PROPERTY OF THE
         OFFICE OF SUPERFUND
                                                PB86-165362
DRUM HANDLING  PRACTICES AT HAZARDOUS
WASTE SITES
JRB Associates,  Incorporated
McLean, VA
Jan 86
                 U.S. DEPARTMENT OF COMMERCE
               National Technical Information Service

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                                            PB86-165362

                                          EPA/600/2-86/013
                                          January 1986
             DRUM  HANDLING PRACTICES
            AT HAZARDOUS  WASTE SITES
                       by

              K. Wagner,  R.  Wetzel
              H. Bryson,  C.  Furman
            A. Wickline,  and V.  Hodge
                 JRB  Associates
             McLean,  Virginia  22102
             Contract  No.  68-03-3113
                                   U.S. Environmental Protection Agency
                                   Region 5, Library (PL-12J)
                                   77 West Jackson Boulevard  12th
                                   Chicago, Ji.  60604-3590'
                 Project Officer

                Anthony N.  Tafuri
Hazardous Waste Engineering Research Laboratory
             Releases  Control  Branch
            Edison, New Jersey  08837
 HAZARDOUS WASTE ENGINEERING RESEARCH LABORATORY
       OFFICE OF RESEARCH AND DEVELOPMENT
      U.S. ENVIRONMENTAL PROTECTION AGENCY
             CINCINNATI, OHIO  45268
              REPRODUCED BY
               NATIONAL  TECHNICAL
              INFORMATION SERVICE
                  U.S. DEPARTMENT OF COMMERCE
                    SPRINGFIELD, VA, 22161

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
 1. REPORT NO.

   EPA/600/2-86/013
                              2.
                                                           3. RECIPIENT'S ACCE5SLQN NO. ,,
                                                              PB8 b   16 ^T6 2 /*
4. TITLE AND SUBTITLE
 DRUM HANDLING PRACTICES AT HAZARDOUS
 WASTE  SITES
                                                           S. REPORT DATE
                                                             January  1986
                                                           6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
 K. Wagner,  R.  Wetzel,  et al
                                                           8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
 ORB Associates
 8400 Westpark  Drive
 McLean,  VA   22102
                                                           10. PROGRAM ELEMENT NO.

                                                           CBRD1A
                                                           11. CONTRACT/GRANT NO.

                                                           68-03-3113
 12. SPONSORING AGENCY NAME AND ADDRESS
  Hazardous  Waste Engineering Research Laboratory
  Office  of  Research and Development
  U.S.  Environmental  Protection Agency
  Cincinnati,  Ohio  45268
                                                           13. TYPE OF REPORT AND PERIOD COVERED
                                                           Final  (Nov. 1981-Feb. 1983)
                                                           14 SPONSORING AGENCY CODE
                                                            EPA/600/14
 15. SUPPLEMENTARY NOTES
  Project  Officer:   Anthony N. Tafuri   (201)  321-6604
 16. ABSTRACT
           The  purpose of this research effort was  to  provide technical guidance on
     planning  and  implementing safe and cost-effective response actions applicable  to
     hazardous waste sites containing drums.
           The  manual  provides detailed technical guidance on methods, procedures, and
     equipment suitable for removing drummed wastes.   Information is  included on locating
     buried  drums;  excavation and onsite transfer;  drum staging, opening, and sampling;
     waste consolidation; and temporary storage  and shipping.
           Each of these operations is discussed  in  terms of the equipment and procedures
     used  in carrying out specific activities; health and safety procedures; measures
     for protecting the environment and public welfare; and factors affecting costs.
     Information  is also included on the applications and limitations of the following
     remedial  measures for controlling or containing  migration of wastes:  surface
     capping,  surface water controls, groundwater  pumping, subsurface drains, slurry
     walls,  and in-situ treatment techniques.
           This manual  will  be useful  to On-Scene Coordinators, Federal, state, and
     local officials, and private firms that plan  and implement response actions at
     sites containing drums.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                                                                         c.  COSATI Field/Group
18. DISTRIBUTION STATEMENT
  RELEASE TO PUBLIC
                                              19 SECURITY CLASS (This Report!
                                                UNCLASSIFIED
                                                                          21. NO. OF PAGES
                                              20 SECURITY CLASS (Tins panel
                                               UNCLASSIFIED
                                                                          22 PRICE
EPA form 2220-1 (9-73)

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                                    NOTICE
     This document has been reviewed in accordance with U.S. Environmental
Protection Agency (EPA) policy and approved for publication.  Mention of trade
names or commercial products does not constitute endorsement or recommendation
for use.
                                      11

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                                   FOREWORD
      Today's rapidly developing and changing technologies and industrial
products and practices frequently carry with them the increased generation of
solid and hazardous wastes.  These materials, if improperly dealt with, can
threaten both public health and the environment.  Abandoned waste sites and
accidental releases of toxic and hazardous substances to the environment also
have important environmental and public health implications.  The Hazardous
Waste Engineering Research Laboratory assists in providing an authoritative
and defensible engineering basis for assessing and solving these problems.
Its products support the policies, programs, and regulations of the Environ-
mental Protection Agency, the permitting and other responsibilities of state
and local governments and the needs of both large and small businesses in
handling their wastes responsibly and economically.

      This manual was conceived and developed to provide guidance in the
planning, selection, and implementation of safe and  effective remedial methods
applicable to hazardous waste sites containing drums.  In tandem with the
National Contingency Plan, this manual will provide  guidance to Federal and
state personnel and private firms in developing technically sound, safe, and
cost-effective remedies for sites containing buried  drums or drums stored
aboveground.  For further information, please contact the Land Pollution Con-
trol Division of the Hazardous Waste Engineering Research Laboratory.
                                            David G.  Stephen
                                            Director
                                            Hazardous Waste Engineering
                                            Research  Laboratory
                                     iti

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                                   ABSTRACT


     The purpose of this research effort was  to  provide  technical  guidance on
planning and  implementing  safe and coat-effective  response  actions applicable
to hazardous waste sites containing drums.

     The manual provides detailed technical guidance on  methods, procedures,
and equipment suitable  for removing drummed wastes.  Information is included
on locating buried drums; excavation  and onsite  transfer; drum  staging,
opening, and  sampling; waste consolidation; and  temporary storage  and
shipping.

     Each of  these operations is  discussed in terms of  the  equipment  and
procedures used in carrying out specific activities; health  and safety
procedures; measures  for protecting the environment and  public welfare;  and
factors affecting costs.   Information is also included on the applications and
limitations of the following remedial measures for controlling  or  containing
migration of wastes:  surface capping, surface water controls, groundwater
pumping, subsurface drains, slurry walls, and in-situ  treatment techniques.

     This manual will be useful to on-scene coordinators, Federal, state, and
local officials, and  private firms that plan  and implement  response actions at
sites containing drums.

     This report was  submitted in fulfillment of Contract No. 68-03-3113 by
JRB Associates under  the sponsorship  of the U.S. Environmental Protection
Agency.  This report  covers the period from November 1981 to February  1983, and
work was completed on February 17, 1984.

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                                   CONTENTS
Foreword	    1X1
Abstract	     iv
Figures	    vii
Tables 	     x
Acknowledgement	    xii

    1.  INTRODUCTION	     1

    2.  CONCLUSIONS	     3

    3.  SELECTION OF DRUM HANDLING METHODS	     5
            Engineering Feasibility	     5
            Health and Safety of Field Personnel 	     6
            Protection of the Environment and Public Welfare  	     7
            Costs	     8

    4.  LOCATION, DETECTION, AND INVENTORY OF DRUMS	     29
            Review of Background Data	     29
            Aerial Photography	     30
            Geophysical Surveying	     34
            Sampling	     44
            Preparing a Drum Inventory	     46

    5.  SITE PREPARATION	     51
            Site Access Improvements	     51
            Support Facilities and Structures.-'	     52
            Site Drainage Improvements 	     53

    6.  AIR MONITORING AND INSPECTIONS FOR DETERMINING DRUM INTEGRITY.  .     55
            Introduction 	     55
            Air Monitoring	     56
            Visual Inspections 	  .     66
            Nondestructive Testing Methods 	     66

    7.  EXCAVATION, REMOVAL, AND ONSITE HANDLING OF DRUMS	     68
            Drum Excavation and Removal Equipment	     68
            Accessories for Drum Excavation Equipment	     83
            Selection and Use of Drum Excavation and Removal
            Equipment	     92
            Excavation/Removal Procedures	     98

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                             CONTENTS (continued)


    8.  DRUM STAGING, OPENING, AND SAMPLING	   104
            Staging	   104
            Drum Opening	   107

    9.  WASTE CONSOLIDATION AND RECONTAINERIZATION	   125
            Compatibility Testing	   125
            Testing Composite Samples	   130
            Segregating Wastes Based on Compatible Waste Classes ....   130
            Treatment/Disposal Options 	   130
            Preparation of Liquid Wastes for Final Treatment or
            Disposal	   137
            Preparation of Solid Wastes and Soils for Final Treatment
            or Disposal	   142
            Gas Cylinders	   145
            Lab Packs	   146
            Drum Crushing	   147
            Decontamination	   148

   10.  INTERIM STORAGE AND TRANSPORTATION 	   149
            Storage	   149
            Transportation 	   153

   11.  ONSITE CONTAINMENT OPTIONS FOR BURIED DRUMS	   157
            Selection of Remedial Measures for Control or Containment
            of Wastes	   157

REFERENCES	   165

SELECTED BIBLIOGRAPHY. .	   174

APPENDIX - HAZARDOUS WASTE COMPATIBILITY CHART 	   176
                                      VI

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FIGURES
Figure
1

2


3


4
5
6
7
8
9

10
11
12
13
14
15
16
17
18

Three Dimensional Representation of EM Conductivity Data
Showing Buried Hazardous Materials 	
Continuous, Parallel Lines of Magnetic Gradient over a
Buried Drum Site Defining the Location and Lateral Limits of
Drums 	
Comparison of Ground Penetrating Radar and Metal Detection
Survey Results for Drum-Containing Trenches Located at Picillo
Farms, Coventry, RI 	
Picillo Hazardous Waste Site Layout (Western Trench) 	
Potential Sources of Information on Drum Integrity 	
Front-End Loader Hauling Drums at Waste Site 	


Modified Backhoe (Barrel Grappler) Loading Drums, onto


Barrel Grappler Removing Drums from Pit Excavation 	
Clamshell Bucket for Crane Attachment 	


Liquids and Solids Handling by an Industrial Vacuum Loader . . .



Page

43


43


44
54
56
70
71
73

74
76
77
78
78
81
82
84
87
88
  Vll

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                              FIGURES  (continued)

Figure                                                                     Page

  19      Forklift-Mbunted  Drum Dumper  and  Hoister-Crane Mounted Drum
         Dumper	••    88

  20      Portable  Hydraulic  Drum  Dumper .  .  .	    89

  21      Drum  Sled	    90

  22      Plexiglas  Safety  Shield  on  Cab of Grappler During Overpacking
         Operation	    91

  23      Use of Grappler Attachment  for Overpacking Drums	   101

  24      Use of Forklift Grabber  Attachment  for  Overpacking	   102

  25      Layout for Separate Drum Staging  and  Opening Areas 	   106

  26      Layout for Combined Drum Staging  and  Opening Operation 	   109

•  27      Nonsparking Bung  Wrench	   HO

  28      Manual Drum Deheader	   112

  29      Self-Propelled  Drum Deheader  	   113

  30      Self-Propelled  Drum Deheader  with Support Tower	   114

  31      Drum  Dekinker	   115

  32      Pneumatic Bung  Wrench:   Attachment  to Drum and Remote Operation
         Setup	   116

  33      Hydraulic Backhoe Drum Plunger Arrangement 	  ...   118

  34      Remote Hydraulic  Drum  Plunger Mounted on Drum	   119

  35      Conveyor  Belt  System  for Remote Hydraulic Puncturing of Large
         Number of Drums	   120

  36      Backhoe Spike  (Nonsparking) Puncturing Drum Held by Grappler .  .   121

  37      Tube  and  Spear  Device  Used  for Venting of Swollen Drums	   122

  38      Compatibility Testing  Protocol	   126

  39      Locations of Treatment/Disposal Facilities for PCBs or
         Radioactive Wastes  	   136

  40      Federal PCB Disposal  Regulations 	   138


                                      viii

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                             FIGURES (continued)

                                                                          Page

       Use of Grappler Aim and Compatibility Chamber for Combining
       Compatible Wastes	    139

42     Available Options for Streamline Vacuum Trucks  	    141

43     Combined Handling of Sludges and Contaminated Soils at  the
       Chemical Control Site	    144
                                     IX

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                                    TABLES

Table                                                                     Page

 1A    Engineering Feasibility and Effectiveness of Various Drum
       Handling Methods - Number of Drums	    11

 IB    Engineering Feasibility and Effectiveness of Various Drum
       Handling Methods - Site Accessibility/Location	    13

 1C    Engineering Feasibility and Effectiveness of Various Drum
       Handling Methods - Depth of Burial/Surface Disposal 	    15

 ID    Engineering Feasibility and Effectiveness of Various Drum
       Handling Methods - Hydrogeologic Conditions 	    16

 IE    Engineering Feasibility and Effectiveness of Various Drum
       Handling Methods - Drum Integrity	     17

 IF    Engineering Feasibility and Effectiveness of Various Drum
       Handling Methods - Hazard/Toxicity 	     19

 2     Major Elements of a Site-Specific Safety Plan 	    21

 3     Safety Precautions for Drum Handling	    23

 4     Measures for Minimizing Environmental Releases During Drum
       Handling	    26

 5     Sources for Background Data Related to Drum Handling and
       Disposal.	    31

 6     Summary of Aerial Imagery as a Tool for Locating Drums. .....    33

 7     Summary of Geophysical Survey Methods	    35

 8     Applicability and Limitation of Various Soil Sampling Methods  .  .    47

 9     Drum Inventory Format, Keefe Environmental
       Services Site, Epping, N.H	    48

10     Categorization of Waste Types at the Keefe Environmental
       Services Site Based on Random Sampling of Drums 	    49

11     Estimated Number of Buried Drums at Picillo Farms, RI, Based
       on Extrapolation of Best Available Data	    50

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                              TABLES (continued)

Table                                                                      Page

12     Summary of Direct Reading Air Monitoring Instruments.  ......     58

13     Specific Applications for Air Sample Collection Media  Including
       the Required Laboratory Analysis	     67

14     Drum Excavation/Removal Equipment Capabilities and
       Limitations	     93

15     Effect of Site-Specific Variables on Selection and Use of Drum
       Excavation and Handling Equipment 	  .  	     95

16     Drum/Bulk Data Form	    105

17     Summary Assessment of Drum Opening Techniques  	    123

18     Potential Analytical Requirements for Disposal	    131

19     Major Treatment/Disposal Alternatives for Various Waste Types  .  .    133

20     Liner-Industrial Waste Compatibilities	    151

21     Ranking of Soil Types Based on Percolation Control and
       Resistance to Wind Erosion	    152

22     Considerations for the Selection, Design, and  Implementation
       of Capping and Surface Sealing Techniques 	  .  	    159

23     Considerations for the Selection, Design, and  Implementation
       of Surface Water Controls 	    160

24     Considerations for the Selection, Design, and  Implementation
       of Groundwater Pumping Techniques	 	    161

25     Considerations for the Selection, Design, and  Implementation
       of Subsurface Drainage Systems	    162

26     Considerations for the Selection, Design, and  Implementation
       of Slurry Walls	    163

27     Considerations for the Selection, Design, and  Implementation
       of In-Situ Treatment Techniques 	    164

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                                ACKNOWLEDGEMENT
     This document was prepared for EPA's Hazardous Waste Engineering Research
Laboratory (HWERL) by JRB Associates in partial fulfillment of contract no.
68-03-3113.

     Mr. Anthony Tafuri was the HWERL Project Manager.  Mr. Brint Bixler of
the Office of Emergency and Remedial Response provided many relevant materials
for our review and use.  The help and guidance of Mr. Tafuri and Mr. Bixler
during the preparation of this document is gratefully acknowledged.

     JRB Associates also acknowledges technical assistance from the following
personnel:  the staff of O.H. Materials, Findlay, Ohio, for technical
assistance and review and for providing JRB with several photographs that
appear throughout the report; the Chemical Manufacturer's Association,
Washington, D.C., Norman Franc ingues, Waterways Experiment Station, Vicksburg,
Mississippi, and Mr. Robert Pojasek of Roy F. Weston, Inc., for their tech-
nical review; and Mr. Robert Cibulskis, EPA Environmental Response Team, for
providing JRB with access to video tapes on the cleanup operations at various
sites.

     Additional information was obtained from contacts with the following
companies:  Wizard Drum Tools, Milwaukee, Wisconsin; Peabody Clean Industries,
East Boston, Massachusetts; Environmental Emergency Services Co., Portland,
Oregon; and CECOS International, Niagara Falls, New York.  Their assistance is
gratefully acknowledged.
                                      Xll

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                                  SECTION  1

                                 INTRODUCTION
     The Comprehensive Environmental Response, Compensation and Liability Act
of 1980 (CERCLA) establishes a nationwide program for the cleanup of uncon-
trolled hazardous waste sites.  This program is implemented through pro-
visions of the National Contingency Plan (NCP), 40 CFR Part 300; which sets
forth the process by which response actions will be selected and evaluated.
Such response actions must meet the need for protection of public health,
welfare, and the environment in the most cost-effective manner.  Therefore,
three broad criteria have been established for selecting and evaluating
response actions:  engineering feasibility; costs; and public health,
environmental, and institutional impacts.  The objective of this manual is to
provide technical guidance relative to these criteria on the selection and
implementation of response actions at uncontrolled hazardous waste sites with
drums.                                                                     '

     The need for technical guidance in the area of response actions at
hazardous waste sites with drums has become evident since the establishment
of CERCLA.  The results of a 1982 survey of disposal practices at
uncontrolled waste sites indicated that over 20 percent of the sites have
major drum-related problems (U.S. EPA, 1984a).  Experience has shown that
there are a number of health, safety, and environmental hazards unique to
drum handling operations.  In addition, since the implementation of CERCLA, a
number of removal and remedial actions have been implemented at hazardous
waste sites with drums.  The experience gained from these activities and
presented in this manual will be invaluable for future response actions at
similar sites.

     This manual has been prepared to provide technical guidance to on-scene
coordinators (OSC), Federal, state, and local officials, private firms, and
U.S. Environmental Protection  Agency (EPA)  field personnel.  It present's
procedures and methods  for  planning and implementing cost-effective response
actions applicable to drum  problems requiring one or more of the three
response categories  outlined in the NCP:   removal, surface cleanup, and
subsurface remedial  action.  The major focus of the document is to provide
guidance specific  to the  removal of drummed wastes including such activities
as locating, excavating,  staging,  opening,  and transporting drums, and
consolidating wastes from drums.   Information is also presented on the use of
source control measures   (e.g.,  pumping,  slurry walls, drains) to contain
or control the migration  of  wastes from drums.   The information on source
control measures is  presented  in the form of summary tables with references
because considerable guidance  is available on the design and implementaiton
of these technologies.

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     Recognizing that every site is unique  in  its drum-related  problems,  the
U.S. EPA and the contractors involved in preparing this manual  have  generally
taken the approach of outlining the planning process and  presenting  various
options for handling drums, rather than recommending one  specific  method  that
should be steadfastly followed.  The exception  to this  is when  the appro-
priate regulations [e.g., CESCLA, Resource  Conservation Recovery Act (RCRA),
Department of Transportation (DOT)] require a certain method  or procedure or
when worker safety, public health, or the environment can only  be  adequately
protected by one specific method or procedure.

     Section 3 of the manual draws on more  detailed  information that is
presented throughout Sections 4 through 11  to  provide  summary guidance for
selecting and implementing drum handling methods based  on the following
criteria:
     •  Technical feasibility
     •  Protection of worker health  and  safety
     •  Protection of the environment  and  public  health
     •  Costs.
Section 4 discusses procedures  for detecting,  locating,  and  inventorying
drums—activities that  typically  are  undertaken  as  part  of  the 'preliminary
assessment or remedial  investigation.   Section 5 discusses  site  preparation
activities including measures  for improving  site access, design   and setup of
the various operating areas  and support  facilities  needed for the response
actions, and measures for  improving site  drainage.   Procedures for determining
drum integrity and unsafe contaminant  levels in  and around  drum  handling
activities are considered in Section  6.   Section 7  addresses equipment and
procedures for excavating buried  drums and maneuvering drums onsite.
Equipment and procedures  for staging  and opening drums are  covered in Section
8, and Section 9 discusses  procedures  for consolidating  or  repackaging drum
contents.  Guidance on  interim  storage and transportation is presented in
Section 10.  Section 11 employs a series of  tables  to summarize  the appli-
cability and limitations  of  various remedial techniques  for  controlling or
containing the migration  of  wastes  from drums.  The following remedial
actions are discussed:  surface capping; surface water controls; groundwater
pumping; subsurface drains;  and in-situ treatment methods.

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                                  SECTION  2

                                 CONCLUSIONS


     Response actions involving  the offsite removal  of drummed  wastes  are
unique in many respects from response actions  taken  at other  sites.  As  a
result of associated safety and  environmental  hazards, a  number of
specialized equipment types have been developed  for  handling  drums,  and  a
number of good operating procedures have evolved.

     Much of the equipment used  for drum handling has been  specially adapted
for the safe handling of hazardous wastes.  Where conventional  construction
equipment such as backhoes or  front-end loaders  are  used, they  can be
equipped with piexiglas safety shields or  other  modifications to reduce
potential safety hazards.  For example, nonsparking  bucket  teeth can be  used
to prevent explosions and a "morman bar" can be  used to cover bucket teeth to
prevent drum rupture.  One of  the most significant equipment  modifications is
the flexible barrel grappler,  which consists of  a grapple attachment suitable
for mounting on  a  hydraulic backhoe.   The grapplier can  grab and lift various
sizes of drums from any angle  and relocate them  without manual  assistance.
Remotely operated drum plungers  and debungers  used for drum opening  are  other
important developments.  Another equipment type  for  handling  hazardous
materials is the industrial vacuum (i.e.,  the  Vactor or Supersucker) which
can convert from liquids to solids handling and  can  convey  materials over
substantial distances.

     Procedures and protocols  have been developed for the safe  and efficient
handling of drums.  These methods provide  reasonable precautions to  prevent
drum ruptures, explosions, fires, toxic releases, and contamination  of
groundwater and surface waters.  Some of the more important procedures and
protocols that have evolved include the following:


     o  The site operating areas should be designed  to promote  the most
        efficient and safest operation possible.  The layout  ideally includes
        one or more areas for  staging the drums  and  separate  areas for
        opening drums, consolidating their contents, equipment  decontamina-
        tion, and temporary storage of contaminated  soils and drums.  Within
        each area, measures should be taken to provide secondary containment.
        Such measures should be consistent with  the  types of  hazards posed by
        accidental releases.   Highly hazardous materials  (e.g.,  radioactive
        materials, explosives, and gas cylinders) should'be isolated to  the
        extent possible and placed in separate,  remote staging  or storage
        areas.

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     •  Air monitoring equipment should be used extensively during such
        operations as drum excavation, opening, consolidation, and storage to
        provide an indication of unsafe levels of toxics, explosives, or
        radioactive materials.

     •  Drums with poor integrity should be overpacked or their contents
        transferred as soon as they are identified.

     •  Compatibility testing should be conducted on all drums to determine
        which wastes can be successfully consolidated.  Efforts should be
        made to maximize the consolidation of compatible wastes since this
        provides for the most cost-effective means of transport and disposal.
        Once incompatible waste types have been identified, they should be
        segregated for all subsequent activities (generally consolidation,
        temporary storage, and transportation).

     •  Direct handling of drums should be minimized to the extent practical
        by use of such equipment types as the grappler, remote drum opening
        equipment, and industrial vacuum trucks.


     Drum handling operations can be conducted safely and cost-effectively by
a careful planning process that considers these procedures and others for
protection of health and safety, protection of the environment, and technical
limitations and applications of various equipment types.

     In addition to methods for removing drummed wastes, there are also a
number of source control measures, such as capping, surface water controls,
slurry walls, and groundwater pumping, which are suitable for containing or
controlling migration of wastes from drums.  These measures are not unique to
drum handling but have a much broader applicability for controlling bulk
hazardous waste migrations from landfills, impoundments, etc.  Although they
are summarized in this manual, the U.S. EPA has funded separate studies to
determine the feasibility, design, and.construction of these remedial action
techniques.

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                                  SECTION 3

                      SELECTION OF DRUM HANDLING METHODS


     Selection and detailed design of response actions involving  removal  of
wastes contained in drums is based on four broad technical criteria con-
sistent with the requirements of the NCP.  These  are:


\    •  Engineering feasibility of various equipment types including waste
        and site-specific factors which affect equipment  performance and  any
        inherent limitations of the equipment

     •  Protection of health and safety of field personnel

     •  Protection of the environment and public welfare

     •  Costs.
Each of these criteria are dealt with in considerable detail  in Sections 4
through 10 of this report in relation to specific drum handling activities
(e.g., excavation, opening, consolidation, etc.). This section draws on the
detailed information presented throughout these  sections  and  summarizes the
data by classifying  them under the four broad criteria listed above.


ENGINEERING FEASIBILITY

     A variety of procedures, equipment types, and equipment  modifications
have been used to respond Co various conditions  found at  uncontrolled waste
sites.  A number of  factors go into the selection of equipment for  a
particular response  action.  The selection process considers  site and waste
characteristics that limit the feasibility and effectiveness  of various
equipment types and  drum handling methods as well as the  performance record
and the inherent operation and maintenance problem of the equipment.  The
engineering feasibility of various equipment and procedures can best be
judged in terms of the following factors:


     •  Number of drums  (Table 1A)

     •  Site accessibility/location (Table IB)

     •  Depth of burial/surface disposal (Table  1C)

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        Hydrogeologic conditions (Table ID)

        Drum integrity (Table IE)

        Hazard/toxicity of the drum's contents (Table IF).
Tables 1A through IF, at the end of this section, summarize the use of
various equipment and methods for handling drums under these various
conditions.
HEALTH AND SAFETY OF FIELD PERSONNEL

     The U.S. EPA and the Occupational Safety and Health Administration
(OSHA) have published extensive guidelines on health and safety procedures
applicable to the cleanup of uncontrolled hazardous waste sites.   Since  this
guidance is already available, it will not be covered in this report.
Procedures for field health and safety should be consistent with  the
following guidance :


     •  Comprehensive Environmental Response, Compensation and Liability Act
        (CERCLA) Section lll(c)(6)

     •  EPA Order 1440.2 - Health and Safety Requirements for Employees
        Engaged in Field Activities

     •  EPA Order 1440. 13 - Respiratory Protection

     •  EPA Occupational Health and Safety Manual (U.S. EPA, 1980)

     •  EPA Interim Standard Operating Safety Guide (U.S. EPA, September
        __
     •  Applicable OSHA Standards.


     The field health and safety procedures should be detailed  in  a site-
specific plan that addresses the elements shown in Table  2, at  the end  of
this section, (based on Buecker and Bradford, 1982).  In  addition, the  plan
should address health and safety procedures and protocols  that  are unique  to
drum handling operations.  These measures, summarized in  Table  3,  include  the
use of specialized equipment adapted  for the  safe handling of drums,  such  as
remotely operated drum-opening equipment, as  well as good safety practices,
such as the prompt isolation of potentially explosive or  radioactive  wastes.

     In addition to health and safety procedures, a site-specific  spill
contingency plan should also be developed.  The plan should outline
procedures /act ions to be followed  in  the event of an emergency  condition,

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starting with the occurrence of a spill, and defining real-time responsibili-
ties and procedures for the following types of emergencies:


     •  Fires and explosions
     •  Major spills

     •  Medical emergencies
     •  Weather extremes
     •  Civil disobedience/unauthorized site entry.


The contingency plan should accomplish the following objectives:


     •  Identify scenarios that could lead to an emergency (e.g., explosion
        of containers of shock-, pressure-, or heat-sensitive materials;
        equipment rollover or cave-ins; chain reactions resulting in  an
        explosion or fire; etc.)

     •  Outline procedures for various types of emergencies

     •  List the response team organization and responsibilities including
        cleanup contractors, local authorities, and  services (e.g., fire,
        police, health services), OSC, and State or EPA officials.


PROTECTION OF THE ENVIRONMENT AND PUBLIC WELFARE

     There are numerous tools or measures available  for minimizing environ-
mental releases during drum handling.  These tools or measures can be divided
into two broad categories:


     1.  Measures that prevent environmental releases, such as overpacking or
         pumping the contents of leaking drums

     2.  Tools that mitigate or contain spills once  they have occurred,  such
         as perimeter dikes.


Mitigative or containment measures generally include low-cost, easy-to-
implament techniques such as the use of dikes and plastic liners to contain
spills in work areas.   A Spills Control and Contingency Plan, prepared  as
part of the Remedial Design, should outline specific measures for mitigating
and containing spills.

     The selection of tools or measures to minimize  environmental releases
depends upon the extent to which the site has already been degraded,  the
proximity of surrounding populations, the potential  for contamination of
groundwater and surface water, and cost impacts.

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      Table 4  summarizes  preventive and  mitigative measures  for controlling
 environmental  releases during  drum handling.

 COSTS

      Costs consist  of all  financial  (cash)  outlays required  to implement  a
 response  action,  including:  engineering, design,  installation,  and  capital
 outlays;  and  other  costs,  as appropriate.   Remedial  action costs can range
 from  as low as  $60/drum  to as much as $1500/drum  or more  (U.S. EPA,  1984a).
 This  wide range is  the result  of  site-specific  requirements, waste  types,
 number of drums,  drum condition,  and transportation  and disposal costs.

      Costs associated with remedial  actions involving  drum handling  can be
 grouped into  four categories based on the activities conducted.


      •  Worker health and  safety

      •  Excavation

      •  Containerization (overpacking)

      •  Remov al/transport.


 Because of the variability between  sites, it  is difficult to assign  a
 specific  cost or range of costs to these activities.   The interrelationship
 of these  activities in all phases  of cleanup  operations preclude isolation of
 the cost  impact of  each  element.   However, general guidelines  can be provided
 for each  category as to  its impact on the total cost of cleanup.

      To ensure adequate worker protection it  is necessary to test and  assess
 the potential hazards at the site  and establish the appropriate  protection
 levels.   The safety equipment required  for a  particular level  of protection
 (e.g., level A, B,  C, etc.) will have an impact on the project cost.  How-
 ever, the cost of protective equipment,  is secondary to the cost  associated
 with  the  increase in time required for  workers to  complete activities  using
 protection levels A or B.  Under these  conditions, worker mobility is
 drastically reduced, requiring additional time to  accomplish even simple
 tasks.

     Excavation costs include equipment rental/lease and mobilization, and
operator  time.  Costs can be minimized by selecting the appropriate  equipment
 for the job based on site-specific conditions.  When specialized equipment is
 necessary to handle unusual problems, costs will  increase; standard  types  of
 equipment (e.g., backhoe, forklift, etc.) generally incur lower  costs.
Mobilization of excavation equipment will also add to  the remedial action
cost.  However, job size does not  significantly affect this cost.  Some
 studies of remedial actions (U.S. EPA,  1984a) indicate that the  excavation of
 drums does not add  significantly to the cost  of a  remedial action.   This
 suggests  that the added cost of excavation equipment is less significant than
other cost items such as treatment or protective equipment necessary for high
 risk  sites.

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     At sites requiring overpacking or recontainerization of wastes, many
specialized service costs may be incurred in addition to the•purchase of
containers for overpacking.  Where drums are extensively damaged or wastes
are leaking onto the surface, vacuum systems may be necessary to collect and
contain the waste.  This type of response action usually results in addi-
tional costs for crushing and emptying the original drums after their con-
tents have been removed.  The drum size required for overpacking will also
affect the cost.  For example, overpacking 30-gallon drums requires a
55-gallon overpack, while overpacking 55-gallon drums requires an 80-gallon
overpack.  The impact of overpacking costs on overall response costs may be
highly variable.

     Costs for removal and transport usually have a significant impact  on
total remedial action costs.  These costs are extremely variable depending on
the waste type, distance to an acceptable disposal site, drum size  and  condi-
tion , drum location, and personnel protective equipment required for safe
handling.  In addition, careful management of the more hazardous waste  types
increases the time necessary for the various elements of the operation  (e.g.,
labor and equipment).  It should be determined on a site-specific basis
whether bulking is feasible.  This procedure can significantly reduce removal
and transportation costs compared to costs assciated with handling  individual
drums.  Elements of the transport and removal cost are also reflected in the
previous discussion of site cost activities (i.e., worker safety, excavation,
containerization).

     Throughout the four activities, economies of scale will affect the total
cost per drum.  There is generally a direct relationship between the total
site costs and the number of drums involved and an inverse relationship
between the total site costs and the unit cost per drum.  Certain minimum
costs, however, are also generally charged for component tasks independent of
the size of the effort such as mobilization of technicians and equipment or
transportation.  Associated costs can be minimized by the selection of  the
most cost-effective contractor and equipment types and by effective
management of the cleanup operation.

     The following list presents several monetary costs that should be
considered and quantified, when possible, during a cost-effective analysis:


     •  Potential outlays including related administrative costs to obtain
        necessary permits, licenses, etc.

     •  Engineering expenses, such as technical services related to sampling,
        testing, designing, managing, and reviewing the remedial measure

     •  Land-related expenses for the rental or purchase of rights-of-way and
        easements, as well as expenditures for land/site preparation

     •  Construction costs including direct outlays for equipment, hardware,
        and materials

     •  Costs for disposing of wastes at an approved off-site facility

-------
     •  Startup costs comprising operator training, temporary professional
        services, additional testing, monitoring, process controls, and
        equipment or materials transport costs

     •  Labor costs including all payments for wages, salaries, training,
        overhead, and fringe benefits to workers employed at the  site.


     In selecting the appropriate contractor or equipment, the  following
points should be considered:


     •  Length of contractor's work day—by specifying that equipment operate
        for 12 hours rather than 8 hours, the cost of equipment downtime can
        be minimized

,     •  Contractor's performance record with proposed equipment/methods

     •  Equipment efficiency under specific site conditions

     •  Equipment dispatching time (transport and setup)

     •  The extent to which a piece of equipment can perform several
        functions thereby minimizing idle time and costs for equipment
        mobilization

     •  The ability of one contractor to handle the entire cleanup operation

     •  The location of potential treatment and disposal facilities and their
        cost per volume of waste.


Once the contractor is selected, additional cost savings can be made by close
management of the cleanup operation.

     A project schedule and cost estimate for each cleanup activity should
be outlined in the Remedial Design.  These guidelines provide reasonable
assurance of completing the cleanup within the specified time and budget.
However, they are subject to change as cleanup reveals additional information
about the number of drums, their contents, and their  integrity.  A schedule
of project milestones provides some guidance for scheduling certain pieces  of
equipment or certain contractors at the  site, thereby minimizing  the  amount
of idle time for equipment and field personnel.

     In addition, when the time  and costs for a particular activity exceed
that which was planned, it may be possible to modify  the approach for
subsequent activities to maintain costs  without sacrificing worker safety or
protection of sensitive environmental areas.
                                       10

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    TABLE 1A.   ENGINEERING  FEASIBILITY AND EFFECTIVENESS  OF VARIOUS DRUM HANDLING METHODS
                                                 NUMBER OF DRUMS
    LOCATION AND INVENTORY

Expenditures for remote sensing
must be kept in perspective;  if
the number of buried drums  it
snail, uae a simple remote
sensing tool (i.e., metal
detector) to locate drums;
may not be worth the expense
to quantify; hand-held  tools
are suitable for small  sites,
whereas vehicle-towed equip-
ment is sometimes needed  at
large sites

A random sampling of drums  above-
ground may Involve 5 to  25 percent
of the drums depending  upon the
total number of drums as  well  as
their hazard and accessibility
          EXCAVATION

For large numbers of drums use highly
mobile, high-productiop equipment  (i.e.,
backhoes, grapplers, rubber tired
loaders, industrial vacuums);
several equipment types can be
employed economically at sites with
over 1000 drums

For small sites «500 drums) use
versatile equipment such as combined
backhoe-front-end loader and limit
number of vehicles onsite
        DRUM STAGING

•  High-production equipment
   (grappler, front-end loader)
   should be used for staging
   and transferring large  numbers
   of drums

•  Where there are a large number
   of drums, staging and opening
   the drums in shifts should  be
   considered if spacing is
   inadequate

•  If the number of drums  is  very
   large, it may be necessary  to
   stage and open the drums in
   the same area; when this is the
   case, drums should be staged
   with adequate space between
   aisles to allow access  of
   remote opening equipment and
   adequate apace between  drums
   to prevent chain reactions  in
   the event of fire or explosion
                                                                                                         (continued)

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                                            TABLE  1A.   (continued)
                                                  NUMBER OF DRUMS
     DRUM OPENING

For large numbers O500) of
drums, a backlioe plunger
or a remote conveyor should be
considered for drum opening

For small numbers of drums,
hand tools can be considered
depending on conditions of
drums and drum contents
 COHSOLIPAT10N/RECONTAIKERIZATION

Where large numbers of compatible
liquid wastes are present, their
contents can usually be bulked
rather Khan shipping the drums
individually.  Large capacity
vacuum equipment is generally
preferred over skid-mounted units
providing these vehicles have
access to the site

On site treatment options should
be considered for a large number of
drums

Drum crushers or shredders are gen-
erally used when large numbers of
empty drums are present.  If the
number of empty drums is few, back-
hoes and loaders can be used for
crushing

Solids are generally shipped in DOT
approved drums although they can be
shipped in bulk along with heavily
contaminated soils, depending upon
the requirements of the disposal
facility
INTERIM STORAGE AND TRANSPORTATION

•  State transportation requirements
   must be consulted to determine
   the number of drums and volume of
   liquid that can be transported
   in a load

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                   TABLE IB.   ENGINEERING  FEASIBILITY  AND  EFFECTIVENESS  OF  VARIOUS  DRUM HANDLING METHODS
                                                          SITE  ACCESSIBILITY/LOCATION
U)
       LOCATION AND INVENTORY

•  Remote wooded site may require
   that geophysical surveying  be
   done manually rather than by
   vehicle; clearing and grubbing
   may be needed to conduct
   continuous surveys

•  Certain cultural features
   commonly present in congested
   or populated areas can inter-
   fere with geophysical surveying
   (i.e., fencing, buried
   utilities, passing cars); the
   fluxgate gradiometer is
   least sensitive to such
   interferences

•  Preparing an inventory of drums
   aboveground can be hazardous
   if the site is congested.
   Minimize hazards by (1) staging
   drums for opening, (2) using
   remote opening equipment, and
   (3) keeping random sampling to
   a minimum
          EXCAVATION

Remote sites may require special
site preparation, such as clearing
and grubbing for easier access, and
may dictate use of fewer, larger
equipment types (backhoes, grapplers,
crawlers, tractors, cranes)

For readily accessible sites, equip-
ment size and number are not limited;
favors mobile rubber-tired vehicles
(bobcats and backhoes)

For congested, urban sites, may need
smaller machinery (forklifts and
loaders) for lifting and transfer;
may also use hoists or slings to
lift drums from congested areas

Cranes and draglines may be used if
a particularly long reach is
required to lift drums in a
congested area
     DRUM STAGING

Where adequate space is avail-
able, drum staging should be
segregated from drum opening

If site is congested, drums
may be staged, opened, and
sampled in shifts to provide
adequate work space; alter-
natively, drums may be staged
and opened in the same work
area; in a combined staging
and opening area, drums should
be staged so there is ade-
quate space between drums to
minimize a chain reaction in
the event of a fire or
explosion and adequate space
between rows to allow access
to drums by remote opening
equipment
                                                                                                                       (continued)

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                                            TABLE IB.   (Continued)
                                            SITE  ACCESSIBILITY/LOCATION
     DRUM OPENING

See preceding discussion on
staging
 CONSOLIDATION/RECONTAINERIZATION

Skid-mounted vacuum units may be
needed for waste consolidation
in inaccessible areas

Location of the site with respect
to treatment/disposal facilities
should be considered prior to
consolidation/recontainerization

Onsite treatment of wastes and
soils can be a viable option,
particularly if the site ia not
in a populated area; detonation
of lab packs onsite should only
be considered if the site is
remote
INTERIM STORAGE AND TRANSPORTATION

•  Storage area should be as
   distant as possible from popu-
   lated areas; reactives and
   explosives should he stored
   away from buildings

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         TABLE  1C.   ENGINEERING FEASIBILITY  AND  EFFECTIVENESS  OF VARIOUS DRUM HANDLING METHODS
                                           DEPTH OF BURIAL/SURFACE DISPOSAL
       LOCATION AND INVENTORY

   Geophysical surveying  is  used
   to determine depth of  burial;
   metal detectors are suitable
   for locating shallow drums;
   magnetouetry, electrical
   conductivity, and resistivity
   can detect drums to consider-
   able depths

   Preparation of a drun  inventory
   nay be limited to drums above-
   ground; however, geophysical
   surveying can be used  to  obtain
   a rough approximation  of  the
   number of drums
             EXCAVATION

   Excavation of buried drums requires
   use of backhoe, grappler,  etc.;  drumt
   buried deeper than about  10 meters
   (30 feet) may require use  of a crane
   or dragline or the excavation of a
   "working platform" parallel to the
   trench or  pit; backhoe or front-end
   loaders can be used for excavation
   of very shallow drums
        DRUM STAGING
•  Not applicable
        DRUM OPENING
                                          CONSOLIDATION/RECONTAINERIZATION
                                                                                  INTERIM STORAGE AND TRANSPORTATION
•  Not Applicable
•  Not  Applicable
                                                                                  •  Not Applicable

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      TABLE  ID.  ENGINEERING FEASIBILITY  AND  EFFECTIVENESS  OF  VARIOUS  DRUM  HANDLING  METHODS
                                            HYDROGEOLOGIC CONDITIONS
    LOCATION AND INVENTORY

Presence of a high water table
may prevent use of a vehicle
to tow remote sensing
equipment

Where groundwater is saline,
ground-penetrating radar,
electromagnetics, and
electrical resistivity may
be ineffective

Complex stratigraphy can make
interpretation of resistivity
and seismic refraction
data very complex

Ground-penetrating radar may
be ineffective in clay soils
          EXCAVATION

Water-logged sites may require
surface runoff diversion with
trenches and berms to improve
drainage; wet, muddy sites favor
equipment mounted with good
flotation tires or crawler-
mounted vehicles; swamp pads
(extra-wide crawler tracks);
and timber mats may also be
useful

For dry sites, less site
preparation is needed and
mobile, rubber-tired vehicles
can be used
        DRUM STAGING

   If the site is in an area with
   high water table, drums  can be
   staged on pallets, flatbed
   trucks, or in diked, elevated
   areas to prevent contact with
   water
     DRUM OPENING

Drum opening area should  be
diked and lined, particularly
in an area with a high water
table
 CONSOLIDATION/RECONTAINERIZATION

High water table may limit  access
of vacuum equipment and box
trailers; skid-mounted units may
be better suited than vacuum
trucks
INTERIM STORAGE AMP TRANSPORTATION

•  Drums stored temporarily onaite
   should not be in contact with
   standing water; if the  water
   table is high, construct the
   storage area on the highest
   ground possible; build  dikes
   and diversions to control  and
   collect runoff and improve
   drainage; use sump pumps to
   remove standing water;  store
   drums on pallets.

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     TABLE IE.   ENGINEERING FEASIBILITY  AND  EFFECTIVENESS OF  VARIOUS  DRUM HANDLING METHODS
                                                 DRUM  INTEGRITY
    LOCATION AND INVENTORY

If buried drums are leaking,  it
may be difficult to distinguish
between drums and the  plume
using the following geophysical
techniques:   electromagnetic
conductivity, electrical
resistivity, and ground-
penetrating  radar; magnetometry
and metal detectors should be
used to confirm location  of
drums

If poor drum integrity is
encountered  during the inventory
of drums, the following precau-
tions may be needed:  (1) staging
of drums for random sampling;
(2) using remotely operated  drum
opening equipment; (3) using air
monitoring equipment extensively
to monitor worker safety
          EXCAVATION

Corroded or leaking drums may require
immediate overpacking or waste trans-
fer prior to excavation; where the
grappler is available it may be
possible to 'risk rupture of the drum
to protect worker safety

Use of the grappler is preferred for
overpacking; forklift trucks equipped
with grabbers can be used but require
manual assistance, which jeopardizes
worker safety

Equipment adaptations such as the
use of mono an bars to cover the
bucket teeth or wide canvas slings
that can be wrapped around a drum
can minimize drum ruptures

Drums should be excavated and
removed one at a time, especially
if integrity is questionable

Small excavation equipment (with
plexiglas shields) such as front-
end loaders and bobcats can be
used if drum integrity is good
and hazard is low
     DRUM STAGING

Overpack or transfer the contents
of drums with poor integrity;
waste transfer requires  use  of
explosion- and acid-proof pumps;
overpacking should preferably be
done using the grappler; forklift
trucks can also be used  but
require manual assistance, which
can jeopardize worker safety
                                                                                                         (continued)

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                                           TABLE  IE.   (continued)
                                                  DRUM INTEGRITY
       DRUM OPENING

All drums with poor integrity
should be overpacked or their
contents transferred prior
to opening

The drum opening area should be
lined and contained with dikes
or benns; spill containment
pans can also be placed
under the drums
   COHSOLIDATIOH/RECONTAIHERIZATION

Waste containers for offsite
transport must meet DOT approval

Fibre drums are suitable for
onsite incineration
INTERIM STORAGE AND TRANSPORTATION

 Drums approved for shipment
 must  have good integrity; no
 signs of corrosion, bulging,
 etc .

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       TABLE  IF.  ENGINEERING FEASIBILITY AND EFFECTIVENESS  OF VARIOUS DRUM HANDLING  METHODS
                                                     HAZARD/TOXICITY
       LOCATION AND INVENTORY

•  If explosives or shock-sensitive
   drums are buried close to the
   surface, geophysical surveying
   using a vehicle-mounted instru-
   ment should not be undertaken;
   surveying may be limited to
   station-by-station monitoring

•  Suspected explosives or shock-
   sensitive drums should only be
   sampled remotely, and pre-
   cautions should be taken to
   prevent a chain reaction in the
   event of a fire or explosion;
   if highly hazardous wastes are
   being sampled as part of the
   drum inventory, adequate spacing
   should be provided for
   emergency evacuation
             EXCAVATION

•, Radioactive wastes should be over-
   packed before excavating

•  Explosive and shock-sensitive wastes
   should be handled remotely wherever
   possible

•  Critically over-pressurized drums
   should be relieved remotely prior
   to excavating

•  Gas cylinders should be excavated
   cautiously, avoiding dragging or
   striking them

•  Potentially explosive or flammable
   wastes require use of non-
   sparking buckets and tools
        DRUM STAGING

•  A grappler should be used for
   staging explosive- and shock-
   sensitive materials

•  Front-end loaders, bobcats,  and
   forklift trucks can be used  for
   onsite transfer and staging  of
   wastes that are not highly
   hazardous

•  Stage radioactive and explosive
   materials in separate fenced
   areas

•  Stage gas cylinders in cool,
   shaded areas
        DRUM OPENING

•  Exp'foaive and shock sensitive
   drums should be opened remotely,
   in a controlled area.   The
   opening area should be
   physically separate from other
   working areas to avoid a chain
   reaction in the event  of a fire
   or explosion
    CONSOLIDATION/RECONTA1NERIZATION

•  Compatibility testing is required
   on all drums to determine which
   materials can be safely bulked

•  Vacuum trucks used for trans-
   porting liquids should be
   dedicated as much as possible to
   hauling one specific type of
   waste.  This practice will
   minimize decontamination costs
INTERIM STORAGE AND TRANSPORTATION

•  Incompatible waste types must  be
   segregated during interim
   storage, using dikes and berms,
   and cannot be transported
   together
                                                                                                             (continued)

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                                                         TABLE  IF.   (continued)
                                                                HAZARD/TOXIC1TY
N)
o
                   DRUM OPENING
                   (centinued)

              A remote drum opener is
              recommended for all hazardous
              or highly toxic wastes

              Where manual drum opening
              tools are used, they should be
              nonsparking
 CONSOUDATION/RECONTAINEKIZATION
            (cont inned)

The lining or coating of vacuum
cylinders must be compatible with
specific waste types

Highly toxic/hazardous wastes
should not be bulked with other
materials where this will create
an off-specification lot unsuitable
for treatment/disposal

Certain wastes may require onsite
pretreatment to make them
acceptable for transport (e>8*>
solidification of sludges,
neutralization, reduction of
flash point)

In some instances, incompatible
waste types (  e.g., acids and
bases) can be combined onsite.
This must be done in a controlled
environment (e.g., reaction tank)
INTERIM STORAfiE AND TRANSPORTATION
          (cont in tied)

•  Special precautions are required
   for interim storage of some
   highly hazardous wastes (  e.g.,
   storage of explosives in
   fences areas; gas cylinders in
   cool shaded areas; reactive
   and explosive waste away from
   bui Idings)

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           TABLE 2.   MAJOR ELEMENTS OF A SITE-SPECIFIC SAFETY PLAN
Major Element
Specific Considerations
         Comment a
Applicability
Responsibilities
Site Description
Levels of
Protection
Air Monitoring
Personnel/Equipment
Decontamination
   site personnel
   contractors
   government agencies
   visitors

   definition of roles
   organization hierarchy
   site supervision
   government liaison
   safety supervision
   public relations
   responsibilities

   define contaminant
   boundaries
   define services,
   materials, and equip-
   ment within hot,
   transition, and
   clean zones

   describe protective
   clothing and
   respiratory gear,
   equipment operators,
   and ancillary
   personnel
   types of equipment
   by zone
   procedures for
   monitoring during
   specific activities
   offsite monitoring

   procedures for
   specific  types of
   contaminants
   sequence of  procedures
   manpower support
Accommodate rotating
supervisory personnel
Consider space constraints,
equipment transportation
access, weather variables,
security, and emergency
response
Consider exposure
potential; job function;
work stations by zone;
level of site activity
Allow for modifications
and input from air
monitoring results

Consider instrument
selectivity & sensitivity;
monitoring location;
frequency; duration;
recordkeeping; worst
case scenarios

Consider reuse and storage
of gear; wet/dry decon-
tamination; discharge of
contaminated wash water;
frequency of use
                                                                  (continued)
                                      21

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                             TABLE 2.(continued)
Major Element
Specific Considerations
         Comments
Operations safety
Emergency
Evacuation
   equipment operation
   use of specially adapted
   equipment/tooIs for safe
   handling of drums
   health monitoring and
   first aid
   weather conditions
   incident logs
   safety meeting
   buddy system
   procedures and protocols
   to minimize potential
   for reactions, fires,
   explosions, etc.

   procedures for onsite
   personnel and public
   levels of response
   notification procedures
   communications
   rescue techniques
   emergency transportation
Consider worst case
and likely events
Adapted from Buecker and Bradford, 1982 with permission of Hazardous
Materials Control Research Institute, Silver Spring, MD.
                                      22

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                                                 TABLE  3.    SAFETY  PRECAUTIONS FOR DRUM HANDLING
            Drum Handling Activity
            Locating  and Inventory
            of  Drums
N)
LO
           Determining Drum
           Integrity
      Potential  Safety Hazard
                                                                                                            Safety Precaution!
Unknown location and contents  of        •   Carefully review background data pertaining to the location and lypt-8
drums can lead to unsuspected  hazards      of  wastes onsite.
                                             •
                                       •   Conduct  soil  and groundwater sampling only after the geophysical survey
                                          is  completed  to minimize the possibility of puncturing drums

                                       •   During the random  sampling of drums, which may he required for an
                                          inventory, spacing between drums should be adequate to allow for
                                          emergency evacuation  if needed

                                       •   Use remotely  operated, nonsparktng tools for random sampling whenever
                                          possible
The process of visual  inspections
requires close contact  with  drums
of unknown content
                                                                      •  Use direct-reading, air monitoring equipment  to detect hot spots where
                                                                         contauination may pose a risk to worker  safety

                                                                      •  Approach drums cautiously,  relying on  air monitoring equipment to
                                                                         indicate levels of hazards  that  require  withdrawal  from  the working
                                                                         area or use of additional  safety equipment

                                                                      •  Any drun that is critically swollen should  not be approached; it should
                                                                         be isolated using a barricade until  the  pressure can be  relieved
                                                                         remoteIy

                                                                      •  Use of the grappler or other remotely  operated equipment can eliminate
                                                                         the need for determining drisn integrity  prior to excavation provided
                                                                         rupture of the drum will not result in fire or unacceptable
                                                                         environmental  impact

Drum Excavation and Handling    Exposure to toxic/hazardous vapors,    •  Where buried drums are suspected,  conduct a geophysical  survey befoie
                               rupture of drums                          using any construction equipment  in order to minimize the possibility
                                                                         of rupture

                                                                      •  Use the drum grappler  where possible and cost-effective  to mininite
                                                                         close contact  with the drima
                                                                                 •  If the grappler is not available, ptunp or overpack drums  of  poor
                                                                                    integrity prior to excavation

                                                                                 •  Ground equipment prior to transferring wastes to new drum
                                                                                                                                                (continue*!!

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                                                                      TABLE  3. (continued)
          DRUM HANDLING ACTIVITY
                                                POTENTIAL SAFETY HAZARD
                                                                                                            SAFETY PRECAUTIONS
          Drum Excavation and
           Handling (continued)
N>
                                       •  Use nonsparking hand tools and nonsparking bucket teeth on excavation
                                         equipment

                                       •  Where  slings, yokes, or other accessories must be used, workers should
                                         back away  from the work area after attaching the accessory and before
                                         the drum  is  lifted

                                       •  Critically swollen drums should not be handled until pressure can be
                                         relieved

                                       •  Use plexiglas shields on vehicle cabs

                                       •  Use "morman  bars," which fit over the teeth of excavation buckets, to
                                         prevent drum puncture

                                       •  Where  ionizing levels of radiation are detected, the safety officer
                                         should be  contacted; generally, the drim should be overpacked and
                                         isolated  promptly

                                       •  Gas cylinders should not be dragged during handling

                                       •  Where  explosive or shock-sensitive material is suspected, every effort
                                         should be  made to handle the drum remotely

                                       •  Use direct-reading, air monitoring equipment when in close proximity to
                                         drums  to detect any hot spots
          Drum  Staging  and  Opening
Release of  toxic,  hazardous vapors,
rupture of  drums
                                                                                    Stage gas cylinders in a cool,  shaded  area
                                                                                 •  Stage potentially explosive or shock-sensitive wastes  in  a  diked,
                                                                                    fenced area

                                                                                 •  Use remote drum opening methods where drums are unsound

                                                                                 •  Conduct remotely operated drim opening from behind  a barricade  or
                                                                                    behind a plexiglas shield if backhoe-mounted puncture  is  being  used

                                                                                 •  Isolate drum opening from staging and other activities  if possible to
                                                                                    prevent a chain reaction if an explosion or reaction does occur

                                                                                 •  If drim opening cannot  be isolated from staging, drums  should be  staged
                                                                                    so as to (1) minimize the possibility of chain reactions  in the event
                                                                                    of a fire or explosion  and (2) provide adequate space  for emergency
                                                                                    evacuat ion

                                                                                         —~   '                                 (continue,!)

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                                                                      TABLE  3. (continued)
            DRUM HANDLING ACTIVITY
            Drum Staging ami
             Opening (continued)
                                                  PUCKNTIAI. SAFKTY HAZARD
                                                                                                             SAFETY PRhCAllTIONS
                                       •  Use only nonsparking  hand  tools if drums  are  to  be  opened manually


                                       •  Remot«ly rel ieve the  pressure  of critically swollen drums before
                                          opening

                                       •  Clean up spills promptly lo minimize mixing of  incompatible materials
ro
Ul
            Consolidation and
             Recontainerizalion
Hixing of incompatible wastes
            Interim Storage and
            Transportation
Mixing of incompatible wastes
•  Perform onaite compatibility testing on all  drums

•  Segregate wastes according to cmnp.il ih i I i ty  class following
   compatibility testing

•  Clean up spills promptly to avoid mixing of  incompatible wastes

•  Intentional mixing of incompatible wastes such as acids and  bases
   sliould be performed under controlled conditions in a reaction tank
   where temperature and vapor release can be monitored

•  Monitor for  incompatible reactions during consolidation using direct-
   reading air monitoring equipment

•  Segregate incompatible wastes using dikes during interim stoiage


•  Maintain a weekly inspection schedule

•  Allow adequate aisle space between drums to  allow rapid exit of winkers
   in case of emergency

•  Keep explosives and gas cyl inilprs in  a rnnl , shaded or roofed area

•  Prevent contact of water reactive wastes with water

•  Clean up spills or leaks promptly

•  Have fire fighting equipment readily available within the storaRe area

•  Knsure adherence to DOT regulations regarding transport of  im omp
-------
                      TABLE  4.   MEASURES FOR MINIMIZING  ENVIRONMENTAL RELEASES  DURING  DRUM  HANDLING
               POTENTIAL ENVIRONMENTAL
                       PROBLEM
                                                                              PREVENTIVE MEASURES
           Groundwater Contamination
a*
Construct a system of dikes and trenches  around  the  site or  around specific
work areas to improve site drainage  and minimize  runoff

Where groundvater is an important  drinking  water  source, it  may be necessary
to hydrologically isolate the work area using  well-point dewatering. (Limited
to highly sensitive environments)

Construct a concrete or asphalt pad  with  gravity  collection  system and simp
for equipment decontamination

Use liners to prevent leaching of  spilled material  into groundwater during
drum handling and drum opening, use  spill containment  pans during drum
opening

Use sorbents or vacuum equipment throughout  the operation to clean up spills
promptly

Maintain overpacks at strategic locations in work areas and  on the access
road to be used for  prompt cleanup of  spills

Locate temporary storage area on the highest ground  area available; install
an impervious liner  in the storage area and  a  dike around the perimeter of
the area; utilize a  sump pump to promptly remove  spills and  rainwater from
the storage area for proper handling

Promptly overpack or transfer the  contents  of  leaking  drums  prior to
excavation in order  to prevent ruptures.
                                                                                                                      (cont inued)

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                                               TABLE  4.  (continued)
    POTENTIAL ENVIRONMENTAL
            PROBLEM
Surface Water Contamination
Air Pollution
                                                                    PREVENTIVE  MEASURES
•  Construct dikes around the rtriim dandling ami storage areas

•  Construct a holding pond downs I ope of the site- to contain contaminated
   runoff

•  Use sorbents or vacuum equipment throughout I he operation to catch spills as
   they occur

•  Design the dikes for temporary storage area to contain a minimum of 10 per-
   cent of the total  waste volume;  ensure that holding rapacity of storage an-a
   is not exceeded by utilizing a sump pump to promptly remove spills and
   rainwater

•  Avoid uncontrolled mixing of incompatible wastes by (I) handling only one
   drum at a time during excavation and (2) isolating drum opening operation
   from staging and working areas

•  Avoid dragging or  striking gas cylinders
                        •

•  Promptly reseat drums following sampling

•  Promptly overpack  or transfer the contents of any drum that is leaking or
   prone to rupture or leaking

•  Use vacium units that are equipped with vapor scrubbers

•  Where incompatible wastes are intentionally mixed (i.e., acids and bases for
   neutralization) in a "compatibility chamber" or tank, releases of vapors ran
   be minimized by covering the tank

•  Use small laboratory scrubbers during drum opening.

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                                                           TABLE 4.  (continued)
                POTENTIAL ENVIRONMENTAL
                        PROBLEM
                            PREVENTIVE MEASURES
            Fire Protection
00
•  Use nonaparking hand tools, drum-opening tools, and explosion-proof pumps
   when handling flammable, explosive, or unknown waste

•  Avoid uncontrolled nixing of incompatible waste by (I)  handling  only one drum
   at a time, (2) pumping or overpacking drums with poor  integrity,  (3)
   isolating drum opening, and (4) conducting compatability testing  of all drums

•  Use sand, foams, etc., to suppress small fires before  they spread

•  Avoid dragging or striking gas cylinders

•  Avoid storage of explosives or reactive wastes in the  vicinity of buildings

•  In a confined area, reduce concentration of explosives by venting to the
   atmosphere

•  Cover drums that are known to be water reactive

•  Properly ground equipment

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                                  SECTION 4

                 LOCATION, DETECTION, AND INVENTORY OF DRUMS


     The activities described in this section are undertaken either  as part
of the preliminary assessment and the remedial investigation or during the
immediate removal operation, as described in the National Contingency Plan
(NCP).  These activities include a review of background data, aerial photog-
raphy, geophysical surveying, sampling, and an onsite inventory of drums.
For drum handling, the objectives of these tasks are to locate and define the
boundaries of buried and aboveground drums, assess the types and  amounts of
wastes and their potential hazard, and provide needed information to
determine whether immediate or planned removal is warranted.

REVIEW OF BACKGROUND DATA

     A review of background data is undertaken as part of the preliminary
assessment.  This activity can provide guidance on the site-specific safety
plan, costs, equipment, and methods required for drum removal or  source
control measures, and can focus subsequent site investigation activities.

     There are four basic types of information that can be obtained  by
reviewing background data:  drum storage, handling, and disposal  practices;
waste characterization; hydrogeologic setting; and location of receptors.

     A review of information on drum storage, handling, and disposal
practices should focus on determining .the following:


     •  Location of drums

     •  Number of drums

     •  Condition of drums (and expected condition in 1 to 2 years)

     •  Burial or aboveground storage of drums

     •  Handling of incompatible wastes during disposal

     •  Codisposal of drums with bulk wastes

     •  Nature of the drum disposal operation (whether drums were disposed of
        haphazardly or efforts were taken to prevent rupture or denting
        during disposal)
                                      29

-------
     •  Efforts taken to minimize corrosion (i.e., lining of trenches or
        cover for drums aboveground).


     Although existing data on waste characterization are frequently sketchy,
background data should be used to the extent possible to determine the
physical state of the wastes (solids, liquids, or gases); broad waste
categories (e.g., flammables, radioactives, or water reactives); and specific
waste types (e.g., solvent still bottoms or paint sludges).

     Information on the hydrogeological setting should be used  to determine
factors such as the elevation of the water table, direction rate, nature of
groundwater flow, and the depth to bedrock.  These factors can  provide  useful
information on the probable condition of the drums, extent of groundwater
plume, and site-specific conditions that may dictate the need for specific
equipment types during drum handling.

     Proximity to receptors can determine whether removal or remedial action
is warranted and can dictate the need for specific precautions  to protect
sensitive environments or nearby populations.

     Table 5 summarizes widely used sources of background information.

AERIAL PHOTOGRAPHY

     Aerial photography is an effective and economic tool for gathering pre-
liminary information on waste disposal sites and  for locating drums.  Use  of
aerial photographs can minimize the need  for extensive remote sensing,  exca-
vation, and/or sampling by providing a general indication of the location  of
buried drums.  Because maps of the  site can be prepared before  inspection,
potential hazards for field personnel can be noted and minimized.

     Aerial imagery' refers to pictorial representations produced by electro-
magnetic radiation that is emitted  or .reflected from the earth  and recorded
by aircraft-mounted sensors.  One type of  aerial  imagery is the photograph,
the simplest, most common kind of imagery, which  uses only the  visible  part
of the electromagnetic spectrum.  Three types of  photographs are often  used
for gathering information on disposal sites.  Oblique photos are taken  at
angles to the earth's surface and thus distort the scale of the picture
{objects in the  foreground are larger and  objects in the background  are
smaller than actual size).  Therefore, oblique photos are useful when  scale
is not important, such as when areas must be 'surveyed for suspicious dead
vegetation, barren areas, or pits.  High  resolution  photographs enable
investigators to  identify drums and other  small-scale objects.   Perpendicular
photos, or stereophotos, which are  taken  from directly above the site  so that
there is little  or no distortion, can be  used in  pairs to show  the  topography
of the site in three dimensions.

     The second  type of aerial imagery uses wavelengths of light that  are
outside the visible spectrum.  The  three most common types of images  are
infrared, radar,  and multispectral.


                                      30

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                                       TABLE 5.   SOURCES  FOR  BACKGROUND DATA RELATED TO
                                                    DRUM  HANDLING AND DISPOSAL
Drum Storage, Handling,
and Disposal Practices
Site owner/operator
Generator*
Waste Characteristics
Site records
• inventories
• permits
• manifests
Hydrogeologic
Setting
Topographic maps
USDA soil surveys
USDA water supply
Location of Receptors
County Planning
Agencies
County and State
papf-rs Health Departments
U)
Private citizens              Generator  records

Site records, especially      REM/FIT reports
  permits

Historic aerial photography   Monitoring/sampling
                               data
                  REM/FIT1  reports
USGS  water  resource maps

Flood Insurance maps
                                                                       Well drillers logs
                                                                       Property surveys
                                                     Climatological  data
                                                     REM/FIT  reports
Zoning records

State Departments
of Natural  Resources

Local citizens  groups
Historical  aerial
  photography

REM/FIT1  reports
                   REM/FIT -  Remedial/Field Investigation  Team

                  2USDA -  United States Department of Agriculture

                   USGS -  United States Geological Survey

-------
     Infrared imagery indicates areas that are hotter or cooler  than  the
general surroundings.  This is useful, as drums leaking hazardous wastes may
give off heat in continuing reactions, and areas of dead vegetation have
different radiant heating (albedo) characteristics than vegetated areas.

     Radar imagery uses side-looking radar to accentuate topographic  relief
without recording vegetation.  This type of image would be  especially useful
for discovering covered trenches or pits that are camouflaged by dense
vegetation.

     Multispectral imagery refers to a series of images, each of which uses a
different portion of the light spectrum.  This type of imagery  provides the
greatest amount of data although it also takes the most time and skill to
interpret.  The cost involved in data acquisition and computer  processing
often makes this system cost-ineffective (JRB Associates,  1980).

     Table 6 summarizes the important aspects of photographs and images in
the discovery of drums and leaking wastes from drums.

     Aerial photos and interpretative assistance for the eastern EPA  regions
are available from the Environmental Photographic Interpretation Center
(EPIC) in Warrenton, Virginia.  The Environmental Monitoring Systems  Labora-
tory (EMSL) in Las Vegas, Nevada, offers similar services  for the western  EPA
regions.  These groups also provide technical support and  film  development
for the EPA regions' Enviropod Systems.  The Enviropod i-s  a portable  camera
system that can be readily installed in aircraft.

     EPIC's Imagery Analysis System (IAS), designed by Calma Corporation,  is
capable of rectifying photo-to-map scales for plotting points directly from
imagery to a standard map.  The system also determines the  exact geocoor-
dinates for an individual site and computes the area of a  particular  feature
(Titus, 1981).

     Trend analysis using sequential historic aerial photographs is another
useful method for locating drums.  Archival photographs taken after 1950  are
available from the National Cartographic Information Center, USGS, Reston,
Virginia, and from Earth Resource Observation System (EROS) Data Center,
Sioux Falls,. South Dakota.  Photographs taken from  about  1930 through 1950
are available from the National Archives in Washington, D.C.  Generally,  the
requestor must specify the geographical coordinates (latitude and  longitude)
of the site.  Standard orders for copies of photographs can generally be
processed within 6 weeks (Holmes, 1980; JRB Associates,  1980).   If  there  are
gaps in the coverage, State archives and. privately owned  cartographic plots
may provide the missing information.

     Comparison of historic photographs over  the  span of  time when  operations
took place at a given site can strongly suggest  the location of drums. The
following changes should be noted:

     •  Filled-in trenches

     •  Mounded soils or paved surfaces

                                      32

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       TABLE 6.  SUMMARY OF AERIAL IMAGERY AS A TOOL FOR LOCATING DRUMS
   Type of
   Imagery
  Type of Infor-
  mation Provided
Key Features to
   Look For
      Comments
Oblique photos
Photographic view
of sites
Dead vegetation,
drums, and pits
Readily available and
easy to interpret,
but limited amount
of information
provided
Stereoscopic
photos
Three-dimensional
photographic view
of sites
Same as oblique,
plus drainage
patterns, stunted
vegetative growth,
and unusual mounds
or sinks
Readily available and
can provide much more
information than
oblique photos but
more difficult to
interpret
Infrared images
Variations in sur-
face temperature
Abnormal vegeta-
tive patterns,
leachate plumes,
anomalous hot
or cool areas
Radar images      Surface topography  Drainage ways,
                  without vegetative
                  cover
                    surface impound-
                    ments , and pits
Not as readily avail-
able on an appro-
priate scale as are
photographs; much
more difficult to
interpret but can
provide a great deal
of information not
available from photos
Multispectral
images
All of the above
plus data
from other spec-
ialized types of
imagery
All of the above
plus other spec-
ialized types of
features
Generally not con-
sidered cost-effec-
tive
Source:  JRB, 1980
                                      33

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     •  Changes in vegetation

     •  Disappearance of pits, quarries, or natural depressions

     •  Changes in traffic patterns.


The areas of concern are generally plotted on overlays to aerial photographs
and analyzed for any changes that may have occurred over time.

GEOPHYSICAL SURVEYING

     A number of surface geophysical techniques have been proven to be
effective in resolving details of site conditions, locating buried drums, and
defining the boundaries of leachate plumes.  These techniques,  and their
applications and limitations, have been described extensively in the litera-
ture.  A number of valuable references have been included in the reference
list.  The theory, applications, and limitations of these methods are briefly
described in Table 7 and in the following subsections.

Metal Detection

     Metal detectors respond to the high electrical conductivity of metal
objects and can detect both ferrous and non-ferrous metals.  The metal
detector is a near-field device that can detect metal objects to a maximum  of
2.4 to 3.7 meters (8-12 feet).  The detection distance is generally much
less, however, because of geological or cultural noise or the presence  of the
drums.  The detection distance may be reduced to as low as  1.2  to 1.5 meters
(4-5 feet) in areas containing buried drums.  The major advantage of the
metal detector is that it is inexpensive and easy to use.   The  hand-held
models are lightweight, readily available, and ,easy to handle,  but models are
also available that can be vehicle mounted for continuous surveying.  In
addition to low sensitivity, a major disadvantage of the metal  detector is
the system's sensitivity to both iron .oxides in the soil and conductive
leachates.  The presence of lateral metallic objects such as fences or  cables
limit the performance of most of the readily available, commercial models.
However, special systems are available that can minimize these  interferences
(Sandness et. al., 1979; Ecology and Environment, 1981; Yaffe,  1980; Pease
and James, 1981).

Magnetometry

     A magnetometer responds to changes in the earth's magnetic field caused
by the presence of ferrous objects.  Unlike the metal detector, the magne-
tometer will not respond to nonferrous-metals.  Compared to the metal
detector, the magnetometer can detect  ferrous objects that  are  smaller  and  at
a much greater distance to depths of 2 to 9 meters (10-30 feet) .  The
increased sensitivity of this instrument makes it valuable  for  approximating
drum density, boundaries of trenches containing drums, and  drum location.

     There are  three types of magnetometers available:   the proton
precession, or  total field magnetometer; the  fluxgate gradiometer;  and  the

                                       34

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                                      TABLE  7.    SUMMARY OF  GEOPHYSICAL SURVEY METHODS
    Method
                   Principle of  Operation
                                          Featurea/Advantages
                                                              Disadvantagea
Hetal Detector
                   Induces an electromagnetic
                   field around  an object  in
                   response to radiation  from
                   a transmitter
                                •  Widely  available  commercial  equipment;
                                   lightweight

                                •  Vehicle-mounted aystems  are  also  avail-
                                   able  for  operation  in  the continuous mode

                                •  Can he  uaed  among vegetation

                                •  Data  can  frequently be  interpreted  in
                                   the  field

                                •  Can detect  ferrous  and
                                   nonferrous metals
                                              •  lav sensitivity;  depth of detection  is only
                                                 1.2 to 1.5 meters (4-5 feet)  in  areas where
                                                 where drums are buried

                                              •  Not  suitable for  nonmetallic  objects

                                              •  Host commercial models have  limited  use  in
                                                 locations  with  pipes,  chain  linked  fences,
                                                 etc., although  apecial models that minimize
                                                 these interferences  are available

                                              •  Hay be sensitive  to  the presence of  iron
                                                 oxides in  soil  and conductive fluida
Magnetometers
 - Proton
   Precession
   Hagne-
   lometer
 - Fluxgate
   gradiometer
Heasures minute changes in
the earth*s magnetic  field
induced by a buried ferro-
magnetic object

Uses the precession of
apinning protons or
nuclei of the hydrogen
atom in a sample of hydro-
carbon fluid to measure
total magnetic intensity
Uses two sensors that  balance
out the effect of the  earth's
magnetic field.  The existence
of an external field such  aa  a
drum disturbs the flux balance
and the voltage induced  is
proportional to the  strength
of the ambient field
•  Much more sensitive than the metal
   detector; can detect metal drums
   to depths of 3 meters (10 feet)
   or more

•  Can approximate boundaries of trenches
   containing buried drums

•  Low sensitivity to soil conditions

•  In simple cases data can be interpreted
   in the field
•  Unsuitable for nonferrous objecta

•  Generally limited to slat ion-by-
   station measurements

•  Has limited use in locstions with
   pipes, chain-link fences, etc.,
   because it will respond to nearly
   all objects, making data interpretation
   very difficult
•  Virtually blind to interferences in the    •  Detects only ferromagnetic  objects
   horizontal plane; can be used near
   (2m, or 7 ft) a chain-linked fence

•  Can approximate the boundaries of
   trenches containing buried drums

•  low sensitivity to soil conditions
                                                                                                                                     (ront inued)

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                                                          TABLE  7.    (Continued)
    Method
                   Principle of Operation
       Feat ures/Adv ant ages
                                                                                                                 Diaadvantages
 -Fluxgate
  gradiometer
  (continued)
    Can  be  vehicle-operated or  hand-towed,
    as conditions  dictate

    In simple  cases, data  can be  inter-
    preted  in  the  field
Ground-            Emits electromagnetic pulses
Penetrating        into the ground and detects
Radar              and records reflections  from
                   from subsurface objects
•  Can detect plastic drums and  leachate
   plumes

•  Provides  approximate depth of burial
   and orientation of drums in the
   trench,

•  Provides  continuous survey data

•  Can bp vehicle-operated or hand-towed
   as conditions warrant

•  Under certain conditions, can provide
   the greatest level of detail of all
   subsurface survey methods

•  Can penetrate concrete if no reinforcing
   bars are  present

a  Can perform rapid exploratory work or
   can be hand-towed at slow speeda to
   provide detailed studies
•   Performance  is highly site-specific,
    affected by  presence of cables,
    chain link fences, etc.

•   Not suitable for site* with heavy clay
    soils, high  groundwater salt concentrations,
    or other materials that absorb electro-
    magnetic energy

•   Limited use  in vegetated areas
                                                                                                    Detection of  some drums can be masked by
                                                                                                    presence of drums above
                                                                                                    Equipment  is more difficult to set up
                                                                                                    and  operate than metal detectors, magne-
                                                                                                    tometers,  or electromagnetic methods
Low Frequency      Measures subsurface
 Electromagnetics  conductivities
•  Detects wastes leaking from drums,
   approximates plume boundaries, and
   determines direction of ptume flow

•  Continuous conductivity data can be
   obtained  for depths ranging from 4.5
   to 6 m (15-20 ft); measurements of 8
   to 60 m (25-200 ft.) are possible in a
   atation-by-station point survey

a  Most cost-effectively applied to lateral
   profiling at fixed depths
•  Cannot atttaya distinguish between drums and
   uncontainerized wasted

•  Performance ia degraded by presence of buried
   pipea , cablea , and fences;. however, aome
   interferencea can be filtered during data
   processing

•  Data  interpretation often requires computer
   processing
                                                                                                                                     (continued)

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                                                                  TABLE  7.    (Continued)
             He t hod
                            Principle of Operation
                                                                 Features/Advantages
                                                                                                                        Disadvantages
         Low Frequency
          Electromagnetics
          (cont inued)
                               •  Combination of continuous and depth
                                  profiling can provide 3-D coverage

                               •  Raw data can be approximated in the
                                  field.  Further data processing
                                  can be used for 3-D plotting, plotting
                                  of contours, filtering of cultural
                                  features.
OJ
-J
         Electrical
         Resistivity
          - Lateral
            Profiling
Based upon the conduction of
electric  current  through
subsurface materials  to
measure changes  in bulk
electrical resistivity
(reciprocal of conduction)
         - Depth Profiling
                               •  Detects materials leaking from drums
                                  and determines the extent of
                                  contaminat ion

                               •  Equipment lightweight and portable
                               •   Determines change  in contamination
                                   with depth
•  Limited ability to detect  nonconductive
   pol I ut ant a

•  Data interpretation may be difficult,
   especially if there are lateral  variations  in
   stratigraphy

•  Performance is degraded by presence of pipes,
   fences, etc .

•  Technique is slow and costly

•  Limited ability to detect  nonconductive
   pol lut ants
                                                           •  Provides more detailed sounding than is    •  Technique is slower  than  depth  profiling
                                                              achievable with EM conductivity
                                                                                                            using EH method
                                                                                                                                              (continued)

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                                                                TABLE 7.   (Continued)
             He t hod
                            Principle of Operation
Feature*/Advantages
Disadvantages
         Seismic Refraction
                                                              Can be  used  to  determine depth of
                                                              buried  drums and  bedrock
                                       •  Method not well tested  for  drm detection
oo
                                       •  Depth of penetration varies  with  energy
                                          source

                                       •  Data interpretation stay be difficult  if
                                          stratigraphy ia conplex

                                       •  Requires access road for vehicles and cannot
                                          be operated in the  cont inuous mode
         Sources:   Ecology and  Environment, 198!; Saniiness,  et.  at.,  1979;  Benson  and Glaccum, 1980; Lord, Tyagi,  and Koerner,  1981; Evans, Bfnaen and
                   Rizzo,  1982;  Kolmer 1981; Horton, 1981;  Pease and  James,  1981;  Yaffe, Cichowicz, and Stoller, 1980.

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cesium vapor magnetometer.  The cesium vapor magnetometer  is a relatively new
device that is expensive  to use and  currently has  little practical  appli-
cation for hazardous waste investigations.  The fluxgate gradiometer  is often
preferred over the proton precession magnetometer  because  the gradiometer  is
less sensitive to background noise.  Gradiometers  are available with  a
neutral dead zone in the  horizontal  plane that blinds the  instrument  to
potential lateral interferences such as metal fences, cables, or  passing
cars.  This instrument can be used as close as 2 meters (7 feet)  to a chain
linked fence.  In addition, the gradiometer can be vehicle-mounted  for
continuous profiling, while the proton precession  magnetometer is generally
limited to station-by-station measurements.  Of all the geophysical surveying
tools, the gradiometer produces the  least amount of cultural (e.g., pipes,
fences, passing cars) and subsurface interferences (Benson and Glaceurn, 1980;
Sandness et al., 1979; Ecology and Environment, 1981; Kolmer, 1981; Lord,
Tyagi, and Koerner, 1981; Evans, Benson, and Rizzo, 1982).

Electromagnetic Conductivity

     Low frequency electromagnetics  (EM) provide a measure of subsurface
conductivities.  These conductivities are a function of the basic soil/rock
matrix, its pore space, and the groundwater or leachate that permeates the
matrix.  In most instances the conductivity of the pore fluid will  dominate
the measurement.  The EM method can  be used effectively for mapping hydro-
geology of the site and conductive leachate plumes and their direction of
flow as well as for locating and defining the boundaries of buried  drums.  In
some cases, however, it may be difficult to distinguish between a conductive
plume and buried drums.

     EM methods can be used either for continuous  profiling at shallow depths
of 4.5 to 6.0 meters (15-20 feet) or for station-by-station profiling at
depths of 7.6 to 60 meters (25-200 feet).  EM measurements are usually, and
most economically, made by traversing the site at  a fixed depth.  However,
sounding data can also be obtained to assess vertical hydrogeologic changes.
A combination of continuous and depth .profiling can provide three dimensional
coverage, although this requires complex data processing.  The performance of
EM methods can be degraded by the presence of buried pipes, cables, and
fences (Ecology and Environment, 1981; Lord, Tyagi, and Koerner,  1981; Benson
and Glaceurn, 1980; Evans, Benson, and Rizzo, 1982).

Ground-Penetrating Radar

     The response of ground-penetrating radar (GPR) is caused by  radar wave
reflections from interfaces of materials having different complex dielectric
constants.  The reflections are often associated with natural hydrogeologic
conditions such as bedding, fractures, moisture and clay content, and voids,
as well as man-made objects such as buried drums and surface cultural
features (e.g., fences, cables).  GPR offers the highest level of detail of
the geophysical survey methods because of the high frequency energy that is
used.  However, it is also subject to several interferences.  Penetration
depths of commercial systems vary from less than 1 to more than 20  meters
(0.3-60 feet)  depending upon the frequency, the dielectric constant of the
medium and the constitutive electromagnetic parameters of the soil.  The

                                      39

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depth of penetration may be particularly shallow where clay soils or
conductive groundwater are present.  Performance of GPR is highly site-
specific, but under favorable site conditions it can be used to define plume
boundaries, locate metallic and nonmetallic drums, and approximate drum
density, depth, and the boundaries of buried trenches.

     Radar performance is also frequency sensitive, and optimum antenna
frequency must be selected based on the depth of penetration and the
resolution required.  Low-frequency antennas provide better penetration while
high-frequency antennas provide better detail (Horton, 1981; Benson and
Glaccum, 1979; Benson and Glaccum, 1980; KoLmer, 1981; Lord, Tyadi, and
Koerner, 1981).

Electrical Resistivity

      Electrical resistivity is somewhat analogous to EM.  In both cases, the
operation depends on the fact that any subsurface variation in conductivity
alters the form of current flow within the earth.  However, electrical resis-
tivity measures changes in bulk electrical resistivity rather than conduc-
tivity (the reciprocal).  Unlike EM, resistivity requires direct electrical
contact with the earth via four probes driven into the soil.  This makes
continuous surveying impossible and station-by-station methods slow in
comparison to EM.  Either lateral or depth profiling can be obtained
depending upon the electrode configuration.  Although electrical resistivity
is slower and more costly than EM, it generally provides more detailed
sounding data.  The two methods can be effectively used together for
delineating subsurface geology and developing three dimensional profiles of
plumes.  As with the EM method, resistivity  is subject to cultural inter-
ferences and may not always distinguish between drums, and conductive  plumes
(Horton, Morey, Isaacson, and Beers, 1981, Lord, Tyadi, and Koerner,  1981;
Evans, Benson, and Rizzo, 1982).  In addition, data interpretation in lateral
profiling can be very difficult if radical changes in topography are  not
adequately accounted for by the electrode spacing and if there are lateral
variations in stratigraphy (Pease and James, 1981).

Seismic Refraction

     Seismic refraction traditionally has determined  the depth and thickness
of geologic strata by using elastic waves transmitted into the ground by an
energy source such as a hammer blow on a steel plate.  The waves travel
through different subsurface strata at different velocities and the refracted
waves are detected by small seismometers (Yaffe, Cichowicz, and Stoller,
1980).  Although not widely used  in locating hazardous wastes, refraction
methods have the potential for locating and  defining  the boundaries of drum
burial pits and trenches (Evans,  Benson, and Rizzo, 1982; Pease and James,
1981).  A major disadvantage to seismic refraction is the difficulty  in
interpreting data  in areas with complex stratigraphy  or where there is no
sharp contrast in velocity (Yaffe, Cichowicz, and Stoller,  1980; Pease and
James, 1981).
                                       40

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Method Selection and Implementation

     There are obvious advantages and limitations to each of the geophysical
survey methods discussed above.  Before initiating a geophysical survey it is
necessary to clearly establish the objectives of the survey, whether it be to
locate drums, to estimate their number and the boundaries of the trench, or
to determine the extent to which they are leaking.  If drum location is all
that is required, magnetometry, or, in some instances, metal detection will
be adequate.  If it is necessary to estimate the number of drums and
determine the extent of leachate migration, EM, GPR, and magnetometry may be
needed in combination.

     Site characteristics should also be an important consideration in
selecting the most appropriate survey methods since a number of site-
specific factors can affect method performance.  The presence of cultural
features can affect the performance of several geophysical techniques.  GPR
is poorly suited for surveying where soils have a high clay content.  The
presence of saline groundwater effects the performance of GPR, EM, and
electrical resistivity.  Other examples of the effects of site-specific
factors on performance are summarized in Table 7.

     Difficulty of data interpretation should also be considered when
selecting the appropriate geophysical surveying equipment, particularly where
immediate results are needed or where financial resources are very limited.
Metal detection and magnetometry will frequently provide useful information
in the field, although further data processing is often recommended for such
things as spatial correction,  filtering, and plotting parallel sets of data.
GPR, electromagnetics, and resistivity usually require data processing,
although raw data may be of value as an initial assessment tool depending
upon the complexity of the site.

     Costs are influenced by numerous factors, some of which cannot be
predicted at the outset of the survey.  Some of the major variables
influencing costs include:


     •  Use of instruments that are towed by a vehicle or are handheld.
        Surveys are likely to be done by hand if the drums are close to the
        surface and there is a risk of rupture or if the site is in a marshy
        or highly irregular terrain.

     •  The type of data needed, particularly the adequacy of determining
        only the general location of groups of drums or the necessity of
        approximating the boundaries of trenches and the number of drums.

     •  Degree of site preparation.  Vegetative cover interferes with many of
        the geophysical survey methods, and sites must often be cleared
        before surveying.
                                      41

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        Degree of data interpretation required, which is determined not only
        by choice of survey method but also by the depth of drums and the
        need to filter interferences such as cultural features and surface
        irregularities.

        Previously unpredicted subsurface anomalies, or interferences, which
        degrade performance of a particular survey method, requiring a change
        to another method.
Case Study Applications of Geophysics

     Three case studies are briefly discussed below to illustrate the
application of geophysical survey methods for drum detection and plume
delineation.

     Figure 1 shows a three dimensional representation of a 10 hectare (25
acre) waste disposal area developed from lateral and depth EM profiling.  The
results clearly defined the perimeter and maximum depth of the wastes.  GFR
was later used to further confirm the perimeter of the contamination.
However, neither EM or 6PR could confirm whether the buried material was
bulk-dumped or disposed of in drums.  Followup magnetometry profiles
indicated that only a few drums were present within the large disposal area.
Before conducting the geophysical survey, six monitoring wells had been
installed at the site in an effort to locate the wastes.  As shown in Figure
1, all of the wells missed the target area.  By conducting the geophysical
survey first, there would have been better guidance on the appropriate
location of monitoring wells (Benson, Glaceurn, and Beam, 1981; Evans, Benson,
and Rizzo, 1982).

     Benson and 61aceurn (1980) reported on a site investigation  in which
ground-penetrating radar, metal detection, magnetometry, and electromagnetics
were used successfully in detecting drums.  Electromagnetics, magnetometery,
and metal detection profiles all showed significant anomalies over a trench
indicating large amounts of conductive metal material.  The combination of
responses indicated the presence of 55-gallon steel drums.  The magnetic
data, when plotted as continuous lines (Figure 2), also provided  a
semi-quantitative measure of the spatial location and quantity of steel drums
present.  The metal detector provided a sharper response at the  edge of the
trench, resulting in a better spatial definition of the drum boundaries.  GPR
clearly showed a trench cut into the soil profile and indicated  the bottom of
the trench at 2.1 meters (7 feet).  This combination of methods  provided  the
investigators with increased confidence in determining drum quantity and
location.

     At the Picillo Farms site in Coventry, Rhode Island,  a combination of
metal detection and GPR data were used to determine the dimension of trenches
containing buried drums and to estimate their number.  Figure 3  shows  a
comparison of the trench boundaries as detected by GPR and metal detection.
The boundaries of two of the three  trenches were detected  to be  similar,
though not overlapping, by the two methods.  The contractor in this  instance
had more confidence in the GPR data.  A third trench was detected by GPR  but

                                      42

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   Rgure 1. Three Dimensional Representation of EM Conductivity Data
           Showing Buried Hazardous Materials
           (Senson, Glaccum, and Beam, 1981. Rgures originally printed in the
           Proceedings of The National Conference on Management of Uncon-
           trolled Hazardous Waste Sites, 1981.  Available from Hazardous
           Materials Control Research Institute, 3300 Columbia Blvd., Silver
           Spring, MD 20910.)
Figure 2. Continuous, Parallel Lines of Magnetic Gradient over a Buried
         Drum Site Defining the Location and Lateral Limits of Drums
         (Benson and Giaccum, 1980. Rgure originally printed in the Pro-
         ceedings of The National Conference on Management  of Uncontrolled
         Hazardous Waste Sites, 1980. Available from Hazardous Materials Con-
         trol Research Institute, 9300 Columbia Blvd., Silver Spring, MD
         20910.)

                                    43

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                                                       — TRCNCM BOUNDARY BY
                                                     —   MCTAL OI7ECTION
                                                              FfCT
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          RAOAR
          GRID
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J

                   40E    80E  /120E    160E   200E   240E  I/280E   320E   360E   400E
NORTHWEST
TRENCH
NORTHEAST
TRENCHES
  Figure 3. Comparison of Ground Penetrating Radar and Metal Detection
           Survey Results for Drum Containing Trenches Located at
           Picillo Farms,  Coventry, Rl
           (Source: Pease  et al.,  1981)
not by metal  detection.   However, the GPR data  provided incomplete areal
coverage  for  the  western trench, and the data were  supplemented by data  from
the metal detection survey.  The GPR data also  provided some qualitative
information on  the  way drums were placed in  the  trench (randomly stacked  and
clustered), but were unable to indicate the  bottom  of the trenches because
the upper drums masked what was beneath (Pease  et  al., 1980).

SAMPLING

     Sampling efforts undertaken during remedial investigations can vary
widely in nature  and complexity.  When conducted prior to an immediate
removal operation for drums aboveground, sampling  is generally limited to  a
random sampling of  the drums.  On the other  hand,  if source control measures
are anticipated,  a  comprehensive groundwater sampling program may be
required.
                                       44

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Drum Sampling

     Drum sampling undertaken prior to immediate removal, or initial  removal
measures, is generally limited to a random sampling of drums stored  above-
ground.  This allows a gross categorization of the types of waste onsite  and
this information is then used to prepare bid documents, cost estimates  for
cleanup, feasibility studies, and design reports.  This random  sampling
effort should not be confused with the more comprehensive sampling of every
drum, which is generally required as part of the drum consolidation  protocol
(see Section 9).  Procedures for opening and sampling drums are discussed in
Sections 8 and 9, respectively.

     A determination of the number of drums to be sampled should be  based on
the total number of drums, costs, requirements for restaging the drums  before
they can be safely sampled, and an observation on the variability of waste
types based on background data and visual inspections.  Depending on these
variables, random sampling of drums may involve 5 to 25 percent of the  drums.
In an effort to obtain a representative, random sample, drums should be
selected for sampling based on markings, labels, codes, type of drum, and
physical location relative to other drums onsite.

Soil Sampling

     Soil sampling is frequently conducted to obtain additional information
regarding drum location, depth of burial, condition of drums, and types of
wastes present.

     Sampling points are selected based on information obtained from back-
ground data pertaining to drum disposal practices, aerial photography,  and
the results of geophysical surveys.  If subsurface burial is suspected, it is
recommended that a geophysical survey precede soil sampling to minimize the
potential for rupturing drums or exposing field personnel to highly  toxic
pockets of waste.  Direct-reading air monitoring equipment should be used
during soil sampling to warn field personnel of potential hazards.   Use of
this equipment is discussed in Section 6.

     The sampling points can be selected using one of three approaches:
random sampling pattern, grid pattern, or grid pattern in which several
samples  from within the grid area are combined to give average  concentra-
tions.  The selection of subsurface soil sampling equipment depends  on  the
accuracy of sampling data needed, the types of soil and subsurface materials
encountered, and the depth of sampling required.  A widely used technique for
rapid location of buried drums is to use a backhoe to excavate  shallow  test
pits that are monitored for volatile organic hydrocarbons.  An  organic  vapor
analyzer (see photoionization and flame ionization detectors under  Section
7), equipped with a probe for remote sensing, is lowered  into the  test  pit
and the concentration of volatile organics is measured.   The results can  be
mapped on overlays of the site to determine vertical and  horizontal  concen-
tration  profiles that can suggest areas of buried drums.  The advantages  to
this method is its quickness compared to other soil sampling techniques and
its lowered risk for field personnel through the use of a backhoe,  rather
than hand tools, to excavate the test pits.

                                      45

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     Various types of hand-operated soil sampling equipment are also avail-
able.  Applications and use of this equipment is discussed in detail in
Sampling and Sampling Procedures for Hazardous Waste Streams (de Vera,
Simmons, Stevens, and Storm, 1980).  Tahl o fl hr-igfly aimimgrT^gg the
capabilities and limitations of hand-operated, soil sampling equipment.

Groundwater Sampling

     Groundwater sampling also may be required as part of a remedial
investigation, particularly if source control options are being considered.
Considerable guidance is available on groundwater monitoring techniques and
analysis and interpretation of data.  Useful references include the
following:


     •  Groundwater Monitoring Guidance  for Owners and Operators of Interim
        Status Facilities (U.S. EPA, 1983a)

     •  Procedures Manual for Groundwater Monitoring at Solid Waste Disposal
        Facilities (U.S. EPA, 1980b)

     •  Aquifer Contamination and Protection  (Jackson, 1980).
PREPARING A DRUM INVENTORY

     After completing the site investigation activities, it  is  usually
possible to prepare a drum inventory, which provides an estimate of  the  number
and type of drums on a site*  The drum inventory can vary considerably in
detail depending on the information gathered during the site  investigation  and
whether the drums are buried or aboveground.  Table 9 shows  the format used to
inventory drums at the Keefe Environmental Services Site where  drums and other
containers had been stored aboveground (U.S. EPA, 1982c).

     Considerable detail was available for this site, and it  was possible  to
determine the number of specific types of drums and containers  at various
locations at the site.  This information was valuable to potential sub-
contractors in determining equipment needs and drum removal  costs.   In
addition, using the data derived from the random sampling effort, it was
possible to develop a gross categorization of waste types found at the site
(Table 10).

     Estimating the number of buried drums at a site usually requires a
reliance on geophysical testing methods and background or historic data. At
the Picillo Farm Site in Coventry, Rhode Island, the number  of  buried drums
was estimated using a combination of geophysical surveying methods.   The
procedure used located the trenches and estimated their dimensions through  a
combination of metal detection, GPR, limited excavation, and  seismic
refraction.  Two nominal trench depths of 4.3 to 6.7 meters  (14-22 feet) were
used to bracket the range determined by remote sensing  and direct excavation.
Two drum densities also were used to estimate the number of  drums:   50 percent
and 90 percent.  An estimated range of the number of drums was  then  prepared,
as shown in Table 11.
                                      46

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              TABLE 8.  APPLICABILITY AND LIMITATION OF VARIOUS
                            SOIL SAMPLING METHODS
   EQUIPMENT
     APPLICATION
    MAJOR LIMITATIONS
Shovel and scoop
Sampling trier
Hand auger
Hand driven,
split spoon
sampler
Hand-driven
hollow stem
Soil samples up to 8 cm
(3 in) deep
Core sampling to depths
of 0.8 to 0.9 m (2.5-
3 feet)

Soil samples to depths
of 1.2 to 1.5 m (4-
5 feet)
Relatively undisturbed
core samples
Undisturbed core samples
to depths of 4.9 m
(16 feet)
Suitable for surface
samples only
Identical mass sample
units for a composite
sample are difficult to
collect

Cannot be used in soils with
high stone and gravel
content

Mixes soils so that no dis-
tinction can be made be-
tween samples collected near
the surface or toward the
bottom

Depth depends on soil type
and the number of sampling
rod sections available for
the split spoon

Suitability limited in rocky
or wet soils
Source:  de Vera, et al., 1980
                                      47

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•o
00
                                           TABLE  9.  DRUM   INVENTORY FORMAT
                                   KEEFE  ENVIRONMENTAL SERVICES  SITE,  EPPING,  N.H.
     Area   Lab Packs       Overpacks    Poly-Liner/ Ring   Bung    Ring    Five     Total    Total   Total   TOTAL
            (Actually Seen)              Poly-Drum   Top    Top     and     Gallon   Liquid   Solid   Empties  ALL
                                                                Bung    Pail a                            DRUM
                                                                Top
  A

  B

  C



Subtotal




Adapted  from U.S.  EPA., 1982c

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               TABLE 10.  CATEGORIZATION OF WASTE TYPES AT THE
     KEEFE ENVIRONMENTAL SERVICES SITE BASED ON RANDOM SAMPLING OF DRUMS*
               Waste Type                        Percent of Total Drums
               Solids                                      19
               Acids                                 ,     18
               Nonchlorinated Solvents                     14
               Resins           "                        '    9
               Aqueous Waste                                7
               Alkali Waste                                 7
               Cyanide Waste                                6
               Waste Oil                                    6
               Paint Waste                                  5
               Sludges                                      4
               Chlorinated Solvents                         2
               Glycols                                      2
               Empty                                        1
               PCS Oil                                      1
*Based on a random sampling of 20 to 25 percent of drums.  Total adds  to  101
 percent due to rounding.

Source:  U.S. EPA, 1982c
                                      49

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                TABLE 11.  ESTIMATED NUMBER OF BURIED DRUMS AT
                   PICILLO FARMS, RI, BASED ON EXTRAPOLATION
                            OF BEST AVAILABLE DATA
                       Maximum                       Drums Randomly
 Trench              Drum Density                        Stacked
Location      ^	

                d - 14 ft      d - 22  ft    . d -  14  ft         d -  22  ft
Northwest         14,800       22,400          8,200           12,400

West              13,500       20,200          7,500           11,200

South              1,700        2,100          1.000            1,200

Total             30,000       44,700         16,700           24,800




Notes:  d » nominal trench depth

        Random stacking indicated by results of excavation of  Northwest
        Trenches, approximated by 50 percent drums, 50 percent earth by
        volume in trench below 2-foot cover and assumed  trench geometry.

        Drums are assumed to be uncrushed, 55-gallon drums.

Source: Pease et al., 1980.
                                       50

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                                  SECTION 5

                               SITE PREPARATION
     Before remedial or removal actions can begin, the  site must be  prepared
to improve the safety and efficiency of drum handling,  and the  appropriate
support facilities must be constructed or installed.  The nature and extent
of site preparation varies widely from site to site depending on the hazard
of the wastes, the environmental sensitivity of the site, and the  location of
the site with respect to surrounding populations.


SITE ACCESS IMPROVEMENTS

     Site roads are required to provide access to  all apparent  drum  disposal
areas as well as to staging, consolidation, and decontamination areas.   Roads
must be suitable for transport of all proposed vehicles under all  possible
weather conditions.  At some sites it may be necessary  to construct  edge
gutters that drain into sumps along the access roads in order to collect
spills and contaminated runoff.

     Where drums have been disposed of in heavily  wooded or vegetated areas,
clearing and grubbing may be necessary to provide  access for drum  handling
and construction equipment or to provide spacing required for such activities
as staging and opening.  This work may include removal  of vegetative cover,
tree-cutting and excavation, and removal of tree trunks and roots.  Although
conventional construction equipment can be used for clearing and grubbing,
several safety precautions should be taken.  Geophysical testing may be
required prior to excavation to determine the presence  of drums or buried
pipes that could be easily ruptured by excavation  equipment.  PI ex iglas
safety shields should be used on all vehicles to protect equipment operators
from explosive or shock-sensitive wastes buried near the surface.

     At sites with buried drums, access improvements may involve excavation
of an access trench near the actual drum trench to facilitate drum removal.
The access trench should have gradual side slopes  that  allow drum  transport
traffic in and out without tipping waste containers.
                                       51

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SUPPORT FACILITIES AND STRUCTURES

     There are a. number of support  facilities or  specially designated
operating areas that must be constructed or  installed prior  to  cleanup.
These may include:


     •  Staging areas

     •  Drum opening area

     •  Waste consolidation/loading areas

     •  Interim storage areas

     •  Equipment and personnel decontamination areas
     •  Mobile laboratory

     •  Command post and administration area
     •  Emergency medical facilities
     •  Equipment maintenance area.


The site layout should be such that there  is a minimum-safe  travel  distance
between the disposal and staging areas, the  staging  and opening areas,  and  so
on.  The drum inventory data gathered during the  remedial  investigation should
be used to determine the number and size of  various  operating  areas or  cells.

     At a minimum, the staging, opening, and consolidation areas for wastes
other than those that are highly hazardous,  should be graded to prevent
puddling, lined with polyethylene,  and bermed or  diked using sandbags or clay.
This design will provide only minimal secondary containment, however, and will
not be acceptable at many sites.  A preferable design at  some  sites would
include a hard surface base or multilayer  liner (e.g., three 1-foot layers  of
graded sands and fines separated by two single layers of  6 mil  polyethylene
sheeting).  Runoff and spills would be contained  by  an edge  berm of the same
material.  Each cell should be sloped toward a sump  to collect  spillage and
rainfall.  The cell, sump, and pump capacity should  be adequate to  contain
runoff from a 10-year, 24-hour storm.

     Highly hazardous materials including  explosives, radioactive materials,
and gas cylinders require separate  staging/opening areas  that  are located as
far as possible from the actual drum handling operation.

     In addition to the above-mentioned secondary containment measures, these
areas should be fenced in and equipped with  warning  signs.

     The decontamination area should always  be a  hard surface  area  that will
retain wash water by perimeter curbing and collect these  liquids by means of  a
central trough and perimeter sump.

     The interim storage area, if required,  should be designed  to provide a
degree of containment consistent with the  length  of  time  wastes will be stored

                                      52

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onsite.  Standards for RCRA permitted  storage  facilities  (40  CFR,  Part 264)
should be followed where  interim  storage of  three or more months  is
anticipated.

     Figure 4 illustrates the  site  layout  for  the drum removal  operation at
the western trench of the Picillo Farm site  in Coventry,  Rhode  Island.

     In addition to these support structures,  the contractor  is required to
make necessary arrangements for power,  water supply, and  telephone,  and to
install security fencing  and a guard gate  to prevent unauthorized  access to
the contaminated zone.
SITE DRAINAGE IMPROVEMENTS

     There are a number of provisions  that  can  improve  site  drainage.   In many
instances, it is required that the drum consolidation,  drum  opening,  and
interim storage areas be graded  to prevent  standing  pools  of liquid that can
corrode the drum or result in incompatible  waste  reactions if water reactive
wastes are present.

     Dikes or berms may be constructed around poorly drained sites  to  divert
the flow of run-on.  Drainage ditches can be used  to  intercept runoff  and
convey it away from the work areas.

     Sites that are poorly drained or  swampy may  require  the construction of
special access roads or work areas for heavy excavation equipment.   Access may
be improved by constructing elevated roadways of  stable soils that  are wide
enough for heavy vehicle use.  These areas  should  be  surveyed with  metal
detectors and/or magnetometers prior to any construction  to  assure  that no
drums are being covered.

     Timber mats can also be used  to provide site  access  for heavy  equipment
in swampy, water-logged areas.   These mats  consist of trees, telephone poles,
or railroad ties that are placed parallel to each  other,  side by side, and
bound together with heavy rope or wire.  When laid across  stretches of swampy
areas, they provide a rigid access road or  stable  working  base from which drum
excavation activities can be performed.
                                      53

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                                                                  TO WHEEL
                                                                  WASH
                                                                 EQUIPMENT
                                                                 PARKING
                         SOUTH TRENCH
                         CELL      FUNCTION

                         1-8      SOLIDS STORAGE/MIXING

                           »      STAGING/SAMPLING

                          10      DRUM CRUSH.RESERVE
                                  STCRAGE

                          11       LAB PACK STORAGE
                          12       LA8 PACK DEMOLITION

                        13.14       ACIO.PC8 DRUM STORAGE

                          IS       CONTAMINATED SOX
                        18       LIQUID SAMPLE/STAGE/BULK
Figure 4. Picillo Hazardous Waste Site Layout (Western Trench)
           (Reprinted from Perkins Jordan, Inc., 1982 with permission of the
           Rhode Island Department of Environmental Management)
                                      54

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                                  SECTION 6

        AIR MONITORING AND INSPECTIONS FOR DETERMINING DRUM INTEGRITY
INTRODUCTION

     Safe handling of drums that are leaking or prone to rupture  is the
biggest problem encountered during drum handling operations.  The major
causes of drum leakage or rupture at hazardous waste sites include:


     •  Overpressurization, as evidenced by a drum head that is swollen  above
        the chime line and creased from the chime line toward the center of
        the drum.  Under these circumstances, the slightest change in
        position of the drum can cause the head, to blow off (Niggle, 1982).

     •  Damage caused by abusive handling during transportation and disposal.

     •  Incomplete tightening of drum bungs.

     •  Corrosion from contact with soil moisture, acids, or chlorinated
        hydrocarbons that have been hydrolyzed to hydrochloric acid.   Drums
        may be uniformly pitted or the corrosion can be concentrated in  a
        particular area.  Areas that are particularly susceptible to
        corrosion include the area around the chime and areas where the
        surface coating has been chipped or the drum surface dented.


     A determination of drum integrity usually involves input from several
sources of information, which can be divided into two broad categories:
information obtained during preliminary assessment and remedial investigation
activities, which provide a gross indication of the overall quality of the
drums; and information obtained during excavation and removal, which provides
detailed information on a drum-by-drum basis.  Figure 5 shows potential
sources of information on drum integrity during each of these phases.  Those
activities undertaken as part of site assessment and remedial investigation
were discussed in Section 4.

     During drum excavation, opening, and recontainerization, investigators
must be able to monitor drum integrity on a drum-by-drum basis to determine
whether drums can be safely moved or handled.  Most companies involved in
                                      55

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                          SITE                   DRUM
                 INVESTIGATION & ASSESSMENT       EXCAVATION 4 REMOVAL
                  Background Data
                            \        !      /
                                                Air Monitoring
                       iral  ^^
                   Surveying
             Aerial Photography
                                 DRUM INTEGRITY
                 Sampling/Monitoring
                                            «>.
                                            \
Visual Inspection
        Figure 5. Potential Sources of Information on Drum Integrity
site cleanup use a combination of air monitoring and visual  inspection of
drums to  accomplish this.  Where  the grappler  is available,  and  drums can be
handled remotely.  Determining drum integrity  before handling may not be
necessary.


AIR MONITORING

     Air  monitoring is the most valuable tool  for determining drum integrity
and worker  safety.  The requirements for air monitoring vary from site-to-
site depending on what is known about drum contents, the availability of
funds for monitoring, and the  size and location of the site.  The monitoring
program should, at a minimum,  accomplish the  following objectives:
         Provide input,  along  with.other information, to establish  hot, tran-
         sition, and clean  zones within the waste site (see Section 3) that
                                        56

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        dictate safety equipment and safety precautions .to which site workers
        must adhere

     •  Monitor changes in air quality in these zones over time

     •  Scan for "hot spots" that indicate a sudden release of toxic,
        flammable, or explosive vapors and radioactivity during such dynamic
        activities as drum excavation, staging, opening, and consolidation.


     Basically, there are two types of monitoring equipment:  direct reading
instruments, which provide onsite readout of pollutant concentrations, and
collection media, used to collect and concentrate pollutants for subsequent
laboratory analysis.

Direct Reading Instruments

     For sites where the drum contents and their potential hazard are
uncertain, the minimum direct reading equipment needed to protect worker
safety includes:


     •  Combustible gas detectors

     •  Oxygen meters
     •  Gas/vapor analyzers
     •  Radiation monitors.
Table 12 summarizes the capabilities and limitations of the most widely used
direct reading equipment.

     When selecting equipment for field monitoring, a number of factors need
to be considered.  These include:
        Detection limits
        Accuracy
        Portability and ease of use
       .Potential interferences that may impact performance
        Alarm capabilities
        Remote sensing capabilities
        Shelf life/battery storage life
        Calibration equipment and other accessories needed
                                      57

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                                   TABLE  12.   SUMMARY OF  DIRECT  READING AIR  MONITORING  INSTRUMENTS
         Monitoring Meed
                             Instrument
                                                     Feature*
                                                                                  Limitation!
                                                                                                              Cost
                                                                                                                               Manufacturer!
         Combustible Gas
                             Combustible Gas
                               Detector
Ui
CO
   Nonspecific  detector  for
   combustible  gases measures
   gas concentration as  a
   percentage of  lower
   explosive limit  (LED
si  Lightweight,  portable,
   and easy to use

•  Visual  and  audible
   alarms

•  Probe provides remote
   sensing capabilities

•  8-12 hr battery operating
   life for most models

•  Accuracy varies depending
   upon Che model, accuracies
   of ^ 2  to 3 percent are
   attainable
Potential interference
from leaded gasoline and
silicates, which are more
strongly adsorbed on
catalyst than oxygen or
gas in question.  Membranes
are available to minimize
these effects.

Host models do not
measure specific gases

Hay not function properly
in oxygen deficient
atmospheres
                                                            Approximately
                                                            $500-700
ENMET Corp.
Ann Arbor, MI

National Mine Service
Co. Pittsburgh,  PA

Gas Tech
Mountain View, CA
         Oxygen Deficiency    Oxygen Meter
•  Direct readout  in percent  •  High humidity may cause
   oxygen                       interferencea.

•  Visual and  audible  alarm   •  Strong ox idants may cause
                                artificially high readout
•  Lightweight,  portable,
   and easy to use

•  Probe provide*  remote sensing
   capabilities

•  Accuracies  of *_ I percent are
   attainable, but  depend on the
   particular  model.

•  Generally 8-10 hr battery life
                                                           Approximately
                                                           $400-700
                                                 ENMET Corp.
                                                 Ann Arbor, MI.

                                                 National  Mine Service Co.
                                                 Pittsburgh,  FA

                                                 Gas Tech
                                                 Mountain  View, CA
                                                                                                                                            (continued)

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                                                         TABLE  12.   (continued)
Monitoring Need
Instrument
                                            Features
                                                                          Limitations
                                                                                                      Coat
                                                                                                                       Manufacturer!
Combustible Gas/    Combination
Oxygen Deficiency   Oxygen  Meter
                    and  Combustible
                    Gas  Detector.
Measure percent oxygen
and gas concentration
as a percentage of Lower
Explosive Limit (LED

Both visual and
audible alarm

Remote sensing capa-
bilites

Lightweight, portable, and
easy to use

Accuracies of *_ 2 percent
are attainable but may be
as high as j* 10 percent
depending on the models.
                                                  Same limitations as
                                                  oxygen  meters  and
                                                  combustible  gas
                                                  detectors
Approximately
$700-1,000
ENMET Corp.
Ann Arbor, MI

National Mine Service
Co., Pittsburgh,  PA.

Gas Tech
Mountain View, CA.
Toxic Gas/Vapors Photo ioniiat ion • Nonspecific gas and •
Detector (PID) vapor detection for both
(based on HNU organics and most
Systems PID) inorganics •

• Lightweight (4 kg or 9 Ib)
and portable •

• Sensitive to 0.5 pom
benzene. Sensitivity is
related to ionization
potential of compound
• Remote sensing
capabilities
Does not monitor for
specific gases or vapors

Cannot detect hydrogen
cyanide or methane

Cannot detect some
chlorinated organics






$6,345 including HNU System Inc.
the analyzer Newton, MA.
($3,745); portable
recorder ($445);
calibrated probe
assembly ($1,995);
audible alarm and
instrument corrosion
protection are also
available for $250




                                     •  Response time of  90  percent
                                        in less  than 3 seconds

                                     •  More sensitive to aromstics
                                        and unsaturated compounds
                                        than the flame ionization
                                        dectector (FID)

                                     •  10 hr battery operating
                                        life

                                     •  Audible  alarm is  available
                                                                                                                                     (continued)

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                                   TABLE  12.   (continued)
Monitoring Need
Toxic Gas /Vapors
(continued)







Instrument
Flame lonization •
Detector (FID)
(based on Century
Organic Vapor
Analyzer,
Model 128)



Features
In the survey mode it
f unc t ions as a non-
apecific total hydro-
carbon analyzer; in
the gas chromatograph
(GC) mode, it provides
tentative qualitative/
quantitative identi-
fication
Limitations
• Not suitable for inorganic
gases.

• Less sensitive to aro-
matics and unsaturated
compound a than FID

• Requirea skilled tech-
niciana to operate the
Coat
Organic Vapor
Analyzer $5,050;
GC with 2 columns,
$880; recorder, $410





Manufacturers
Foxboro Analytical
S. Norwalk, CT.







Infrared
Analyzer
(Based on Miran
Model IA)
•  Lightweight (5.4 kg or
   12 Ib) and portable

•  Remote sensing probe
   is available

•  Response time is 90
   percent in 2 sec

•  8 hr battery operating
   life

a  Sounds audible alarm when
   predetermined levels are
   exceeded

•  Overcomes the limits of
   most infrared (IR)
   analyzers by uae of a
   variable filter; can be
   used to scan through a
   portion of the spec trim to
   •ensure concentrations of
   several gases or can be
   set at a particular wave-
   length to measure a
   specific gaa
                                                  equipment in the GC mode
                                                  and to analyze the reaulta

                                                  Requirea changes of
                                                  columns and gas supply
                                                  when operated in the GC
                                                  mode

                                                  Since specific chemical
                                                  standards and calibration
                                                  columns are needed, the
                                                  operator must have some
                                                  idea of the identification
                                                  of the gas/vapor
Not aa aensitive as
the photoionization
detector or flame
ionization detector

Leas portable than other
methods of vapor/gas
detection

Requires skilled tech-
nician to operate and
analyze the reaulta when
positive chemical identi-
fication is needed.
Analyzer, $8,601

Closed loop
calibration, $540
Wilkea Infrared
Center, Foxboro
Analytic,
S. Norwalk, CT
                                                                                                                  (continued)

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                                                        TABLE  12.   (continued)
Monitoring Need
                    Instrument
                                            Features
                                                                          Limitation!
                                                                                                       Coat
                                                                                                                       Manufacturers
Toxic Gaa/Vapora    Infrared          •  Detect* both organic
  (continued)       Analyzer  (con't)     and inorganic gaeea

                                     •  Portable but not aa
                                        lightweight (14.5 kg or
                                        32 Ib) aa the photo-
                                        ionization or the flame
                                        ionizstion detectora
                              •  Requirea  power  aource
                    Detector  Tubea
•  Provides qualitative,
   semi-quantitative
   identification of
   volatile organica and
   inorganiea

•  Accuracy of only
   about + 25 percent.
                                                                   •  Low accuracy

                                                                   •  Subject to leakage
                                                                      during pumping

                                                                   a  Requirea previous
                                                                      knowledge of gases/
                                                                      vapora in order to
                                                                      select the appropriate
                                                                      detector tube.

                                                                   •  Sane chemicals interfere
                                                                      with color reaction
                                                                      to give false positive
                                                                      reading
                             Positive  identifi-
                             cation  requires
                             comparison  of  spec-
                             trum  from atrip
                             chart recorder with
                             published adsorption
                             spectrum; infrared
                             spectrum  ia not
                             available for  all
                             compounds

                             Multigaa  detector
                             kit,  including
                             hand  operated  pump,
                             stroke  counter,  and
                             carrying  case,
                             $200

                             Detector  tubes,
                             about $20 to $24
                             for package of 10

                             Detector  tubes are
                             not available  for
                             all gases
National Draeger,  Inc.
Pittsburgh, PA

Matheson Gas Products
East Rutherford, NJ

Bendix/CASTEC
Lewisburgh, WV
Radiation
                    Radiation
                    Meters
   Measures radiation in
   uR/hr (battery operated)

   Probe provides remote
   sensing capabilitiea

   Accuracy and aensitivity
   variea considerably with
   manufacturer and type of
   meter
Some meters do not deter- •  Start at about
mine type of radiation       $500
Solar Electronica
Summertown, TN

Reactor Experiments
Incorporated
San Carloa, CA

Ludlum Measurements
Sweetwater, TN
                                                                                                                                      (continued)

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                                                               TABLE  12.   (continued)
        Monitoring Need     Instrument
                                                   Features
                                                                               Limitations
                                                                                                           Coat
                                                                                                                           Manufacture™
Radiation
(continued)
Radiation
Meters
(continued)
• A variety of meters are
available. Some measure
total ionizing radiation;
others are specific for
ganna, alpha, or a comb in'
nation of two or more types
The mo Election
Sante Fe , NH
        Sources:  Mathamel,  1981; Spittler, 1980; McEnery,  1982; National Mine  Service Company, 1980; Gas-Tech, 1980;  Enmet, undated; Century  Syatem
                  Coporation, 1979; Foxboro Analytical,  1982; HNU Systems, 1982
N>

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      •   Built-in  pumping  capacity
      •   Explosion-proofing

      •   Sampling  range.


      For monitoring  toxic gases/vapors  and  oxygen deficient  atmospheres, the
 investigator  should  be  attuned  to the  advantages  and  limitations  of the
 different  equipment  types.

 Combustible Gas Detectors and Oxygen Meters —
      Combustible  gas detectors,  oxygen  meters,  and combination combustible
 gas/oxygen indicators are available  from  a  number of  manufacturers.   These
 instruments are easy to operate  and  reliable.   They are  available with  audio-
 visual  alarms, rechargeable battery  packs that  provide  from  8  to  12 hours  of
 continuous monitoring,  and remote sensing capabilities  that  are facilitated
 by attaching  the  sensor leads to  a detachable sensor  cable (Enmet,  undated;
 Gas Tech,  1980).

      The combustible gas detector does  not  express concentration  directly  but
 rather  as a percentage of the Lower Explosive Limit (LEL).   The LEL is
 defined  as the lowest concentration of  flammable  gas, by volume of air, that
 will  explode, ignite, or burn when there  is an  ignition  source.   Although  the
 combustible gas detector is simple to operate,  there  are many  physical  and
 chemical factors  that affect the  instrument's response.  The instrument will
 not record accurately in oxygen  deficient atmospheres.   Leaded gasoline,
 silicones, and silicates also can impair  the response.   However,  filters are
 available to minimize these effects (McEntry, 1982; Mathamel,  1981).

      The oxygen meter generally measures  oxygen concentrations in the range
 of 0  to 25 percent,  and the readout is  directly in percent oxygen.   High
 concentrations of strong oxidants  such  as chlorine will  result in erroneously
 high  oxygen readings (McEntry, 1982; Mathamel,  1981).

 Gas/Vapor Analyzers--
      The most widely used portable instruments  for monitoring  toxic  gases/
vapors  are the photoionization detector (FID),  the flame ionization  detector
 (FID),  the infrared  analyzer, and the detector  tube.

      Both the photoionization detector  and  the  flame  ionization detector can
be adapted with a gas chromatographic (GC)  column attachment to provide
 tentative identification and quantification of  hydrocarbons.

      The HNU Systems-photoionization detector (HNU-PID)  has broad applica-
bility  for detecting non-specific  gases (HNU System,  1982).  It can  detect
both  organic and  inorganic gases  but will not respond to methane.  Lack of
response to methane  can be an important feature in many  site investigations,
because it allows the detection of hazardous pollutant concentrations as low
as 0.1 ppm without interference  from ambient methane  concentrations,  which
can range from 2 to  10 ppm (Driscoll, undated).   Since the instrument works
on the photoionization principle,  sensitivity is  related to the wavelength of
the exciting lamp and the ionization potential  of the vapor  to  be measured.

                                      63

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The HNU-PID has a sensitivity of about 0.5 ppm benzene  and a response  time of
less than 90 percent  in 3 seconds.  The Century  Organic Vapor Analyzer (OVA)
Model  128 is a sensitive, non-specific hydrocarbon  flame  ionization  detector
when operated in the  total  survey mode (see  the  discussion below on  GC mode).
There  are a number of important similarities and differences between the
HNU-PID and the Century OVA 128.  Both instruments  are  lightweight,  have  a
rapid  response time,  and can be equipped with a  rechargeable battery,  a probe
for remote sensing, and an  audible alarm (Foxboro Co.,  1982; HNU Systems,
1976).  Unlike the HNU-PID, the OVA 128 responds to background methane but
does not respond to inorganic gases.  It is  less sensitive to aromatics and
unsaturated hydrocarbons but more sensitve to many chlorinated compounds
(Driscoll and Becker, 1979).

     The Century OVA  128 can be adapted with a GC column  attachment  useful
for separating mixtures of  gaseous compounds to  provide tentative compound
identification.  In the GC mode, the OVA 128 can determine the retention  time
of an  unknown compound.  By comparing the retention time  with that of  known
standards, a positive chemical identification can be made.  However, since
specific chemical standards and calibrated columns  are needed, an idea of the
nature of the waste components is needed prior to GC analysis.   Equipment
operation and data interpretation requires use of skilled operators.
Photovac, Inc., has developed a portable GC that operates on the photo-
ionization principle  (Photovac, Inc., 1980).  This  instrument is extremely
sensitive and is most applicable to situations where volatile components  are
present in the parts per billion (ppb) range.

     The Miran Infrared Analyzer also can be used as a nonspecific gas
detector or for specific compound identification.  The  instrument measures
the amount of infrared light absorbed by the gas being analyzed  at a selected
wavelength using a single beam infrared spectrometer (Foxboro, 1981).
Although somewhat simpler to use for positive compound  identification, the
instrument is less portable and less sensitive than the GC's discussed above.
The operator must have some idea of the nature of the vapor, since the wave-
length must be preset to determine the absorption spectra of specific  com-
pounds.  Positive chemical  identification requires comparison of printouts
from strip recorder charts with published absorption spectra.  Absorption
spectra are not available for all compounds.

     Detector tubes also have the capability of  providing qualitative, semi-
quantitative determinations.  The major advantage of this method is  that  they
are very simple to use.  However, detector tubes have low accuracy as  com-
pared  to GC and infrared analysis, response  time is slow, and they are
subject to leakage. (Gillespie, 1979; Rodgers, 1976).  It is not recommended
that they be used for onsite monitoring except as a backup to other  more
sensitive and accurate instruments.

     Use of a detector tube requires knowledge of the vapors present in order
to select the appropriate detector tube.  In some instances other waste
components may interfere with the reaction to give  a false reading (McEntry,
1982).
                                      64

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Radiation Meter3—
     There are three types of radiation that can be encountered  at hazardous
waste sites:  alpha, beta, and gamma.  Field personnel  should be equipped
with a portable alpha/beta/gamma survey meter.  Gamma radiation monitors that
respond with an audible alarm when gamma radiation is encountered should also
be worn since there is no convenient method of protecting workers from gamma
radiation.  In addition, dosimeters that provide an indication of total body
exposure to radiation over an extended period of time (time weighted  average)
should be worn (Gillespie, 1979).

Use of Monitoring Equipment—
     All sites must be checked for radioactivity, explosivity, oxygen levels,
and toxic gas levels during entry.   Once  it is established that site entry
is safe, air monitoring equipment is then  used to establish "zones of
concentration," hot, transition, and clean zones, which govern the types of
activities that can be conducted in each zone.

     When the actual drum handling operation begins, air monitoring equipment
should be relied on to monitor any changes that require evacuation or addi-
tional safety precautions, especially when conditions require contact with
the drums.  Specific uses of air monitoring equipment include:


     •  Scanning the excavation area before and during  the use of hand tools
        or other equipment that require working close to a drum burial area.

     •  Approaching the drums cautiously once the earth is removed from
        around the drums and scanning the  immediate area before making any
        physical contact with the drums (lifting, attaching slings or yokes,
        loading drums onto vehicles for hauling, opening, etc.).  Critically
        swollen drains should be isolated  from field personnel until  the
        pressure can be released remotely.

     •  Relying on direct reading instruments and their audible alarm capa-
        bilities to indicate unsafe levels of pollutants or "hot spots"
        resulting from spills or release of vapors during drum opening,
        staging, consolidation, and loading.


Collection Media

     Where little information is available on drum contents and where funds
are available, it may be desirable to obtain positive identification  of air
pollutants.  Since this type of analysis is costly, it  is understandably kept
to a minimum.

     Positive identification is accomplished by chemically absorbing  pollu-
tants on collection media with sampling pumps and transporting the samples
for subsequent GC/MS or atomic absorption  analysis.  Mylar bags are also
available for collecting air samples but are not recommended unless analysis
is immediate.   Sampling pumps are commercially available in numerous  configu-
rations,  but an intrinsically safe National Institute for Occupational Safety

                                      65

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 and  Health  (NIOSH)  pump  is  recommended.   This  type  of  pump is  portable and
 light  enough  so  that  it  can be worn  by personnel.   Table 13 summarizes
 applications  for collection media  and  the required  laboratory  analysis.

     In  using  collection media,  it is  advisable  to  place pumps in several
 strategic locations.  They  could be  placed within work areas as  well  as
 upwind and  downwind of the  site.   They should  also  be  placed near drums for
 positive identification  of  drum  contents.  If  needed,  the PID  or FID  can be
 used to  locate hot  spots Where pumps should  be placed.


 VISUAL INSPECTIONS

     Visual inspection of drums  to determine their  integrity before lifting
 is a widespread  practice.   Relying on  air monitoring equipment to detect any
 potential problems, the  investigator carefully approaches the  drum, and the
 exposed  surface  is  examined for  obvious  corrosion,  swelling, punctures, and
 bungs.   This method,  though potentially unsafe,  is  commonly used where
 equipment such as front-end loaders  and  backhoes are being used  to lift
 drums, since under  these conditions, worker  safety  could be jeopardized if
 the drums rupture or  spill.  Where drum  integrity is questionable and only
 backhoes or front-end loaders are  available, investigators should opt to pump
 the contents of  the drum or place  the  drum in  an overpack rather than lift it
 on the basis of  their visual inspection.  The  use of the barrel  grappler with
 a plexiglas shield  (see  Section  7) minimizes the need  for visual inspections
 since worker exposure will  not result  from rupture.


 NONDESTRUCTIVE TESTING METHODS

     There are a number  of  nondestructive testing methods that have the
 capability of determining cracks,  fissures,  and the overall integrity of
metal surfaces.  Ultrasonics and eddy-current  techniques, for  example, have
been used to determine the  integrity of  storage tanks  and vessels and
 associated piping.  However, these methods have not been used  to date for
determining drum integrity.

     There are severe limitations  on the usefulness of these methods  for
 determining drum integrity.  For the methods to effectively detect cracks or
 fissures, the drum  surface must be fairly clean and chipped paint must be
brushed off.  This  implies  that  field  personnel must be  in contact with the
drum.  The second limitation is  that the integrity  of  the underside of a
buried drum cannot be determined.

     Since visual inspections are  a  fairly reliable indication of drum
 integrity at least  at the exposed  surface, there seems to be no  significant
 safety advantage to using existing nondestructive methods since  the field
worker must be in contact with the drum  regardless of  which method is used.
                                      66

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       TABLE 13;  SPECIFIC APPLICATIONS FOR AIR SAMPLE COLLECTION MEDIA
                  INCLUDING THE REQUIRED LABORATORY ANALYSIS
     Pollutant
    Collection Media
  Laboratory Analysis
Volatile organics
Particulate
 organics

Pesticides
 (including PCBs)


PBBs

Metals

Volatile inorganics

Particulate
 inorganics

Cyanides
Carbon tubes
Tenax tubes
XAD-2 tubes
Silica gel tubes

Glass fiber filters
Florisil tubes
Polyurethane plugs
Glass fiber filters

Glass fiber filters

Membrane filters

Impingers/reagent solutions

Membrane filters
Glass fiber filters

Filters/impingers
Gas chromatograph/mass
spectroscopy (GC/MS)
GC/MS
GC/MS
GC/Electron capture
GC/MS

Atomic absorption (AA)

Wet chemical methods

Wet chemical methods


Wet chemical methods
Mathamel, 1981.  Table originally printed in the Proceedings of The National
Conference on Management of Uncontrolled Hazardous Waste Sites, 1981.
Available from Hazardous Materials Control Research Institute, 9300 Columbia
Blvd., Silver Spring, MD  20910.
                                      67

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                                  SECTION 7

              EXCAVATION, REMOVAL, AND ONSITE HANDLING OF DRUMS


     Drum removal is required when it is more cost  effective  than  source
control measures or when it is necessary for the protection of public  health
and the environment.  Excavating, removing, and handling drums at  hazardous
waste sites are generally accomplished with conventional heavy construction
equipment.  This equipment includes vehicles used  for excavating,  lifting,
loading, hauling, dumping, grading, and compacting  onsite soil and waste
materials.  Equipment commonly used to excavate and transfer  waste containers
and soils at disposal sites includes the following:


     •  Crawler tractors (dozers  and loaders)

     •  Rubber-tired loaders
     •  Backhoes

     •  Barrel grapplers

     •  Forklift trucks
     •  Cranes, draglines, and clamshells

     •  Scrapers and haulers
     •  Industrial vacuum loaders

     •  Hand tools.


     In some instances this equipment  is modified  to improve  the safety and
efficiency of handling drums.  In other  instances,  specially  designed acces-
sories  such as slings, drum grabbers,  and nylon yokes  are  used  as  equipment
attachments for drum handling.  This section discusses  the  applications,
advantages, and limitations of equipment and  accessories  for  drum  handling,
emphasizing safety aspects and site-specific conditions  that  affect equipment
selection.  This section also discusses  specific  procedures for  excavating
drums.


DRUM EXCAVATION AND REMOVAL EQUIPMENT

     This  subsection describes conventional  equipment  and  methods  applicable
to  hazardous waste drum  excavation work.   Subsections  that  follow explain
specialized equipment  types and  accessories  used  in drum excavation and

                                       68

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removal, as well as selection  and use of equipment  combinations  used  in  drum
handling.  To  illustrate useful equipment combinations, we have  included case
histories of hazardous waste site drum excavation efforts.

Dozers and Loaders

     Dozers and loaders are generally equipped with a hydraulically control-
led (versus mechanical cable hoist) blade and bucket lift and  can  be  either
crawler-, or rubber-tire-mounted.  Crawler machines are equipped with self-
laying steel tracks of variable cleat design and width, which  provide good
ground contact and excellent flotation and traction capabilities.   For this
reason, crawlers are ideally suited for excavating  over rough, unstable
surfaces.  In marshy or swampy areas where mobility is limited,  extra wide
tracks are recommended to improve traction.

     Dozers and loaders are also available with large rubber-tired wheels
that are faster and more mobile than crawler machines on level terrain.
Their ability to maneuver on rough, muddy, and sloping terrain,  however,
depends somewhat on the type of tires.  For example, tires with  a  wide base
and low air pressure provide good flotation and traction (Church,  1981).

     Crawler dozers equipped with blades of various sizes and  shapes
(straight to U-shaped) have tremendous earth-moving power and  are  excellent
graders.  In drum excavation work these dozers can  remove miscellaneous  fill
or soil overburden, or they can push earth and undamaged or  empty  drums  from
unstable surface areas to more accessible areas for lifting  and  loading
operations.  The dozers are usually used in combination with other excavation
equipment such as backhoes.

     Front-end loaders are tractors equipped with buckets for  digging,
lifting, hauling, and dumping materials.  Both crawler-mounted and
rubber-tired front-end loaders are widely used in hauling and  staging
undamaged drums (Figure 6).  However, because lifting and loading  drums  onto
front-end loaders usually requires manual assistance, their  use  should be
limited to structurally sound drums.

     The crawler loader is an excellent excavator that can carry materials  as
far as 90 meters (300 feet) (Brunner, 1972).  Front-end buckets  vary  in
capacity and design.  Medium-sized crawler loaders  typically have  maximum
bucket capacities of 3.8 to 4.5 cubic meters (5-6 cubic yards).  Wheel-
mounted bucket loaders, for high-production operations on stable surfaces
such as paved areas, have bucket capacities to 15 cubic meters (20 cubic
yards).

     The multiple-purpose bucket, also known as a "bull clam"  or "4-in-l,"  is
a hydraulically operated, hinged loader that will clamp onto drums and lift
and haul them.  When using the bull clam with "choker chains"  to bind the
drums together, three or four drums can be moved at a time (Brunner,  1972).

      One widely used model of rubber-tired front-end loaders  is the  "Bobcat"
series manufactured by Clark Equipment Company (Figure 7).   This machine is
well suited for drum loading and transporting on stable working  surfaces and

                                      69

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                                                                                Mi,;,
--4
o
                                Figure 6.  Front-End  Loader Hauling Drums at Waste  Site


                                               Source:   U.S. EPA, 1980a

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1.   Loader 742 DS has DS rating by NFPA for fire hazards.
2.   Special Applications Kit has operator protection at cab
    openings.

Figure 7.  Bobcat Rubber-Tired Loader and Attachments

     (Courtesy of Clark Equipment Co. Fargo, ND)

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can be equipped with a variety of hydraulically controlled bucket, grapple,
and lifting attachments.  The bobcat can also be converted to an agile,
small-capacity backhoe excavator.

Backhoes

     Backhoes (Figure 8), also known as pull shovels or power hoes, are
generally crawler-%ounted, hydraulically operated vehicles with various sized
steel-toothed buckets ("dippers") attached to boom and dipper-arm assemblies
of varying lengths.  Backhoes are used for trenching and subsurface excava-
tion.  They can dig as deep as 11 to 12 meters (35-40 feet), carry from 0.2
to 2.7 cubic meters (0.25-3.5 cubic yards) of material, and reach up to 18
meters (60 feet).

     Backhoes are  the most versatile and widely used vehicles for drum
handling.  They are suitable for removing the soil covering the drums and  for
excavating and lifting the drums.  Their long boom assemblies permit removal
of drums from considerable depths' and  allow the equipment operator to work
away from immediate and potentially unsafe disposal areas.  When drums are
buried deeper than the maximum reach of the backhoe's boom and dipper
assembly, a "working bench" can be excavated for the backhoe next to the
trench so that the vehicle can excavate to the required depth.  There are
also several modifications to the conventional backhoe that can further
increase its versatility.

     Smaller backhoes with rubber tires are useful for fast excavation on
stable working surfaces.  One frequently used smaller backhoe is a wheel-
mounted combination backhoe and  front-end loader (Figure 9).  This vehicle
can excavate, lift, load, haul, and dump soil and waste materials (including
both crushed and undamaged drums).  Its operation, however, is generally
restricted to relatively flat and stable working surfaces.

     The conventional backhoe dipper shovel can be replaced by several types
of special purpose, hydraulically controlled accessory attachments,
including:


     •  Drum grapple
     •  Clamshell  buckets

     •  Loader buckets

     •  Air percussion hammers

     •  Rotating drum grapples
     •  Drum plungers for sample collection (see Section 8).


     Perhaps the most useful backhoe attachment  for drum excavation work  is
the drum grapple.  This articulated backhoe attachment incorporates wrist
action motion and  can rotate 360 degrees  along  the plane of  its attachment
assembly platform.  The grapple  also hydraulically self adjusts its grip


                                       72

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i
»«-..., .^ffiutztjir jwz/WMapKD;!
                                 Reproduced  from
                                 bes> available  copy.
             Figure  8.
American Backhoe  Loading  Excavated  Soil Onto  Truck


  (Courtesy of  Amhoist,  St. Paul, MN)

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,v
      Figure 9.  Modified Backhoe (Barrel Grappler) Loading Drums Onto
                 Combination Backhoe and Front-End Loader

                 (Courtesy of O.H. Materials, Findlay, OH)

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radius so  that it can grab  and  lift containers of various  size  and  lower  them
gradually  without spillage  (verbal communication with J. Walker and R.
Panning, O.H. Materials Co., Findlay, Ohio).  When the drum  grapple assembly
is attached  to a backhoe dipper  arm, the conventional backhoe becomes what  is
known as a "grappler" (Figure 10).

Grapplers

     Grapplers, as discussed above, are specially modified crawler-mounted
hydraulic  backhoes with rotating drum grapple heads replacing the con-
ventional  dipper bucket.  One design by O.H. Materials for hazardous waste
work, has  a  grapple and dipper-arm assembly with a reach in  excess  of 9
meters (30 feet) and is used with a Caterpillar 215 or 225 backhoe. The  R.J.
Gorman Co.,  and United Hydraulics of Eugene, Oregon, have  also  designed
grapplers  with similar capabilities.

     When  controlled by experienced backhoe operators, the grappler can
safely and efficiently grab, lift, and relocate or dump hazardous waste
drums; and selectively remove partially buried or totally  uncovered drums,
one at a time from trench excavations, waste disposal pits,  and other drum
disposal areas of varying slope  and roughness (Figure 11).   It  is partic-
ularly useful in selectively removing drums from stacks piled several drums
high and from the upper floors of drum storage or disposal warehouses; and
can be used  for relocating  and  segregating undamaged waste drums, overpacking
damaged drums, and as a "scrap grabber" for rapidly lifting, moving, and
dumping a number of damaged drums at the same time.

Forklift Trucks

     Heavy-duty, rubber-tired forklift trucks are widely used in drum
handling operations.  The advantage of the forklift truck  is that it is
compact, maneuverable, and very versatile.  Its use in drum  handling depends
largely on the type of forklift  attachment with which it is  adapted.  The
various attachments are discussed in the subsection "Accessories for Drum
Excavation Equipment."  When adapted with drum grabbers, the forklift
efficiently  stages, segregates,  and loads structurally sound drums  that  are
upright.  When used with drum lifting hooks and slings, the  forklift can  lift
drums from shallow disposal areas.  This operation, however, requires manual
assistance from field personnel  and, therefore, should be  used  when drums are
structurally sound.

Cranes, Clamshells, and Draglines

     Large cable-operated cranes are sometimes fitted with clamshell buckets,
(Figure 12) drum grapples, magnets, hoists, slings, and lifters for large-
scale drum excavation, lifting,  and staging at sites with  unrestricted
working space.  They can also be adapted for use as dragline excavators
(Figure 13)  for deeper excavations over large areas.

     Clamshells and dragline excavators with bucket capacities  up to
4.6 cubic meters (6 cubic yards) and booms as long as 30 meters (100 feet)
can excavate heavy loads from depths of 15 to 18 meters (50-60  feet).

                                      75

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       Figure 10.  The Barrel Grapple.r




(Courtesy of O.H. Materials Co., Find!ay,  OH)

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Figure 11.   Barrel Grappler Removing Drums from Pit Excavation




         (Ctourtesy of O.K. Materials Co., Findlay, OH)

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Figure 12. Clamshell Bucket for Crane Attachment
          (Source: U.S. EPA, 1982b)
       Figure 13. A Dragline
                 (Source: U.S. EPA, 1982b)
                      70

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Because of  their  long reach  and deep  excavation  capabilities,  clamshells,
draglines,  and  other crane-based  operations  are  indispensable  in  some drum
handling operations.  They are economical  for  large-scale  drum removal where
drums are buried  deeper  than 9 to  12  meters  (30-40  feet) .  Wheel-mounted
cranes equipped with long booms can lift drums from warehouses or congested
urban areas  that  are inaccessible  to  other types of equipment.

     Cranes  are either crawler-mounted  for better stability  over  rough, muddy
terrain or  wheel-mounted  for mobility on more  stable  surfaces. Cranes also
can be mounted on barges  for drum  removal  from congested,  urban disposal
areas accessible  only from adjacent rivers or  bays.  Smaller,  rubber-tired,
truck-mounted hydraulic  cranes ("cherry pickers") are  useful in drum lifting
and staging  in confined  working areas with stable surfaces.

     Although clamshells  and draglines  have  excellent  lifting  power, they  are
limited in mobility and  rotation  speed, which  slows drum lifting  and staging
operations.  Smaller, hydraulic backhoes equipped with wrist action  dippers
or grapples  are more mobile, dexterous, and  generally better adapted than
cranes and  draglines for  combined  drum  excavation and  relocation  operations.

Scrapers and Haulers

     The use of wheel-mounted scrapers  in drum excavation  work are generally
used to remove and haul  surface cover material at large  disposal  sites where
drums are known to be buried at given depths or  in  given areas (discrete
trenches or  pits).  They  are also  useful in  respreading  and  compacting cover
soils after  drum  removal.

     Scrapers are available  as both self-propelled, self-loading  vehicles,
and as models that are push-loaded by crawler  tractors.   Soft- to medium-
density cover soils and  fill favor the  self-loading scraper; medium  to hard
rock and earth favor the  use of the push-loaded  machine.   The  hauling
capacities of scrapers range from  1.5 to 30  cubic meters (2  to 40 cubic
yards).  These earthmoving machines can haul cover  material  economically over
relatively  long distances—more than  300 meters  (1,000 feet) for  self-
propelled scrapers (Church,  1981).

     A variety of haul trucks are  available  for  transporting excavated
materials and waste drums, both off-the-road and on-the-road.   Haulers are
large rubber-tired vehicles  available as single-trailer,  2-, or 3-axle
vehicles and as double-trailer, multiple-axle  haulers.   Their  rated  haul
capacities range  from 0.9 to 91 metric  tons  (1-100  tons),  and  they are
available as bottom-dump, rear-dump,  and side-dump  vehicles.   Small  1- and
2-MT (1-2 ton) haul trucks are used most commonly in drum  transport
operations.  Simple flatbed  or enclosed trailer  trucks of  varying lengths  are
also used in offsite transport of excavated  drums.

     At hazardous waste disposal sites, haul trucks are most useful  for
hauling excavated drums  (damaged or undamaged) to offsite  secure  landfills or
selected drum reburial sites.  Drums  can be  carefully  loaded onto and removed
from haulers using backhoes, cranes,  loaders,  and forklift trucks, usually


                                      79

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with manual  assistance  from  field workers.   Barrel  grapplers,  however,  can
usually perform this  task without manual  assistance.

Industrial Vacuum Loaders

     Industrial vacuum  loaders (Figure  14)  such  as  the  "Supersucker"  (Super
Products, undated)  and  the "Vactor"  (Peabody Myers, undated) can be used  in
large-scale  drum removal operations  to  remove remaining soil or pool-s of
liquid waste  from around the drums during excavation.   Using industrial
loaders for  soil removal is  safer and more  efficient  than  using hand  tools.
The Supersucker and the Vactor are vehicle-mounted, high-strength vacuums
that can carry solids,  liquids, metal,  and  plastic  scraps  and  almost  any
other material that can fit  through  a 20  cm (8 in)  hose.   They are equipped
with a boom  and up  to 150 meters (500 feet)  of hose that allow them to  convey
materials from otherwise inaccessible areas.  Their mobility and large
capacity eliminate  the  need  to transfer materials to  other vehicles before
hauling for disposal or treatment.   Vacuum  loaders  can  operate in either  a
solids or liquids handling mode.  Changing  modes can  be done quickly  with  an
exterior adjustment and without emptying  the load (Figure  15).  This  allows
the Vactor or Supersucker to convey  both  soils and  pools of liquid waste
without dumping the load.

Hand Tools

     Direct handling of drums by field workers is often necessary during  drum
excavation,  lifting, and unloading operations.   However, these operations
should be minimized to  limit worker  exposure to  waste-related  hazards,  and
the workers should be outfitted at all  times with appropriate  protective
clothing and safety devices.

     There are a number of conventional and specialized tools  available for
direct handling of waste containers.  Activities that may  require such
handling include the following:


     •  Removing soil and debris from around the surface of drums before
        excavation

     •  Excavating  and  removing drums from  critical areas  (next to buried  gas
        lines, adjacent drums with noncompatible wastes, building
        foundations , etc.)

     •  Placing chains, grippers/lifters, hoists/hooks, and slings around
        drums for lifting and transporting  by front-end loaders, cranes,
        forklifts, etc.

     •  Excavating  and  segregating small numbers of drums  «10) in scattered
        locations

     •  Staging and segregating drums in  storage areas
                                      80

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(II
                                                                                        oo

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                                 Solids Mode Flow Diagram
                                         Quad Filtration
   Rotary Blower
     Silencer
                                Bag Filter
  External
Screen Control
                                                             Secondary Top Inlet
                                                                Hydraulic Boom
                  Solid/Fluid Micro Strainer   ^Dust Box
      Rotary Blower
                                 Liquids Mode Flow Diagram
                                         Tripte Filtration

                        Filter Bags Are Bypassed by         External
                        Internal Ducting When Operated      Screen
                        on Liquids Modef^™0^^™'^^     Cor)
                       External Auger
                       Discharge Shut-Off
                   Centrifugal Separator
                   Solid/Fluid Micro Strainer
Figure 15.  Liquids and  Solids Handling  by  an Industrial Vacuum  Loader
              (Courtesy of  Peabody-Myers, Streator,  ID
                                              82

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        Opening drums  for  sample collection  and compatibility  testing  (see
        Section 8).
It  should be noted  that mechanical  equipment can  successfully  replace  hand
operations in most of these  instances, depending  on  safety  and  cost
tradeoffs.

     Hand tools useful in excavating and removing drums  include shovels  and
picks made of special non-sparking manganese-bronze, molybdenum, or  aluminum
alloys.  Hand-operated pneumatic  jackhammers are  useful  for excavating
through pavement, rock, or brick  to get  to buried drums.  Drum trucks
(special hand trucks) and drum  dollies can be  used  for  transporting  excavated
drums over short distances.  Additional  equipment and accessories  used for
drum lifting and handling are discussed  in the  following section.
ACCESSORIES FOR DRUM EXCAVATION EQUIPMENT

     There are a number of commercially available  equipment  accessories  that
can be used in drum handling (excavation,  lifting,  and  transport)  at  hazard-
ous waste sites.  These accessories are generally  designed  for  conventional
use as attachments to forklift trucks or in manual  container handling
operations.  However, they may be adapted  for use  with  other drum  excavation
equipment discussed in the previous section.  Other  accessories  include
health and safety equipment available for  routine  use during drum  excavation
work where drum explosions or ruptures may pose a  threat  to  field  workers  and
equipment operators.

Drum Lifting and Transfer Accessories

     There are several types of drum excavation and  lifting  accessories  for
backhoes and cranes (e.g., magnets, loader buckets,  clamshell and  dragline
buckets, and drum grapples).  These accessories have been discussed  in the
previous subsection.  Other accessories include drum slings  and  hoist attach-
ments, drum grippers, and drum lifters and dumpers.

     Drum lifting attachments and slings include heavy-duty nylon  yokes  and
straps and a variety of steel or metal alloy mechanical hoist attachments
(Figure 16) of variable capacity (up to 1800 kg or 4000 Ib).  The  attachments
are adjustable for different drum heights  and diameters,  and some  models can
lift at any angle (BASCO, 1982).  They can be used on backhoes,  cranes,  and
forklift trucks.

     Drum lifting attachments are most useful to lift and relocate drums to
staging areas in congested, hard to access areas of  waste sites.   Drums
lifted with most of these attachments must be structurally sound and  should
not contain explosive or shock-sensitive wastes.  Wide nylon or  canvas yokes
are the best suited attachments for handling drums of questionable integrity
since they can be wrapped around the drum  so as to  exert  little  pressure or
stress on any particular part of the drum.  The major disadvantage of using
these lifting attachments is that workers must be near  the drums to  properly

                                      83

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(a)
(b)
(c)
    (a)  Lifting hook for handling any type of drum.
    (b)  Drum band for handling and emptying 55 gallon
        drums with forklift.
    (c)  Drum lifting hook for steel drums (may be
        used with barrels).
     Figure 16.  Mechanical Drum Lifting Attachments

            (Courtesy of BASCO,  Chicago, IL)
                             84

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(d) Adjustable slings for handling barrels
    horizontally; vertical slings are also available,
(e) Drum chime tongs to handle drums in upright
    position with or without heads.
(f) Crank operated drum lifter.
               Figure 16.  (continued)

          (Courtesy of BASCO, Chicago, IL)
                         85

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position and secure the slings, chains, yokes, etc.  These operations tend to
be time consuming as well as dangerous if the drum contents are unknown or
hazardous.  Drums could easily be damaged during these operations and leaks
could occur.  For lifting drums that may contain flammable wastes, lifting
attachments must be made of nonsparking materials such as nylon, canvas,
rope, or bronze.

     Drum grippers (Figure 17), also known as drum totes or grabbers, are
forklift attachments that can also be adapted to crawler-mounted backhoes and
loaders for lifting and transporting drums.  Adjustable drum totes can handle
two similar or different sized drums simultaneously (30- and 55-gallons),
with a maximum capacity of 680 kilograms per drum (1,500 Ib) (BASCO, 1982).
Drum totes are most useful as forklift attachments for relocating and
segregating drums that have been stacked upright at waste disposal sites.  A
single drum grabber on a backhoe boom or loader can selectively remove drums
from exposed waste trenches or pits provided the drums are in an upright
position.

     Drum lifters and dumpers are available as hydraulically or mechanically
operated forklift attachments, as manually operated hoist or crane attach-
ments (Figures 18 and 19), and as portable low- and high-level hydraulic
dumpers (Figure 20).  These equipment types are useful for stacking  struc-
turally sound drums in temporary storage areas, elevating drums to loading
platforms or flatbed trucks, and dumping the contents of drums into
"compatibility chambers" (Section 9).

     The drum grabbers, grippers, and lifters described above may not be
cost effective for a large site in which many drums must be transported
efficiently from the excavation area to a staging area.  Grouping drums onto
a compartmentalized "scale pan" for removal by flat bed truck with loading
and unloading capability may be more suitable where site conditions  permit
truck traffic.  Another alternative would be to construct a "drum sled"
similar to the conceptual design shown in Figure 21 (Perkins Jordan  Inc.,
1982).  The sled, which can be attached to a dozer, can haul drums over level
or gently sloping terrain.

Worker Safety and Drum Protection Accessories

     Equipment accessories used for operator safety and drum protection
include plexiglas safety shields for vehicle cabs (Figure 22) and steel bars,
or "morman bars ."

     Plexiglas safety shields are installed to provide an explosion- and
splatter-proof layer around the cabs of backhoes, loaders, and cranes when
excavating drums of explosive or liquid hazardous wastes.  They should also
be used on forklift trucks, in which the operator is near to the drums being
handled.

     Morman bars are cast-iron bars that are placed over the teeth of various
excavator buckets (backhoe dippers, loader buckets, dozer blades, clamshells)
to blunt the digging edge of the buckets to avoid drum punctures and spills.
                                      86

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Adjusted for two 55-galion drums,        ...for one 55- and one 30-gallon drums,
  ...for two 30-gallon drums,
...for one 55-gallon drum...
     Figure 17. Drum Gripper Attachment for Forklifts
                (Courtesy of BASCO, Chicago, ID
                              87

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               Figure 18.  Hydraulic Drum Grab

              (Courtesy of BASCO, Chicago, IL)
Figure 19.  Forklift-Mounted Drum Dumper and Hoistei—Crane-
            Mounted Drum Dumper

             (Courtesy of BASCO, Chicago, IL)
                           88

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Figure 20.  Portable Hydraulic Drum Dumper




     (Courtesy of BASCO, Chicago, IL)
                  89

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                              I' PLYWOOD DIVIDERS
                                                                           2* BAY SUPPORT POSTS
V0
O
                                                                                       CHAIN WITH LATCH
                                                                                             " WOOD SKIDS
                                                                              t* GRATING WITH
                                                                              ANGLE IRON SUPPORTS
           6* DEEP DRIP PAN RUNS LENGTH OF SLED.
           HOLDS 300 GALLONS ON LEVEL GROUND.
           66 GA1LONS ON 10% SLOPE.
                                                                 TIE RODS FOR SKID STABILITY
NOTE: THIS SKETCH FOR

     ILLUSTRATIVE PURPOSES ONLY.
     NOT FOR CONSTRUCTION.
                     Figure 21. Drum Sled
                              Note: The sled has not been used in actual field conditions
                              (Reprinted from Perkins Jordan, Inc., 1982 with permission of the
                              Rhode Island Department of Environmental Management)

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                        Reproduced from
                        best available copy.
Figure 22.  Plexiglas  Safety Shield on  Cap of Grappler During
            Overpacking Operation (Note second backhoe in back-
            ground)

        (Courtesy of O.H.  Materials Co.,  Findlay, OH)

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Such bars can also be custom made of nonsparking metal alloys for excavating
potentially explosive drums.  Excavating buckets fitted with nonsparking
teeth provide additional protection when working with potentially explosive
drums.

     Safety accessories that should be carried in the cabs of all vehicles
involved in drum handling include fire extinguishers, spare respirators and
respirator cartridges, and self-contained breathing apparatus (SCBA) with air
tanks and harnesses.  Field workers should wear appropriate protective
clothing at all times.


SELECTION AND USE OF DRUM EXCAVATION AND REMOVAL EQUIPMENT

     Drum excavation and removal equipment is used to perform several
distinct, important functions including the following:


     •  Excavating to the depth of buried drums and removing surface cover
        over buried drums

     •  Excavating around buried drums to free them for removal

     •  Removing (lifting) drums from exposed pits and trenches

     •  Loading and transporting drums to onsite storage  areas

     •  Sampling, segregating, bulking, storing, and recontainerizing  (e.g.,
        overpacking) drums

     •  Transporting offsite for appropriate storage, treatment, or disposal.


     The choice of equipment for drum handling is based on  inherent capabil-
ities and limitations of the equipment, site-specific conditions that  affect
equipment performance, the necessity to protect worker safety,  and costs.
Table 14 summarizes the capabilities and limitations of the drum excavation
and removal equipment considered for this manual.  Generally, a combination of
equipment and accessories is required for a particular drum handling  problem.
Table 15 summarizes the effect that site-specific factors and safety have  on
equipment selection and use.

     The most significant ways to improve the safety of a drum  handling
operation are to keep the operation as remote from workers as possible,  to
avoid sudden releases of chemicals if the operation cannot be remote,  and  to
provide adequate safety gear and equipment to protect the worker if spillage
or contact with the drums is unavoidable.  Implementing these precautionary
measures should be an overriding factor in selecting equipment  for  excavating
and manipulating drums.
                                       92

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TABLE 14.  DRUM EXCAVATION/REMOVAL EQUIPMENT CAPABILITIES AMD LIMITATIONS
Main Function* and Capabilities
Gross Cross
Equipment Type ' Excavation Excavation*
of Cover to Depth*
Material*
Crawler docer* X X
(and attachment*)
Crawler loader*
(and attachment*) X
Rubber-tired loader* '
(and attachment*) X
Bacfchoe*
(and attachments) X X
Crapplert
(modified backhoes)
Crane* and attachment*
(magnets, clamshells, X X
draglines, etc.)
Scrapers X
Box Trailer*
Hand Tools/Hand
Manipulation
Precise Drum Drum Drum Long
Excavation* Lifting Loading Segregation 4 Distance
Around Drissa 4 Transfer 4 Onsite Recontainer- Hauling/
Transport ization Offsite Major Limitations and
Transport Disadvantagea
XXX Limited speed and mobility
Generally require* losding of
X XX drum* by hand; short-distance
transport only
Restricted to fairly stable
X XX surf sees; generslly requires
loading of drums by hand
Very versatile but cannot mani-
X X . X pulate drums without worker
intervention
Host veraatile type of equipment
XXX but limited to handling one
drum at a time
'Very limited mobility; slow
X X
X X Imprecise loading action;
requires manual assistance
for drum loading
X X Used only to transport drums
offsite

with Wai tea
                                                                                   (cnnt i inued)

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TABLE  14.  (continued)
Main Functions and Capabilitiea

Equipment Type



Forklift Truck*
(and attachxienta)

Drum Lifter* and
Diaaper*


Industrial Vacuum
Loader*
Gro** Groes Precise Driaa Dria*
Excavation Excavation* Excavation* Lifting Loading
of Cover to Depth* Around Drun* & Transfer I Onsite
Materiala Transport


X X

X X




X X
Drias
Segregation i
Recontainer-
izat ion


X

X





l-ong
Distance
Hauling/
Offaite Hajor Limitation* and
Transport Disadvantage*
Limited to stable working
surface* and to lifting drum*
in an upright poaition
Cloae worker contact with
vastes; one drua at a time;
driaaa must be upright for •
grabbing
Costly to contract equipment;
coat effective only for large
                                              acale operations

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                              TABLE 15.   EFFECT  OF SITE-SPECIFIC VARIABLES  ON SELECTION AND USE
                                            OF  DRUM EXCAVATION AND HANDLING EQUIPMENT
Site Variable
Acceaaibility
Equipment Reconmendationa
• Remote wooded site may require clearing.
Major Site Problems/Consideration*
• In remote wooded sites, geo-
Ul
grubbing, and road construction;   crawler
tractors, dozers, and scrapers  would
be used

If site is readily accessible,  rubber-tired
vehicles should be used  because of their higher
efficiency

Congested urban sites require use  of  small
equipment, such as forklifts and bobcats; may
require use of slings or yokes  attached to
backhoes or crane if drums are  located
in a warehouse or building

Industrial vacuum loaders with  long hoses (up
to ISO m or 500 ft) can  be useful  in  removing
soil around drums in areas that are inaccess-
ible to large excavation equipment
                                                                                              physical testing  should be
                                                                                              conducted prior to  clearing
                                                                                              and road construction  to mini-
                                                                                              mize the possibility of ruptur-
                                                                                              ing drums with equipment

                                                                                              Population and worker  exposure
                                                                                              are of particular concern  in
                                                                                              congested areas;  extensive
                                                                                              air monitoring is required
             Number of Drums
Where a large number of drums  are  involved, use
high-product ion equipment,  such  as  the barrel
grappler and industrial vacuum loaders

Where few drums « 500) are involved, efforts
should be made to limit the number  and types of
equipment; front-end loaders and bobcata may be
suitable at small sites, but the condition of the
drums must be considered in selecting appropriate
equipment
Economics are a major  concern
where large numbers or small
numbers of drums are involved;
however, worker safety is not
compromised in efforts to
save money
                                                                                                                   (continued)

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                                                         TABLE  15.   (continued)
             Site Variable
       Equipment Recommendations
Major Site Problems/Considerations
             Drum Integrity
vo
The barrel grappler ia recommended, however,
liners or dikes should be used in the work
area to contain apilla if drum* rupture; work
areas should be diked and plexiglas shields
should be used on vehicle cabs; drums should
be handled individually to avoid mixing
incompatible wastes; highly over pressurized
drums should be isolated by barriera and
vented before handling

Where drum integrity is poor, contents should be
transferred or drums overpacked rather
than hauled
   Worker aafety and environmental
   releases are of overriding
   concern; every effort should
   be made to avoid mixing
   incompatible wastes and handling
   explosives of overpressurized
   drums
             Water Table
If water table is high, site may require drainage
prior to drum handling

Crawler-mounted vehicles or flotation tirea are
recommended for swampy, marshy areas; swamp pads
and timber mats may improve accessibility

Where water table is low, rubber-tired vehicles can
generally be used efficiently
   Contamination of water and
   groundwater

   Drum integrity is likely to be
   poor where drums have been in
   contact with water
             Highly Toxic/
             Hazardous
Where highly toxic materials are being handled,
the operation should be as remote as possible;
the drum grappler should be used where possible
with precautions taken to contain apilla within
the work area
   Worker safety and environmental
   releases are an overriding
   concern
                                                                                                                     (continued)

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                                                         TABLE  15.   (continued)
             Site Variable
                                                Equipment  Recommendations
                                                     Major  Site  Problems/Considerations
             Highly Toxic/
             Hazardous (continued)
vO '
 Radioactive,  explosive,  and  shock-sensitive
 materials  should  be  moved  remotely to  an
 isolated  staging  area.

 Where the  drum grappler  cannot  be used,  drums
 should be  handled one at a time;  where a
 backhoe is used,  nonsparking bucket teeth
 and  a moman  bar  should  be uaed;  aplaahes in
 the  vicinity  of workers  should  be avoided;
 if drum grabbers  are used  for overpack ing,
•workers should leave the immediate vicinity
 before the drum ia lowered into over pack;
 vehicle operator  should  be protected by  a
 plexiglas.shield
                                                                                                Where  drum  integrity  is  poor,
                                                                                                contents  should be  transferred
                                                                                                or  drums  should be  overpacked
             Depth of Burial
 Evacuation  of  subsurface drums  generally
 requires  use of a backhoe or  grappler;  a grappler
 ia more adept  at  removing drtnta from  parallel
 trenches, while the  conventional  backhoe ia
 limited to  excavation  from above; use no man .
 bars  and  plexiglaa shields on vehicles  when
 dealing with unknowns

 Drums  that  are very  deep may  require  use
 of a  clamshell or dragline during excavation

 Drums  on  the surface can he handled using
 loaders ,ind  forklift trucks providing drum
 integrity is good
Where drums are buried beneath
the surface, contents are fre-
quently unknown requiring that
all safety precautions be taken;
although geophysical surveying
may have been done, exact
location of drums ia not a
certainty

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     The final factor that influences the selection of equipment is the cost
to complete the cleanup.  Factors that should be considered in estimating
costs include:


     •  Equipment efficiency under site-specific conditions

     •  Equipment dispatching time (transport and setup)

     •  Contractor performance record with equipment

     •  Equipment idle time and how it can be minimized

     •  Equipment versatility to perform several functions

     •  Adaptation of equipment to increase efficiency.


EXCAVATION/REMOVAL PROCEDURES

     Regardless of the type of equipment used for drum excavating and
handling, certain standard operating procedures and safety practices should
be followed.

     As the soil around the drum is excavated with nonsparking hand tools or
an industrial vacuum and the face of the drum is exposed, a visual inspection
of the drum is made to determine whether it is empty, intact, leaking, or
potentially dangerous, as evidenced by bulking, buckling, corrosion, and
other deformations.  Onsite monitoring should also be done to determine
unsafe levels of volatile organics, explosives, or the presence of
radioactive materials (Section 6).  This preliminary visual inspection is the
basis for determining the appropriate mode of excavating and handling.

     Drum identification and inventory (Section 8) should begin before
excavation.  Information such as location, date of removal, drum identifi-
cation number, overpack status, and any other identification marks should be
recorded on the drum inventory forms.

Handling Precautions for Specific Waste/Container Types

     If there is an indication that the drums contain explosive or shock-
sensitive materials, they should be handled remotely, or as a minimum, with
vehicles equipped with plexiglas safety shields.   It is important to be able
to identify types of drums as possibly containing explosive materials.  For
instance, one cleanup contractor observed that drums without rolling hoops
that are not Department of Transportation (DOT) specification drums are
frequently of military origin and are likely to contain explosives or nerve
gas.  Also, small (5 gallon) pails, because of their convenient size, are
probably lab packs (personal communication with F. Klotzbach, SCA, Inc.,
Boston, MA, 1982).
                                      98

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      If  a  drum  is  critically  overpressurized,  it  should be  isolated  with  a
barricade  or  steel demolition net  until  the  pressure  can  be relieved remotely
(Section 8, Drum Opening  Tools).   If  it  is not  possible to  set  up  a
barricade,  a  tarpaulin may be used  to cover  the drum,  provided  the cloth  is
positioned  remotely using long  poles  or  rods.   However, it  must be cautioned
that  the mere weight of the tarpaulin or change in  position of  the drum could
cause rupture.  Slow venting  using  a  bung wrench  and  plastic cover over the
drum has worked for less  critical  situations; however, this should only be
attempted by  experienced  personnel  and extreme  caution should be exercised.

     Drums  containing ionized levels  of  radiation should  be handled  on a
site-specific basis.  Generally, when such drums  are  identified (via
radiation meters),  they are immediately  overpacked  using  remotely  operated
equipment  and moved to a  separate  staging area.   However, depending  on the
level of radiation, special shielding devices may be  required to protect
field personnel.   The Safety  Officer  should  be  consulted  if radioactive
material is encountered.  To  avoid  tracking  the radioactive material about
the site,  the equipment used  in handling the drums must be  decontaminated,
and any  radioactive soils immediately surrounding the  drum  should  be
excavated  and isolated.

     If  gas cylinders are encountered, they  should be moved promptly to an
area where  the temperature can be controlled, particularly  if they are
subjected  to  temperature  extremes or  direct  sunlight.  Gas  cylinders should
not be rolled, dragged, or slid, even for short distances.   Care should be
taken not  to drop  the cylinders or  allow them to  violently  strike  another
cylinder or drum (Matheson Gas Products,  undated).

     As  contaminated soils are excavated from the disposal  area, they should
be transferred to a temporary storage  area,  preferably a  diked  or  bermed area
lined with  plastic  or low permeability   clays.  A layer of  absorbent should
be placed on the bottom of the diked  area.

Handling Drums with Poor  Structural Integrity

     Any drum that  is leaking, badly  corroded,  or deformed  either  should be
overpacked  or the contents transferred,  by pumping, to a  new or reconditioned
drum.  If the drum  has a  small puncture  or leak,  it may be  possible  to use
wooden plugs, neoprene stoppers, etc., to temporarily plug  the  leak.  Wooden,
felt-covered plugs  are most effective because the wood and  felt expand to
contain  the leak.   In some instances, it may be possible  to transfer the drum
contents to a "compatibility" chamber or vacuum truck.  These procedures,
however, are usually used for bulking after  wastes have been identified
(Section 9) rather  than at this stage, since lack of knowledge  about waste
types could result  in incompatible waste reactions.

     As a rule, liquids contained in  drums that are leaking or  highly deter-
iorated  should be  immediately transferred to a new or reconditioned  drum.
Leaking drums containing  sludges or semisolids, drums that  are  structurally
sound but opened, or drums that are deteriorated  but moveable may  be
overpacked.
                                      99

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      It is generally safer to pump the contents of a structurally poor drum
 into a new drum,  since maneuvering the drum into an overpack may cause
 rupture.  Pumping is usually done with a skid-mounted vacuum pump.  Since the
 drum contents are unknown, it is necessary to use explosion-proof, chemically
 resistant pumps and to decontaminate the pump and hosing between transfers to
 avoid incompatible waste reactions.

      Overpacking  requires considerable skill on the part of the equipment
 operator because  of the narrow clearance between the overpack and the drum.
 Attachments suitable for overpacking include the backhoe-mounted grapple arm
 and  forklift trucks equipped with drum grabbers (Figures 23 and 24, respec-
 tively).  The grabbers, however, do not have the flexibility for lowering the
 drum into the overpack; consequently, their use may cause the drum contents
 to  splash out. Where the drums are slightly bent or dented, the dexterity of
 the  grappler arm  is particularly important for successful overpacking.
 Severely bent or  dented drums, however, are not suitable for overpacking.

      When liquids are being removed from a drum by pumping, a ground must be
 established between the drum and the receiving container if the container is
 metallic, or to a ground stake if the receiving container is not metallic.
 Such grounding will eliminate the buildup of significant static charges.  If
 the  liquid, such  as a solvent, does not conduct electricity, a very thin area
 where the solvent and the wall of the drum touch has an electrical imbalance.
 When the solvent  leaves the drum through a spout or bung hole, it carries
 some electrical charge.  The drum is left with a small and opposite elec-
 trical  charge, which increases as more solvent is drawn from it.  If this
 charge  becomes large enough and the drum comes in close contact with another
 surface such as the container or vessel to which the waste is being trans-
 ferred, a spark can result causing a fire or explosion.  Any spills that
 occur when drums  rupture should be cleaned up promptly using pumps or sorbent
 materials.

 Case Histories

      A  few case histories are presented below to illustrate the use of equip-
 ment for drum excavation, staging, and hauling.  Other operational aspects of
 these case studies (i.e., sampling, recordkeeping, etc.) are not discussed.

      At the Chemical Control site in Elizabeth, New Jersey, O.H. Materials
 Company used forklifts, front-end loaders, a barge-mounted crane, a specially
 developed barrel  grappler, and a team of 71 workers to remove over 40,000
 drums,  many of which were badly charred and damaged by a large explosion and
-fire.  The crane  and grappler were used to lift and relocate drums piled six
 to  ten  high at the congested site.  The grappler was able to remove and stage
 as many as 1,000  drums each day.  Forklifts equipped with drum grabber
 attachments were  initially employed to remove and overpack scattered, damaged
 drums and provide working space for the grappler and loader operations.  Some
 liquid  from leaking drums spilled out during overpacking.  Once the stacked
 drums were reduced to one to two layers, front-end loaders were used to
 segregate drums by waste type (solid, liquid, sludge) for subsequent sampling
 and  analysis.  Field crews often had to lift the damaged drums onto the
 loader  buckets by hand.  Extensive manual handling of drums was also required

                                       100

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Figure 23.   Use of the Grappler Attachment for Overpacking Drums




            (Courtesy of O.K.  Materials,  Findlay, OH)

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Figure 24.  Use of Forklift Grappler Attachment for Overpacking




         (Courtesy of Pollution Engineering Magazine)
                              102

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 for  the  crane  lifting operation.  Empty, damaged  drums were  crushed  with
 backhoe  and  loader buckets  and  disposed of  as bulk  contaminated  solids.
 Hydraulic compactors were also  used by O.K. Materials  for  drum crushing  and
 solids compaction.  (EPA Environmental Response Team,  Video  Tapes  of Chemical
 Control  Site Cleanup) (Finkel and Golob, 1981).

     At  the 3.2-hectare (8-acre) Picillo Farm dump  site  in Coventry, Rhode
 Island,  Peabody Clean Industries and R.J. Gorman  removed approximately
 5,000 drums from excavated  trenches using a barrel  grappler, crawler loaders,
 and backhoes (both crawler-mounted and rubber-tired).  The grappler  was  also
 used to  excavate and remove over 100 lab packs and  proved  very efficient and
 dexterous.  Drums were excavated at several angles  from  an open  trench and
 placed directly in a staging area with very little  shock to  the  drums.  The
 lab packs were segregated and field workers repacked  them.   Rubber-tired
 backhoes then hauled the drums  to temporary storage.   (EPA Environmental
 Response Team, Video Tape of Picillo Farm Site Cleanup.)

     Drum handling operations at the Gilson Road  Hazardous Waste Disposal
 Site in Nashua, New Hampshire,  involved the removal of approximately  •
 1,400 drums from four disposal  areas.  For  the most part,  the drums  had  been
 disposed of on the surface  or partially buried.   This  site was inaccessible
 to some of the heavy equipment  required for drum  removal and an  access road
 had to be constructed.  The drums were individually handled  and  moved to a
 staging  area using a heavy-duty forklift truck with a chain  or set of drum-
 lifting hooks.  Before moving,  each drum was visually  inspected  to check for
 drum integrity.  Leaking drums  were transferred or overpacked.   A  drum
 grabber attachment was also available for the forklift truck.  However,  the
 grabber was not effective in removing drums from  the  pile  because  of the
 haphazard manner in which the drums had been disposed  and  because, in many
 instances, the drums were stuck together.   Both the drum grabber attachment
 and the drum-lifting hooks were used to segregate the  drums  into compatible
waste classes, overpack damaged drums, and  load the drums  onto flatbed trucks
 (Recra Research Inc., 1980).

     As these case studies  illustrate, drum handling  efforts typically
 involve the combined use of several equipment types,  and in  the  absence  of
 the grappler, require close contact between workers and  drums in loading or
 attaching the drums onto buckets, grabbers, etc.  Drum removal equipment must
dig, grab, lift, load, haul, and manipulate drums.  These  functions  generally
require the use of at least two or three different machines  in addition  to
hand tools or the assistance of site workers.  However,  the  versatile barrel
grappler often eliminates the need for direct manipulation by field  person-
nel.  Again, the most efficient and cost effective combination of  equipment
types is determined by site-specific conditions and required activities.
                                      103

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                                  SECTION 8

                     DRUM STAGING, OPENING, AND SAMPLING
STAGING
     Once a drum has been excavated and any immediate hazard has been  elim-
inated by overpacking or transferring the drum's contents,  the drum is
affixed with a numbered tag and transferred to a staging  area.  Color-coded
tags, labels, or bands could be used to mark similar waste  types.

     A description of each drum, its condition, any unusual markings,  and  the
location where it was buried or stored are recorded on a  drum data sheet
similar to the one shown in Table 16.  This data sheet becomes the principal
recordkeeping tool for tracking the drum onsite.  A separate drum/bulk sheet
is also required for laboratory analysis and offsite transport (manifest)  of
the wastes.

     When a large number of drums is involved, a computerized data retrieval
system should be considered to provide instant information  on drum location,
waste type, and current inventory of similar drums via search programs.   If a
computerized data system is not practical or feasible, forms should be
prepared showing the layout of each storage area.  The drum identification
number and color code should then be marked on the form.

     In many instances, the state, or responsible party,  also requires that
the drums be photographed (before overpacking or transferring), particularly
if they have identifying marks.

     Ideally, the staging area(s) should be located just  far enough from  the
drum opening area to prevent a chain reaction if one drum should explode  or
catch fire when opened.  The area should be free of debris  and arranged so
that vehicles can access the drums easily for transfer to the drum or  con-
solidation opening area (Figure 25).  Secondary containment measures for
staging areas are described in Section 5.  If the site is located in an area
with a high water table, low flatbed trucks may be adapted  for staging.   If
the site is located in a confined or congested area, the  possibility of
excavating, staging, opening, and bulking the drums in shifts should be
considered.  If drums have been stored in a warehouse, the  warehouse may
serve as the staging area, providing there is adequate ventilation and space
available for drum handling equipment and emergency evacuation in case of
fire or explosion.

     During staging, the drums, or other containers, should be physically
separated into the following categories when possible:  those containing

                                      104

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                    TABLE  16.  DRUM/BULK DATA FORM
Sampling                                     Date Sampled:

Drum ID#: ___	  _       Time:

Eatimated Liquid Quantity;

Grid Location*:	
Staging toe at ion:_

Sampler'a Name:

Drum Condition:
Physical Appearance of the Drum/Bulk
Contents:
Odor:

Color:
pH: __^^^_^_______^___^^__^_ t Liquid:
Laboratory                            Date of Analysis:_
Analytical Data:  ^^^^^^^^^^^^^^^^^^^^^^^^^_^^
Compatibility:

Hazard:
Waste ID:
Treatment Disposal Recoanendationa:
Approval

Lab:          -                                    Date:
Site Manager: 	              Date:
*Area of site where drum was orginally located
Based on DiNapoli,  1982.   Table  originally  printed in the Proceedings of the
National Conference on Management  of Uncontrolled Hazardous Waste Sites,
1982.  Available from Hazardous  Materials Control Research Institute, 9300
Columbia Blvd., Silver Spring, MD   20910.
                                    105

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                                                   High Haunt Slaying Area Linur Explosives
Contaminated Soils
  and Empties
   Liquids
   Staging
   Area
\\
                      iH«     Ifjlj/
                      j::       iH  r.
                      ! • •   I   :« *   '
                      •mm m mmM.m M>   mm m mmm m mj
                     .Dike


                      Liner

                        Gas Cylinders

                      Cool Shaded Area
                                                                       'Explosives
                          I!  L * l : •.": JOium Opening?  . i
                                                                      Liner
     Figure 25. Layout for Separate Drum Staging and Opening Areas

-------
liquids,  those containing  solids,  lab  packs, gas cylinders,  and  empties,
since  the  strategy for  sampling  and handling drums/containers  in each of
these  categories is different.

     Where there is a good reason  to suspect that drums containing  radio-
active, explosive, and  shock-sensitive materials are present,  these materials
should be  staged in a separate,  isolated  area  if possible  (Figure 25).
Placement of explosives and shock-sensitive materials  in diked and  fenced
areas  will minimize the hazard and the adverse  effects of  any  premature
detonation of explosives.

     The process of staging drums  is rarely straightforward.   Segregating
drums  into liquids, solids, and  drums containing assorted  laboratory
containers may require  use of one  or more of the following methods:


     •  Visual inspection of the drum and its  labels,  codes, etc.   Solids  and
        sludges are typically disposed of in open top  drums  (i.e.,  with
        bolted rings).  Closed head drums with  a bung opening  generally
        contain liquid.

     •  Tapping on the drum by hand or with a brass tool,  to determine the
        category by sound.

     •  Visual inspection of the contents of the drum  during sampling,
        followed by restaging, if  needed.


     Several cleanup contractors expressed concern over the  practice  of tap-
ping drums to determine their contents.  This  approach is  neither uniformly
safe nor effective and  should not  be used if the drums are visually
overpresssurized or if  shock-sensitive materials are suspected.

     The use of nondestructive test methods as  an alternative  for determining
whether a drum contains liquid or  solid has been investigated.   Ultrasonics
has been found to be unsuitable  for this purpose, because  it requires that
the surface of the drum be clean and free of chipping  paint  and  debris (Lord,
Tyagi, and Koerner, 1981).  Highly sensitive infrared  scanners can  distin-
guish  solids, liquids, and air inside containers based on  their  thermal
conductivity.  However, this method requires that the drum be  heated  and the
pattern of cooling observed.  Such an approach would obviously be unsafe
where drums containing unknown wastes are involved (Greenhalgh,  1980).


DRUM OPENING

Drum Opening Area

     Where space allows, the drum  opening area  should be physically separated
from the drum removal  and drum staging operations, as mentioned  previously.
                                      107

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There should be sufficient distance between  the drum opening  and  the  removal
and staging operations to prevent  a chain reaction  or  fire  during drum
opening (CMA, 1982).

     A drum opening bunker should  be constructed  at sites where drum
integrity is poor and drum contents are highly toxic,  explosive or reactive.
The bunker is an isolated area surrounded by sandbags,  earthen dikes  or
cinder blocks and lined with plastic, concrete, etc.   The pad should  be
sloped so that spills flow toward  a central  collection sump.  Alternatively,
the drum may be placed in a pan that has adequate volume  to recover any
spillage in case the drum ruptures (CMA, 1982).   The pan  should have  a drain
for recovering the wastes.  Further protection should  be  provided for field
workers by using a plexiglas shield that they can step behind when opening
drums.  Sensors and probes for direct reading of  air monitoring equipment
should be located near the drum opening equipment,  and the  meters should be
situated behind the plexiglas shield.  A laboratory scale gas scrubber could
be installed in the opening area  for recovering vented gas.

     Drums are moved from the staging area to the drum opening  area one at a
time using forklift trucks equipped with drum grabbers or the barrel
grappler.  In a large-scale drum handling operation, drums  may be conveyed to
the drum opening area using a roller conveyor.

Combined Drum Staging/Drum Opening Areas

     At some sites where the work  space is too confined or  where  the
logistics of marshalling thousands of drums  from  a  staging  area  to a  drum
opening area is cost prohibitive,  cleanup contractors  have  used  a combined
drum opening/staging area rather  than the separate  staging  and opening areas
discussed previously.  Using this  approach,  drums are  staged  in rows  of two
or in groups of four, with sufficient distances between each  row  or group to
provide easy access for drum opening equipment and  adequate space for
emergency evacuation in the event  of fire or explosion.  A  spacing of 0.3 to
0.5 meters (1-1.5 feet) or more is provided  between each  drum in  a row to
minimize the possibility of chain  reactions  in the  event  of explosions or
fires.  A layout of this type of  combined staging/opening operation is shown
in Figure 26.  This method was used in the cleanup  of  drums at  the General
Disposal Company in Santa Fe Springs, California, to provide  for  rapid,
remote opening of drums and to eliminate the need to relocate the barrels
(Buecker and Bradford, 1982).

Drum Opening Equipment

     There are three basic techniques available  for drum opening  at hazardous
waste sites:
     •  Manual opening with nonsparking  bung (or plug)  wrenches

     •  Drum deheading
     •  Remote drum puncturing  or  bung removal.
                                       108

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o
VO
                                           Aisle Spacing
                               Adequate to Maneuver Drum Opening Equipment
                                      and for Emergency Evacuation
                                 * » HUM • «IQl*^|
                     9& fj ^^. f! *^^^|
                     fc#j&^Jfi—Dike

                     '•Wlri^'
                                                                                High Hazard Staging Area
                                                       ^»t? *•<•••   ,,
                                                       ,>•'••• >- ^..». 4J	Liner
                                                      'vtSi'f.:?!
                      C*«fl
                      I -'-^
                            ' i"'*~-l
                            s.;W^!
                            c«
                              Between Drum Spacing
                                Adequate to Minimize
                                  Chain Reactions
Contaminated Soils and Empties
           :ri^:,|
                                        1
   •
   |<	Dike
^ |	Liner
   i
   i
   i
                                                                      Gas Cyli
                                                                                 i  r»uirr.   inssKnJi  |
                                                                        Cool Shaded Area
                                                                                                        Radioaclives
                     Dike—^


                           i. Liquids
                                                                                Drum Consolidation Area

                                                                                            '  "'*"""]
                                                                                           *
                                      Lbiaf
•i**  - -   I I *  * P» ••
i  ,:, * •   I 11  * I  i * •
• Water f f .. .  I • N»n Flammable  '
                                            *Heacli«& Liquids I •
                                            i. _ __ • «^> ti J t
                                            ^ w^ » ?•

                                            i ••>
                                                                                                    .Solid
                                                                                                         1
                                                                                                         1
                                                                                     j,:>'s4»  I   ' : Acids Liquid  , I
                       Figure 26. Layout for Combined Drum Staging and Opening Areas

-------
      The choice of drum opening  techniques and accessories largely depends on
 the number of drums to be  opened,  their waste contents (if known), and their
 physical condition.  Remote  drum opening  eauipment should always be considered
 in order to protect worker safety, especially if the drums are damaged or
 corroded.  Manual  opening  with bung wrenches or drum deheaders should be
 performed only with structurally sound drums with waste contents that are
 known to be nonreactive and  nonexplosive.

 Hand Wrenches—•
      If closed head drums  are present, access for sampling or removing the
 contents is most conveniently obtained by removing the bung plug located on
 the head or side of the drum.  Bung plugs are threaded plugs of various
 design, and there  are  a number of commercially available "universal" bung
 wrenches suitable  for  bung removal (Figure 27).
             Figure 27. Nonsparking Bung Wrench
                       (Courtesy of Wizard Drum Tools,
                       Hydrothermal Corporation, Milwaukee, Wl)
     Bung wrenches should be of nonsparking metal alloy construction
(bronze/manganese, aluminum, molybdenum) to eliminate the potential explosions
posed by certain waste types or pressurized gases and liauids.  This tool is
generally available for about S20 (Arrow Star Inc., 1981; INTEREX Safety
Supplies, 1982).

     Again, manual drum opening with bung wrenches should not be performed
unless the drums are structurally sound (no evidence of bulging or defor-
mation) and their contents are known to be nonexplosive.  If opening the drum
with bung wrenches is deemed reasonably cost-effective and safe, then certain

                                      110

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procedures should be implemented to minimize the hazard.  Field personnel
should be fully outfitted with protective gear.  Drums should be positioned
upright with the bung up, or, for drums with bungs on the side, laid on their
sides with the bung plugs up.  The wrenching motion should be a slow, steady
pull across the drum.  If the length of the bung wrench handle provides
inadequate leverage for unscrewing the plug, a "cheater bar" can be attached
to the handle to improve leverage.  If there is evidence of incompatible
chemical reactions, sudden pressure buildup, or a release of potentially toxic
fumes while the bung is being loosened, field personnel should immediately
leave the area and arrange for remo'te drum opening equipment to be used.  If
the drum plug cannot be opened successfully using a nonsparking hand wrench,
then other methods of drum opening (deheading or puncturing) must be
considered.

Drum Deheading—
     Wizard Drum Tools manufactures manually operated drum deheaders (Figure
28), which act as "can openers" to cut away the heads of steel drums.
Manually deheading a drum is time consuming and inefficient, but it may be
desirable for opening small numbers of drums.  Manual deheaders are unsafe
under many conditions since they require that the worker be close to the drums
being opened.  The manual deheader illustrated in Figure 28 is manufactured by
Wizard Drum Tools and can be purchased for about $315 (Hydrothermal
Corporation, 1981).

     Wizard Drum Tools also manfactures a portable, self-propelled drum opener
(Figure 29) for quicker and more efficient deheading.   It may be either
electrically or pneumatically driven and is available for about $1,000 (Wizard
Drum Tools, 1981).  The opener can be attached to a support tower via a chain
attachment on a roller sheave (Figure 30).  This allows the opener to rotate
around the drum head with minimal manual assistance.  The equipment is
generally set up and operated manually.  It could be operated remotely as
well, although this would require modification to the existing equipment.

     A problem frequently encountered when using a drum deheader or self-
propelled opener is that the equipment cannot cut away  those parts of the drum
head that have been dented or otherwise distorted.  The deheader must be
frequently readjusted and/or the drum chimes must be undented.  A drum
dekinker (Figure 31) can be used  to manually straighten dented chimes  for
easier deheading and to reseal leaking drum heads.  However, its operation
also requires working near potentially hazardous drums.

Remote Drum Opening—
     Remotely operated drum opening tools are  the safest available means of
drum opening.  Two basic tools, originally developed by EPA's National
Enforcement Investigation Center  (NEIC) and since modified by several  cleanup
contractors, are available.  Remote drum opening is slow but provides a high
degree of safety compared to manual methods of opening.  The remote "bung
remover"  is essentially an air impact wrench  that uses a compressed air  tank.
A specially devised mounting bracket and a nonparking bung  socket  are  used  to
spin the bung from the top or side of a drum (Figure 32).  The  second device
developed by NEIC is a hydraulic  drum plunger  that forces a penetrator


                                      111

-------
                 Figure 28.  Manual Drum Deheader

(Courtesy of Wizard Drum Tools, Hydrothermal Corp., Milwaukee, WI)

Note:  This photograph does not show appropriate safety gear
       required in the field

-------
        Figure 29.  Self-Propelled Drum Deheader
                    (Electric or Pneumatic Models Available)

(Courtesy of Wizard Drum Tools, Hydrothermal Corportion,
 Milwaukee, WI)

 Note:  This photograph does not show appropriate safety gear
        required in the field
                             113

-------
    Figure 30.  Self-Propelled Drum Beheader with Support Tower




(Courtesy of Wizard Drum Tools, Hydrothermal Corp., Milwaukee, WI)
                                114

-------
                     Figure 31.  Drum Dekinker

(Courtesy of Wizard Drum Tools, Hydrothermal Corp., Milwaukee, WI)

 Note:  This photograph is intended only to illustrate drum opening
        equipment and does not illustrate safety precautions required in
        the field.
                                  115

-------
                   Reproduced from
                   best available copy.
Figure 32.
Pneumatic  Bung Wrench:   Attachment to Drum

and Remote Operation Setup
              al
              "
                                  originally printed in  the
                                                    ,300
  Blvd.,  Silver Spring

-------
 into  the  drums  and  seals  the  resulting  holes.   A sample  is  withdrawn through
 the hollow stem of  the  penetrating  device and  the device is then left in
 place  to  seal the drum  (Blackman  et al.,  1980).   The  system can be backhoe-
 mounted (Figure 33)  or  manually set up  (banded or clamped around the drum)  for
 remote operation (Figure  34).   The  drum plunger may also be incorporated into
 a mechanized conveyor system  (Figure 35)  for remote puncturing of a large
 number of drums in a timely manner  (CMA,  1982).   NEIC has made the specifica-
 tions  for these pieces  of equipment available  to several of the EPA Regional
 Offices.   These tools can be  developed  by making simple  and low-cost modifi-
 cations to existing  equipment (Verbal communication with K. Fischer U.S. EPA,
 NEIC, Denver, Colorado, 1982).  As  mentioned previously, Wizard Drum Tools'
 portable,  self-propelled  drum opener could also be set up to operate remotely
 provided  the chime is free of dents that  could cause  the opener to stick.

     Another technique  for drum puncturing involves the  use of a nonsparking
 metal spike attached to a backhoe arm.  Figure 36 shows  the O.H. Materials
 barrel grappler holding a drum as it is spiked open with this tool.  This
 method achieves relatively quick  and safe drum opening for  subsequent
 sampling,  but the nonspecific action of the spike may damage drum integrity.
 If this method  is used, the backhoe boom  and dipper assembly should have a
 relatively long reach (at least 12  meters, or  40 feet),  and the backhoe cab
 should be  plexiglas  shielded  for  operator safety.   The backhoe spike method
 for drum  opening should be performed by experienced backhoe operators only.

     Drums  that have been overpressurized to the extent  that the head is
 swollen several  inches  above  the  level  of the  chime should  not be moved. A
 number of  devices have been developed for venting critically swollen drums.
 One method  that has  proven to  be  effective is  a tube  and spear device
 illustrated in  Figure 37.  A  light  aluminum tube 3 meters (10 feet) long is
 positioned  at the vapor space  of  the drum. A  rigid,  hooking device attached
 to the tube goes over the chime and holds the  tube securely in place.  The
 spear is  inserted in the  tube and positioned against  the drum wall.  A sharp
 blow on the end of the  spear  drives the sharpened  tip through the drum and  the
 gas vents  along  the  grooves.   The venting should be done from behind a wall or
 barricade  (Niggle, 1982).  This device  could be  cheaply  and easily designed
 and constructed where needed.   Once the pressure has  been relieved, the bung
 can be removed, the  drum  sampled, and the bung hole fitted  with & pressure
 venting cap set  at 5 psi  release.   The  opening made by tube and spear device
 should then be  sealed.

     Table 17 summarizes  available  drum opening .techniques, their recommended
 applications, and major disadvantages.  Remote drum opening via pneumatic bung
 removal, deheading,  or  drum puncturing  is much more desirable than the manual
methods of drum opening discussed previously.   They may  require more time for
 drum staging and equipment setup, but they maximize the  distance between
workers and drums during  the  potentially  dangerous activity of drum opening.
Puncturing drums with hand tools  and manual bung removal with wrenches or
manual deheading is  recommended only with structurally sound drums (no
bulging, corrosion",  dents) with waste contents that are  known to be relatively
 nonhazardous.
                                      117

-------
BACKHOE
ARM (REF.)
HYDRAULIC LINES
                                                       HYDRAULIC CYL.
                                                       WITH 6 IN. STROKE
                                                       SPLASH PLATE
                                                       REPLACEABLE 316
                                                       STAINLESS STEEL
                                                       CONICAL PLUNGER
                                                       (3IN.DIA.X 4IN.LG.)
STANDARD SINGLE
DRUM GRABBER
                                                       55 GALLON DRUM
DRAIN TO VACUUM TRUCK,
WASTE RECOVERY SYSTEM ^^^r ^**
OR TANK- 	 -* r
1
i j

^ SPILL C
!
ASLOPE

75 GAL
  Figure 33. Hydraulic Backhoe Drum Plunger Arrangement
            (Courtesy of Chemical Manufacturer's Association, Washington, DC)
                                  118

-------
                                               Wff,
Figure 34.  Remote Hydraulic Drum Plunger Mounted on Drum

(Blackman, et al., 1980.  Figure originally printed in the
Proceedings of the National Conference on Management of
Uncontrolled Hazardous Waste Sites, 1980.  Available from Hazardous
Materials Control Research Institute, 9300 Columbia Blvd., Silver
Spring, MD  20910.)
                               119

-------
55 GAL. DRUM
CONVEYOR
DRAIN TO VACUUM TRUCK,
WASTE RECOVERY SYSTEM
OR  TANK	:
             REMOTE
             LOCATION

             NEEDLE  VALVE

             3 WAY VALVE

APPROX. 50FT. OF HOSE

AIR/HYDRAULIC CYLINDER


SPLASH PLATJE

REPLACEABLE, 316 STAINLESS
STEEL CONICAL PLUNGER
(3IN. DIA. X 4 IN. LG.)
DOORS (2 SIDES)
SPILL CONTAINMENT  PAN &
SUPPORT FRAME (75 GAL CAPACITY*

BELT  CONVEYOR
FORK LIFT SLOTS
                   Note: A non-sparking, bronze plunger could replace the stainless steel
                      but will be less durable
    Figure 35. Conveyor Belt System for Remote Hydraulic Puncturing of
              Large Number of Drums
              (Courtesy of Chemical Manufacturer's Association, Washington, DC)
                                     120

-------
Figure 3.6.  Backhoe Spike (nonsparking) Puncturing Drum Held by Grappler




              (Courtesy of O.H.  Materials Co., Findlay, OH)

-------
                                Hook for Too
                                CMRNOfOium'
                                    Light might hotow tub*
                                    WprosMiiMy 10 It in tangtti
            FraMVtow
             nmvww  \
             ©-1-
             SMiodvttivjfgihMppeM
VwdnaSM
         NOTE: Both tub* «id rod eouU b* out
Figure 37. Tube and Spear Device Used for Venting Swollen Drums
           (Source: Niggle, 1982)
           {Reprinted with permission of Government Institutes  Inc., Rockville,
           MD)
                                    122

-------
                                TABLE  17.    SUMMARY  ASSESSMENT  OF  DRUM  OPENING TECHNIQUES
                  Recommended Drum Opening Application* (for  Sample Acquisition or Recontaineriiat ion)
Bung Wrenches
(Nonsparking)
Manual  Drum
Deheader
                        Number of Drums  to be Opened    Physical Condition of Drums


                        <100
                                                                                    Haste Content of Drum
                                                                                                                       Restrict iona /Disadvantages
                                                                                        Shock
                            100-500       >iOO    Damaged  or     Structurally     Unknown   Senoitive/      Non-
                                                  Bulging         Sound                 Explosive    hazardous
                                                                                                                      Not recommended for unknown
                                                                                                                      waste contents; full  protective
                                                                                                                      gear for worker.
                                                                                                                      Only if bung is impossible  to
                                                                                                                      open; used mainly for
                                                                                                                      reconlainerization vs.  sample
                                                                                                                      acquisition; unsafe if  waste
                                                                                                                      contents are unknown.
i—    Self-Propel led
£J    Drum Deheader
      (Electric or
      Pneumatic)
  S3  Portable
                                                                                                                 May  require use of a dekinker
                                                                                                                 or readjustment of the deheader
                                                                                                                 it the chine Is dented.
Remotely XX X
Operated
Pneumatic
Wrench
Remote
Hydraul ic
Plunger
X XX Requires direct contact with the
drum during attachment of
wrench .
Time-consuming setup.
Only in controlled area
with spill containment.

the





                                                                                                                 Host  tine-conaiiming of Che
                                                                                                                 hydraulic plunger method*.
                                                                                                                 Requires direct contact
                                                                                                                 with  the drum in order to
                                                                                                                 •et up the plunger.
•
Self -Pro- X X
pel led
(Electric or
Pneumst ic )
X XX X Only suitable if
is free of dents
the chime
                                                                                                                                      (continued)

-------
                                                TABLE  17.   (Continued)

Technique

• Backhoe-
att ached
• Conveyor
Backhoe Spike
(Nona park ing)
Tube and
• pear device
for venting
Recommended Drum Opening Application! (for Sample Acquisition
Number of Drums to be Opened Physical Condition of Drums
<100 100-500 >SOO Damaged or Structurally
Bulging Sound
XX X
XX X
X X .X
X X XX
or Recontaineritation)
Uaate Content of Drum
Shock
Unknown Sensitive/ Non-
Exploaive hazardous
X X(l) X
X X(l) X
XX X
X

Restrictions/Disadvantages

Use long boon-dipper arms
(> 12 neters or 40 feet).
Has not been used in the field
to date.
Hay damage drum; use long back-
hoe boom O40').
Method applicable for venting
of pressure, but not for dnun
sampling.
(I) Plunger may be of nonsparking bronze
   or of stainless steel,  which is more durable.

-------
                                  SECTION 9

                  WASTE CONSOLIDATION AND RECONTAINERIZATION


     The activities discussed in this section are designed  to achieve  two
basic objectives:


     •  Pretreat, bulk, or recontainerize the waste to meet the requirements
        of the treatment or disposal facility in the most economical way
        possible

     •  Put the wastes in a safe and acceptable form for transportation to  a
        permitted treatment/disposal facility.


COMPATIBILITY TESTING

     As each drum is opened, it is scanned for radioactivity and, if
negative, a sample is taken for compatibility testing.  Compatibility  testing
refers to simple, rapid, and cost-effective testing procedures that are used
to segregate wastes into broad categories (i.e., radioactive, oxidative,
water reactive). .By identifying broad waste categories, compatible waste
types can be safely bulked onsite without risk of fire or explosion, and
disposal options can be determined without exhaustive and costly analysis of
each drum.

     Sampling is conducted using a sampling thief for liquids and a coring
tool for solids.  Solid samples should be taken from several different areas
within the drum.  In addition, the contents of all drums should be described
on the drum data sheet in terms of physical state, viscosity, and number of
phases.  A sample must be taken for each phase.

     Compatibility testing protocols have been developed by a number of
cleanup contractors and waste generators.  Often, however,  the compatibility
testing procedures must be tailored for site-specific conditions or to meet
the testing requirements of prospective treatment/disposal  facilities.  A
thorough compatibility testing protocol, developed by Chemical Manufacturers
Association (CMA) (1982) is outlined in Figure 38.  This protocol has been
used in a number of cleanup operations.
                                      125

-------



Isolate £


























solate Gas Cylinders -*
suspected Explosives •*

*
Liquids
»
Open Drum
*
Test for Radioactivity
1 1
Confirm Liquid
1 -
* *
Test for Peroxides
and Oxidizers
\ No
Test for Water
Reactivity
J No
Test for Water
Solubility
| Yes
Test for Water
Content
>10% \
See
Water Soluble
Liquids
Yes

I
Determine Contents »• Isolate Oddball Drums
of Containers ^ lso|gte ^ packs
1

Solids
I
Open Drum
*
Yes Yes _ . _ „
» isolate «- Test for Radioactivity
To Solids To Liquids 1
i » " , „ .
— ££J Regroup T No Confirm Solid




I
Test for EP Toxicity
	 *• lsolate ' and PCBs
PCB | | No PCB
No ^x""^""^ ^. — ^s^
* f Bulk for \ / Bulk for \
1 Disposal } I Disposal J
<10% X^_^X X.___^X


See
Water Insoluble
Liquids
Figure 38. Compatibility Testing Protocol (Modified by Princeton Aqua
          Science)
          (Reprinted courtesy of Chemical Manufacturer's Association,
          Washington, D.C.)
                                126

-------
                     Water Insoluble Liquids Testing
                                Test for
                            Organic Halogen
       Compatibility
                         No
                                 Isolate
                             No
                                     Compatibility
              Yes
                                        Yes
        Test for PCS
       on Composite
                                     Test for PCS
                                     on Composite
                                             Retest if PCB
                                               <50 mg/l
Retest if PCB
  <50 mg/l
                                                                Compatibility
Compatibility
                   <500 mg/l I

                    No
                          l>500 mg/l

                                 No
                              Compatibility
                                               High Halogen
                                                 No PCB
                                                Composite
Low Halogen
  No PCB
 Composite
                           Mixed
                          Halogen
                        Middle PCB
                         Composite
                        Mixed
                        Halogen
                       High PCB
                       Composite
                                                       High
                                                      Halogen
                                                     Low PCB
                                                     Composite
           Low Halogen
             No PCB
            Composite
Figure 38. (continued) (Modified by Princeton Aqua Science).
           (Reprinted courtesy of Chemical Manufacturer's Association,
           Washington, D.C.)
                                 127

-------
                            Water Soluble Scan
          Strong
          Acids
Weak
Acids
<7
>7
Weak       Strong
Bases       Bases
           I
         pH <2
  r
pH 2-7
                                  Isolate
                                              Yes
                 pH 7-12      pH >12
                J	L
                                  Cyanide, Sulfide
                  Neutralize (optional)
Isolate
            Strong Acid
             Composite
                                                         No
                        Neutralize (optional)
                                                No
                                                                          Isolate
                                  Compatibility
                                     Strong Base
                                      Composite
         Figure 38. (continued) (Modified by Princeton Aqua Science)
                    (Reprinted courtesy of Chemical Manufacturer's
                    Association, Washington,  D.C.)
                                      128

-------
     Based on the CMA protocol, wastes can be segregated into the following
broad waste categories:


     •  Liquids

           Radioactives
        -  Peroxides and oxidizing agents
        -  Red uc ing ag en t s
        -  Water-reactive compounds

     •  Water insolubles

           low halogen, low PCB
        -  mixed halogen, high PCB
        -  high halogen, low PCB

     •  Acids

        -  strong (pH <2)
        -  weak (pH 2-7)

     •  Bases

        -  strong (pH >12), with or without cyanides or  sulfides
        -  weak (pH 7-12), with or without cyanides or sulfides

     •  Solids

        -  radioactives
        -  nonradioactive.
     These field compatibility testing procedures are only  suitable  for
determining gross halogen content (> 1%).  Samples must be  retested  for  PCBs
prior to bulking since the EPA-approved disposal options  differ  depending
on the PCB concentration.  Testing to determine gross halogen  content  is
sometimes eliminated if all insoluble wastes are to be incinerated at  a
facility capable of handling chlorinated organics.  However, testing  for PCBs
is required, regardless of the need for testing other halogenated compounds.

     The protocol also requires that a compatibility test be performed by
mixing small samples of wastes that are intended to be bulked.   Visual obser-
vations are made for precipitation, temperature changes or  phase separation.

     There are some differences between the CMA compatibility  protocol and
the protocol used by some cleanup contractors.  One commonly used procedure
is to conduct flammability and ignitability tests on a drum-by-drum  basis  for
both liquid- and solid-containing drums.  CMA, on the other hand, recommends
that these tests be performed on composite samples before bulking since  these
tests require more costly and time-consuming analysis (torch test and  closed
cup flame test, respectively).  Another common practice not included  in  the

                                      129

-------
CMA protocol is to conduct further testing on samples from drums containing
solids.  These tests may include water reactivity, water solubility, pH, and
the presence of oxidizers.  In general, the decision to perform these
analyses on a drum-by-drum basis rather than on a composite sample  (prior  to
bulking) is made based on the number of drums and the types of wastes known
to be present on site.

     Hatayama et al., (1980a) have also provided guidance on waste  incompati-
bilities that can be useful during the waste consolidation process.  These
researchers have developed a "Hazardous Waste Compatibility Chart"  (included
in the Appendix) that allows the user to evaluate potential adverse reactions
for binary combinations of hazardous wastes.  Binary waste combinations  are
evaluated in terms of the following adverse reactions:  heat generation  from
a chemical reaction, fire, toxic gas generation, flammable gas generation,
explosion, violent polymerization, and solubilization of toxic substances.


TESTING COMPOSITE SAMPLES

     A detailed analysis of a composite waste is generally required prior  to
acceptance by a treatment/disposal facility.  Once a significant group of
compatible waste types (about 100 drums) have been identified, a PCB analysis
must be conducted on subgroups (generally about 5 drums).  When a composite
sample shows a significant PCB concentration (>50 rag/1), each drum  in the
subgroup must be analyzed separately.  Once a compatible group of samples  is
identified and PCB-contaminated drums are removed, a final disposal analysis
is conducted.  Muller, Broad, and Leo (1982) have compared the analytical
requirements of a number of disposal facilities and found that the  tests
identified in Table 18 are representative of tests that may be required  prior
to acceptance of liquids and solids for disposal.


SEGREGATING WASTES BASED ON COMPATIBLE WASTE CLASSES

     Once drums have been categorized into compatible waste classes, the
drums are assigned a color code that corresponds to their compatibility  class
(i.e., oxidizers, strong acid, etc.).  The drums are then physically
segregated on the basis of compatible waste types and consolidation or volume
reduction techniques.  In this way, compatible waste types can be efficiently
combined for final treatment, storage, or disposal.  To  facilitate  easy
access to the drums, compatible waste types should be placed  in groups of
four or in long double rows (CMA, 1982).  Spacing between rows or groups
should allow easy access to drums by drum handling equipment  and  rapid exit
in case of emergency.


TREATMENT/DISPOSAL OPTIONS

     Once the wastes have been categorized, they are assigned  appropriate
treatment/disposal options.  These options are selected  based on  such  factors
as protection of public health, regulatory requirements, availability  and
                                       130

-------
          TABLE 18.  POTENTIAL ANALYTICAL REQUIREMENTS FOR DISPOSAL
 1.  Flammability
 2.  pH
 3.  Specific gravity
 4. _PCB analysis
 5.  Thermal content (BTU/lb)
 6.  Physical state at 70°F
 7.  Phases (layering in liquids)
 8.  Solids (%)
 9.  Hydrocarbon composition
10.  Pesticide analysis
11.  Sulfur content
12.  Phenols
13.  Oil and grease (%)
14.  Water (%)
15.  Viscosity
16.  Organochlorine percentage
17.  Metals analysis
     a.  Liquids for soluble metals.
     b.  Solids extracted according to the EPA Toxicant Extraction Procedure
         (24 hr) which shows leachable metals.
     c.  Both liquid and solids checked for concentrations of  the following
         metals:
         Arsenic                       Mercury
         Barium                        Nickel
         Cadmium                       Selenium
         Chromium                      Silver
         Copper                        Zinc
         Lead
18.  Both free and total cyanide content checked.
19.  Solids checked for solubility in water, sulfuric acid, and dimethyl
     sulfoxide.
Reprinted from Muller, Broad, and Leo, 1982.  Table originally printed  in  the
Proceedings of the National Conference on Management of Uncontrolled
Hazardous Waste Sites, 1982.  Available from Hazardous Materials  Control
Research Institute, 9300 Columbia Blvd., Silver Spring, MD  20910.
                                      131

-------
appropriateness of Treatment/Storage/Disposal (TSD) facilities, applicability
to site specific conditions (i.e., number of drums, location, etc.), and
costs.

     Treatment or disposal options for specific waste types are covered in
detail in numerous reports, several of which are listed in the references.
The U.S. EPA (1981b) prepared a useful summary of major treatment and
disposal options for various waste categories.  The summary is shown in Table
19.  Although this table was prepared specifically for the Pollution
Abatement Services Site in Oswego, New York, it is generally applicable for
most cleanup operations since it identifies the most widely used treatment or
disposal option for various broad waste categories.  Nevertheless, the
selection of the best treatment/disposal option should be made on a site-
specific basis.

     The major factors to consider in determining the feasibility and
effectiveness of the various treatment options are summarized below:


     •  Incineration:  BTU values, organic chlorine, organic sulfur, water
        content, viscosity, heavy metals (i.e., percent ash),  feasibility of
        onsite incineration, location of a suitable offsite incinerator

     •  Aqueous Treatment:  pH, acidity, alkalinity, flash point, water
        content, microbial toxicity, TOC, sulfide, cyanide, metals,
        feasibility of onsite treatment, sludge disposal if treated onsite,
        onsite pretreatment requirements

     •  Resource Recovery:

        -  organic solvents and nonemulsified oils:  PCS content, halogen
           content, water content, dissolved metals, and other dissolved
           compounds, BTU value

        -  metals recovery:  metal concentration, economics of production of
           the metal from the raw material

     •  Secure Landfill:  water content, PCB content, radioactivity,
        reactivity, ignitability, presence of carcinogens, presence of  toxics

     •  Solidification/Stabilization;  potential  for reversal  of reactions,
        costs, status of technology, compatibility of wastes with a
        solidifying agent.


     Location of suitable  facilities for final treatment or disposal depends
primarily on the specific waste type.  The Hazardous Waste Management
Directory (1982-1983) (Pennsylvania Environmental Research Foundation,  Inc.)
identifies treatment/disposal facilities  by city and state.   The types of
wastes handled, the treatment/disposal processes  used, and the service  are
listed for each facility.  For radioactive- and PCB-containing wastes (except
liquids with <50 ppm PCB)  the options are rather  limited.  Figure 39 shows

                                      132

-------
                TABLE  19.  MAJOR  TREATMENT/DISPOSAL ALTERNATIVES
                            FOR VARIOUS WASTE TYPES

Waste
Segregation

Radioactive

Waste
Type

Solid
Liquid
Aqueous Recovery/ Incin- Solidification
Treatment Recycle eration Fixation/
De water ing
P
P
Secure
Land
Burial
LD
LD
Water Reactive   Liquid
           U
                 Solid
                 (alkaline  PS
                  metals)
Strong Reducer
Strong Oxidizer
Organic Liquid
with Low Halogen
Concentration
(£2% halides,
<50 ppm PCS)
Solid/
Liquid

Solid/
Liquid

Solvents
U
0
Organic Liquid
with High Halo-
gen Concentra-
tion
(>2% halides,
<50 ppm PCB)
Oil

Other

Solvents



Oil
                 Pesticides,
                 Herbicides

                 Other
        PS/U




        PS/U

        PS/U

        PS/U
                   PS/U
                              U
U

U

U



U


U


U
                                                                      (continued)
                                       133

-------
                              TABLE 19. (continued)
Waste
Segretation
Waste
Type
Aqueous
Treatment
Recovery/
Recycle
Incin-  Solidification/ Secure
eration Fixation/       Land
        Dewatering      Burial
Aqueous Acid
Aqueous Base
Contaminated
With Cyanide

Aqueous Base
Contaminated
With Sulfide

Aqueous Base
Acids
with or
without
heavy
metals

Organic
Acids
Alkalines
pH 7-12
with or
without
heavy
metals

Organic
Alkalines
   PS/U
                   P*
                        LD*
                            PS/U*
           U
           U
   PS/U
                      U*
                   P*
                        LD*
                   P*
                        LD*
                            PS/U
                      U*
                   P*
                        LD*
Solid Material
Uncontaminated
w/PCB «50 ppm)
Inorganic
Acid
Sludge
                              p**
                                   LD
                 Inorganic
                 Alkaline
                 Sludge
                                      P**
                                              LD
                                                                      (continued)
                                        134

-------
                               TABLE  19.  (continued)
Waste
Segregation
           Waste     Aqueous     Recovery/
           Type      Treatment   Recycle
Incin-  Solidification/ Secure
eration Fixation/       Land
        Dewatering      Burial
 Solid Material  Organic
 Uncontaminated  Acid
 w/PCB «50 ppm) Sludge
 (continued)
                Organic
                Alkaline
                Sludge

                Salts/
                pure
                organic

                Tar/
                Residues
                (i.e., still
                bottoms filter
                cake, spent
                catalyst, etc)

                Other
                Organic
                Sludges

                Metals

                Asbestos

 PCS Contam-     50-500 ppm  PS
 inated Material

                >500 ppm .  PS
                               PS
                                           U*
                                           U*
                                          U
                                          U
                                          p
                                          u
        p
        u
        p
                        LD
                        LD
                        LD
                        LD
LD
LD
U.S. EPA, 1981b

Key.
 U -
PS =
 P =
LD =
 * a
** =
 a _
Ultimate Disposal
Pretreatment Sidestream
Pretreatment
Land Disposal
Solid Phase Only
Neutralization Part of Process
Recovery/recycle includes fuel blending, auxiliary fuels and product
recovery
                                  135

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Reproduced from
best available copy
   Legend

Hiyli Teinpcrdtuie Inciiieidtoi

Low Itvul RddiOdClivlly

Secured PCB Utidlills

Secured PCB iJiidfiDs 160 SUOppm)

Chc-imral Trealmenl
   Figure 39.  Locations  of Treatment/Disposal Facilities for
                     PCBs or Radioactive Wastes

            (Sources: USEPA, 1983b;  USEPA, 1983c; USEPA,  1983d)

          Note: Mobile incinerators, mobile treatment system, and permitted boilers are
               not included. Permitted chemical treatment facilities may not accept
               outside wastes.

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 the location of  facilities capable of  secure  landfilling  of  low-level  radio-
 active wastes and PCB containing wastes  and of high  temperature  incineration
 of PCB liquid wastes in  excess of 500  ppm.  The  facilities capable  of
 handling  low-level  radioactive wastes  have very  specific  requirements
 regarding types, concentrations, and packaging of  radioactive materials .
 Requirements for the land disposal of  low-level  radioactive  wastes  are
 outlined  in the Low-Level. Radioactive  Wastes  Policy  Act of 1980  and 10 CFR
 Parts 10, 19-21, 30, 40, 51,  61, 70, 73,  and  170.  Requirements  for treatment
 and disposal of PCB-containing wastes  are outlined in 40  CFR Part 761.  The
 PCB requirements are summarized briefly  in Figure  40.


 PREPARATION OF LIQUID WASTES  FOR FINAL TREATMENT OR  DISPOSAL

     Once the final treatment or disposal options  have been  determined,  the
 wastes are then prepared to meet the requirements  of the  treatment  or
 disposal  facility and the transportation  regulations.  In some  instances  this
 involves  pretreatment of the wastes.   In  other cases,  compatible  wastes  are
 simply bulked for transport or transferred into  a  DOT-approved  container  or
 fiber container in  the case of onsite  incineration.

 Onsite Pretreatment

     Onsite pretreatment of wastes may be required to  make them  acceptable
 for offsite transport, to meet the requirements  of the treatment  facility, or
 to allow them to be bulked with other  similar wastes.  Onsite pretreatment is
 generally limited to the following:


     •  Acid-base neutralization

     •  Metal precipitation

     •  Hypochlorite oxidization of cyanide and  sulfide

     •  Flash point reduction (use of  a Freon-based  flash suppressant).


     Chemical reactions  should be carried out under  carefully controlled
 conditions using a  "compatibility chamber" or reaction tank  for mixing
 wastes.  O.H. Materials, Findlay, Ohio (undated),  developed  a 38,000 liter
 (10,000 gallon)  "compatibility chamber" that monitors  the heat of reaction
 using thermocouples mounted in the chamber.  A nonsparking bar  scraper with
 explosion-proof drive, prevents sludges and solids from entering  the collec-
 tion chamber.  Other cleanup contractors  use  small storage tanks.  If  opened,
 the tank should have a minimum of 2 feet  of freeboard  or  some sort  of
containment structure equal to the volume of 2 feet  of freeboard.  Ideally,
 the storage tanks should have some type of closure and should be  painted
black to control loss of volatiles.  Drums should  be emptied into an open
chamber or tank using the grappler.  This provides for a  safe and rapid means
of bulking wastes (Figure 41).  Hydraulic drum dumpers (Section 7,  Figure 20)
 are also suitable for dumping the contents of drums  into  a reaction tank.

                                       137

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                                                  Nan Liquids
                                                   Liquids
      Large Capacitors Must Be
            Incinerated
00
  Some Containers and
Large Hydraulic Machinery
 May Be Decontaminated
     and Landfilled
  All Other Items To Be
 Disposed of in Chemical
Waste Landfill (There Are
8 EPA Approved Landfills
      for Solids')
                                                                                            >50 ppm
                                                            >500 ppm
                                                                         
-------
U)
\o
                                               Reproduced from
                                               best available copy.
                       Figure 41.   Use of Grappler  Arm and Compatibility Chamber  for  Combining
                                    Compatible Wastes                 ,


                                      (Courtesy of O.K. Materials Co.,  Findlay, OH)

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 Consolidation

      In instances  where  the  contents  of a large number  of drums  can be
 consolidated  for  purposes  of treatment  or disposal,  vacuum equipment can
 offer a highly efficient  approach to  consolidation.

      Vacuum trucks are  available  in capacities  ranging  from about  4,700 to
 23,000 liters (1,250-6,000 gallons.)  They are  available in a range of vacuum
 strengths  and with a  wide  variety of  options.   Figure 42 illustrates a number
 of available  options  for  one manufacturer's line of  equipment (Huber
 Manufacturing Inc., undated).

      Portable skid-mounted vacuum units are also available.  They  can be
 airlifted,  dragged by bulldozer,  or even hauled on the  back of a pickup truck
 to otherwise  inaccessible  areas.   These units  are generally available in
 capacities  ranging from 1,900 to  5,700  liters  (500-1,500 gallons), although
 units that  can handle up  to  11,400  liters (3,000 gallons) are manufactured.
 Skid-mounted  units with vapor  recovery  systems  are also available.

      A number of  factors  should be  considered  prior  to  contracting for the
 services of a vacuum  truck.   Because  of the large capacity of the  vacuum
 cylinder, vacuum  trucks  are  generally not well  suited to sites with fewer
 than 30 drums to  be consolidated.  For  a small  site  it  is generally more
 cost-effective to overpack the drums  or to use  a vacuum skid-mounted unit.
 This is due to the high  transportation  costs and cost of handling  wastewater
 generated  from decontaminating the  truck.  The  water or solvent used in
-decontamination is considered hazardous and must be  disposed of or treated as
 such.  Highly hazardous  chemicals such  as PCBs  require  stringent
 decontamination procedures in accordance with  the Toxic Substances Control
 Act (TSCA).

      The cost of  decontamination  can  be substantially reduced by a number of
 good management practices.  The vacuum  truck or skid-mounted unit  should be
 dedicated  as  much as  possible to  handling a certain type of waste  so that
 decontamination is not  required between each load.  The units should also be
 sized for  the job so  that  excessive decontamination water is not generated as
 a. result of choosing  an oversized vacuum cylinder.

      Another  important  factor to  consider in selecting  vacuum trucks or skid-
 mounted units is  the  compatibility of wastes with materials of construction.
 Vacuum cylinders  can  be purchased in  carbon steel, stainless steel, aluminum,
 nickel, etc., and/or  with a  variety of  coatings including epoxy, fiberglass,
 and neoprene  rubber.   In addition to  selecting vacuum trucks with compatible
 liners, compatibility problems can be minimized by allowing wastes to react
 in a "reaction tank"  or "compatibility  chamber" where the heat of reaction
 can be released before  pumping the wastes into the vacuum truck.

      In addition, when  a grappler is  available, it is often more efficient to
 dump the contents of  the drums into a chamber or tank and transfer the load
 to the vacuum truck rather than to load each drum separately into the vacuum
 truck.
                                       140

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                     HOIST - Hydraulic lilt lor ease and
                    speed  in dumping heavy  materials
                    from the tank.
TOP HATCH - Available
in sizes 12" and 20" lor
top loading or use as a
manway.
REAR DOOR - Full opening rear
door for ease in dumping.  Abo
helpful in cleaning out the tank.
COOLOI • Duel P«M oil oooUr
The cooler th* oil. the moi« ef
lici«nt tim xyitcm Coolm »'
•tandani «quipm«ill on  unite
with hydinultc dnvcn pump*
                                    VACUUM/PRESSURE
                                    PUMP - Air  cooled  or
                                    liquid cooled,  ranging in
                                    size from 90  CFM thru
                                    1.600CFM.
     DRIVE FOR PUMP-Your
     choice oi either belt or
     hydraulic drive lor pump.
                        J
   VIBRATOR - Electric vi-
   brator  lor shaking out
   semi solids, mounted on
   the  underbelly of the
   front quarter of the tank.
                    Figure  42.   Available  Options  for  Streamline  Vacuum  Trucks

                        (Courtesy  of  Streamline Manufacturing,  Gulfport,  MS)

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Use of Overpacks and Drums

     Under certain circumstances it is more economical or acceptable  to
transport liquid wastes in drums or overpacks rather than to bulk them.  This
is the case when the number of drums containing compatible waste types is  too
few to make the use of vacuum equipment economical or when there are  a few
drums that contain highly toxic or incompatible wastes that cannot be bulked
with other wastes without contaminating the load.

     Procedures for overpacking or transferring liquids to new drums  were
discussed in Section 7.  Drums or overpacks must meet with DOT specifications
with regard to waste-container compatibility, packaging, and  labeling before
being transported offsite.  Specifications are found in 49 CFR 172 through
179.  If wastes are to be incinerated, fiber drums should be  considered  as an
alternative to steel drums.  Fiber drums generally can meet DOT requirements
by lining or overpacking them (Gordon, 1982).  The use of a fiber drum rather
than a steel drum greatly simplifies the incineration process.

     In instances where the contents of several partially filled drums are to
be combined, a simple flow gauge can be used to monitor the liquid level in
the drums to prevent overfilling.  These gauges fit into standard bungs  and
can be easily adjusted to any desired liquid level (Industrial Safety and
Material Handling, 1981; BASCO, 1982).
PREPARATION OF SOLID WASTES AND SOILS FOR FINAL TREATMENT  OR DISPOSAL

     Secure land fill ing  is the most  common means  for  ultimate disposal  of
solid wastes including sludges, process residues,  still bottoms,  and  highly
contaminated soils.  RCRA, State,  and DOT regulations  will dictate  the  type
of pretreatment required to make the waste acceptable  for  secure  land fill ing.
Soils and wastes may be bulked, transferred  to a  new  drum, or overpacked
depending upon specific waste and  site conditions and  requirements  of the
secure  landfill.   Incineration can be a viable alternative to landfill ing
some solids provided water content and heavy metal  concentrations are low.
Solidification/stabilization methods are also  a potential  treatment option,
but their use is limited to highly toxic materials  because of the high  cost
of solidification.

Use of  Drums and Overpacks

     In many instances,  drums containing sludges  and  solids are overpacked or
their contents are transferred to  new or reconditioned drums.  Highly contam-
inated  soils are sometimes drummed as well  if  the volume  is small.

     RCRA land disposal  regulations  require  that  all  free-standing  liquid be
removed by decanting or  by mixing  with  sorbents before landfilling.  No
visible pools or layers  of liquid  are permitted  (Federal  Register,  March 22,
1982).  One common practice  is to  mix contaminated soils  with the drummed
waste to absorb the free liquid.   Other  absorbents commonly used  include
cement  kiln dust,  fly  ash, fuller's  earth,  saw dust,  and  vermiculite.  A
number  of other stabilization/solidification processes are available

                                       142

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including encapsulation, cement-based processes, thermoplastic processes,
organic polymer techniques, and lime-based processes.  Success with these
methods is highly waste specific.  The cement-based and lime-based processes
that use relatively cheap and readily available materials have more practical
applications than other solidification/stabilization methods.  Cement- and
lime-based solidification may be used to solidify inorganic sludges, although
the tendency at hazardous waste sites is to use absorbents such as saw dust,
fuller's earth, etc., rather than the more time-consuming solidification
processes.

Consolidation

     Large volumes of contaminated soils and solid wastes are generally
prepared for transport by combining compatible wastes and loading them in a
box trailer.  As indicated in Section 7, highly contaminated soils and
spilled waste materials that are excavated during the drum removal operation
either are transferred to a diked and lined storage area or vacuumed as
encountered using high-strength industrial vacuum loaders ("Vactor" or
"Supersucker".) .  Compatible solids and sludges in drums may be combined with
these highly contaminated soils to provide a more economical method of
packaging and transporting solid wastes.  Sludges and solids may be mixed
directly with the highly contaminated soils along with absorbent material to
create a stable waste pile that is free of visible liquids.  These wastes can
then be transferred to a box trailer truck, Vactor or Supersucker.  In
instances where the sludges and solids are to be transferred from drums to a
Vactor or Supersucker, the wastes should first be dumped into a compatibility
chamber to avoid reactions that could damage the vacuum system's storage box.
Where box trailers are being used, they should be lined and covered with a
layer of sorbent material.  The soils and solids can be rapidly transferred
into the box trailer using a backhoe or a front-end loader (Figure 43).

Handling Nonhazardous Soils

     Soils that are determined by laboratory analysis to be nonhazardous are
generally not landfilled but treated or left onsite.  There are several
alternatives available for handling slightly contaminated soils depending on
the type of wastes, the volume of soils, and the site location.  These
include:
     o  Backfilling excavation trenches if contaminant levels are very low

     o  Aerating the soils using a rototiller to release organic vapors

     o  Employing microbial degradation using indigenous or adapted
        microorganisms with or without addition of nutrients and air

     o  Using chemical treatment methods such as neutralization, redox
        reactions, or precipitation.
                                      143

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                                   Reproduced from
                                   best available copy._
Figure 43.  Combined  Handling of Sludges  and Contaminated
            Soils  at  the Chemical Control Site


      (Courtesy  of O.K.  Materials Co.,  Findlay, OH)

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GAS CYLINDERS

     Once compressed gases are identified by sampling, they can be disposed
of by one of several methods.  However, extreme care must be  taken in
choosing the appropriate treatment alternative and  in handling the gases.  If
possible, the gas supplier should be contacted for  appropriate handling
techniques.  Physical, chemical, and toxicological  data  for specific gases
should be consulted prior to selecting the appropriate treatment method.
Safe handling procedures should be followed at all  times.  The cylinders
should never be dragged even for short distances or permitted to strike each
other.  Protective caps should be kept over the valves at all times (Matheson
Gas Products, undated).

     Gas cylinders can be disposed of using the appropriate method discussed
below (Matheson Gas Products, undated):
     •  Return to the manufacturer or supplier if known

     •  Vent confirmed nontoxic gases - cylinders containing inert gases  such
        as helium, argon, or nitrogen do not represent a hazard unless  they
        are situated in a confined place with no ventilation.  The cylinders
        should be moved to a well-ventilated outside area, and the gases
        should be discharged or vented at a moderate rate.  After the gas has
        been discharged the valve should be closed.

     •  Chemical treatment - Some alkaline and acidic gases may be chemically
        treated but should be done so with extreme caution since these  gases
        are corrosive and toxic.  Alkaline gases are flammable, as well.

        Alkaline gases such as ammonia and the lower alkyl amines should  be
        handled as follows:  the cylinders should be moved to an isolated
        area free of all sources of ignition.  A control valve equipped with
        a trap or check valve should be attached to the cylinder and a  long
        piece of flexible hose should be connected to the control valve out-
        let.  The gas should then be discharged at a moderate rate into an
        adequate amount of sulfuric acid solution.  When the cylinder is
        empty, the control valve should be closed and the resultant solution
        treated and disposed.

        Acidic gases are handled similarly.  However, the gases should be
        discharged into an adequate amount of about 15 percent aqueous  sodium
        hydroxide.

     •  Destructive combustion - The best procedure for disposing of
        flammable gases is controlled burning in an isolated area.
                                      145

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LAB PACKS

     The first step in handling lab packs is to manually separate  the
individual bottles in the drums into categories of knowns, unknowns, and
debris.  This is accomplished by observing labels, physical  appearances,  and
general chemistry (i.e., pH, corrosivity, reactivity, explosiveness) of
contents, and by determining the origin of the lab pack itself.  Care  should
be taken to preserve any labels or partial labels present.

     Known materials are handled by segregating them  into compatible groups.
The chemically compatible bottles can either be repacked in  confortnance with
appropriate U.S. EPA, and DOT regulations regarding shipment, or they  can be
bulked for treatment or disposal.

     Unknowns should be stored separately from known materials.  If possible,
the generator of the lab packs should be contacted to assist in material
identification.  Containers that are unknown should be separated into  similar
groups based on such characteristics as physical state, color, particle size,
etc.  A shock test should be performed on samples from each  group  to deter-
mine whether it is safe to open the containers within tha group.   After the
shock test, the remaining containers should be opened, checked for visual
similarity, and randomly sampled for compatibility testing.

     Explosive fractions of lab packs must be handled with extreme care and
require the presence of an expert in explosives.  However, when there  is
reason to believe such chemicals are present, extreme care is necessary
during staging and characterization activities.  Aside from  the shock  test,
one indication of the presence of explosive or shock-sensitive compounds  is
the formation of crystals around the caps or within individual bottles.

     Any explosive material that is identified should first  be labeled and
placed within a remote bunker or staging area in a vermiculite filled
container until all of the waste is categorized.  The location of  a staging
area for explosive wastes should be based upon a careful evaluation of the
quantity of explosives and their relative hazard.  The staging area should be
enclosed with a fence or dike to minimize the adverse effects of any
premature detonation.

     The treatment of explosive or shock-sensitive wastes differs  from that
of other categories of hazardous wastes.  Typically,  these types of wastes
are either detonated or incinerated under very controlled conditions.
Detonation at a specially designated site or uncontrolled waste site,  if
sufficiently remote, is a widely accepted practice for disposal of
explosives.

      Once a sufficient quantity of explosive material has been categorized
and a remote site has been located for detonation, the State Fire  Marshall
should be contacted to detonate the wastes.  For the  removal and disposal of
explosive waste, one basic permit is required from the U.S.  Bureau of
Alcohol, Tobacco, and Firearms.  The permit requirement is associated  with
the actual transport of explosives and the purchase of any explosive


                                      146

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materials required  to detonate  the waste material.   Once  the  Federal  permit
is secured, written approval  from the State  and  local  governments  is  required
before detonation is begun.

     Typically, a bomb trailer  would be employed  to  transport the  wastes  to
the site.  Wastes would be segregated according  to their  chemical  compat-
ibility and shock sensitivity.  For example, very shock-sensitive  material
such as blasting caps and nitroglycerin would not be  transported with
nonshock-sensitive materials  possessing explosive properties.  This would
ensure that premature detonation of a shock-sensitive  item would not  result
in a detonation of more stable  explosives.

     Detonation should be accomplished by exploding  downward  into  clean,
moist earth.  At the Picillo  Farms site, the detonation area  was to be triple
lined with at least 2 feet of soil between each  layer  of  6 mil  polyethylene
plastic film (Perkins Jordan, Inc., 1982).   The  debris remaining after the
explosion should be cleaned up  before the next explosion  is prepared.


DRUM CRUSHING

     There are several options  available for handling  empty drums.
Generally, as the empty drums are excavated  or generated  during consolidation
they are transferred into a dump truck and hauled to  a drum crushing  area.
Depending upon the site and hazard of the wastes  which were stored in the
drums, the empty drums may be crushed daily  to minimize the release of
volatile compounds or they may  be stored temporarily.  If the.empty drums are
temporarily stored, measures  should be taken to  prevent the accumulation  of
precipitation in the drums and  leaching of residues  into  the  ground.   These
measures might include:  diking the empty drum staging area,  lining it with
plastic, clay, or sorbent material and covering  the  empty drums with  a liner
material.

     Before crushing, the drums should be checked for  liquid  and solid
residue.  Drums containing more than 5 centimeters (2  inches)  of residue
should not be considered empty.  Liquid residue  should be transferred to  a
compatibility chamber or reaction tank.  Solid residue should be shoveled or
scrapped out and transferred  to a bulk storage trailer.

     Use of a portable hydraulic drum crusher is  generally the most efficient
method for crushing large numbers of drums.  Drums can be crushed  to  a thick-
ness of 20 centimeters (8 inches) or less.   In instances  where  the residues
are highly toxic or difficult to remove, a drum  shredder  can  be used.  O.H.
Materials has a shredder that uses negative  air  pressure  to prevent escape of
vapors (personal communication  with R. Graziano  and  S. Insalaco, O.H.
Materials, Findlay, Ohio, 1982).  If the number  of empty  drums  onsite is  few,
a backhoe or front-end loader can be used for crushing.

     Generally, crushed drums are disposed of in  bulk  storage trailers
without segregating them into the compatibility  class  of  the  waste that they
contained.  However, some disposal facilities do  require  that  they be


                                      147

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segregated into compatible waste categories.  If there are very  few empty
drums onsite, it may be cost-effective to overpack them and haul  them with
drums to disposal.


DECONTAMINATION

     All equipment, facilities, and  field personnel must be decontaminated
before entering the clean zone.  Procedures for personnel decontamination are
detailed in  several of the references on waste site safety procedures listed
in Section 3 and will not be discussed here.

     The equipment decontamination area should preferably include a hard
surface pad (concrete or asphalt) that is diked or bermed to collect rinse
water and a collection sump from which the contaminated water can be col-
lected and treated.  Where the site  is highly degraded and further remedial
actions are anticipated, all of the  precautions may not be required.

     Equipment decontamination may include degreasing if required, followed
by high-pressure hot water rinsing with low volime nozzles, supplemented by
detergents and solvents, as needed (U.S. EPA, 1982c).  In winter  it may be
necessary, to add alcohol to water to prevent freezing.  In order  to reduce
the volume of rinse water generated, brushes and scrapers may be  initially
used to remove packed or caked contaminated soils.  Special attention should
be given to material on and within the tracks and sprockets of crawler
equipment, and tires and axles of trucks and rubber-mounted equipment (U.S.
EPA, 1981b).  Any small tools or personnel safety.equipment that  cannot be
decontaminated should be overpacked  and disposed of in a secure  landfill.

     Decontamination of temporary facilities erected onsite for  the cleanup
operation is generally limited to low-volume, high-pressure, hot  water
rinsing.  More rigorous decontamination procedures may be required for
warehouses or trailers if drums were stored in them.
                                       148

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                                  SECTION 10

                      INTERIM STORAGE AND TRANSPORTATION


STORAGE

Regulations Affecting Interim Storage Facilities

     Drum handling operations at hazardous waste sites freauently involve the
temporary storage of drums onsite.  Conditions may require that the drums be
stored for an undetermined period of time until additional funds become
available to transport them offsite or until a suitable site is located for
their final disposal.  In the event that drums may be stored longer than 90
days, the storage area(s) should comply with the intent of RCRA promulgated
standards (40 CFR, Part 264) for waste storage at RCRA permitted facilities
(treatment, storage, and disposal facilities).  Where onsite storage is
expected to occur for only a short duration, measures should nevertheless be
taken to provide some means of secondary containment and segregation of
incompatible wastes.

     In many instances the waste site is located in a confined or congested
area and it is not possible to meet the RCRA requirements for spacing and
layout.  For these cases, the state or on scene coordinator (OSC) may have to
make alternate provisions to minimize releases and maximize safety during
storage.  The discussion below focuses on RCRA requirements for storage of
hazardous wastes.  Less stringent storage requirements are generally
satisfactory for short-term storage.

Selection and Layout of the Temporary Storage Area

      RCRA requires that incompatible waste types be separated by dikes,
berms, walls, or other devices and that the entire storage area be secured by
fencing.  RCRA also requires that ignitable or reactive wastes be a minimum
of 15 meters (50 feet) from the site property line and separated from any
source that may cause them to ignite or react.  Although not specifically
mentioned by RCRA, special precautions may be required for specific waste
types.  For instance, gas cylinders and explosives, if stored in the open,
should be assigned to separate storage areas that are kept cool, dry, and
protected from sunlight and temperature extremes.  Adequate aisle space
should be maintained to allow the unobstructed movement of personnel, fire
protection equipment, etc., in the event of an emergency (40 CFR, Part 264).
The aisle space should also be adequate to carry out inspections and allow
adequate mobility for forklift trucks or other vehicles used in loading drums
for offsite transport.  These spacing requirements generally result in a


                                      149

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layout in which the drums are placed in long double rows or  in groups of  four
with adequate spacing between each row or group.

     When the waste site is located in a large unconfined area,  it may be
possible to be more discriminating about the location of the temporary
storage area.  The geohydrology of the site should be studied to determine
where there are low permeability soils in an elevated ground area  suitable
for the storage site.  This is particularly important in an  area with a high
water table.

Waste Containment Procedures

     RCRA regulations require that a permanent container storage area have  a
containment system capable of holding spills, leaks, and precipitation.   To
comply with this intent, there are several measures which must be  taken.
Generally, these measures would provide reasonable assurance of  waste
containment at a hazardous waste site without adding excessively to  the
cleanup costs.

     The interim storage area should have a base underlying  the  containers
that is free of cracks and gaps and is sufficiently impermeable  to contain
leaks, spills, and accumulated rainfall until the material can be  detected
and removed.  The storage area may be underlain by low permeability,
compacted clay; plastic liner material; or asphalt or concrete pads, provided
the material is compatible with the wastes.  Table 20 summarizes the
compatibility of various liner materials with several broad  waste  classes.
If the chemicals can be neutralized, an alternative would be to  cover the
base of the storage area with crushed limestone, shells, or  other
neutralizing materials.  The disadvantage of such neutralizing ground cover
is that it must be removed and replaced promptly in the event of a spill.

     An interim storage area should have sufficient capacity to  contain
10 percent of the volume of the containers or the volume of  the  largest
container, whichever is greater.  Run-on should be prevented unless  the
system has sufficient excess capacity'to contain it (CFR 40, Part  264).   This
is generally accomplished by constructing a system of dikes  or bertns around
the perimeter of the storage area as well as between areas containing incom-
patible wastes.  Dikes and berms may be constructed of well  compacted soils,
cinder blocks, or concrete.  Earthen dikes are ideally constructed of
erosion-resistant, low-permeability compacted clays, although, in  practice,
readily available soils and excavation equipment are often used  at waste
sites.  Table 21 lists different soil types and ranks them based on
percolation control and resistance to wind erosion.  Clay, silty clays,  and
silt are most suitable for dike construction.  The problem with  using
improper earth materials for constructing dikes and berms is exemplified  by a
problem that occurred at the Seymour Site in Indiana.  Originally, a sand
dike was built at a storage area on the site at a cost of $800,000.  The  dike
washed away in a heavy rainfall and had to be replaced by a  clay dike
(Hazardous Waste Report, 1981).  Earthen dikes constructed of less suitable
materials can be stabilized by mixing the soil with bentonite or fly ash  and
lime or by coating the surface of the dike with an asphaltic emulsion.


                                      150

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                         TABLE 20.  LINER-INDUSTRIAL WASTE COMPATIBILITIES
Liner
Material
Soils:
Compacted clayey soils
Soil-bentonite
Admixes :
Asphalt-concrete
Asphalt-membrane
Soil asphalt
Soil cement
Polymeric membranes:
Butyl rubber
Chlorinated polyethylene
Chlorosul fonated poly-
ethylene
Ethylene propylene
rubber
Polyethylene (low den-
sity)
Polyvinyl chloride
Caustic
Petroleum
Sludge

P
P

F
F
F
F

G
G

G

G

G
G
Acidic
Steel-
Pickling
Waste

P
P

F
F
P
P

G
F

G

G

F
F
Electro-
plating
Sludge

P
P

F
F
P
P

G
F

G

G

F
F
Toxic
Pesticide
Formula-
tions

G
G

F
F
F
G

F
F

F

F

G
G
Oil
Refinery
Sludge

G
G

P
P
P
G

P
P

P

P

F
G
Toxic
Pharma-
ceutical
Waste

G
G

F
F
F
G

F
F

F

F

G
G
Rubber
and
Plastic

G
G

G
G
G
G

G
G

G

G

G
G

G - Good,  F = Fair, P =  Poor.
Source:   Stewart, 1978.

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        TABLE 21.  RANKING OF SOIL TYPES BASED ON PERCOLATION  CONTROL
                        AND RESISTANCE TO WIND EROSION

Soil Type
Gravel
Silty Gravel
Clayey Gravel
Sand
Silty Sand
Clayey Sand
Silt
Silty Clay
Clayey Silt
Clay
Ranking
Impe ding
Percolation
10
7
5
9
8
6
4
2
3
1
for
Resistance to
Wind Erosion
1
3
5
2
4
6
7
8
9
10

 Assuming low soil moisture and no cover vegetation.

Source:  Lutton, 1979.
                                      152

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     RCRA  standards  also  require  that  storage  areas  be  designed for
sufficient drainage  so  that  standing water  or  wastes do not  remain on the
base longer  than  1 hour after a spill  or  precipitation  event  unless the
containers are  elevated to protect  them  from contact with the liquid.  A
frequent practice is  to elevate the containers on  pallets to  avoid contact
with standing liquid.  Another practice  is  to  have the  liquid drain into a
collection sump equipped  with a sump pump that is  usually manually activated
to remove  the liquid.  Depending  on the  type and concentration of contam-
inants, this liquid may be run through an oil-water  separator, pumped to a
collecting tank, or discharged to a treatment  plant.

     The integrity of the drums and containers must  be  maintaned  in order to
minimize the possibility  of  spills and leaks.   There are several  measures
commonly taken to ensure  this integrity.  RCRA requires that  container
storage areas be inspected weekly for  container leaks and deterioration (CFR
40, Part 264).  This practice should be upheld, regardless of whether or not
storage is temporary.  Visual inspections for  leaks  and deterioration should
be supplemented with air  monitoring of volatile organics or combustibles.   If
drums begin  to swell it will be necessary to vent  them  to relieve the.
pressure.  Where overpressure is  slight,  hand  tools  may be used.   Venting
should be done remotely if containers  are critically swollen  (head raised
several centimeters above chime).

     A number of cover materials  are available for minimizing corrosion of
drums.  Drums caps, which are available in  chemical  and UV light  resistant
rubber (Uniroyal Chemical, 1981), or as thin,  clear  polyethylene  "shower
caps" (BASCO, 1982), offer some degree of protection against  weathering.
Plastic sheets also have  been used to  cover drums  during temporary storage.
However, this practice is not safe because  the sheeting can cause a
"greenhouse  effect" that  can lead to overpressure  in the drums.  Canvas
provides a more suitable  cover material,  however it  makes inspections
difficult.  At the Stump  Gap Creek site in  West Point,  Kentucky,  empty drums
and those containing sludges were stored  in diked  areas, covered  with
plastic, and topped with  a foot of soil to  minimize  the "greenhouse effect"
(U.S. EPA, 1981).  The soil cover, however,  makes  it impossible to inspect
the containers.

     Roofing provides the highest degree  of protection  against weathering and
may be advisable to minimize exposure  of  gas cylinders  and explosives to
sunlight and prevent contact of water  reactive wastes with rainwater.


TRANSPORTATION

Regulations Affecting Transportation of Hazardous  Wastes

     The transportation of hazardous wastes  is  regulated by the Department of
Transportation, the Environmental Protection Agency, the States,  and, in some
instances, by local ordinances and codes.   In  addition,  more  stringent
Federal regulations also  govern the transportation and  disposal of highly
                                      153

-------
 toxic  and hazardous materials  such  as  PCBs  and  radioactive  wastes.
 Applicable Department  of Transportation  regulations  include:


     •  Department of  Transportation 49  CFR 172-179
     •  Department of  Transportation 49  CFR 387 (46  FR 30974,  47073)

     •  Department of  Transportation DOT-E  8876.


     The U.S. EPA regulations  under RCRA (40 CFR  Part  263)  adopt  DOT  regula-
 tions pertaining to labeling,  placarding, packaging, and  spill  reporting.
 RCRA regulations also  impose certain additional requirements  for  compliance
 with the manifest system and recordkeeping.  Specific  shipment  and  packaging
 requirements are set forth under 49 CFR  Part 173.  Requirements for shipping
 containers are outlined in 40  CFR Part 178,  and specifications  for  tank  cars
 are given under 40 CFR Part 179.  Additionally, Section 108  (b)(5)  of CERCLA
 imposes upon motor carriers the financial responsibility  requirements of
 Section 30 of the Motor Carrier Act of 1980 (PL 96-296).  Section 30  requires
 the issuance of regulations for minimal  levels  of  financial  responsibility to
 cover public liability, property damage,  and environmental  restoration
 required as a result of waste  transportation (U.S. EPA, 1981b).

     State regulations required for hazardous material  transportation are
 generally similar to the EPA transportation regulations.  However,  many  of
 the States that have received  EPA authorization to run  their  own  hazardous
 waste programs under RCRA have adopted rules for  transporters  that  are more
 stringent than the Federal program.

     Local codes and ordinances may also  govern the  transportation  of
 hazardous waste.  These may include weight  limitations  on roads and bridges
 as well as prohibiting the use of some local roads.

 Procedures for Offsite Transport

     Vehicles for offsite transport of hazardous wastes must  be DOT approved
 and must display the proper DOT placard.  Liquid wastes must  be hauled in
 tanker trucks that meet certain requirements and  specifications for the  waste.
 type.  Contaminated soils are  hauled in box trailers and  drums  in box
 trailers or flat bed trucks.   The trucks  should be lined  with plastic and/or
 covered with absorbent material.  A typical 12-meter (40-foot)  truck  is
 capable of transporting about  80 drums in a single haul.  The number  of  drums
 permitted, however, depends on the weight of the container material.   The
majority of States permit a gross weight  of 36,000 kilograms  (80,000  Ib) in a
 single transporter.  The number of drum  stacks  a hauler will  permit depends
 on the distance of transport,  the type of material,  and the  State
 regulations.
                                      154

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     To comply with DOT  and EPA regulations, drums must be  handled  as
 follows:
     •  Wastes must be contained  in DOT-approved drums  for  the  specific  waste
        type

     •  Each drum must be  individually  labeled with  the appropriate  DOT
        hazard classification

     •  Drums must be thoroughly  cleaned  to  remove any  residue,  defective
        parts must be replaced, and drums must show  no  visible  evidence  of
        pits, creases, or  reduction in  parent material  thickness

     •  Drums containing incompatible wastes are not permitted  to be hauled
        on the same vehicle.
     Mildly contaminated soils, empty and crushed drums,  and  other  debris
not highly contaminated or DOT regulated are frequently hauled  in dumpsters
with sealed tailgates, particularly when the volume  is so large that  the cost
is prohibitive to place the materials in drums.  Where dumpsters are  used,
they should be lined with polyethylene sheeting and  covered with polyethylene
or a tarpaulin.

     The hazardous waste manifest must be signed by  the OSC and transporter
before shipping bulk liquid or drums containing hazardous wastes.   The
manifest summarizes the total quantity of drums or liquid waste and their
respective DOT chemical and hazard classification.

     Before a vehicle is allowed to leave the site,  it should be rinsed or
scrubbed (Section 10).  Before a bulk liquid container is permitted to leave
the site it should be inspected for the following:


     •  Proper placarding

     •  Proper venting

     •  Closed valve positions
     •  Secured hatches

     •  Excess liquid levels
     •  Proper tractor-to-trailer hitch

     •  Cleanliness
     •  Tire conditions.
                                      155

-------
     Before a box trailer is permitted to leave  the  site  it  should  be
inspected for the following items:
     •  Correct line installation
     •  Secured cover tarpaulin
     •  Locked lift gate
     •  Proper placarding
     •  Proper tractor-to-trailer hitch
     •  Excess waste levels
     •  Cleanliness (Di Napoli, 1982).
                                      156

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                                   SECTION  11

                   ONSITE  CONTAINMENT  OPTIONS  FOR BURIED DRUMS
     The use  of source control measures  to  contain  or  control  migration of
contaminants  from buried drums generally is  preferred  over  excavation and
removal of wastes for the  following  reasons:


     •  Excavation of buried drums may present  greater hazards to  site workers
        and nearby residents.

     •  For sites with a large number of drums,  excavation  is  likely to be
        more  costly than onsite containment.


Excavation and removal of  drums may  be preferred.   However, where  onsite
containment is not feasible, excavation  is  either more cost-effective (i.e.,
very few drums) or is necessary to protect  public health  or the  environment.
Generally, the design, application,  and  implementation of remedial measures
for controlling or containing migration  from buried drums are  similar to those
required for bulk wastes.  However,  two  additional  factors  should  be
considered where large numbers of buried drums  are  involved:


     •  Added precautions may be required during remedial actions  at drum
        sites to avoid explosion of  drums close  to  the working surface.

     •  The nature and concentration of  contaminants in the leachate may
        change with time as drums rupture and leak.


SELECTION OF REMEDIAL MEASURES FOR CONTROL  OR CONTAINMENT OF WASTES

     The NCP  (Section 300.70) identifies  a number of remedial  measures for
controlling or containing wastes from abandoned  sites.  These  remedial
measures can be grouped into six general  categories.   Within each  category
there are specific measures that can be  applied  to  a given  situation.   The six
categories are as follows:


     •  Surface capping and sealing  (with or  without gas  venting)

     •  Surface water controls

     •  Groundwater pumping (with or without  tre'atment)

                                      157

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     •  Subsurface drains (with or without treatment)
     •  Slurry walls
     •  In-situ treatment.                                           ^


     These categories are groupings of the available onsite containment
options identified in the NCP.  It is essential to consider site-specific
conditions before selecting a specific remedial alternative.  The  selection
should be conducted by a detailed process that is beyond the scope of this
document.

     The control and containment categories presented above are described in
Tables 22 through 27 in terms of their applications, limitations, design and
construction considerations, flexibility, reliability, and relative costs.  It
should be emphasized that these* are categories of remedial alternatives and
site-specific conditions will influence their selection or applicability.
These remedial alternatives may be used singularly or in combination.
However, the objectives of the remedial action must be clearly established
prior to selection and remedial design.  The objective can vary from simple
procedures to minimize infiltration to a relatively complete hydrologic
isolation of the site.

     Tables 22 through 27 briefly show how these containment options apply to
sites with buried drums.  These tables are not intended to provide a site-
specific detailed remedial alternative selective outline.  Instead they
provide a logical starting point for the remedial alternative selection
process.  In support of this selection process, there are a number of
documents available on the detailed selection, design, and implementation of
remedial techniques for waste sites.  Some of the documents are listed below.


     •  Handbook for Remedial Actions at Waste Disposal Sites.  (U.S. EPA,
        1982b)

     •  Leaehate Plume Management.  (U.S. EPA, 1985, At Press)

     •  Technical Handbook:  Slurry Trench Construction for Pollution
        Migration Control, (U.S. EPA, 1984b)

     •  Alternatives to the Land Disposal of Hazardous Wastes, (Toxic Waste
        Assessment Group, State of California, 1981).

     •  Case Studies!  Remedial Response at Hazardous Waste Sites, (U.S. EPA,
        1984c)


These and other pertinent documents should be consulted during preparation of
the  feasibility study and final design for remedial measures.  Additional
documents are in preparation and when available, should also be considered.
                                      158

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                         TABLE 22.    CONSIDERATIONS  FOR THE SELECTION, DESIGN,  AND  IMPLEMENTATION
                                            OF CAPPING  AND SURFACE SEALING  TECHNIQUES
Ul
VO
Design and Construction
Applications limitations Considerations
• Minimize infiltration • Liners stay crack • Extensive subgrade prepara~
of precipitation if Isndfill, tion nay be required to
etc., is subject elininate irregularities
• Control upward to settling
nigration of gases • Potential capping and
sealing materials include:
• Control erosion • Some sealants native fine-grained soils;
with proper are incompatible bentonite; asplialtic
vegetative cover with various materials; synthetic mem-
wastes types branes, cement a; and soil
sealants. Waste-sealant
incompatibility should be
a major factor in selecting
the moat appropriate
aealant or cap

• Gas collection or venting
systems may be required
along with capping if gas
migration is a problem

• Precautions are needed to
protect construction
workers againat explosion
and fires during capping
Flexibility*
• Design flexibility is
limited when caps or
sealants are used
atone; however, when
used together with
slurry walla.
dewatering, or gas
migration controls,
capping can greatly
increase the flexi-
bility of these
techniques

• Some liners have low
tolerance to change
in leachate compo-
sition and concentration








Reliability
• High when •
compatibil ity
and site-speci-
fic variables •
are' considered
in the
selection of
sealant or cap •

• Performance of
some synthetic
membranes and
asphalt is
affected by tem-
perature extremes
and sunlight

• Prolonged contact
with incompatible
wastes <;sn
result in
cracking, shrink-
age, etc., of
sealants and caps

Costs
Capital costs
are generally low

Operating and main-
tenance costs are
relatively low

When used together
with dewatering
systems, sealants
and caps can
markedly decrease
costs

'










    ^Flexibility is used to describe the ability of the remedial action to (I) withstand  changes in
     leachate composition and quantity  (operational flexibility) and (2) accomplish various
     remedial action objectives (design flexibility).

    Note:  Information in this table was gathered  from JRB in-house sources, including staff
          experience, and is intended  to provide general guidance.

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                      TABLE 23.   CONSIDERATIONS  FOR THE  SELECTION, DESIGN,
                                                     OF  SURFACE  WATER CONTROLS
AND  IMPLEMENTATION

Appl icationi
• Dikes and berraa can •
be used to direct
upland flow around
a disposal area; •
provide erosion or
flood protection;
and contain contami-
nated runoff;

• Ditches are used
upslope of a disposal

Limitations
Limited to small
drainage areas

Earthen structures
(dikes, berma ( and
and ditches) are
generally intended
as a temporary
measure until more
permanent actions
can be taken
Design and Construction
Considerations
• Seeding and mulching,
linera, or chemical stabil-
izers can be used to extend
the life of these structures

• Frequently, a combination of
surface water controla are
neceaaary




Flexibility*
• Moderate to high —
structures can be
eaaily modified
to account for changes
in flow or voline







Reliability
• Moderate
— earthen
structures
are subject to
erosion and
flood damage

• Continued main-
tenance is
required for
long-term use

Costs
• Low capital



costs

• Low O4M costs

• Generally no
val ue .






salvage






   area to channel runoff
   to a downslope outlet

•  Chutes and downpipes
   are used to convey
   flow from top to
   bottom of a slope
   without causing
   erosion

•  Holding ponds and
   basins are used to
   temporarily store
   collected runoff
*Flexibility ia used  to describe  the ability of the remedial action  to (I) withstand changea  in
 leachate composition  and quantity (operational flexibility) and  (2) accomplish various
 remedial action objectives (design flexibility).
Note:   Information  in this table was gathered from JRB  in-house  sources, including staff
       experience,  and  is intended to provide general guidance.

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                      TABLE  24.    CONSIDERATIONS FOR  THE SELECTION,  DESIGN,  AND  IMPLEMENTATION
                                               OF GROUNDWATER PUMPING  TECHNIQUES
Appl icat ions
• Use of ex tr set ion
wells to remove or
contain a pi me or
lower the water
table beneath the
disposal area

• Use of injection
wells to divert
or dilute a plume
and reinject
clean groundwater

• Use of injection
and extraction wells
in combination to
contain a plume or
recycle ground-
water

Limitations
• Generally cost
prohibitive in
low transmisai-
vity aquifera

• Highly corrosive
wastes can corrode
pumps, casings,
etc.

• Viscous wsstes may
clog pimps








Design and Construction
Considerationa
• Deaign and operation can be •
difficult in very hetero-
genoua soils

• Certain natural components
of groundwater (i.e., iron, •
manganese, calcium carbon-
nate) can clog well screens
and reduce efficiency

• Location of subsurface
utilities and power lines
must be determined

• Hells can be tampered with;
security measures are required

• Steep hydraulic gradient
can distort the cone of
influence; more water
Flexibility*
High operational flexi- •
bil ity — can meet
increased or decreased
pumping depends

High design flexibility-
can be used to accomp-
lish almost sny
abjective in con-
trolling groundwater •
contaminat ion
,



•




Reliability
Haa electrical •
and mechanical
parts that are
subject to fail- •
ure. However,
parts can be •
replaced easily
and quickly

Technology ia
well demonstrated.
and experienced
firms are widely
available

If the systems
operation ia
interrupted,
contaminants can
escape
Costs
Capital costs are
high to moderate

O&M costs are high

Generally requires
treatment that
greatly increases
costs











   Used together with
   capping and slurry
   walla to hydro-
   logic ally isolate
   the site

   Usable in rock
   and unconsolidated
   material

   Usable in confined
   and unconfined
   aquifers
tends  to be puaped  from
upgradient areaa
•Flexibility ia used to describe the ability of the remedial  action to (1) withstand  changes in
 leachate composition and quantity (operational flexibility)  and (2) accomplish varioua
 remedial action objectives (design flexibility).
Hote:
       Information  in this table was gathered from JRB in-house aourcea,  including ataff
       experience,  and ia intended to provide general guidance.

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                          TABLE 25.    CONSIDERATIONS  FOR THE SELECTION,  DESIGN,  AND IMPLEMENTATION
                                                     OF SUBSURFACE  DRAINAGE SYSTEMS
Nl
Applications
• Suitable for
removing or con-
taining a plume
and for lowering
the water table
beneath a dis-
poaal area

• Hay be better suited
than pumping in low
tranamiasivity
aqui fers

• Can be uaed with
capping and slurry
walla to hydro-
logically isolate
a site














Limitations
• Generally limited
to shallow or
floating plumes
because of equip-
ment limitations
and the need for
shoring during
construction

• Poorly suited to
contaminants

• Hay be cost pro-
hibitive in sreas
with frequent rock
outcrops

• Hay not be
well suited
above or below
highly permeable
soils; groundwater
may flow prefer-
entially into
permeable, layers







Design and Construction
Considerat ions
• Since drains are gravity
flow systems, hydraulic
gradient significantly
affects design

• High percentage of fines
in soil may result in
drain clogging

• Subsurface featurea and
with installation and
function

• Large quantities of
contaminated soils may
be generated during
excavation

• Certain natural components
of groundwater can form
precipitates which clog
drains and filters










Flexibility*
• Moderate operational
flexibility, can accom-
odate aorae changes in
leachate volume but ia
considerably leas
flexible than pumping

• Moderate design
flexibility; can be used
to accompliah several
trolling groundwater
contamination

• Low tolerance to change
in leachate viscosity
or solubility
















Reliability Costs
• System relia- • Capital coats are
bility is high high
if properly
constructed and • O&H costs are
maintained low to moderate

• Technology is • Generally treatment
well proven is required that
although design significantly
and operation of increases O&H costs
hazardous waste
sites is limited

• Sudden unex-
pected fail urea
are unlikely
aince draina are
a passive col-
lection system

• If drain failure
does occur over-
time, repairs are
likely to be
time consuming
and costly; may
need to employ
pumping tech-
niques to prevent
escape of con-
tamination during
repairs
    •Flexibility is  used to describe  the ability of  the remedial action to (I) withstand changes  in
     leachate composition and quantity (operational  flexibility) and (2) accomplish various
     remedial action objectives (design flexibility).

    Note:   Information in this table  was gathered from JRB in-house sources, including  staff
           experience, and is intended to provide general guidance.

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                   TABLE  26.   CONSIDERATIONS FOR  THE SELECTION,  DESIGN   AND  IMPLEMENTATION
                                                         OF SLURRY WALLS
Applicationa

a Generally uaed
together with
capping, dewatering.
etc.

a Circiaaferent ial
alurry walla uaed
together with capp-
ing and pumping or
draina to completely
dewater a aite

• Uaed downgradient
of a aite to
capture teachate

• Used upgradient
of pumping or
drainage system
to prevent dilution
by clean water

• Uaed together with
dewatering upgrad-
ient of a aite to
divert the flow of
groundwater around
a aite

• Suitable for
•iscible, or non-
•iacible plumes








Limitations

a Dewatering techn-
ique a (pumping or
draina) are almost
alwaya required
together with
alurry valla to
prevent over-
topping of the
wall or to mini-
mile contact with
leachate which
could degrade the
wall over time

• Depth ia limited
only by the coat
of excavation and
capabilitiea of
trenching equip-
ment (24 meter a
modified backhoe;
45 metera or more
for clamshell)

• May be coat pro-
hibitive in very
rocky areaa

• Prolonged contact
with aome waatea
may degrade the
wall (i.e. atrong
acida and baaea,
inorganic sslts,
aome orfanice)





Deaign and Construction
Considerations

• Hell muat be keyed into an a
aquilude in order to
to control water miacible or
denae plumes. Bottom grout- •
ing can be uaed to aeal
fractured bedrock

• Cement bentonite walla are
leaa chemical resistant
than aoil bentonite walla •

• Cement bentonite walla are
better auited than aoil
bentonite walla in areaa
subject to heavy traffic
loada or other heavy
atreaaea























Flexibility*
•
De a i gn f 1 ex ibility ia
low when used alone

When uaed together
with other remedial
actiona, alurry walla
can significantly
increaae flexibility

Hay have low tolerance
to changee in leachate
composition eapecially
increaaed acidity or
baaicity or preaence
of highly concentrated
aluga
























Reliability
.
well demon-
atrated aa a
means of •
dewatering
during conatruc- •
tion but limited
performance data •
ia available on
use of alurry
walla at waate
• itea

• Hall integrity
may be degraded
over time by
prolonged con-
tact with
certain typea of
contaminants

• Piping failure
can reault from
{•proper mixing
of backfill
during
conatruction

• Permeability can
be as low aa
10 cm/aec for
aoil bentonite
walla

• Reliability can
be increaaed by
reinforcing the
integrity of the
wall with a
aynthetic liner
Coata

very high

O4M coata are low

No aalvage value

When uaed ogether
with dewat ring
ayatem, al rry
walla can ignifi-
cantly dec ease
MM coata



























•Flexibility ia uaed  to describe the ability of the remedial  action to (I) withatand change! in
 leachate composition and quantity (operational flexibility)  and (2) accomplish varioua
 remedial action objectivea (deaign flexibility).
Note:
      Information in  this table wai gathered  from JRB in-house sources including ataff
      experience, and ia intended to provide general guidance.

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                      TABLE  27.   CONSIDERATIONS  FOR  THE  SELECTION,  DESIGN
                                                OF  IN-SITU TREATMENT TECHNIQUES
AND IMPLEMENTATION
• In-place treatment
of a contaminated
groundwater plume

aoil to reduce
contaminants to an
acceptable level

• Techniques include
bio reclamation,
oxidation-reduction,
neutral i zat ion ,
precipitation,
polymerization, etc.























• Bioreclanation: •
- aui table for
relatively bio-
degradable waatea
only (i.e., high
BOD/COD ratio)

- not well-suited
where groundwater
temperatures are
leas than 60*F

- better suited
to permeable
substrate
• Chemical treatment:

- highly waate
apecific

- generally
limited to
highly permeable
substrata
•
- chemicals used
for treatment are
often toxic and
could further
contaminate
groundwater

- may be difficult
to achieve good
contact between
wastes and treat-
ment reagents
Bioreclamation: • Operational flexibility
- requires hydraulic mani- ia limited; techniques
pulation of the plume; are highly waate
plume can be contained apecific and have a low
by extraction wells or tolerance to change in
aubsurface drains and can leachate composition
be recycled by injection or concentration
wells

- microorganisms can
include indigenous
organisms with or without
nutrient additions, or
adapted or genetically
engineered organisms
- Groundwater may require
pH amendment if too
acidic or baaic

- additional oxygen aource
is generally required
(i.e., aeration, zone,
hydrogen peroxide)

Chemical Treatment:
- as with bioreclamation.
requires hydraulic mani-
pulation of the plume

- Treatment reagenta must
be selected carefully
since many of the
reagents are toxic




• Hethoda have not • Capital coats -
been well demon- moderate to high
atrated for
treatment at • O&M coata can be
hazardous waate aigni f icantly lower
sites than with pumping
or draina aince
• In the event of there ia no need for
pump failure offaite or above-
treatment chem- ground treatment
icala, micro-
organiama and
waate contaminants
can eacape
containment
• For certain
chemical treat-
ment met hod a
(i.e., precipi-
tation and poly-
merization)
there is the
potential for
reveraal of
react iona





'
<





'Flexibility is used to describe the ability of the remedial action to (I) withstand changes in leachate composition and quantity (operational
 flexibility)  and (2)  accomplish various remedial action objectives (design flexibility).

Note:  Information in  thi* table was gathered from JRB  in-house  sources,  including staff experience, and is intended to provide general guidance.

-------
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                                     165

-------
10.  Carson, A.B.   1961.   General Excavation Methods.  F.W. Dodge Corporation,
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-------
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                                      167

-------
37.  Horton, K.A., R.M. Morey, L. Isaacson, and R.H. Beers.  1981.  The
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     Cine innati, Ohio.


                                      168

-------
49.  Mathamel, M.  1981.  Hazardous Substance Site Ambient Air Character-
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                                      169

-------
60.  PHOTOVAC, Inc.  1980.  Photovac Introduces the 10A10.  Thornhill,
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                                      170

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     and Conestoga-Rovers and Associates,  Inc.


                                      171

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83.  U.S. Environmental Protection Agency.  1983a.  U.S. Ground  Water
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93.  Vanell, L.D.  1982.  Identifying and Measuring Hazardous Spills On Site.
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                                      172

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95.  Yaffe, H.J., N.L.  Cichowicz, and P.J. Stoller.  Remote Sensing for
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                                      173

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                             SELECTED BIBLIOGRAPHY
Pojasek, R.B., ed.  1979.  Toxic and Hazardous Waste Disposal.  Volume  I:
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     Arbor Science Publishers, Inc.

Sittig, M.  1979.  Incinceration of Industrial Hazardous Wastes.  Noyes Data
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Sittig, M.  1980.  Metal and Inorganic Waste Reclaiming Encyclopedia.   Noyes
     Data Corporation.  Park Ridge, New Jersey.

Tierney, D.R., et al.  1978.  Source Assessment:  Reclaiming of Waste
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     Research Corp., Dayton, Ohio.

Battelle Memorial Institute.  1974.  Program for the Management of Hazardous
     Wastes, Volumes I and II.  EPA SW-530/54c-l; NTIS/PB 233-630, Richland,
     Washington Pacific Northwest Laboratory.

Brown, B.J., et al.  1977.  Assessment of Techniques for Detoxification of
     Selected Hazardous Materials.  EPA/600/2-77/143; NTIS/PB 272-783,
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De Renzo, D.J., ed.  1980.  Biodegradation Techniques for Industrial Organic
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De Renzo, D.J., ed.  1978.  Unit Operations for Treatment of Hazardous
     Industrial Wastes.  Park Ridge, New Jersey:  Noyes Data Corp.

The Marquardt Company.  1977.  Destroying Chemical Wastes in Commercial Scale
     Incinerators.  Facility Report Numbers 1 and 2.  EPA/SW-122c-l; NTIS/PB
     265-541, Clausen, J.F., et al. TRD, Redondo Beach, California.

U.S. EPA.  1980.   Guide to Disposal of Chemically Stabilized and Solidifed
     Waste.  SW-872, Washington, D.C.

Hackman III, E.E.  1978.  Toxic Organic Chemicals Destruction and Waste
     Treatment.  Park Ridge, New Jersey:  Noyes Data Corp.

Lande, S.S.  1978.  Identification and Description of Chemical Deactivation/
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     EPA/530/Sw-165c; NTIS/PB 285-208, Syracuse Research Corp., New York
     Center for Chemical Hazard Assessment.
                                      174

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Metry, A.A.  1977.  New Concepts in Hazardous Waste Management.  Proceedings
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Metry, A.A.  1979.  "An Overview of Residual Waste Treatment Technology."
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IT Enviroscience.  1979.  Model Regional Hazardous Waste Recovery and Disposal
     Facility.  Los Angeles Department of Natural Resources, Los Angeles,
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Berkowitz, J.B.  1977.  Physical, Chemical, and Biological Treatment
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Berkowitz, J.B.  1976.  Physical, Chemical, and Biological Treatment for
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     Little, Inc., Cambridge, Massachusetts.

National Environmental Research Center.  1974. Physical-Chemical Processes.
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U.S. Environmental Protection Agency.  1974.  Resource Recovery and Source
     Reduction.  Second Report to Congress.  NIIS/PB 253-406, Washington, D.C.

U.S. Environmental Protection Agency.  1975.  Resource Recovery and Waste
     Reduction.  Third Report to Congress.  EPA SW-161; NTIS/PB 255-141,  Solid
     Waste Management Office, Cincinnati, Ohio.
                                       175

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               APPENDIX
HAZARDOUS WASTE COMPATIBILITY CHART
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14
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It
IJ
1*
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20
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22
21
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it
n
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M
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M
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in
IN
10*
IM
it?
•uwcnvmciwuFNAM
**Lmm*m.»--—*,
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|l hW|^OTV
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Source:  Hatayama et al., 1980a
                             177

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