste?
If answer is No proceed to inspections, page 4.
27. Has the condition been repaired within a reasonably prompt period of time
following discovery? [265.443(m)]
Upon detection of leakage by the leak detection system, has the owner or operator:
Rev. 4-12-94
DRIP 3 of 4
Facility:__________________________
Date:____________________________
31. Within 24 hours after discovery of the condition, notified the Regional
Administrator of the condition and, within 10 working days, provided a written
notice to the Regional Administrator with a description of the steps that will be
taken to repair the drip pad, and clean up any leakage, and the schedule for
accomplishing this work.? [265.443(m)(1))(iv)]
Y____
N____
32. Upon completing all repairs and clean up, has the owner or operator notified
the Regional Administrator in writing and provided a certification, signed by an
independent qualified, registered professional engineer, that the repairs and clean
up have been completed according to the written plan submitted in accordance
with paragraph (m)(1)(iv) of this section? [265.443(m)(3)]
Y____
N____
33. Has the owner or operator maintained, as part of the facility operating log,
documentation of past operating and waste handling practices?
Y____
N____
Does it include identification of preservative formulations used in the
past, a description of drippage management practices, and a description of
treated wood storage and handling practices? [265.443(n)]
Y____
N____
1. During construction or installation, have the liners and cover systems been
inspected for uniformity, damage, and imperfections ?
Y____
N____
a. Immediately after construction or installation, have the liners been
inspected and certified by an independent qualified, registered professional
engineer?
Y____
N____
b. Is this certification maintained at the facility as part of the facility
operating record?
Y____
N____
c. After installation have the liners and covers been inspected to ensure
tight seams and joints and the absence of tears, punctures, or blisters?
[265.44(a)]
Y____
N____
Inspections [265.444]
While drip pad is in operation, is it inspected weekly and after storms to detect evidence of any of the following:
2. Deterioration, malfunctions or improper operation of run-on and run-off
control systems? [265.44(b)(1)]
Y____
N____
3. The presence of leakage in and proper functioning of leakage detection
system? [265.44(b)(2)]
Y____
N____
4.
Y____
N____
Deterioration or cracking of the drip pad surface? [265.44(b)(3)]
Rev. 4-12-94
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