Why pass the cost estimate responsibility to RWQCB when CIWMB has financial mechanism review responsibility?
The RWQCB already reviews the design so is in the best position to review the estimated cost. The CIWMB’s responsibility focuses upon the viability of the financial mechanism itself, plus cost validation for any topics not addressed by the RWQCB’s review (e.g., fencing-off the facility). There are two parts to the financial assurance question: 1) how much money is needed to cover the anticipated costs; and 2) the adequacy of the financial instrument to assure that these funds will be available when needed. The CIWMB’s principal duty concerns the latter. Q: Chapter 15 deals with landfills, waste piles, surface impoundments and land treatment units. How are the last two handled under the consolidated regulations if they are non-hazardous wastes? A: They are covered in Title 27 in the same way as they were under Chapter 15. Q: What Article 5 compliance costs should be included in cost estimates for preliminary or final closure and post-closure maintenance plans? A: For closure plans, the
