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myriad of potential treatment process trains.   Instead, an  over-
view of important considerations is presented based upon  infor-
mation provided throughout this manual.

     In general, when both inorganic and organic contaminants
are present, the inorganics generally should be removed first  to
minimize effects on subsequent processes.  Examples of such
effects include metal toxicity to biological processes and  cor-
rosion, scaling, and inerts accumulation during carbon regenera-
tion.  Information on metals toxicity to biological processes  is
included in Appendix E and in a report by Pajak, et al. (10).

     The processes most suitable for inorganics removal are dis-
cussed in Section 6.6.2 and are illustrated in  Figures 6-5, 6-6,
6-7, and 6-8.  These processes include chemical precipitation,
chemical oxidation and reduction, neutralization, filtration,
and sedimentation.  In addition to providing inorganics removal,
chemical precipitation and oxidation processes  also could effect
some pretreatment of organic compounds.  This is especially true
for chemical oxidation with ozone or hydrogen peroxide and  is  a
factor which must be considered when chemical dosage require-
ments are determined.  Handling of residues generated by  these
processes is discussed in Sections 5.4 and 6.6.2.

     The two leading processes for treating organics are  biolog-
ical treatment and activated carbon adsorption.  Whether  these
processes should be used separately or in combination depends
upon leachate characteristics.  If the organics consist solely
of biodegradable compounds, then biological treatment alone
would suffice; although a subsequent solids removal polishing
step could be necessary in some situations.

     A leachate containing degradable organics  only is not
expected to occur frequently; consequently, the two processes
most frequently will be used in series.  They may be arranged
with the biological process preceding granular  activated  carbon
(GAG) to remove degradable organics and reduce  the organic  load
to the GAG process which then is used for refractory organics
removal and polishing.  To.avoid GAG column plugging a sedimen-
tation or filtration step should be located between the biolog-
ical process and GAG.  This treatment sequence  could be applied
when organics content is high and refractory but not when toxic
organics are present.

     A second arrangement would be to have GAG  preceding  biolog-
ical treatment.  This sequence would be used when toxic organics
would interfere with the biological process.  The GAG could be
operated to leak the maximum concentration of organics that the
biological system could tolerate and still meet performance
requirements.  This results in a longer sorption cycle for  the
carbon.
                               6-41

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     Approaches to treatment of the organic component of  leach-
ates have been discussed in Section 6.6.1 and process train
schematics given in Figures 6-2, 6-3, and 6-4.  One additional
process train which merits consideration is shown schematically
in Figure 6-9.  This biophysical treatment approach combines
simultaneous biological (activated sludge) and powdered acti-
vated carbon treatments in the biological process reactor.  This
approach is simpler than the previously described sequential
carbon-biological treatments and has the potential of achieving
comparable effluent quality.  Potential advantages include the
use of less costly carbon (powdered vs. granular) and minimiza-
tion of physical facilities required.  Spent carbon-biological
sludge can be regenerated or dewatered and disposed directly.
However, if the latter approach is considered, it is necessary
to include cost for disposal of toxics-laden carbon when  making
economic comparisons.

     Most of the considerations necessary for development of a
process train for treatment of leachates containing both  organic
and inorganic contaminants have been previously discussed in
Sections 6.6.2 and 6.6.3.  The components discussed in these
previous sections must be assembled in a manner so as to  opti-
mize the treatment process train for the leachate at hand.
Probably the most important aspect is proper sequencing of unit
processes to achieve an optimum result for a given situation.
Careful attention should be paid to proper interfacing of com-
ponents discussed in Sections 6.6.2 and 6.6.3 (e.g., pH control
may be necessary from one treatment component to the next).
With these cautions in mind, the reader is referred to these
earlier sections to derive a basis for formulating conceptual
process trains for mixed (organic and inorganic) component
leachates.

6.7. REFERENCES

 1.  U. S. Environmental Protection Agency.  Water Quality
     Criteria Documents Availability.  Federal Register,45
     (231): 79318-79379.  U. S. Government Printing Office,
     Washington, D.C. November 28, 1980.

 2.  U. S. Environmental Protection Agency.  Proposed Ground
     Water Protection Strategy.  U. S. Environmental Protection
     Agency, Washington, D.C. November 18, 1980.

 3.  McDougall, W. J., S. D. Cifrulak, R. A. Fusco, and R. P.
     O'Brien.  Treatment of Chemical Leachate at the Love Canal
     Landfill Site.  In: Proceedings of the Twelfth Mid-Atlantic
     Industrial Waste Conference, Bucknell University, Lewis-
     burg, Pennsylvania, 1980.  pp 69-75.
                               6-42

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 4.   McDougall,  W.  J.,  R.  A.  Fusco, and R. P. O'Brien.  Con-
     tainment and Treatment of the Love Canal Landfill Leachate.
     Journal of  the Water  Pollution Control Federation, 52(12):
     2914-2924,  1980.

 5.   Barth,  E.  F. and  J.  M. Cohen.  Evaluation of Treatability
     of Industrial  Landfill Leachate. Unpublished Report. U. S.
     Environmental  Protection Agency, Cincinnati, Ohio.  Novem-
     ber 30, 1978.

 6.   Pajak,  A.  P.,  A.  J.  Shuckrow, J. W. Osheka, and S. C.
     James.   Concentration of Hazardous Constituents of Contami-
     nated Groundwater.  Proceedings of the Twelfth Mid-Atlantic
     Industrial  Waste  Conference, Bucknell University, Lewis-
     burg, Pennsylvania.  July, 1980. pp 82-87.

 7.   Shuckrow,  A. J.,  A.  P. Pajak, and J. W. Osheka.  Concen-
     tration Technologies  for Hazardous Aqueous Waste Treatment.
     EPA-600/2-81-019,  U.  S.  Environmental Protection Agency,
     Cincinnati, Ohio.   February, 1981.

 8.   Pajak,  A.  P.,  A.  J.  Shuckrow, J. W. Osheka, and S. C.
     James.  Assessment of  Technologies for Contaminated Ground-
     water Treatment.   Proceedings of the Industrial Waste
     Symposia,  53rd. Annual WPCF Conference, Las Vegas, Nevada.
     September,  1980.

 9.   Shuckrow,  A. J.,  A.  P. Pajak, J.W. Osheka, and S. C. James.
     Bench Scale Assessment of Technologies for Contaminated
     Groundwater Treatment.  Proceedings of National Conference
     on Management of  Uncontrolled Hazardous Waste Sites,
     Washington, D.C.  October, 1980.  pp 184-191.

10.   Pajak,  A.  P.,  E.  J.  Martin, G. A. Brinsko, and F. J. Erny.
     Effect of Hazardous  Material Spills on Biological Treatment
     Process.  EPA-600/2-77-239, U. S. Environmental Protection
     Agency, Cincinnati,  Ohio, 1977.  202 pp.
                               6-44

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                            SECTION 7

                           MONITORING
7.1  GENERAL DISCUSSION

     This section is intended to point out considerations which
are important in the design of a monitoring program to support
hazardous waste leachate management efforts.  It is not  intended
to be a rigorous exposition of how monitoring should be  accom-
plished nor does it address aspects of monitoring which  are not
directly related to leachate management.  Numerous analytical
standards and texts which detail many of the specific aspects
are available to guide development procedures.  Moreover, the
user should recognize that leachate monitoring, as discussed
herein, probably will be carried out as one element in an over-
all disposal site monitoring program which will encompass addi-
tional considerations and objectives.

     Leachate monitoring is needed to characterize aqueous
wastes which result from disposal of hazardous materials at per-
mitted sites, to develop data necessary for design and operation
of leachate treatment facilities, to evaluate the effectiveness
of leachate treatment systems, to assure compliance with dis-
charge permits, and to assure personnel safety in leachate
handling and treatment operations.

     A leachate monitoring program in the broadest sense could
encompass the following objectives:

     1)  Define materials placed within the disposal site,

     2)  Determine the types of compounds in the leachate and
         their concentration ranges,

     3)  Determine the variation of concentrations as a  function
         of time,

     4)  Determine the factors which influence movement  and
         concentrations,

     5)  Determine the rate and direction of migration,

     6)  Establish leachate treatment process alternatives,


                               7-1

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     7)  Establish leachate treatment process operating ranges,

     8)  Monitor leachate treatment process effectiveness,

     9)  Monitor leachate containment effectiveness,

    10)  Assure safety in leachate handling and processing
         operations, and

    11)  Determine conformance to or accuracy of a leachate
         forecasting procedure.

The above items are not of equal concern in the current context.
Moreover, some encompass aspects of disposal site management
which are broader than leachate management alone.  The relative
importance and potential usefulness of these objectives from a
leachate management viewpoint are discussed subsequently  in this
section.

     Monitoring can be carried out at several locations in the
leachate management system:

     1)  Wastes received for disposal,

     2)  In-situ monitoring for off-gas generation and leachate
         formation,

     3)  Collected leachate,

     4)  Leachate treatment system,

     5)  Treatment system effluent and residues, and

     6)  Areas of potential safety hazards.

Reasons  for monitoring at the locations noted above,  and  the
types  of information needed are described later in this section.

     Monitoring data are expected to be used for a variety of
purposes.  Data obtained on incoming wastes will permit hazard-
ous waste disposal site operators to decide whether or not to
accept the wastes.  It also will provide an inventory of  mate-
rials.   Given such an inventory, the site operator can have a
basis  for predicting the range of compounds likely to be  en-
countered in resultant leachate.  Concentrations of certain con-
taminants in the leachate might be able to be estimated based
upon the amount and type of materials disposed.  This aspect is
important at new sites prior to the time of leachate  generation.
Moreover, such information can provide a basis  for  initial
selection of parameters to be measured in subsequent  leachate
characterization efforts.
                                7-2

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     In-situ monitoring data can be used to determine how the
leachate is formed and how it moves through the disposal site.
Furthermore, it may be possible to use in-situ data to char-
acterize the types and concentrations of compounds in the
leachate collection system.  Monitoring collected leachate is
one of the most important aspects of leachate monitoring.  The
information gained provides a baseline for treatment system in-
fluent characterization; thus facilitating decisions regarding
treatability (or necessary treatability studies) and optimum
treatment/disposal operating ranges.

     Other important monitoring data obtained will be that from
treatment process operations.  Such data are necessary to assure
proper functioning of treatment system components, to establish
treatment system effectiveness, and to assure compliance with
discharge permit requirements.

     Manual users are reminded that the discussion of monitoring
herein emphasizes leachate.  While other aspects are important
in overall disposal site management, e.g. monitoring of the
surrounding environs, other technical resource documents are
expected to deal with these topics in greater detail.

7.2  MONITORING PROGRAM DESIGN

     To a large extent, design of a leachate monitoring program
will be highly site specific.  However, there are certain gen-
eral elements which will be common to all monitoring programs.
The following discussion addresses these general considerations.
Although it is recognized that monitoring of some gaseous and
solid materials may be involved in the program, the primary
focus herein is on liquid streams.

7.2.1  Parameters To Be Measured

     Selection of parameters to be measured is the initial step
in development of a monitoring program.  Analytical costs can be
significant.  Therefore, a major objective should be to minimize
the number and types of analysis performed while still gener-
ating data sufficient to satisfy the objectives of the moni-
toring program.

     Substances of potential concern in hazardous waste leachate
include:

     1)  soluble, oxygen demanding organics;

     2)  soluble substances that cause tastes and odors in water
         supplies;

     3)  color and turbidity;
                               7-3

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     4)   nutrients such as nitrogen, phosphorus, and carbon;

     5)   toxic organic and inorganic substances;

     6)   refractory materials;

     7)   oil, grease, and immiscible liquids;

     8)   acids and alkalis;

     9)   substances resulting in atmospheric odors;

    10)   suspended solids; and

    11)   dissolved solids.

     Monitoring for purposes of leachate characterization  should
be sufficient to provide data adequate to facilitate decisions
on the best approaches to leachate  treatment/disposal.  Re-
quirements for monitoring of effluents from treatment operations
prior to discharge must be rigorous enough to permit assessment
of the quality of the discharge so  as to assure a minimum  of
environmental degradation and compliance with governmental  reg-
ulations.

     The selection of parameters for other monitoring objectives
need only be rigorous enough to assure that effluent quality  can
be maintained within discharge permit specifications.   It  is  in
this latter area that the opportunity exists to use relatively
inexpensive analyses, and indicator and surrogate parameters  to
obtain quick and accurate information which can be used to con-
trol treatment processes and disposal site operations.  For ex-
ample, TOC (total organic carbon) provides a rapid, relatively
inexpensive measure of gross organic content of an aqueous
stream.   Such a measurement may be  sufficient for many  purposes
as opposed to more expensive organic compound identification
measures.

     Parameters which should be considered for  inclusion  in haz-
ardous waste leachate monitoring program are as follows:

               1.  temperature;

               2.  electrical conductivity;

               3.  turbidity;

               4.  settleable solids;

               5.  suspended  solids;

               6.  total dissolved  solids;

                               7-4

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               7.   volatile solids;

               8.   oils,  greases and immiscible liquids;

               9.   odor;

              10.   pH;

              11.   Oxidation Reduction Potential (ORP);

              12.   acidity;

              13.   alkalinity;

              14.   Biochemical Oxygen Demand (BOD);

              15.   Chemical Oxygen Demand (COD);

              16.   Total Organic Carbon (TOC);

              17.   specific organic compounds;

              18.   heavy metals;

              19.   other specific inorganic compounds;

              20.   nitrogen and phosphorus compounds;

              21.   dissolved oxygen;

              22.   volatile organic acids;

              23.   flow; and

              24.   toxicity.

Selection of a particular parameter set will be dependent upon
monitoring objectives as well as upon factors specific  to a
given site and leachate management program.  Different  parameter
sets might be chosen to support leachate characterization ef-
forts than for purposes of treatment process operation  or for
effluent discharge monitoring.  As an example, TOC measurements
may be more reasonable than BOD measurements for hazardous waste
leachate characterization and process control purposes  since the
TOC measurement is rapid and the leachate may be toxic  to the
organisms necessary to conduct of the BOD test.  On the other
hand, the BOD test would provide more information on the biode-
gradability of the leachate.  Thus, parameters must be  chosen
judiciously for the specific purpose and situation.

     Additional information on monitoring parameters can be
found in tests and handbooks (1, 2).

                               7-5

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7.2.2  Analytical Considerations

     Good analytical procedures are vital to an effective mon-
itoring program.  Basic references for wastewater analytical
procedures are contained in the EPA Methods for Analysis of
Water and Wastes (3), Standard Methods (4), ASTM Standards  (5),
the EPA Handbook for Analytical Quality Control (6) and other
EPA guidance documents (7, 8, 9).  The reader is referred to
these basic reference works for details since a thorough dis-
cussion of analytical procedures is beyond the scope of this
document.

     Often, there is a choice among several standard methods for
measurement of a particular parameter.  Among the factors to be
considered in selection of an analytical method are:

     •  sensitivity, precision and accuracy required;

     •  interferences;

     •  number of samples to be analyzed;

     •  quantity of sample available;

     •  other determinations to be made on the sample;

     •  analytical turn-around time; and

     •  analytical costs.

Since leachate  is a complex system of variable composition,
there is high potential for numerous interferences  in many  of
the chemical and biological determinations.  This aspect should
be given particular attention when selecting an analytical
method.

7.2.3  Sampling

     Proper sampling is critical to any monitoring  program  since
the validity of analytical results relies upon the  validity of
the samples analyzed.  In order to assure valid samples, atten-
tion must be paid to obtaining samples which are truly repre-
sentative of the waste stream.  Moreover, proper sampling tech-
niques must be  employed.  Finally, the integrity of the  sample
must be maintained from the time of sampling to the time of
testing.  This  time interval should be kept to a minimum; even
then certain types of samples must be preserved through  addition
of chemical agents or refrigeration.

     Methods and equipment used for sampling will vary with the
waste stream and the sampling purpose.  The reader  is referred
to the following sources  for sampling protocols:  Samplers  and

                               7-6

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Sampling Procedures for Hazardous Waste Streams  (10) and Test
Methods for the Evaluation of Solid Waste, Physical/Chemical
Methods (11).  Other sources (4,5) also provide useful infor-
mation on sampling.  Ideally, leachate samples should be ana-
lyzed immediately after collection for maximum reliability of
the analytical results.  Leachates are such complex mixtures
that it is difficult to predict precisely the physical, biolog-
ical, and chemical changes that occur in the samples with time.
After sample collection, pH may change significantly in a matter
of minutes, sulfides and cyanides may be oxidized or evolve as
gases; and hexavalent chromium may slowly be reduced to the
trivalent state.  Certain cations may be partly lost as a result
of adsorption to the walls of sample containers.  Microorganism
growth also may cause changes, and volatile compounds may be
lost rapidly.

     In many cases, the undesirable changes described above may
be minimized by refrigeration of samples at 4° C, or by the
addition of preservatives.  Refrigeration may deter the evolu-
tion of volatile components and acid gases such as hydrogen
sulfide and hydrogen cyanide, but some salts precipitated at the
lower temperature may not redissolve when warmed for analysis,
thus causing error in determining the actual concentrations of
dissolved sample constituents.  Preservatives may retard bio-
chemical changes; other additives may convert some constituents
to stable hydroxides, salts, or compounds.  Compounds may be
converted to other forms (such as the products of nitration,
sulfonation, and oxidation of organic components).  Upon sub-
sequent analyses, the results may not reflect the original
identity of the components.

     Thus, both advantages and disadvantages are associated with
the refrigeration and/or addition of preservatives or additives
to waste samples.  Various methods of preservation for specific
tests on selected constituents are given elsewhere (4,10).  When
more than one specific test is to be run on a sample, it may be
necessary to divide the sample and preserve each subsample by a
different method.

     Adequate record keeping and use of proper sample containers
also are important aspects of a good sampling program.  As a
general rule, a detailed sampling plan should be developed prior
to any sampling operations.

7.3  LEACHATE CHARACTERIZATION

7.3.1  Wastes Received

     RCRA regulations require an owner/operator to obtain a de-
tailed chemical and physical analysis of a representative sample
of a waste before placement into a disposal site.  Moreover, the
facility operator is required to maintain a record of the quan-

                               7-7

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tity and location of each hazardous waste placed in the disposal
site.

     From a leachate management point of view, this type of data
may be useful in predicting future leachate composition at new
sites.  However, it may be several years before a leachate is
collected.  Therefore records maintenance is important.

     Formalized procedures should be used to file manifests and
analytical results.  It may be useful to keep running inven-
tories according to specific compound types, and total quanti-
ties disposed for each.  In this way, predictions of leachate
generation would be facilitated.

7.3.2  In-situ Monitoring

     There are a number of questions which can be answered using
in-situ monitoring:  1) what mechanisms are involved in waste
modification as the leachate migrates through the disposal site
and previously disposed materials; 2) at what rate and in which
direction does the leachate move; 3) how do compounds and their
concentrations vary with depth and time; 4) are any off-gases
evolved; and 5) what factors influence movement and concentra-
tions?

     In-situ monitoring could be incorporated within the leach-
ate collection system.  Sampling points should be designed to
provide a representative picture of waste movement and degrada-
tion throughout the site.  If the site is compartmentalized,
then the monitoring should be representative  for each cell or
separate disposal area.

     Emrich and Beck (12) have discussed methods used to eval-
uate closure and monitoring plans for a hazardous waste disposal
site.  Some of these methods may be useful  in conjunction with
in-situ monitoring.  Suction lysimeters and pan lysimeters were
used to determine moisture movement.  With  some modification,
these methods might be adaptable to in-situ monitoring.

7.3.3  Collected Leachate

     The leachate collection system will be a key monitoring
location.  Because leachate composition is  expected to vary with
time in terms of types and concentration of compounds, analyses
of collected leachate will serve to define  the unit operations
used for treatment and their operating ranges.  Hence, collected
leachate characterizations are expected to be useful in making
treatability assessments of process alternatives and in defining
specific unit operations and their operating  ranges.

     Collected  leachate characterizations also provide a base-
line for  evaluating treatment effectiveness.  Coupled with

                               7-8

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effluent analyses, this would provide an assessment of removal
efficiencies for individual unit operations as well as the over-
all treatment chain.

7.4  TREATMENT EFFLUENT MONITORING

7.4.1  Sampling Locations

     Sampling and analysis of collected leachate serves as the
measure of leachate treatment plant influent.  Where there are
several monitoring points in the leachate collection system be-
cause of the size of the disposal site, or because of compart-
mentalization, the point closest to the treatment plant should
be used.  In this way, aggregated flow and composition will be
most representative of the influent baseline.

     Previous sections have noted that leachate probably is not
amenable to treatment by a single unit process.  Instead, treat-
ment probably will include several unit operations.  Individual
unit operations should be monitored separately to facilitate
optimized operation.  For example, granular activated carbon
adsorption may be used prior to biological treatment in order to
remove toxic constituents which could impair biological treat-
ment effectiveness.  Hence, it would be necessary to monitor
carbon-treated effluent to prevent biological upset.  Therefore,
monitoring at each major point in the treatment chain is
strongly suggested.  Moreover, the analytical techniques selec-
ted for such monitoring should have rapid turn-around times to
enable timely process control decisions.

7.4.2  Parameters

     Experience shows that it is infeasible to analyze all pa-
rameters of concern at frequent intervals.  Rigorous analysis of
complex organic and inorganic constituents simply is too costly
to sustain at frequent intervals.  As a result, an attempt
should be made to identify surrogate measurements or indicator
parameters which can be used inexpensively to gage treatment
effectiveness.  For organic constituents, such a surrogate pa-
rameter could be total organic carbon (TOG).  Another less well
developed method could be thin layer chromatography (TLC).  Sim-
ilarly, for inorganic constituents selected indicator metals
could be analyzed using common spectrophotometric techniques.

     It is recommended that such surrogates or indicators be
identified using inventory information to predict likely com-
pounds which are expected to appear in the collected leachate.
Further refinements potentially could be made in conjunction
with treatability studies if they are anticipated.

     It also may be possible to use biological toxicity tests to
determine process effectiveness.  Procedures are evolving which

                               7-9

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offer potential for evaluating residual toxicity subsequent to
individual treatment operations.  Although such procedures do
not measure specific parameters or surrogates directly, judg-
ments can be made regarding treatment capabilities by inference.

     Thus, indicators and surrogate parameters permit cost-ef-
fective process control.  However, more costly analysis using
rigorous and sophisticated analytical methods will be required
periodically for process refinement, and for detailed assessment
of overall treatment effectiveness.  The rigorous analytical
techniques could include gas chromatography/mass spectrometry
(GC/MS), atomic absorption (AA), x-ray fluorescence  (XRF), or
other refined methods.

     The frequency of the more sophisticated analytical methods
will be dependent upon the types and concentrations  of compounds
in the leachate, their amenability to removal, mode  of dis-
charge, flow rates, and concentration and flow variability.
Costs also will be an important determinant.  Rigorous analyses
also should be used to monitor any significant changes either in
unit operations employed or for changes in operating procedures.
Once equilibrium operation is achieved, it may be appropriate to
schedule rigorous analysis at regular intervals.

7.4.3  Data Analysis

     Detailed performance records should be maintained for unit
and overall treatment operations.  A thoughtful protocol  should
be developed in advance of treatment plant start-up.  Where nec-
essary, sufficient data should be obtained to define key  process
control parameters.  In some cases, statistical correlations
could be used to insure that process interactions are appro-
priate.  For example, it might be possible to identify TOG
levels which are required for downstream operations  to function
optimally.

7.4.4  Process Optimization

     Because leachate is characterized by expected variability
in flow, types of compounds, and concentrations, process  optim-
ization is envisioned as an ongoing task.  Detailed  analysis
using sophisticated measurement techniques will be used for this
purpose.  As mentioned earlier, process refinement is one of the
principal functions of detailed analyses.  Attempts  should be
made to verify the correlation of surrogate parameters with de-
tailed actual parameter measurements.  In this way,  process op-
timization need not wait until detailed analyses are made.

7.4.5  Safety Considerations

     Site operators must be aware that the function  of many
treatment unit operations is to concentrate hazardous leachate

                               7-10

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constituents.  Therefore, detailed safety considerations are
essential.  Moreover, in-plant monitoring should be provided to
discover the existence or evolution of hazardous materials.  For
example, it is possible that volatile organics will be stripped
from biological treatment systems, or that gassing can occur
within granular carbon columns.  Hence, in-plant monitoring sys-
tems should be installed, and employees thoroughly trained for
emergencies.  These plans should be in-place well before initi-
ation of treatment operations.

7.5  REFERENCES

 1.  Sawyer, C.N. and P.L. McCarty.  Chemistry For Sanitary
     Engineers.  McGraw-Hill, Inc. New York, New York,'1967.
     518 pp.

 2.  U.S. Environmental Protection Agency.  Handbook for
     Monitoring Industrial Wastewater.  U.S. Environmental
     Protection Agency, Technology Transfer, Nashville,
     Tennessee, 1973.

 3.  U.S. Environmental Protection Agency.  Methods for Analysis
     of Water and Wastes.  EPA-600/4-79-020, U.S. Environmental
     Protection Agency, Cincinnati, Ohio, 1979.

 4.  American Public Health Association, American Water Works
     Association and Water Pollution Control Federation.
     Standard Methods For the Examination of Water and
     Wastewater, 15th Edition.  Washington, DC.  1193 pp.

 5.  American Society For Testing and Materials.  1980 Annual
     Book Of ASTM Standards, Part 31, Water.  Philadelphia,
     Pennsylvania, 1980.  1401 pp.

 6.  U.S. Environmental Protection Agency.  Handbook for
     Analytical Quality Control In Water and Wastewater
     Laboratories.  U.S. Environmental Protection Agency,
     Technology Transfer, Cincinnati, Ohio, 1972.

 7.  U.S. Environmental Protection Agency.  Hazardous Waste and
     Consolidated Permit Regulations, Federal Register, Volume
     45, No. 98, May 19, 1980.

 8.  U.S. Environmental Protection Agency, Effluent Guidelines
     Division.  Sampling and Analysis Procedures For Screening
     of Industrial Effluents For Priority Pollutants.  U.S.
     Environmental Protection Agency, Washington, DC, March
     1977, revised April 1977.

 9.  Guidelines Establishing Test Procedures For the Analysis of
     Pollutants:  Proposed Regulations.  Federal Register,
     Volume 44, No. 233, pp. 69464-69575.  December 3, 1979.

                               7-11

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10.   deVera,  E.R.,  B.P.  Simmons,  R.D.  Stephens,  and D.L.  Storm.
     Samplers and Sampling Procedures  For Hazardous Waste
     Streams.  EPA-600/2-80-018,  U.S.  Environmental Protection
     Agency,  Cincinnati,  Ohio,  1980.

11.   U.S.  Environmental  Protection Agency,  Office of Solid
     Waste.  Test Methods for the Evaluation of Solid Waste,
     Physical/Chemical Methods.   SW-846.  U.S. Environmental
     Protection Agency,  Washington, DC.
12.   Emrich,  G.H. and W.W. Beck,  Jr.   Top-Sealing to Minimize
     Leachate Generation Case Study of the Windham, Connecticut
     Landfill.  In:  Proceedings  of U.S. EPA National Conference
     on Management of Uncontrolled Hazardous Waste Sites,
     Washington, DC, October 1980.  pp. 135-140.
                               7-12

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                            SECTION 8

                 OTHER IMPORTANT CONSIDERATIONS
8.1   SAFETY

      Hazardous waste leachate management operations will vary
widely in complexity.  Moreover, the compounds and associated
hazards will differ from site to site.  The  following  discussion
outlines safety considerations which apply to the general case.
The purpose is to provide guidance to the leachate manager  in
development of a safety program for a particular site.

8.1.1  Degree of Risk

      Safety considerations will vary dependent upon the degree
of risk involved for plant personnel.  Handling of hazardous
materials is inherently dangerous; however,  some areas  and
functions may constitute a higher degree of  risk than  others.
For example, sampling in an area where volatile organics may be
evolved is more dangerous than working in a  treatment  plant
control room.  Similarly, handling residues  may be more danger-
ous than handling raw leachate, simply because the hazardous
materials are more concentrated in the residues.

      Therefore, it is necessary to identify safety procedures
and protective measures commensurate with the risk involved.
Prior to facility start-up, a thoughtful assessment of  risks
should be made for each work area and job function.  Because it
would be confusing and burdensome for workers to adjust for each
and every work situation, safety procedures  should be  devised
for general levels of risk.  A major chemical manufacturer  uses
a classification system to categorize risk levels.  This system
is described by Morton (1).

      Procedures should be established for reviewing and reclas-
sifying degrees of risk based upon plant experience, and infor-
mation secured through the literature.

8.1.2  Restricted Entry

      The entire disposal site area should be fenced and posted.
Entry should be granted only to authorized personnel.   Security
patrols could be used at night to prevent intruders from gaining
access and to check all work stations at regular intervals.

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Arrangements should be made between plant security and local
police and fire departments to provide rapid backup in the  event
of emergencies.

      Within the restricted plant area, entry to dangerous  areas
should be limited to those personnel directly related to spe-
cific operations.  For example, office workers need not be
granted entry into processing areas.

      Specified clean areas could be provided within the plant
and safeguards taken to insure that the clean areas remain  un-
contaminated.  Generally, clean areas will include office and
administrative areas, lunchrooms, lounges, and restrooms for
non-operating personnel.  Access to the clean areas should  be
through a changeroom.  Moreover, operating employees should be
encouraged to shower before leaving plant premises.

8.1.3  Safety Rules

      It is important that safety rules be communicated to  all
employees, and adherence to these rules be strictly enforced.
Morton (1) has presented a comprehensive list of general plant
safety rules which is directly applicable to hazardous waste
management facilities.

      All employees should be trained in safety with more de-
tailed instruction given to those in processing operations.
Safety meetings at regular intervals are recommended.  These
meetings should be designed for small groups and emphasize  spe-
cific operating problems.

      Certain plants which handle hazardous materials have  min-
imum age limitations for employees.  In some cases, individuals
younger than 18 years old are not permitted on the site.

         Some plants do not allow employees to work alone in
processing areas.  Backup personnel should be available at  all
times for emergency evacuation of work stations.

      Two key rules applied at hazardous waste management facil-
ities are: 1) all employees must remove protective clothing and
wash thoroughly before breaks and lunch, and 2) illness must be
communicated to supervision immediately, even after normal  work-
ing hours.

8.1.4  Supervision

      Effective supervision is crucial to worker safety.  Super-
visors must be firm and consistent  in their enforcement of  safe-
ty procedures.  No workers should be without supervision  for
more than two hours.  Management should hold plant supervisors


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accountable for plant safety and security.  Furthermore, super-
visors should be well trained for all contingencies.

8.1.5  Inspections

      Designated personnel should conduct safety inspections at
regular intervals.  Formalized checklists should be used, and
fixed procedures should be in place to rectify deficiencies
within 24 hours.  In the event a deficiency poses an imminent
danger, work functions in the area should be terminated and the
area cordoned off until the deficiency is corrected.

8.1.6  First Aid and Medical Assistance
      Employees who work in processing areas should have a base-
line medical examination upon hiring, and should have periodic
examinations at regularly scheduled intervals.  Workers at pes-
ticide handling facilities often have a cholinesterase baseline
level established in conjunction with their initial examination.

      Selected plant personnel should be trained in first aid
procedures related to the types of risks to which the employees
are exposed.  First aid treatment should be available at all
times.

      Medical assistance also should be available both on an
emergency basis and for chronic problems.  Medical personnel
should be contacted in advance of problems to be informed about
the types of materials to which employees may be exposed.  More-
over, they should be given information on the behavior and
nature of materials.  Emergency plans should be worked out in
detail prior to plant startup, if possible.

8.1.7  Protective Equipment

      Processing and laboratory areas should be equipped with
emergency showers and eyewashers.  These should be tied to an
alarm system so that co-workers can come to the aid of poten-
tially contaminated workers.  Face-shields, safety shoes, safety
glasses, gloves, aprons, coveralls, hard hats, and shoe covers
should be provided to workers whose jobs require varying degrees
of protection.

      Full suit protection should be provided for particularly
hazardous tasks, and for emergency evacuation -operations.  Res-
piratory protective devices usually are used in conjunction with
situations requiring full suit protection.  There are three
basic types of respiratory protective devices: 1) air-purifying
respirators, 2) supplied-air respirators, and 3) self-contained
breathing apparatus.  The type used is dependent upon the degree
of hazard involved.
                               8-3

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      Acid suits consisting of a rubber coat, rubber pants,  acid
gloves, rubber boots up under the pants, and a rubber acid hood
should be available in the event of line breaks or leaks under
pressure.  Similarly, such equipment may be used for repair
operations.

      All protective clothing and equipment must remain on-site.
It should be decontaminated before reuse.  Reusable clothing is
more durable and is preferred.  Appropriate washing procedures
should be used to insure complete decontamination.

      Protective equipment should be accessible in all work
areas where contamination may be encountered so as to permit
safe exit in an emergency.

8.1.8  Ventilation

      Adequate ventilation of work spaces is required to prevent
harmful exposure to toxic materials.  Morton (1) stated that ex-
posures are related to threshold limit values (TLV) based upon a
time-weighed concentration for a normal workday.  The TLV is the
level at which workers can be exposed daily without harmful  ef-
fect.  Furthermore, a "ceiling" value is established which
should not be exceeded under any circumstances.  Although expo-
sures above the TLV up to the ceiling value are undesirable,
they can be permitted as long as an overall time-weighed average
(usually for an eight-hour day) is not exceeded.

      Ventilating system design should account for work areas
where there might be accumulation of volatile organics or haz-
ardous dust.  Air exchange rates will be based upon industrial
hygiene ventilation parameters.

      Monitoring to assure that there is satisfactory ventila-
tion can be performed using a number of sampling instruments.
Weiby and Dickinson (2) described the major factors in specify-
ing instruments for monitoring work areas as instrument speci-
ficity, operational range, accuracy, response time, and special
features.  In a companion article, Herrick (3) discussed the
following topics: portable instruments, electrolytic cell detec-
tors, flame ionization detectors, catalytic cell detectors,  and
signaling alarms.  The reader is encouraged to consult these
references for detailed consideration of work area monitoring.

      Because toxic fumes may be evolved in some sample handling
and analytical procedures, hoods should be provided in labora-
tory areas.  In certain cases, air cleaning equipment may be
necessary for air exhausted from the hood.
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8.1.9  Housekeeping

      Good housekeeping is an adjunct to any safety program.
For the leachate treatment facility, it is especially important
to keep work areas clean and free from obstructions.  Spills
should be cleaned up immediately, and resultant residues dis-
posed safely.  Exposed areas and walkways should be kept ice-
free to reduce possibilities for falls.

8.2  CONTINGENCY PLANS/EMERGENCY PROVISIONS

      Much of the following discussion is not limited to
leachate management alone but applies to hazardous waste manage-
ment operations in general.  The intent of the discussion is to
provide the leachate manager with information sufficient to
enable development of contingency/emergency plans tailored to a
given site operation.  Part VII of the Hazardous Waste and Con-
solidated Permit Regulations also contains useful guidance in-
formation on contingency/emergency plans.

8.2.1  Emergency Situations

8.2.1.1  Natural Disasters—

      Development of contingency plans for natural disasters is
substantially different than for accidents.  Accidents require
action to address an incident which already has occurred, where-
as planning for natural disasters usually is designed to prevent
problems.  Developments in predictive meteorology and hydrology
permit advanced warning of hurricanes, tornadoes, and floods.
However, sometimes the warning period is limited.  On the other
hand, earthquake planning involves other kinds of considera-
tions .

      The thrust of contingency planning for natural disasters
is to shut down plant operations, prevent escape of contamina-
tion to the environment, and safeguard plant equipment.  Pre-
ventive measures can be designed into the plant.  For example,
berms and dikes can be built to prevent inundation of water  from
flooding.  Moreover, these measures can be designed to mitigate
events based upon historical data,  e.g., 100-year floods.   Sim-
ilarly, structures can be designed to mitigate damage from
earthquakes.  State of California building codes have been de-
vised to guide those who build in high risk areas.

      Plan development should include natural disaster consider-
ations for areas known to be subject to possible problems.   Site
operators should devise procedures for determining when such
risks exist by designating specific responsibilities for com-
munication with the National Weather Service, the U. S. Geolog-
ical Survey, or other agencies having early warning systems.


                               8-5

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Furthermore, clear decision responsibility for determining when
to shut down and take protective measures should be in place.

      In the event that preventive measures are unable to handle
the event because of its magnitude, i.e., a tornado "direct hit"
or a flood beyond design criteria, emergency actions similar to
those formulated for accidents should be planned for.

8.2.1.2  Accidents—

      Accidents include fires, explosions, leaks, and spills.
Although bomb threats can be handled by shutdown and subsequent
searches, actual sabotage will have to be dealt with in the same
manner as accidents.

      Because of the dangers inherent in fires and explosions, a
separate subsection of this manual will be devoted to fire pro-
tection.  Spills and leaks will be discussed within the context
of contingency planning.

8.2.2  Plan Development

8.2.2.1  Organizational Responsibilities—

      The most important aspect of an effective contingency plan
is clear definition of responsibilities for execution.  Plant
management must be fully involved, and it is highly desirable to
have a company officer be responsible for insuring plan execu-
tion.  The chain of command should be specified in advance,
along with delegation of authority and backups where needed.  A
job description for each responsible party should be incorpor-
ated in the plan.

3.2.2.2  Plan Components—

      In addition to in-house contingency plans, it is expected
that hazardous waste disposal sites will be required to file a
Spill Prevention Control and Countermeasure Plan (SPCC) with
their state water pollution control agency.  Components of a
typical plan include:

      • responsible officials names, addresses, telephone num-
        bers;

      • facility location and site map;

      • potential spill dangers, pathways, remedial measures;

      • past spill frequency;

      • sources of assistance (e.g. emergency  fire, cleanup con-
        tractors ) ;

                               3-6

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      • legally required reporting requirements  (names, tele-
        phone numbers);

      • schedule for installing mitigating devices;

      • materials inventory; and

      • inspection procedures.

Further descriptions of contingency plan components follow.

8.2.2.2.1  Implementation Manual—Because rapid  action and thor-
oughness is essential in emergencies, a detailed implementation
manual should be prepared to cover all expected  contingencies.
However, it must contain some degree of flexibility because the
unexpected will normally occur.  Steps for response should be
written down and understood by all who are expected to partic-
ipate.  Not only should all the components of the plan be
listed,  but also the sequence of actions to be executed.  The
information which follows generally is arranged  in the order of
execution.  Furthermore, once the manual is prepared, it should
be reviewed and updated at regular intervals.

8.2.2.2.2  Alarm Systems—The first step in plan execution is a"n
alarm system to indicate that an emergency has occurred.  The
primary purpose of the alarm system is to enable rapid evacu-
ation of affected areas.  A secondary but equally important pur-
pose is to initiate the emergency response plan.

8.2.2.2.3  Communications Network—When an alarm signals an
emergency condition,on-site personnel should begin response
actions, and all appropriate contacts for assistance made.  The
responsible company official should be notified  first.  It is
suggested that a telephone "tree" be activated so that all en-
tities and agencies be notified as quickly as possible.  The
priority of notification will be dependent upon  the nature of
the emergency.  For example, if a fire or explosion is involved,
the local fire department and medical assistance teams should be
called first.  A log of telephone calls made and actions taken
should be maintained.  This log should be signed and witnessed.

      The contact list should be part of the manual and should
include: plant management and supervision; fire, medical, and
police personnel; local, state, and federal governments; and
surrounding population if evacuation is envisioned.  Manuals
should specify the person to be called and their telephone num-
bers .   Alternate names and numbers should be provided in the
event the primary contact cannot be reached.

8.2.2.2.4  Execution Checklist--During the period when plant
management is on the way to the scene, fire and medical assis-
tance is enroute, and contacts are being made, on-scene person-

                               8-7

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nel should be executing the contingency plan using a prepared
checklist of actions.  The checklist is part of the emergency
implementation manual discussed above.

8.2.2.2.5  Personal Injury—The first priority of the plan is to
attend to those injured in the incident.  Next in priority is to
prevent further injuries from occurring.  Injured persons should
be removed from contaminated areas and administered first aid
until medical assistance arrives.

8.2.2.2.6  Information Assistance—There are a number of excel-
lent information sources which can be used to assist in acci-
dents involving hazardous materials.  The Chemical Transporta-
tion Emergency Center (CHEMTREC) can provide help in determining
the nature of hazards involved, and in providing expert assis-
tance on how to manage the situation. The CHEMTREC emergency
number is (800) 424-9300.  It is operational 24 hours a day.
The National Poison Control Center (telephone (502) 589-8222) is
available to provide help where there is personnel exposure to
toxic materials.

      EPA operates OHM-TADS (Oil and Hazardous Materials Tech-
nical Assistance Data System) which is a potential source of
useful information on the materials involved".  A similar system
of the U. S. Coast Guard is CHRIS (Chemical Hazard Response
Information System). It too can provide data on the materials
involved.  Both of the systems can be accessed in emergencies
through the National Response Center, telephone (800) 424-8802.

      The National Fire Protection Association handbook en-
titled, "Fire Protection Guide on Hazardous Materials" is a
valuable resource to have on-site to guide fire protection ac-
tivities.  "Dangerous Properties of Industrial Materials" by N.
I. Sax (5th ed., 1979, Van Nostrand Reinhold Co.) also is a very
valuable resource.  Long a standard in the field of industrial
hygiene,  this excellent book is extremely useful in dealing with
hazardous materials because it is a single, quick, up-to-date,
concise hazard analysis informative guide to nearly 13,000 com-
mon industrial and laboratory chemicals.

      Most of the above information resources were devised for
response to transportation accidents where the compounds in-
volved are not known in advance.  Because the hazardous waste
disposal site will have knowledge of what materials are ac-
cepted, and presumably an inventory of these materials, it
should be possible to utilize information sources in advance of
an emergency, and include response and toxicity data in the
implementation manual for each chemical handled.  Every effort
should be made to do so.

8.2.2.2.7  Plant Shutdown—Early warning of possible natural
disasters (e.g., hurricanes, tornadoes, and floods), will dic-

                               8-8

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tate plant shutdown procedures.  Time allowed  for execution of
shutdown orders will be specified by emergency warning agencies.

      For an accident situation, only certain portions of the
plant might be shut down if the emergency is contained within a
restricted area.  The decision of whether to shut down, and how
much of the plant is affected is the responsibility of the plant
management in charge of plan execution.

8.2.2.2.8  Press and Media Contact List—An emergency at a haz-
ardous disposal site is certain to generate public apprehension.
The plan should provide for press conferences and debriefings.
After the emergency is under control, a company official should
contact a list of news media personnel to provide a statement of
the nature of the emergency, the actions taken, and current
status.  The purpose should be to give factual information so
that misinformation will not mislead concerned citizens in the
plant locale.

8.2.2.2.9  Incident Documentation—The incident should be docu-
mented fully for several purposes.  Documentation will permit
post-facto review of whether the plan was executed as expected.
Also, it can be used to correct problems and thus avoid similar
future incidents.  Finally, it can serve as a legal record of
what happened.

8.2.3  Fire Protection

8.2.3.1  In-Plant Measures—

8.2.3.1.1  Fire Extinguishers—Fire extinguishers should be
located at strategic points throughout the plant.  Extinguishers
should be readily accessible, and plant personnel should be
trained in their use.  The type of extinguisher used is depen-
dent upon the likely kinds of fires that may be encountered.
For example, dry chemical and carbon dioxide extinguishers usu-
ally are preferred in laboratory areas where water may react
with burning chemicals.

8.2.3.1.2  Sprinkler Systems—Sprinkler systems should be in-
stalled in compliance with local and state building and fire
protection codes.  Testing of the sprinkler systems in conjunc-
tion with plant safety inspections is good practice.  Just as
water extinguishers are inappropriate for certain locations,
sprinklers may not be useful in certain plant work areas.  Dis-
posal site operators should consult with loss and fire preven-
tion specialists regarding the best approach for their plant.
Often casualty insurance companies will provide expert assis-
tance to their clients as a service, and in order to assess
risks for premium determinations.  Site operators should explore
using this resource.
                               8-9

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8.2.3.1.3  Use of Plant Security Personnel--Plant security per-
sonnel likely will be on the scene of a fire shortly after dis-
covery.  They should be trained to deal with the fire on a
"first response" basis, and should be responsible for notifying
trained in-plant fire fighters and the local fire department.

8.2.3.2  Training—

8.2.3.2.1  Local Fire Department—Plant operating and management
personnel should meet with the local fire department to inform
them of the types of materials on site and to give them infor-
mation on the hazards which may be involved with such materials
in the event of fire (including an explosion).  It would be a
good idea to have fire department officials visit the plant to
familiarize them with its layout, the location of high risks
areas, and to inspect fire protection capabilities on-site.

      The local fire department could conduct training exercises
using some of the actual materials which potentially could be
involved.  Furthermore, selected plant personnel could partic-
ipate in these exercises preparatory to the formation of an
emergency squad composed of fire department personnel and a few
selected plant employees.

8.2.3.2.2  Emergency Squad—Based upon potential fire hazards
which are evident at the disposal site, it is good practice to
form an emergency squad trained for the specific purpose of
dealing with known and anticipated hazardous materials.  Often
the emergency squad is comprised of a select crew from the local
fire department and several well-trained plant employees.  The
reason for including plant employees is so they can begin emer-
gency operations immediately, prepare for the arrival of the
local fire department, and guide the fire fighting effort be-
cause of their intimate knowledge of the plant.

      In addition to normal fire fighting, the emergency squad
is responsible for rescue operations, evacuation of injured or
threatened personnel, and escalation decisions in the event of
broad involvement in the disposal site.  This group should re-
ceive specialized training in advance (e.g., use of self con-
tained breathing apparatus, boom deployment).

8.2.3.3  Hazards Identification—

      The National Fire Protection Assocation (4) has devised a
system for identifying the inherent hazards of certain chemicals
and the order of severity of these hazards under emergency con-
ditions such as spills, leaks, and fires.  A section of the NFPA
manual, "Fire Protection Guide on Hazardous Materials", provides
hazardous chemicals data.  There are four categories of data
provided: health, flammability, reactivity, and other unusual
conditions.  For the first three categories, a numbering system

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has been devised to inform fire fighting personnel  about protec-
ting themselves and how to fight fires where the hazard exists.
In the fourth category, special considerations are  indicated.
For example, fire fighters are alerted to possible  hazards where
there may be unusual reactivity with water and oxidizing chem-
icals are noted.  It would be beneficial to identify the mate-
rials potentially involved in advance so that fire  protection
measures can be incorporated within the contingency plan and the
implementations manual.  Moreover, emergency squad  training can
proceed using identified materials.

8.3  EQUIPMENT REDUNDANCIES/BACKUP

8.3.1  General Discussion

      Because a leachate treatment plant will use unit opera-
tions similar to those employed at municipal and industrial
wastewater treatment plants, certain reliability considerations
also are similar.  EPA has issued minimum standards of reliabil-
ity for mechanical, electric, and fluid systems and components
which may be applicable for leachate treatment plants (5).  Man-
ual users are referred to these criteria for details.

      There is a question, however, of whether the  need for
redundancy is as great for hazardous waste leachate treatment
systems as for municipal and industrial systems.  In the latter
cases, it is difficult to shut-off or divert flow during emer-
gencies, shutdowns, or repair.  Frequently, considerable flows
are involved, and the option of storage is economically in-
feasible.  On the other hand, leachate flows generally will be
low.  As a result, storage possibly could be a cost-effective
substitute for certain redundant and backup systems.  Therefore,
during leachate treatment plant design, costs of redundant and
backup systems should be balanced against costs for building
storage for raw leachate.  Further considered in design should
be: estimated volume of incoming wastes, estimated  flow of
leachate, projected time periods for outages or emergencies,
tankage costs, and redundant system costs.

      In general, there are two locations at which  storage might
be required: collected leachate, and treated leachate.  Some
storage might be designed into the plant for purposes of equal-
izing flows in any case.  Because concentrations of materials
will be different at each location,separate storage would be
required.

      Nevertheless, attention should be given to important
equipment considerations related to redundant and backup condi-
tions.  Discussion on these items is found in the subsequent
subsection.
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8.3.2  Equipment

8.3.2.1  Control Systems—

      The plant control room should have redundant emergency
alarms.  Frequent practice is to couple display warning lights
with an annunciator sound alarm.  All electrical controls  should
have manual overrides.  Electric failure backup systems will be
discussed separately.

8.3.2.2  Tanks and Containers—

      Tanks should be fitted with gravity overflow piping  in the
event that pumps fail to shut off.  Tank areas should be on con-
crete pads, if possible, with curbs and walls sufficient in
height to contain leaks, spills, or tank failures.  Addition-
ally, spare tanks should be used to empty the curbed area  if
other storage is unavailable.

      All containers in processing areas should have plugs in
place when not being used.

8.3.2.3  Pipes and Transfer Lines--

      For pipes that convey hazardous materials, failsafe  trans-
fer lines should be used.  Such failsafe systems measure in-
coming flow and discharge flow.  Assuming no intervening taps,
the two flows are compared.  A difference noted will trip  an
alarm.  Differences of greater than 0.5 percent commonly are
used to indicate a leak.

      Pipes should be color-coded to avoid cross connections,
and to permit easy location.

8.3.2.4  Valves—

      Pressure relief valves should be used wherever necessary.
All valves should be located as close as possible to the source
in the event they must be operated during an emergency.  How-
ever, the valves should be accessible if an emergency occurs.
Emergency shut-off valves should be placed on all gravity  trans-
fer lines.

8.3.2.5  Pumps—

      It is good practice to locate pumps outside if possible.
This reduces the possibility of being rendered inoperable  due  to
fires or explosions.  It is required in areas where there  may  be
a build-up of potentially explosive gases.

      Back-up pumps may be desirable where needed to move
leachate to storage during emergencies.  Portable pumps are

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desirable to have on hand in emergencies.

8.3.2.6  In-Plant Drainage--

      Leaks and spillage from equipment should be collected
within the plant and returned to the appropriate unit  process.
Typically, leaks and spillage can be controlled by dikes, berms,
and curbs.

8.3.2.7  Electrical Failures—

      Emergency lights on battery packs are recommended  for all
plant areas.  Operators should judge the potential damage re-
sulting from an extended electrical outage.  It may be cost-
effective to install an emergency back-up generator dependent
upon the number of critical functions involved.

8.3.2.8  Maintenance and Repair—

      Wherever possible, preventive maintenance should be sched-
uled so that redundancy and back-up are unnecessary.  This can
be done during scheduled shutdown.  If major repairs can be de-
ferred, they also should be performed at that time, i.e., during
scheduled shutdowns.

8.4  PERMITS

8.4.1  Consolidated Permit Regulations

      In conjunction with issuance of final rules for the fed-
eral hazardous waste management program (Federal Register, May
19, 1980), the U. S. Environmental Protection Agency established
rules for a consolidated permit program.  The rules governed
programs authorized by the following legislation: Resource Con-
servation and Recovery Act (RCRA), Underground Injection Control
(UIC) under the Safe Drinking Water Act (SDWA), the National
Pollutant Discharge Elimination System (NPDES) under the Clean
Water Act (CWA), State dredge and fill (404) provisions  of the
CWA, and Prevention of Significant Deterioration under the Clean
Air Act (CAA).  There are three primary purposes of these rules:

        "1.  To consolidate program requirements for the RCRA
        and UIC programs with those already established  for the
        NPDES program.

        "2.  To establish requirements for state programs under
        the RCRA, UIC, and Section 404 programs.

        "3.  To consolidate permit issuance procedures for EPA-
        issued Prevention of Significant Deterioration permits
        under the Clean Air Act with those for the RCRA, UIC,
        and NPDES programs."

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      The rules are complex and require substantial effort in
order to enable complete and thorough preparation of permits.
Manual users are urged to consult documents intended by EPA to
clarify and define permit application requirements.

      Responsibilities for state program requirements also are
specified by the EPA rules and regulations.  Although flexibil-
ity is allowed in how states implement these requirements, and
they are free to impose more stringent controls, EPA has spec-
ified minimum requirements consistent with RCRA provisions.

      Permit officials and site operators should recognize that
certain aspects of the consolidated permits are ill-defined
relative to hazardous waste leachate treatment.  NPDES require-
ments for direct discharge of treated leachate to receiving
waters need to be defined in greater detail.  Furthermore, if
treated leachate is to be discharged into a POTW system, no
guidance has been provided relative to pretreatment require-
ments.  There is a crucial need for defining such requirements
in greater detail.  As a point of departure, permit officials
might deal with leachate treatment plant effluent in a manner
similar to that for the chemical manufacturing industry, both
organic and inorganic segments.  Also, many cities are now in
the process of developing pretreatment requirements for dis-
charge of heavy metals, cyanide, phenols and other toxic com-
pounds into POTWs.

8.4.2  Other Permits

      There are several other areas which manual users should
consider in assuring that site operations conform with govern-
mental plans and regulations.  Water quality aspects should be
factored into areawide waste treatment management plans (section
208), and facility planning efforts (Step I).  This is espe-
cially important where direct discharge or discharge to POTWs is
envisioned.  Other areas of concern are zoning requirements and
local building permits.

8.5  PERSONNEL TRAINING

      Training is envisioned for personnel engaged in the  fol-
lowing four functional areas of leachate treatment facilities:
operations and maintenance, safety, emergency response, and
security.  Training related to safety and emergency response has
been discussed earlier in this section, and as a result, will
not be repeated here.

      The basis for operations and maintenance training should
be a well-conceived O&M manual.  During training, personnel
should be acquainted with key operating parameters, acceptable
                               8-14

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operating ranges, problem diagnosis, troubleshooting,  repair
procedures, preventive maintenance, and  shutdown  procedures.   An
example of a suggested guide for development of an O&M manual
for conventional waste treatment facilities is shown  in Table
8-1.  Obviously, a manual for a leachate treatment plant would
have to be modified to reflect the processes used, and incor-
porate provisions germane to the handling of hazardous mate-
rials.  The table does, however, provide a good starting point
for structuring an O&M manual.

      Security personnel should be trained not only to prevent
unauthorized entry into the plant, but also in first  aid,  emer-
gency communications and first response measures, essentials of
spill containment, and some fire fighting as appropriate.

      Training should be conducted upon hiring, and should be
updated at regular intervals.  Consideration should be given to
sending key personnel to formal off-site training courses  and
seminars.

8.6  SURFACE RUNOFF

      Disposal sites should be designed  so that stormwater is
diverted away from and around the site.  This can be  accom-
plished through grading and the use of berms and dikes.  Hence,
this subsection addresses only the fate of precipitation falling
directly within the disposal site.  Four options  exist for deal-
ing with stormwater runoff, dependent upon the degree of contam-
ination: 1) route uncontaminated flow to a holding or storage
pond from which discharges can be made to surface water courses;
2) route mildly contaminated runoff to the same holding or stor-
age area, and treat prior to discharge; 3) route contaminated
runoff to the leachate treatment plant; and 4) place  heavily
contaminated runoff into the disposal area, or containerize and
ship off-site for appropriate disposal.

      Work areas likely to be contaminated, e.g.  loading docks,
waste transfer areas, storage tank areas, should be paved  and
curbed to collect contaminated spillage.  These curbed areas
should be able to be drained by gravity.  Drainage valves  should
remain closed until the areas are drained either to the holding
ponds (when spillage has not occurred), or to treatment and dis-
posal areas (when there is evidence of leaks or spillage).
                               8-15

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                           TABLE 8-1

    SUGGESTED GUIDE FOR AN OPERATION AND MAINTENANCE MANUAL

                FOR WASTE TREATMENT FACILITIES (5)


  I.   INTRODUCTION

      A.   Operation and Managerial Responsibility
      B.   Description of Plant Type and Flow Pattern
      C.   Percent Efficiency Expected and How Plant Should
          Operate
      D.   Principal Design Criteria


 II.   PROCESS DESCRIPTION
      (Function,  relation to other plant units, schematic
      diagrams)

      A.   Pumping
      B.   Screening and Comminution
      C.   Grit Removal
      D.   Sedimentation (Primary)
      E.   Aeration and Reaeration
      F.   Sedimentation (Secondary)
      G.   Trickling Filters
      H.   Sand Filters
      I.   Sludge Digestion
      J.   Sludge Conditioning
      K.   Sludge Disposal
      L.   Gas Control and Use
      M.   Disinfection
      N.   By-Pass Controls and Excess Flow Treatment Facilities
      O.   Waste Stabilization Lagoons
      P.   Other
III.  DETAILED OPERATION AND CONTROLS

      (Routine, alternate, emergency, description of various
      controls, recommended settings, reference to schematic
      diagrams, failsafe features)

      A.  Manual
      B.  Automatic
      C.  Physical
      D.  Chemical

                                                  (continued)

                              8-16

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                          TABLE 8-1 (continued)
       E.  Biological (including Bacteriological)
       F.  Industrial Wastes Monitoring
       G.  Safety Features
       H.  Problems, Causes, and Cures
  IV.  LABORATORY CONTROLS

       (What and why tests are made, interpretation of results,
       and how samples are obtained)

       A.  For Each Process Description Given Above

           1.  Sampling
           2.  Flow Controls
           3.  Analysis

       B.  Monitoring of Effluent and Receiving Waters
       C.  Water Quality Standards
   V.  RECORDS

       (Importance of records, graphing test results, example
       and sample forms)

       A.  Process Operations
       B.  Laboratory
       C.  Reports to be Submitted to State Agencies
       D.  Maintenance
       E.  Operating Costs
  VI.  MAINTENANCE

       (Schedule—daily, weekly, monthly, etc., reference to
       pages in manufacturers' manuals)

       A.  Manufacturers' Recommendations
       B.  Preventive Maintenance Summary Schedule
       C.  Special Tools and Equipment
       D.  Housekeeping Schedule

VII.  SAFETY

       A.  Sewers
       B.  Electrical Equipment
       C.  Mechanical Equipment
                                                  (continued)

                               8-17

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                      TABLE 8-1 (continued)
       D.  Explosion and Fire Hazards
       E.  Health Hazards
       F.  Chlorine Handling
       G.  Aeration Tank Hazards
       H.  Recommended Safety Equipment
VIII.  UTILITIES
       (Source, reliability, cost)

       A.  Electrical
       B.  Gas
       C.  Water
       D.  Heat
  IX.  PERSONNEL

       (Detail of job requirements, task plan estimating man-
       hours per month and year)

       A.  Manpower Requirements
       B.  Qualifications and Background
       C.  Certifications
       D.  Administration and Supervision
       E.  Laboratory
   X.  APPENDIX

       A.  Schematics
       B.  Valve Indices
       C.  Sample Forms
       D.  Chemicals Used in Plant
       E.  Chemicals Used in Laboratory
       F.  Water Quality Standards
       G.  Detailed Design Criteria
       H.  Equipment Suppliers
       I.  Suppliers' Manuals
           (may be bound separately)
                               8-18

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8.7  REFERENCES

 1.  Morton, W. I.   Safety Techniques for Workers Handling Haz-
     ardous Materials.  Chemical Engineering, 83(22):127-132,
     1976.

 2.  Weiby, P., and K. R.  Dickinson.  Monitoring Work Areas for
     Explosive and Toxic Hazards.  Chemical Engineering, 83(22):
     139-145, 1976

 3.  Herrick, L. K. Jr.  Instrumentation for Monitoring Toxic
     and Flammable Work Areas.  Chemical Engineering, 83(22):
     147-152, 1976.

 4.  National Fire Protection Association.  Fire Protection
     Guide on Hazardous Materials, Sixth Edition.  Boston, MA,
     1975.

 5.  Federal Water Quality Administration.  Federal Guidelines -
     Design Operation and Maintenance of Waste Water Treatment
     Facilities.  U.S. Department of the Interior, Washington,
     DC, September 1970.
                               8-19

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                       APPENDICES

                          APPENDIX A

             SUMMARY OF REPORTED WATER CONTAMINATION
          PROBLEMS (at Hazardous Waste Disposal Sites)


     Appendix Table A-l contains data on identified hazardous
waste problems and to the extent possible data on waste composi-
tion.  A reference list which indicates data sources and pertains
only to this table follows the main body of the table.

     Problem sites are identified by a code number in Table A-l.
The code numbers and associated problem sites are listed below.

Site Number                   Site Description

   001      Helevia Landfill adjacent to West Omerod water supply
               (near Allentown, PA)
   002      Haverford, PA
   003      Centre County, PA (near State College, PA)
   004      Stringfellow Landfill, Riverside, CA
   005      Rocky Mountain Arsenal, Commerce City, CO
   006      Geological Reclamation Operations and Waste Systems,
               Inc. (GROWS)  landfill, Falls Township, PA
   007      Wade Site, Chester, PA
   008      Bridgeport Quarry, Montgomery County, PA
   009      Redstone Arsenal, Huntsville, AL
   010      Love Canal, Niagara Falls, NY
   Oil      LaBounty Dump Site, Charles City, IA
   012      Saco Landfill, Saco, ME
   013      Whitehouse, FL
   014      near Myerstown,  PA
   015      Undisclosed
   016      Necco Park, Niagara Falls, NY
   017      FMC, Middleport, NY
   018      Frontier Chemical Waste Process Inc., Pendleton, NY
   019      102nd Street, Niagara Falls, NY
   020      Pfohl Brothers,  Buffalo, NY
   021      Reilly Tar & Chemical Co., St.  Louis Park,  MN
   022      Windham Landfill, Windham, CT
   023      LiPari Landfill, Gloucester County, NJ
   024      Kin-Buc Landfill, Middlesex County, NJ
   025      South Brunswick, NJ
   026      Ott/Story site,  Muskegon County, MI
   027      Hooker Chemical  Co., Montague,  MI


                               A-l

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Site Number                  Site Description

   028      Mayer Landfill,  Springfield Township,  PA
   029      Chemcentral-Detroit,  Detroit,  MI
   030      Bofors-Lakeway,  Muskegon,  MI
                              A-2