EPA/530-SW-87-002A
Technical Resource Document for Obtaining
Variances from the Secondary Containment
Requirement of Hazardous Waste Tank Systems
Volume 1: Technology-Based Variance
Prepared by:
Office of Solid Waste
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Frbruary 1987
U.S Environment*! Protection Agency
Region V, Library
2300 South Dearborn Str««t
HliMrtt i06»4
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DISCLAIMER
This report was prepared under contract to an agency of the United States
Government. Neither the United States Government nor any of its
employees, contractors, subcontractors, or their employees makes any
warranty, expressed or implied, or assumes any legal liability or
responsibility for any third party's use of or the results of such use of
any information, apparatus, product, or process disclosed in this report,
or represents that its use by such third party would not infringe on
privately owned rights.
Environmental Protection Agency
11
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TABLE OF CONTENTS
Page No.
EXECUTIVE SUMMARY ES-1
1. INTRODUCTION 1-1
1.1 Purpose and Scope of Technical Resource Document 1-1
1.1.1 Background.... 1-1
1.1.2 Purpose of this Document 1-1
1.1.3 Who May Apply for Variances 1-1
1.1.4 The Secondary Containment Requirement 1-2
1.1.5 Rationale for Allowing Variances from the
Secondary Containment Requirements 1-3
1.1.6 Equivalency Versus Effective Containment ....... 1-4
1.1.7 Organization of Document 1-5
1.1.8 Information Sources ........ . 1-6
1.2 Overview of Variances 1-6
1.2.1 Technology-Based Variances 1-7
1.2.2 Risk-Based Variances 1-12
2. PROCEDURES FOR SUBMITTING VARIANCE APPLICATIONS 2-1
2.1 General 2-1
2.2 Format and Content of Appl ications 2-1
2.2.1 Risk-Based Variance 2-1
2.2.2 Technology-Based Variance 2-1
2.3 Information to be Submitted 2-2
2.3.1 Notice of Intent to Submit 2-2
2.3.2 When to Submit Applications 2-9
2.3.3 Approval/Disapproval Procedures for Interim
Status and Less Than 90-Day Accumulation
Tank Systems ... 2-9
2.3.4 Approval/Disapproval Procedures for Tank
Systems Receiving a RCRA Permit Per
40 CFR Part 270 2-10
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TABLE OF CONTENTS (Continued)
Page No.
2.4 Risk-Based Preliminary Screening Procedure 2-10
2.5 Technology-Based Preliminary Screening Procedure 2-17
2.5.1 Location Criteria 2-18
2.5.2 Catastrophic Release and Transport
Through the Unsaturated Zone 2-18
2.5.3 Catastrophic Release and Surface
Transport - Overland 2-22
2.5.4 Existing Tank System Integrity 2-31
2.6 Relationship with Other Rules, Policies, and
Guidelines 2-31
2.6.1 Risk-Based Variance 2-31
2.6.2 Technology-Based Variance 2-31
3. TECHNOLOGY-BASED VARIANCE INFORMATION AND DATA NEEDS 3-1
3.1 Overall Description of System and Why Variance
Is Being Sought 3-2
3.2 Characterization of Tank System and/or Operating
Procedures 3-3
3.2.1 Tank System Design 3-3
3.2.2 Corrosion Protection 3-8
3.2.3 Information on Existing Tank Systems 3-14
3.2.4 Overfill and Spill Protection Features 3-14
3.3 Source Characterization 3-19
3.3.1 Physical and Chemical Characteristics of
Stored Materials 3-19
3.3.2 Potential Worst-Case Release Volumes 3-23
3.4 Characterization of Site Hydrogeologic Conditions 3-29
3.4.1 Investigative Techniques 3-29
3.4.2 Climatic and Meteorological Data 3-29
J.4.3 Site Geology 3-35
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TABLE OF CONTENTS (Continued)
Page No.
3.5 Determination of Zone of Engineering Control 3-39
3.5.1 Genera] Procedures " 3-39
3.5.2 Relationship of Zone of Engineering Control
to Migration Time and Remediation Time 3-43
3.6 Leak Detection System Evaluation 3-43
3.6.1 Internal Leak Detection Systems 3-47
3.6.2 Perimeter Leak Detection Systems 3-51
3.6.3 Unsaturated Zone Monitoring Systems 3-59
3.7 Determination of Waste Travel Time 3-70
3.7.1 Overland Flow „ 3-70
3.7.2 Unsaturated Zone Flow 3-78
3.8 Response Contingency Plan 3-95
3.8.1 Preparation of Response Plan 3-96
3.8.2 Submittal of Response Plan 3-106
3.9 Demonstrate Adequacy of Detection and
Remedial Action 3-106
3.9.1 Preparation of Demonstration 3-106
3.9.2 Submittal of Variance Application 3-110
4.0 REFERENCES 4-1
APPENDIX A: Information Sources for Environmental
and Hydrogeologic Information A-l
APPENDIX B: Full Text of July 14, 1986, Standards for
Hazardous Waste Storage and Treatment Tank
Systems and Generators (51FR25471-25486) .. B-l
APPENDIX C: Unsaturated Zone Monitoring Instruments ... C-l
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LIST OF TABLES
Page
Table 2-1 Range of Saturated Hydraulic Conductivity 2-23
Table 2-2 Typical Values of Saturated Hydraulic
Conductivity (C Values) 2-24
Table 3-1 Nationally Accepted Tank Design Standards 3-5
Table 3-2 References Related to Corrosion Control 3-13
Table 3-3 Hydrogeologic Investigative Techniques 3-30
Table 3-4 Principal Sources of Geotechnical Data 3-31
Table 3-5 Darcy's Velocity and Time to Ground Water for
Various Degrees of Saturation 3-86
Table 3-6 Methods of Measurement of Model Parameters or Soil
Properties Relevant to Modeling and Validation 3-87
Table 3-7 General Flow Equations Used to Determine
Contaminant in the Unsaturated Zone 3-88
Table 3-8 Example of an Equipment List 3-103
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LIST OF FIGURES
Page
Figure 1-1 Flow Diagram for Secondary Containment
for Existing and New Tank Systems . 1-9
Figure 2-1 Format and Contents of a Risk-Based
Variance Application 2-3
Figure 2-2 Format for Contents of a Technology-Based
Variance Application 2-5
Figure 2-3 Timetable for Demonstration of Risk-Based
Variance From Secondary Containment 2-11
Figure 2-4 Timetable for Demonstration of Technology-Based
Variance From Secondary Containment 2-15
Figure 2-5 Checklist for Location Criteria Portion of
Preliminary Screening Determination 2-19
Figure 2-6 Graphical Representations of Unsaturated
Zone with Sample Calculations 2-25
Figure 2-7 Preliminary Screening Checklist for Catastrophic
Release and Transport Through the Unsaturated
Zone 2-27
Figure 2-8 Preliminary Screening Checklist for Overland Flow of
Aboveground Tank Systems 2-33
Figure 2-9 Existing Tank Criteria Checklist for
Preliminary Screening Analysis 2-35
Figure 3-1 Format and Contents for Description of
Tank System Des 1 gn 3-9
Figure 3-2 Format and Contents of Description of
Corrosion Protection 3-15
Figure 3-3 Description of Existing Tank Systems 3-17
Figure 3-4 Format and Contents for Descr.ption of Overfill
and Spill Protection Features 3-21
Figure 3-5 Format and Contents for Source Characteristics .. 3-25
vii
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LIST OF FIGURES (Continued)
Figure 3-6
Figure 3-7
Figure 3-8
Figure 3-9
Figure 3-10
Figure 3-11
Figure 3-12
Figure 3-13
Figure 3-14
Figure 3-15
Figure 3-16
Figure 3-17
Figure 3-18
Figure 3-19
Checklist of Data Requirements for Waste
Constltuents
Format for Presenting Climatic Data
Format for Presenting Hydrogeologic Data
Format and Contents for Determining Zone
of Engineering Control
Leak Detection Systems Evaluation Checklist
Perimeter Leak Detection Systems Evaluation
Checklist ...........
Format and Presentation of Data Pertaining
to Unsaturated Zone Monltoring
Depth Penetration and Horizontal Migration
Checklist for Overland Flow Time Calculation ...
Time Travel Format
Range of Hydraulic Conductivities and
PermeabiTitles
Unsaturated Zone Properties Checklist
Format for Release Response Plan
Format and Contents of Demonstration of
Sufficiency of Detection and Response Times
3-27
3-33
3-37
3-44
3-53
3-61
3-71
3-75
3-79 "
3-81
3-89
3-97
3-107
3-111
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No. 9483.00-2
EXECUTIVE SUMMARY
This document was developed to provide hazardous waste tank system
owners and operators information for submitting technology-based and
risk-based variances from the EPA requirement for secondary containment
with release monitoring for these tank systems. It was written in two
volumes; Volume 1 covers technology-based variances, and Volume 2 covers
risk-based variances. This summary covers Volume 1.
On July 14, 1986, EPA promulgated revised standards for hazardous
waste storage and treatment tank systems. These regulations require that
all new hazardous waste tank systems be provided secondary containment
with release monitoring. This requirement will also be phased in for
existing tank systems.
EPA recognized that the goal of protecting human health and the
environment might be achieved in ways other than secondary containment.
For example, new tank system design, operating practices, or release
detection technologies could substitute for traditional secondary
containment approaches. Innovative risk management methods that would
provide low probability of risk to the environment could also be used. A
combination of any of the above approaches might be demonstrated to be
protective of human health and the environment. Therefore, tank system
owners or operators may apply for a variance from the secondary
containment requirements of the hazardous waste tank system standards.
Both risk-based and technology-based variances can be obtained.
Technology-based variances can be granted if the tank system
owner/operator can show that by using new technology and/or alternative
operating procedures together with location characteristics, a release
will be contained, detected, and removed before it leaves the area under
control of the owner/operator. Ultimately, the applicant must
demonstrate that the release is prevented from reaching ground water or
surface water at least as effectively as if a secondary containment
technique were employed. New and existing tank systems may qualify for
this type of variance. The demonstration to be conducted and submitted
to EPA In order to support a request for this variance is discussed in
detail in this volume.
A risk-based variance may be granted if the tank system owner/
operator can show that if a release occurs there will be no substantial
hazard (present or future) to the environment and numan health. Details
of the demonstration needed for risk-based variance are covered in
V/lume 2 of this report.
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Technology-Based Variance Application Process
The tank system owner/operator provides the EPA Regional
Administrator (or cognizant state authority) a written notice of his/her
intent to conduct a demonstration of all requirements in §§ 264.193(g)(l)
or 265.193(g)(l) needed to apply for this variance. Owners/operators of
existing tank systems must send the Regional Administrator written notice
of intent at least 24 months before secondary containment is required.
Those owner/operators of new tank systems have 30 days prior to entering
into a contract to send the Regional Administrator written notice of
intent. This notice must have the following information: facility
location, nature and quantity of waste, system age, description of the
steps required to conduct the demonstration, and a timetable for
completing each of these steps. The actual application must be submitted
within 180 days after the written notice has been provided. Once the
application is received, the Regional Administrator will notify the
public and allow 30 days to comment upon it. For interim status tank
systems, the variance must be approved or denied by the Regional
Administrator within 90 days of his/her receipt of the demonstration.
Preliminary Screening Procedure
Guidelines are provided for the potential applicant to determine
whether he/she should apply for a variance. The assumption that a
release incident will be equivalent to a catastrophic release of waste
material is used to determine whether granting of the variance is
likely. The extent of a catastrophic release is affected by poor tank
system conditions and vulnerable hydrogeologies. These will create a .
potential for denial of the variance. Sensitive hydrogeologies are
evaluated with respect to tank system location (proximity to ground water
or surface water), waste release movement through the unsaturated zone,
and waste release movement above ground. Tank system integrity is
evaluated via an examination for leaks, cracks, corrosion (or erosion)
and potential for collapsing, rupturing, or failing.
Data Needed to Apply
The actual variance application should include the following items:
general company information, executive summary, description of the
alternative design/operating procedure justifying the variance,
characterization of the tank/operating system, source characterization,
site hydrogeology, determination of zone of engineering control, leak
detection effectiveness demonstration, determination of waste travel
time, effectiveness of spill/leak response plan, and sufficiency of
detection and remedial action. This information must be as complete as
possible to prevent any unnecessary delay in the approval or disapproval
process.
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A brief description of each data need is> provided below:
• Overall description of system - this section describes the
alternative system design or operating procedures that the tank
system owner/operator believes will justify the variance;
• Tank system and operating system description - this section should
provide information on the tank system's demonstrated ability to
prevent releases. The Regional Administrator will evaluate this
ability based on the actual tank system design, installation
procedures, corrosion protection measures, operational
history/problems encountered with existing tank systems, and the
tank system's overfill and spill protection features;
• Source characterization - the physical and chemical properties of
the stored waste must be provided to determine its potential for
migration (in the event of a release) or contribution to tank
system corrosion or incompatibility;
• Site hydrogeologic conditions - this information is necessary in
order to determine the time of travel of the waste (in the event
of a release) through the unsaturated zone of the soil. Such
information should include, but not be limited to, site geology,
climatic and meteorological data, and any subsurface investigative
methods/results used;
• Zone of engineering control - this zone is the area under control
of the owner/operator in which releases can be detected,
contained, and ultimately removed prior to such releases reaching
the ground water or surface water. The Information provided will
describe how this zone is defined, and consists of the site plan,
water table maps, cross-sections (of the tank system location,
highest seasonal water table, property boundaries, nearest surface
water, locations of all surface and subsurface structures and
utilities), accesses/obstructions to any remedial action, any
cleanup equipment limitations, migration pathways (travel times),
soil volume, legal agreements, and safety margins.
• Release detection - this section will demonstrate how effectively
the owner/operator's system can detect a release. This entails a
thorough description of the effectiveness, reliability, lower
detection limit and response time of the release detection system;
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• Determination of waste travel time - this section contains the
calculations supporting projection of waste travel time during a
release. These times must be provided for overland flow
(horizontal movement) and/or unsaturated zone flow (vertical
movement) depending on whether the tank system is aboveground or
underground;
• Response contingency plan - this section must contain details of
the applicant's response to any inadvertent waste release;
• Demonstration of adequacy for detection and remedial action - this
section builds upon the previous data elements and uses them to
demonstrate to the Regional Administrator whether remedial actions
are sufficient to contain the waste releases within the zone of
engineering control. In particular, the applicant must
demonstrate that the time for detection, response, and completion
of remedial action is less than the time for the release to
migrate beyond the zone of engineering control.
Submittal and Review
After completing the preparation of the application, owner/operators
then submit it to the Regional Administrator for review. (In a State
that has received authorization from EPA to Implement the RCRA program,
demonstrations should be made to the appropriate State official.) The
following review process applies for both the technology-based and
risk-based application.
Upon review of the application, the EPA may take one of the following
actions:
• Approval of Variance Request
If the demonstration satisfies the Regional Administrator that
migration is contained at least as effectively as it would be by a
secondary containment system, a variance may be granted under 40
CFR 264(265).193(g) and (h).
• Request for More Information
The Regional Administrator may deem the application incomplete if
he or she feels that additional data are necessary to complete or
more fully substantiate the premises of the demonstration. In
such an instance, the Regional Administrator may request specific
additional information. The decision for approval or disapproval
may be suspended until such time as the application is deemed
complete.
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1. INTRODUCTION
I.I Purpose and Scope of Technical Resource Document
1.1.1 Background
The hazardous waste storage and treatment tank system standards were
developed and promulgated by EPA to respond to the Hazardous and Solid
Waste Amendments of 1984 while modifying certain existing hazardous waste
tank system regulations that had proved unworkable and/or ineffective.
These standards were published in the Federal Register (51 FR 25422-486,
July 14, 1986).
The rule essentially requires secondary containment with interstitial
monitoring for all new hazardous waste tank systems. For existing tank
systems, the requirement for secondary containment with Interstitial
monitoring will be phased in. Tank systems storing or treating listed
dioxin-containing wastes must meet these requirements within two years of
the effective date of this regulation. Other existing tank systems that
are determined to be non-leaking on the basis of tank system integrity
assessments or other means must meet these requirements by the time the
tank system is 15 years old. Periodic tank system integrity assessments
are required for all tank systems not fitted with secondary containment.
The rule also contains procedures for use in the event that a leak is
discovered.
1.1.2 Purpose of This Document
The purpose of this technical resource document is to provide
technical assistance and information for owners/operators of hazardous
waste tank systems applying for either a technology-based variance or a
risk-based variance from the secondary containment requirements of the
hazardous waste tank systems regulations. The document Identifies the
information requirements of the variance applications and prescribes a
format for presenting this Information. The document does not set
standards or acceptable criteria for such variances. Further, the
document does not prescribe specific techniques to obtain required
Information or to demonstrate the effectiveness of an alternative
method. It is the responsibility of the applicant to devise and
demonstrate the validity of techniques used, to gather required
Information, and to demonstrate the effectiveness of the proposed method.
1.1.3 Who May Apply for Variances
This document provides information to aid the potential applicant in
deciding whether to apply for a variance from the secondary containment
provision in the hazardous waste storage and treatment tank system
standards.
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In some instances, applicants may not need to seek a variance from
the secondary containment requirement because their design may actually
satisfy the definition of secondary containment. To help applicants
identify such situations, Chapter 1.1.6 below includes a discussion of
the distinction between (a) an equivalent secondary containment device
and (b) an alternative design and operating practice that prevents
releases from reaching ground water or surface water at least as
effectively as a secondary containment device.
The Agency recommends that the applicant become familiar with the
intent and scope of the secondary containment and variance provisions
before deciding whether to invest the resources necessary to prepare a
comprehensive petition for a variance.
1.1.4 The Secondary Containment Requirement
Before publishing the hazardous waste tank system standards, the EPA
conducted an analysis of the problems associated with these tank
systems. The analysis concluded that many of these systems are now
leaking or can be expected to release hazardous waste or hazardous
constituents in the future. Such releases may pose a significant risk to
the communities exposed to the released substances. The principal causes
of tank system failure were identified as (1) external corrosion,
(2) installation problems, (3) structural failure, (4) overfills due to
operator error, and (5) ancillary equipment failure.
EPA considered the technical options available for addressing
releases from tank systems. A variety of studies on tank system failure
and the associated risk analyses supported EPA's conclusion that the only
demonstrated method for ensuring against releases to the ground water and
surface water is secondary containment with interstitial monitoring. The
principal advantage of secondary containment with interstitial monitoring
over other release detection and prevention methods considered is its
ability to both detect and contain a release before contaminant migration
into the environment occurs.
Secondary containment systems therefore act as a defense against
releases reaching the environment. The Agency did not dismiss other
alternative technologies to secondary containment such as tank system
testing and corrosion protection; in fact, the Agency maintains that
their use, especially in combination with secondary containment, can
enhance th
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1.1.5 Rationale for Allowing Variances from the Secondary Containment
Requirements
The hazardous waste tank system standards provide for two types of
variances. The first can be obtained if the owner/operator can show that
alternative design and operating practices, together with location
characteristics, will prevent the migration of released materials to
ground water or surface water at least as effectively as secondary
containment with interstitial monitoring. This variance is referred to
throughout this document as the technology-based variance.
The second type of variance, referred to as the risk-based variance,
can be obtained if it can be demonstrated that there would be no
substantial present or potential hazard to human health or the
environment associated with a release that migrates to the ground water
or surface water.
Both variances are available for permitted, interim status, and
90-day accumulation tank systems; however, the risk-based variance is not
available for new underground hazardous waste tank systems.
The Agency concluded that secondary containment is not necessarily an
end in itself but that other methods may achieve the regulation's goal
when site-specific situations are taken into account. By allowing a
technology-based variance from the secondary containment requirements,
the Agency is encouraging the refinement and further development of
existing technologies as well as the development of new technologies.
The Agency concluded that it was not reasonable to pass judgment on the
viability of innovative technologies that have not yet been developed.
The technology-based variance thus becomes a vehicle for assessing new
approaches to the problems related to hazardous waste tank system
management.
The Agency recognizes that there may be certain limited situations in
which secondary containment devices are not needed and for which a
variance is therefore appropriate. One example may be the storage of
non-flowing hazardous waste materials, such as dry residues, ash, and
spent catalysts. Since there are a variety of properties associated with
these materials (e.g., solubility in water, size of particles), and site
specific factors that could affect the potential release of hazardous
constituents into the environment, the Agency concluded that it was
inappropriate to allow a class exemption for non-flowing hazardous
wastes. Thus, the regulation provides a means by which an owner/operator
can obtain a variance from all or part of the secondary containment
requirements of the regulation by demonstrating that the design of his
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system meets the established goal of preventing the migration of any
hazardous waste or hazardous constituent into the ground water or surface
water during the life of the facility.
Because the risk-based variance is based on the potential effects on
human health or the environment, a petition for a risk-based variance
need not include information on leak detection and prevention
technologies. Rather, the petition can be based solely on the risks
associated with a potential release into the environment. The
distinction between these two variance procedures is important for a
potential applicant to understand before making a decision on whether
(and which type of) a variance is appropriate for his or her situation.
The Agency discourages the submission of technology-based variance
applications in those situations where secondary containment is obviously
provided. For example, for tank systems located inside buildings, the
building floor (if impervious and if appropriate berms are constructed
and drains are not a pathway for releases), could function as the
secondary containment system. The Agency also discourages the submission
of unpersuasive applications without a sound technical and scientific
rationale that supports the variance request, and may deny a variance
petition if the application is incomplete.
1.1.6 Equivalency Versus Effective Containment
It is important to understand the distinction between an equivalent
secondary containment device and alternative design/operating practices
that protect the ground water and surface water at least as effectively
as secondary containment. Sections 264.193
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criterion that states that the secondary containment system must be
"designed, installed and operated to prevent any migration of wastes or
accumulated liquid out of the system to the soil, groundwater, or surface
water at any time during the use of the tank system." [40 CFR
264(265).193
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as accessibility and obstructions, equipment limitations,
migration pathways and travel times, soil volume, and legal
agreements.
• Demonstration of the effectiveness of leak detection devices that
will be used (Chapter 3.6). This is based on a description of the
detection method; identification of the variables that may affect
system operation; calibration, testing, and maintenance
procedures; the lower limit of leak detection; and response time.
• Determination of waste travel time (Chapter 3.7). This is based
on the results of computation of waste travel time in the overland
scenario (for aboveground tank systems) and unsaturated zone
scenario (for both aboveground and underground tank systems).
• Demonstration of the effectiveness of the spill/leak response
plan, including time required to respond to a release
(Chapter 3.8). The description of the plan for responding to and
containing spills and leaks must include discussions of company
responsibilities, alarm mechanisms, response actions, safety,
disposal, training, and financial responsibility; and
• Demonstration of the sufficiency of the overall detection and
remedial action plan (Chapter 3.9). The final analysis must
demonstrate that the time to detect and contain a leak is
sufficient to prevent migration of releases to ground water or
surface water. The computation is based upon data presented in
Chapter 3.5 through 3.8.
1.1.8 Information Sources
Appendix A lists sources of environmental and hydrogeologic
information, including EPA offices and Regions, the U.S. Geological
Survey and U.S. Department of Agriculture, and various other Federal and
State agencies.
1.2 Overview of Variances
The standards that apply to owners and operators of hazardous waste
tank systems are contained in Title 40 of the Code of Federal
Regulations. Parts 26' and 2'5, Subpart J. Sections 264.193 and 265.193,
"Containment and Detection of Releases," require that tank systems be
provided with secondary containment with release detection to prevent the
release of hazardous waste or hazardous constituents to the environment.
The owner or operator of a tank system may obtain a variance from this
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requirement, however, by demonstrating to the EPA Regional
Administrator* either that (1) alternative design and operating
practices, together with location characteristics, will prevent the
migration of the hazardous waste or hazardous constituents into ground or
surface water at least as effectively as secondary containment during the
active life of the tank system, or that (2) in the event of a release
that does migrate to ground or surface water, no present or potential
hazard will be posed to human health or the environment (40 CFR
264(265).193
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aspects, prevent the migration of any hazardous waste or hazardous
constituent into the ground water or surface water during the life of the
facility. In addition, a description of controls and operating practices
to prevent spills and overflows must be supplied. Owners and operators
of tank systems in which ignitable, reactive, or incompatible wastes are
to be stored or treated must describe how operating procedures, tank
systems, and facility design will achieve compliance with the
requirements for these types of waste.
Meanwhile, all existing tank systems that do not have secondary
containment must be assessed to determine that the tank system is not
leaking or unfit for use. The operator must obtain and keep on file a
written assessment reviewed and certified by an independent, qualified
registered professional engineer by January 12, 1988. In some instances,
tank systems may be storing materials that are not defined as hazardous.
If these materials are subsequently listed by EPA as hazardous in its
regulations (i.e., in 40 CFR 261.30, 31, 32, and 33), specific procedures
apply to the tank systems storing these materials. Integrity assessments
for tank systems storing materials that become hazardous wastes subsequent
to July 14, 1986, must be conducted within 12 months after the date that
the waste becomes a hazardous waste.
Tank systems subject to Interim Status standards are eligible for
variances from secondary containment subject to the requirements of
40 CFR Part 265. These requirements are the same as for 40 CFR Part 264
tank systems except for the following provisions (Section 265.193(h)):
• The Regional Administrator will inform the public, through a
newspaper notice, of the availability of the demonstration for a
variance. The notice will be placed in a daily or weekly major
local newspaper and will provide at least 30 days for the public
to review and comment on the demonstration for a variance.
• The Regional Administrator also may hold a public hearing, in
response to a request or at his or her own discretion, to clarify
Issues concerning the demonstration for a variance. Public notice
of the
hearing will be given at the same time as notice of the opportunity
for the public to review and comment on the demonstration. These
two notices may be combined.
• The Regional Administrator has 90 days to approve or deny the
request for a variance after receipt of the demonstration from the
owner or operator. The Regional Administrator will notify the
owner or operator and each person who submitted written comments
or requested notice of the variance decision in writing.
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Secondary
containment
required prior
to being placed
In service
lank system
new?
264(265).183
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• If the demonstration for a variance is incomplete or does not
Include sufficient information, the 90-day time period will begin
when the Regional Administrator receives a complete demonstration,
Including all Information necessary to make a final determination.
• If the public comment period is extended, the 90-day time period
will be similarly extended.
Granting of the variance by EPA entitles the owner/operator to construct
and/or operate the proposed tank system without secondary containment. In
the event of a leak or spill of the tank contents, specific procedures must
be followed. These procedures may differ depending on whether the release
(1) 1s contained within an area known as the "zone of engineering control"
or (2) migrates beyond this zone. In either case, §264.193 and (4)
and §265.193(g)(3) and (4) require the owner/operator to cease operation of
the tank system, remove sufficient waste from the tank system to allow
inspection and repair, and remove wastes from the environment to prevent
migration to the ground water or surface water.
If the release is within the "zone of engineering control," the owner
must make the necessary repairs before the tank system can be returned to
service. If the variance was based upon leak detection and response.
contaminated soils must be removed or decontaminated to allow the tank
system to resume operation with the same efficiency of leak detection it
had prior to the release. The tank system can be returned to operation
provided the above conditions are met. If, however, the soil cannot be
decontaminated or removed, the system must be closed and put under post-
closure care. In such cases, if the tank system 1s repaired, replaced,
or reinstalled, the owner must either provide secondary containment or
reapply for a variance in order to operate that tank system.
If the release migrates beyond the zone of engineering control, post-
closure care must be Initiated If (1) the soils cannot be decontaminated
or removed or (2) contamination of ground water or surface water occurs.
The above conditions of secondary containment, or reapplication for a
variance, however, would apply regardless of whether the soils were
decontaminated or removed. This is because such migration itself
signifies a failure of the technology for which the technology- based
variance was originally granted.
A tank system that has started to leak or that is unfit fo- use must
immediately be removed from service. Wastes must be removed within 24
hours or, if this is not possible, as quickly as possible. The tank
system must be inspected to determine the cause of the release, and a
visual inspection should be performed to determine the extent of
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No. 9483.00-2
environmental contamination. Measures should then be taken to prevent
further migration of contaminants to soils or surface water and to remove
and properly dispose of any visible contamination that has already taken
place (40 CFR 264(265).196.
All leaks larger than one pound that are not immediately contained
and cleaned up must be reported to the Regional Administrator within 24
hours, and a report must be submitted to the Regional Administrator
within 30 days. This report must contain the following information
(40 CFR 264(265). 196(d)(3»:
• Likely route of migration.
• Characteristics of the surrounding soil (soil composition,
geology, hydrogeology, climate).
• Sampling or monitoring data (if not available within 30 days, the
data should be submitted as soon as possible).
• Distance to downgradient drinking water, surface water, and
population areas.
• Description of response actions taken or planned.
For major repairs (e.g., installation of an internal liner; repair of
a ruptured primary or secondary containment vessel; etc.), the tank
system cannot be returned to service unless an independent, qualified,
registered professional engineer has certified that the repaired system
is capable of handling hazardous wastes without release for the intended
life of the system. The certification must be submitted to the Regional
Administrator within seven days of the system being returned to service
(40 CFR 264(265).196(f)).
1.2.2
Risk-Based Variances
The general procedures for obtaining a risk-based variance are
similar to the above, except that the demonstration must consist of a
detailed assessment of the substantial present or potential hazards to
human health or the environment from a release to the environment.
Volume 2 provides a detailed discussion of these procedures.
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2. PROCEDURES FOR SUBMITTING VARIANCE APPLICATIONS
2.1 General
This chapter provides information on how to prepare and submit
variance applications and also includes a method to determine whether an
owner/operator should apply for a variance from the secondary containment
requirements of the hazardous waste tank system regulations. This method
is termed a "preliminary screening procedure"; separate procedures apply
for the risk-based and technology-based variances.
The format and contents of each type of variance application are
discussed. Applicants should provide the required information in the
prescribed format. The body of the application should provide the
results of analyses, tests, calculations, and other procedures.
Applicants are advised, however, to include as appendices any raw data,
worksheets, test reports, and other supporting data that have been used
to prepare the application as well as reference material (or portions
thereof). For example, simply stating the lower limit of detection of a
monitoring instrument and basing it on the vendor's guarantee would not
be sufficient. Rather, the applicant must take the responsibility to
include any of the manufacturer's test data that substantiate claims
related to the performance of the device.
2.2 Format and Contents of Applications
2.2.1 Risk-Based Variance
Figure 2-1 provides a description of the format and contents of the
risk-based variance application. Specific details on the information and
analyses required are provided in Volume 2 of this document.
2.2.2 Technology-Based Variance
Figure 2-2 provides a description of the format and contents of the
technology-based variance application. Each application will contain
introductory material consisting of general information (name of company,
address, and other pertinent data) and an executive summary of the
.technical information to follow. The executive summary must highlight
the key points that lead to the conclusion that the proposed alternative
design or operating practice will prevent migration of released material
to the ground water or surface water at least as .ffectively as secondary
containment.
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OSWER Pol icy Directive
No. 9483.00-2
After the introductory material, the application consists of nine
parts. Each of these parts is described in detail in Chapter 3.0 of this
document; Figure 2-2 provides references to the corresponding sections in
Chapter 3.0.
The EPA Regional Administrator (or appropriate State official in
States authorized to Implement RCRA) will retain ultimate authority for
determining which portions of the application must be completed. Failure
to comply with the Regional or State Office's request for information may
result in the application's being deemed incomplete and in the consequent
denial of the variance request.
2.3 Information to Be Submitted
Applicants should submit the variance application to the EPA Regional
Administrator. A list of EPA Regional Offices and the States covered by
each Region is provided in Appendix A. If any of the Information
contained in an application is considered to be proprietary by the
applicant, he or she may indicate which pages are to be treated as
confidential by stamping or otherwise indicating their status and
following the Confidential Business Information (CBI) procedures
contained in EPA's "TSCA Confidential Business Information Security
Manual" (available from NTIS, publication number PB85-137305).
Applicants must follow the procedures described in 40 CFR
264(265).193(h) for submitting variance applications, as detailed below.
2.3.1 Notice of Intent to Submit
The first step In submitting a variance application is for the
owner/operator to provide the Regional Administrator a written notice of
the intent to conduct and submit a demonstration for a risk- or
technology-based variance. For existing tank systems, the notice of
Intent must be submitted at least 24 months before the date on which
secondary containment must otherwise be provided (i.e., if the variance
Is denied). Applicants must therefore establish the date by which
secondary containment would otherwise be required based on the phase-in
schedule described 1n 40 CFR 264(265) .193(a). Chapter 1.2 of this
document provides applicants with more information related to this
provision. (The full text of the regulation is included in Appendix B.)
For new tank systems, applicants must notify the Regional Administrator
of the intent to apply for a variance at least 30 days prior to entering
into a contract for installation of the tank system.
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OSWER Dir. 9483.00-2
INTRODUCTORY MATERIAL
General Information:
Provide name of company, address, location of tank system(s) for which variance application is being made, status of
tank system (existing or new), key contact at company, and telephone number.
Executive Summary:
Provide summary of the following aspects of the variance application:
• Site and source characteristics
• Health effects evaluation
• Environmental impact evaluation
• Demonstration of no substantial present or potential hazard to
human health and the environment
PART I. SOURCE CHARACTERIZATION (See Vol H, Chapter 2)
Characterize potential source of contamination, including physical and chemical characteristics of the constituents,
and selecting indicator chemicals (when appropriate), worst-case release volumes.
PART II. HYDROGEOLOGIC CHARACTERIZATION (See Vol H, Chapter 3)
Characterize hydrogeology surrounding the tank system and facility, including proximity of the tank system to
surface water and ground water, direction and velocity of ground-water flow, depth and composition of the unsaturated
zone, and patterns of regional rainfall.
PART HI. SURROUNDING WATER USE AND WATER QUALITY
CHARACTERISTICS (See Vol H, Chapter 4)
Determine surrounding water use and water quality characteristics, including proximity and withdrawal rates of ground
water uses, the current and future uses of ground water, surface waters, and surrounding land, and the existing quality
of ground water and surface water.
PART IV. EXPOSURE POINT CONCENTRATIONS (See Vol H, Chapter 5)
Estimate potential exposure point concentrations.
PART V. HEALTH EFFECTS EVALUATION (See Vol H, Chapter 6)
Analysis of potential health effects consisting of: (1) comparison of exposure point concentrations to established
acceptable concentration levels; (2) estimation of potential human intake of constituents: (3) determination of
chemical toxiciry values: (4) estimation of potential carinogenic and non-carcinogenic risks based on chemical toxity
values and intake rates, and (5) determination of other potential health hazards of hazardous waste releases.
PART VL ENVIRONMENTAL IMPACT EVALUATION (See Vol H, Chapter 7)
Evaluation of potential environmental impacts. Includes comparing exposure point concentrations to established
quality standards for ground water, surface water, and land; and estimating potential for damage to wildlife, crops,
vegetation, and physical structures.
PART VII. PREPARATION OF "NO-SUBSTANTIAL HAZARD" DEMONSTRATION
(See Vol U, Chapter 8)
Summarize the results of the risk-based variance analysis.
Figure 2-1 Format and Contents of a Risk-Based
Variance Application
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OSWER Dir. 9483.00-2
INTRODUCTORY MATERIAL
General Information:
Provide name of company, address, location of tank system(s) for which variance application is being made, status of
tank system (existing or new), key contact at company, and telephone number.
Executive Summary:
Provide summary of the following aspects of the variance application:
Why variance is being sought
Overall description of tank system
Source characterization
Site hydrogeologic conditions
Zone of engineering control
Demonstration of leak detection system effectiveness
Waste travel time
Demonstration of effectiveness of spill/leak response plan
Demonstration that detection and remedial action is sufficient
PART I. OVERALL DESCRIPTION OF ALTERNATIVE DESIGN/OPERATING
PRACTICE (See Chapter 3.1)
General description of alternative design/operating practice, with emphasis on the specific aspect(s) of design or
operation that would provide containment of releases at least as effectively as secondary containment (e.g., tank
design, leak detection and containment plan).
PART H. CHARACTERIZATION OF TANK SYSTEM(S) AND/OR OPERATING
PROCEDURE (See Chapter 3.2)
A more detailed description of aspects of tank system that would prevent migration of hazardous waste or hazardous
constituents to ground water or surface water at least as effectively as secondary containment. Must include details
on tank system design, corrosion protection, information on existing tanks (age, location), overfill and spill
protection features, and operation and maintenance.*
PART HL SOURCE CHARACTERIZATION (See Chapter 3.3)
Information on physical and chemical characteristics of stored materials and potential worst-case release volumes.4
PART IV. CHARACTERIZATION OF SITE HYDROGEOLOGIC CONDITIONS
(See Chapter 3.4)
General information on climatic and meteorological data and site geology."'
PART V. DETERMINATION OF ZONE OF ENGINEERING CONTROL
(See Chapter 3.5)
Description of dimensions of the zone of engineering confil for the tank system of concern. Based on depth to
ground water, distance to surface water, and distance to neighboring property.
PART VI. DEMONSTRATE LEAK DETECTION DEVICE EFFECTIVENESS
(See Chapter 3.6)
Description of leak detection device, information showing effectiveness, including compatibility with tank material,
device placement and spacing, data on system reliability, and leak detection time.
Figure 2-2 Format and Contents of a Technology-Based
Variance Document
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OSWER Dir. 9483.00-2
PART VIL DETERMINATION OF WASTE TRAVEL TIME (See Chapter 3.7)
Results of computation of waste travel time in the overland scenario (for aboveground portion of tank systems) and
unsaturated zone scenario (for both above- and underground tanks).
PART VIH. DEMONSTRATE EFFECTIVENESS OF SPILL/LEAK RESPONSE PLAN
(See Chapter 3.8)
Description of plan for responding to and containing spills and leaks. Must include discussions of company
responsibilities, alarm mechanisms, response actions, safety, disposal, training, and financial responsibility.
PART IX. DEMONSTRATE SUFFICIENCY OF DETECTION AND REMEDIAL
ACTION (See Chapter 3.9)
Final analysis which must demonstrate that the time to detect and contain a leak is sufficient to prevent migration of
releases beyond the zone of engineering control.
The variance application must be signed by the owner/operator.
'Note: For variances submitted in conjunction with Part B permit applications, this information would be submitted as
part of that application. Provide appropriate cross-references to the Part B application as necessary.
Figure 2-2 Format and Contents of a Technology-Based
Variance Document (Continued)
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OSWER Policy Directive
No. 9483.00-2
The written notice for variances for new and existing hazardous waste
tank systems must contain the following information:
1. Facility location;
2. Nature and quantity of the waste;
3. System or component (i.e., tank, ancillary equipment) age (if
system age is not known, provide facility age);
4. Description of the steps necessary to conduct the demonstration
for the technology-based or risk-based variance; and
5. Timetable for completing each of the steps of the demonstration.
Figures 2-3 and 2-4 are provided for addressing these items. These
figures can serve as "worksheets" that can be submitted as part of the
notice of intent to apply.
2.3.2 When to Submit Applications
Applicants must submit applications for variances within 180 days
after providing the written notice of intent to apply. Therefore, the
timetables in Figures 2-3 and 2-4 extend across 180 days.
2.3.3 Approval/Disapproval Procedures for Interim Status and Less
Than 90-Day Accumulation Tank Systems
Procedures for approval and disapproval of variance applications are
provided for interim status and less than 90-day accumulation tank
systems in 40 CFR 265.193
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OSWER Policy Directive
No. 9483.00-2
The Regional Administrator will notify the owner or operator and each
person who submitted written comments or requested notice of the variance
decision (either granting or denying) in writing. If the Regional
Administrator decides the demonstration, and supporting information,
Indicates there is a potential for migration of any hazardous waste or
hazardous constituent into the groundwater or surfacewater, then the
request for a technology-based variance will be denied (the
owner/operator must ensure any release is detected and subsequently
contained). The regulations at 40 CFR 265 do not provide a process for
administrative appeal of the Regional Administrator's decision.
2.3.4 Approval/Disapproval Procedures for Tank Systems Receiving a
RCRA Permit per 40 CFR Part 270.
Procedures for approval or disapproval of variance applications are
provided for tank systems being permitted per 40 CFR Part 270 can be
found at 40 CFR 264.193(h). Here the Regional Administrator would be
granting or denying the request for variance from the secondary
containment requirements at the time the permit decision is made. If the
application for a technology-based variance is denied and a RCRA permit
is issued, the owner/operator may petition the Administrator to review
any condition of the permit decision (see 40 CFR 124.19).
2.4 Risk-Based Preliminary Screening Procedure
Appendix A of Volume II provides the potential applicant with a
preliminary screening procedure for risk-based variances. The screening
procedure for risk-based variances has three purposes: (1) to determine
whether the tank system falls into a category that is not allowed a
variance; (2) to inform the applicant of the types of Issues and data
involved; and (3) to identify whether an exposure pathway exists.
Upon completion of this preliminary screening procedure, the
applicant should have identified the following:
• Facilities or tank systems that are exempt from the secondary
containment requirement;
• Situations in which a variance from secondary containment is not
allowed;
• The types of necessary data gathering efforts that are needed for
a variance application; and
2-10
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ro
INSTRUCTIONS;
1. Fill In Starting Date and Finishing Date.
2. Place a xX at expected time of completion for each activity.
3. Next tOv", place expected date in parenthesis (e.g., (10/25/88))
Facility ID:.
System/Component ID(s):.
System/Component
Age (If unknown, then
facility age):.
Date:
Analyst:,
Starting Date
Finishing Date
WEEK
ACTIVITY
/ 234 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
I. Source Characterization
a. Physical and Chemical
Characteristics of Constituents
b. Indicator Chemical Selection
c. Potential Worst Case Release volumes
II. Hydrogeological Charcteristics
a. Proximity of Tank System to
Surface and Ground Water
b. Ground Water
c. Patterns of Regional Rainfall
d. Facilities and Surrounding Land
e. Soil Characteristics
III. Surrounding Water Use and Water
Quality Characteristics
a. Proximity of Tank System to
Surface and Ground Water
b. Ground Water
c. Patterns of Regional Rainfall
d. Facilities and Surrounding Land
e. Soil Characteristics
Figure 2-3 Timetable for Demonstration of Risk-Based Variance from
Secondary Containment
-------
Starting Date
Finishing Date
WEEK
IV.
V.
VI.
ACTIVITY /
e. Existing Quality of Ground Water 1
f. Existing Quality of Surface Water f
Exposure Point Concentration
a. identify Exposure Pathways 1
b. Estimate Exposure Point Concentrations I
Surrounding Water Use and Water
Quality Characteristics
a. Compare Exposure Point |
Concentrations to Established l__
Quality Standards for Health Impacts
b. Estimate Chemical Intakes (Doses) |
c. Determine Chemical Toxicities 1
d. Characterize Risk 1
e. Other Potential Health Hazards [
Environmental Impact Evaluation
a. CumpaiC EAJJOSUIC Puinl 1
Concentrations to Established 1
23 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
\
\
1
1
1
1
1
1
1
1
Quality Standards for Environmental
Impacts
b. Estimate Potential for Damage to
Wildlife, Crops, Vegetation, and
Physical Structures
VII. Preparation of the "No-Substantial
Hazard" Demonstration
a. Summarize Result of the
Risk-Based Assessment
b. Prepare Supporting
Documentation
Figure 2-3 Timetable Tor Demonstration of Risk-Based Variance from
Secondary Containment (Continued)
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OSWBR Dir. 9483.00-2
I
I—•
en
INSTRUCTIONS;
1. Fill In Starting Dale and Finishing Date.
2. Place a >/ at expected time of completion for each activity.
3. Next to*/, place expected date in parenthesis (e.g., (10/25/88))
Facility ID:.
System/Component ID(s): •
System/Component
Age (If unknown, then
facility age):-
Date:.
Analyst:.
Starting Date
Finishing Date
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
1 1
ACTIVITY
Proposed Alternate Design and
Operation
Characterization of Tank System(s)
and/or Operating Procedures
Source Characteri/ation
Characterization of Site Hydro-
geologic Conditions
Determination of Zone of
Engineering Control
Demonstrate Leak Detection
Effectiveness
Determination of Waste Travel Time
Demonstrate Effectiveness of Spill/Leak
Response Plan
Demonstrate Sufficiency of
Detection and Remedial Action
WEEK | |
/ 2 3 4 567 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
1
1
1
1
1
1
1
1
1
Figure 2-4 Timetable for Demonstration of Technology-Based Variance from
Secondary Containment
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OSWER Pol icy Directive
No. 9483.00-2
• Whether the variance application will be based on a demonstration
of (1) no present or potential exposure pathways or (2) no hazard
to human health and the environment due to the chemical
concentrations at exposure points.
This Information will assist the applicant 1n deciding whether or not to
apply for a risk-based variance and in identifying the level of detail
and effort that will likely be needed to complete the variance
application.
2.5 Technology-Based Variance Preliminary Screening Procedure
This screening process was developed to facilitate the variance
process and to eliminate unnecessary studies and paperwork. It is
included as an aid to applicants in deciding whether to apply for a
technology-based variance and in identifying the level of detail and
effort that will be needed to complete the variance application. Because
this analysis is for the benefit of the applicant in making the decision
of whether to apply, it is not a necessary part of the variance
application. Applicants may choose to include the preliminary screening
analysis as an appendix to their formal application for a
technology-based variance.
The purpose of this section is to provide the applicant with
guidelines to quickly determine when a technology-based variance is not
likely to be granted. This section was developed to flag potentially
vulnerable site conditions or tank structural integrity. In the event of
a catastrophic release, surface/ground waters could be contaminated very
quickly; since applicants must demonstrate that released wastes would not
reach ground water or surface water, their application would not be
approved If such contamination were possible. The preliminary screening
analysis uses catastrophic release Incidents as the primary criterion in
determining whether a variance application is warranted. If a
catastrophic release cannot be contained or remediated before reaching
ground water or surface water, a variance would not be granted. The
Agency recognizes that non-catastrophic releases may also pose the
potential of being undetected and contaminating ground water or surface
water. The assumption of a catastrophic release, however, is more
suitable for a preliminary screening analysis, since, at a minimum,
applicants must be able to demonstrate containment in such instances.
Another condition to consider is the integrity of the tank system; this
element is also addressed in this section. Although the hydrogeology may
be adequate, a lack of structural integrity of the tank system can result
in denial of an application.
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OSWER Pol icy Directive
No. 9483.00-2
The criteria for determining sensitive hydrogeologic settings,
transport through the unsaturated zone, transport by overland flow, and
those requirements for determining existing tank, system integrity are
described below.
2.5.1 Location Criteria
A major consideration in the decision of whether a technology-based
variance should be granted is proximity to ground water or surface
water. In addition, tank systems subject to the RCRA Part B permit
requirements must be located in compliance with the location requirements
of 40 CFR 264.18. These standards are discussed in Chapter 2.5.
Since the water table surface can rise or fall depending on seasonal
precipitation, it will be necessary for the applicant to determine what
the seasonal high for the site is anticipated to be. This will usually
be during the spring or winter.
Hydrogeologic and geologic data such as depth to the seasonal high
water table and proximity to geologically sensitive areas (fault zones,
mud-slide zone) will be used to determine whether the tank system
location is situated in a vulnerable surface/ground-water area.
Ground water, surface water, and other geologic information can be
obtained from County Soil Conservation (SCS) reports or specific United
States Geological Survey (USGS) reports. Particularly useful are the
USGS topographic maps.
The checklist in Figure 2-5 provides a procedure for the applicant to
follow when assembling this information. The determination of whether
proximity to ground water or surface water is unacceptable depends on the
time of travel of the release through the unsaturated zone. The location
information discussed here will be used in the manner described below to
establish whether the time of travel is sufficient to allow remediation
of the release.
2.5.2 Catastrophic Release and Transport Through the Unsaturated Zone
To provide a conservative estimate of the probability of a release
reaching the ground water or surface water, it will be necessary to
calculate the consequences of a catastrophic release.
The possibility of ~t such a release reaching ground water or surface
water is a function of:
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OSWER Dir. 9483.00-2
I. GEOGRAPHICAL LOCATION OF TANK SYSTEM SITE
II. IS TANK SYSTEM ABOVE GROUND OR PARTIALLY ABOVE GROUND?
III. IS TANK SYSTEM BELOW GROUND?
IV. DO ANY FAULTS, FAULT ZONES OR FRACTURE ZONES EXIST WITHIN 200
FEET OF THE TANK SYSTEM SITE?
V. DESCRIBE ANY OTHER GEOLOGICALLY SENSITVE ASPECTS OF THE
TANK SYSTEM ENVIRONMENT (SUCH AS PROXIMITY TO ROCK- OR
MUD-SLIDES)
VI. VERTICAL DISTANCE FROM TANK BOTTOM TO SEASONAL HIGH
WATER TABLE
VII. VERTICAL DISTANCE FROM TANK BOTTOM TO PERCHED WATER TABLE
VIII. LIST ALL SURFACE WATER SITES, TYPE, AND LEAST HORIZONTAL
DISTANCE FROM TANK SYSTEM SITE.
Name
a.
b.
c.
d.
e.
Type
Least Horizontal Distance (feet)
Figure 2-5
Checklist for Location Criteria Portion of Preliminary
Screening Determination
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OSWER Policy Directive
No. 9483.00-2
• Distance to ground water/surface water;
• Waste characteristics (see Chapter 3.3);
• Saturated hydraulic conductivity* of soil/sediment/rock; and
• Overland flow characteristics (-see Chapter 3.7.1).
How quickly a waste or constituent reaches any water is measured in
terms of the velocity of the waste or constituent and distance to the
water. The waste or constituent can move horizontally over the earth's
surface, and it can move vertically through the soil/sediment/rock.
Normally the distance to ground water is measured vertically, whereas
distances to surface waters are measured horizontally. The horizontal
movement of fluid over the earth's surface is known as overland flow; the
vertical movement of fluid beneath the surface of the earth to the
ground-water table is known as unsaturated zone transport. Thus, if the
tank system is underground, the applicant should estimate unsaturated
zone transport velocity. If any portion of the tank system is
aboveground, the applicant should estimate both unsaturated zone
transport and velocity of overland flow.
The flow rate of any fluid in the environment is dependent upon the
types of soils, sediments, and rocks, and their thickness in the
subsurface. For the purpose of this application, once the nature of the
subsurface is identified, unsaturated zone velocity can be estimated as
the value of the saturated hydraulic conductivity. Several assumptions
that must be met for this approach to be valid are:
• The waste travels with the velocity of water.
• Velocity is strictly vertical.
• Heterogeneities (such as faults, fractures) are absent.
(These conditions are addressed in Chapter 3.7.)
If there is only a short distance to the ground water and the soils
are highly permeable, it is unlikely that a technology based variance
would be granted. The means by which an initial (preliminary screening)
determination of waste migration time can be made is discussed in detail
below.
Saturated hydraulic conductivity is a measure of velocity of
material through permeable media.
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OSWER Pol icy Directive
No. 9483.00-2
Table 2-1 lists a range of saturated hydraulic conductivities for
several soil and rock types. These values can be used to estimate waste
velocity within the unsaturated zone. For example, a ground-water table
of moderate depth (such as 50 feet) overlain exclusively by gravel is
unlikely to be protected from a catastrophic release. Assuming, for
purposes of making a preliminary screening analysis, that cleanup efforts
take one week, this waste could travel anywhere from 1,984 to 1,984,250
feet. With a 50-foot water table, the time of travel (TOT) from the
bottom of the tank to the ground water could be 4.25 hours (50-foot
depth/1,984 feet/week velocity), or less than a minute (50-foot
depth/1,984,250 feet/week velocity). This example illustrates a
shortcoming of this estimation method which is due to the variation of
saturated hydraulic conductivities of soils, sediments, and rocks. A
better method to determine saturated hydraulic conductivity of any medium
is to do field measurements; however, for purposes of preliminary
screening, the values in Table 2-2 are used. The applicant is advised to
carefully consider the results of this preliminary screening analysis.
In contrast to the example given above, if a fairly shallow water
table (10 feet deep) is overlain by 10 feet of silt, the waste will
travel from less than an inch up to 19.8 feet in a week. Time of travel
to the ground-water table would then range from 3.5 days to 13.7 years
(10 foot depth/19.8-.002 feet/week velocity), which may, depending upon
where in the range it falls, provide enough time for cleanup.
Travel times in most situations will fall between these two
extremes. It is suggested that, to estimate waste velocity to the
ground-water table, the applicant evaluate a soil/sediment/rock column
that lists (for each medium type) its description, saturated hydraulic
conductivity, and thickness. Figure 2-6 provides such an example. The
water table surface and calculations of waste velocity and TOT should
also be shown. The checklist in Figure 2-7 provides a recommended format
for the applicant to follow when assembling this information.
2.5.3 Catastrophic Release and Surface Transport - Overland
Overland flow only needs to be calculated for inground and
aboveground tank systems. It is assumed that a catastrophic release from
an underground tank system will not contribute to overland flow. An
analytical determination of overland flow is more difficult than that of
unsaturated zone velocity, and a somewhat qualitative approach must be
taken. The possibility of a catastrophic release reaching ground water
or surface water from overland flow is d function of:
• Distance to the ground water/surface water;
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OSWER Dir. 9483.00-2
2355s
Table 2-1 Range of Saturated Hydraulic Conductivity
Medium
cm/sec
Feet/day
Feet/week
Soils
Silt, loess
Silty sand
Clean sand
Gravel
ID-7 _ io-3
10-5 _ iQ-1
10-4 . 1QO
- 102
2.8X10-4 - 2.8x10°
2.8x10-2 - 2.SSxlO2
2.8X10"1 - 2.835X103
2.83X102 - 2.83X105
2xl(T3 - 1.98x10]
2xKH - 1.98X103
2.0x10° - 1.98X104
1.98X103 - 1.98X106
Rocks*
Unfractured metamorphic
and igneous
Shale
Sandstone
Limestone A dolomite
Permeable basalt
10-8 -
5xlO-12 - 10-7
10-8 - SxlO-4
SxlO"8 - SxlO"4
10-5 - 10°
2.8xlO-5 - 2.8X101
1.4X10-8 - 2.8x10-*
2.8xlO-5 - 1.4x10°
l.AxKT4 - 1.4x10°
2.8x10-2 - 2.83xl03
2X10-4 - 1.98X102
IxlO"7 - 2xlO-3
2X10-4 - 1.0x10°
IxlO-3 - 1.0x10°
2X10"1 - 1.98xl04
* Rocks that are faulted, fractured,-or have high porosities are likely to have very high
saturated hydraulic conductivities, even higher than those listed.
2-23
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2355s
OSWER Dir. 9483.OC
Table 2-2 Typical Values of Saturated
Hydraulic Conductivity (C Values)
Description of area
Runoff
coefficients
Business
Downtown areas
neighborhood areas
Residential
Single-family areas
Multiunlts. detached
Multiunlts, attached
Residential (suburban)
Apartment dwelling areas
Industrial
Light areas
Heavy areas
Parks, cemeteries
PIaygrounds
Railroad yard areas
Unimproved areas
Streets
Asphaltic
Concrete
Brick
Drives and walks
Roofs
Lawns: Sandy soil
Flat 21
Average 2-7X
Str p n
Lawns: Heavy soil
Flat 25
Average 2-7*
Steep 71
0.70 - 0.95
0.50 - 0.70
0.30 - 0.50
0.40 - 0.60
0.60 - 0.75
0.25 - 0.40
0.50 - 0.70
0.50 - 0.80
0.60 - 0.90
0.10 - 0.25
0.20 - 0.35
0.20 - 0.40
0.10 - 0.30
0.70 - 0.95
o.ao - 0.95
0.70 - 0.85
0.75 - 0.35
0.75 - 0.9S
0.05 - 0.10
0.10 - 0.1S
0.15 - 0.20
0.13 - 0.17
0.18 - 0.22
0.25 - 0.35
Source: Kibler 1982.
2-24
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OSWER Dir. 9483.00-2
01
UJ
C/5
en
UJ
z
*
o
r
i-
H
UJ o
2 U
- In
*~ = § *"*
cc < ^ ?^
< > O u.
(O X O O
UJ
o
UJ Q
cr o
u x
u. H-
UJ UJ
t£ S
UJ
>
<
cc
u.
O
UJ
LAND „
SURFACE
UJ
<
oc
o
UJ
UJ
u.
o
o
120 FEET
DEPTH OF
SEASONALLY
HIGH WATER TABLE
3000
f/DAY
USGS
REPORT
110,
1983
.03
DAY
O
Z
<
(A
O UJ
N UJ
10
f/DAY
AS
ABOVE
2.0
DAY
CALCULATIONS:
DISTANCE/VELOCITY = TIME
GRAVEL = 100 ft/3000 ft-day = .03 day
SAND = 20 ft/1 Oft-day = 2.0 day
TOT to SEASONALLY HIGH WATER TABLE s 2.03 days
Figure 2-6 Graphical Representation of Unsaturated Zone
With Sample Calculations
2-25
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OSWER Dir. 9483.00-2
I. SOIL INFORMATION
Identify all soil/sediment/rock types, their thickness, depth from the earth's surface, saturated hydraulic conductivities
and method used to determine saturated hydraulic conductivity (e.g., Table 2-2, specific USGS report, field
measurments).
Media
a.
b.
c.
d.
e.
Thickness
Depth
Sat Hyd. Cond.
Method (Reference)
II. VELOCITY OF WASTE
Estimated velocity of the waste.
III. TIME OF TRAVEL (TOT)
Estimate waste TOT from the bottom of the tank to the seasonally high groundwater table.*
IV. CLEAN UP TIME
Estimate time of clean-up from a catastrophic release.
V. TIME SUFFICIENCY FOR REMEDIATION
Determine whether TOT is less than estimated clean-up time.
*For heterogeneous subsurfaces this will require summing the travel times through each
layer.
Figure 2-7 Preliminary Screening Checklist for Catastrophic Release and
Transport Through the Unsaturated Zone
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OSWER Policy Directive
No. 9483.00-2
• Topography;
• Natural and artificial conduits;
• Form and viscosity of the waste (1n terms of Its velocity);
• Surface son condition and saturated hydraulic conductivities; and
• Rainfall amount and rate.
Time of overland flow can be crudely estimated using the Federal
Aviation Agency (FAA) empirical formula (Kibler 1982).
. 1.8 (1.1 - C)DmlX2 (2-1)
where
t0 » overland flow time (minutes)
C - runoff coefficient
Dm - travel distance (feet)
S » overland slope (percent).
The runoff coefficients for many types of ground cover are given in
Table 2-2. The travel distance is the distance to the nearest surface
water site. An overland slope can be estimated from the appropriate USGS
topographic map. The FAA formula assumes the waste is mobile and that
there is sufficient rainfall to keep it mobile. This preliminary
screening estimation method does not consider other soil characteristics
such as soil infiltration rates which can slow down the waste
considerably. Chapter 3.7.1 presents the more rigorous approach to
estimating overland flow velocities and volumes to be used in the actual
variance application.
These conditions are conducive to rapid flow or early entrance of
waste into surface waters in the event of a release:
• Short distance to surface water;
• Steep land slope towards surface water;
• High annual precipitation rates and/or frequent rain storms with
large volume rainfall;
2-29
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OSWER Pol icy Directive
No. 9483.00-2
• Natural gullies or artificial conduits (drainage ditches, paved
impermeable roads) that direct wastes towards surface waters;
• Absence of divergence structures that impound or shunt wastes from
surface waters;
• Low waste viscosity (in terms of its ability to flow — liquid
wastes will move more readily than solid wastes);
• Absence of obstructions to flow (e.g., trees, vegetation);
• Impenetrable soil/sediment/rock surface (saturated hydraulic
conductivities); and
• Storm sewers that connect the site to nearby surface water.
Two examples of overland flow extremes are illustrated below:
1. An aboveground tank system holding waste the consistency of water
rests on crystalline metamorphic rock (see saturated hydraulic
conductivity, Table 2-1) which slopes 15 degrees towards a creek,
5 feet downslope from the tank site. There are no impoundments,
no obstructions to flow, and no shunting devices. The tank system
suddenly ruptures during an intense, high volume rainstorm,
spilling Jts contents. -None of the waste seeps into the rock •
because the rock is impermeable and acts as a conduit toward the
creek. Within seconds, the waste reaches the creek.
2. An aboveground tank system holds a solid hazardous waste. The
tank system rests on very flat caliche soils (hardpan soils) in
the desert. Annual rainfall is very low, and intense rain storms
drop only a fraction of an inch of precipitation which is quickly
taken up by dry soils. The nearest surface water, a creek that
dries up during the summer, is a half-mile away. Despite the
absence of obstructions or other divergence structures, it is
unlikely that the waste will enter the creek by overland flow (as
for all tank systems, unsaturated zone flow would also need to be
estimated in this scenario) before cleanup efforts have been
completed.
Useful information con-erning these conditions can be obtained from
the DSC?, SCS, and local meteorlogical stations It is suggested that
the applicant conduct the preliminary screening analysis with a schematic
representation of the tank system site in relation to surface waters.
Included in this drawing should be location of natural and/or artificial
conduits, divergence structures, and vegetation cover and type. In
2-30
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OSWER Policy Directive
Mo. 9483.00-2
addition, the applicant should specify the site's annual rainfall, the
largest expected rate of precipitation during a storm, and
soil/sediment/rock hydraulic conductivities. The applicant should
specify the form (solid, liquid, gas) of the waste and its viscosity.
The checklist in Figure 2-8 provides a recommended format for the
applicant to follow when conducting this preliminary screening analysis.
2.5.4 Existing Tank System Integrity
The applicant must meet the integrity assessment requirements for
existing tank systems as outlined 40 CFR 264(265).191. The tank system
must be judged fit for use; i.e., it must show no evidence of leaks,
cracks, or corrosion and no tendency to collapse, rupture, or fall. In
addition, the tank system must have sufficient structural strength,
adequate design, and compatibility with the waste that it holds. Only
through approved tests confirmed by a written assessment by an
independent qualified professional engineer will such assertions be
deemed valid. All data from tests and records of the tank system's past
performance will also be used in assessing tank system integrity. The
checklist in Figure 2-9 provides a recommended format for the applicant
to follow when assembling this information.
2.6 Relationship of Other Rules. Policies, and Guidelines
This section describes other Agency rules, policies, and guidelines
that are incorporated in the development of the risk-based and
technology-based variance procedures.
2.6.1 Risk-Based Variance
The Agency developed the risk-based variance for hazardous waste tank
systems 1n the context of other Agency rules, policies, and guidelines.
These Include the Ground-Water Protection Strategy (GWPS), the Location
Standards (hydrogeologlc vulnerability criteria), the Alternative
Concentration Limit (ACL) Demonstration Guidance, the Superfund Exposure
Assessment Manual, the Superfund Public Health Evaluation Manual, and the
EPA Risk Assessment Guidelines among others. The relationship of the
risk-based variance to these other documents and regulatory strategies is
described in more detail in Volume 2 of this document.
2.6.2 Technology-Based Variance
Essentially two regulations also influence the procedure for
technology-based variances: the Oil Pollution Prevention Plan
regulation, and the location standards for treatment, storage, and
disposal facilities set forth in 40 CFR 264.18. These are described in
further detail below.
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OSWER Pol icy Directive
No. 9483.00-2
(1) 011 pollution prevention plan regulation. The overlap of
EPA's 011 Pollution Prevention Plan and the Standards for Hazardous Waste
Storage and Treatment Tank Systems occurs in certain situations where the
hazardous waste stored in the tank systems falls under the jurisdiction
of both regulations. The Oil Pollution Prevention Plan established
procedures, methods, equipment, and other requirements to prevent the
discharge of oil of any kind to "navigable waters" from
non-transportation related facilities. This methodology for spill
control is called a Spill Prevention Control and Countermeasure (SPCC)
Plan. The Standards for Hazardous Waste Storage and Treatment Tank
Systems (40 CFR Parts 264 and 265) regulate those wastes stored in
hazardous waste storage and treatment tank systems as defined under the
Resource Conservation and Recovery Act. The wastes that pertain to both
regulations are those that contain oil contaminated with RCRA wastes
(e.g., waste oil contaminated with solvents) contained in a tank system.
The regulations differ in some respects. The SPCC Plan is designed to
protect "navigable waters." which include water bodies used for shipping
and their tributaries, interstate surface waters, intrastate lakes,
rivers, and streams used for recreational or commercial fishing. The
Standards for Hazardous Waste Storage and Treatment Tank Systems (40 CFR
264 and 265) are designed to protect these waters and also ground waters
that are not addressed by the SPCC Plan. When applying for a
technology-based variance, the engineering practices recommended for a
SPCC Plan can be used for designing a spill control system but the
applicant must provide proof that the protection of surface and ground
waters meets the more stringent requirements of the Standards for
Hazardous Waste Storage and Treatment Tank Systems.
(2) Location criteria. A technology based variance cannot be
granted for new tank systems if they do not meet the location criteria
set forth in 40 CFR 264.18. The criteria are divided into two parts,
seismic and floodplaln areas. The seismic location criteria state that
new tank systems may not be located within 61 meters (200 feet) of a
fault that has displayed relative movement ^n the last 10,000 years
(within the Holocene period). The floodplaln location considerations
state that tank systems located 1n a 100-year old floodplain must be
maintained to prevent washout of any hazardous waste by a 100-year
flood. This requirement can be waived providing the applicant can
demonstrate that procedures can be enacted to remove the hazardous waste
safely before flood waters can reach the facility (40 CFR 264.18
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OSWER Dir. 9483.00-2
I. TYPE OF WASTE
Identify waste viscosity, and form (solid, liquid, or gas)
II. SURFACE WATER INFORMATION
What surface water sites does the land (from the tank site) slope towards? For each surface water site, give name,
type, least horizontal distance, and slope.
Name
a.
b.
c.
d.
e.
Type
Least Horizontal Distance
Surface Slope
III. DIVERSION STRUCTURES
A. Identify diversion structures and distances of these structures from the tank system site.
\
B. Identify natural or artificial conduits which can direct wastes towards any surface water site.
C. Identify any obstructions (trees, vegetation, buildings) to surface flow.
»
IV. PRECIPITATION
Obtain annual precipitation and greatest .expected rainfall rate that could occur from a rain storm at the tank system
site.
V. SURFACE/SOIL
Identify and evaluate general condition of the surface (soil/sediment/rock type and saturated hydraulic
conductivities).
VI. ESTIMATE TIME TO IMPACT SURFACE WATER.
VII. REMEDIATION TIME
Estimate time of clean-up from a catastrophic release.
Figure 2-8
Preliminary Screening Checklist for Overland
Flow of Aboveground Tank Systems
2-33
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OSWER Dir. 9483.00-2
I. TANK CONDITION
A. Does tank have any cracks, leaks or evidence of corrosion or erosion?
B. Does tank meet the requirements of 40 GFR 264(265). 191?
II. ANCILLARY SYSTEM CONDITION
A. Does the ancillary equipment (piping, flanges, pumps, etc.) have any cracks, leaks or evidence of corrosion?
B. Does the ancillary system meet the requirements of 40 CFR 264 (265). 191?
III. COMPATIBILITY
Evaluate compatibility of the tank and its contents
IV. TANK SYSTEM TESTS
A. List all tank system tests performed, test dates, and results. Include the certification/credentials of the personnel
that perfonned the test
B. Age (year and month) of tank and any documentation that supports the claim.
Figure 2-9 Existing Tank System Criteria Checklist for Preliminary
Screening Analysis
2-35
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OSWER Policy Directive
No. 9483.00-2
3. TECHNOLOGY-BASED VARIANCE INFORMATION AND DATA NEEDS
This chapter provides descriptions of the type of information
required for the variance application, how the data will be used, and how
the information is to be presented. The overall content and format of
the variance application is shown in Figure 2-2. The content of the
individual parts of the application are described in each of the sections
in this chapter.
In order for a variance to be granted, the application for a variance
must provide a convincing and supportable demonstration that the alternative
design or operating practice, together with location characteristics, will
prevent the migration of releases into the ground water or surface water at
least as effectively as secondary containment. Upon review of the variance
application, the EPA may take one of the following actions:
• Approval of Variance Request
If the demonstration satisfies the Regional Administrator that
migration of hazardous waste or hazardous constituents to ground
water or surface water is prevented as effectively as it would be
through the use of a secondary containment system, a variance may
be granted under 40 CFR 264(265). 193
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policy Directive
No. 9483.00-2
• Appeal of the Technology-Based Variance Decision
The regulations at 40 CFR 265 (for interim status and 90-day
accumulation tank systems) do not provide a process for
administrative appel of Regional Administrator's decisions
regarding variance requests for secondary containment. The
regulations do, however, provide administrative appeal of the
Regional Administrator's decisions regarding variance requests for
secondary containment made during the permit process pursuit to
40 CFR Part 124.
In general, the technology-based variance application must
demonstrate that a release of tank system contents can be detected soon
enough to allow it to be controlled and removed before it reaches the
ground water or surface water. Release detection is a very significant
component of the proposal. Thus, variance applicants will be required to
demonstrate that potential releases can be prevented from reaching ground
water or surface water by a combination of detection methods and remedial
measures. The operator must have sufficient time to effect the
excavation or decontamination of the tank system discharge before it
reaches the ground water or surface water. A key part of the
demonstration will be a showing that the time to detect a release plus
the time for remedial measures is less than the time it takes for the
release to migrate to ground water or surface water. This demonstration
is Part IX of the variance application and is described fully in Chapter
3.9.
3.1 Overall Description of System and Hhy Variance Is Being Sought
The overall description of the system for which a technology-based
variance is being sought makes up the first part of the variance
application. In this part, applicants should provide a brief description
of the alternative design or operating practice. The discussion should
emphasize the specific aspects of the design or operation that would
provide containment of releases at least as effectively as secondary
containment. The purpose of this section is to establish the basis for
the variance, thus identifying the type of analysis that must be provided
in the remainder of the application.
For example, an applicant may submit an application for a tank system
design with unsatu^ated zone monitoring. The specific aspects that must
be identified .,1 the description woul J be the design of the tank system,
the type and design of the unsatura^ed zone monitoring equipment, and the
response and remediation plan. The basis for seeking a variance in such
3-2
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OSWER Pol icy Directive
No. 9483.00-2
an Instance would be the demonstration that releases could be detected,
contained, and remediated prior to migration to the ground water and
surface water.
3.2 Characterization of Tank System and/or Operating Procedures
An essential component in any application for a technology-based
variance is the system's demonstrated ability to prevent releases to
ground water and surface water. The Regional Administrator will assess
the information provided both in this section and in Chapter 3.6 (on the
design of the leak detection system) to determine whether the overall
tank system's design warrants a variance from the secondary containment
requirements. The design and operational procedures for a tank system
owner/operator in applying for a variance must meet all of the other tank
system management standards of Subpart J, except those related to the
design and performance of a secondary containment system.
The information requested in this section falls into the following
categories:
• Tank System Design/Installation
• Corrosion Protection
• Information on Existing Tank. System
• Overfill and Spill Protection
3.2.1 Tank System Design
(1) Information required
(a) Schematic Drawing of Tank System. The drawing should be to
scale and should depict the entire tank system, including any associated
piping, pumps, valves, vents, or monitoring wells. The following
components should be included, if applicable:
Excavation walls, floor and cap
Overfill prevention devices
Observation wells
Backfi11
Dielectric bushings on pipe connections
Waste fill and draw-off lines
Manways and other openings
Sumps
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OSWER Policy Directive
No. 9483.00-2
Level alarms
Piping/pumps/valves/vents
Flow meters/gauging lines
Leak detection devices
Floating suction arms
All other pertinent Information
(b) Tank System Design Information. The information to be
provided relates to the general design and installation of the tank
system. The codes and standards referenced in Table 3-1 at the end of
this section can provide additional detail on most of the descriptive
elements requested. The following is a list of information on the design
features of the tank system that must be addressed In the application for
a variance. The applicant may submit additional information on the
design of the system if it will aid In the overall assessment of the
system's ability to prevent releases.
• Material of construction of all components;
• Methods of joining components, e.g., whether pipe joints are
welded or not;
• Evidence of compatibility of wastes stored with the material(s) of
construction;
• Tank capacity (ft^ or m^);
• Tank dimensions (ft or m);
• Thickness of the primary container (1n or cm);
• Location of tank system with respect to ground level (% buried);
• Depth of tank below surface (ft or m);
• Type of tank (atmospheric, low or high pressure);
• Bottom pressure - as it relates to the density of the material(s)
stored and the pressure rating of the system (liquid height
multiplied by liquid density);
• Backfill material and dimensions (if below grade);
• Number and types of valves (ball-check, etc.);
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OSWER Dir. 9483.00-2
2360s
Table 3-1 Nationally Accepted Tank Design Standards
Document Number
AA-*SD-1a
AA-ED-33*
AA-SAS-303
ACI-344R-70b
Title
Aluminum Standards and Data, 1970-71
Engineering Data for Aluminum Structures
Specifications for Aluminum Structures
Design and Construction of Circular
Date
1984
1981
1982
1970
ACI-350R-77b
AISI-TS-291-
582-10M-NBc
ANSI B96.1d
API 12Be
API 12D6
API 12F*
API 620*
API 650s
ASfC BPV-VIII-lf
ASTH D 32999
Prestressed Concrete Structures
Concrete Sanitary Engineering Structures 1983
Useful Information on the Design of 1985
Plate Structures
Steel Tanks for Liquid Storage 1982
Standard for Welded Aluminum-Alloy 1981
Storage Tanks
Specification for Bolted Tanks for Storage 1977
of Production Liquids, 12th Ed.
Specification of Field Welded Tanks 1982
for Storage of Production Liquids, 8th Ed.
Specification of Shop Welded Tanks for 1982
Storage of Production Liquids, 7th Ed.
Recommended Rules for Design and 1982
Construction of Large, Welded,
Low-Pressure Storage Tanks
Welded Steel Tanks for Oil Storage 1984
ASME Boiler and Pressure Vessel Code 1980
Standard Specification for Filament-Wound 1981
Glass-Fiber Reinforced Thertnoset Resin
Chemical Resistant Tanks
3-5
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2360s
OSWER Dir. 9483.00-
Table 3-1 (Continued)
Document Number
Title
Date
ASTH D 40219
AWUA-0100h
NFPA 301
UL 58J
UL 80J
UL 142J
UL 1316J
Standard Specification for Glass-Fiber 1981
Reinforced Polyester Underground
Petroleum Storage Tanks
Standard for Welded Steel Tanks for 1984
Water Storage
F1 amiable and Combustible Liquids Code 1984
Standard for Steel Underground Tanks 1976
for Flammable and Combustible Liquids
Standard for Steel Inside Tanks for Oi1 1980
Burner Fuel
Standard for Steel Above Ground Tanks for 1981
Flanmable and Combustible Liquids
Standard for Glass-Fiber-Reinforced 1983
Plastic Underground Storage Tanks for
Petroleum Products
aThe Aluminum Association (AA)
bAmerican Concrete Institute (ACI)
cAn»rican Iron and Steel Institute (AISI)
dAmerican National Standards Institute, Inc. (ANSI)
eAmerican Petroleum Institute (API)
fAmerican Society for Mechanical Engineers (ASHE)
^American Society for Testing and Materials (ASTH)
^American Water Works Association (AUMA)
'National Fire Protection Association (NFPA)
^Underwriters Laboratories, Inc. (UL)
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OSWER Policy Directive
No. 9483.00-2
• Number and types of pumps (diaphragm, etc.);
• Anticipated or measured internal liquid, vapor pressure, and
hydrostatic pressure.
• Results of tank system integrity assessment required by
40 CFR 264(265).191.
(c) Design Installation Standards/Codes. This section provides
the applicant an opportunity to cite those standards or codes that are
used in the design or installation of the tank system. It is recognized
that standards may not apply to new or innovative designs. In lieu of
applied standards, the applicant is encouraged to submit evidence that
sound engineering practices have been used in the design of the system.
The applicant is also encouraged to indicate features of the tank
system design installation or proposed operation that go beyond the
standards promulgated in the July 14, 1986, Federal Register (51 FR
25471-25486). This information may provide additional support to the
applicant's petition.
(d) Effectiveness of Design. In this section, the applicant is
given the opportunity to provide evidence on the effectiveness of the
proposed tank system's design. The kinds of information that would be
the most useful would include data from bench or pilot studies that
simulate the design and operational conditions of the system. Data
supplied from manufacturers on the effectiveness of the design could also
be submitted. Any evidence provided should be convincing and complete.
For example, test results whether provided by the manufacturer or as a
result of studies performed by the applicant would, by themselves, be
Incomplete without the details of the test protocols used.
(2) How data are to be used. The information received on the design
of the tank system will first be evaluated to determine whether the
system Includes the use of innovative technologies that previously have
not been considered by the Agency. The Information on the use of
relevant standards will be considered in determining whether the system
was designed and Installed according to reliable engineering practices.
Evidence supplied on the effectiveness of the design will help in the
overall assessment of the system's long-term capability of preventing
releases.
(3) Presentation of data. Figure 3-1 provides a recommended format
for presenting the data. The objective is to demonstrate the
effectiveness of the proposed system in preventing releases.
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policy Directive
No. 9483.00-2
3.2.2 Corrosion Protection
(1) Information required. This section of the variance application
solicits Information on the design, operation, and maintenance
considerations that deal with corrosion protection. The applicant should
note that 40 CFR 264.192 and 265.192 of the July 14, 1986, regulations
require that a corrosion expert conduct an assessment of the corrosion
potential for new tank systems and recommend appropriate preventative
measures. Table 3-2 provides some further references on corrosion
control. The same information 1s requested In this application.
If the tank, system is at or below grade, information must be provided
that relates to the potential corrosive nature of the surrounding soils.
The following two standards can be used where applicable, as guidelines
in making these determinations: "Recommended Practice - Control of
External Corrosion on Underground or Submerged Metallic Piping Systems"
(NACE 1985) and "Cathodic Protection of Underground Petroleum Storage
Tanks and Piping Systems" (API 1986). The kinds of information required
regarding the potential for corrosion include soil moisture content, soil
pH, soil sulfides, soil resistivity, structure to soil potential,
influence of nearby underground metal structures, and existence of stray
electric current.
Additional information required relates to the corrosion protection
measures that exist or are planned for the tank system. These are:
external coating, corrosion-resistant materials, electrical isolation
devices, and cathodic protection systems.
The applicant will also be requested to supply information on the
potential for the stored wastes to cause internal corrosion of the
vessel, and, for existing tank systems, information on previously stored
wastes and their compatibility with the tank system's material(s) of
construction.
For the corrosion protective measures that are dependent on
operational and/or maintenance practices, additional Information must be
provided related to the planned inspection and maintenance schedule.
Finally, information on corrosion protection must also be provided
for aboveground tank systems, since these are not immune from corrosion
related problems.
3-8
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I. SCHEMATIC DRAWING
II. DESIGN OF LEAK DETECTION SYSTEM
A. Material of construction
l.Tank
2. Ancillary Equipment
B. Thickness of vessel (in/cm)
C. Tank capacity (f^/m3)
D. Tank dimensions (ft/m)
E. Evidence supporting compatibility of waste(s) stored with material(s) of construction.
F. Location of tank with respect to ground level (% below grade)
G. Extent and location of associated piping (give lateral and vertical depiction)
H. Type of tank (atmospheric, low or high pressure)
1. Type of dimensions of backfill material if partially or completely buried.
J. Number and types of valves
K. Number and types of pumps
L. Calculated or measured:
*
1. Internal liquid pressure
2. Internal vapor pressure
3. Hydrostatic pressure
M. Other relevant information related to how the design of the tank system will prevent the
release of hazardous wastes into the environment such as pressure shut off valves for the piping.
III. DESIGN/INSTALLATION STANDARDS OR CODES
This format should be followed for each standard or code used in the design or installation of
the tank system
A. Standard used
B. Name of standard
C. Components of standard used
D. Components of standard not used
E. Components of standard exceeded (Include description of how exceeded.)
F. Description of sound engineering practices used
in lieu of applicable standards.
IV. EFFECTIVENESS OF DESIGN
Figure 3-1 Format and Contents for Description of Tank
System Design
3-9
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OSWER Dir. 9483.00-2
A. Source of data (pilot study, manufacturers data)
B. Test protocol used.
C. Results
The preceeding format can be followed for multiple evaluations of the effectiveness of design
Figure 3-1 Format and Contents for Description of Tank
System Design (Continued)
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2360s
Table 3-2 References Related to Corrosion Control
Husock, B. "Pipe-to-Soil Potential Measurements and Cathodic Protection
of Underground Structures," Paper No. HC-8, Materials and Performance,
Vol. 10, Mo. 5, Nay, 1971.
Husock, B. "Use of Pipe-to-Soil Potential in Analyzing Underground
Corrosion Problems," Paper No. HC-7, Harco Corporation, Cathodic
Protection Division, Median, OH.
Husock, B. "Cathodic Protection - One Way to to Prevent Underground
Corrosion," Paper No. HC-4, Harco Corporation, Cathodic Protection
Division, Median, OH.
Husock, B. "Causes of Underground Corrosion," Paper No. NC-36, Harco
Corporation, Cathodic Protection Division, Median, OH.
National Association of Corrosion Engineers, Recommended Practice -
Control of External Corrosion on Underground or Submerged Metallic Piping
Systems, NACE Standard RP-01-69, National Association of Corrosion
Engineers, Houston, TX, January 1972.
Rizzo, F. E. "Detection of Active Corrosion," Paper No. HC-14, Harco
Corporation, Cathodic Protection Division, Median, OH.
Rothman, P. S. "Cathodic Protection'of Tank and Underground Structures,"
Harco Corporation, Cathodic Protection Division, Hatboro, PA, 1978.
The Hinchman Company, Suggested Ways to Meet Corrosion Protection Codes
for Underground Tanks and Piping, Job Number 1079-4542, The Hinchman
Company, Corrosion Engineers, Detroit, Michigan, April 8, 1981.
U.S. Department of Agriculture, "Control of Underground Corrosion,"
Design Note No. 12, Soil Conservation Service, U.S. Department of
Agriculture, Soil Conservation Service, February 1, 1971.
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No. 9483.00-2
(2) How data are to be used. The potential for either internal or
external corrosion of the tank system will be assessed from the data
supplied in context with both the location of the tank system in relation
to the soil and the contents of the waste stored. Second, the proposed
corrosion prevention measures will be evaluated for their potential to
adequately inhibit the corrosion related factors identified.
(3) Presentation of data. Figure 3-2 provides a format for
presenting the information discussed above. The objective is to
demonstrate the effectiveness of corrosion prevention techniques.
3.2.3 Information on Existing Tank Systems
(1) Information required. The information requested in this section
relates to the operational history of existing tank systems applying for
a technology-based variance. The data requested will deal primarily with
the problems encountered during the operational life of the system
including a description of any major repair conducted or parts replaced.
For release incidents, details are required on the amount and migration
of the material released and the associated remedial response. In
addition, the applicant will be asked to indicate the modifications in
the tank system design or operational procedures that resulted from each
incident.
<2) How data are to be used. The information provided here will be
evaluated in terms of the system's successful operation during its
operational history. ' The information should also illustrate the
responsiveness of the personnel involved when confronted with an
emergency such as a release of hazardous waste into the environment. The
repair and replacement records will also demonstrate the effectiveness of
the maintenance program.
<3) Presentation of data. Figure 3-3 provides a recommended format
for presenting the information discussed above.
3.2.4 Overfill and Spill Protection Features
CD Information required. The information requested in this section
applies to the measures designed to prevent and/or contain spills that
result during the transfer of waste into and out of the tank systems. A
description of the devices, operational procedures, and maintenance
schedules that are intended to prevent such incidents should be
pr sented. Devices that are designed to sense the level in the tank
system include: float-actuated devices, displacement devices,
hydrostatic sensors, capacitance sensors, ultrasonic devices, optical
devices, and thermal conductivity sensors. These level sensing
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OSWER Dir. 9483.00-2
I. FACTORS AFFECTING THE POTENTIAL FOR CORROSION
A. Corrosive Potential of Soil
1. Soil moisture content
2. SoilpH
3. Soil sulfides level
4. Structure to soil potential
5. Influence of nearby underground metal structures
6. Existence of stray electric current
7. Soil resistivity (ohm-cm)
B. Other Corrosive Related Factors
1. Percent of system on or below ground level
2. pH range of the tank contents
3. Description of precipitation protection for tank system
II. CORROSION PREVENTIVE MEASURES
A. Cathodic Protection
1. Schematic drawing of system illustrating all components
2. Information for impressed current method
Provide tank system soil volt potential as measured by copper-copper suifate half cell reference, and a
detailed maintenance and operational schedule.
3. Information for sacrificial anode method
Provide number, dimensions, and material of construction of anodes used, and a detailed maintenance and
operational schedule
B. Other Corrosion Protection Measures
For each of the measures selected, indicate why it was selected and provide description.
1. Soluble corrosion inhibitors
2. Paints, coatings, or linings
3. Electrical isolation
4. Corrosion allowance
5. Corrosion resistant materials of construction
C. Evidence of Adequacy of the Corrosion Protection Measures Employed
1. Provide findings of corrosion expert
Discussion of potential for corrosion, measures necessary to ensure integrity of tank system, and protective
measures recommended but not employed and reasons why they were not used.
2. Include evidence that supports the case of the corrosion protection measures employed (e.g., manufacturer's
data, information on tank life)
Figure 3-2 Format and Contents for Description of
Corrosion Protection
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OSWER Dir. 9483.00-2
I. GENERAL INFORMATION
A. Age of tank system
B. Percent of time used since installed
C. If a treatment tank, what is volume of waste treated annually
D. If a storage tank, the average time stored before waste is removed
E. Waste characterization
H. OPERATIONAL HISTORY
A. Discuss in detail any major repairs or replacement of pans that took place since the system
was installed.
B. Describe each release incident that exceeded one gallon of waste. Include, at a minimum, the
following information:
Date of release
Volume released
Causes(s)
Description of remedial response
Distance release traveled (lateral and vertical)
Extent of surface or ground water contamination
Modification in the design or operational practices that resulted from the incident
Copies of any spill reports submitted to local, State, or Federal agencies
Figure 3-3 Description of Existing Tank Systems
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OSWER Policy Directive
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Instruments most often work in combination with alarms and/or automatic
shut-off devices. Additionally, transfer lines can be equipped with
spring loaded shut-off valves that prevent overfilling.
(2) How data are to be used. The data provided here will be
evaluated in terms of the adequacy of the spill control measures to both
prevent and contain any releases that could occur during the transfer of
waste to or from the tank system. The use of proper equipment and
operating practices will be analyzed from the information provided.
(3) Presentation of data. Figure 3-4 provides a format and content
for presenting information on spill control equipment and procedures.
3.3 Source Characterization
This section discusses the physical and chemical properties of the
waste that affect its ability to flow and those that affect tank system
corrosion processes. Worst case scenarios of catastrophic releases,
corrosion leak rate, and release detection problems are also discussed.
3.3.1 Physical and Chemical Characteristics of Stored Materials
(1) Information required. The chemistry of the waste and that of
the tank system material can act together to accelerate the corrosion
process. Factors that should be taken into consideration include pH,
tank construction material, waste, total waste volume, tank volume,
compatibility, protective linings and other anticorrosion methods,
oxidizing agents, electrolytic activity, moisture levels, temperature,
bacterial action, and soil reactivity. Each of these factors will be
unique to a specific tank system, waste, and site. Most of these factors
are discussed in Chapter 3.6 because they also relate to leak initiation.
Hazardous wastes stored in tank systems will not always be composed
of a single chemical. Because different hazardous constituents are
likely to travel at different velocities 1n the unsaturated zone, the
determination of the velocity of a waste should take into account the
chemicals' viscosity, density, and retardation capability.
Because physical-chemical properties of waste components differ from
those of wa^er, and the flow equations that will be introduced later were
developed to model water velocity, modifications must be made to them to
better predict waste velocity, 'ihe physical and chemical factors of
waste components that affect waste velocity are density, viscosity, water
solubility, precipitation, redeposition, solution composition and
concentration, pH, and soil temperature. These modifications should
reflect the variations in these physical-chemical properties of the waste-
component versus the physical-chemical properties of water.
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KOI icy Directive
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(2) How data are to be used. The significance of a chemical varies
with its concentration in the tank. For each chemical, the concentration
of that chemical in the waste in terms of weight percent, volume percent,
or parts per million should be determined. The largest anticipated
concentration of each should be the one chosen for use in the flow
equations.
Before the constituent concentration is calculated, the percent
volume of water in the waste should be calculated. Then, percent volume
of the hazardous wastes, or hazardous constituents, should be calculated.
Following below is a brief discussion of the correction factors that
may apply in this calculation:
• Density
Density is the mass or quantity of a substance usually measured in
grams per cubic centimeter. Density is an indication of how close
atoms of a substance are packed together and how heavy the
material is. The heavier the material, the greater is its
gravitational downward pull through the unsaturated zone, which
results in faster TOTs (time of travel to the ground-water
table). As a component's density increases, its hydraulic
conductivity increases and its velocity increases. Density
differences between the hazardous waste and water are reflected in
the corrected TOT equation (see Chapter 3.7).
• Viscosity
Viscosity is the internal fluid resistance of a substance caused
by molecular attraction which makes the substance resist a
tendency to flow. Generally, the more viscous a waste, the
greater is its TOT to the ground-water table. A chemical's
viscosity must be either measured or obtained from the
literature. As a given chemical's viscosity increases, its
hydraulic conductivity decreases and its velocity decreases.
Differences between the hazardous waste's viscosity and water are
reflected in the corrected TOT equation (see Chapter 3.7).
• Retardation
Retardation is the process that decreases the velocity of the
soU>J-e by providing soil s;tes for chemicals to adhere to. Clays
and organic carbon are th« most common retardants.
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OSWER Dir. 9438.00-2
I. SPILL CONTROL EQUIPMENT
A. If the tank system employs level sensing equipment, indicate which of the following applies:
Float-actuated
Displacer valves
Hydrostatic-head sensor
Capacitance sensors
Thermal-conductivity sensors
Ultrasonic devices
Optical devices
Others
If a multiple level sensor is used, indicate the percentage of capacity that each is set for.
B. For each check valve or coupling used, provide the following applicable information:
1. Material of construction for piping
2. Distance of fill line offset from tank
3. Distance from tank bottom to termination of fill pipe
4. Method of attachment and support of fill pipe
5. Liquid-delivery/vapor-recovery system
6. Type of check valve or coupling connection including size and material of construction.
C. Indicate whether the overfill spill control system automatically shuts off the pump when a high level is indicated
(safety cutoff) or the flow is diverted elsewhere (bypass). In either case, describe the sequence that takes place
during a potential overfill incident, including the role of any backup systems.
D. Describe any other equipment and its role in spill control.
II. OPERATIONAL AND MAINTENANCE PROCEDURES
A. Describe the operational procedures followed during the transfer of wastes to or from the tanks with emphasis on
any control measures routinely taken. Also provide any related information on the personnel that perform this
function, for example, their safety record, training, and responsibilities.
B. Describe in detail the maintenance schedule and procedures related to the maintenance of the spill control equipment
Figure 3-4 Format and Contents for Description of Overfill
and Spill Protection Features
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OSWER Pol icy Directive
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Hydrophobia (lacking strong affinity for water) or cationic
(positively charged ions) chemical components, if migrating in a
dilute plume, are subject to retardation. In a concentrated
plume, it is not necessary to model retardation because chemical
components will not preferentially partition from liquid solvent
to the solid "solvent." Therefore, only aqueous liquids moving in
a dilute plume need to be modeled for retardation. (For
aboveground tank system releases where the percolation rate (q) is
less than the hydraulic conductivity (k), see Chapter 3.7.1.)
Retardation is a mass balance process dependant upon the
concentration gradient of the chemical component. For net
movement of the chemical from the plume to the medium surface to
occur, the chemical's concentration on the medium must be smaller
than that in the plume; otherwise, there will be no net movement
of the chemical. The amount of chemical component adsorbed onto
the media surface will be a function of the amount of organic
carbon in the medium (as organic carbon content increases,
adsorption increases) and the retardation factor, Rd, of that
particular chemical.
The retardation factor, Rd, is a function of the medium bulk
density (p) and unsaturated zone porosity (n), the partition
coefficient (Koc), and fractional organic material of the medium
(Foe). Bulk density and total porosity of each medium can be
measured, or representative values can be selected from the
literature. If Koc, organic carbon-water partition coefficient,
cannot be found in the literature for that particular component,
then it can be calculated using the octanol/water partition
coefficient (Kow) and a regression equation (Lyman 1982).
(3) Presentation of data. Figures 3-5 and 3-6 provide a recommended
format for presenting the data required above.
3.3.2 Potential Worst-Case Release Volumes
Wastes can be unintentionally released from tank systems in one of
two volume/time scenarios: catastrophic release or non-sudden release.
(1) Information required. The information necessary to estimate a
worst case scenario is the same as that required in Chapter 3.3.1(1).
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No. 9483.00-2
(2) How data are to be used
• Catastrophic Release
By definition, a catastrophic release occurs when the
entire contents of the tank are released instantaneously.
In certain instances (e.g., the filled tank volume is
large) surface/ground waters can be contaminated quickly.
Although such a release can be detected immediately by
properly functioning detectors, the ability to contain such
a release varies. If the filled tank volume is large, the
waste is of low-viscosity, and the tank is above ground,
containing the release within the zone of engineering
control (defined in Chapter 3.5) may be extremely
difficult. Factors such as the filled tank volume being
small and the waste being viscous would lead to a better
chance of containing the waste within the zone of
engineering control.
Because the volume of waste expelled by a catastrophic
release is high and the period of release is short, waste
velocity through the unsaturated zone or TOT (Chapter 3.7.2)
is calculated using the conservative assumption of saturated
flow of the waste.
• Corrosion Release
A corrosion release can be a release that starts with the
size of a pin hole and develops very slowly. The potential
danger of such a release occurs when a finite volume of
waste must pass by a detector before the detector is
activated. It is possible that the undetected leaking
waste could travel to surface/ground waters in such small
quantities over such long periods of time that
surface/ground waters could be contaminated. The detection
limit of unsaturated zone sensors varies (Chapter 3.6.3),
and the Agency has not identified an unsaturated zone
sensor that can detect initial waste release from a small
corrosion hole.
(3) Presentation of data. Refer to Chapter 3.3.1(3) for the data
formats. Th,.- data input will be the maximum value(s) required to
calculate waste velocity.
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OSWER Dir. 9483.00-2
I. MAXIMUM VOLUME OF THE TANK
II. EXPECTED MAXIMUM VOLUME OF TOTAL WASTES IN THE TANK
III. RANGE OF THE VOLUME OF TOTAL WASTES IN THE TANK
IV. RANGE OF PERCENT VOLUMES OF WATER (IN COMPARISON TO TOTAL
WASTE VOLUMES) IN THE TANK
V. RANGE OF PERCENT VOLUMES OF HAZARDOUS WASTES (IN
COMPARISON TO TOTAL WASTE VOLUME) IN THE TANK
VI. COMPLETE CHECKLIST FOR EACH CONSTITUENT OF THE WASTE
(SEE FIGURE 3-6)
Figure 3-5 Format and Contents for Source Characteristics
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Complete for Each Waste Constituent:
Chemical Name
% Weight (Show Method)
% Volume (Show Method)
Density (Show Method or Reference)
Viscosity (Show Method or Reference)
Koc* (Show Method or Reference)
Is Chemical Organic?
Is Chemical Inorganic?
*Koc is the organic carbon partition coefficient
Figure 3-6 Checklist of Data Requirements for Waste
Constituents
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3.4 Characterization of Site Hydroqeoloqlc Conditions
Hydrogeologic Information constitutes part of the location data
required to support the contention that releases of waste from tank
systems will not migrate to ground water or surface water. Specifically,
it is used to estimate the time of travel of waste through the
unsaturated zone of the soil. Note that the factors listed below may not
be a complete listing of all information necessary on a site-specific
basis to demonstrate that a variance is warranted. For example, a site
with complex subsurface structure or stratigraphy may need a more
thorough characterization than one that varies uniformly across or under
the site.
3.4.1 Investigative Techniques
The July 14, 1986, regulations do not prescribe specific methods;
rather, the selection of appropriate methods is up to the applicant.
Volume 2, Chapter 3, contains a general discussion of the types of data
necessary for characterizing the hydrogeology of a site, and the types of
investigative techniques to collect such data. Table 3-3 lists a number
of relevant techniques that may be useful. Table 3-4 summarizes
potential sources of data that may already be available. It should be
noted that much of the required data may already be included in the RCRA
Part B permit application for the facility, if one exists. In such
instances, applicants should reference the Part B applications, rather
than reintroducing data.
3.4.2 Climatic and Meteorological Data
(1) Information required. The following types of climatic and
meteorological data should be included in the application (see Volume 2,
Chapter 3, for more specific requirements):
• Precipitation data, Including monthly and annual rainfall and
snowfall (expressed as its equivalent in rainfall and at its
highest levels);
• Ambient air temperature, reported as monthly and annual averages;
• Evaporation and transpiration rates at their highest levels
(depth/time);
• Runoff; and
• Infiltration rate at its highest levels (depth/time).
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Table 3-3 Hydrogeologic Investigative Techniques
Identification of Subsurface Materials (geology):
• Survey of existing geologic information
• Soil borings
• Rock corings
• Material tests (grain size analyses, standard penetration tests.
etc.)
Geophysical well logs (point and lateral resistivity and/or
electromagnetic conductance, gaiima ray. gamma density, callpher,
etc.)*
Surface geophysical surveys (direct current, resistivity.
electromagnetic. seism1c)a
• Hydraulic conductivity measurements of cores (unsaturated zone)
• Detailed 1Ithologlc/structural mapping of outcrops and trenches
Identification of Hydraulic Conductivities:
• Slug test and/or pump tests
• Tracer studies
• Estimates based on sieve analyses
aThese techniques can be used to supplement information gathered from
other sources and may be necessary to perform at some sites (e.g., very
heterogenous areas).
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Table 3-4 Principal Sources of Geotechnical Data
Published Data;
1. USGSa surficial geology maps
2. US6S bedrock geology maps
3. USGS hydrological atlases
4. USGS basic data reports
5. State and County geologic and hydrologic maps and reports
6. National and local technical journals, magazines, and conference
proceedings
7. USSCSb soil maps
Unpublished Data:
1. Local test boring and well drilling firms
2. Local and State highway departments
3. Local water departments
4. State well permit records
5. State and local transportation departments
6. State and Federal Environmental Agencies
7. State and Federal Mining Agencies
8. Army Corps of Engineers
9. Local consulting, construction and mining companies
10. Geologists, hydrologists, and engineers at local universities
11. Historical records
12. Interviews
*USGS - United States Geological Survey.
'HJSSCS - United States Soil Conservation Service.
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Rainfall and temperature data can be obtained from the National
Oceanic and Atmospheric Administration (NOAA) or the National Weather
Service. Daily precipitation records are published by the U.S.
Environmental Data Service in "Climatological Data" and "Hourly
Precipitation." Regional data may be used if they were generated within
a reasonably close distance to the tank site (approximately 15 km) and
are representative of rainfall conditions at the site (see Volume 2,
Chapter 3). Estimated Infiltration rates may be available from the Soil
Conservation Service (U.S. Department of Agriculture); it may, however,
be necessary to estimate this value by subtracting the average annual
evaportranspiration and runoff rates from the average annual
precipitation rate.
(2) How data are to be used. Climatic factors at the site are
important parameters affecting the transport of contaminants in the event
of a release. For example, runoff helps determine the potential for
overland flow to carry a waste from the site of release to a body of
surface water (see Chapter 3.7.1). The following are factors that might
indicate high potential for contamination of ground and surface water:
• Moderate to high annual rainfall;
• High rainfall In one season;
• Low infiltration rate (suggesting greater overland flow);
• High infiltration rate (which may assist transport of contaminants
in the unsaturated zone);
• High runoff (suggesting the possibility of overland flow); and
• Location of the site within a flood plain.
The following factors might Indicate a reduced possibility of
contamination:
• Low annual rainfall; and
• Infrequent storms depositing small amounts of precipitation. •
(3) Presentation of data. It is recommended that climatic data be
presented in the format shown in Figure 3-7.
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OSWER Dtr. 9483.00-2
I. TABLES
A. Monthly mean precipitation
B. Monthly range of preciptation
C. Annual mean precipitation
D. Annual range of precipitation
E. Time period sampled
F. Inches of precipitation in a 24-hour period during storms
with a return frequency of 1,10,25,50, and 100 years
G. Monthly average temperature and annual average temperature
H. Evaporation and transpiration rates
I. Annual surface runoff
J. Soil infiltration rate
ILMAPS
A. Location of the rain gauge with respect to die facility
B. Potential flooding from 1,10,25, 50, and 100-year return frequency storms (if facility
is located in a flood plain)
C. Facility site map showing flood prevention stuctures, if any
Figure 3-7 Format for Presenting Climate Data
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OSWER Policy Directive
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3.4.3 Site Geology
Since the technology-based variance is based on a showing that
releases of hazardous waste can be "contained" by excavation before
reaching ground water or surface water, the geologic site
characterization focuses on the unsaturated rather than the saturated
zone'of the soil. This section will address two topics, surficial
geology and the unsaturated zone.
(1) Information required. Factors necessary for characterizing the
hydrogeologlc setting of the site include the following:
• Chemical and physical characterization of the soil and underlying
rocks;
• Structural features and stratigraphlc relationships of the bedrock
and the overlying strata;
• Types, distribution, and composition of soils;
• Heterogeneities in the underlying strata or backfill that would
provide preferential transport channels through the unsaturated
zone; and
• The seasonal high ground-water table level.
Geological factors that appear to present an increased possibility
for contamination of ground water should be examined in detail (see "How
data are to be used," below). The following types of information will be
required.
• Regional geologic map. A large-scale, plan-view geologic map from
a source such as the U.S. Geological Survey or State geological
surveys.
• Regional structural trends. Identify regional structural trends
that may have a bearing on the site (e.g., fracture patterns,
folds, or faults).
• Published geologic studies. Structural, stratigraphic, and
hydrologic studies relating to the location of the tank system
site should be included.
• Hydrologic map. A map of regional aquifers may be obtained from
sources such as the U.S. Geological Survey's Hydrologic Atlas
series.
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UbwtK POIicy Directive
No. 9483.00-2
• Topographic map. A topographic map should be constructed under
the supervision of a licensed surveyor; a regional topographic map
prepared from published sources may also be useful. See Volume 2,
Chapter 3 for further discussion.
• Site geologic map. Detailed surflcial geologic information on the
site should be collected and presented on a plan-view geologic
map. While published sources may be helpful, the level of detail
required may require onslte field and mapping surveys. See
Volume 2, Chapter 3 for further discussion.
Field studies should be carried out in the unsaturated zone. The
first step is defining the high and low depth to water table. All strata
(rocks, sediments, and soils) above the low depth of water table should
be examined in field and laboratory studies. Samples should be logged in
the field by a qualified professional geologist. Drilling logs and field
records should be prepared on gross petrography, gross structural
interpretation of each geologic unit and structural feature, development
of soil zones and vertical extent and field description of soil types,
and grain-size distributions. For further discussion, see Volume 2,
Chapter 3. That section also describes how to obtain the required
laboratory data.
(2) How data are to be used. These data will be used at an early
stage in the evaluation process to assess potentially vulnerable
hydrogeologies. Data will be Interpreted to determine possible aquifer
recharge zones, regional stratigraphy, prevailing structures, and the
presence of karst or solution passages near the tank system site.
As pointed out above, the unsaturated zone plays the major role in
governing the transport of hazardous waste to ground water. For a
complete discussion of factors required for time of travel estimation,
see Chapter 3.7. Hydrogeologic information Is also necessary to evaluate
the functioning of leak detection Instruments. Information on monitoring
instruments and properties is presented in Chapter 3.6 of this volume.
The high water table level establishes the lower boundary of the
unsaturated zone for modeling time of travel of pollutants to ground
water. The lower water table level determines the lower boundary of the
unsaturated zone and the depth to which strati graphic studies should be
completed. A detailed discussion of the process of unsaturated zone
characterization can be found in Volume 2, Chapter 3.4.
(3) Presentation of data. Data gathered to characterize the
unsaturated zone should be presented using maps, cross-sections, and
tables as shown in Figure 3-8.
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OSWER Dir. 9483.00-2
I. TABLES
A. Soil types and properties
B. Sediment/rock types and properties
C. Gross petrography
D. Gross structural features
E. Gross soil types
F. Grain-size distributions
II. MAPS
. A. Plan-view map of soils
B. Stratigraphic maps of cross-sections displaying extent and arrangement of geological units in
the unsaturated zone.1
III. DRILLING AND BORING LOGS
IV. LABORATORY ANALYSES
JThis may be in the form of structural contour maps. 150 pack maps, or vertical sections.
Figure 3-8 Format for Presenting Hydrogeologic Data
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3.5 Determination of Zone of Engineering Control
The "zone of engineering control" is defined in the July 14, 1986,
regulations as follows (40 CFR 260.10):
"Zone of engineering control" means an area under the control of the
owner/operator that, upon detection of a hazardous waste release, can
be readily cleaned up prior to the release of hazardous waste or
hazardous constituents to ground water or surface water."
It includes the greatest lateral extent a material released from a tank
system or the piping lattice could travel, whether surface or subsurface,
and the depth to which it would travel in a specified time (discovery and
remediation). For the purposes of the variance procedure described here,
the zone of engineering control refers to the space in which the released
material is confined for the time necessary for (1) detection,
(2) remediation, and (3) complete cleanup of the released material. This
section describes how the zone of engineering control is established.
3.5.1 General Procedures
(1) Information required. Information requirements for determining
the zone of engineering control are described below:
• Site Plan
Provide a site plan showing the location of the tank system, the
areal extent of the zone of engineering control, property
boundaries, nearest surface water, and locations of all surface
and subsurface structures and utilities, both onsite and offsite,
that have a bearing on establishing the zone of engineering
control. Be sure that all associated piping and other ancillary
and the possible extent of migration from them are included in the
calculation of the areal extent.
• Mater Table Map
Provide a water table map showing the depth to the highest
seasonal water table.
• Cross-sections
Provide cross-sections showing the location of the tank system,
highest seasonal water table, property boundaries, nearest surface
water, and locations of all surface and subsurface structures and
utilities, both onsite and offsite, that have a bearing on
establishing the zone of engineering control.
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• Accessibility and Obstructions
Provide a description of all surface and subsurface structures
that may restrict access for remedial actions. If any of these
structures are within the zone of engineering control, describe
plans to remove them to attain access for remediation. For
example, if any part of the zone of engineering control lies
beneath a paved area, provide information on the areal extent and
thickness of the pavement and discuss the feasibility of removing
the pavement to attain access to the contaminated' soil within the
required tiqie frame.
• Equipment Limitations
Identify the equipment that would be used to excavate contaminated
soil in a spill/leak response. This information should also be
provided in the spill/leak response plan. Describe the
operational limitations of the equipment, and consider any
limitations this may impose on the zone of engineering control.
For example, the maximum depth of excavation may be limited by the
reach of the equipment, or some equipment may be too large to get
into some areas.
• Migration Pathways and Travel Times
On the site plan and cross-sections, show the shortest flow paths
along the migration routes towards surface water and ground
water. Calculate the travel times within the zone of engineering
control along these flow paths (using migration rates determined
in Section 3.7). If there are any subsurface structures (e.g.,
sewer lines, water mains, or other pipelines) that may provide
special pathways for waste migration, calculate travel times
within the zone of engineering control along these pathways. The
shortest travel time calculated is the maximum time for
remediation that is available.
• Volume of Soil
Calculate the total volume of soil contained within the zone of
engineering control.
• Legal Agreements
If there are any legal agreements to extend the area under the
control of the owner/operator beyond the owner/operator's property
line for the express purpose of establishing a zone of engineering
control, attach all such agreements.
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• Margin of Safety
Discuss the selection of the zone of engineering control
boundaries in terms of the margin of safety they provide along the
migration routes towards surface water, ground water, and any
structures that would obstruct access for remediation.
(2) How data are to be used. By definition, there are several
constraints on the zone of engineering control. These constraints serve
as a mechanism to establish the zone of engineering control and are
listed below:
• The zone must be under the control of the owner/operator of the
tank system.
• There can be no ground water within the zone.
• There can be no surface water within the zone.
• It must be readily accessible for cleanup.
(a) Area under control of the owner/operator. In most cases,
in order for the zone of engineering control to be within the control of
the owner/operator of the tank system, it must lie entire.ly within the
owner/operator's property boundary. It is conceivable, however, that the
zone of engineering control can extend beyond the property line if
control by the owner/operator of the tank system can be established
through a legal agreement with adjacent land owners.
(b) Determination of areas free of ground water. There can be
no ground water within the zone of engineering control. The applicant
must establish the location and depth of the seasonal high ground-water
table at the site. This data will serve to define the depth of the zone
of engineering control. As a margin of safety, the lower boundary of the
zone of engineering control must be established at a depth above the
seasonal high ground-water table.
(c) Determination of areas free of surface water. There can be
no surface water within the zone of engineering control. The applicant
must identify the nearest surface water to the tank system. For surface
water, as with ground water, a margin of safety must be considered in
defining the limits of the zone of engineering control.
Loose fill around subsurface structures, such as buried pipelines,
may provide migration pathways for contaminants. Any surface or
subsurface structures that may provide pathways for migration of
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contamination to surface water or ground water should be identified. If
such structures exist, the applicant ultimately must demonstrate that the
migration of contaminants along such pathways can be contained within the
zone of engineering control. This demonstration must be shown in
Chapters 3.8 and 3.9. (The relationship of other analyses in this
chapter to the zone of engineering control 1s discussed in item (e)
below.)
(d) Determining areas readily accessible for cleanup. In
addition to source control actions, such as emptying or removing a
leaking tank, remediation within the zone of engineering control would
most likely consist of removal of contaminated soil. In some cases,
other remedial measures may be suitable (e.g., soil vapor recovery,
in-situ decontamination); however, soil removal is the worst-case
remedial alternative. The following discussion on the accessibility of
the zone of engineering control for cleanup assumes that soil removal
from the zone of engineering control would be the remedial action taken
in event of a spill/leak.
The zone of engineering control must be readily accessible for
cleanup should a release from the tank system occur. In practical terms,
this means that the zone of engineering control must contain no
buildings, pavement, other surface structures, buried pipeline,
utilities, or other subsurface obstructions that restrict access for
remedial response. Alternatively, If such obstructions do exist, it must
be demonstrated in the spill/leak response plan (Chapter 3.8) that they
can be removed or circumvented to attain access as part of the
remediation plan. For example, if the tank system lies beneath a paved
area, removal of the pavement may be part of the spill/leak response
plan. If, however, leaking material were to migrate beneath a building,
it would probably not be practical to demolish the building to remediate
the leak. In such a case, the edge of the zone of engineering control
would have to be established somewhere between the tank system and the
building. Again, some margin of safety must be provided in establishing
this boundary. The boundary should be established far enough away from a
structure to allow soil excavation without undermining the integrity of
any foundations.
The zone of engineering control must be within the operational
limitations of the equipment that would be used for remedial response.
For example, it would not be practical to define the zone of engineering
control to d depth of 100 feet if the equipment available for soil
excavation could reach a depth of only 30 feet. Additionally, the zone
of engineering control must be restricted to a volume that can reasonably
be cleaned up within the time constraints imposed.
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(3) Presentation of data. Figure 3-9 provides the format for
presenting the information pertaining to establishment of the zone of
engineering control. This is not a form, but a suggested format and
order for the required Information. The objective is to determine the
vertical and horizontal boundaries of the zone of engineering control as
defined by distance to ground water and surface water. The boundaries
must be selected to provide a "margin of safety" between the unsaturated
zone and ground water and surface water.
3.5.2 Relationship of Zone of Engineering Control to Migration Time
and Remediation Time.
The maximum size of the zone of engineering control will depend on
the proximity of the tank system to ground water and surface water, the
area under control of the owner/operator of the tank system, and the area
accessible for remedial action. The maximum size is also a function of
the time required for detection, remediation, and complete cleanup of the
released material. The size must be larger than the space through which
the waste would migrate within this time.
Ultimately, the zone of engineering control is determined by the
migration rates of released material along the migration routes towards
surface water and ground water. This section provides the basis for
establishing the initial physical boundaries of the zone of engineering
control. This Information will be used in conjunction with analyses in
Chapters 3.7 (Determination of Time of Travel), 3.8 (Site Remediation/
Response Plan), and 3.9 (Demonstrate Sufficiency of Response and Remedial
Times). The applicant must show the shortest amount of time in which
released material might reach ground water or surface water. This
"shortest time" is the maximum time for remediation that is available.
Depending on the time of remediation required, the edge of the zone of
engineering control may vary. This time must also take Into account the
distance travelled by any released material that may have leaked prior to
detection as discussed 1n Chapters 3.6 and 3.9
3-6 Leak Detection System Evaluation
The purpose of this section Is to provide a framework for the
applicant to present a demonstration that a release from the tank system
can be effectively detected. While EPA has reviewed existing tank
testing and inventory monitoring techniques, it has found that they are
not sufficiently reliable to serve as long-term methods of detecting
leaks from hazardous waste tank systems. EPA is currently considering
the applicability of existing unsaturated zone monitoring techniques in
detecting releases from tank systems. It is feasible that some
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unsaturated zone monitoring methods could potentially be employed on a
case-by-case basis as part of a technology-based variance. In the
meantime, the burden of proof for a technology-based variance (for leak
detection systems) will be on the applicant.
To demonstrate the effectiveness of the proposed leak detection
system, the applicant must include the following:
• A description of the leak detection method to be used;
• Identification of the variables that may affect the operation of
the system, and techniques to compensate for the effects of these
variables;
• A description of the calibration, testing, and maintenance
procedures that will be used to ensure reliable operation of the
system for the life of the system, and under the range of
operating conditions in which it will be used;
• A determination of the lower limit of leak detection for the
system; and
• A determination of the response time of the leak detection system.
The applicant must particularly demonstrate the effectiveness,
reliability, lower detection limit, and response time of the leak
detection system. The validity of the demonstration method used to
evaluate these factors has to be discussed in the variance application.
A leak detection system may be operated on either a continuous or
intermittent basis. The only limitation is that the response time for
leak detection must meet the time constraints of the performance
methods. Potential demonstration methods may Include calculations, or
bench scale, pilot scale, or in-situ physical tests. No specific
demonstration technique is prescribed in this manual. It is the
responsibility of the applicant to devise a method to demonstrate the
validity of a particular leak detection system.
The effectiveness of the leak detection method must be demonstrated
for two principal leak scenarios: <1) a catastrophic leak in which there
is a rapid release of material and (2) a slow release In which it may
take a long time for a detectable amount of material to escape. Timely
detection of corrosion-caused leaks is critical because they may start
and leak slowly for a long period of time before they reach a detectable
level. The detection of catastrophic releases is less problematic in
that a detectable quantity of material is released quickly.
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I. SITE PLAN
II. WATER TABLE MAP
III. CROSS SECTIONS
A. Location of tank system
B. Vertical and lateral extent of zone of engineering control
C. Highest seasonal water table
D. Property boundaries
E. Nearest surface water
F. Locations of all surface and subsurface structures and utilities
IV. ACCESSIBILITY AND OBSTRUCTIONS
V. EQUIPMENT LIMITATIONS
VI. MIGRATION PATHWAYS AND TRAVEL TIMES
VII. VOLUME OF SOIL WITHIN ZONE OF ENGINEERING CONTROL
VIII. LEGAL AGREEMENTS
IX. DETERMINATION OF MARGIN OF SAFETY
Figure 3-9 Format and Contents for Determining Zone of
Engineering Control
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3.6.1 Internal Leak Detection Systems
(1) Information required. There are two types of internal leak
testing, volumetric and non-volumetrie. The volumetric methods measure
leak rates, while the non-volumetric methods provide only the indication
that there is a leak. Applicants will need to describe the type of
testing proposed and how leaks will be measured and detected. Changes in
volume can be determined by measuring parameters associated with volume
change, Including changes in liquid level, temperature, pressure, and
density. Inventory monitoring and some types of tank testing procedures
use this approach. Certain variables affect the volume change or the
measurement of the volume change. These variables include, temperature,
water table conditions, tank deformation, vapor pockets, evaporation of
stored material, tank geometry, wind, vibration, noise, equipment
accuracy, operator error, type of material stored, power variation,
instrument limitation, atmospheric pressure, and tank inclination.
Applicants must Identify how these variables affect volume change or its
measurement.
Examples of non-volumetrie methods Include (1) the placement of a
pressurized tracer gas inside the tank and monitoring for the tracer gas
outside the tank or (2) monitoring the sound caused by a leak inside a
tank. Some forms of tank testing use these approaches. Non-volumetric
detection methods generally require that the tank system be completely
sealed so that pressure can be exerted within the system. This increase
in pressure can cause or enhance a leak. These methods may not be
applicable for tanks during normal use when they must be opened and
closed to add or remove materials. There 1s also a potential for the
tracer gas to react with material in the tank, possibly creating an
explosion hazard. The reliability of non-volumetric leak detection
methods is generally affected by the same variables as that of volumetric
methods. For non-volumetric methods In which external sensors are used
(e.g., for detecting tracer gas leakage), hydrogeologic variables may
also affect reliability.
Finally, applicants must specify the lower limit of leak detection.
The lower limit of leak detection has different significance for
different leak detection methods. For volumetric leak detection methods,
the lower limit of leak detection is usually expressed as the minimum
rate of leakage (volume per unit time) that can be detected. For
non-volumetric leak detection methods, the lower detection limit may be
dependent on a minimum rate of leakage or on a minimum hole diameter for
the leak.
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<2) How data are to be used. The objective of the analysis of the
data presented above will be to demonstrate lower leak detection limits.
The applicant must be able to quantify the time (duration of release) and
volume of any potential releases that fall below the leak detection
limit. There must be a way to account for these small leaks that could
grow large enough to be detected. Based on the above information, a
final determination will be made concerning the potential for any
undetected releases that can migrate to the ground water or surface
water. (These determination parameters are also discussed and used in
Section 3.9 of this document.)
If EPA believes that the time for release of stored materials to
accumulate to detectable levels will lead to a ground-water or
surface-water migration problem, EPA may deny the application.
A detailed discussion of the individual information requirements
follows with an explanation as to why they are necessary in the
evaluation process.
• Temperature
Changes in temperature cause expansion or contraction in the
product and in the tank dimensions, which in turn results in
pressure changes within the tank.. The extent of temperature
effects on volume changes Is dependent on the material stored in
the tank, and the tank material Itself. Temperature effects may
also cause stratification of material within the tank, making
volume corrections for temperature changes more difficult. The
basic Information the applicant must be concerned with is the
seasonal ambient temperature <°F) at which the hazardous wastes
will be stored. Furthermore, It will be necessary to provide the
boiling and freezing points (°F) of the waste material.
• Hater Table Conditions
Hydrostatic head and surface tension forces caused by ground water
outside a storage tank may mask leaks partially or completely.
Leaks may take the form of the stored material leaving the tank or
of ground water entering. Tank systems with any portion below the
water table will not qualify for a technology-based variance.
• Tank Deformation
Tank deformation may result from the change of volume of material
stored in the tank or from changes in temperature and pressure.
Factors that affect tank deformation include the material of tank
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construction, thickness of the tank walls, age of the tank, and
properties of the fill material around the tank. Non-volumetric
methods are generally not affected by tank deformation.
Vapor Pockets
Vapor pockets may form within tanks when the tank is completely
full. The volume of these vapor pockets may change rapidly with
changes In temperature and pressure and lead to inaccurate
volumetric measurements for the liquid material in the tank.
Factors that affect the formation of vapor pockets Include the
volatility of the material stored in the tank and the tank
geometry (i.e., vapor pockets may form at the high end of an
uneven tank, in a manway, or at the top of a drop line).
Furthermore, ambient atmospheric pressure and temperature (°F)
will have an effect on their formation.
Evaporation
Evaporation of the material stored 1n the tank causes a decrease
in volume which, if not accounted for, would be Interpreted as a
leak by a volumetric monitoring system. The material's
volatility, evaporation rate, and boiling point (°F) will be
factors in evaporation, along with the ambient temperature (°F).
Tank Geometry
Tank geometry affects volumetric leak detection in several ways.
In a horizontal, cylindrical tank, for example, the surface area
of the material changes at different levels within the tank. This
may cause variation In evaporative loss at different material
levels. Also, a given change in the fluid level Indicates
different changes In volume at different levels in the tank.
Non-volumetrie methods are generally not affected by tank geometry,
Hind
Wind may affect some leak detection methods in tanks that are kept
open to the atmosphere during monitoring, by creating motion
within the material or by causing pressure changes or both. The
data to quantify wind are broken down to wind speed and direction.
Vibration and Noise
Vibration can affect a volumetric measurement by causing motion in
the material. It can also hinder detection of leaks because
moving fluid will produce a masking "noise."
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• Equipment Accuracy (Sensitivity)
Changes in many of the variables described in this section are
measured and corrected for by the leak detection instrumentation.
Therefore, the sensitivity of the equipment to respond to these
variations (e.g., temperature changes) is a limiting factor on the
accuracy of the test equipment. The sensitivity of the
instrumentation is subject to change at different operating
conditions, such as temperature, pressure, and range of
measurement. All" minimum detection levels (ug/1, ug/m3, etc.)
should be listed.
• Operator Error
The potential for operator error increases with increasing
complexity of the monitoring procedure. A typical example of
operator error is Inadequate sealing of openings when a particular
monitoring method requires extensive sealing of the system's
openings. Also note whether wastes are added or removed from the
tank system as part of normal operating conditions. This is
another source of operator error.
• Type of Material Stored (Compatibility)
The physical properties of the material could affect the function
or accuracy of a detection method. The compatibility of the
material with the components of the leak monitoring system must be
demonstrated. For example, stored materials may cause corrosion
of monitoring components or may coat them, rendering them
inaccurate or non-functional. Waste viscosity can also affect the
sound characteristics of leaks that occur below the waste level.
All physical-chemical properties of the material stored and
material used 1n tank system construction should be listed.
• Power Variation
Most of the detection methods require electrical power for
operation. Power variations may lead to inaccuracy. An
alternative power source, such as a backup battery may also be
required in case the primary power source fails. The application
should state whether power Is AC or DC and where there is an
alternative power source.
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• Instrument Limitation
Some of the leak detection methods are to be used only under
certain operating conditions, such as a specific range of
temperatures or tank sizes. The selected detection method and
instrumentation must be used within its design range. Proper
ranges for instrument (temperature, pressure, volumes) and storage
material types (gas, liquid, solid) should be described.
• Atmospheric Pressure
Atmospheric pressure changes may cause a pressure change within
the tank system resulting in contraction or expansion of the tank
material. This effect may be magnified by the presence of a vapor
pocket within the tank system. The range of atmospheric pressure
(mm Hg) over the seasonal ambient temperatures (°F) should be
given.
• Tank Inclination
Tank inclination may affect detection accuracy for product level
detection methods. This 1s due to the difference in cross
sectional areas, at certain levels, for inclined versus level
tanks. This effect can be corrected by measurement of.level
change due to a known material volume change. The inclination
(0°-90°) from level ground should be recorded.
• Other Variables
This category 1s provided to cover any miscellaneous
characteristic of the site, tank system, or operating conditions
that the operator has reason to believe will affect the system
design and that are not covered 1n the sections above.
(3) Presentation of data. Figure 3-10 presents the format for Leak
Detection System Evaluation. This format provides a list of the minimum
information requirements for this section of the variance application and
a recommended order for presenting the information. This worksheet is
presented only as a recommendation for a data presentation format.
3.6.2 Perimeter Leak Detection Systems
A perimeter leak detection system is defined as a leak detection
system situated on the outer surface of the tank and appropriate
ancillary parts of the system (e.g., piping). Little research and
development have been done in this area; however, it is mentioned here as
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a possible approach among monitoring possibilities because some
innovative technology may lead to development of such a system. The
techniques that may be developed for perimeter leak detection systems
might utilize the same properties for current unsaturated zone
monitoring, for example, electrical conductivity, and sensitivity to
hydrocarbons, temperature, and moisture. Hypothetical examples of a
perimeter leak detection system could encompass an electrical
conductivity-sensitive wire grid around the tank system to detect a leak
of waste material.
(1) Information required. Because a perimeter leak detection system
is In contact with both the tank and its external environment, a
combination of variables affecting both external and Internal leak
detection systems would affect this system's accuracy. Common variables
are listed below. (See Chapter 3.6.1 for a more detailed discussion.)
Temperature
Water table conditions
Tank deformation
Vibration and noise
Equipment accuracy (sensitivity)
Operator error
Type of material stored (compatibility)
Power variation
Instrument limitation
Soil moisture
Soil type (compatibility)
Surface spills
(2) How data are to be used. The common variables listed above will
be used In the same manner as described in Chapter 3.6.1(2). The
variables listed below reflect the influence of the external
environment. A brief discussion follows on their possible effect on the
detection system. It must be noted that external environments will be
different from site to site and variables other than those listed above
may apply. The applicant must Include any and all aspects of information
the external environment (e.g., hydrogeology, weather) that can have any
effect on the leak detection system.
• Soil Moisture
Soil moisture conditions may vary between dry and moist
conditions. A peru.eter leak detection system would have to
remain operational through these varying soil moisture conditions.
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I. DESCRIPTION OF METHOD
Description of leak detection method including:
• Description of physical principle on which the detection method is based
• Indication of whether the method is continuous or periodic (semi-continuous intermittent)
• Indication of whether the system can operate under normal tank system operating conditions
or whether special preparation conditions are required
• Description of how the system communicates leak detection.
Section may include a conceptual drawing of the leak detection method.
II. DESIGN OF LEAK DETECTION SYSTEM
Provide engineering drawings of the tank, ancillary equipment, and all components of the leak detection system.
Demonstrate that the method is capable of detecting a leak occurring in any pan of the tank system.
III. TECHNIQUES TO COMPENSATE FOR THE EFFECTS OF VARIABLES
For each variable listed below, provide an explanation of either (1) how the leak detection method compensates for
the effects of the variable, or (2) why the effects of the variable are not applicable to or have no effect on the leak
detection method.
A. Temperature
B. Tank Deformation
C. Vapor Pockets
D. Evaporation
E. Tank Geometry
F. Wind
Figure 3-10 Leak Detection Systems Evaluation Checklist
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ID. (Con't)
G. Vibration
H. Noise
I. Equipment Accuracy (Sensitivity)
J. Operator Error
K. Compatibility With Waste
L. Power Supply
M. Instrumentation Limitation (Provide Sensitivity Limits for All Parameters
Measured by the Method)
N. Atmospheric Pressure
O. Tank Inclination
P. Addition and Removal of Material From the Tank as Part of Normal Operations
Q. Other Variables
Figure 3-10 Leak Detection Systems Evaluation Checklist (Continued)
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IV. CALIBRATION, TESTING, AND MAINTENANCE PROCEDURES
Describe the procedures used to ensure reliable and accurate operation of the leak detection system throughout its
useful lifetime, and under the range of operating conditions in which it will be used.
V. DETERMINATION OF LIMIT OF LEAK DETECTION
Provide lower leak detecdon limit (minimum leak rate, hole diameter, waste quantity or concentration, or other
limiting factor) of the system, and describe how determined. Summarize all error introduced by the effects of
variables described above, compensation for these effects, and a calculation of the final lower limit of leak detection.
Alternatively, some physical demonstration method may be used such as a bench scale, pilot scale, or in-situ test It
is the responsibility of the applicant to devise and demonstrate the validity and reliability of a particular method under
the range of operating conditions that the instrumentation is designed for. The applicant must also demonstrate the
reproducibiliry of the data.
VI. DETERMINATION OF RESPONSE OF LEAK DETECTION
For a continuous monitoring system, the applicant must provide a determination of the lower limit of leak detection,
and the time required for a leak to grow to this quantity. For intermittent monitoring, the maximum time interval
between monitoring events should be added to the values determined above.
Figure 3-10 Leak Detection Systems Evaluation Checklist (Continued)
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• Soil Type (Compatibility)
The physical properties of the soil could affect the function or
accuracy of a leak detector. For example, an acidic soil could
corrode components of the leak detection system, or soil could
agglomerate around the sensor rendering it non-functional. This
also ties'into the above variable since different soil types
retain or lose moisture at different rates.
• Surface Spills
With any external monitoring device, spills on the surface may
infiltrate the soil and reach the detectors, and thereby be
Interpreted as a tank leak. Again, a demonstration that a new
innovative technology for perimeter leak detection systems will
work must demonstrate that each of these potentially adverse
variables either does not affect the proposed detection method or
incorporates techniques to compensate for the effects of the
variable.
(3) Presentation of data. Figure 3-11 provides the format for
presentation of the above mentioned data. It can be amended to provide a
perimeter leak detection device evaluation worksheet by just adding the
external environment variables under Section III of Figure 3-10.
3.6.3 Unsaturated Zone Monitoring Systems
Owners and operators of tank systems that would include unsaturated
zone monitoring as an element of their leak detection program must
demonstrate to the Regional Administrator that the system Is sufficiently
sensitive to allow leaks to be detected. This section describes the
information and analysis that must be submitted by applicants.
(1) Information required. General information requirements for
evaluating unsaturated zone monitoring systems are described below.
(a) Description of the physical principle(s) upon which the
method relies. This section should describe how the device will
determine that a leak has occurred (e.g., by measuring conductance
changes in the soil, resistivity changes, pH, total volatile organic
vapor, etc). Any possible problems with shielding should be discussed.
For example, might the ceramic or polymer cup have a preferential
adsorption pattern for the ion of concern?
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(b) Device compatibility. This section will describe how the
subsurface probes are expected to interact with the soil environment.
For some devices, such as PVC probes used for drawing pore gas vapors,
this will require little if any additional work. For other devices,
however, such as gypsum blocks or ceramic cups, a demonstration will have
to be made that the device will survive its environmental surroundings
without self destruction or clogging.
(c) Design of leak detection system. This section is the heart
of the effectiveness part of the application, describing in detail the
physical characteristics of the system. Drawings should be included, if
possible. It will use the Information gathered to show that the proposed
placement and number of probes or devices Is such that no leak will go
undetected. It will show that even under the worst of circumstances
(e.g., extreme dilution due to precipitation events), the detection
limits of the system are such that a leak will be picked up within a
reasonable time. Chapters 3.8 and 3.9 will relate this reasonable time
to the emergency response plan and the time of reaction needed to prevent
the material from reaching the ground water). The applicant must
describe in detail how the system can differentiate between actual
releases and "false alarms." The degree to which "false alarms" can be
minimized without losing effectiveness must be discussed.
(d) Calibration, testing, and maintenance procedures. In this
section, the applicant will describe the procedures to be used to ensure
reliable and accurate operation of the leak detection system throughout
its useful lifetime under the range of operating conditions in which it
will be used. Personnel to be used for this purpose (in-house or outside
contractor) should be identified and their qualifications presented.
Some specific types of data required are as follows:
• Depth to ground water (high water mark on site). The regional or
area depth is not acceptable.
• In-situ permeability tests on the most and least permeable
sections of the stratigraphy between the surface and the ground
water. Laboratory tests are not acceptable. At least two
locations should be tested to verify continuity.
• Continuous core sampling (or other suitable Technique) that will
allow for accurate field logging of the soil stratigraphy down to
the ground water.
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I. DESCRIPTION OF METHOD
Description of leak detection method including:
• Description of physical principle on which the detection method is based
• Indication of whether the method is continuous or periodic (semi-continuous intermittent)
• Indication of whether tne system can operate under normal tank operating conditions
or whether special preparation conditions are required
• Description of how the system communicates leak detection.
Section may include a conceptual drawing of the leak detection method.
II. DESIGN OF LEAK DETECTION SYSTEM
Provide engineering drawings of the tank, ancillary equipment, and all components of the leak detection system.
Demonstrate that the method is capable of detecting a leak occurring in any part of the tank system.
III. TECHNIQUES TO COMPENSATE FOR THE EFFECTS OF VARIABLES
For each variable listed below, provide an explanation of either (1) how the leak detection method compensates for
the effects of the variable, or (2) why the effects of the variable are not applicable to or have no effect on the leak
detection method.
A. Temperature
B. Taok Deformation
C. Vapor Pockets
D. Evaporation
E. Tank Geometry
F. Wind
Figure 3-11 Perimeter Leak Detection Systems Evaluation
Checklist
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IH. (Con't)
G. Vibration
H. Noise
I. Equipment Accuracy (Sensitivity)
J. Operator Error
K. Compatibility With Waste
L. Power Supply
M. Instrumentation Limitation (Provide Sensitivity Limits for AH Parameters
Measured by the Method)
N. Atmospheric Pressure
O. Tank Inclination
P. Addition and Removal of Material From the Tank as Part of Normal Operations
Q. Soil Moisture
R. Soil Type
S. Surface Spills
Figure 3-11 Perimeter Leak Detection Systems Evaluation
Checklist (Continued)
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IV. CALIBRATION, TESTING, AND MAINTENANCE PROCEDURES
Describe the procedures used to ensure reliable and accurate operation of the leak detection system throughout its
useful lifetime, and under the range of operating conditions in which it will be used.
V. DETERMINATION OF LIMIT OF LEAK DETECTION
Provide lower leak detection limit (minimum leak rate, hole diameter, waste quantity or concentraaon, or other
limiting factor) of the system, and describe how determined. Summarize all error introduced by the effects of
variables described above, compensation for these effects, and a calculation of the final lower limit of leak detection.
Alternatively, some physical demonstration method may be used such as a bench scale, pilot scale, or in-situ test It
is the responsibility of die applicant to devise and demonstrate the validity and reliability of a particular method under
the range of operating conditions that the instrumentation is designed for. The applicant must also demonstrate the •
reproducibility of the data.
VI. DETERMINATION OF RESPONSE OF LEAK DETECTION
For a continuous monitoring system, the applicant must provide a determination of die lower limit of leak detection,
and die time required for a leak to grow to this quantity. For intermittent monitoring, the maximum time interval
between monitoring events should be added to the values determined above.
Figure 3-11 Perimeter Leak Detection Systems Evaluation
Checklist (Continued)
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• For gas-based probes, calculation of the rate of diffusion of the
volatlle(s) of concern in the subsurface. If possible, reference
should be made to published experiments that have shown this
calculation to be valid in the context used. Calculations should
be made such that the full range of expected moisture content of
the unsaturated zone is covered.
• For liquid-based probes, calculation of the rate of flow in the
subsurface. This should include a lateral spread component to
allow a determination of whether the proposed density of
deployment is adequate.
• For liquid-based probes, a calculation of what dilution will occur
in a saturated flow condition caused by precipitation.
• For detectors in contact with the soil, a determination of
compatibility with the soil chemistry. For example, one would not
want to put a gypsum block in a highly acidic environment.
• For all in-situ detectors or detector probes, a determination that
the expected concentrations under all foreseeable circumstances of
escaping wastes will be high enough to detect. Or, if detectors
are species-specific, it must be demonstrated that the presence of
other materials in the waste will not mask the material of
interest.
• Calculation for small and large leaks of the time required for the
device to provide an indication that a release has occurred.
(2) How data are to be used. Unsaturated zone monitoring devices
can be grouped into two large segments: those that respond to changes
brought about by a saturated flow event that crosses their zone of
influence (e.g., lysimeters, electrical resistance blocks) and those that
respond to a change in concentration of contaminants within the gas pore
space. Both of these have been shown to work with some degree of
accuracy in their given areas (EPA 1983; Spittler 1985; and Marrin 1984
and 1985).
A number of problems have been attributed to these devices (USEPA
1983), and the applicant must demonstrate that these will not interfere
with the devices' functioning at his/her facility. For example, problems
associated with the devices used for periodic measurement of saturated
flow in the unsaturated zone include clogging of pores and a tendency to
absorb certain cations so that they do not appear in the collected
materials in representative concentrations.
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There have also been numerous reported incidents of devices such as
resistance blocks dissolving under the influence of saturated flow across
them, whether flow of contaminants is evident or not. The applicant must
assure the Agency that subsurface conditions at the site will not cause
these problems, and that an inspection and maintenance schedule will be
in place to guarantee adequate performance of the equipment. Many of
these devices are also associated with collection routines that are
neither continuous nor connected to an alarm system. To be successful,
the applicant must demonstrate that this would not adversely affect his
ability to detect and respond to a leak in a timely fashion.
Vapor detection systems generally have the opposite problem. They
are relatively sensitive to any increase in gas pore space contaminant
concentrations at the parts-per-mi1 lion level or above. This leads to
the problem, especially for older industrial facilities, of trying to
differentiate between a relatively high background and what could be, if
the waste stream does not contain elevated levels of volatile organics,
fairly low gas concentrations from a leaking system. This can be
overcome (at some expense) by using a species-specific detector and by
choosing (as surrogate) a waste constituent not generally used in the
production process.
Finally there are the problems of travel time and spheres of
influence. Most devices are relatively passive. That is, materials of
interest have to come to them. They are not unl'ike a ground-water
monitoring well where a plume on or in the ground water must pass into
their screen before its existence is known. A plume can pass within a
few feet of a monitoring well and not be detected.
For devices such as resistance blocks there is no sphere of
influence. The material or material-influenced water must pass directly
over it for detection to take place. Therefore, the applicant must
calculate how far the material will spread laterally between a small
point source and the positioning of the detection system. This will
determine the density with which he or she will have to deploy the
detection equipment.
For devices such as suction lysimeters, there is a moderate sphere of
influence, usually a few inches. The same calculations will have to be
made for these as for the resistance-type blocks, resulting in the number
of blocks per unit area being less for some soil classes. This is
because the resistance block has no ability to draw materials to 't and
some soils will allow small leaks to flow vertically downward with very
little spread. Historically, these devices have been used to monitor
land farming operations where general trends are measured since wastes
are usually applied evenly across a large area. They are looking for
contaminant fronts rather than point source leaks.
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Gas detection equipment currently on the market is generally of two
types. One consists of a passive device that is suspended in a bored,
cased hole that alarms when a diffusion cloud of volatile organics passes
over it. The detector is constructed of a metal oxide that operates on
the principle of changing electric current due to changing gas
composition in the probe. It is not highly sensitive and is not
species-specific.
The second type is not as passive as the first. It is usually
located out of the ground and depends on a vacuum being applied to
subsurface probes to bring the pore gas to it. The sphere of influence
for these devices depends directly upon how long the vacuum pumping is
continued, and on the type of soil and its degree of saturation. That
is, the more saturated the soil is, the more difficult it is for gasses
to move through it. Since the detection device is remote and does not
have to be located in the ground, its configuration, portability,
sensitivity, and ability to detect species-specific chemicals can vary
widely.
It will be incumbent upon the applicant to show, should he or she
choose one of these instruments, that it will function under the most
adverse conditions possible at his or her facility. An example might be
a tank that lacks any kind of a cover (pavement, concrete) and that
begins to leak on the second day of a two-week continuous rainstorm; the
subsurface is sandy, and the rain generates saturated flow in the
unsaturated zone. How will this affect the ability of the detection
system to discover the leak before it migrates beyond the zone of
engineering control? In this situation, if it is a gas detection system,
the vapors as well as the escaping liquid are liable to be caught up in
the downward flow and the system will never "see" the leak because of
restricted lateral diffusion and dilution. If the system depends on a
change in composition of the pore space liquid, then this amount of water
flow may dilute a small leak so that it is missed for several weeks. If
either of these situations should occur so that a small leak is missed
for some period, then the system will not qualify for the technology-
based variance.
(3) Presentation of data. Figure 3-12 provides the format for
presenting the information pertaining to unsaturated zone monitoring.
This is not a form, but a suggested format and order for the required
information.
(4) Other information available. Additional information on
unsaturated zone monitoring instruments and selected references on the
subject are included in Appendix C.
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3.7 Determination of Haste Travel Time
This section provides the applicant with procedures to determine
actual waste travel time 1n the event of a release. The two types of
travel that EPA Is interested in quantifying are overland flow
(horizontal surface movement) and unsaturated zone flow (vertical
movement). The determination of waste travel time and subsequent
evaluation of adequate spill response time will have significant bearing
on whether the variance is granted.
3.7.1 Overland Flow
This section discusses the methods for determining the velocity of
horizontal movement of releases from aboveground tank systems or the
aboveground portion of the tank system. The movement of fluids along the
surface of the earth is termed "overland flow." The analysis is
concerned with catastrophic releases since it is presumed that non-sudden
leaks from aboveground tank systems do not present as serious a problem.
That is, the aboveground tank systems are easier to inspect than
underground systems. The analysis Includes the effects of diversion
structures on the acceleration and retardation of the overland flow
velocity.
(1) Information required. The estimation of the migration velocity
of tank system contents during catastrophic releases depends on the
volume of release, land topography, soil and land use characteristics,
and waste characteristics. Many of the parameters discussed in
Chapters 3.3 and 3.4 will be used as data for the overland flow
calculations. These source characteristics are used in the equations
described below.
(2) How data are to be used. The objective of the analysis is to
establish a worst-case time of travel of overland flow to the edge of the
zone of engineering control. The migration of waste may occur both
horizontally and vertically, as the soils become saturated with released
materials. The applicant must demonstrate the depth to which the
released material will penetrate, and the time of travel of horizontal
migration to the boundary of the zone of engineering control.
(a) Depth of penetration. Depth of penetration refers to the
vertical movement of the ralease from the tank system. It can be
calculated using the fol'owing equation:
Dp = Vf/AED (3-1)
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I. DESCRIPTION OF MONITORING METHOD
A. Physical principle for monitoring
B. Detection limits
C. Device ranges of use/accuracy
D. Potential shielding/interference problems
II. DEVICE COMPATABILITY
A. Site hydrogeology/soil chemistry
B. Demonstration that instrument is compatible with soil environment
III. DESIGN OF LEAK DETECTION SYSTEM
A. Drawings of system plan and layout
B. Detection limits of the system
C. Time to detect releases
D. Demonstration that no release will occur undetected (discuss sensitivity, spacing of instruments, and worst-case
performance; e.g., high dilution due to precipitation events)
IV. CALIBRATION, TESTING, AND MAINTENANCE PROCEDURES
A. Depth to seasonal high water table
B. Results of in-situ permeability tests on stratigraphy between surface and the ground water
C. Results of continuous core sampling
D. Rate of diffusion of volatiles of concern
E. Concentration dilution that may occur in a saturated flow condition caused by precipitation
F. Rate of flow in the subsurface (including lateral spread component)
G. Demonstration that expected concentrations under all forseeable release incidents will be high enough to detect
H. Time to detect releases
I. Procedures to be used to ensure reliable and accurate operation of the leak detection system
Figure 3-12 Format and Presentation of Data Pertaining to
Unsaturated Zone Monitoring
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where
Dp « Depth of penetration
Ago - Downgradient surface area of the zone of
engineering control (m^)
Vf - Total volume of the tank (m3).
The equation conservatively assumes that the total release volume
migrates downward over the area of the zone of engineering control. The
volume is thus used to define the depth of penetration by making it a
function of the surface area of the zone of engineering control.
An example is provided to illustrate how the equation works. The
downgradient surface area of the zone of engineering control is assumed
to be 312.5 m2 and the volume, 250 m3. Using the equation, the depth
of waste penetration is 0.8 meters or 80 centimeters.
(b) Horizontal migration. Time of travel (TOT) of the release
to the edge of the zone of engineering control is calculated by the
following equation:
TOT « 1.8 (1.1 - C) (Dm)1/2 (3-2)
sl/3
where
TOT » Time of travel of release to edge of zone of
engineering control
C - Runoff coefficient
S « Overland slope percent
Dm » Travel distance
The equation assumes that the release has the same viscosity as that
of water. If this is not a valid assumption, onsite testing can be
performed to evaluate waste velocity, or the viscosity adjustments
explained in Chapter 3.3 can be applied.
The runoff coefficient (C) can be estimated from Table 2-2. The
overland slope percent (S) can be estimated from USGS topographic maps.
An example is provided to illustrate how Equation (3-2) works. The
downgradient zone of engineering control is 50 percent overlain by
unimproved areas and 50 percent overlain by conc.ete. The C values sho'fl
in Table 2-2 indicate that for unimproved areas, C is in the range of
0.10 to 0.30, and the concrete, from 0.80 to 0.95. Taking the average of
the ranges, C is estimated as 0.20 and 0.87 for the respective areas.
Since both areas are distributed equally (50 percent for each), the
average of the two C values is taken to obtain 0.54.
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The slope Is assumed to be 0.07, and the minimum distance to the edge
of the zone of engineering control is 12.5 meters. Using the equation,
the time of travel is estimated as 16 minutes. Figure 3-13 illustrates
the example used for both the depth penetration and horizontal migration
equations (3-1 and 3-2).
(c) Diversion effects. The horizontal migration equation
cannot be used alone to assess the time of travel. Qualitative
evaluations must be made to adjust the initial time of travel computed
using the equation. In particular, diversion effects must be taken into
account, such as all natural and man-made obstructions. In many
Instances, an unimpeded catastrophic release could result in migration
beyond the zone of engineering control. The flow may be channeled or
shunted to earthen berms or man-made containment devices via diversion
structures such as dikes and ditches. Also, existing divergence
structures such as roads or buildings may contribute to delaying the
flow. On the other hand, some structures may actually accelerate
overland flow.
The applicant must demonstrate to what extent any alternative
spillage containment system alters the time of travel. This is critical,
since the time of travel is a significant part of the final analysis in
Chapter 3.9, in which it must be shown that there Is sufficient time in
which to detect and remediate any releases prior to migration beyond the
zone of engineering control. Waste type, land surface characteristics,
and the presence of diversionary structures are the main factors that
must be considered in this evaluation.
This analysis, therefore, must examine the devices that control
(either intentionally or Incidentally) the direction and travel time of
the release and must Identify the final location of the release. The
analysis must also address what the time of travel of releases to the
boundary of the zone of engineering control can be in the event of a
25-year, 24-hour rainfall, and a release event from the largest tank in
the facility. (The response plan for such an event must be addressed per
the requirements of Chapter 3.8, not In the time of travel analysis.)
If no diversionary structures are used for control of releases, or if
the structures are Insufficient to delay migration, the type of waste
stored, topography, and soil will be considered. Of particular
importance in evaluating the effect of structures on travel time is the
effect of shunts on overland flow. If the system shunts the flow to the
subsurface and poses a potential migration to the ground Water, the time
of travel through the unsaturated zone should be calculated (see
Chapter 3.7.2).
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SLOPE
DIRECTION
S = 70
12.5 nn x 25 m
2
AED= 312.5 m
Vf= 250 m3
1 2
Ops 250 m /312 m s .8 m or 80 cm
Dm a 12.5 m or 41 FEET (3.28 FEET/METER)
S s 7° or .07
C a .5
KEY
CONCRETE
UNIMPROVED
TOT
.8 (1.1 - C) Dm
S1/3
1 12
TOT = 1.8 (1.1 • .54X41 )1/2 . 15.7
.07
1/3
Figure 3-13 Depth Penetration and Horizontal Migration
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The following factors must be considered in evaluating the alteration
of the time of travel of releases.
• Waste Characteristics
Viscosity is a key factor that affects the velocity of the waste
flow on the ground surface and infiltration rates. The velocity
of the waste varies inversely with its viscosity. Volatility is
also significant, since it can affect the amount of liquid
available for overland flow, depending on volatilization rate,
temperature, humidity, and time of exposure. (See Chapter 3.3 -
Source Characterization - for more information on determining
waste characteristics.)
• Soil Characteristics
Soil factors control the rate of infiltration into the ground.
These factors are hydraulic conductivity. Initial water content,
and surface conditions. In general, soil infiltration rates are
high in the early stages of absorption and decrease to a constant
rate as the soil becomes saturated.
Hydraulic conductivity controls the velocity in which fluids can
move through the soil (infiltration rate). The velocity is
dependent on the particle size; large particle sizes result in
high hydraulic conductivity.
Soil surface conditions also affect the rate of infiltration. If
the soil surface is open and highly porous with little compaction,
the initial infiltration rate Is higher than that of uniform
soil. This condition can be created by macropore openings from
plants and burrowing animals or by tilling or furrowing of the
land. Conversely, compacted and/or crusted soil acts as a
hydraulic barrier. Finally, the presence of vegetation is another
surface condition that can affect overland flow.
• Topography
The topography of the local land surface influences the direction,
velocity, and the amount of fluid available for overland flow.
The topographic factors are slope, surface storage, and formation
of stream flow by drainage patterns. Areas with high slope have
overland flows with higher velocities, thus reducing the travel
time of the spill per given area. The higher velocity reduces the
time in which the soil has to absorb the flow; therefore, a larger
surface area is needed for the fluid volume to infiltrate
completely.
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Drainage patterns determine whether overland flow will be able to
form stream flow. If the spill is able to form a stream flow, the
distance and velocity the spill can travel are increased. The
presence of rills or gullies can channel the flow and create a
conduit for spilled waste to travel. In some cases, these gullies
or rills are directly connected to surface water bodies. Man-made
drainage patterns can also greatly influence the direction that a
spill can travel. Roads (paved and unpaved), machinery tracks,
and even footpaths can act as stream channels for the
transportation of a spill.
• Land Use
The evaluation of an alternative spill control system must take
into consideration how normal operating procedures and equipment
use will affect the system. Buildings may block or divert a waste
spill. Storm sewers may act as pathways for spills to exit the
zone of engineering control. Roads and pathways for vehicles may
change the physical properties of the soil and reroute drainage
patterns.
• Spill Control Structures
Applicants must address how diversionary structures such as dikes,
berms, or retaining walls will affect time of travel. The use of
such structures as a spill control response must be discussed in
the emergency response contingency plan in the next section
(Chapter 3.8).
(3) Presentation of data. The checklist in Figure 3-14 provides a
recommended format for the applicant to follow in presenting the data and
analysis for overland flow. Figure 3-15 provides a format for submitting
calculations of overland flow time of travel.
3.7.2 Unsaturated Zone Flow
This section discusses how to calculate hazardous waste travel time
(TOT) through the unsaturated zone.
(1) Information required. Movement of water and solute through the
unsaturated zone is dynamic and particularly sensitive to the physical
properties of th^ soil. Because water will always move from areas of
high pressure to areas of low pressure and because moisture content is a
manifestation of soil pressure distribution, a complete description of
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I. SCHEMATIC DIAGRAM
Provide a scale representation of the tank system site, showing dimensions of the downgradient zone of engineering
control (AED) slope direction and magnitude (S), minimum distance (Dm), tank placement, tank volume (Vf), and all
natural and artifical land covers or structures and approximate area covered by each.
II. VARIABLES FOR CALCULATIONS
A. Downgradient area of zone of engineering control (Ag^-
B. Volume of tank (m3)
C . Maximum volume of fluid in tank ( Vf - m3 ; show calculation)
D. Waste depth penetration (Dp; show calculation)
E. Maximum precipitation rate (cm/hr) during a 100-year rainstorm.
F . Slope (S; percent) - reference or method
G. Land use (complete table below)
Land Use Area
a.
b.
c.
d.
e.
f-
Percea of Total Land
C Value
H. Weighted runoff coefficient value C (show calculation)
I. Minimum distance (Dm; meters • convert to feet)
J. Overland flow travel time (TOT; show calculation)
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L TYPE OF WASTE
(Information can be obtained from the Source and Tank Charactrzation sections of Variance - See
Chapters 3.2 and 3.3)
A. Number of aboveground tanks in facility
B. Volume of tank (for tanks treated as a group, give volume of of largest tank)
C. Description of hazardous waste stored
1. Amount of solids, liquids and gas
2. Average viscosity of each liquid waste and density of each gas
H. CHARACTERISTIC OF LAND SURFACE
A. Describe soil characteristics within zone of engineering (ZOEC) control
1. Soil types
2. Soil surface conditions (compaction, vegetation, etc.)
B. Describe topographic features
1. Slope within the zone of engineering control
2. Provide topographic map of area showing extent of ZOEC and land features in and
around ZOEC
m. OVERLAND FLOW TRAVEL TIME CALCULATION
(SEE FIGURE 3-14)
IV. DIVERSION EFFECTS
A. Diagram showing
1. Tank system location,
2. The laterial extent of zone of engineering control,
3. Diversion structures,
4. Direction of slope (down gradient), and
S. Other man-made structures (roads, building, storm sewers, etc.)
B. Describe diversion system
L Volume system can hold
2. Materials and/or soils used for the construction of the system
3. If spill control is dependent on travel time or the land surface characteristics, provide
information and data to support the system and include calculations of TOT under worst case
conditions.
4. Estimate release to ground water for all unlined areas that may be exposed to a spill event
Figure 3-15 Travel Time Format
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the soil profile with accurate soil moisture content is indispensable for
deriving accurate TOTs. Several other parameters will affect waste
movement. These Include, but are not limited to:
• Media type;
• Zone thickness;
• Makeup of the soil/sediment/rock column (media column);
• Saturated hydraulic conductivity of soil (Ks>'»
• Porosity/pore-size distribution;
• Soil moisture range (seasonally);
• Organic-carbon-water partition coefficient (KoC);
• Saturated hydraulic conductivity of chemical (KCH);
• Density (chemical and water);
• Viscosity of water and chemical;
• Heterogeneities;
• Depth of seasonal high water table; and
• Fraction clay/organic carbon content in media (retardation factor).
The applicant must be able to provide this information so that EPA
can evaluate the catastrophic release scenario (i.e., the entire tank
volume Is released Instantaneously). It 1s only necessary to compute the
velocity of a waste from a catastrophic release because EPA 1s interested
in how soon the waste can reach the ground water. Waste velocity and TOT
from a catastrophic release will generally be greater than from a
corrosion release. Velocity prediction from a corrosion release is
difficult to model because the initial leakage would be undetectable and
the leakage rate could be highly variable. Modeling the corrosion
release would require the pre-assignment of dimensions of the waste
plunte. These dimensions are sensitive to contaminant and soil specifics,
and erroneous dimensions could invalidate the TOT equations.
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The modeling procedure for the underground in-ground storage tank
will be slightly different from that of the aboveground storage tank. To
model a catastrophic release from an aboveground storage tank, the
effects of overland flow must be computed. As the waste seeps into the
subsurface, waste movement is by saturated or unsaturated flow. With
saturated flow from catastrophic releases, the waste's travel will be
limited only by the medium's characteristics (Its hydraulic
conductivity). Unsaturated flow occurs when the waste's movement is
limited by air pockets within the media.
Only movements of liquid wastes should be modeled. Wastes that have
high vapor pressures could volatilize and thereby reduce waste loading to
the unsaturated zone. However, even on a site-specific basis,
volitalization 1s difficult to quantify. Because the assumption of no
volitalization will still give the same TOT (assuming saturated flow),
volitalization processes and movements of vapors are considered to be
insignificant. This is an admittedly conservative approach since
volitalization will result In some loss, but 1s justified since the
standard for granting a variance is equivalency to secondary containment.
(2) How data are to be used. To obtain all of the physical
parameters needed to calculate TOT for the release scenarios, the
applicant must:
• Perform initial hydrogeological analysis;
• Measure media properties by field analysis;
• Calculate either saturated or unsaturated flow; and
• Correct velocities (when appropriate) for viscosity, density* and
retardation.
(a) Initial hydrogeological analysis. The character of a
hydrogeologic setting from region to region can change rapidly.
Therefore, each tank's unsaturated zone must be analyzed Individually by
a qualified hydrogeologlst. This study should Include stratigraphic and
structural analyses, complete descriptions of each soil type and
thickness, and depth of the high water table.
The hydrogeologist also must determine whether subsurface vertical
flow is a valid assumption and whether heterogeneities (such as highly
fractured sandstone layers or loosely packed material around pipes that
can serve as a conduit for leaking fluids) ex^st that will accelerate
waste velocity. The TOT to both the horizontal and vertical zones of
engineering control must be calculated.
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(b) Measurement of media parameters. To calculate TOT for
catastrophic releases of hazardous wastes into the unsaturated zone field
measurement of soil/sediment/rock properties is suggested.
Because spatial variability of soil types and moisture content are so
high, description of solute movement in the unsaturated zone is complex.
Using computer modeling of TOT shows the high dependency of TOT on soil
type and degree of saturation (Table 3-5; Oarcy's Velocities, Versar
1986). For example, solute in a 90 percent water saturated sand will
travel more than 20 feet per day while solute in a 30 percent water
saturated sand will travel less than 0.1 foot per day — a difference of
two orders of magnitude. The sand itself could have a wide range of
saturated hydraulic conductivity. This is the measure of ease by which a
medium transmits ground water. Figure 3-16 (Freeze & Cherry 1979) shows
that hydraulic conductivities of sand alone span five orders of magnitude.
Thus, an acceptable portrayal of solute movement through the
unsaturated zone necessitates procurement of field data — select soil
properties for each soil horizon.
The unsaturated zone is generally composed of many soil, sediments,
and rock types. Thus, the hydraulic conductivity, water content,
porosity, and pore size distribution must be measured for each media
type. The hydraulic conductivities and water contents should be adjusted
to represent the seasonal high conditions. For modeling of saturated
flow, in the underground release scenario, it is only necessary to
measure saturated hydraulic conductivities. Table 3-6 (Hern and Melancon
1986) lists the accepted locale of measurement and measurement method for
these and other parameters.
If these properties cannot be measured for each soil, then a complete
soil profile showing soil types and their thicknesses for the unsaturated
zone of interest must be described in detail by the hydrogeologist.
Then, using Figure 3-16 (Freeze and Cherry 1979) the highest hydraulic
conductivity value for each soil will be selected. If moisture content
cannot be measured for a particular soil horizon, then a moisture content
of 100 percent is assumed. Along with these measured values, the
equations described later in this section are used to estimate TOT.
(c). Saturated and unsaturated flow equations. A series .of flow
equations is shown in Table 3-7 (McWhorter and Nelson 1980), These have
been developed to estimate TOT quantitatively. These flow equations fall
into two categories, based on release rate into the unsaturated zone.
These equations model unsaturated and saturated flow regimes and apply
when:
3-85
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OSHER Dir. 9483.00
2360s
Table 3-5 Oarcy's Velocity and Time to Ground Water for Various Degrees of Saturation
Degree of
saturation
Saturated
90% sat.
801 sat.
701 sat.
601 sat.
501 sat.
401 sat.
30% sat.
Ft/day
V
sand
35
23.45
14.7
8.4
4.38
1.82
.546
.068
Sand
T days
time to
GU
1.14
1.7
2.72
4.76
9.1
22
73
588
Ft/day
V
silt
sand
3.5
2.345
1.47
.84
.438
.182
.0546
.0068
Silt
sand
T days
time to
GU
11.4
17
27.2
47.6
91
220
730
5880
Ft/day
V
clay
silt
sand
.35
.2345
.147
.084
.0438
.0182
.00546
.00068
Clay
silt
sand
T days
time to
GU
114
170
272
476
910
2200
7300
58800
Ft/day
V
high
clay
soil
.035
.02395
.0147
.0084.
.00438
.00182
.00055
.00007
High
clay
soil
T days
time to
GU
1140
1700
2720
4760
9100
22000
73000
58800
Source: Versar 1986.
3-86
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OSWER Dlr. 9438.00-2
2360s
Table 3-6 Methods of Measurement of Model Parameters or Soil
Properties Relevant to Modeling and Validation
Locale of
Parameter measurement Methodology
1. Static Soil Properties
Porosity Laboratory Water content at zero suction on undisturbed cores
Bulk density Laboratory Coring into known volume or intact clod of soil
Particle size Laboratory Hydrometer or pipette method after sieving
(I Sand, etc.)
Organic carbon Laboratory Walkley-Black chromic acid titrailon method
2. Water Transport and Retention Functions
Saturated
hydraulic conductivity Field Steady state infiltration while monitoring pressure
head
Field Air entry pertneameter
Matric potential- Laboratory Hanging water table and pressure plate
water content function Field Simultaneous tensiometer-neutron probe measurements
Unsaturated
hydraulic conductivity Field Instantaneous profile method
Field Unit gradient methods
Field Air entry permeameter
3. Basic Chemical Properties
Vapor pressure Laboratory Gas saturation
Octanol-water Laboratory Equilibration with octanol-water mix
partition coefficient
4. Time Dependent Parameters Requiring Monitoring
water content Field to Gravimetric determination from soil core
laboratory
Field Neutron probe
Solute concentration Field Solution samplers and soil cores
5. Soil Adsorption Parameters
Distribution Laboratory Batch adsorption to equilibrium
coefficient
Organic carbon Derived Ratio of distribution coefficient to organic
partition coefficient carbon fraction
Source: Hern and Melancon 1986.
3-87
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OSWER Dir. 9438.00-<
2360S
Table 3-7 General Flow Equations Used to Determine Contaminant Flow In the Unsaturated Zone
Unsaturated Flow
TOT, = [(L/q) (n-9r)(q/IC)x/<2-'-3x>]Rc( (3-7.1)
TOT = TOT, + TOT1+1 + TOT1+2 + . . . + TOT1+n (3-7.2)
TOT, = Travel time within a media layer
TOT = Travel time from bottom of tank to water table
L = Distance traveled by wetting front (I.e.. distance
between media layers)
q = Percolation rate (length/time)
n = Soil porosity (dlmensionless)
er = water content below wetting front (dlmensionless)
K = Hydraulic conductivity (length/time)
x = Pore size distribution index (dlmensionless)
Rd = Retardation factor (dlmensionless. see Equation 3-4)
Saturated Flow
TOT = L/(K/ne) (3-7.3)
TOT = Travel time
K = Hydraulic conductivity (length/time)
ne = Effective porosity
Viscosity and Density Corrections
Kch = K(Dc/Dw)(V1w/V1c) (3-7.4)
Kch = Saturated hydraulic conductivity for chemical (length/time)
DC = Density of chemical (gm/cm3)
Ow = Density of water (gin/cm3)
V1w = Viscosity of water
V1c = Viscosity of chemical
1C = Hydraulic conductivity of soil (length/time)
Retardation Factor
Rd = 1.0 •»• (p/n)(Foc)(Koc) (3-7.5)
log KOC = O.S44 log Kow + 1.377 (3-7.6)
Rd = Retardation factor (dlmensionless)
p = Bulk density (gm/cm3)
n = Porosity of Unsaturated zone materials (dlmensionless)
Koc = Organic carbon-water partition coefficient for organic
contaminant (cm3/g)
Foe = Fractional organic carbon in the soil (dlmensionless)
Kow = Octanol/water partition coefficient (dlmensionless)
Source: McWhorter and Nelson, 1980.
3-88
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OSWER Dir. 9483.00-2
Unconsol (dated k it Jt * k
HOCJCS Deoosits _ (darcy) (cm') (cm/s) (m/s) (gal/day/ft')
—
>
2
o
i» *
\l 3
: s c
2 o S
:ll « . c 2
5 « 5 j< 1 " 1
£— _t
8 | §1 2 S
• *• M Q wi yj
•I "" • 11
J, W -
I « 1
1 1 ^
I ll°
J I'i
1 - " e
i5i -ii
S •= o • c 2
ItsS3!
5 s g
= « |
- -
ptO5
-to4
-to3
-to2
-10
- 1
-to-1
-to-2
-to-3
-to-4
-to-5
-IO*
-to-7
-to-*
pip-3
—to-4
-to-5
-to-8
-to-7
-to-8
-to-9
-to-10
-to-11
-to-12
-to-13
-to-14
-to-15
-to-16
r'°2
-10
-t
-to-1
-to-2
-to-3
-to-4
-to-5
-10s*
-to-7
-to-8
-to-9
-to-10
-to-11
-t
-to-1
-to-2
-to-3
-to"1
-to-5
-to-*
-to-7
-to-*
-io-9
-to-10
-to-11
-to-12
-to-13
,-to6
-to5
-IO4
-103
-to2
-to
-1
-to-1
-1Q-2
-to-3
-to-5
-to-5
-to-7
Source: Freeze and Cherry, 1979
Figure 3-16 Range of Hydraulic Conductivities and Permeabilities
3-89
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OSWER Policy Directive
No. 9483.00-2
• The contaminant and interstitial water do not completely fill pore
spaces (unsaturated flow corresponding to release from an
aboveground tank system); and
• The contaminant and interstitial water completely fill pore spaces
(saturated flow corresponding to release either from an
underground or aboveground tank system).
These TOT equations are based on Darcy's flow equation and the
physical properties of the subsurface media such as hydraulic
conductivity and moisture content. These general flow equations grossly
estimate contaminant travel times. Additional corrections to TOT,
dependent on waste density, viscosity, and retardation ability, are
described in a later part of this section. Thus, for each soil,
sediment, or rock type of the unsaturated zone, TOT is calculated.
• Unsaturated Flow Equation
The unsaturated flow equation may be applicable when determining
TOT from aboveground catastrophic releases. Assuming one
dimensional vertical flow of solute which travels as a function of
the velocity of the interstitial pore waters, one can estimate TOT
using Equation 3-3 (see Table 3-7, McWhorter and Nelson 1980):
x/(2+3x)
TOT. - C(L/q)(n-er)(q/K) ]Rrf (3-3)
where
Travel time within a medium layer
Distance between medium layers
Percolation rate (length/time)
Soil porosity (dlmensionless)
Water content below wetting front (dlmensionless)
Hydraulic conductivity (length/time)
Pore-size distribution index (dlmensionless)
Retardation factor (dimensionless).
L
q
n
e
K
r
There is a separate travel time calculated for each media type
(TOT). Overall TOT, or travel time from the tank bottom to the
ground-water table is simply the sum of these travel times
(Equation 3-7.2, Table 3-7, McWhorter and Nelson 1980).
TOT > TOTi + TOT1+1 + TOT1+2
i+n
3-91
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OSWER Pol icy Directive
No. 9483.00-2
TOT
TOT1
TOTU1
TOT1+2
Travel time
Travel time
Travel time
Travel time
Travel time
where
from tank bottom to ground-water table
within first layer
within second layer
within third layer
within successive layers
The parameters for porosity (n), medium water content (9r),
hydraulic conductivity (K), and pore-size distribution index (x)
need to be directly measured for each media type. The leakage
rate or hydraulic loading rate "q" Is a function of the area of
the spill and volume of the tank. It may also include the volume
that soaked into the ground. If "q" is higher than the saturated
hydraulic conductivity of the most conductive layer, then
Equation 3-7.3, Table 3-7, can be substituted above.
• Saturated Flow Equation
If one-dimensional vertical flow is assumed, waste velocity from a
catastrophic release of an underground tank will be solely a
function of each medium's saturated hydraulic conductivity
(Equation 3-7.3, Table 3-7). Only the hydraulic conductivity of
each'soil layer will determine waste velocity.
(d) Correction factors. Because physical/chemical conditions
of the unsaturated zone media and physical/chemical conditions of wastes
differ, modifications must be made to the general flow equations to
enable better prediction of waste velocity. Some of the physical and
chemical factors of the media that affect waste velocity are clay
composition, particle size and sorting cation exchange capacity, organic
matter content, root holes, macropores, soil water content, and bulk soil
density. Among the properties of the waste that affect velocity are
chemical density, viscosity, water solubility, precipitation and
redeposltlon, solution composition and concentration, pH, and soil
temperature.
Because the flow equations were developed assuming the moving liquid
was water, there should be correction factors for each waste component to
allow for property differences. For most of these factors, however,
general equations or correction coefficients have not been developed
because of the complenty of modeling the soil solution. Empirical
relationships have b-en developed for: (1) viscosity and density
differences, and (2) retardation capability.
3-92
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OSWER Pol icy Directive
No. 9483.00-2
Regardless of the TOT measurement approach, it may be necessary to
correct the component velocity for differences in viscosity and density
and effects of retardation. (See Chapter 3.3.1 to determine whether
corrections are applicable for each component of the waste or whether
average corrections will suffice.)
• Viscosity and Density Corrections
TOT and velocity calculations have assumed so far that the
chemical components of the waste travel with the velocity of
interstitial pore water. If the waste's density and/or viscosity
differ from that of water, then it may be necessary to adjust
waste velocity to reflect the waste's own density and viscosity
(see Chapter 3.3.1). Generally as waste density increases, its
hydraulic conductivity increases and its velocity increases.
Conversely, as waste viscosity increases, its hydraulic
conductivity decreases and its velocity decreases.
Velocity adjustments are simple component water density and
viscosity ratios as formulated in Equation 3-7.4 (Table 3-7,
McWhorter and Nelson 1980).
Kch - K(Dc/Dw)(Viw/V1c)
where
Kch » Saturated hydraulic conductivity for chemical
(length/time)
K Hydraulic conductivity (length/time)
DC
Dw
V1w
V1c
Density of chemical (gm/cc)
Density of water (gm/cc)
Viscosity of water
Viscosity of chemical
The Kch term In Equation 3-7.4 (the corrected hydraulic
conductivity for density and viscosity) Is used in lieu of K in
Equations 3-3 and 3-7.3, Table 3-7.
Retardation Capabi1i ty
Because of the conservative estimations used in these TOT
calculations, retardation corrections are minor and need not be
computed. However, for information purposes, a discussion follows
on the potential effects of retardation.
3-93
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OSWER Policy Directive
No. 9483.00-2
Retardation 1s a decrease in the velocity of the solute due to the
availability of soil sites for chemical adhesion. Clays and
organic carbon are the most common retardants; however, because no
definitive protocol has yet been developed for clays (Versar
1986), only retardation from carbon adsorption is discussed.
Because retardation of the waste flow results in slower velocities
and higher TOTs, it is not necessary to calculate for effects of
retardation, though it may be in the applicant's interest to do so.
Hydrophobic (lacking strong affinity for water) or cationic
(positively charged ions) chemical components, if migrating in a
dilute plume, are subject to retardation. Because the
technology-based variance does not allow for any material to reach
the ground water, modeling retardation for concentrated plumes is
not encouraged since some of the materials will get through
without being retarded.
Retardation of organlcs is a mass balance process dependent upon
the concentration gradient of the chemical component. The amount
of chemical component absorbed onto the soil surface will be a
function of the amount of organic carbon In the media (as organic
carbon content Increases, absorption Increases) and the
retardation factor, Rd, of that particular chemical (Equations
3-7.5 and 3-7.6, Table 3-7, McWhorter and Nelson 1980).
R
-------
OSWER Policy Directive
No. 9483.00-2
(3) Presentation of data. The checklists in Figure 3-17 provide the
applicant with a recommended format to follow when assembling data.
3.8 Response Contingency Plan
A technology-based variance assumes by its very nature that the
applicant will be able to control a release before it affects human
health or the environment. To ensure that this is the case, the
applicant will be required to develop and implement an emergency response
contingency plan. This plan will be integrated into any other facility
response plan (such as spill prevention, control, and countermeasure
contingency plans required under the Clean Water Act). The emergency
response plan will address the following areas:
• Overview discussion of the plan and company policy.
• Company responsibilities. Who in the company is responsible for
what actions during a release?
• Alarm mechanisms. How a release will be detected and how its
occurrence will be communicated to management.
• Response mechanism. What release scenarios are possible and what
equipment and resources are available (onsite as well, as from
outside contractors) to deal with them. The plan must.also
discuss the means employed to obviate a response delay due to a
holiday or weekend release.
• Safety Plan. Health and safety problems that may be encountered
by responding personnel and what they should do to protect
themselves.
• Disposal. Provisions that have been made to treat and/or dispose
of contaminated materials.
• Training program. Programs that have been put in place or will be
instituted that ensure personnel will react as predicted in this
plan.
• Financial responsibilities. Costs associated with the worst-case
situation and a showing that the company has ihe financial
resources to cover it.
3-95
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OSWER Policy Directive
No. 9483.00-2
3.8.1 Preparation of Response Plan
(1) Information required. The following Information will need to be
obtained or developed before the plan can be written.
• For aboveground tank systems, a site topography map that will
detail potential flow paths from the tank system to points
offsite. Be sure in preparing this to take into account the full
extent of the piping and ancillary equipment.
• A determination from subsurface investigation of what the zone of
engineering control is and what the estimated travel time of a
release through it will be. These should be readily available
from Chapters 3.5 and 3.7 of the application.
• A list of all available onsite equipment or supplies that may be
used for spill response and a list of any offsite contractors plus
equipment/resources available from them and on what basis (i.e.,
immediate, within 48 hours, etc.).
• If a surface water may be affected, any vulnerable down-stream
areas, Identified on a topographic map and Including phone numbers
of responsible individuals listed (e.g., the phone number of a
downstream water supply-plant with a water intake on the river or
lake).
• A list of disposal sites that will accept the materials from a
spill cleanup.
• Plan for storage prior to disposal.
• A list of the costs for utilizing any offsite resources, including
the probable cost of disposal of cleanup materials.
Additional details on what the plan must contain follow.
(a) Company Responsibilities. The applicant should develop a
response team roster. The roster consists of a list of actions that need
to be taken during a response and a description of the actions. It will
describe in detail who, by job title, is responsible for various aspects
of the response and what they are responsible for. It will lay out a
notification and alert scheme to place the various assignments into a
chain of command. A flow chart would be a useful adjunct to the text.
An example of a partial roster would be as follows:
3-96
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OSWER Dir. 9483.00-2
MEDIA TYPES
1
2
3
4
5
ETC.
I
PROPERTIES
ZONE THICKNESS
HYDRAULJC CONDUCTIVITY
of SOIL (K)
SATURATED HYDRAULIC
CONDUCTIVITY of CHEMICAL ( K CH )
POROSITY
PORE-SIZE DISTRIBUTION
SEASONAL SOIL-
MOISTURE RANGE
DEPTH of SEASONAL
HIGH WATER TABLE
ORGANIC CARBON-WATER
PARTITION COEFFICIENT (KQC)
OCTANOL-WATER
PARTITION COEFFICIENT ( KQW )
DENSITY (CHEMICAL)
DENSITY (WATER)
VISCOSITY (CHEMICAL)
VISCOSITY (WATER)
FRACTION CLAY/ORGANIC
CARBON CONTENT (KQC )
HETEROGENEITIES
MISCELLANEOUS SITE
FACTORS
METHODS of
MEASUREMENTS
METHODS of
CALCULATION
REFERENCES
REMARK
Figure 3-17 Unsaturated Zone Properties Checklist
3-97
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OSWER 01r. 9438.00-2
II. FULLY DESCRIBE THE UNSATURATED ZONE
III. GIVE JUSTIFICATION FOR USING EITHER SATURATED OR
UNSATURATED FLOW EQUATION
IV. SHOW TOT CALCULATIONS (TOT = TIME OF TRAVEL)
V. SHOW ANY CORRECTIONS MADE TO TOT
VI. SHOW FINAL TOT, DEPTH TO MAXIMUM HEIGHT OF SEASONAL HIGH
WATER TABLE AND ANTICIPATED CLEANUP TIME FROM A
CATASTROPHIC RELEASE
Figure 3-17 Unsaturated Zone Properties Checklist (Continued)
3-99
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OSWER Policy Directive
No. 9483.00-2
• Top management
• Plant superintendent
• Cleanup operations supervisor
• Cleanup operations foreman
• Response team personnel, Including any heavy equipment operators
• Techniques and materials evaluator
• Cleanup operations procurement and transportation officer
• Documentation officer
• Labor recruiter
• Government liaison officer
The roster will be more or less complex depending upon the size of
the facility and the anticipated complexity of the operation.
The above descriptions for plant supervisory personnel will .
specifically delineate who is in charge of any offsite contractors that
may be called onto the site to assist in cleanup. It is not necessary to
have a different individual for each job as long as the duties are -not
such that they would require the person to be at two different places at
once.
Alarm Mechanisms. The plan should briefly describe any
automatic alarm mechanisms that are to be employed for detecting leaks.
It should describe In detail how personnel should respond to these alarm
mechanisms, including the reaction to possible false positives, as well
as the precise methods for determining whether a false positive exists.
It should specifically delineate when and what process equipment, if any,
will be shut down if an alarm sounds. The individual responsible for
deciding whether a leak is occurring should be specifically named. There
has to be an individual onsite with this responsibility for each shift.
The plan should describe the in-place system, manual or automatic,
that will inform management if the alarm is not functioning because of
either a malfunction or a power shut-off.
3-101
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OSWER Policy Directive
No. 9483.00-2
(c) Response Actions. Since this is an operational plan,
descriptions of the plant site, underlying hydrology, and any vulnerable
natural resources (such as an adjacent wetland) should be given. The
units to be covered should be described and any expected logistical
problems that may be encountered in emergency operations laid out. An
example might be buried electrical cables.
As required by §§ 264.37, 265.37, 264.52(c), 265.52(c), and
264.l94(c)(l), the tank system owner/operator is to include (or attempt
to include) arrangements made with local authorities (police, fire
departments, contractors, hospitals, and State/local response teams) in a
contingency plan to a potential release. Other factors to consider in
these arrangements are factors that may affect human health and safety.
Tank systems may not always be located in remote areas. Physical
structures such as schools, residential neighborhoods, roads/highways,
recreational areas, businesses and hospitals may border or surround the
tank system. The response plan should provide procedures to prevent or
ensure as little disturbance as possible to these areas and their human
community.
A detailed description of possible release scenarios and response
actions should be given. Each scenario should contain a listing of the
resources needed to contain and/or cleanup the release. From these
descriptions, a master list of resource needs should be developed along
with an identification of where these resources
-------
OSWER Dir. 9438.00-2
2360s
Table 3-3 Example of an Equipment List
Facility Resources
Building 1
30 18 in. sorbent rolls
70 1 ft. sq. bundles sorbent pads
Building 2
3 Dozen rubber rain gear
40 Boxes 9 100 per plastic bags
20 Flat spades
10 Wheelbarrows
200' Sorbent boon
300' Containment boom
10 Acid suits
10 Respirators with acid/organic vapor cartridges
Heavy Equipment
1 0-9 bulldozer
2 Backhoes (20-foot reach)
1 2,000-gallon vacuum truck
Outside Contractors
Joe's Jiffy Rent
200 Hard to Find Lane
Phone:
3 0-9 bulldozers
2 Cranes (40-ton lift capacity)
4 Backhoes (2 with 20-foot reach; two with 40-foot reach)
1 8-51 mobile drill rig
4 Graders
2 Front end loaders
Jack's Environmental
400 Long Way Road
Phone:
2 5,000-gallon vacuum trucks
1000' Oil containment boom
500 Packages sorbent
2 14-foot motor boats
50 55-gallon over-pack barrels
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If an aboveground tank is involved, site maps should be developed
that estimate flow direction and travel time. If there is the
possibility that surface water may inadvertently be contaminated by
failure to contain a release, then a specific set of scenarios should be
developed to address this. Also, if surface water contamination is a
possibility, then a notification procedure may be required by the Clean
Water Act, CERCLA, and/or State law.
Adverse conditions due to weather should also be considered. This
would include problems that may be encountered in the winter, such as
frozen ground, or during the spring, such as heavy rain. The latter is
of particular importance since this would not only make surface handling
of contaminated materials especially difficult, but might also produce
saturated flow in the unsaturated zone. This would lead to decreased
travel time of the contaminant release to the ground water besides
producing considerably more contaminated soil to contend with. In
particular, the plan must address the response during a 25-year 24-hour
rainfall, and a release from the largest tank in the facility, as
discussed in Chapter 3.7.1.
(d) Safety. Since the material in the tank is hazardous by
definition, the plan must address safety. The plan should address
specific health hazards that may be expected to be encountered by
specific personnel. It should describe what protective gear will be
needed, what actions will be taken in the event of an accident, and what
decontamination procedures may be required for both personnel and
equipment. Any personnel whose function may require the use of special
equipment, such as respirators, will need to be trained and certified in
its use. The U.S. EPA Field Standard Operating Procedures for
Preparation of a Site Safety Plan (USEPA 1985) provide general guidelines
on the preparation of a safety plan.
(e-) Disposal. Any release will produce a certain amount of
contaminated materials. The plan should discuss what will be done with
these materials and when. For example, if the facility has the means to
treat or decontaminate soil on site, then the plan must specify where the
soil will be stored until it can be treated and how this area will be
protected from the elements. If the soil and/or any liquids cannot be
handled on site, the plan must specify where and how they will be
shipped. Note that a treatment/disposal facility that accepts liquid
wastes ma^ or may not accept contaminated soils; therefore, the
acceptability of the waste should be verified and alternatives
identified. Also, the question of how the facility intends to
differentiate between "contaminated" and "uncontaminated" materials
should be addressed.
3-104
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OSWER Policy Oirecti-ve
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(f) Training. The contingency plan should delineate the
training needs of facility personnel and how these will be met. One such
need was previously identified: that of personal safety and the use of
safety equipment. Another might be the use of response equipment. Also,
the plan should provide for regularly scheduled drills so that the
employees will become familiar with their response duties. The
regularity of these drills and the amount of staff participation will
depend directly upon how much reliance is placed by management on
facility resources, how vulnerable subsurface and/or offsite water
resources are, and how much dependence is placed on outside contractors.
(g) Financial. In developing the various response and disposal
scenarios, the applicant should estimate the out-of-pocket costs of each
and prepare a discussion of his/her ability to meet them should the need
arise. These costs would include:
• Cost of disposable gear (acid suits, absorbents, gloves, etc.);
• Cost of outside contractors (heavy equipment rental and operators);
• Cost of overtime for facility personnel;
• Cost of disposal of spoils; and
• Income loss due to production equipment shutdown, if applicable.
(2) How data are to be used. The emergency response contingency
plan is a crucial factor in EPA's evaluation of the applicant's ability
to control a release. Therefore, it is essential that the plan be
sufficiently specific, detailed, and comprehensive to guide facility
employees through an actual crisis. EPA will review the plan to ensure
that it supports estimates of response and remediation times. These
times are a critical part of the final analysis described in
Section 3.9. Data presented in the plan must be convincing and
technically and scientifically sound. Failure to provide adequate
support for remediation and response times will result either in the
application's being deemed incomplete or denial of the variance.
(3) Presentation of data. Figure 3-18 outlines a recommended format
for the response plan. The applicant is not restricted to this format
and should not hesitate to expand it if necessary.
3-105
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No. 9483.00-2
3.8.2 Subnrittal of Response Plan
The response plan must be submitted as part of the variance
application. Actual employee manuals are not a necessary part of this
submlttal, but may be Included as an appendix to the application. Also,
existing plans that are required under different programs (e.g., SPCC)
can be submitted as appendices.
3.9 Demonstrate Adequacy of Detection and Remedial Action
The previous sections of this chapter have focused on tank system
design, the zone of engineering control, leak detection devices, time of
detection, response time, waste travel time, and remedial time. In this
section, these elements are used to perform the final and most critical
portion of the technology-based variance demonstration: whether remedial
measures can be implemented and completed prior to the waste releases'
migrating beyond the zone of engineering control. Failure to demonstrate
this adequately would result in a denial of the variance application.
3.9.1 Preparation of Demonstration
(1) Information required. Some of the information required for this
analysis has already been provided in order to complete the earlier
analyses in this chapter. Other information will be obtained from having
completed the various analyses. Cross-references to the corresponding
sections in which such information is to be derived are provided in the
list below.
• Zone of Engineering Control (See Chapter 3.5)
Chapter 3.5 provides Information on how the zone of engineering
control 1s to be defined. Vertical and horizontal distances that
define the zone of engineering control must be submitted for this
analysis, accompanied by a diagram drawn to scale. The diagram
should show neighboring properties and the location of conduits of
lower porosity soils.
• Leak Detection Time (See Chapter 3.6)
The leak detection time of the monitoring system is required for
the analysis described in Chaptr - 3.6, and also draws i-pon
information provided for the analysis in Chapter 3.2. There are
two components to leak detection time. The first, and most
significant, is related to the failure characteristics of the tank
and the lower limit of leak detection of the monitoring device.
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I. LIST OF PERSONNEL TO BE CONTACTED IN THE EVENT OF A RELEASE
II. OVERVIEW OF PLAN
III. COMPANY RESPONSIBILITIES - List what needs to be done and who will do it
IV. DESCRIPTION OF ALARM MECHANISMS - Detail sequence of events if an alarm sounds.
V. DESCRIPTION OF RESPONSE ACTIONS - Describe plant layout, underlying hydrology,
resources to be protected and expected logistical problems and their solution. This section should also include onsite
and offsite response resources. Include actions and arrangements made with local authorities to eliminate or reduce
human health and safety problems.
VI. SAFETY PLAN - Identify expected hazards to response personnel and measures to be taken to midgate them.
VII. DISPOSAL OPTIONS - Identify how and who will treat/dispose of hazardous materials (soils etc.) created
by a release.
VIII. TRAINING — List personnel assigned to response, skills needed for response and training provided to ensure
these skills are obtained.
IX. FINANCIAL - Estimate costs of response to catastrophic release and available resources to meet them.
Figure 3-18 Format for Release Response Plan
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Owners/operators of tank systems for which there is a potential
for corrosion leaks to occur must provide Information on the time
delay required for a leak to grow to the point at which the rate
of leakage is large enough to be detected by the monitoring system.
The second component of leak detection time 1s the time that the
released material takes to travel from the failure point to the
detector.
• Time of Travel'of Released Material (See Chapter 3.7)
Chapter 3.7 provides Information on how the "release migration
time" is calculated. "Release migration time" is the shortest
time for the released material to migrate from the tank system to
the boundary of the zone of engineering control. Depending on
what is the shortest travel time, a horizontal or vertical time of
travel may be required. The vertical time of travel is calculated
based on the time for releases to reach the lower boundary of the
zone of engineering control. The horizontal time of travel can be
either the time for overland flow to the horizontal boundary of
the zone of engineering control or the time for releases to
migrate horizontally through a less permeable layer of the
unsaturated zone to the boundary of the zone of engineering
control.
• Release Response Time (See Chapter 3.8)
Release response time is derived from the analysis to be completed
In Chapter 3.8. The release response time is the sum of (1) the
time between the alarm detecting the leak and human response to
the alarm; (2) the time required to mobilize the equipment and
personnel necessary to conduct the release response; and (3) the
time required to effect the remediation.
In calculating release response time, applicants must take into
account time lost for absence of personnel during weekends,
evenings, and holidays. For example, if a release occurs on a
Saturday and no one is available to respond to an alarm until
Monday, 48 hours must be included in calculating human response
time. If personnel are available, the response plan discussed in
Chapter 3.8 should include details on how personnel are notified
and the approximate time delays that may occur during these
periods.
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(2) How data are to be used. The basic premise of the
technology-based variance Is that complete protection of ground water and
surface water can be provided by means other than secondary containment.
The purpose of this analysis Is to demonstrate that releases from the
subject tank system can be detected and excavated or decontaminated in
sufficient time to prevent migration to the ground water or surface
water. The fundamental consideration, therefore, 1s whether the shortest
time for the release to travel to the boundary of the zone of engineering
control is longer than the time required for detection and remedial
measures.
The demonstration Is made by first calculating the time for detection
and remedial measures. This 1s done by (1) summing the two components of
leak detection time, (2) summing the three components of release response
time, and (3) summing leak detection time and release response time. The
total time is then compared to the shortest time of travel. The
demonstration is adequate if the shortest time of travel is longer than
the sum of leak detection time and release response time.
The demonstration will be considered to be inadequate if (1) it can
be shown that the shortest time of travel is less than the time for
detection and remedial action or (2) there 1s sufficient reason to
believe that undetected releases may migrate beyond the zone of
engineering control.
(3) Presentation of data. Figure 3-19 provides a format for
presentation of the data required for this section. This is not a
"form"; rather, it is a format to guide the presentation of the data so
that there will be consistency In the variance applications. The size of
the sections will vary, but they should be presented in the order shown.
3.9.2 Submlttal of Variance Application
The above analysis Is a critical part of the variance application and
should tie together the analyses that are completed in the other parts of
the application. This portion of the analysis is the final
demonstration, or "proof" that the alternative technology or operating
design can prevent releases from migrating to ground water or surface
water at least as effectively as secondary containment. The burden of
proof for this analysis 1s on the applicant, and the request for a
variance will be denied If the alternative technology or operating design
is not proven to be as effective as secondary containment.
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L ZONE OF ENGINEERING CONTROL
Based on infonnation in Parts V, vn and vm of the variance application, submit diagram drawn
to scale showing vertical and horizontal distances which define the zone of engineering control.
H. LEAK DETECTION TIME
A. Identify lower limit of leak detection of monitoring device
B. Assess time delay required for leaks to reach threshold detection limits
C Specify time required for released material to reach detector
m. TIME OF TRAVEL OF RELEASED MATERIAL
Based on information derived from Part Vn of the variance application, provide the shortest time
for the released material to migrate from the tank system to the boundary of the zone of
engineering control
IV. RELEASE REPONSE TIME
A, Human response to the alarm
Derived from information provided in Part Vm of die variance application; include time lost
due to releases over weekends, evenings, or holidays, if personnel not available or slower to
respond at such times. (For example, if personnel are not able to respond until Monday to an
alarm on a Saturday, 48 hours should be added to the response time.)
B. Identify time required to mobilize equipment and personnel
C. Identify time required for remediation
V. COMPARISON OF RELEASE RESPONSE TIME TO TIME OF
TRAVEL
Describe why the total time to respond to the release, inclusive of remediation, will be less than
the time required for the release to migrate beyond the zone of engineering control.
Figure 3-19 Format and Contents of Demonstration of Sufficiency of
Detection and Response Times
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4.0 REFERENCES
American Petroleum Institute (API). 1986. Cathodlc protection of
underground petroleum storage tanks and piping systems. Publication
1632. 2nd ed. HashIngton, D.C.: American Petroleum Institute.
Eklund, B., et al. 1986. Guidance document for developing performance
standards and certification procedures for out-of-tank petroleum leak
detection devices: Phase I Draft report for vendor survey. Radian Corp.
EPA Contract Ho. 68-02-3994. U.S. Environmental Protection Agency:
Environmental Monitoring Systems Laboratory. June 1986.
Everett, L.G., et al. 1984. Constraints and categories of vadose zone
monitoring devices. Ground Mater Monitoring Review. 4<7):26-32.
Freeze, R.A. and Cherry, J.A. 1979. Groundwater. Englewood CUffs,
N.J.: Prentice-Hall, Inc.
Hern, S.C., Melancon, S.M. 1986. Vadose zone modeling of organic
pollutants. Chelsea, M1ch.: Lewis Publishers, Inc.
Kibler, D.F. 1982. Urban stormwater hydrology. Water Resources
Monograph 7. Washington, .D.C.: American Geophysical Union.
Lyman, W.J., et al. 1982. Handbook of chemical property estimation
methods. New York, N.Y.: McGraw-Hill Book Company.
Marrln, O.L. 1985. Delineation of gasoline hydrocarbons in groundwater
by soil gas analysis. In Proceedings of the 1985 hazardous materials
west conference.
Marrln, O.L. and Thompson, G.M. 1984. Remote detection of volatile
organic contaminants In groundwater via shallow gas sampling. In
Proceedings of the petroleum hydrocarbons and organic chemicals in
groundwater conference.
McWhorter, D.B., and Nelson, J.D. 1980. Seepage in the partially
saturated zone beneath tailings Impoundments. Mining Engineering.
pp. 432-439. April.
National Association of Corrosion Engineers, (NACE). 1985. Recommended
practice-control of external corrosion on underground or submerged
metallic piping systems. NACE Standard RP-01-69. Houston, Texas:
National Association of Corrosion "ngineers. January 1972.
4-1
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OSWER Policy Directive
No. 9483.00-2
Spittler, T.M. 1985. Field measurement of PCB's 1n soil and sediment
using a portable gas chromatograph. Sampling and Monitoring, pp. 105-107.
USEPA. 1983. Vadose zone monitoring for hazardous waste sites. Kaman
Tempo. U.S. Environmental Protection Agency, Office of Research and
Development. EPA Report No. KT-82-018(R). Las Vegas, Nevada: U.S.
Environmental Protection Agency.
USEPA. 1985. Field standard operating procedures for preparation of a
site safety plan"! F.S.O.P. 9. Washington, D.C.: U.S. Environmental
Protection Agency, Office of Emergency and Remedial Response, Hazardous
Response Support Division.
Versar. 1986. Methodology for determining sources of ground-water
contamination. Draft report. Washington, D.C.: U.S. Environmental
Protection Agency, Office of Toxic Substances, Exposure Assessment Branch.
4-2
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APPENDIX A
Information Sources for Environmental and Hydrogeologic Information
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OSWER Policy Directive
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APPENDIX A
Information Sources for Environmental and Hydrogeologlc Information
Federal Agencies
U.S. Environmental Protection Agency, Headquarters (U.S. EPA)
—Office of Water Enforcement and Permits
—Office of Mater Regulation and Standards
—Office of Water Programs Operations
—Office of Drinking Hater
—Office of Ground-Hater Protection
401 M Street, S.W.
Washington, DC 20460
(202) 755-9112
U.S. Geological Survey (U.S.G.S.)
Water Resources Scientific Information Center
425 National Center
Reston, VA 22902
(703) 860-7455
U.S. Department of Agriculture (U.S.D.A.)
—Agricultural Extension Service
—Soil Conservation Service
Washington, DC 20250
(202) 447-2791
Regional EPA Offices
Region I
Water Management Division
John F. Kennedy Federal Building
Boston, MA 02203
(617) 223-7210
Region II
Water Management Division
26 Federal Plaza
New York, NY 10278
(212) 264-2525
Region III
Water Management DivUon
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
Region IV
Water Management Division
345 Courtland Street, NE
Atlanta, Georgia 30365
(404) 881-4727
Region V
Water Division
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000
Region VI
Water Management Division
1201 Elm Street
Chicago, IL 60604
(312) 353-2000
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Regional EPA Offices (cont'd)
Region VII Region IX
Mater Management Division Mater Management Division
726 Minnesota Avenue 215 Fremont Street
Kansas City, KS 66101 San Francisco, CA 94105
(913) 236-2800 (415) 974-8071
Region VIII Region X
Mater Management Division Mater Division
726 Minnesota Avenue 1200 Sixth Avenue
Kansas City, KS 66101 Seattle, MA 98101
(303) 293-1603 (206) 442-5810
Federal and State Agency Contacts
Alabama
Department of Public Health
Environmental Health Administration
Public Mater Supply Division
Montgomery, AL 36130
Mater Improvement Commission
749 State Office Building
Montgomery, AL 36130
U.S. Geological Survey
Hater Resources Division
University of Alabama
Oil & Gas 81dg - Room 202
P. 0. Box V
Tuscaloosa, AL 35486
FTS-229-2957 (205) 752-8104
Geological Survey of Alabama
P. 0. Drawer 0
University, AL 35486
(205) 349-2852
U.S. Soil Conservation Service
State Conservation Office
Wright Building
138 South Gay Street
P. 0. Box 311
Auburn, AL 36830
FTS-534-4535
(202) 821-8070
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Federal and State Agency Contacts (cont'd)
Alaska
Hater Quality and Environmental Sanitation Division
Alaska Department of Environmental Conservation
Pouch 0
Juneau, AK 99811
Division of Forest, Land and Hater Management
Alaska Department of Natural Resources
323 East Fourth
Anchorage, AK 99501
Alaska Division of Geology and Geophysical Surveys
3001 Porcupine Drive
Anchorage, AK 99501
(907) 279-1433
U.S. Soil Conservation Service
State Conservation Office
Suite 129, Professional Building
2221 E. Northern Lights Boulevard
Anchorage, AK 99504
(907)- 276-4246 (FTS & CML)
U.S. Geological Survey
Hater Resources Division
218 E. Street
Anchorage, AK 99501
FTS-399-0150
(907) 271-4138
Ar1zona
Planning Division
Arizona Department of Hater Resources
222 North Central, Suite 850
Phoenix, AZ 85004
Larry D. Fellows
Arizona Bureau of Geology and Mineral Technology
Geological Survey Branch
845 N. Park Avenue
Tucson, AZ 85719
(602) 626-2733
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Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
State Conservation Office
230 N. 1st Avenue
3008 Federal Building
Phoenix, AZ 85025
(602) 261-6711 (FTS & CML)
U.S. Geological Survey
Water Resources Division
Federal Building
301 M. Congress Street
Tucson, AZ 85701
FTS-762-6671
<602) 792-6671
Arkansas
Soil and Mater Conservation Commission
Arkansas Department of Commerce
818 West Capital Avenue, Building A
Little Rock, AR 72202
Arkansas Geological Commission
Vardelle Parham 'Geological Center
3815 W. Roosevelt Road
Little Rock, AR 72204
(501) 371-1488
U.S. Soil Conservation Service
State Conservation Office
Federal Building. Room 5029
700 West Capitol Street
P. 0. Box 2323
Little Rock, AR 72203
FTS-740-5445
(501) 378-5445
U.S. Geological Survey
Water Resources Division
Federal Office Bldg-Room 2301
700 West Capltrl Avenue
Little Rock, AR 72201
FTS-740-6391
(501) 378-6391
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Federal and State Agency Contacts (cont'd)
California
California Department of Hater Resources
P. 0. Box 388
Sacramento, CA 95802
California Division of Mines & Geology
California Department of Conservation
1416 9th St., Room 1341
Sacramento, CA 95814
(916) 445-1923
U.S. Soil Conservation Service
State Conservation Office
2828 Chiles Road
Davis, CA 95616
(916) 758-2200 ext. 210 (FTS & CML)
U.S. Geological Survey
Water Resources Division
855 Oak Grove Avenue
Menlo Part, CA 94025
FTS-467-2326
(415) 323-8111
Colorado
Colorado Mater Resources Division
Department of Natural Resources
1313 Sherman Street
Room 818
Denver, CO 80203
Colorado Mater Quality Division
Department of Health
4210 East 11th Avenue
Denver, CO 80220
Colorado Geological Survey
1313 Sherman St., Room 715
Denver, CO 80203
(303) 839-2611
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Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
Sate Conservation Office
2490 H. 26th Avenue
P. 0. Box 17107
Denver, CO 80217
FTS-327-4275
(303) 837-4275
U.S. Geological Survey
Water Resources Division
Building 53
Denver Federal Center
lakewood, CO 80225
FTS-234-5092
(303) 234-5092
Connecticut
Connecticut Natural Resources Center
Department of Environmental Protection
State Office Buldlng, Room 553
Hartford, CT 06115
Connecticut Geological & Natural History Survey
State Office Building, Room 553
165 Capitol Avenue
Hartford, CT 06115
<203) 566-3540
U.S. Soil Conservation Service
State Conservation Office
Mansfield Professional Park
Route 44A
Storrs, CT 06268
FTS-244-2547/2548
(203) 429-9361/9362
U.S. Geological Survey
Water Resources Division
135 High Street - Room 235
Hartford, CT 06103
FTS-244-2528
(203) 244-2528
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Federal and State Agency Contacts (cont'd)
Delaware
Delaware Department of Natural Resources and Environmental Control
Hater Supply Branch
Edward Tatnall Building
P. 0. Box 1401
Dover, DE 19901
Delaware Geological Survey
University of Delaware
Newark. DE 19711
(302) 738-2833
U.S. Soil Conservation Service
State Conservation Office
Treadway Towers, Suite 2-4
9 East Loockerman Street
FTS-487-5148
(302) 678-0750
U.S. Geological Survey
Water Resources Division
Subd1str1ct-01st. Off1ce/MD
Federal Butldlng - Room 1201
Dover, DE 19901
FTS-487-9128
(302) 734-2506
Florida
Florida Department of Environmental Regulation
Division of Environmental Programs
Groundwater Section
2600 Blair Stone Road
Tallahassee, FL 32301
Florida Bureau of Geology
903 W. Tennessee St.
Tallahassee, FL 32304
(904) 488-4191
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Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
State Conservation Office
Federal Building
P. 0. Box 1208
Gainesville, FL 32602
FTS-946-3871, ext. 100
(904) 377-8732
U.S. Geological Survey
Mater Resources Division
325 John Knox Rd-Su1te F-240
Tallahassee, FL 32303
FTS-946-4251
(904) 386-1118
Georgia
Georgia Department of Natural Resources
Water Protection Branch
270 Washington Street, N.H.
Atlanta. GA 30334
Georgia Department of Natural Resources
Environmental Protection Division
Geological Survey and Mater Resources Section
270 Washington Street, S.W.
Atlanta, GA 30334
Georgia Department of Natural Resources
Geological & Water Resources Division
19 Dr. Martin Luther King, Jr. Drive, S.W.
Atlanta, GA
(404) 656-3214
Soil Conservation Service
State Conservation Office
Federal Building
355 E. Hancock Avenue
P. 0. Box 832
Athens, GA 30603
FTS-2dO-2275
(404) 546-2274
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Federal and State Agency Contacts (cont'd)
U.S. Geological Survey
Hater Resources Division
Suite-B „, J
6481 Peach Tree, Indust. Blvd
Doravllle, GA 30360
FTS-242-4858
(404) 221-4858
Hawal1
Hawaii Division of Water and Land Development
Department of Land and Natural Resources
P. 0. Box 373
Honolulu, HI 96809
(808) 548-7533
U.S. Soil Conservation Service
State Conservation Office
300 Ala Moana Blvd.
Room 4316
P. 0. Box 5004
Honolulu, HI 96850
(808) 546-3165
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Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
State Conservation Office
304 North 8th Street, Room 345
Boise, ID 83702
FTS-554-1601
(208) 384-1601 ext. 1601
U.S. Geological Survey
Mater Resources Division
P. 0. Box 2230
Idaho Falls, ID 83401
FTS-583-2438
(208) 526-2438
Illinois
Illinois Environmental Protection Agency
Public Water Supply Division
2200 Churchill Road
Springfield, IL 62706
Illinois State Hater Survey
605 E. Springfield Avenue
P. 0. Box 5050, Station A
Champaign, IL 61820
Illinois State Geological Survey
121 Natural Resources Building
Urbana, IL 61801
(217) 333-5111
U.S. Soil Conservation Service
State Conservation Office
Federal Building
200 W. Church Street
P. 0. Box 678
Champaign, Illinois 61820
FTS-958-5271
<217) 356-3785
U.S. Geological Survey
Water Resources Division
P. 0. Box 1026
605 N. Nek Street
Champaign, Illinois 61820
FTS-958-5353
(217) 398-5353
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Federal and State Agency Contacts (cont'd)
Indiana
Indiana Department of Natural Resources
Division of Water
608 State Office Building
Indianapolis, IN 46204
Environmental Health
Indiana State Board of Health
1330 W. Michigan Street
Indianapolis, IN 46206
Department of Natural Resources
Indiana Geological Survey
611 North Walnut Grove
Bloomlngton, IN 47401
(812) 337-2862
U.S. Soil Conservation Service
State Conservation Office
Atkinson Square-West Suite 2200
5610 Crawfordsville Road
Indianapolis, IN 46224
FTS-331-6515
(317) 269-3785
U.S. Geological Survey
Water Resources Division
1819 North Merldan Street
Indianapolis, IN 46202
FTS-331-7101
(317) 269-7101
Iowa
Iowa Natural Resources Council
Wallace State Office Building
East 9th and Grand
Des Moines, IA 50319
Iowa Department of Environmental Quality
Division ef Water Supply
Wallace State Office Building
East 9th and Grand
Des Moines, IA 50319
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Federal and State Agency Contacts (cont'd)
Iowa Geological Survey
123 N. Capitol
Iowa City, IA 52242
(319) 338-117.3
U.S. Soil Conservation Service
State Conservation Office
693 Federal Building
210 Walnut Street
Des Moines, IA 50309
(515) 862-4260 (FTS & CML)
U.S. Geological Survey
Water Resources Division
Federal Building - Rm 269
P. 0. Box 1230
Iowa City, IA 52244
FTS-863-6521
(319) 337-4191
Kansas Oil Field and Environmental Geology
Department of Health and Environment
Topeka, KS 66620
State Geological Survey of Kansas
Raymond C. Moore Hall
1930 Ave. A, Campus West
Lawrence, KS 66044
(913) 864-3965
U.S. Soil Conservation Service
State Conservation Office
760 South Broadway
P. 0. Box 600
Salina, KS 67401
FTS-752-4753
(913) 825-9535
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Federal and State Agency Contacts (cont'd)
U.S. Geological Survey
Mater Resources Division
University of Kansas
Campus West
1950 Avenue A
Lawrence, KS 66045
FTS-752-2300
(913) 864-4321
Kentucky
Kentucky Division of Water Resources
Department for Natural Resources and Environmental Protection
950 Leestown Road
Frankfort, KY 40601
Kentucky Division of Water Quality
Department for Natural Resources and Environmental Protection
Capital Plaza Tower, Fifth Floor
Frankfort, KY 40601
Kentucky Geological Survey
University of Kentucky
311 Breckinridge Hall
Lexington, KY 40506
(606) 622-3720
U.S. Soil Conservation Service
State Conservation Office
333 Waller Avenue
Lexington, KY 40504
FTS-355-2749
(606) 233-2749 ext. 2749
U.S. Geological Survey
Water Resources Division
Federal Building - Room 572
600 Federal Place
Louisville, KY 40202
FTS-352-5241
(502) 582-5241
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Federal and State Agency Contacts (cont'd)
Louisiana
Office of Public Works
Louisiana Department of Transportation and Development
1201 Capital Access Road
Baton Rouge, LA 70804
Louisiana Geological Survey
Box G. University Station
Baton Rouge, LA 70893
(504) 342-6754
U.S. Soil Conservation Service
State Conservation Office
3737 Government Street
P. 0. Box 1630
Alexandria, LA 71301
FTS-497-6611
(318) 448-3421
U.S. Geological Survey
Hater Resources Division
6554 Florida Boulevard
Baton Rouge, LA 70896
FTS-687-0281
(504) 389-0281
Maine
Maine Office of Legislative Assistants
State Capital
Augusta, ME 04333
Maine Geological Survey
State Office Bldg., Room 211
Augusta, ME 04330
(207) 289-2801
U.S. Soil Conservation Service
State Conservation Office
USDA Building
University of Maine
Orono, ME 04473
FTS-833-7393
(207) 866-2132/2133
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Federal and State Agency Contacts (cont'd)
U.S. Geological Survey
Water Resources Division
(District Office in Mass.)
26 Ganneston Drive
Augusta, ME 04330
FTS-833-6411
(207) 623-4797
Maryland
Division of Water Supply
Maryland Department of Health and Mental Hygiene
201 W. Preston Street
O'Connor Building
Baltimore, MD 21201
Water Resources Administration
Maryland Department of Natural Resources
Tawes State Office Building
580 Taylor Avenue
Annapolis, MD 21401
Maryland Geological Survey
Merryman Hall
Johns Hopkins University
Baltimore, MD 21218
(301) 235-0771
U.S. Soil Conservation Service
State Conservation Office
Room 522, Hartwick Building
4321 Hartwick Road
College Park, MD 20740
(301) 344-4180 (FTS & CML)
U.S. Geological Survey
Water Resources Division
208 Carroll Building
8600 Lasalle Road
Towson, MD 21204
FTS-922-3311
(301) 828-1535
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Federal and State Agency Contacts (cont'd)
Massachusetts
Massachusetts Department of Environmental Management
Hater Resources Division
100 Cambridge Street
Boston, MA 02202
Mater Resources Commission
Massachusetts Department of Environmental Management
100 Cambridge Street
Boston, MA 02202
Massachusetts Department of Environmental Quality Engineering
Division of Waterways - Room 532
100 Nashua Street
Boston, MA 02114
(617) 727-4793
U.S. Soil Conservation Service
State Conservation Office
29 Cottage Street
Amherst, MA 01002
(413) 549-0650 (FTS & CML)
U.S. Geological Survey
Water Resources Division
150 Causeway St., Suite 1001
Boston, MA 02114
FTS-232-2822
(617) 223-2822
Michigan
Water Quality Division
Michigan Department of Natural Resources
P. 0. Box 30028
Lansing, MI 48909
Michigan Department of Natural Resources
Geological Survey Division
P. 0. Box 30028
Lansing, MT 48909
(517) 373-1256
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Federal and State Agency Contacts (cont'd)
Michigan Department of Public Health
Hater Supply Division
3500 N. Logan
P. 0. Box 30035
Lansing, MI 48909
U.S. Soil Conservation Service
State Conservation Office
1406 South Harrison Road
Room 101
East Lansing, MI 48823
FTS-374-4242
(517) 372-1910 ext. 242
U.S. Geological Survey
Water Resources Division
6520 Mercantiel May - Suite 5
Lansing, MI 48910
FTS-374-1561
(517) 372-1910
Minnesota
Minnesota Department of Natural Resources
Water Division
300 Centennial Building
St. Paul, MN 55155
Minnesota Pollution Control Agency
1935 Hest County Road, B-2
Roseville, MN 55113
Minnesota Health Department
717 Delaware Street, N.E.
Minneapolis, MN 55440
Minnesota Geological Survey
1633 Eustls Street
St. Paul, MN 55108
(612) 373-3372
17
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
State Conservation Office
200 Federal Bldg. & U.S. Courthouse
316 North Robert Street
St. Paul, MN 55101
(612) 725-7675 (FTS & CML)
U.S. Geological Survey
Mater Resources Division
702 Post Office Building
St. Paul, MN 55101
FTS-725-7841
(612) 725-7841
Mississippi
Bureau of Land and Mater Resources
Mississippi Department of Natural Resources
P. 0. Box 10631
Jackson, MS 39209
Mississippi Board of Health
Mississippi Bureau of Environmental Health
Water Supply Division
Jackson, MS 39209
Mississippi Geological, Economic, and Topologlcal Survey
P. 0. Box 4915
Jackson, MS 39216
(601) 354-6228
U.S. Soil Conservation Service
State Conservation Office
Mllner Building, Room 590
210 South Lamar Street
P. 0. Box 610
Jackson, MS 39205
FTS-490-4335
(601) 969-4330
U.S. Geological Survey
Mater Resources Division
Federal Building, Suite 710
100 Mest Capitol Street
Jackson, MS 39201
FTS-490-4600
(601) 969-4600
18
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
Missouri
Missouri Department of Natural Resources
Division of Environmental Quality
Water Supply Program
P. 0. Box 1368
Jefferson City, MO 65102
Missouri State Geological Survey
P. 0. Box 250
Roll a, MO 65401
(314) 364-1752
Missouri Department of Natural Resources
Division of Environmental Quality
Public Drinking Water Program
P. 0. Box 1368
Jefferson City, MO 65102
U.S. Soil Conservation Service
State Conservation Office
555 Vandlver Drive
Columbia, MO 65201
FTS-276-3145
(314) 442-2271 ext 3155
U.S. Geological Survey
Water Resources Division
Mall Stop 200
1400 Independence Road
Roll a, MO 65401
FTS-277-0824
(314) 341-0824
Montana
Montana Water Rights Bureau
32 South Ewlng
Helena, MT 59620
Water Quality Bureau
Montana Department of Health and Environmental Science
Helena, MT 59601
19
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
Montana Bureau of Mines & Geology
Montana College of Mineral Science and Technology
Butte, MT 59701
(406) 792-8321
U.S. Soil Conservation Service
State Conservation Office
Federal Building
P. 0. Box 970
Bozeman, MT 59715
FTS-585-4322
(406) 587-5271 ext. 4322
U.S. Geological Survey
Water Resources Division
Federal Building - Drawer 10076
Helena, MT 59601
FTS-585-5263
(406) 559-5263
Nebraska
Nebraska' Department of Environmental Control
301 Centennial Mall South
P. 0. Box 94877
Lincoln, NE 68509
Nebraska Department of Water Resources
301 Centennial Mall South
f>. 0. Box 94676
Lincoln, NE 68509
Conservation & Survey Division
University of Nebraska
Lincoln, NE 68508
(402) 472-3471
U.S. Soil Conservation Service
State Conservation Center
Federal Building
U.S. Courthouse, Room 345
Lincoln, NE 68508
FTS-541-5300
(402) 471-5301
20
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.-.-. -v--..;--^Yjfm,-.
OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Geological Survey
Mater Resources Division
Federal Building/Courthouse - Room 406
100 Centennial Mall North
Lincoln, NE 68508
FTS-541-5082
(402) 471-5082
Nebraska
Nebraska Department of Environmental Control
301 Centennial Mall South
P: 0. Box 94877
Lincoln, NE 68509
Nebraska Department of Water Resources
301 Centennial Mall South
P. 0. Box 94676
Lincoln, NE 68509
Conservation & Survey Division
University of Nebraska
Lincoln, NE 68508
(402) 472-3471
U.S. Soil Conservation Service
State Conservation Center
Federal Building
U.S. Courthouse, Room 345
Lincoln, NE 68508
FTS-541-5300
(402) 471-5301
U.S. Geological Survey
Mater Resources Division
Federal Building/Courthouse - Room 406
100 Centennial Mall North
Lincoln, NE 68508
FTS-541-5082
(402) 471-5082
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OSkER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
Nevada
State Engineer
Nevada Department of Conservation and Natural Resources
201 South Fall Street
Carson City, NV 89710
Nevada Bureau of Mines & Geology
University of Nevada
Reno, NV 89557
(702) 784-6691
U.S. Son Conservation Service
State Conservation Office
U.S. Post Office Bldg., Rm 308
P. 0. Box 4850
Reno, NV 89505
FTS-470-5304
(702) 784-5304
U.S. Geological Survey
Water Resources Division
Federal Building - Room 227
705 North Plaza Street
Carson City, NV 89701
FTS-470-5911
(702) 882-1388
New Hampshire
New Hampshire Office of State Planning
Division of Water Supply
2 1/2 Beacon Street
Concord, NH 03301
Office of State Geologist
James Hall
University of New Hampshire
Durham, NH 03824
862-1216
22
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
State Conservation Office
Federal Building
Durham, NH 03824
FTS-834-0505
(603) 868-7581
U.S. Geological Survey
Water Resources Division
Subdlstrlct-Dlst. Off./Mass
Federal 81dg - 210
55 Pleasant Street
Concord, NH 03301
FTS-834-4739
(603) 224-7273
New Jersey
New Jersey Department of Environmental Protection
Division of Water Resources
P. 0. Box CN-029
Trenton, NO 08625
New Jersey Bureau of Geology & Topography
P. 0. Box 1390
Trenton, NJ 08625
(609) 292-2576
U.S. Soil Conservation .Service
State Conservation Office
1370 Hamilton Street
P. 0. Box 219
Somerset, NJ 08873
FTS-342-5341
(201) 246-1205 ext. 20
U.S. Geological Survey
Water Resources Division
Federal Bldg. Room 436
402 E. State St.-P.O Box 1238
Trenton, NO 08607
FTS-483-2162
(609) 989-2162
23
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
New Mexico
Hater Resources Division
New Mexico Natural Resources Department
Bataan Memorial Building
Santa Fe, NM 87503
Water Pollution Control Bureau
New Mexico Environmental Improvement Division
P. 0. Box 968
Santa Fe, NM 87503
New Mexico Interstate Stream Commission
Bataan Memorial Building
Santa Fe, NM 87503
New Mexico Bureau of Mines & Mineral Resources
New Mexico Tech
Socorro, NM 87801
(505) 835-5420
U.S. Soil Conservation Service
State Conservation Office
517 Gold Avenue, SH
P. 0. Box 2007
Albuquerque, NM 87103
FTS-474-2173
(505) 766-2173
U.S. Geological Survey
Hater Resources Division
Hestern Bank Building
505 Marquette, NH
Albuquerque, NM 87125
FTS-474-2430
(505) 766-2430
New York
New York Department of Environmental Conservation
Division of Pure Haters
50 Wolf Road
Albany, NY 12233
24
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
New York State Geological Survey
State Education Building
Albany, NY 12234
(518) 474-5816
U.S. Soil Conservation Service
State Conservation Office
U.S. Courthouse & Federal Bldg.
100 S. Clinton Street, Room 771
Syracuse, MY 13260
FTS-950-5494
(315) 423-5493
U.S. Geological Survey
Water Resources Division
236 U.S. Post Office/Courthouse
P. 0. Box 1350
Albany, NY 12201
FTS-562-3107
(518) 472-3107
North Carolina
Division of Environmental Management
North Carolina Department of Natural Resources
Raleigh, NC 27611
North Carolina Department of Natural Resources
and Community Development
P. 0. Box 27687
Raleigh, NC 27611
(919) 733-3833
U.S. Soil Conservation Service
State Conservation Office
310 New Bern Avenue, Federal Bldg., Room 544
P. 0. Box 27307
Raleigh, NC 27611
FTS-672-4210
(919) 755-4165
25
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Geological Survey
Mater Resources Division
Century Station - Room 436
Post Office Building
P. 0. Box 2857
Raleigh, NC 27602
FTS-672-4510
(919) 755-4510
North Dakota
North Dakota
State Mater Commission
900 East Boulevard
Bismarck, ND 58506
Division of Water Supply and Pollution Control
Department of Health
1200 Missouri Avenue
Bismarck, NO 58505
North Dakota Geological Survey
University Station
Grand Forks, ND 58202
(701) J77.7-2231
U.S. Soil Conservation Service
State Conservation Office
Federal Building - Roser Ave. & 3rd
P. 0. Box 1458
Bismarck. ND 58501
FTS-783-4421
(701) 255-4011 ext. 421
U.S. Geological Survey
Water Resources Division
821 E. Interstate Avenue
Bismarck, ND 58501
FTS-783-4601
(701) 255-4011
26
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
Ohio
Ohio Department of Natural Resources
Division of Water
Groundwater Section
Fountain Square, Building D
Columbus, OH 43224
Ohio Division of Geological Survey
Fountain Square, 81dg. 8
Columbus, OH 43224
(614) 466-5344
U.S. Soil Conservation Service
State Conservation Office
200 No. High St., Room 522
Columbus, OH 43215
FTS-943-6962
(614) 469-6785
U.S. Geological Survey
Water Resources Division
975 West Third Avenue
Columbus, OH 43212
FTS-943-5553
(614) 469-5553
Oklahoma
Chief, Planning and Development Division
Oklahoma Water Resources Board
P. 0. Box 53585
N. E. 10th and Stonewall Street
Oklahoma City, OK 78152
Oklahoma Geological Survey
830 Van Vleet Oval, Rm. 163
Norman, OK 73019
(405) 325-3031
27
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Son Conservation SeRvlce
State Conservation Office
Agriculture Building
Farm Road & Brumley Street
Still water. OK 74074
FTS-728-4360
(405) 624-4360
U.S. Geological Survey
Water Resources Division
215 NW 3rd - Room 621
Oklahoma City, OK 73102
FTS-736-4256
(405) 231-4256
Groundwater Section
Oregon Water Resources Department
555 13th Street, N.E.
Salem, OR 97310
Oregon Water Quality Division
P. 0. Box 1760
Portland, OR 97207
State Department of Geology and Mineral Industries
1069 State Office Bldg.
1400 SM Fifth Avenue
Portland, OR 97201
(503) 229-5580
U.S. Soil Conservation Service
State Conservation Office
Federal Office Building
1220 SH 3rd Avenue
Portland, OR 97209
FTS-423-2751
(503) 221-2751
28
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Geological Survey
Mater Resources Division
P. 0. Box 3202
Shlp-830 NE Holladay St., 97232
Portland, OR 97208
FTS-429-5242
(503) 231-5242
Pennsylvania
Pennsylvania Department of Natural Resources
Bureau of Mater Quality Management
Box 1467
Harrlsburg, PA 17120
Pennsylvania Bureau of Topography and Geological Survey
Dept. of Environmental Resources
P. 0. Box 2357
Harrlsburg, PA 17120
(717) 787-2169
U.S. Soil Conservation Service
State Conservation Office
Federal Bldg. & Courthouse
Box 985 Federal Square Station
Harrlsburg, PA 17108
FTS-590-2202
(717) 732-4403
U.S. Geological Survey
Mater Resources Division
Federal Bldg. - 4th Floor
Harrlsburg, PA 17108
FTS-590-4514
(717) 782-4514
Puerto R1co
Director
Servldo Geologlco de P. R.
Dept. de Recursos Naturales
Apartado 5887, Puerto de Tlerra
San Juan, PR 00906
(809) 722-3142
29
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... .r...l--,'_a, ifr. L^Jf. S3 .a*I2Jf±. -.^.... ^
OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
State Conservation Office
Federal Office Bldg. Room 633
Mail: GPO Box 4868
Puerto R1co, San Juan 00936
Hato Rey, PR 00918
(809) 753-4206
U.S. Geological Survey
Mater Resources Division
Building 652, Ft. Buchanan
G.P.O. Box 4424
San Juan, PR 00936
FTS-967-1221
(809) 783-4660
Rhode Island
Rhode Island
Water Resources Board
P. 0. Box 2772
Prov1dence..RI 02907
Rhode Island
Assoc. State Geologist for Marine Affairs
Graduate School of Oceanography
Kingston, RI 02881
U.S. Soil Conservation Service
State Conservation Office
46 Quaker Lane
Nest Warwick, RI 02893
(401) 828-1300
U.S. Geological Survey
Mater Resources Division
(District Office 1n Mass.)
Federal Bldg. & U.S. Post Office
Room 224
Providence, RI 02903
FTS-838-4655
(401) 528-4655
30
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
South Carolina
South Carolina Hater Resources Commission
Division of Hydrology
3830 Forest Drive
P. 0. Box 4515
Columbia, SC 29240
South Carolina Geological Survey
State Development Board
Harbison Forest Road
Columbia, SC 29210
(803) 758-6431
U.S. Soil Conservation Service
State Conservation Office
240 Stonerldge Drive
Columbia, SC 29210
FTS-677-5681
(803) 765-5681
U.S. Geological Survey
Water Resources Division
Strom Thurmond Federal Bldg.
1835 Assembly St., Suite 658
Columbia, SC 29201
FTS-677-5966
(803) 765-5966
South Dakota
South Dakota Mater and Natural Resources
Joe Foss Building
Pierre, SD 57501
South Dakota State Geological Survey
Science Center
University of South Dakota
VermllHon, SD 57069
(605) 624-4471
31
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
State Conservation Office
Federal Building, 200 4th St., S.W.
P.O. Box 1357
Huron, SD 57350
FTS - 782-2333
(605) 352-8651
U.S. Geological Survey
Water Resources Division
Federal 81dg. - Room 308
200 4th St., S.W.
Huron, SD 57350
FTS - 782-2258
(605) 352-8651
Tennessee
Tennessee Department of Public Health
Bureau of Environmental Health
Division of Water Quality Control
Nashville, TN 37220
Department of Conservation
Division of Water Resources
4721 Trousdale Avenue
Nashville, TN 37220
Tennessee Department of Conservation
Division of Geology
G-5 State Office Building
Nashville, TN 37219
(615) 741-2726
U.S. Soil Conservation Service
State Conservation Office
675 U.S. Courthouse
Nashville, TN 37203
FTS - 852-5471
(615) 749-5471
32
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Geological Survey
Mater Resources Division
U.S. Federal Bu1ldlng-A-413
Nashville, TN 37203
FTS - 852-5424
(615) 251-5424
Texas
Texas Department of Water Resources
Box 13087, Capital Station
Austin, TX 78711
Texas Bureau of Economic Geology
University Station, Box X
Austin, TX 78712
(512) 471-1534
U.S. Soil Conservation Service
State Conservation Office
W. R. Poage Federal Building
Temple, TX 76501
FTS - 736-1214
(817) 773-1711 ext. 331
U.S. Geological Survey
Water Resources Division
Federal Building - 649
300 East 8th Street
Austin, TX 78701
FTS - 734-5766
(512) 397-5766
Utah
State Engineer
Utah Department of Natural Resources
231 East 400 South
Salt Lake City, UT 84111
Utah Geological & Mineral Survey
606 Black Hawk Hay
Salt Lake City, UT 84108
(801) 581-6831
33
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
State Conservation Office
4012 Federal Bldg. - 125 S. State St.
Salt Lake City, UT 84138
FTS - 588-5050
(801) 524-5051
U.S. Geological Survey
Water Resources Division
Administration Bldg. - 1016
1745 West 1700 South
Salt Lake City, UT 84104
FTS - 588-5663
(801) 524-5663
Vermont
Vermont Agency of Environmental Conservation
State Office Building
5 Court Street
Montpeller, VT 05602
(802) 828-3357
U.S. Soil Conservation Service
State Conservation Office
1 Burlington Square, Suite 205
Burlington, VT 05401
FTS - 832-6794
(802) 862-6501 ext. 6261
U.S. Geological Survey
Water Resources Division
(District Office In Mass.)
U.S. Post Office/Courthouse
Rooms 330B and 330C
Montpeller, VT 05602
FTS - 832-4479
(802) 229-4500
34
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
Virginia
Virginia State Mater Control Board
P.O. Box 11143
2111 Hamilton Street
Richmond, VA 23230
Bureau of Mater Supply Engineering
State Health Department
109 Governor's Street
Richmond, VA 23219
Virginia Division of Mineral Resources
P.O. Box 3667
Charlottesvllle, VA 22903
(804) 293-5121
U.S. Soil Conservation Service
State Conservation Office
Federal Bldg., Room 9201
400 N. 8th Street - P.O. Box 10026
Richmond, VA 23240
FTS - 925-2457 "
(804) 782-2457
U.S. Geological Survey
Mater Resources Division
200 Mest Grace St. - Room 304
Richmond, VA 23220
FTS - 925-2427
(804) 771-2427
Washington
Washington Department of Ecology
Office of Mater Programs
Mater Resources Management
Olympla, MA 98504
Washington Dept. of Natural Resources
Geological & Earth Resources Division
Olympla, MA 98504
(206) 753-6183
35
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
State Conservation Office
360 U.S. Courthouse
W. 920 Riverside Avenue
Spokane, NA 99201
FTS - 439-3711
(509) 456-3711
U.S. Geological Survey
Water Resources Division
1201 Pacific Ave - Suite 600
Tacoma, MA 98402
FTS - 390-6510
(206) 593-6510
West Virginia
West Virginia Department of Natural Resources
Division of Water Resources
1201 Greenbrler
Charleston, WV 25311
West Virginia Geological & Economic Survey
P.O. Box 879
Morgantown, WV 26505
(304) 292-6331
U.S. Soil Conservation Service
State Conservation Office
75 High Street, P.O. Box 865
Morgantown, WV 26505
FTS - 923-7151
(304) 599-7151
U.S. Geological Survey
Water Resources Division
Federal Bu1ld1ng/U.S. Courthouse
500 Quarrler St., East-Room 3017
Charleston, WV 25301
FTS - 924-1300
(304) 343-6181
36
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
Wisconsin
Bureau of Mater Management
Wisconsin Department of Natural Resources
P.O. Box 7921
Madison, WI 53707
Wisconsin Geological & Natural History Survey
1815 University Ave.
Madison, WI 53706
(608) 262-1705
U.S. Soil Conservation Service
State Conservation Office
4601 Hammers ley Road
Madison, WI 53711
FTS - 364-5351
(608) 252-5351
U.S. Geological Survey
Water Resources Division
1815 University Building
Madison, WI 53706
FTS - 262-2488
(608) 262-2488
Wyomlng
Department of Environmental Quality
Water Quality Division
401 West 19th Street
Cheyenne, WY 82002
State Engineer
Barrett Building
Cheyenne. WY 32002
Wyoming Geological Survey
Box 3008, University Station
Laramle, WY 82071
(307) 742-2054
37
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OSWER Policy Directive
No. 9483.00-2
Federal and State Agency Contacts (cont'd)
U.S. Soil Conservation Service
State Conservation Office
Federal Office Bldg, P.O. Box 2440
Casper, MY 82601
FTS - 328-5201
(307) 265-5550 ext. 3217
U.S. Geological Survey
Hater Resources Division
P.O. Box 1125
J. C. O'Mahoney Federal Center
2120 Capitol Avenue - Room 5017
Cheyenne, WY 82001
FTS - 328-2153
<307) 778-2220
38
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APPENDIX 8
Full Text of July 14, 1986, Standards
for Hazardous Waste Storage and Treatment
Tank Systems and Generators and
August 15, 1986, Corrections
(51 FR 25471-25486)
(51 FR 29430-29431)
-------
Federal Register / Vol. 51. No. 134 / Monday, July 14. 1986 / Rules and Regulations 25471
1. The authority citation for Part 260 is
revised to read aa follows:
Authority: SMS. 1006.2002(a). 3001 through
3007,3010,3014.3015.3017.3018. and 3019 of
the Solid Waste Disposal Act as amended by
the Resource Conservation and Recovery Act
of 1978. as amended (42 U.S.C. 8909.OBlZfa).
6821 through 6927.6830. 8094.8834 8937. 6030.
and 8939].
2. Section 280.10 is amended by
adding the following ttrma and
definitions in alphabetical order:
§280.10 Definitions.
* • • • •
"Aboveground tank" means a device
meeting the definition of "tank" in
S 280.10 and that is situated in such a
way that the entire surface area of the
tank is completely above the plane of
the adjacent surrounding surface and
the entire surface ana of the tank
[including the.tank bottom) is able to be
visually inspected.
• • • • •
"Ancillary equipment" means any
device including, but not limited to, such
devices as piping, fittings, flanges.
valves, and pumps, that is used to
distribute, meter, or control the flow of
hazardous waste front its point of
generation to a storage or treatment
tank(s), between hazardous waste
storage and treatment tanks to a point of
disposal onsite. or to a point of shipment
for disposal off-site.
• * • • •
"Component" means either the tank or
ancillary equipment of a tank system.
* • • • •
"Corrosion expert" means a person
who. by reason of his knowledge of the
physical sciences and the principles of
engineering and mathematics, acquired
by e professional education and related
practical experience, is qualified to
engage in the practice of corrosion
control on buried or submerged metal
piping systems and metal tanks. Such a
pet sun must be certified as being
qualified by the National Association of
Corrosion Engineers (NACE) or be a
registered professional engineer who
has certification or licensing that
includes education and experience in
corrosion control on buried or
submerged metal piping systems and
metal tanks.
• • • # •
"Existing tank system" or "existing
component" means a tank system or
component that is used for the storage
or treatment of hazardous waste and
that is in operation, or for which
installation has commenced on or prior
to July 14.1986. Installation will be
considered to have commenced if the
owner or operator has obtained all
Federal. State, and local approvals or
permits necessary to begin physical
construction of the site or installation of
the tank system and if either (1) a
continuous on-site physical construction
or installation program has begun, or (2)
the owner or operator has entered into
contractual obligations which cannot
be canceled or modified without
substantial loss—far physical
construction of the site or installation of
the tank system to be completed within
a reasonable time.
"Ingronnd tank" means e device
meeting tbedefinition of "tank" in
J 280.10 whereby • portion of the tank
weilfr situated to any degree-within the
ground, thereby preventing visual
inspection of that external surface area
of the **nJk thai is in *hif ground.
"Installation inspectt
person who. by reason of his knowledge
of the physical sciences and the
principles of m\fttmmtiu^ acquired by a
professional education »«"t related
practical experience, is qualified to
supervise die in«taiiaHnn of tank
systems.
'Teak-detection system" means a
system capable of detecting the failure
of either the primary or secondary
containment structure or the presence of
a release of hazardous waste or
accumulated liquid in the secondary
containment structure. Such a system
must employ operational controls (e-gM
daily visual inspections for releases into
the secondary containment system of
aboveground tanks) or consist of an
interstitial monitoring device designed
to detect continuously and
automatically the> failure of the primary
or secondary containment structure or
me presence of a release of hazardous
waste into the secondary containment
structure.
• « « « •
"New tank system" or "new tank
component" means a tank system or
component that will be used for the
storage or treatment of hazardous waste
and for which installation has
commenced after July 14,1986; except.
however, for purposes of S 284.193(g}(2}
and ) 265.193(g)(2), a new tank system is
one for which construction commences
after July 14.1988. (See .iso "existing
tank system."}
"Onground tank" means a device
meeting the definition of "tank" in
5 260.10 and that is situated in such a
way that the bottom of the tank is on the
same level as the adjacent surrounding
surface so that the external tank bottom
cannot be visually inspected.
* • * * *
"Sump" means any pit or reservoir
that meets the definition of tank and
those troughs/trenches connected to it
that serves to collect hazardous waste
for transport to hazardous waste
storage, treatment, or disposal facilities.
'Tank system" means a hazardous
waste storage or treatment tank and its
associated ancillary equipment and
containment system.
* * • • •
"Underground tank" means a device
meeting the definition of "tank" hi
$ 200.10 whose entire surface area is
totally below the surface of and covered
by the ground.
• • • • •
"Unnt-for use tank system" means a
tank system that has been determined
through an integrity assessment or other
inspection to be no longer capable of
storing or treating hazardous waste
without posing a threat of release of
hazardous waste to the environment
• » • • *
"Zone of engineering control" means
an area under the control of the owner/
operator that, upon detection of a
hazardous waste release, can be readily
cleaned up prior to the release of
hazardous waste or hazardous
constituents to ground water or surface
water.
PART »1—IDENTIFICATION AND
LISTING OF HAZARDOUS WASTE
3. The authority citation for Part 261
continues to read as follows:
Authority: Sees. 1008.2002(a). 3001. and
3002 of the Solid Waste Disposal Act. u
amended by the Resource Conservation and
Recovery Act of 1978. u amended (42 U-SJi
8805. 8812(8). 6921. and 6922).
4. Section 261.4 is amended by adding
paragraph (a)(6) to read as follows:
5281.4 Exclusions.
(a) * * '
(8) Secondary materials that are
reclaimed and returned to the original
process or processes in which they were
generated where they are reused in the
production process provided:
(i) Only tank storage is involved, and
the entire process through completion of
reclamation is closed by being entirely
connected with pipes or other
comparable enclosed means of
conveyance:
(ii) Reclamation does not involve
controlled flame combustion (such aa
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25472 Federal Register / VoL 51. No. 134 / Monday. July 14. 1986 / Rules and Regulations
occurs in boilers, industrial furnaces, or
incinerators);
(Hi) The secondary materials are
never accumulated in such tanks for
over twelve months without being
reclaimed; and
(Iv) The reclaimed material is not used
to produce a fuel or used to produce
products that an used in a manner
constituting disposal.
PART 282—STANDARDS APPLICABLE
TO GENERATORS OF HAZARDOUS
WASTE
40 CFR Part 282 is amended as
follows:
5. The authority citation for Part 282 is
revised to read as follows:
Authority: Sees. 1006.2002.300t 3002.3003.
3004.3005. aad 3017 of the Solid Waste
OUposai Act as amended by the Resource
Conservation and Recovery Act of 1978. as
amended (42 U3.C, 8808. W12,6822.9823,
8824.8023. and 0937).
6. Section 282J4 is amended by
revising paragraphs (a)(l) and (d)(2). by
redeaignating existing paragraphs (d}(3)
and (d](4) as (d)(4) and (d)(5).
respectively, and by adding a new
paragraph (d](3). as follows:
J262J4 Aeewnmadonmiw.
(a) Except as provided in paragraphs
(d). (e). and (f) of this section, a
generator may accumulate hazardous
waste on-site for 9O days or less without
a permit or without having interim
status, provided that
(1) The waste is placed in containers
and me generator complies with Subpart
I of 40 CFR Part 285, or the waste is
placed in tanks and the generator
complies with Subpart J of 40 CFR Part
285. except J285,197(c), and 328&200. In
addition, such a generator is exempt
from all the requirements in Subparts C
and H of 40 CFR Part 285, except for
S 285.111 and S 283.114.
• * * * •
(d)' ' •
(2) The generator complies with the
requirements of Subpart I of Part 285.
except S 265.178;
(3) The generator complies with the
requirements of } 265.201 in Subpart J of
Part 285:
PART 264—STANDARDS POP
OWNERS AND OPERATORS OF
HAZARDOUS WASTE TREATMENT,
STORAGE, AND DISPOSAL
FACILITIES
40 CFR Part 284 is amended as
follows:
7. The Authority citation for Part 284
is revised to read as follows:
Authority: SMS. 1006.2002.3004. and 3005
of the Solid Waste Disposal Act at amended
by the Resource Conservation and Recovery
Act of 1979. as amended (42 US.C. 8903,
9912(a). 9924. and 9829).
8. The Table of Contents and heading
of Part 284, Subpart J—Tanks, is revised
to read as fellows:
Subpart J—Tank Systems
Sea,
264.190 Applicability.
294.191 Assessment of existing tank
tystaB'i integrity*
264492 Design and installation of new tank
systems or components.
294.193 Containment and detection of
releases.
264.194 General operating requirements.
284.195 Inspection*.
264.196 Response to leaks or tpills and
disposition of hiking or unfit-for-use
tank systems.
264J97%» Closure and post-ciosurs care.
264.196 Special requirement* for ignitable or
reactive wastes.
264.199 Special requirements for
incompatible wastes.
• • • • •
9. Section 264.15 is amended by
revising paragraph (b)(4) to read as
follows:
$264.15 Gs
(4) The frequency of inspection may
vary for the items on the schedule.
However, it should be based on the rate
of possible deterioration of the
equipment and die probability of an
environmental or human health incident
if the deterioration or malfunction of
any operator error goes undetected
between inspections. Areas subject to
spills, such as loading and unloading
areas, must be inspected daily when in
use. At a minimum, the inspection
schedule must include the terms and
frequencies called for in Ji 264.174,
284.193. 284.198. 264.226, 284.253, 284JB4.
264.303. and 264.347. where applicable.
* • ft » *
10. Section 284.73 is amended by
revising paragraph (b)(6) to read as
follows:
} 264.73 Operating record.
• • • • •
(b) *' '
(6) Monitoring, testing, or analytical
data where required by Subpart F and
53 264.191. 264.193. 264.195. 264.228.
264.253. 264.254. 284.278. 264.278. 284.280.
264.303. 264.309. and 284.347.
11. Section 284.110 is amended by
adding a new paragraph (b)(3) to read as
follows:
§ 264.110 Applicability.
* * « * •
(b) * * •
(3) Tank systems that are required
under S 284.197 to meet the requirements
for landfills.
12, Section 264.140 is amended by
adding a new paragraph (b)(3) to read as
follows:
J 284.140 Applicability.
* • * * *
(W'' "
(3) Tank systems that are required
under i 264.197 to meet the requirements
for landfills.
**•••
13. The Subpart J—Tank Systems
requirements are amended by revising
the Subpart as follows:
Subpart 4—Tank Systems
8 264.190 Applicability.
The requirements of this Subpart.
apply to owners and operators of
facilities that use tank systems for
storing or treating hazardous waste
except as otherwise provided in
paragraphs (a) and (b) of this section or
in 1284.1 of this part.
[a] Tanks that are used to store or
treat hazardous waste which contains
no free liquids and ore situated inside a
building with an irapermeaLie floor are
exempted from the requirements in
5 264.193. To demonstrate the absence
or presence of free liquids in the stored/
treated waste. EPA Method 9095 (Paint
Filter Liquids Test) as described in 'Test
Methods for Evaluating Solid Wastes.
Physical/Chemical Methods" (EPA
Publication No. SW-846) must be used.
(b) Tanks, including sumps, as defined
in $ 260.10. that serve as part of a
secondary containment system to collect
or contain releases of hazardous wastes
are exempted from the requirements in
§ 284 193 of this subpart.
(Information collection requirement
contained in paragraph (a) was approved by
the Office of Management and Budget under
control number 205O-0050.J
§ 264.191 Assessment of existing tank
system's Integrity.
(a) For each existing tank system that
does not have secondary containment
meeting the requirements of § 284.193.
the owner or operator must determine
that the tank system is not leaking or is
unfit for use. Except as provided in
paragraph (c) of this section, the owner
or operator must obtain and keep on file
at the facility a written assessment
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Federal Register / Vol. 51. No. 134 / Monday. July 14. 1986 / Rules and Regulations
reviewed and certified by an
independent qualified registered
professional engineer, in accordance
with 5 270.11(4). that attests to the tank
system's integrity by January 12.1988.
(b) This assessment must determine
that the tank system is adequately
designed and ha* sufficient structural
strength and competibiltty with the
waste(s) to be stored or treated, to
ensure that Kwffl not collapee. rupture.
OT faff, /»» * minimum, rtito mMamMtit
must consider the foDowing:
(1) Design standard(s). if available;
according to which the tank and
ancillary equipment were constructed;
(2) Hazardous characteristics of the
waste(s) that have been and wiB be
handled:
(3) Brifrt"g corrosion protection
measures;
(4) Documented age of the tank
system, if available (otherwise, an
estimate of the age): and
(5) Results of a leak test internal
inspection, or other tank integrity
examination such that
(i) For non-enterable underground
tanks, the assessment must include a
leak teat that is capable of taking into
account the effects of temperature
variations, tank end deflection, vapor
pockets, and high water table effects.
and
(ii) For other than non-enterable
underground tanks and for ancillary
equipment this assessment must include
either a leak teat aa described above, or
other integrity examination, that is
certified by an independent qualified.
registered professional engineer in
accordance with i ZTail(d). that
addresses crack*, leaks, common, and
erosion.
§a«Atta .
tanfc systems or components.
(a) Owners or operators of new tank
systems or components must obtain and
submit to the Regional Administrator, at
time of submrttal of Part B information.
a written assessment ie»ia»ed and
certified by an independent qualified
legfateied professional engineer, in
accordance with I Z70.11(d). attesting
that the tank system has sufficient
structural integrity and is acceptable for
the storing and trea
of new (NACE) standard. "Re
ided Practice
[No**—Them
AoMricaaPeln
described (nth*
Publication G«rid« for in»p«ctiaaa Structure to soil potential:
(F) Influence of nearby underground
metal strectures (e.g» piping);
(G) Existence of stray electric current;
(H) lfrdTt<"g corrosion-protection
measure* (e.g» coating, cathodic
protection), and
(ii) The type and degree of external
corrosion protection that are needed to
ensure the integrity of the tank system
during the use of the tank system or
component consisting of one-or more of
the following:
(A) Corrosion-resistant materials of
construction such as special alloys.
fiberglass reinforced plastic etc.:
(B) Corrosion-resistant coating (such
as epoxy. fiberglass, etc.) with cathodic
protection (e.g~ impressed current or
sacrificial anodes); and
(C) Electrical isolation devices such as
insulating joints, flanges, etc.
[Note,—The practices described in the
National Association of Corrosion Engineers
inntrfbf stCToiMMu. .»«««*•••••«»«•———
(RP-02-aSr—Control of External Corrosion on
Metallic Boned. Partially Buried, or
Submerged Liquid Storage Systems." and the
American Petroleum Institute (API]
Publication i«*?t "Cathodic Protection of
Underground Petroleum Storage Tanks and
Piping Systems.* may be used, where
applicable, as guidelines in providing
corrosion protection for tank systems.)
(4) For underground tank system
components that are likely to be
adversely affected by vehicular traffic, a
determination of design or operational
measures that will protect the tank
system again*! potential damage; and
(5) Design considerations to ensure
that
(i) Tank foundations will maintain the
load of a full tank;
(ii) Tank system* win be anchored to
prevent flotation or dislodgment where
the tank system is placed in a saturated
zone, or is located within a seismic fault
zone subject to the standards of
S 284.18(a); and
(iii) Tank system* will withstand the
effect* of frost heave.
(b) The owner or operator of a new
tank system must ensure that proper
handling procedures are adhered to in
order to prevent damage to the system
during installation. Prior to covering,
enclosing, or placing a new tank system
• or component in use. an independent
qualified installation inspector or an
independent qualified, registered
professional engineer, either of whom is
trained and experienced in the proper
installation of tank systems or
component must inspect the system for
the presence of any of the following
items:
(1) Weld breaks;
(21 Punctures;
(3) Scrapes of protective coatings:
(4) Cracks;
(5) Corrosion;
(6) Other structural damage or
inadequate construction/installation.
All discrepancies must be remedied
before die tank system is covered.
enclosed, or placed in use.
fc) New tank systems or components
that are placed underground and that
are backfilled must be provided with a
backfill material that is a noncorrosive.
porous, homogeneous substance and
that is installed so that the backfill is
placed completely around the tank and
compacted to ensure that the tank and
piping are fully and uniformly
supported.
(d) All new tanks and ancillary
equipment must be tested for tightness
prior to being covered, enclosed, or
placed in use. if a tank system is found
not to be tight, all repairs necessary to
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25474 Federal Register / Vol 51. No. 134 / Monday. July 14. 1986 / Rules and Regulations
remedy the leak(s) in the system must
be performed prior to the tank system
being covered, enclosed or placed into
(e) Ancillary equipment must be
supported and protected against
physical damage and excessive stress-
due to settlement vibration, expansion.
or contraction.
(Nottb—The piping system installation
procedures described in American Petroleum
Institute (API) Publication 1615 (November
19791. "Installation of Underground Petroleum
Storage Systems." or ANSI Standard 831J.
-Petroleum Refinery Piping." and ANSI
Standard B31.4 "Liquid Petroleum
Transportation Piping System." may be used.
where applicable, as guidelines for proper
installation of piping systems.)
(f) The owner or operator must
provide the type and degree of corrosion
protection recommended by an
independent corrosion expert, baaed on
the information provided under
paragraph (a)(3) of this section, or other
corrosion protection if the Regional
Administrator believes other corrosion
protection is necessary to ensure the
integrity of the tank system during use
of the tank system. The installation of a
corrosion protection system that is field'
fabricated must be supervised by an
independent corrosion expert to ensure
proper installation.
(g) The owner or operator must obtain
and keep on file at the facility written
statements by those persons required to
certify the design of the tank system and
supervise the installation of the tank
system in accordance with the
requirements of paragraphs (b) through
(f) of this section, that attest that the
tank system was properly designed and
installed and that repairs, pursuant to
paragraphs (b) and (d) of this section.
were performed These written
statements must also include the
certification statement as required in
S 270.1l(d) of this Chapter.
(Information collection requirements
contained in paragraphs (a) and (g) were
approved by the Office of Management and
Budget under control number 2050-0050.)
§264.193 Containment and detection o<
(a) In order to prevent the release of
hazardous waste or hazardous
constituents to the environment
secondary containment that meets the
requirements of this section must be
provided (except as provided in
paragraphs (f) and (g) of this section):
(1) For all new tank systems or
components, prior to their being put into
service:
(2) For all existing tank systems used
to store or treat EPA Hazardous Waste
Nos. F020. F021. F022. F023. F026. and
F027, within two yean after January 12.
1987:
(3) For those existing tank systems of
known and documented age. within two
yean after January 12.1987 or when the
tank system has reached IS yean of age.
whichever cornea later: and
(4) For those existing tank system* for
which the age cannot be) documented.
within eight yean of January 12.1987;
but if the age of the facility is greater
than seven-years, secondary
containment must be provided by the .
time the facility reaches IS yean of age.
or within two yean of January 12.1987.
whichever comes latex: and
(S) For tank systems that store or treat
material* that become hazardous-wastes
subsequent to January 12.1987. .within
the time intervals required in
paragraph* (a)(l) through (a)(4) of this
section, except that the date that a
material become* a hazardous waste
must be used in place of January 12.
1987.
(b) Secondary containment systems
must bet
(1) Designed, installed and operated
to prevent any migration of waste* or.
accumulated liquid out of the system to
the soil ground water, or surface water
at any time during the use of the tank
system: and
(2) Capable of detecting and collecting
release* and accumulated liquid* until
the collected material 1* removed
(c) To meet the requirements of
paragraph (b) of this section, secondary
containment systems must be at a
minimum;
(1) Constructed of or lined with
materials that are compatible with the
wastes(s) to be placed in the tank
system and must have sufficient
strength and thickness to prevent failure
owing to pressure gradients (including
static head and external hydroiogical
forces), physical contact with the waste
to which it i* exposed climatic
conditions, and the stress of daily
operation (including stresses from
nearby vehicular traffic).
~ (2) Placed on a foundation or base
capable of providing support to the
secondary containment system.
resistance to pressure gradient* above
and below the system, and capable of
preventing failure due to settlement
compression, or uplift
(3) Provided with a leak-detection
system that is designed and operated so
that it will detect the failure of either the
primary or secondary containment
structure or the presence of any release
of hazardous waste or accumulated
liquid in the secondary containment
system within 24 hours, or at the earliest
practicable time if the owner or operator
can demonstrate to the Regional
Administrator, that existing detection
technologies or site conditions will not
allow detection of a release within 24
hours; and
(4) Sloped or otherwise designed or
operated to drain and remove liquids
resulting from leaks, spills, or
precipitation. Spilled or leaked waste
and accumulated precipitation must be
removed from the secondary
containment system within 24 hours, or
in a* timely a manner as is possible to
prevent harm to human health and the
environment, if the owner or operator
can demonstrate to the Regional
Administrator that removal of the
released waate or accumulated
precipitation cannot be accomplished
within 24 hours.
[Note^-If the collected material is a
hazardous waste under Part 281 of this
chapter, it is subject to management aa a
hazardous waste in accordance with all
applicable requirements of Parts 262 through
265 of this chapter. If the collected material is
discharged through a point source to waters
of the United States, it U subject to the
requirements of sections 301. 304. and 402 of
the Clean Water Act as amended. If
discharged to a Publicly Owned Treatment
Works (POTW). it is subject to the
requirements of section 307 of the Gean
Water Act as amended. If the collected
material is released to the environment it
may be subject to the reporting requirements
of 40 CTR Part 302,]
(d) Secondary containment for tanks
must include one or more of the
following devices:
(1) A liner (external to the tank);
(2) A vault:
(3) A double-walled tank; or
(4) An equivalent device as approved
by the Regional Administrator
(e) In addition to the requirements of
paragraphs (b). (c). and (d) of this
section, secondary containment systems
must satisfy the following requirements:
(1) External liner systems must be:
(i) Designed or operated to contain 100
percent of the capacity of the largest
tank within its boundary:
(ii) Designed or operated to prevent
run-on or infiltration of precipitation
into the secondary containment system
unless the collection system has
sufficient excess capacity to contain
run-on or infiltration. Such additional
capacity must be sufficient to contain
precipitation from a 25-year. 24-hour
rainfall vent.
(iii) Free of cracks or gaps; and
(iv) Designed and installed to
surround the tank completely and to
cover all surrounding earth likely to
come into contact with the waste if
released from the tank(s) (i.e.. capable
of preventing lateral as well as vertical
migration of the waste).
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Federal Register / VoL SI. No. 134 / Monday. July 14. 1986 / Rules and Regulations 25475
(2) Vault system* must be:
(i) Designed or operated to contain 100
percent of the capacity of the largest
tank within its boundary;
(ii) Designed or operated to prevent
. run-on or infiltration of precipitation
into the secondary containment system
unless the collection system has
sufficient excess capacity to contain
nut-on or infiltration. Such additional
capacity must be sufficient to contain
precipitation from a 25-year. 24-hour
rainfall event
(iii) Constructed with chemical-
resistant water stops in place at all
Joints (if any):
(iv) Provided with an impermeable
interior «oating or lining that is
compatible with the stored waste and
that will preveatmigntion of waste into
the concrete; .
(v) Provided with a means to protect
against the formation of and ignition of
vapors within the vault if the waste
being stored or treated-
(A) Meets the definition of »g«<»«KU
waste under 1282^1 of this chapter or
(B) Meets the definite-" at mattve
waste under I ;I*J*M. of this chaqer, and
m*u/iurm an ignitable or explodva
vapor. .
(vi) Provided with an exterior '
moisture barrier or be otherwise
designed or operated to prevent
migration of moisture into the vault if
the vault is subject to hydraulic :
pressure.
(3) Double-walled tanks must be:
(i) Designed as an integral structure
(i.e, an inner tank completely enveloped
within an outer shell} so that any
release from the inner tank is contained
by the outer shelL
(ii) Protected, if constructed of metal
from both corrosion of the primary took
interior and of the external surface of
the outer sheik and
(iii) Provided with a built-in
continuous leak detection system
capable of detecting a release within 24
hours, or at the earliest practicable time,
if the owner or operator can
demonstrate to the Regional
Administrator, and the Regional
Administrator concludes, that the
existing detection technology or site
conditions would not allow detection of
a release within 24 hours.
[Note*—The provisions outlined in the
Steel Tank Institute's (STI) •'Standard for
Dual Wail Underground Steel Storage Tank*"
may be used as guidelines for aspects of the
design of underground steel double-walled
tanks.)
(f) Ancillary equipment must be
provided with secondary containment
(e.g., trench, jacketing, double-walled
piping) that meets the requirements of
paragraphs (b) and (c) of this; section.
except for
(1) Aboveground piping (exclusive of
flanges, joints, valves, and other
connections) that are visually inspected
for leaks on a daily basis:
(2) Welded flanges, welded Joints, and
welded connection*, that are visually
inspected for leak* on a daily basis;
(3) Sealless or magnetic coupling
pumps, that an visually inspected for
Itttkt on a daily h»«»«; vvlt
' (4) Pressurixed-abovegronnd piping
systems with automatic shut-off devices
(e.g» excess flow check valves, flow
metering shutdown devices. los» of
pressure actuated shut-off devices) that
are visually inspected for leaks on a .
daily basis,
(g) The owner o> operator may obtain
a variance from the requirements of this
section if the Regional Administrator
finds, as a result of a demonstration by
the owner or operator that alternative
design and operating practices, together
with location characteristics, will
prevent the migration of any hazardous
waste or hazardous constituents into the
ground water; or surface water at least
as effectively as secondary containment
during the active life of the tank system
or that in the event of a release that
does migrate to ground water or surface
water, no substantial present or
potential hazard will be posed to human
health or the environment New
underground tank systems may not per
a demonstration in accordance with
paragraph (g](2) of this section, be
exempted from the secondary
containment requirements of this
section.
(!) In deciding whether to grant a
variance based on a demonstration of
equivalent protection of ground water
and surface water, the Regional
Administrator will consider
(i) Th» nature and quantity.of the
wastes;
(ii) The proposed alternate design and
operation;
(iii) The hydrogeologic setting of the
facility, including the thickness of soils
present between the tank system and
ground water, and
(iv) Afl other factors that would
influence the quality and mobility of the
hazardous constituents and the potential
for them to migrate to ground water c
surface water
(2) In deciding whether to grant a
variance based on a demonstration of
no substantial present or potential
hazard, the Regional Administrator will
consider:
(i) The potential adverse effects on
ground water, surface water, and land
quality taking into account:
(A) The physical and chemical
characteristics of the waste in the tank
system, including its potential for
migration.
(B) The hydrogeological
characteristics of the facility and
surrounding land.
(C) The potential for health risks
caused by human exposure to waste
constituents,
(D) The potential for damage to
wildlife, crops, vegetation, and physical
structures caused by exposure to waste
constituents, and
(E) The persistence and permanence
of the potential adverse <
(ii) The potential adverse effects of a
release on ground-water quality, taking
Into account
(A) The quantity and quality of
ground water and the direction of
ground-water flow.
(B) The proximity and withdrawal
rates of ground-water users,
(O The current and future uses of
ground water in the area, and
(D) The existing quality of ground
water, including other sources of
contamination and their cumulative
impact on the ground-water quality;
(iii) The potential adverse effects of a
release on surface water quality, taking
into account .
(A) The quantity and quality of
ground water and the direction of
ground-water flow,
(B) The patterns of rainfall in the
region,
(Q The proximity of the tank system
to surface waters,
(D) The current and future uses of
surface waters in the ana and any
water quality standards established for
those surface waters, and
(E) The existing quality of surface
water, including other sources of
contamination and the cumulative
impact on surface-water quality; and
(iv) The potential adverse effects of a
release on the land surrounding the tank
system, taking into account
(A) The patterns of rainfall in the
region, and
(B) The current and future uses of the
surrounding land.
(3) The owner or operator of a tank
system, for which a variance from
secondary containment had bsen
granted in accordance with tae
requirements of paragraph ;g)(l) of this
section, at which a release of hazardous
waste has occurred from the primary
tank system but has not migrated
beyond the zone of engineering control
(as established in the variance), must:
(i) Comply with the requirements of
! 264.196. except paragraph (d), and
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25478
Federal Register / Vol. 51. No. 134 / Monday, July 14, 1988 / Rules and Regulations
(ii) Decontaminate or remove
contaminated soil to the extent
necessary to:
(A) Enable the tank system for which
the variance was granted to resume
operation with the capability for the
detection of releases at least equivalent
to the capability it had prior to the
release: and
(B) Prevent the migration of hazardous
waste or hazardous constituents to
ground water or surface water; and
(iii) If contaminated soil cannot be
removed or decontaminated in
accordance with paragraph (g)(3)(ii) of
this section, comply with the
requirement of S 28tl97(b).
(4) The owner or operator of a tank
system, for which a variance from
secondary containment had been
granted in accordance with the
requirements of paragraph (g}(l) of this
section, at which a release of hazardous
waste has occurred from the primary
tank system and has migrated beyond
the zone of-engineering control (as
established in the variance), must:
(i) Comply with the requirements of
§ 284.190 (a), (b), (c), and (d); and
(ii) Prevent the migration of hazardous
waste or hazardous constituents to
ground water or surface water, if
possible, and decontaminate or remove
. contaminated soiL If contaminated soil
cannot be decontaminated or removed
or if ground water has been
contaminated, the owner or operator
must comply with the requirements of
§ 284.197(b); and
(iii) If repairing, replacing, or
reinstalling the tank system, provide
secondary containment in accordance
with the requirements of paragraphs (a)
through (f) of this section or reapply for
a variance from secondary containment
and meet the requirements for new tank
systems in J 284.192 if the tank system is
replaced. Tan owner or operator must
comply with these requirements even if
contaminated soil can be
decontaminated or removed and ground
water or surface water has not been
contaminated.
(h) The following procedures must be
followed in order to request a variance
from secondary containment
(1) The Regional Administrator must
be notified in writing by the owner or
operator 'hat he intends to conduct and
submit a demonstration for a variance
from secondary containment as allowed
in paragraph (g) according to the
following schedule:
(i) For existing tank systems, at least
24 months prior to the date that
secondary containment must be
provided in accordance with paragraph
(a) of this section.
(ii) For new tank systems, at least 30
days prior to entering into a contract for
installation.
(2) As part of die notification, the
owner or operator must also submit to
die Regional Administrator a description
of die steps necessary to conduct die
demonstration and a timetable for
completing each of die steps. The
demonstration must address each of the
factors listed in paragraph (g)(l) or
paragraph (g)(2) of mis section:
(3) The demonstration for a variance
most be completed witiiin 180 days after
notifying die Regional Administrator of
an intent to conduct die demonstration;
ami
(4) If a variance is granted under this
paragraph, die Regional Administrator
will require die permittee to construct
and operate die tank system in die
manner dial was demonstrated to meet
the requirements for die variance.
(i) All tank systems, until such time as
secondary containment that meets die
requirements of this section is provided.
must comply with die following:
(1) For non-enterable underground
tanks, a leak test that meets die
requirements of § 284.191(a) or other
tank integrity, method, as approved or
required by the Regional Administrator.
must be conducted at least annually.
(2) For odier than non-enterable
underground tanks, die owner or
operator must either (i) conduct a leak
test as in paragraph (i)(l) or (ii) of this
section develop a schedule and
procedure for an assessment of the
overall condition of the tank system by
an independent qualified registered
professional engineer. The. schedule and
procedure must be adequate to detect
obvious cracks, leaks, and corrosion or
erosion that may lead to cracks and
leaks. The owner or operator must
remove die stored waste from die tank.
if necessary, to allow the condition of all
internal tank surfaces to be assessed.
The frequency of these assessments
must be based on die material of
construction of die tank and its ancillary
equipment die age of die system, the
type of corrosion or erosion protection
used, die rate of corrosion or erosion
observed during die previous inspection.
and die characteristics of the waste
being stored or treated.
n For ancillary equipment a leak test
or other integrity assessment as
approved by die Regional Adminisbdtor
must be conducted at least annually.
[Note^-The practices described in the
American Petroleum Institute (API)
Publication Guide for Inspection of Refinery
Equipment Chapter XIII, "Atmospheric and
Low-Pressure Storage Tanks." 4th edition.
1981. may be used, where applicable, as
guidelines for assessing the overall condition
of the tank system.)
(4) The owner or operator must
maintain on file at the facility a record
of the results of the assessments
conducted in accordance with
paragraphs (i)(l) through (i)(3) of this
section.
(5) If a tank system or component is
found to be leaking or unfit for use as a
result of die leak test or assessment in
paragraphs (i)(l) through (0(3) of this
section, the owner or operator must
comply with the requirements of
§•284.196.
(Information collection requirements
contained in paragraphs (c), (d). (•). (g). (h).
and (i) were approved by the Office of
Management and Budget under control
number 2050-0050.)
§284.184 Qenenl operating requirements.
(a) Hazardous wastes or treatment
reagents must not be placed in a tank
system if they could cause the tank, its
ancillary equipment or the containment
system ."o rupture, leak, corrode, or
otherwiefauV
(b) Ta owner or operator urc«st use
appropiate controls and practices to
prevent spills and overflows from tank
or containment systems. These include
at a minimum:
(l) Spill prevention controls (e.g..
check valves, dry disconnect couplings):
(2) Overfill prevention controls (e.g..
level sensing devices, high level alarms.
automatic feed cutoff, or bypass to a
standby tank); and
(3) Maintenance of sufficient
freeboard in uncovered tanks to prevent
overtopping by wave or wind action or
by precipitation.
(c) The owner or operator must
comply with die requirements of
1284.196 if a leak or spill occurs in the
tank system.
(Information collection requirements
contained in paragraph (c) were approved by
the Office of Management and Budget under
control number 2050-0090)
§264.196 Inspections.
(a) The owner or operator must
develop and follow a schedule and
procedure for inspecting overfill
controls.
(b) The owner or operator must
inspect at least once each operating day:
(1) Aboveground portions of the tank
system, if any, to detect corrosion or
releases of waste:
(2) Data gathered from monitoring and
leak detection equipment (e.g.. pressure
or temperature gauges, monitoring
wells) to ensure that the tank system is
being operated according to its design:
and
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Federal Register / VoL 51. No. 134 / Monday, July 14, 1986 / Rules and Regulations
2S477
(3] The construction materials and the
area immediately surrounding the
externally accessible portion of the tank
system, including the secondary
containment system (e.g» dikes) to
detect erosion or signs of releases of
hazardous waste (e.g* wet spots, dead
vegetation).
[Nate, Section 284.ia(c| requires the
owner of operator to remedy uiy
deterioration or malfunction he find*.
284.198 requires the owner or operator to
notify the Regional Administrator within 24
hoars of confirming a leak. Also, 40 CFR Part
302 may require the owner or operator to
notify the National Response Crater of a
release.)
(c) The owner or operator must
inspect cathodic protection systems, if
present, according to, at a minimum, tog
following schedule to ensure that they
are functioning properly:
(1) The proper operation of the
cathodic protection system must be
confirmed within six months after initial
installation and annually thereafter and
(2) All sources of impressed current
must be inspected and/or tested, as
appropriate, at least bimonthly (i.e.,
every other month).
[Note*—The practice* described in the
National Association of Corrosion Engineer*
(NACE) standard. "Recommended Practice
(RP-02-8S}—Control of External Corrosion on
Metallic Buried. Partially Buried, or •
Submerged Liquid Storage Systems," and the
American Petroleum Institute (API)
Publication 1632. "Cathodic Protection of
Underground Petroleum Storage Tanks and
Piping Systems." may be used, where
applicable, as guidelines in maintaining and
inspecting cathodic protection systems.)
(d) The owner or operator must
document in the operating record of the
facility an inspection of those items in
paragraphs (a) through (c) of this
section*
(Information collection requirement*
contained in paragraph (a) and (d) were
approved by the Office of Management and
Budget under control number 2050-0080)
9 264. t9a Response to leaks or sptts and
opposition at leaking or unflMor-uae tank
systems*
A tank system or secondary
containment system from which there
has been a leak or spill or which is unfit
for use. must be removed from service
immediately, ?nd the owner or operator
must satisfy the following requirements:
(a) Cessation of Use: prevent flow or
addition of wastes. The owner or
operator must immediately stop the flow
of hazardous waste into the tank system
or secondary containment system and
inspect the system to determine the
cause of the release.
(b) Removal of waste from tank
system or secondary containment
system. (1) If the release was from the
tank system, the owner/operator must
within 24 hours after detection of the
leak or. if the owner/operator
demonstrates that it is not possible, at
the earliest practicable time, remove as
much of the waste as is necessary to
prevent further release of hazardous
waste to the environment and to allow
inspection and repair of the tank system
to be performed.
(2) If the material released was to a
secondary containment system, all
released material* must be removed
within 24 hours or in as timely a manner
as is possible to prevent harm to human
health and the environment
(c) Containment of visible releases to
the environment The owner/operator
must immediately conduct a visual
inspection of the release and. based
upon that inspection:
(1) Prevent further migration of the
leak or spill to soils or surface water
and
(2) Remove, and properly dispose of,
any visible contamination of the soil or
surface water.
(d) Notifications, reports. (1) Any
release to the environment except as
provided hi paragraph (d)(2) of this
section, must be reported to the
Regional Administrator within 24 hours
of its detection. If the release has been
reported pursuant to 40 CFR Part 302.
that report will satisfy this requirement
(2) A leak or spill of hazardous waste
that is:
(i) Lass than or equal to a quantity of
one (1) pound and
(ii) Immediately contained and
cleaned-up ia exempted from the
requirements of this paragraph.
(3) Within 30 days of detection of a
release to the environment a report
containing the following information
must be submitted to the Regional
Administrator
(i) Likely route of migration of the
release:
(ii) Characteristics of the surrounding
soil (soil composition, geology,
hydrogeology, climate);
(iii) Results of any monitoring or
sampling conducted in connection with
the release (if available). If sampling or
monitoring data relating to the release
are not available within 30 days, these
data must be submitted to the Regional
Administrator as soon as they become
available.
(iv) Proximity to downgradient
drinking water, surface water, and
population areas: and
(v) Description of response actions
taken or planned.
(e) Provision of secondary
containment, repair, or closure. (1)
Unless the owner/operator satisfies the
requirements of paragraphs (e)(2)
through (4) of this section, the tank
system must be closed in accordance
with § 264.197.
(2) If the cause of the release was a
spill that has not damaged the integrity
of the system, the owner/operator may
return the system to service as soon as
the released waste is removed and
repairs, if necessary, are made.
(3) If the cause of the release was a
leak from the primary tank system into
the secondary containment system, the
system must be repaired prior to
returning the tank system to service.
(4) If the source of the release was a
leak to the environment from a
component of a tank system without
secondary containment the owner/
operator must provide the component of
the system from which the leak occurred
with secondary containment that
satisfies the requirements of § 234.193
before it can be returned to service,
unless the source of the leak is an
aboveground portion of a tank system
that can be inspected visually. If the
source is an aboveground component
that can be inspected visually, the
component must be repaired and may be
returned to service without secondary
containment as long as the requirements
of paragraph (f) of this section are
satisfied. If a component is replaced to
comply with the requirements of this
subparagraph. that component must
satisfy the requirements for new tank
systems or components in §§ 264.192
and 264.193. Additionally, if a leak has
occurred in any portion of a tank system
component that is not readily accessible
for visual inspection (e.g.. the bottom of
an inground or onground tank), the
entire component must be provided with
secondary containment in accordance
with ] 264.193- prior to being returned to
(f) Certification of ma/or repairs. If
the owner/operator has repaired a tank
system in accordance with paragraph (e)
of this section, and the repair has been
extensive (e.g.. installation of an internal
linen repair of a ruptured primary
containment or secondary containment
vessel), the tank system must not be
returned to service unless the owner/
operator has obtained a certification by
an independent qualified, registered.
professional engineer in accordance
with § 270.11(d) that the repaired system
is capable of handling hazardous wastes
withput release for the intended life of
the system. This certification must be
submitted to the Regional Administrator
within seven days after returning the
tank system to use.
(Note.—The Regional Administrator may.
on the basis of any information received that
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25478
Federal Register / VoL 51. No. 134 / Monday. July 14. 1986 / Rules and Regulations
there it or has been a reieese of hazardous
waste or hazardous constituents into the
environment issue an order under RCRA
section* 3004(w), 3008(h). or 7003{a) requiring
corrective action or such other response as
deemed necessary to protect human health or
the environment)
[Note—See } 254.1S(c) for the requirements
necessary to remedy a failure. Also. 40 CFR
Pert 302 may require the owner or operator to
notify the National Response Center of
certain release*.)
(Information collection requirement* '
contained in paragraphs (dj. (e}, and (f) were
approved by the Office of Management and
Budget •m'itT control ««vqh
3254.197
(a) At closure of a tank system, the
owner or operator must remove or
decontaminate all waste residues,
contaminated containment system
components (liners, etc.), contaminated
soils, and structures and equipment
contaminated with waste, and manage
them as hazardous waste, unless
§ 26l.3(d) of this Chapter applies. The
closure plan, closure activities, cost
estimates for closure, and financial
responsibility for tank systems must
meet all of the requirements specified in
Subparts G and H of this Part
(b) If the owner or operator
demonstrates that not ail contaminated
soils can be practicably removed or
decontaminated as required in
paragraph (a) of this section, then the
owner or operator must close the tank
system and perform post-closure care in
accordance with the closure and post-
closure care requirements that apply to
landfills (5 264.310). In addition, for the
purposes of closure, post-closure, and
financial responsibility, such a tank
system is then considered to be a
landfilL and the owner or operator must
meet all of the requirements for landfills
specified in Subparts G and H of this
Part
[c] If an owner or operator has a tank
system that does not have secondary
containment that meets the
requirements of J 284.193 (b) through (f)
and is not exempt from the secondary
containment requirements in accordance
with §2B4.193(g), then:
(Ij The closure plan for the tank
system must include both a plan for
complying with paragraph (a) of this
section and a contingent plan for
complying with paragraph (b) of this
section.
(2) A cor'ingent post-closure plan for
complying with paragraph (b) of this
section must be prepared and submitted
as part of the permit application.
(3) The cost estimates calculated for
closure and post-closure care must
reflect the costs of complying with the
contingent closure plan and the
contingent postrdosun plan, if those
costs are greater than the costs of
complying with the closure plan
prepared for the expected closure under
paragraph (a) of this section.
(4) Financial assurance must be based
on the cost estimates in paragraph (c)(3)
of this section.
(5) For the purposes of the contingent
closure and post-closure plans, such a
tank system is considered to be a
landfilL and the contingent plans must
meet sit of the closure, post-closure, and
financial responsibility requirements for
landfills under Subparts G and H of this
Part
(Information collection requirements
contained in paragraphs (a He) were
approved by the Office of Management and
Budget under control- number 2050-0050)
§ 264. 194 Special requeretMnts for
lejnttBMe)or raacttvej wastes*
(a) Ignitable or reactive waste must
not be placed in tank systems, unless:
(1) The waste is treated, rendered, or
mixed before or immediately after
placement in the tank system so that
(i) The resulting waste, mixture, or
dissolved material no longer meets the
definition of ignitable or reactive waste
under Si 261.21 or 281.23 of this Chapter.
and
(ii) Section 284,17(b) is complied with:
or
(2) The waste is stored or treated in
such a way that it is protected from any
material or conditions that may cause
the waste to ignite or react or
(3) The tank system is used solely for
emergencies.
(b) The owner or operator of a facility
where ignitable or reactive waste is
stored or treated in a tank must comply
with the requirements for the
maintenance) of protective distances
between the waste management area
and any public ways, streets, alleys, or
an adjoining property line that can be
built upon as required in Tables 2-1
through 2-4 of the National Fire
Protection Association's "Flammable
and Combustible Liquids Code," (1977 or
1981). (incorporated by reference, see
§ 280.11).
} 264. 199 Special requirements for
(a) Incompatible wastes, or
incompatible wastes and materials.
must not be placed in the same tank
system, unless § 264.17(b) is complied
with.
(b) Hazardous waste must not be
placed in a tank system that has not
been decontaminated and that
previously held an incompatible waste
or material, unless § 264.17(b) is
complied with.
PART 265—iNTEHIM STATUS
STANDARDS FOR OWNERS AND
OPERATORS OF HAZARDOUS WASTE
TREATMENT, STORAGE, AND
DISPOSAL FACILITIES
40 CFR Part 265 is amended as
follows:
14. The Authority citation for Part 265
continues to read as follows;
Authority: Sees. 1006.200Zfa), 3004.3005.
and 3015 of the Solid Waste Disposal Act as
amended by the Resource Conservation and
Recovery Act of 1978, as amended (42 U.S.C.
8908. emga). 6824.8925. and 8935).
15. The Table of Contents and the
heading of Part 285. Subpart J—Tanks is
revised to read as follows:
Subpart *-Tank Systems
Sec.
265.190 Applicability.
265.191 Assessment of existing tank
system's integrity.
258.192 Design and installation of new tank
systems or components.
285.193 Containment and detection of
releases.
285.194 General operating requirements.
285.195 Inspections.
285.198 Response to leaks or spills and
disposition of leaking or unfit-for-use
tank systems.
265.197 Closure and post-closure care.
283.198- Special requirements for ignitable or
reactive wastes.
285.199 Special requirements for
incompatible wastes.
285^00 Waste analysis and trial tests.
205.201 Special requirements for generators
of between 100 and 1.000 kg/mo that
accumulate hazardous waste in tanks.
• * • • *
18. Section 285.13 is amended by
revising paragraph (b)(6) to read as
follows:
§ 28&.13 General waste anatysis.
• « » * *
(b) *' *
(8) Where applicable, the methods
that will be used to meet the additions!
waste analysis requirements for specific
waste management methods as
specified in § § 265.200. 265.225. 265.252.
265.273. 285.314. 285.345, 265.375. and
285.402.
*****>
17. Section 265.15 is amended by
revising paragraph (b)(4) to read as
follows:
§ 265.15 General inspection requirements.
• * » * «
(b)' •'
(4) The frequency of inspection may
vary for the items on the schedule.
However, it should be based on the rate
of possible deterioration of the
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Fodaral Register / Vol. 51, No. 134 / Monday, July 14, 1988 / Rules and Regulations
25479
equipment and the probability of ah
environmental or human health incident
if the deterioration, or malfunction, or
any operator error goes undetected
between inspections. Areas subject to
spills, such as loading and unloading
areas, must be inspected daily when in
use. At a minimum, the inspection
schedule must' include the items and
frequencies called for in { } 288.174.
289.193. 285.195. 28&22S, 266447, 28&3T7.
and 285.403.
18. Section 28573 is amended by
revising paragraphs (b)(3) and (b)(8) to
read as follows:
526&T3 Operating won*.
* * *^T> * *
(b) • * *"
(3) Records and results of waste
analysis and trial tests performed as
specified in §5 285.13, 285.200,
285J52. 285J73. 285.314. 28SJ41. 285.375,
and 285.402.
• • • • *
(8) Monitoring, testing, or analytical
data when required by 55 285.90, 285£4,
285.191. 265.193. 285.135. 285.278. 28*278.
285.280(d)(l). 285.347. and 285.377; and
• • t • •
19. Section 285.110 is amended by
revising paragraph (b){2) to read as
follows:
§265.110 Applicability.
*****
(b) ' ' '
(2) Tank systems that are required
undsr § 265U97 to meet requirements for
landfills.
• * « • *
20. Section 285.140 is amended by
revising paragraph (b) to read ae
follows:
5265.140 Applicability.
(b)The requirements of 5 J 285.144
and 285.148 apply only to owners and
operators of disposal facilities and tank
systems that are required under
5 265.197 to meet the requirements for ,
landfills
. • « • •
21. The Subpart I is revised to read as
follows:
Subpart J— Tank Systems
§285.190 Applicability.
The regulations of this Subpart apply
to owners or operators of facilities that
use tank systems for storing or treating
hazardous waste, except as otherwise
provided in paragraphs (a) and (b) of
this section or in § 265.1 of this part.
fa) Tanks that are used to store or
'rest hazardous waste containing no
free liquids and that are situated inside
a building with an impermeable floor
are exempted from the requirements of
5 285.193 of this subpart. To
demonstrate the absence or presence of
free liquids in the stored/ treated waste.
EPA Method 9095 (Paint Filter Liquids
Test) as described in "Test Method* for
Evaluating Solid Wastes. Physical/
Chemical Methods" (EPA Publication
No. SW-848) must be used.
(b) Tanks, including sumps, as defined
in 1 280.10, that serve as part of a
secondary f*yn>a»pm»n» system to collect
or contain release* of hazardous wastes
are exempted from the requirements in
1285.183,
(I&bnuttoB collection requirement
contained i& paragraph (a) was approved by
the Office of Management and Budget under
control number 2090-4050.)
§286.191
of eatettnq tar*
(a) For each existing tank system that
does not have secondary containment
meeting the requirements of 5 285.193.
the owner or operator must determine
that the tank system is not leaking or is
unfit for use. Except as provided in
paragraph (c) of this section, the owner
or operator must obtain and keep on file
at the facility a written assessment
reviewed and certified by an
independent qualified, registered
professional engineer in accordance
with ! 270.11(d), that attests to the tank
system's integrity by January 12, 1988.
(b) This assessment must determine
that the tank system is adequately
designed and has sufficient structural
strength and compatibility with the
waste(s) to be stored or treated to
ensure that it will not collapse, rupture.
or faiL At a minimmq, this assessment
must consider the following:
(1) Design standard(s), if available.
according to which the tank and
ancillary equipment wen constructed:
(2) Hazardous characteristics of the
waste(s) that have been or will be
handled:
(3) Existing corrosion protection
measures:
(4) Documented age of the tank
system, if available, (otherwise, an
estimate of the age): and
(5) Results of a leek test internal
inspection, or other tank integrity
examination such that:
(i) For non-enterable underground
tanks, this assessment must consist of a
leak test that is capable of taking into
account the effects of temperature
variations, tank end deflection, vapor
pockets, and high water table effects.
(ii) For other than non-enterable
underground tanks and for ancillary
equipment, this assessment must be
either a leak test, as described above, or
an internal inspection and/or other tank
integrity examination certified by an
independent, qualified, registered
professional engineer in accordance
with 5 270.11(d) that addresses cracks.
leaks, corrosion, and erosion.
[Note*—The practices described in tht
American Petroleum Institute (API)
Publication. Guide tat Inspection of Refinery
Equipment Chapter Xffl. "Atmospheric and
Low-Pnwun Storage Tanks." 4th edition.
1981. may be used, when applicable, as
[pi«4-!in«. in conducting the integrity
examination of an other than non-enterable
underground tank system.)
(c) Tank systems that store or treat
materials that become hazardous wastes
subsequent to July 14.1988 must conduct
this assessment within 12 months after
the date that the waste becomes a
hazardous waste.
(d) It as a result of the assessment
conducted in accordance with
paragraph (a) of this section, a tank
system is found to be leaking or unfit for
use, the owner or operator must comply
with the requirements of i 285.198.
(Information collection requirements
contained in paragraphs UHd) were
approved by the Office of Management and
Budget under control number 2050-0050.)
§269.1*2 Design and Installation of new
tank systems or components.
(a) Owners or operators of new tank
systems or components must ensure that
the foundation, structural support
seams, connections, and pressure
controls (if applicable) are adequately
designed and that the tank system has
sufficient structural strength.
compatibility with the waste(s) to be
stored or treated, and corrosion
protection so that it will not collapse.
rupture, or faiL The owner or operator
must obtain a written assessment
reviewed and certified by an
independent qualified, registered
professional engineer in accordance
with §270.lKd) attesting that the
system has sufficient structural integrity
and is acceptable for the storing and
treating of hazardous waste. This
assessment must include, at a minimum,
the following information:
(1) Design standard(s) according to
which the tank(s) and ancillary
equipment is or will be constructed.
(2) Hazardous characteristics of the
waste(s) to be handled.
(3) For new tank systems or
components in which the external shell
of a metal tank or any external metal
component of the tank system is or will
be in contact with the soil or with water,
a determination by a corrosion expert
of:
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25480 Federal Register / Vol. 51, No. 134 / Monday. July 14. 1986 / Rules and Regulations
(i) Factors affecting the potential for
corrosion, including but not limited UK
(A) Soil moisture content;
(BJSoilpH:
(C] Soil sulfides level:
(D) Soil resistivity;
(E) Structure to soil potential;
(F] Influence of nearby underground
metal structures (e.g« piping];
• (G) Stray electric currant; .
(H) Existing corrosion-protection
measures (e.g» coating, cathodic
protection), and
(ii) The type and degree of external
corrosion protection that are needed to
ensure the integrity of the tank system
during the use of the tank system or
component consisting of one or more of
the following:
(A) Corrosion-resistant materials of
construction such as special alloys.
fiberglass-reinforced plastic, etcu
(B) Corrosion-resistant coating (such
as epoxy, fiberglass, etc] with cathodic
protection {e.g., impressed current or
sacrificial anodes); and
(Q Electrical isolation devices such as
insulating joints, flanges, etc.
[Not«<—The practices described in the
National Association of Corrosion Engineers
(.MACE) standard. "Recommended Practice
(RP-02-aSr—Control of External Corrosion on
Metallic Buried. Partially Buried, or
Submerged Liquid Storage Systems,*' and the
American Petroleum Institute (API)
Publication 1832. "Cathodic Protection of
Underground Petroleum Storage Tanks and
Piping System*" may be used, when
applicable, as guidelines in providing
corrosion protection for tank systems.]
(4) For underground tank system
components that are likely to be
affected by vehicular traffic, a
determination of design or operational
measures that will protect the tank
system against potential damage: and
(5) Design considerations to ensure
that
(i] Tank foundations will maintain the
load of a full tank;
(ii] Tank systems will be anchored to
prevent flotation or dislodgement when
the tank system is placed in a saturated
zone, or is located within a seismic fault
zone: and
(iii) Tank systems will withstand the
effects of frost heave.
(b) The owner or operator of a new
tank system must ensure that proper
handling procedures are adhered to in
order to prevent damage tr the system
during installation. Prior to covering,
enclosing, or placing a rvjw tank system
or component in use. an independent
qualified installation inspector or an
independent qualified, registered
professional engineer, either of whom is
trained and experienced in the proper
installation of tank systems, must
inspect the system or component for the
presence of any of the following items:
(1) Weld breaks;
(2) Punctures:
(3) Scrapes of protective coatings:
(4) Cracks:
(5) Corrosion;
(6) Other structural damage or
inadequate construction or installation.
All discrepancies must be remedied
before the tank system i* covered,
enclosed, or placed in use.
• (c) New tank systems or components
and piping that an placed underground
and that an backfilled must be provided
with a backfill material that is a
noncorrosive. porous, homogeneous
substance, and that is carefully installed
so that the backfill is placed completely
around the tank and compacted to
ensure that the tank and piping an fully
and uniformly supported.
(d) All new tanks and ancillary
equipment must be tested for tightness
prior to being covered, enclosed or
placed in use. If a tank system is found
not to be tight all repairs necessary to
remedy the leak(s) in the system must
be performed prior to the tank system
being covered, enclosed, or placed in
use.
(e) Ancillary equipment must be
supported and protected against
physical damage-and excessive stress
due to settlement vibration, expansion
or contraction.
(Note.—The piping system installation
procedure* described in American Petroleum
Institute (API) Publication 1815 (November
1979), "Installation of Underground Petroleum
Storage Systems." or ANSI Standard 831J.
"Petroleum Refinery System." may be used.
where applicable, as guideline* for proper
installation of piping systems.)
(f) The owner or operator-must
provide the type and degree of corrosion
protection necessary, based on the
information provided under paragraph
(a)(3) of this section, to ensure the
integrity of the tank system during use
of the tank system. The installation of a
corrosion protection system that is field
fabricated must be supervised by an
independent corrosion expert to ensure
proper installation.
(g) The owner or operator must obtain
and keep on file at the facility written
statements by those persons required to
certify the design of the tank system and
supervise the installation of the tank
system in accordance with the
requirements of paragraphs (b) through
(f) of this section to attest that the tank
system was properly designed and
installed and that repairs, pursuant to
paragraphs (b) and (d) of this section
were performed. These written
statements must also include the
certification statement as required in
§ 270.11(d] of this chapter.
(Information collection requirements
contained in paragraphs (a) and (g) were
approved by the Office of Management and
Budget under control number 2050-0050.)
§289.193 Containment and detection of
(a] In order to prevent the release of
hazardous waste or hazardous
constituents to the environment
secondary containment that meets the
requirements of this section must be
provided (except as provided in
paragraphs (f) and (gj of this section}:
(1) For all new tank systems or
components, prior to their being put into
service;
(2] For all existing tanks used to store
or treat EPA Hazardous Waste N'os.
P020, F021. F022. F023, F028. and F027,
within two years after January 12.1367;
(3) For those existing tank systems of
known and documentable age. within
two years after January 12.1987, or
when the tank systems have reached IS
years of age. whichever comes liit^n
(4) For those existing tank system for
which the age cannot be documented.
within eight years of January 12.19«7:
but if the age of the facility age is
greater than seven years, secondary
containment must be provided by the
time the facility reaches 15 years of ..^e.
or within two years of January 12. W87.
whichever comes later: and
(5) For tank systems that store or treat
materials that become hazardous wastes
subsequent to January 12.1087, within
the time intervals required in
paragraphs (a)(l) through (aj(4) of this
section, except that the date that a
material becomes a hazardous waste
must be used in place of January 12.
1987.
(b) Secondary containment systems
must be:
(1) Designed, installed, and operated
to prevent any migration of wastes or
accumulated liquid out of the system to
the soil, ground water, or surface water
at any time during the use of the tank
system: and
(2) Capable of detecting and collecting
releases and accumulated liquids until
the collected material is removed.
(c) To meet the requirements of
paragraph (b) of this section, secondary
contaHment systems must be at a
minimum:
(1) Constructed of or lined with
materials that are compatible with the
waste(s) to be placed in the tank system
and must have sufficient strength and
thickness to prevent failure due to
pressure gradients (including static head
and external hydrological forces).
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Federal Register / VoL 51. No. 134 / Monday. July 14. 1986 / Rules and Regulations 25481
physical contact with the waste to
which they are exposed, climatic
conditions, the stress of installation, and
the stress of daily operation (including
stresses from nearby vehicular traffic}:
(2) Placed on a foundation or base
capable of providing support to the
secondary containment system and
resistance to pressure gradients above
and below the system and capable of
preventing failure due to settlement
compression, or uplift
(3) Provided with a leak detection-
system that is designed and operated so
that it will detect the failure of either the-
primary and secondary containment
structure or any release of hazardous
waste or accumulated liquid in the
secondary containment system within 24
hours, or at the earliest practicable time
if the existing detection technology or
site conditions will not allow detection
of a release within 2* hours;
(4) Sloped or otherwise designed or
operated to drain and remove liquids
resulting from leaks, spills, or
precipitation. Spilled or leaked waste
and accumulated precipitation must be
removed from the secondary
containment system within 24 hours, or
in as timely a manner as is possible to
prevent harm to human health or the
environment if removal of the released
waste or accumulated precipitation
cannot be accomplished within 24 hours.
(Not*—4f the collected material is a
hazardous waste under Part 281 of this
chapter, it is. subject to management as a
hazardous waste in accordance with all
applicable requirements of Parts 282 through
285 of this chapter. If the collected material is
discharged through a point source to waters
of the United States, it i* subject to the
requirements of sections 301.304. and 402 of
the dean Water Act as amended, if
discharged to Publicly Owned Treatment
Works (POTWs). it is subject to the
requirements of section 307 of the deer
Water Act as amended. If the collected
material if released to the environment it
may be subject to the reporting requirements
of 40 CTR Part 302-1
(d) Secondary containment for tanks
must include one or more of the
following devices:
(1) A liner (external to the tank);
(2) A vault:
(3) A double-walled tank: or
(4) An equivalent device as approved
by the Regional Administrator.
(e) In addition to the requirements of
paragraphs (b). (c). and (d) of this
section, secondary containment systems
must satisfy the following requirements:
(1) External liner systems must be:
(i) Designed or operated to contain 100
percent of the capacity of the largest
tank within its boundary;
(ii) Designed or operated to prevent
!t:n-on or infiltration of precipitation
into the secondary containment system
unless the collection system has
sufficient excess capacity to contain
run-on or infiltration. Such additional
capacity must be sufficient to contain
precipitation from a 25-year, 24-hour
rainfall event:
(ill) Free of crack* or gaps: and
(iv) Designed and installed to
completely surround the tank and to
cover all surrounding earth likely to
come into contact with the waste if
released from the tank(s) (La* capable
of preventing lateral aa well as vertical
migration of the waste).
(2) Vault systems) must be:
(i) Designed or operated to contain 100
percantof the capacity of the largest
tank within its boundary;
(ii) Designed oroperated to prevent
run-on or infiltration of precipitation
into the secondary containment system
unlttM the collection system has
sufficient to contain run-on or
infiltration. Such additional capacity
must be sufficient to contain
precipitation from a 25-year. 24-hour
rainfall event:
(iii) Constructed with chemical-
resistant water stops in place at all
joints (if any):
(iv) Provided with an impermeable
ulterior coating or lining that is
compatible with the stored waste and •
that will prevent migration of waste into
'the concrete:
(v) Provided with a means to protect
against the formation of and ignition of
vapors within the vault if the waste
being stored or treated:
(A) Meets the definition of ignitable
waste under §26Z21 of this chapter, or
(B) Meets the definition of reactive
waste under }2nZ21 of this chapter and
may form an ignitable or explosive
vapor and
(vi) Provided with an exterior
moisture barrier or be otherwise
designed or operated to prevent
migration of moisture into the vault if
the vault is subject to hydraulic
pressure.
(3) Double-walled tanks must be:
(i) Designed as an integral structure
(i.e., an inner tank within an outer shell)
so that any release from the inner tank
is contained by the outer shell:
(ii) Protected, if constructed of metal.
from both corrosion of the primary tank
interior am Jie external surface of the
outer shell: and
(iii) Provided with a built-in.
continuous leak detection system
capable of detecting a release within 24
hours or at the earliest practicable time.
if the owner or operator can
demonstrate to the Regional
Administrator, and the Regional
Administrator concurs, that the existing
leak detection technology or site
conditions will not allow detection of a
release within 24 hours.
[Not*—The provisions outlined in the
Steel Tank Institute's (STI) "Standard for
Dual Wall Underground Steel Storage Tank"
may be used as guidelines for aspects of the
design of underground steel double-walled
tanks.)
(f) Ancillary equipment must be
provided with full secondary
containment (e.g» trench, jacketing.
double-walled piping) that meets the
requirements of paragraphs (b) and (c)
of this section except for
(1) Aboveground piping (exclusive of
flanges, joints, valves, and connections)
that an visually inspected for leaks on a
daily basis:
(2) Welded flanges, welded joints, and
welded connections that are visually
inspected for leaks on a daily basis:
(3) Sealless or magnetic coupling
pumps that are visually inspected for
leaks on a daily basis: and
(4) Pressurized aboveground piping
systems with automatic shut-off devices
(e.g.. excess flow check valves, flow
metering shutdown devices, loss of
pressure actuated shut-off devices) that
are visually inspected for leaks on a
daily basis.
(gj The owner or operator-may obtain
a variance from the requirements of this
Section if the Regional Administrator
finds, as a result of a demonstration by
the owner or operator, either
(1) That alternative design and
operating practices, together with
location characteristics, will prevent the
migration of hazardous waste or
hazardous constituents into the ground
water or surface water at least as
effectively as secondary containment
during the active life of the tank system
or (2) that in the event of a release that
does migrate to ground water or surface
water, no substantial present or
potential hazard will be posed to human
health or the environment New
underground tank systems may not per
a demonstration in accordance with
paragraph (g)(2) of this section, be
exempted from the secondary
containment requirements of this
section. Application for a variance as
allowed in paragraph (g) of this section
does not waive compliance with the
requirements of this Subpart for new
l jik syst .ms.
(1) In deciding whether to grant a
variance based on a demonstration of
equivalent protection of ground water
and surface water, the Regional
Administrator will consider:
(i) The nature and quantity of the
waste:
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25482 Federal Register / Vol. 51. No. 134 / Monday. July 14. 1986 / Rules and Regulations
(ii) The proposed alternate design and
operations
(iii) The hydrogeologic setting of the
facility, including the thickness of soils
between the tank system and ground
waten and
(iv) All other factors that would
influence -the quality and mobility of the
hazardous constituents and the. potential
for them to migrate to ground water or
surface water.
(2) In deciding whether to grant a
no substantial present or potential
hazardt the Regional Administrator will
consider! • •
(i) The potential advene effects on
ground water, surface water, and land
Quality fyjfrf*»g into account*
(A) The physical and chemical
characteristics of the waste in the tank
system, including its potential for
migration.
(B) The hydrogeological
characteristics of the facility and
surrounding land,
(C) The potential for health risks
caused by human exposure to waste
constituents.
(D) The potential for damage to
wildlife, crops, vegetation, and physical
structures caused by exposure to waste
constituents, and
(El The persistence and i
of the potential adverse <
(ii) The potential adverse effects of a
release on ground-water quality, taking
into account
(A) The quantity and quality of
ground water and the direction of
ground-water Sow,
(B) The proximity and withdrawal
rates of water in the area.
(Q The current and future uses of
ground water in the area, and
(D) The existing quality of ground
water, including other sources of
contamination and their cumulative
impact on the ground-water quality;
(iii) The potential adverse effects of a
release on surface water quality, taking
into account
(A) The quantity and quality of
ground water and the direction of
ground-water flow,
(B) The patterns of rainfall in the
region.
(Q The proximity of the tank system
to surface waters,
(D) The current and future uses of
surface waters in the area and any
water quality standards established for
those surface waters, and
(E) The existing quality of surface
water, including other sources of
contamination and the cumulative .
impact on surface-water quality: and
(iv) The potential adverse effects of a
release on the land surrounding the tank
system, taking into account
(A) The patterns of rainfall in the
region, and
(B) The current and future uses of the
surrounding land.
(3) The owner or operator of a tank
system, for which a variance from
secondary containment had been
granted IB accordance with .the
requirements of paragraph (g)(l) of this
section, at which a release of hazardous
waste has occurred from the primary
tank system but has not migrated
beyond the* zone of ^nginifwHig control
(as established in the variance), must:
(i) Comply with the requirements of
1285.198. except paragraph (d); and
(ii) Decontaminate or remove
contaminated soil to the extent
necessary to:
(A) Enable the tank system, for which
the variance was granted, to resume
operation with the capability for the
detection of and response to releases at
least equivalent to the capability it had
prior to the release, and
(B) Prevent the migration of hazardous
waste or hazardous constituents to
ground water or surface waten and
(iii) If contaminated soil cannot be
removed or decontaminated in
accordance with paragraph (g)(3)(ii) of
this section, comply with the
requirements of i 2B4.197(b):
(4) The owner or operator of a tank
system, for which a variance from
secondary containment had been
granted in fl^qgr*^1?*^ with the
requirements of paragraph (g)(l) of this
section, at which a release of hazardous
waste has occurred from the primary
tank system and has migrated beyond
the zone of engineering control (as
established in the variance), must:
(i) Comply with the requirements of
S 285.198(a). (b). (c). and (d); and
(ii) Prevent the migration of hazardous
waste or hazardous constituents to
ground water or surface water, if
possible, and decontaminate or remove
contaminated soil. If contaminated soil
cannot be decontaminated or removed,
or if ground water has been
contaminated, the owner or operator
must comply with the requirements of
J285.197(b);
(iii) If repairing, replacing, or
reinstalling the tank system, provide
secondly containment in accordance
with the requirements of paragraphs (a)
through (f) of thi section or reapply for
a variance from secondary containment
and meet the requirements for new tank
systems in § 285.192 if the tank system is
replaced. The owner or operator must
comply with these requirements even if
contaminated soil can be
decontaminated or removed, and ground
water or surface water has not been
contaminated.
(h) The following procedures must be
followed in order to request a variance
from secondary containment:
(1) The Regional Administrator must
be notified in writing by the owner or
operator that he intends to conduct and
submit a demonstration for a variance
from secondary containment as allowed
in paragraph (g) of this section
according to the following schedule:
(i) For existing tank systems, at least
24 months prior to the date that
secondary containment must be
provided in accordance with paragraph
(a) of this section; and
(ii) For new tank systems, at least 30
days prior to entering into a contract for
installation of the tank system.
(2) As part of the notification, the
owner or operator must also submit to
the Regional Administrator a description
of the steps necessary to conduct the
demonstration and a timetable for
completing each of the steps. The
demonstration must address each of the
factors listed in paragraph fg)(l) or
paragraph (g](2) of this section.
(3) The demonstration for a variance
must be completed and submitted to the
Regional Administrator within ISO days
after notifying the Regional
Administrator of intent to conduct the
demonstration.
(4) The Regional Administrator will
inform the public, through a newspaper
notice, of the availability of the
demonstration for a variance. The notice
shall be placed In a daily or weekly
major local newspaper of general
circulation and shall provide at least 30
days from the date of the notice for the
public to review and comment on the
demonstration for a variance. The
Regional Administrator also will hold a
public hearing, in response to a request
or at his own discretion, whenever such
a hearing might clarify one or more
issues concerning the demonstration for
a variance. Public notice of the hearing
will be given at least 30 days prior to the
date of the hearing and may be given at
the same time as notice of the
opportunity for the public to review and
comment on the demonstration. These
two notices may be combined.
(5) The Regional Administrator will
approve or disapprove the request for a
variance within 90 days of receipt of the
demonstration from the owner or
operator and will notify in writing the
owner or operator and each person who
submitted written comments or
requested notice of the variance
decision. If the demonstration for a
variance is incomplete or does no*
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Federal Register / VoL 51. No. 134 / Monday, July 14. 1986 / Rules and Regulations 23483
include sufficient information, the 90-
day time period will begin when the
Regional Administrator receives a
complete demonstration* including all
information necessary to make a final
determinations If the public comment
period in paragraph (h)(4) of this section
is extended, the 90-day time period will
be similarly extended.
(!) All tank systems, until such time as
secondary containment meetinfl'the)
requirements of this section is provided.
must comply with the following:
(1) For non-enterable underground
tanks, a leak test that meets the
requirements of § 285.191(a) must be
conducted at least annually;
(2) For other than non-enterable
underground tanks and for all ancillary
equipment an annual leak test as
described in paragraph (i)(l) of this
section, or an internal inspection or
other tank integrity examination by an
independent qualified, registered
professional engineer that addresses
cracks, leaks, corrosion, and erosion
must be conducted at least annually.
The owner or operator must remove the
stored waste from the tank, if necessary,
to allow the condition of all internal
tank surfaces to be assessed.
(Not*—The practices described in the
American Petroleum Institute (API)
Publication Guide for Inspection of Refining
Equipment Chapter JOB.."Atmospheric and
Low Pressure Storage Tanks," 4th edition.
1981. may be used when applicable, aa
guidelines for assessing the overall condition
of the tank system.]
(3) The owner or operator must
maintain on file at die facility a record
of the results of the assessments
conducted in accordance with
paragraphs (i)(l) through (i)(3) of this
section.
(4) If a tank system or component is
found to be leaking or unfit-for-use as a
result of the leak test or assessment in
paragraphs (i)(l) through (i)(3) of this
section, the owner or operator must
comply with the requirements of
§285.196.
(Information collection requirements
contained in paragraphs (cH«) and (gHO
were approved by-the Office of Management
and Budget under control number 20SO-OOSO.)
§268.194 general operating requirements.
(a) Hazardous wastes or treatment
reagents must not be place j in a tank
system if they could cause the tank, its
ancillary equipment or the secondary
containment system to rupture, leak.
corrode, or otherwise fail
(b) The owner or operator must use
appropriate controls and practices to
prevent spills and overflows from tank
or secondary containment systems.
These include at a minimum:
(1) Spill prevention controls (e.g ,
check valves, dry discount couplings);
(2) Overfill prevention controls (e.g ,
level sensing devices, high level alarms.
automatic feed cutoff, or bypass to a
standby tank); and
(3) Maintenance of sufficient
freeboard in uncovered tanks to prevent
overtopping by waive or wind action or
by precipitation.
(c) The owner or operator must
comply with the requirements of
1285.196 if a leak or spill occurs in the
tank system.
(Info
ollectio
quir
contained in paragraphs (c) were approved
by the Office of Management and Budget
under control number 20SO-0090.)
} 266.196
(a) The owner or operator must
Inspect when present at least once
each operating day:.
(1) Overfill/spill control equipment
(&g~ waste-feed cutoff systems, bypass
systems, and drainage systems) to
ensure that it is in good working order;
(2) The aboveground portions of the
tank system, if any, to detect corrosion
or releases of waste:
(3) Data gathered from monitoring
equipment and leak-detection
equipment (e.g~ pressure and
temperature gauges, monitoring wells) to
ensure that the tank system is being
operated according to its design: and
(4) The construction materials and the
area immediately surrounding the
externally accessible portion of the tank
system including secondary containment
structures (e.g., dikes) to detect erosion
or signs of releases of hazardous waste
(e4* wet spots, dead vegetation);
[Note*—Section 28B.15(c) requires the
owner or operator to remedy any
deterioration or malfunction he finds. Section
208.196 requires the owner or operator to
notify the Regional Administrator within 24
hours of confirming a release. Also. 40 CTR
Pert 302 may require the owner or operator to
notify the National Response Center of a
release.]
(b) The owner or operator must
inspect cathodic protection systems, if
present according to. at a minimum, the
following schedule to ensure that they
an functioning properly:
(1) The proper operation of the
cathodic protection system must be
confirmed within six months after initial
installation, and annually thereafter
and
(2) All sources of impressed current
must be inspected and/or tested, as
appropriate, at least bimonthly (i.e..
every other month).
[Not*—.The practices described in the
National Association of Corrosion Engineers
(MACE) standard. "Recommended Practice
(RP-02-83)—Control of External Corrosion on
Metallic Buried. Partially Buried, or
Submerged-Liquid Storage Systems." and the
American Petroleum Institute (API)
Publication 1632, "Cathodic Protection of
Underground Petroleum Storage Tanks and
Piping Systems.'* may be used, where
applicable, as guidelines in maintaining and
inspecting cstiicdic protection systems.]
(c) The owner or operator must
document in the operating record of the
facility an inspection of those items in
paragraphs (a) and (b) of this section.
(Information collection requirements
contained in paragraphs (aHc) were
approved by the Office of Management and
Budget under control number 2050-0050.)
} 265.196 neeponse to leaks) or spate and
i of leafctoa or uoflt-for-uee tank
A tank system or secondary
containment system from which there
has been a leak or spill, or which is unfit
for use. must be removed from service
immediately, and the owner or operator
must satisfy the following requirements:
fa) Cessation of use: prevent flow or
addition of wastes. The owner or
operator must immediately stop the flow
of hazardous waste into the tank system
or secondary containment system and
inspect the system to determine the
cause of the release.
(b) Removal of waste from tazk
system or secondary containment
system. (I) If the release was from the
tank system, the owner or operator
must within 24 hours after detection of
the leak or, if the owner or operator
demonstrates that that is not possible, at
the earliest practicable time remove as
much of the waste as is necessary to
prevent further release of hazardous
waste to the environment and to allow
inspection and repair of the tank system
to be performed.
(2) If the release was to a secondary
containment system, all released
materials must be removed within 24
hours or in as timely a manner as is
possible to prevent harm to human
health and the environment
(c) Containment of visible reiccses to
the environment The owner or operator
must immediately conduct a visual
inspection of the release and. based
upon that inspection:
(1) Prevent further migration of the
leak or spill to soils or surface water
and
(2) Remove, and properly dispose of.
any visible contamination of the soil or
surface water.
(d) Notifications, reports. (1) Any
release to the environment, except as
provided in paragraph (d)(2) of this
section, must be reported to the
Regional Administrator within 24 hours
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25484
Federal Resistor / VoL 51. No. 134 / Monday. July 14. 1986 / Rules and Regulations
of detection. If the rains* has been
reported pursuant to 40 CFR Part 302.
that report wtU satisfy this requirement
(2) A leak or spill of hazardous watte
that IK
(!) Less than or equal to a quantity of
one (1) pound, and
**'*"* hi accordance
with S 285.193 prior to being returned to
use.
(f) Cartification of major repairs. If
the owner or operator has repaired a
tank f«•*•*• jn •fflfflPJEff**'* with
paragraph (a) of this section, and ti»
repair baa been extensive (e.g»
installation of an internal linen repair of
a ruptured primary containment or
secondary containment vessel), die tank
system must not be returned to service
unless the owner/operator has obtained
a certification by an independent
qualified, registered professional
engineer hi accordance with f 27ttll(d)
that die repaired system is capable of
handling hazardous wastes without
release for the intended life of the
system. This certification must be
submitted to the Regional Administrator
within seven days after returning the
tank* system to use.
[Note*—The Regional Administrator may.
on die basis of any information received that
there is or has been a release of hazardous
waste or hasardoos constituents into the
environment, issue an order under RCRA
•acttons 300«(w). 3008(hU or 70Q3(a) requiring
corrective action or such odier response as
deemed necessary to protect human health or
the environment.]
[Hots—See i 2M.IS(c) for the requirements
necessary to remedy a failure. Also. 40 CFR
Put 302 requiiM the owner or operator to
notify the National Response Canter of a
release of any "reoortable quantity."]
(huonBauon ocilectloo i
contained in paragraphs (d*HQ i
approved by UM Office of Mans.
Budget under control number 2050-0050.)
soils can be practicably removed or
decontaminated as required in
paragraph (a) of this section, then the
owner or operator must close the tank
system and perform post-closure care in
accordance with the closure and post-
closure care requirements that apply to
landfills (S 2B&310) In addition, for the
purposes of closure, post-closure, and
financial responsibility, such a tank
system is then considered to be a
the owner or operator must
(a) At closure of a tank system, the
owner or operator must remove or
decontaminate all waste residues,
contaminated containment system
components (liners, etc.), contaminated
soils, and structures and equipment
contaminated with waste, and manage
them as hazardous waste, unless
S 281.3(d) of this Chapter applies. The
closure plan, closure activities, cost
estimates for closure, and financial
responsibility for tank systems must
meet all of the requirements specified in
Subparts G and H of this Part.
(b) If the owner or operator
demonstrates that not all contaminated
,
meet all of the requirements for landfills
specified in Subparts G and H of this
Part
(c)If an owner or operator has a tank
system which does not have secondary
i^>«t«intt»«tnf that meets the
requirements of S 285.193(b) through (f)
and which is not exempt from the
secondary containment requirements in
accordance with $ 295.193(8). then.
(1) The closure plan for the tank
system must include both a plan for
complying with paragraph (a) of this
section and a contingent plan for
complying with paragraph (b) of this
section.
(2) A contingent post-closure plan for
complying with paragraph (b) of this
section must be prepared and submitted
as part of the permit application.
(3) The coat estimates calculated for
closure and poet-closure care must
reflect the costs of complying with the
contingent closure plan and the
contingent post-closure plan, if these
costs are greater than the costs of
complying with the closure plan
prepared for the expected closure under
paragraph (a) of this section.
(4) Financial assurance must be based
on 'the cost estimates in paragraph (cj(3)
of this section.
(S) For the purposes of the contingent
closure and post-closure plans, such a
tank system is considered to be a
landfill and the contingent plans must
meet ail of the closure, post-closure, and
ffoaprinl responsibility requirements for
landfills under Subparts G and H of this
Part
(Information collection requirements
contained in paragraphs (a He) wen
approved by the Office of Management and
Budget under control number 20SO-OOSO.)
«2MU9a Spe^ requirements tar
IcjnftsDIo of reactive wastes.
(a) Ignitable or reactive waste must
not be placed in a tank system, unless:
(1) The waste is treated, rendered, or
mixed before or immediately after
placement in the tank system so that:
(i) The resulting waste, mixture, or
dissolved material no longer meets the
definition of ignitable or reactive waste
-------
Federal Register / Vol. 51. No. 134 / Monday, July 14. 1986 / Rules and Regulations
25485
under S928L21 or 281.23 of this Chapter;
and
(li) Section 265.17(b) is complied with;
SpOCMl FHQUIfVflMfltS TOT
generators of ber»«en100 and 1.000 kg/
jno aMt acoufiMilets) riasacclous wsiato In
or
(2) The waste is stored or treated in
such a way that it is protected from any
material or conditions that may cause
the waste to ignite or react or
(3) The tank system is used solely for
(b) The owner or operator of a facility
where ignitabla or reactive waste is
stored or treated in tanks must comply
with the requirements for the
maintenance of protective distances
between the waste management area
and any public ways, streets, alleys, or
an adjoining property line that can be
built upon as required in Tables 2-1
through 2-6 of the National Fire
Protection Association's "Flammable
and Combustible Liquids Code." (1877 or
1981). (incorporated by reference, see
J2flo.ll).
J26S.19* Special raqummwits for
(a) Incompatible wastes, or
incompatible waste and materials, must
not be placed in the same tank system.
unless i 285.17(b) is complied with.
(b) Hazardous waste must not be
placed in a tank system that has not
been decontaminated and that •
previously held an incompatible waste
or material, unless § 285.17(b) is
complied with.
}26&200 Waste analysis and Mel teeta.
In addition to performing the waste
analysis required by } 286.13, the owner
or operator must whenever a tank
system is to be used to treat chemically
or to store a hazardous waste that is
substantially different from waste
previously treated or stored in that tank
system: or treat chemically a hazardous
waste with a substantially different
process than any previously used in that
tank system:
(a) Conduct waste analyses and trial
treatment or storage tests (e.g.. bench-
scale or pilot-plant scale tests); or
(b) Obtain written, documented
information on similar waste under
similar operating conditions to show
that the proposed treatment or storage
will meet the requirements of
! 285.194(a).
(Not*.—Section 285.13 requires the waste
analysis plan to include analyses needed to
comply with §5 283.198 and 285.199. Section
285.73 requires the owner or operator to place
the results from each waste analysis and trial
test or the documented information, in the
operating record of the facility.)
(a) The requirements of this section
apply to small quantity generators of
more than 100 kg but less than 1.000 kg
of kafardntif waste in a calendar month.
that accumulate hazardous waste in
tanks for less man 180 days (or 270 days
if the generator must ship the waste
greater than 200 miles), and do not
accumulate over WOO kg on-site at any
(b) Generators of between 100 and
WOO kg/mo hazardous waste must
comply with the following general
operating requirements:
(1) Treatment or storage of hazardous
waste in tanks must comply with
}2U.17(b).
(2) Hazardous wastes or treatment
reagents must not be placed in a tank if
they could cause the tank or its inner
liner to rupture, leak, corrode, or
otherwise fail before the end of its
intended life.
(3) Uncovered tanks must be operated
to ensure at least 60 centimeters (2 feet)
of freeboard, unless the tank is equipped
with a containment structure (e.g« dike
or trench), a drainage control system, or
a diversion structure (e.g.. standby tank)
with a capacity that equals or exceeds
the volume of the top 60 centimeters (2
feet) of the tank.
(4) Where hazardous waste is
continuously fed into a tank, the tank
must be equipped with a means to stop
this inflow (e.g» waste feed cutoff
system or by-pass system to a stand-by
tank).
[Notav— These systems are intended to be
used in the event of a leek or overflow from
the tank due to • system failure (e.g, e
malfunction in the treatment process, e creek
In the teak, etc.).]
(c) Generators of between 100 and
14100 kg/mo accumulating hazardous
waste in tanks must inspect where
present:
(1) Discharge control equipment (e.g»
waste feed cutoff systems, by-pass
systems, and drainage systems) at least
once each operating day, to ensure that
it is in good working order
(2) Data gathered from monitoring
equipment (e.g~ pressure and
temperature gauges) at least once each
operating day f> ensure that the tank is
being operated according to its design:
(3) The level of waste in the tank at
least once each operating day to ensure
compliance with | 28S.l92(c):
(4) The construction materials of the
tank at least weekly to detect corrosion
orieaking of fixtures or seams: and
(5) The construction materials of. and
fhe area immediately surrounding.
discharge confinement structures (e.g..
dikes) at least weekly to detect erosion
or obvious signs of leakage (e.g., wet
spots or dead vegetation).
[Notsw— A» required by i 28S.15(c). the
owner or operator must remedy any
deterioration or malfunction he finds.)
(d) Generators of between 100 and
14000 kg/mo accumulating hazardous
waste in tanks must upon closure of the
facility, remove all hazardous waste
from frtiiksi discharge control equipment.
and discharge confinement structures.
[Note. At closure, as throughout the
operating period, unless the owner or
operator can demonstrate, lo accordance
with 1 2BL3(c) or (d) of this chapter, that any
solid waste removed from his tank is not a
hazardous waste, the owner or operator
becomes a generator of hazardous waste and
must manage it in accordance with all
applicable requirements of Parts 282. 283. and
288 of this chapter.]
(e) Generators of between 100 and
1,000 kg/mo must comply with the
following special requirements for
ignitable or reactive waste:
(1) Ignitable or reactive waste must
not be placed in a tank, unless:
(i) The waste is treated, rendered, or
mixed before or immediately after
placement in a tank so that (A) the
resulting waste, mixture, or dissolution
of material no longer meets the
definition of ignitable or reactive waste
under § 261.21 or § 261.23 of this
Chapter, and (B) § 285.17(b) is complied
with: or
(ii) The- waste is stored or treated in
such a way that it is protected from any
material or conditions that may cause
the waste to ignite or react or
(iii) The tank is used solely for
(2) The owner or operator of a facility
which treats or stores ignitable or
reactive waste in covered tanks must
comply with the buffer zone
requirements for tanks contained in
Tables 2-1 through 2-6 of the National
Fire Protection Association's
"Flammable and Combustible Liquids
Code," (1977 or 1981) (incorporated by
reference, see i 260.11).
(f) Generators of between 100 and
1.000 kg/mo must comply with the
following special requirements for
incompatible wat>ies:
(1, Incompatible wastes, or
incompatible wastes and materials, (see
Appendix V for examples) must not be
placed in the same tank, unless
! 265.17(b) is complied with.
(2) Hazardous waste must not be
placed in an unwashed tank which
previously held an incompatible waste
-------
25486
Federal Register / VoL 51. No. 134 / Monday, July 14. 1986 / Rules and Regulations
or material unless § 285.17{b) is
complied with.
PART 270—EPA ADMINISTERED
PERMIT PROGRAMS: THE
HAZARDOUS WASTE PERMIT
PROGRAM
40 CFR Part 270 is amended aa
follows;
22. The authority citation for Part 270
continues to read as follows:
Authority: Sees. 1008, ant 3008.3007.3019.
and 700* of the Solid Waste Oispoul Act as
amended by the Resource Conservation and
Recovery Act of 1976, as •mended (42 U&C
3805, 9812. 8825, 8927, 8839, and 6874).
23. Section 270.14 is amended by
revising paragraphs (b)(5) and (b)(13) to
read as follows:
} 379.14 Contents of Part Brgenent
• « • « «
(b) • * •
(5) A copy of the general inspection
schedule required by § 264.15(b); include
where applicable, as part of the
inspection schedule, specific
requirements in §5 264.174. 264.193(i),
284.195. 284.228. 284.254, 284.273, and
284.303.
• * « • •
(13) A copy of the closure plan and.
where applicable, the post-closure plan
required by { J 264.112.284118. and
264.197. Include, where applicable, as
part of the plans, specific requirements
in {§284.178. 264.197, 284J28. 264458.
264.280.284 310, and 264.351.
• • • • »
24. Section 270.16. is revised to read
as follows:
8270.1* SpecttlePsrtBWonnaUon
feojujmnenis) for tank systems*
Except as otherwise provided in
$ 284.190, owners and operators of
facilities that use tanks to store or treat
hazardous waste must provide the
following additional information:
(a) A written assessment that is
reviewed and certified by an
independent qualified, registered
professional engineer to the structural
integrity and suitability for haqdUng
hazardous waste of each tank system.
as required under {$264.191 and
264.192:
(b) Dimensions and capacity of each
tank:
(c) Description of feed systems, safety
cutoff, bypass systems, and pressure
controls (e.g*. vents);
(d) A diagram of piping,
. instrumentationv and process flow for
each tank system:
(e) A description of materials and
equipment used to provide external
corrosion protection, aa required under
{284.191(c);
(f) For new tank systems, a detailed
description of how the tank system(s)
will be installed in compliance with
f 264.192 (b),(c).(d), and (e):
(g) Detailed plans and description of
how the secondary containment system
for each tank system is or will be
designed, constructed, and operated to
meet the requirements of J 284.193 (a),
(b), (c). (d), (e). and (0:
(h) For tank systems for which a
variance from the requirements of
§ 264.193 is sought (as provided by
5 J 284.133(8]):
(1) Detailed plans and engineering and
hydrogeoiogic reports, as appropriate.
describing alternate design and
operating practices that will in
conjunction with location aspects.
prevent the migration of any hazardous
waste or hazardous constituents into the
ground water or surface water during
the life of the facility, or
(2) A detailed assessment of the
substantial present or potential hoards
posed to human health or the
environment should a release enter the
environment.
(!) Description of controls and
practices to prevent spills and
overflows, aa required under
{264.194(0); and
(j) For tank systems in which
ignitable, reactive, or incompatible
wastes an to be stored or treated, a
description of how. operating procedures
and tank system and facility design will
achieve compliance with the
requirements of S § 284,198 and 264.199.
(Information collection nqui
contained in paragraphs I a Hi) were
approved by the Office of Management and
Budget under control number 2050-0050.]
§270.72 [Amended].
25. In 5 270.72, paragraph (e) is
amended by adding the following
sentence after the last sentence:
J27Q.72 Chsnojea during Interim statue.
*****
(e) * * * Changes under this section do
not include changes made solely for the
purpose of complying with requirements
of $ 285.193 for tanks and ancillary
equipment.
PART 271— REQUIREMENTS FOR
AUTHORIZATION OF STATE
HAZARDOUS WASTE PROGRAMS
28. The authority citation for Part 271
continues to read as follows:
Authority. Sec. 1006. 2002(a), and 3006 of
the Solid Waste Dispose! Act as amended by
the Resource Conservation and Recovery Act
of 1976, as- amended (42 U.S.C. 6005. 8812(a|.
and 6928).
$271.1 [Amended]
27. In { 271.1. paragraph (j) is
amended by adding the following entry
to Table 1 in chronological order by date
of publication:
TASXE l.-^flMuixnoNS IMPLEMENTING THC
HAZARDOUS AND Sous WASTE AMEND-
MENTS o* 1984
July 14. 198*_ lumnim w«m TH* 51 FB
r;
284.110: p
264.19K- <1
280.110:
280.190.
270.140)1:
284.140;
284.19*
288.140:
28UM:
270.1ft n*270.72W.
HSWA M* B M KMM
amte or ommid
• " (or
(FR Doc. 88-19265 Filed 7-11-86: 8:45 am)
-------
29430 Federal Ragtotar / VoL 51. Na 158 / Friday. August 1S> 1986 / Rules and Regulation*
eNVfRONMEMTAL PROTECTION
.AGENCY
40 CHI Parts 260,261,262,264,295,
270, and 271
[SWH-fm.-30M.1l
tor Hazardous
i Environmental Protection
Agency.
ACTION: Final role: correction.
>: This document correct*
ihical and other errors in a final
laxatdona waste storage and
typo
rule
treatment >»»A my^lantm mtititf \
Resource Conservation and Recovery
Act (RCRA) that appeared in the
Federal Register of Monday, lory 14,
1988. (51 FR 25422).
fOKmmnmn lapQMunori co*r*cn
The RGRA/Superrund Hotline, at (800)
424-9346 (toil tree) or (202) 382-3000 in
Washington. DC or William ]. Kline.
Office of Solid Waste (WH-566), US.
Environmental Protection Agency,
Washington, DC 20480, (202) 382-7917.
sumjMorrMV INPOMUTION: On Inly
14. 1986 (51 FR 29422). EPA issued a
final rale that revised the standards for
hazardous waste storage and treatment
tank systems. Today, EPA is correcting
several typographical and other errors
contained in the July 14 final rale.
Dated: August a. 1986.
|.W.McGrav,
Acting Aatiatmat Administrator for Office of
The following conectioas are made ia
the preamble for FRL 3023-9 (FR Doc.
15266). The Hazardous Waste
Managua ant System: Standards for
Hazardous Waste Storage and
Treatment Tank Systems, published in
the Federal Register on July 14. 1986, (51
FR 25422).
1. On page 25444. column 3. the
second sentence of the first full
paragraph, which reads "Concurrently.
in today's Federal Register. EPA is
proposing revised tank system
standards that would apply to these
generators," is corrected to read as
follows: "In the future. EPA will propose
revised tank system standards uiat
would apply to these generators."
2. On page 25447, column 1. first
paragraph, last line. "55 284.191 and
285.191" is corrected to read "55 284.192
and 285.192."
3. On page 25455. column 3. las*
paragraph, second line. 55 284.ias(b)
and28S.19a(b)" ie corrected to read
"5! 284.198(6) and 285.196(e|."
4. On page 25458, column 2. first foB
paragraph, fifth line. "55 284.196(b) and
265.196(b)M is corrected to read
"51264.196(f) and 265.196(f)."
5. On page 25469. column 2. fin* Ml
paragraph, fourth Una, "June 16. MM" ie
corrected to read "June 28.1985.""
The following corrections are mad* m
the rales for FRL 3023-4 the HazardoaB
Waste Management System: Standard*
for Hazardous Waste Storage ami
Treatment Tank System, published ia
the Federal Register on July 14.1888. (51
FR 25422).
} 2*4.190 [Corrected]
1. On page 25472. column 3. i 264490,
paragraph (b). line 8. the-reference to
"5 284193" is corrected to wad
"5 284.193."
9264.191 [Corrected]
2. On page 25473, column 1. f 264.191.
the last sentence. "Approved by me
Office of Management and Budget i
control number 2050-0050.)" is <
to read "(Information collection
requirements contained in paragraphs
(a) dm (d) were approved by the Office
of Management and Budget under
control number 2050-0050.)"
S 264.192 [Corrected]
3. On page 25473. column 3. 5 248.192,
the word "component" in line 13 of
paragraph (b) is corrected to read
conifmneiits.
§264.193 [Corrected]
4. On page 25474. column 2. 5 264193.
the word "and" at the end of line 5 of
paragraph (a)(3) is removed.
5. On page 25474. column 3. § 264,193.
line 4 of paragraph (e)(l)(iv) is corrected
by inserting the words "the waste is"
after the word "if."
6. On page 25475. column 1. 5 284.193.
the word "Joints" in line 3 of paragraph
(e)(2)(iii) is corrected to read "joints."
7. On page 25473. column 2. 5 284,131
the word "Joints" in line 1 of paragraph
(f)(2) is corrected to read "joints."
8. On page 25476. column 2. 5 284.193,
paragraph (ijfl). the reference to
"! 284.191(aj" ia corrected to read
"! 284.191(b)(5)."
9. On page 25476. column 2. 5 284,193,
paragraph (i)(2). lines 3 through 5 which
reed "operator must either (i) conduct a
leak test as in paragraph (i)(l) or (ii) of
this section develop a schedule and" an
corrected to reed as follows: "operator
must either conduct a leak test as in
paragraph (i}(l) of this section or
develop a schedule and."
1264.196 [Corrected]
10. On page 25477. column 2. 5 264.198.
paragraph (d)(2) is corrected to read as
follows;
(Z) A leak or spill of hazardous waste
ie exaeapted from the requirements of
ttoe paragraph if it is:
(1) Las* than or equal to a quantity of
on* (1) pound, and
(fij Immediately contained and
canned up.
tl. On page 25477, column 2. 5 284.196.
paragraph (d)(3)(iv). the word
a" is corrected to read
12. On page 25478. column 1. f 284.198.
Uaa4, the reference to "section*
30M(w)" 1* corrected to read "sections
1266.192 [Corrected]
IX On page 25478. column 1. 5 284.197.
paragraph (c). line 5 ia corrected by
removing the word* "is not exempt" and
averting in their place, the words "has
not been granted a variance."
f 2*4.192 (Corrected]
14. On page 25480. column 1. 5 265.192.
paragraph (a)(3)(i)(G) is corrected to
read a* follows: "(G) Stray electric
current; and ,".
15. On page 25480, column 1. 5 285.192.
paraanpfc (a)(3)(ii)(A). line 3 is
corrected by deleting the term "etc."
18. On page 25480. column 1. §285.192.
paragraph (a)(3)(ii)(B) line 2 is corrected
by removing the term "etc."
17. On page 25480. column 1. §285.192.
paragraph (a)(3)(ii)(C). line 2 is corrected
to read "insulating joints and flanges."
f 268.193 [Corrected]
18. On page 25480. column 3. 5 285.193.
paragraph (a)(4), line 4 is corrected by
removing the word "age" that appears
after the word "facility."
1& On page 25481. column 2. 5 285.193.
paragraph (e)(2)(ii), line 5 is corrected by
in earring me words "excess capacity"
after the word "sufficient"
20. On page 25481. column 3. 5 285.193.
paragraph (g). line 8 is corrected by
removing the number "(It." lowercasing
"mat" and making the te~< continuous
after the colon.
21. On page 25481. column 3. 5 285.193.
paragraph (g). line 14 is corrected by
itaUcJimg the word "or" and removing
the number "(2)."
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Federal Register / VoL 51. No. 158 /Friday, August 15, 1986 / Rules and Regulations 294
22. Oa page 25483, column 1. $ 285.193*
paragraph (i)(l), Una 3, the reference to
"5 28S.191(«r ia corrected to read
"5 2B5.19I(b)(5)."
J270.H (Carraeted)
23. On page 25488, column 1. J 270.16.
paragraph (a), Una 4 is corrected by
inserting the word "as" after the word
"engineer."
24, On page 25480, column 2. J 270.16,
paragraph (e). line 4. the reference to
§ 284.191(0)" ia corrected to read
"5 284.192{a)(3)(ii)."
5271.1 [Corrected]
25. On page 25488, column 3. J 271.1
Table 1 is corrected by inserting the
page number "25422" under the heading
of "Federal Register Reference."
(FR Doe. 86-18458 Filed 8-14-8* &45 «n|
-------
OSWER Policy Directive
No. 9483.00-2
APPENDIX C
Unsaturated Zone Monitoring Instruments
-------
OSWER Policy Directive
No. 9483.00-2
APPENDIX C
UNSATURATED ZONE MONITORING INSTRUMENTS
Cl. SOIL SAMPLER MONITORING INSTRUMENTS
C1.1 Soil Samplers
Numerous soil samplers are available that extract both cores and soil
chips. The samples obtained by these samplers may analyze both the solid
and pore water portion of the sample. Both the solids and the pore water
may be analyzed for these samples. Soil sampling is a destructive
technique, however, since it does not allow repeated samples at the same
location and also could create pathways for waste to migrate to a greater
depth at a faster speed than predicted. Therefore, soil sampling is not
recommended as an unsaturated zone monitoring method for hazardous waste
tank systems.
C1.2 Pore Mater Samplers
Pore water samplers are used to extract interstitial water from
sediments during movement through the unsaturated zone. They are
effective during unsaturated flow in soils or sediments in which most
liquids move through the pore spaces. Samples are drawn into the
Instruments through porous ceramic, teflon, or aluminum cups or tubing
that become continuous with the pore spaces of the soil when properly
Installed. When a negative pressure is applied, pore water flows into
the cup and a sample can be withdrawn. O'her designs use absorbrnt
fibers to draw pore water from the soil to the sampling instrument.
C-l
-------
OSWER Policy Directive
No. 9483.00-2
Cl.2.1 Limitations of Pore Water Samplers
A primary limitation of pore water sampling Is the lag time for
analysis of the pore fluid. The hazardous waste tank system regulations
require interstitial monitoring devices to detect a leak within 24 hours
(or at the earliest practicable time If the owner/operator can
demonstrate to the Regional Administrator that the existing detection
technologies or site conditions will not allow detection within 24
hours). If a significant lag time such as 14 to 30 days exists before
chemical analysis, the monitoring system may not qualify for a variance
because of the possibility that waste constituents may contaminate the
ground water before they are detected.
To Improve detection of releases from hazardous waste tank systems,
tank system owners or operators might consider using tracer chemicals
which can be analyzed quickly. Fluorescent dyes detected by ultraviolet
lights, radioactive tracers, and volatile chemicals for vapor monitoring
devices may be appropriate tracers. As part of the demonstration for the
variance, the tank owner must show that the waste constituents or
sediments will not inhibit the property of the tracer being analyzed.
In order to be effective, pore water samplers must be operated under
the range of conditions for which they were designed. During the
demonstration for a variance, the tank owner or operator must first
specify the ranges of potential matrices, soil moisture, pore size, and
grain size in the unsaturated zone at the site. Seco..d, the owner or
C-2
-------
OSWER Policy Directive
No. 9483.00-2
operator must show that the monitoring instruments are effective under
the site specific conditions to which they will be subjected. Data from
bench scale lab tests, the technical literature, and the manufacturer may
be used to illustrate this Instrument effectiveness. (See Everett 1985
for operating ranges of suction lysimeters.) The demonstration should
include bench scale tests for both a low and high soil moisture content.
Proper installation is another critical factor in the performance of
these systems. The tank owner/operator should be prepared to document
that the installation procedures followed are compatible with operation
of the instruments. Table C-l summarizes common problems in the use of
suction-type samplers.
For an effective monitoring network, suction pore-water samplers
should be spaced neither too close together nor too far apart. The
sampling radius or radius of influence Is the area from which the
instrument can draw pore water. Morrison and Szecsody (1985) calculated
that for .Iys1meter diameters of 2.2 to 10.1 cm, the maximum radius of
influence ranged from 43 cm for the smallest lysimeter to 92 cm for the
largest lysimeter 1n fine soil, since fine soils have the greatest radius
of sampling influence. Morrison and Szecsody also determined that a
lysimeter with a diameter of 5.1 cm has a sampling radius of less than 10
cm in coarse soils, and about 65 cm in fine soils. These types of
calculations will he necessary to determine the number and placement of
lysimeters (Morrison 1986; Morrison 1983).
C-3
-------
1878*
Table C-l Factors Limiting the Operation of Suction-Type Sampling Devices
Soil physical properties
Hydraulic factors
Cup waste water
Climatic factors/
interactions
o
i
1. Contact between cup and
soils difficult to maintain
in very coarse textured
soils (e.g., gravels).
2. In highly structured soils
and fractured material, the
composition of fluid in
cracks may differ from that
in pores. Cups sample only
from small pores.
Consequently, cup samples
may not be representative
of "average fluid.
Samples cannot be
obtained when soils
dry to the point that
soil-water suction is
great enough to allow
air to enter cups when
applying vacuum.
For very wet conditions,
fluid will move more
rapidly in layer pores
and cracks. Because
of time lag, sample for
cups may not be
representative.
1. Solids moving with fluid
may plug cups.
2. Bacteria nay plug cups.
3. Trace metals may be
attenuated during flow
through cups.
4. Sorption of Nt^-N nay occur.
5. Sorption of some organics
(e.g., chlorinated
hydrocarbons) may occur.
In frozen soils, the
tension of unfrozen water
is greater than air entry
value of cups.
In freezing-thawing soils,
the unit may shift in the
profile and lose contact.
Source: (Everett 1984)
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Lysimeter placement is affected by both the sampling radius of the
instrument and the lateral spreading of waste through the unsaturated
zone. Because of lateral spreading, a lysimeter with a radius of 22 cm
can effectively sample a larger area, since a point-source leak will flow
and diffuse down through the unsaturated zone.
C1.3 Gravity-flow Samplers
In saturated or near-saturated flow conditions, suction-type samplers
will not provide an accurate assessment of water quality in the
unsaturated zone because most pore water or waste moves through
macropores or large Interconnected pore spaces in a rapid pulse.
Suction-type samplers could easily miss the fluid in macropores
because the porous cup is a continuation of the micropore spaces of the
soil, which contain slow moving pore water. Therefore, free drainage or
gravity-flow samplers, should be used to sample macropores (Hornby 1986).
In well structured soils, macropore flow is particularly important
because it accounts for the majority of water flow and flow of chemical
constituents that can be lost from the soil by leaching (Shaffer 1979).
Gravity-flow samplers physically collect pore water for later
analysis as the water flows down through the unsaturated zone.
Cl.3.1 Limitations of Gravity-Flow Samplers
For free drainage or gravity-flow samplers, the biggest limitation is
that the flow may miss the sample collector. For this reason, it is
useful to >:ave as large a collecting pan as possible or to have a large
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number of samplers. In addition, if the saturated flow diminishes to
unsaturated flow, a sample cannot be taken and alternate means of
sampling should be In place.
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C2. VAPOR DETECTION SAMPLING METHODS
C2.1 Vapor Detectors
Many hazardous chemicals are volatile. This property allows them to
diffuse very quickly as gases through the unsaturated zone. A vapor well
or vapor detector In an existing well may allow early detection of
release of volatile chemicals on a continuous basis. These monitors
allow continuous monitoring and may be established as networks with
several monitors sending signals to a single data acquisition system.
C2.1.2 Limitations of Vapor Detectors
The two primary limitations governing the actions of vapor detectors
are their compatibility with the wastes and their ability to distinguish
background concentrations from a bona fide leak. To avoid the former
problem, the waste or waste constituent of interest should exhibit a good
response factor with the device. The latter is a more challenging
problem especially when the constituent of Interest is at a low
concentration. What will then face the applicant is how to determine
that a slight Increase in detected concentration is an actual leak. For
the most common of these devices, a certain level of "total" detection
for a specific parameter Is set and an alarm goes off if it is exceeded.
If a site has an elevated background level to begin with, then the
addition of a few more parts per million of detectable compound may not
matter. If on the other hand the waste is basically a r.ient eolvent,
then its release will result in a fairly concentrated front that the
device should have little difficulty in detecting.
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C3. NON-SAMPLING (INDIRECT) METHODS
C3.1 Salinity Sensing (Indirect) Methods
For polar or ionic liquid wastes, electrical resistivity or salinity
/
sensors might be effective in detection of a release in the unsaturated
zone. Common instruments that could detect changes in these physical
properties are the salinity sensor, the electrical conductivity probe,
and the four probe method. All of these methods measure either the
electrical conductivity or resistivity of the soil and relate this to
salinity.
C3.1.2 Limitations of Salinity Sensors
Salinity sensors should be calibrated to the natural conductivity or
resistivity of the site. This may require testing of each layer of
sediment. In addition, a variable soil moisture content may cause
inaccurate readings by causing variation in the soil resistivity with
time. As with other non-sampling methods, means should be available to
draw a sample for analysis after the alarm is activated.
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C4. MONITORING CHANGES IN MOISTURE CONTENT
OR FLUX IN THE UNSATURATED ZONE
A broad range of monitoring tools are used to measure changes in the
amount of water moving through the unsaturated zone. If run-on to the
tank system site is controlled, an increase in the volume of pore water
probably indicates a leak. The following methods are used to measure
changes in moisture in the unsaturated zone (flux):
Gravimetric
Neutron Moisture Logging
Gamma Ray Attenuation
Tensiometers
Hygrometer/Psychrometer
Heat Dissipation Sensor
Res istor/Capacitor Type sensors
These methods (Everett 1982) may be useful for indicating a leak event,
but the ability to withdraw samples for analysis should be designed into
the overall monitoring system to differentiate between leaks and rainfall
surges. Instruments or wells used for monitoring of soil moisture
content should be demonstrated to be within the sampling radius of the
instruments.
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C5. SELECTED REFERENCES
Amoozegar, A.; Fuller, W. H.; and Warrlck, A. W. 1986. Movement of
selected organic liquids Into dry soils. Hazardous Waste and Hazardous
Materials, Vol. 3, No. 1, pp. 29-41.
Anderson, 0. C. and Brown, K. W. 1983. Effects of organic solvents on
the permeability of clay soils. Cincinnati, Ohio: U.S. Environmental
Protection Agency.
Barber, A. J. and Braids, 0. C. 1982. Application of a portable organic
vapor analyzer in ground-water contamination Investigations. In
Proceedings of the second national symposium on aquifer restoration and
ground water monitoring, ed. D. M. Nellsen, pp. 129-132. Columbus,
Ohio: National Water Well Association.
Bear.J. 1979. Hydraulics of groundwater. New York., N.Y.: McGraw-Hill
Book Company.
Bouwer, H. 1978. Groundwater hydrology. New York, N.Y.: McGraw-Hill
Book Company.
Bouwer, H. and Rice, R. C. 1984. Hydraulic properties of stony vadose
zones. Ground Water. 22(6):696-705.
Cartwright, <.; Johnson, T. M.; and Schuller, R. M. 1981. Monitoring of
leachate migration in the unsaturated zone in the vicinity of sanitary
landfills. Ground-Water Monitoring Review. (Fall Issue) pp. 55-63.
Century Systems of Foxboro. Portable organic vapor analyzer model
OVA-128, instruction and service manual (2R900AC). Foxboro Company,
South Norwalk, Conn.
Chlou, C. T.; Porter, P. E.; and Schmeddlng, D. W. 1983. Partition
equalibria of nonionic organic compounds between soil organic matter and
water. Environ. Sc1. and Technol.. 17(4):227-297.
Chlou, C. T. and Snoup, T. D. 1985. Soil sorptlon of organic vapors and
effects of humidity on sorptive mechanism and capacity. Environ. Sci.
and Technol.. 19(12):1196-1200.
Clark, A. E.; Lataille, M.; and Taylor E. L. 1983. The use of a
portable PIP gas chromatograph for rapid screening of samples for
purqeable organic compounds in the field and in the lab. Lexington,
Mass.: U.S. Environmental Protection Agency.
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Clarkson, W. W.; Friedman, G. S.; Jewell, W. J.; Loehr, R. C.; and Novak,
J. D. 1979. Land application of wastes. Vol. II. New York, N.Y.: Van
Nostrand Reinhold Company.
Clay, P. F. and Spittler, T. M. The use of portable Instrumentation in
hazardous waste site characterizations. In Proceedings of the national
conference on management of uncontrolled hazardous waste sites.
Clifford, W. S.; Fitch; L. G.; and Spittler, T. M. 1986. A new method
for detection of organic vapors 1n the vadose zone. Lexington, Mass.:
U.S. Environmental Protection Agency.
Concawe. Behavior of oil spills In the subsurface.
Crawley, W.; Hornby, W. J.; and Zabdk, J. D. 1986. Factors which
affect soil-pore liquid: a comparison of currently available samplers
with two new designs. Ground-Hater Monitoring Review. (Spring issue)
pp. 61-66.
Eklund, 8. 1985. Detection of hydrocarbons In qroundwater by analysis
of shallow soil gas/vapor. Washington, D.C.: American Petroleum
Institute (Publication No. 4394).
Evans, R.; Glaccum, R.; McMllllon, L.; and Noel, M. 1983. Correlation
of geophysical and organic vapor analyzer data over a conductive plume
containing volatile organlcs. In Proceedings of the third national
symposium on aquifer restoration and ground-water monitoring, ed. D. M.
Nielsen, pp. 421-427.
Everett, L. G.; Wilson, L. G.; and Hoylman, E. W. 1983. Vadose zone
monitoring for hazardous waste sites. EPA-KT-82-018(R). Las Vegas,
Nev.: U.S. Environmental Protection Agency.
Ewlng, G. W. 1975. Instrumental methods of chemical analysis. New
York, N.Y.: McGraw-Hill Book Company.
Fuller, W. H.; Schramm, M.; and Warrlck, A. W. 1986. Permeabilty of
soils to four organic liquids and water. Hazardous Waste & Hazardous
Materials. 3(l):21-27.
Gerhardt, R. A. 1984. Landfill leachate migration and attenuation in
the unsaturated zone In layered and nonlayered coarse-grained soils.
Ground-Water Monitoring Review (Spring issue), pp. 56-65.
Green, W. J.; .lones, R. A.; Lee, G. F.; and Pallt, T. 1983. Interaction
of clay soils with water and organic solvents: implications for the
disposal of hazardous wastes. Environ. Sci. and Technol., 17:278-282.
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Grob, R. L. and Kanatharana, P. 1983. Gas chromatographic study of
hydrocarbons adsorbed on soils. J. Environ. Sci. Health, pp. 59-77.
Gschwend, P. M. and Swallow, J. A. 1983. Volatilization of organic
compounds from unconflned aquifers. In Proceedings of the third national
symposium on aquifer restoration and ground-water monitoring, ed. 0. M.
Nell sen, pp. 327-333.
Harris, H. E.; Laltlnen, H. A. 1975. Chemical analysis. New York,
M.Y.: McGraw-Hill Book Company.
Hlllel, 0. 1980. Fundamentals of soil physics. New York, N.Y.:
Academic Press.
Horvltz, L. 1985. Geocnemlcal exploration for petroleum. Science.
229(4716):821-827.
Hounslow, A. W. 1983. Adsorption and movement of organic pollutants.
In Proceedings of the third national symposium on aquifer restoration and
ground-water monitoring, ed. D. M. Nellsen, pp. 334-346.
Hydro-fluent, Inc. Vapor detection monitoring system. Vernon, Calif.
Johnson, T. M. 1982. Unsaturated zone monitoring techniques.
Springfield, 111.: Illinois State Geological Survey.
Klinger, G. S.; Nadeau, R. J.; and Stone, T. S. 1986. Sampling soil
vapors to detect subsurface contamination: a technique and case study.
Edison, N.J.: U.S. Environmental Protection Agency.
lataille, M. M.; Parks, P.; Slscanaw, R. J.; Spittler, T. M. 1983.
Correlation between field GC measurement of volatile organlcs and
laboratory confirmation of collected field samples using the GC/MS.
Lexington, Mass.: U.S. Environmental Protection Agency.
Mahllum, B. C.; Moh1udd1n, S. H.; and Merrill, L.G. 1982. Organic
compounds in soils, sorptlon. degradation, and persistence. Ann Arbor,
M1ch.: Ann Arbor Publishers, Inc.
Malot, J. and Wood, P. R. Low cost, site specific, total approach to
decontamination. Dorado, Puerto R1co: Terra Vac, Inc.
Marrln, D. L. and Thompson, G. M. 1984. Remote detection of volatile
organic contaminant- in ground water via shallow gas sampling. In
Proceedings of the petroleum hydrocarbon* and organic chemicals in ground
water conference.
rtJ.S Environmental Protection
Region V, Library
230 South Dearborn Street
Chicago, Illinois 60604-"' .,,,-^^i C'12
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Marrln, D. L. 1985. Delineation of gasoline hydrocarbons in ground
water by soil gas anal-ysis. In Proceedings of the 1985 hazardous
materials west conference.
Mehran, M.; Nimmons, M. J.; and Sirota, E. B. Delineation of underground
hydrocarbon leaks by organic vapor detection.
Radian Corp. Field sampling protocol, vapor ventilation program.
Austin, Texas.
Spittler, T. M. 1980. Use of portable organic vapor detectors for
hazardous waste site investigations. In Proceedings of the national
conference on management of uncontrolled hazardous waste sites.
Spittler, T. M. Field measurement of PCB's in soil and sediment using a
portable gas chromatograph. Sampling and Monitoring, pp. 105-107.
Thompson, G. M. and Lappala, E. G. Detection of ground-water
contamination by shallow soil gas sampling in the vadose zone.
Tinsley, I. J. 1979. Chemical concepts in pollutant behavior. New
York, N.Y.: W1ley-Intersc1ence, John Wiley & Sons.
Universal Sensors and Devices. Vadose zone monitoring of gasoline and
diesel in soil. Chatsworth, Calif.
USEPA. 1981. U.S. Environmental Protection Agency, National Enforcement
Investigations Center. NEIC manual for groundwater/subsurface
investigations at hazardous waste sites. Denver: U.S. Environmental
Protection Agency, EPA-330/9-81-002.
USEPA. 1983 U.S. Environmental Protection Agency, Environmental
Monitoring System Laboratory. Vadose zone monitoring for hazardous waste
sites. Las Vegas, Nevada: U.S. Environmental Protection Agency.
USEPA. 1986. U.S. Environmental Protection Agency, Hazardous Waste
Engineering Research Laboratory. Underground tank leak detection
methods: a state of the art review. Cincinnati, Ohio: U.S.
Environmental Protection Agency.
Wilson, L. G. 1980. Monitoring in the vadose zone, a review of
technical elements and methods. EPA-600/7-80-134. Las Vegas, Nevada:
U.S. Environmental Protection Agency.
Wilson,. L. G. 1981. Monitoring In the vadose zone part I: storage
changes. Groundwater Monitoring Review, (Fall issue), pp. 32-41.
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Wilson, L. G. 1982. Monitoring in the vadose zone part II. Groundwater
Monitoring Review. (Winter issue), pp. 31-42.
Wilson, L. G. 1983. Monitoring in the vadose zone part III.
Qroundwater Monitoring Review. (Winter issue), pp. 155-166.
US Environmental Protection Agency
Reg on V. Library
23J South Dearborn Street
Chicago.
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