United States Office of Emergency and
Environmental Protection Remedial Response
Agency Washington DC 20460
Superfund OSWER Directive 9380 0-3
&EPA Guidance
Document for
Cleanup of Surface
Tank and Drum Sites
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OSWER Directive 9380.0-3
GUIDANCE DOCUMENT FOR CLEANUP
OF SURFACE TANK AND DRUM SITES
Prepared by:
CAMP DRESSER & McKEE INC.
WOODWARD-CLYDE CONSULTANTS
ROY F. WESTON, INC.
C.C. JOHNSON AND ASSOCIATES. INC.
Project Team
Jeffrey A. Cassis (Camp Dresser & McKee)
Richard C. Cote (Camp Dresser & McKee)
Eward P. Hagarty, P.E. (C.C. Johnson & Associates, Inc.)
Edward P. Kunce (Camp Dresser & McKee)
Leonard C. Sarapas, P.E. (Woodward-Clyde Consultants)
John W. Thorsen (Roy F. Weston)
Work Assignment Managers
Edwin Barth and Brint Bixler
U.S. Environmental Protection Agency
Office of Emergency and Remedial Response
401 M Street, S.W.,
Washington, D.C. 20460
This document has been prepared for the U.S. Environmental Protection Agency
under Contract No. WA 68-01-6939
May 28, 1985 U.S. Environmental Protection Agency
Region 5 Library (PL-12J)
77 West Jackson Blvd., 12th Floor
Chicago, IL 60604-3590
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O,S. Environmental Protection Agency
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TABLE OF CONTENTS
Section Page
FOREWORD vi i
1.0 INTRODUCTION 1-1
1.1 Purpose 1-1
1.2 Intended User 1-2
1.3 Organization of Guide 1-3
2.0 LIMITED REMEDIAL INVESTIGATION 2-1
2.1 Develop Site Description and Data Base 2-1
2.1.1 Obtain Available Data 2-1
2.1.2 Review and Evaluate Available Data 2-6
2.2 Site Familiarization and Project Approach 2-7
2.2.1 Prepare Preliminary Base Map 2-8
2.2.2 Prepare Initial Health and Safety Guide 2-10
2.2.3 Prepare Community Relations Plan 2-12
2.2.4 Identify Potential Remedial Technologies 2-12
2.3 Perform Initial Site Characterization 2-13
2.3.1 Conduct Initial Site Visit 2-14
2.3.2 Determine if an Immediate Threat Exists 2-16
2.3.3 Conduct Preliminary Exposure Assessment 2-19
2.3.4 Determine Need for Continued Limited Activity . 2-20
2.3.5 Define Data Needed to Conduct Limited
Feasibility Study 2-21
2.4 Conduct Detailed Field Investigation 2-22
2.4.1 Prepare Project Operations Plan 2-24
2.4.1.1 Sampling Plan 2-24
2.4.1.2 Health and Safety Plan 2-32
2.4.1.3 Quality Assurance/Quality Control
Plan 2-36
2.4.2 Perform Tank and Drum Survey/Inventory 2-37
2.4.3 Conduct Site Characterization ; 2-43
2.4.4 Conduct Sampling Program 2-43
2.4.5 Review Analytical Results for Conformance
with QA/QC Program 2-45
2.4.6 Evaluate All Data and Prepare Limited
Remedial Investigation Report 2-46
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OSWER Directive 9380 0-3
TABLE OF CONTENTS
(Continued)
Section Page
3.0 LIMITED FEASIBILITY STUDY 3-1
3.1 Identify Major Remedial Alternatives 3-3
3.2 Screen Initial Remedial Alternatives 3-10
3.2.1 Evaluate Technical Reliability and
Feasibility 3-11
3.2.2 Evaluate Environmental and Public Health
Effects 3-12
3.2.3 Evaluate Costs 3-14
3.2.4 Refine List of Potential Remedial Action
Alternatives 3-15
3.3 Conduct Detailed Analysis of Potential Remedial
Action Alternatives 3-17
3.3.1 Perform Technical Analysis of Alternatives .... 3-17
3.3.2 Perform Cost Analysis of Alternatives 3-19
3.3.3 Perform Environmental and Public Health
Analysis 3-22
3.3.4 Perform Regulatory and Institutional Analysis
of Alternatives 3-23
3.4 Conduct Comparative Summary of Potential Remedial
Action Alternatives 3-24
3.5 Prepare Limited Focused Feasibility Study 3-27
4.0 TANK AND DRUM SITE REMEDIAL DESIGN/REMEDIAL ACTION 4-1
4.1 Approach 4-1
4.2 Contracting Procedure 4-2
4.2.1 Fixed Price (Lump Sum) Contract 4-2
4.2.2 Unit Price Contract 4-3
4.2.3 Time and Materials Contract 4-4
4.3 Contract Provisions 4-4
4.3.1 Change Orders 4-5
4.3.2 Special Provisions 4-8
4.4 Design Requirements 4-9
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OSWER Directive 9380 0-3
TABLE OF CONTENTS
(Continued)
Section Page
5.0 REFERENCE GUIDE 5-1
APPENDIX A - EXAMPLE OF A SITE PERSONNEL PROTECTION AND SAFETY
EVALUATION FORM FOR USE DURING INITIAL SITE VISITS
APPENDIX B - EXAMPLE OF A DRUM HANDLING, DRUM SAMPLING, SPECIAL
WASTE HANDLING, AND TANK SAMPLING PROTOCOL
APPENDIX C - EXAMPLE OF A BULKING AND CONSOLIDATION PROTOCOL
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OSWER Directive 9380.0-3
LIST OF FIGURES
Figure Page
2-1 Surface Tank and Drum RI Logic Diagram 2-2
2-2 Existing Conditions, Base Map, Examples from an NPL Site .. 2-9 "
3-1 Logic Diagram 3-4
LIST OF TABLES
Table Page
2-1 Example of a Simple Procedure for Evaluation of Short-
Term Hazards at Tank and Drum Site 2-18
2-2 Examples of Data Needs for Evaluation of Potential
Remedial Activities 2-23
2-3 Categorization of Waste Types at an NPL Site Based on
Random Sampling of Drums 2-29
2-4 Waste Treatment Disposal Categories 2-31
2-5 Example of Procedures for Tank and Drum Sampling:
Safety Aspects 2-34 :
2-6 Aspects of Aerial and Ground Drum Surveys 2-38
2-7 Example Drum Inventory Form 2-40
3-1 Categories and Potential Treatment/Disposal Technologies .. 3-7
3-2 Final Remedy for Hypothetical Abandoned Tank Site 3-26
3-3 Limited Feasibility Study Report Format 3-28
4-1 Table of Contents for Drum Disposal Technical
Specifications 4-10
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OSWER Directive 9380 0-3
FOREWORD
A U.S. EPA 1982 survey of disposal practices at uncontrolled hazardous
waste sites indicated that over 20 percent of the sites surveyed had drum
related problems (EPA, 1983). Although remedial action has been
implemented at many of these sites, these problems still remain a major
threat to the public health and environment. This guidance document was
prepared to assist on-scene federal, state and local officials and private
firms that plan and implement remedial actions at National Priorities List
(NPL) sites which contain hazardous wastes in surface tanks and drums.
The primary purpose of this document is to provide guidance on carrying out
concurrent remedial planning activities and accelerating project
implementation for the cleanup of surface tanks and drums containing
hazardous waste. This document is designed to be used in conjunction with
EPA's guidance documents on conducting remedial investigations and
feasibility studies (EPA 1985a,b).
This guidance manual will provide the user with a systematic approach to
remedial action for hazardous wastes stored in tanks and drums. However,
there are many unique and potentially hazardous conditions on tank and drum
sites which require very specialized considerations. This manual does not
substitute for the services of a competent professional but is intended to
serve as a comprehensive planning and technical guidance tool.
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OSWER Directive 9380 0-3
1.0 INTRODUCTION
1.1 PURPOSE
This guidance document addresses remedial actions for the cleanup of
surface tanks and drums containing hazardous wastes, as well as grossly
contaminated soils associated with the tanks and drums. Guidance is
provided for a limited remedial investigation (limited RI), limited
feasibility study (limited FS), and contracting procedures. A limited
remedial action addresses one "operable unit" at a site that, in the
estimation of the lead regulatory agency can be investigated, evaluated and
implemented in a relatively short time period. An operable unit is one
definable problem area or source of contamination at a site that can
basically be addressed independently of other site issues/problems. It can
typically be thought of as one piece of the total remedial action at a
site.
This is one of three guidance documents on specific remedial actions. The
second guidance document is for cleanup of surface impoundments (e.g.,
pits, ponds, and lagoons). The third addresses development of alternative
water supplies. All three manuals may be applicable at a complex site.
While the term "remedial action" is used, this document applies either to
removal or remedial actions, since both require a similar decision process.
Limited RI/FS are typically the first steps in the remedial response at a
National Priorities List (NPL) site and must be consistent with the long
term remedy. Remedial actions, as defined by the National Contingency Plan
(NCP) in Section 300.68(a), "... are those responses to releases on the NPL
that are consistent with a permanent remedy to prevent or mitigate the
migration of a release of hazardous substances into the environment." Any
remedial action contemplated for implementation at a site must be cost-
effective, stabilize the situation, prevent or limit the extent of contami-
nation, and/or provide temporary containment.
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OSWER Directive 93bO u j
Depending on the urgency of response, removal actions may be taken without
the preparation of a limited RI/FS, although many of the issues addressed
in this document will be assessed in an expedited manner.
A typical limited remedial investigation/feasibility study of this type
should take 5-7 months to complete, if sampling is required to supplement
existing data. For planning of a single operable unit, one can assume a
limited RI may last 4-5 months while the limited FS should be completed in
1-2 months. These time estimates are very general and can vary consider-
ably depending on many factors. Typically the RI and the FS can be
performed concurrently, with the limited FS finishing shortly after the end
of the limited RI.
1.2 INTENDED USER
This guidance manual is intended to be an aid to state and federal staff
and private firms for the implementation of a remedial action for the
cleanup of hazardous wastes contained in above-ground tanks and drums. The
manual is informative rather than prescriptive in nature. The basic
objectives are to provide a concise description of the necessary steps to
implement surface remedial actions for the cleanup of tanks and drums
within the provisions of the NCR.
It must be emphasized that this guidance is not to be used as an absolute
reference. It should be supplemented with other EPA guidance documents and
technical reports/references as appropriate. Refer to Section 5.0 for
references relevant to the performance of a limited RI/FS. This manual
should be used under the direction of an engineer or scientist experienced
in hazardous waste remedial projects or equivalent.
Revisions of this manual will be provided, as necessary, to assure
compliance with the NCR. Revisions will be made available through EPA for
intended users.
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OSWER Directive 93800-3
1.3 ORGANIZATION OF GUIDE
This manual is organized into three major sections: (1) limited remedial
investigation, (2) limited feasibility study, and (3) contracting pro-
cedures. These sections represent major activities to be conducted for the
cleanup of surface tanks and drums. A detailed review of the steps to
conduct a remedial investigation to estimate the characteristics and
quantities of those above-ground wastes stored in tanks and drums is
presented in Section 2.0. The feasibility study steps are presented in
Section 3.0; these steps will lead to the evaluation and recommendation of
a cost-effective and environmentally sound remedial alternative for wastes
stored in drums and tanks. Contracting procedures, presented in Section
4.0, include a review of typical remedial design and remedial action issues
that may be unique to tank and drum sites.
The guidance presented in this manual represents a compilation of existing
approaches derived from similar remedial actions implemented at many sites
where tanks and drums were handled as a single operable unit. However, it
will be necessary to tailor this approach to meet the user's particular
needs and the site specific characteristics.
Flow diagrams have been developed to present a logical sequence of activ-
ities for the implementation of this type of remedial action. The flow
diagrams present the major activities for remedial investigation and
feasibility study. The diagrams are located at the beginning of each major
section. Each major activity on the flow diagrams is denoted by a rectan-
gle. Diamonds represent decision points and circles indicate starting and
ending points for each phase of the entire project. These activities are
cross referenced by number to the text in this manual. For example, the
activity "Conduct Summary Evaluation" is referenced to Section 3.4.1 in the
text, which details the necessary steps to implement this activity. The
user may start anywhere on the flow diagram as long as the predecessor
activity has been completed.
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OSWER Directive 9380 0-3
The execution of a limited RI/FS for a single operable unit is designed to
be very flexible in practice. While many of the component activities are
similar to a full RI/FS the user should tailor the approach based upon site
specific conditions and other previous and/or ongoing remedial action
activities. A limited RI/FS for a surface tank and drum site could be
initiated during the execution of a full RI/FS or in parallel with other
limited RI/FSs (e.g., alternative water supply activities).
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OSWER Directive 93800-3
2.0 LIMITED REMEDIAL INVESTIGATION
After a decision has been reached to evaluate surface tank and drum cleanup
activities at an NPL site, a limited remedial investigation (limited RI)
should be performed to provide the information necessary to further define
the site, provide the basis to evaluate conditions on the site, and to
develop a remedial program to mitigate potential adverse public health and
environmental impacts. The four main components of a limited RI are:
1. Develop site description and data base (Section 2.1)
2. Site familiarization and project approach (Section 2.2)
3. Perform initial site characterization (Section 2.3)
4. Conduct detailed field investigation (Section 2.4)
A description of these tasks and the associated decision points are
presented below. The logic flow diagram for the RI is presented in Figure
2-1.
2.1 DEVELOP SITE DESCRIPTION AND DATA BASE
The initial component of the limited RI is to obtain available data on site
conditions (e.g., the nature, amount, and container condition of tank and
drum wastes on-site and unique site features) and to make an initial
evaluation of these data related to cleanup activities for the site.
2.1.1 OBTAIN AVAILABLE DATA
Purpose
Data are collected for the following reasons:
• To better define site conditions so that a health and safety plan
and sampling plan can be prepared (Section 2.4)
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OSWER Directive 9380 0-3
Figure 2-1. Guidance flow diagram for surface tank and drum limited remedial investigation.
Obtain Available Data
• Background Data
— facility description
—site history
— past operation and
disposal practices
—physiography/
topography
— soils/geology
— climate/ weather
— surface water
— ground water
— ecology/land use
—sensitive receptors
• Agency Data
—RAMP
— PASR
—health & safety plans
— chronology of agency
involvement
Review and Evaluate
Available Data
• Summary maps, tables,
matrices
• Executive Summary
• Evident data gaps
• Quality of data
2 1 2
21
Prepare Preliminary
Base Map
• Underground/overhead
utilities
• Availability of water and
electrical hookups
• Nearby structures and
residences
• Drum & tank locations
• Location of known
potential hazards
• Property lines/
boundaries
• Access/security
• Buildings/structures/
piping
• Existing wells and
sampling locations
2 2 1
Prepare/Revise Health &
Safety Plan
Training
Medical screening
Protective and
monitoring equipment
Entry/exit procedures
On-site procedures
Emergency response
Site walkover
(if necessary)
22.2
Prepare Community
Relations Plan
J
Identify Potential Remedial
Technologies
224
Conduct Initial Site Visit
• Verification of existing data
• Identification of unusual
features
—spills/stained soils
—evident environmental
stress/impact
—special wastes
(radioactive/explosive)
—other wastes (drums/
tanks, closed
impoundments)
• Preliminary inventory
—tanks, drums, pits,
ponds, and lagoons
• Access/egress/security
2 3 1
223
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OSWER Directive 9380 0-3
Figure 2-1.
(continued)
Is There
an Immediate
Public Health or
Environmental
Threat?
Notify Agency and
National Response
Center
as Appropriate
Continue
Investigation
When Appropriate
Conduct Preliminary
Exposure Assessment
• Waste characteristics
• Migration pathways
• Potential receptors
233
Is
Existing
Data Base
Sufficient
for Limited
Feasibility
Study?
etermme
Need for
Continued
Limited
RI/FS
Conduct Limited
Feasibility Study
Handle as
Part of Full or
Expanded RI/FS
Prepare Project Operations Plan
• Sampling plan
• Health and safety plan
• QA/QC plan
Submit Plans for Agency
Review and Revisions
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OSWER Directive 9380 0-3
Figure 2-1.
(continued)
Prepare for Field Activities
Indoctrination of field
personnel
—site conditions
—sampling plan
—activities plan
—facilities layout
—health and safety plan
—emergency
contingency plan
—decontamination and
security procedures
—documentation/site
log procedures
—sample handling and
cham-of-custody
procedures
Mobilization of field
facilities
—office and changing
trailers
—decontamination
stations (personnel
and equipment)
—materials and
equipment
—site security
—fixed air monitoring
stations
Perform Survey/Inventory
of Tanks and Drums
Drum count
Condition
Type
Isolate special wastes
Accessibility
Structural integrity
242
Conduct Site
Characterization
Survey/property
Line
Structures
Utilities
Major areas of
contamination
243
Conduct On-Site
Sampling (Optional)
• Ship to lab for analysis
• Conduct on-site analysis
Review Analytical Results
for Compliance with
Quality Control Program
245
Evaluate All Data and
Prepare Limited Remedial
Investigation Report
246
244
Does
Additional Data
Confirm Basis for Limite
Source Control
Action?
Handle as
Part of Full or
Expanded RI/FS
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OSWER Directive 9380 0-3
• To provide a basis for initial site evaluation and identification of
potential remedial alternatives (Section 2.2.4 and 2.3.1)
• To perform an assessment of current on-site hazards (Section 2.3.3)
t Identify and evaluate existing data base so that future field
activities can be planned to fill data gaps (Section 2.3.6)
0 To develop a data base for design of an ultimate remedial program
(contract documents, plans and specifications) (Section 4)
• Provide data for evaluation of remedial alternatives (Section 3)
Techniques
There are many federal, state, and local agencies which may have pertinent
information useful in conducting a limited RI/FS at a tank and drum site.
Most of the available data may be general in nature but possibly useful in
establishing a baseline. Other data sources that may be particularly
useful in obtaining more specific information on the conditions of a site
include:
• Site history, ownership, operation/disposal practices (past and
present, from past owners, operators, and/or generators)
• Sensitive receptors in the vicinity of the site
• Initial planning documents, such as Remedial Action Master Plan if
available
• Preliminary assessment/site inspection data
• Aerial photos of the site
• Hazard Ranking System (MRS) documentation
Many other agencies and potential data sources along with types of
information that's generally available from these sources are reviewed in
the Remedial Investigations Guidance Document (EPA, 1985).
Limitations
Effort should not be wasted on obtaining data that are not applicable to
the scope of the project or obviously generic or duplicative in nature.
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OSWER Directive 9380 0-3
2.1.2 REVIEW AND EVALUATE AVAILABLE DATA
Purpose
The data should be evaluated and summarized in formats that are easy to
review for individuals not involved in the collection process. By
reviewing and evaluating the available data, an understanding of site
conditions will be developed and evident data gaps will be identified.
During this activity, the quality (i.e., accuracy and precision) of the
data and its conformance with the quality assurance/quality control
protocols under which it was collected, should be assessed.
Techniques
At this early stage it is important to focus on compiling as much informa-
tion as possible on the quantity and types of wastes and the condition of
tanks and drums found on site.
Whenever possible, available data should be summarized in graphical,
tabular, or matrix formats. These formats are compact and allow for
efficient presentation, comparison, and utilization of large amounts of
data. A written summary is also valuable for conveying data trends and
general conditions. All summaries, whether graphical, tabular or written,
should identify both what is known — conditions at the site — and what is
not known — evident data gaps.
An important part of reviewing and evaluating the available data is an
assessment of its reliability — the extent to which the data represent
site conditions. The dates of maps, drawings, and plans should be checked;
sampling locations should be evaluated for representativeness. Analytical
data should be checked against internal laboratory QA/QC criteria (blanks,
duplicates, spike/recovery); and the methods of sample collection, preser-
vation, handling, and sampler decontamination should be examined for
potential irregularities. If more than one laboratory analyzed samples
from the same area on site, the results should be assessed for consistency
and variations in methodology should be identified.
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OSWER Directive 9380 0-3
Limitations
The data pool will be examined to see if the desired information is avai-
lable. A balance must be maintained between the need to develop a detailed
data base, the need to concentrate on data essential to solving environ-
mental problems at the site, and the need to arrive at a solution ex-
peditiously. The quality and accuracy of the data are principal concerns
along with the relative timeliness of various data elements.
2.2 SITE FAMILIARIZATION AND PROJECT APPROACH
The goal of the second major component of the limited RI is to develop the
approach (scope) to be followed in subsequent activities. This is
accomplished through the preparation of preliminary maps and plans, and the
identification of potential remedial technologies. The activities
performed during this component are to:
• Prepare a preliminary base map of the site (Section 2.2.1)
t Prepare initial health and safety guidelines (Section 2.2.2)
• Prepare a community relations plan (Section 2.2.3)
• Identify potential remedial technologies (Section 2.2.4)
Identification of potential remedial technologies that are applicable to
site conditions is a key step in the limited RI. By identifying these
technologies early in the overall limited RI/FS process, subsequent data
collection and analysis can be focused on the development and evaluation of
realistic and practicable alternatives. Preparation of a base map, a
community relations plan, and an initial health and safety plan will serve
to better define site conditions and data needs. The health and safety
guide will be prepared in conformance with Standard Operating Safety Guides
(EPA, 1984).
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OSWER Directive 9380 0-3
2.2.1 PREPARE PRELIMINARY BASE MAP
Purpose
The purpose of this activity is to develop an accurate, detailed, up-to-
date map of the site. The preliminary site map is needed to effectively
plan the field activities of the initial site visit and is used to record
many of the observations made during that visit. In most cases, the
preliminary site map will be updated to provide a completed site base map
which will provide an accurate representation of the drums and tanks on
site as well as grossly contaminated soil areas, facilities on site and
other key physical features to meet all limited RI/FS requirements.
Technique
The preliminary base map can be developed from existing site maps, aerial
photos or a site topographic survey. The EPA Environmental Monitoring
Systems Laboratory (EMSL) in Las Vegas, Nevada can provide a wider range of
information on a site. EMSL will provide:
• Aerial photographs and analysis for a single date
• Aerial photographs and analysis over time either for the site itself
or a larger area
t Topographic mapping at 1 foot to 5 foot intervals
• Orthophotographic mapping - a rectified photoimage with a
topographic map superimposed
These services can be obtained through the regional EPA office.
A sample base map is included as Figure 2-2. Features shown on the site
map should include:
• Property lines, used to identify boundaries for site access control
and site security
• Drum number and location (noting if drums are stacked)
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OSWER Directive 9380 0-3
Figure 2-2. Existing conditions base map. example from an NPL site.
lr
Property Line
Below
Ground
Storage
Tanks
Incinerator
Above
Ground
Storage
Tanks
Legend
Well Locations
Drum Areas
Radio
Station,
12" Water Mam
Not To Scale N
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OSWER Directive 9380 0-3
• Potential drum staging/decontamination areas
• Tank locations
• Existing piping between tanks
• Drainage patterns, wetlands, and other water features
• Buildings and structures
t Wells
• Access/egress points
• Adjacent structures/residences
t Prior sampling locations (on and off site)
• Topography
• Vegetation and other environmental features
• Stained soils, pits, ponds, lagoons and other waste disposal areas
Limitations
Old figures, photos and maps may be a useful source of historic information
but should not be relied on for current site conditions. A fly-over of the
site to obtain aerial photos may be necessary.
2.2.2 PREPARE INITIAL HEALTH AND SAFETY PLAN
Purpose
An adequate protocol to protect personnel during the initial site visit
(Section 2.3.1), data collection period (Section 2.4), and later during
tank and drum cleanup, is one of the most important aspects of the remedial
investigation phase. This initial health and safety guide should be
prepared, (or revised, if available) and administered by a trained
professional.
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OSWER Directive 9380 0-3
Techniques
If an existing health and safety plan has been developed for prior site
work, this plan may be adequate for the initial site visit. This document
should be reviewed by a qualified professional using the existing site data
base. If no plan exists, guidance must be developed based on the existing
data. Appendix A is a set of site personnel protection and safety evalua-
tion forms which can be used for this purpose. This guidance must include:
• An objective evaluation of the goals of the site visit and the
remedial action
• An evaluation of site specific hazards, including airborne contami-
nants; potential radiological exposure; dermal hazards; hazards due
to falls, electrical shock or other traumatic injury; hazards from
heavy equipment operation, enclosed space entry, heat stress, etc.
• Medical monitoring of personnel going on-site
• Delineation of contaminated, decontaminated, and clean zones
• If tanks are to be surveyed, specific protocol must be included
describing access procedures, how personnel are to open and check
tanks, and how worker safety will be insured if tank structural
integrity is uncertain.
• A description of site conditions including the number and condition
of tanks/drums, and the nature of wastes on site
t Contingency plan for emergency action (e.g., include telephone
numbers and locations of local hospitals, fire departments, and
police etc.)
t Training required
The user is referred to the Occupational Safety and Health Guidance Manual
for Superfund Activities (NIOSH, 1984) and Remedial Investigations Guidance
Document (EPA, 1985) and Standard Operating Safety Guides (EPA, 1984) for
additional information.
Limitations
If only limited data describing the potential hazard level on site are
available, the health and safety guidance may be excessively conservative
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OSWER Directive 9380 0-3
or inadequate to protect workers. Any existing data or past health and
safety plans should be field verified prior to adoption.
2.2.3 PREPARE COMMUNITY RELATIONS PLAN
Purpose
A community relations plan is a prerequisite for remedial actions at NPL
sites because of their high public visibility and public interest.
Techniques
The purpose of a community relations plan is to keep the public aware of
plans and activities related to the site and to receive input from the
community regarding the site. This plan includes: a site description;
history of community relations activities; discussion of key parties and
their concerns; the site specific community relations objectives;
communications methods; a staffing and budget plan; a site mailing list;
and work schedule. Further guidance on these activities is provided in
Community Relations in Superfund: A Handbook, Interim Version (EPA, 1983).
Limitations
Not applicable
2.2.4 IDENTIFY POTENTIAL REMEDIAL TECHNOLOGIES
Purpose
This activity plays an important role in the development of the remedial
program and provides the basis to determine if existing data are adequate
to support proceeding directly to a limited FS. A preliminary list of
potentially applicable technologies is also prepared so that during the
initial site characterization, any obvious limitations to a specific
technology or alternative can be identified. While this step occurs in the
RI phase, it is actually the initial activity of the limited feasibility
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OSWER Directive 9380 0-3
study phase. This overlap in phases helps to expedite the schedule, but
more importantly improves the usefulness of data generated in the limited
RI.
Techniques
The user should use best engineering judgment and working knowledge of
remedial technologies to identify a range of potential remedial actions.
Documents are currently available which describe remedial technologies for
the cleanup of tank and drum sites (See Section 5.0).
If the project site is a "simple site" (i.e., a site containing less than
100 drums or a small volume of tankage, less than 10,000 gallons), one may
be able to proceed directly to a limited FS (Section 3.0) and obtain other
required data during the actual cleanup operation. Based on the small
waste volume, the number of cost effective and feasible alternatives is
limited and obtaining a detailed and extensive data base is not usually
necessary.
Field activities during the limited RI should be directed towards obtaining
data to aid in the evaluation of the range of remedial technologies that
can be considered feasible at this point in the study.
Limitations
Limited data may make selective identification of potential remedial
technologies difficult.
2.3 PERFORM INITIAL SITE CHARACTERIZATION
The initial site characterization is an important transitional activity
which is centered around an initial site visit. The limited RI progresses
from activities that are based upon existing data to activities and
decision points which use information developed from initial field
activities. The principal activities in initial site characterization
include:
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t Performing an initial site visit (Section 2.3.1)
• Determining if conditions could result in an immediate threat
to human health and/or the environment (Section 2.3.2)
• Conducting a preliminary exposure assessment so the scope of the
limited RI/FS can be evaluated (Section 2.3.3)
t Determining the need for continued- limited activity based upon
review of additional information (Section 2.3.4)
t Defining the data requirements for conducting the limited FS
(Section 2.3.5)
2.3.1 CONDUCT INITIAL SITE VISIT
Purpose
The purpose of this activity is to:
• Verify existing data (e.g., estimate the number and location of
tanks and condition of drums)
• Identify critical areas on-site (e.g., possible future drum handling
areas)
• Identify wastes which require special care in handling due to high
potential risks (e.g., cylinders, lab packs, containers/drums with
various warning labels etc.)
• Gather additional data to support further site evaluation (e.g.,
number and type of drums, amount of waste in tanks, areas where
spills have occurred)
Techniques
After all the preparatory activities described in Section 2.2 have been
completed, the user is ready to enter the tank and drum site for the
initial site visit. While on-site, the provisions of the initial site
health and safety plan must be strictly observed. Furthermore, if anything
unanticipated in the health and safety plan happens, discontinue on-site
activities and re-evaluate the situation.
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The potential hazards associated with volatilization of some organic com-
pounds will be assessed utilizing a portable organic vapor analyzer (OVA),
and/or commercially available portable photoionization GC. Indicator tube
sampling can also be used to provide qualitative information or grab
samples can be collected for later analysis by a laboratory, all of which
can provide important input to the design of the site safety program. The
sample team monitors ambient air for the specific compounds identified in
preliminary information to determine whether an imminent health hazard
exists. Typically, no waste sampling is performed during the initial site
visit.
The following activities may be performed during the initial site visit:
• Estimate number and types of drum and tanks found on site. Note
general condition of tanks and drums. Note any identification of
types of wastes contained in tanks or drums.
• Identify
- Site utilities, facilities and structures
- Unusual waste (lab pack, cylinder)
- Drainage
- Spills, seeps, etc.
- Divide site into zones to facilitate identification of drum/tanks
and future remedial actions
• Make preliminary inventory of any waste surface impoundments and
grossly (visually) contaminated soil areas
• Locate access, egress and security points
• Note evident environmental stress
• Perform air quality monitoring
t Interview local residents
• Photograph or videotape site features
Unique or special wastes are often found on tank and drum sites. During the
site visit, note the presence of any of the following wastes:
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• Laboratory packs (drums, cans or boxes containing laboratory
wastes). These types of containers may hold biologically or
genetically hazardous wastes. More commonly, however, lab packs
hold small containers of often incompatible materials.
• Radioactive materials
• Gas cylinders
• Explosives/shock sensitive materials
0 Highly reactive wastes
A much higher level of risk is associated with the disturbance or handling
of these types of wastes. If any of these wastes are observed on-site,
assistance from trained personnel who are experienced in dealing with these
types of wastes should be obtained before proceeding further.
Limitations
During the initial site visit, little or no sampling is performed and only
preliminary on-site activities are performed. Critical information such as
the location number and size of tanks and drums can be obtained. Tanks
(and possibly a limited number of drums) can be identified by spray
painting identifier numbers on each drum and tank. This effort could
assist in any future sampling activities. Unless absolutely unavoidable,
the movement or staging of drums at this point is not recommended.
Depending on site specific features, (e.g., piled and unlabeled drums) it
may be difficult to identify special wastes.
2.3.2 DETERMINE IF AN IMMEDIATE THREAT EXISTS
Purpose
The primary purpose of this activity is to determine if an immediate threat
to human health or the environment exists. The most common threat would be
the release of hazardous wastes due to rupture and/or explosion of tanks or
drums.
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OSWER Directive 9380 0-3
Technique
The following physical conditions justify special and immediate attention:
t The absence of fencing or other measures to prevent direct contact
between the public and hazardous materials in or around the tanks
and drums
• The presence of flammable or explosive materials in situations
making fire or explosion possible or probable
• Severely degraded tanks or drums that could result in sudden and/or
widespread releases of hazardous materials
• Air releases above acceptable levels as measured by direct reading
instruments or other air quality monitoring devices
The presence of one or more of these conditions does not necessarily mean
there is a significant immediate threat to human health or environment.
Other factors should be considered such as: types of waste materials in
the tanks or drums; location and exposure routes to sensitive/human
receptors; and existing topographic and physical site features near the
site.
If an immediate threat is observed during the initial site visit, after all
factors have been considered, the agency responsible for site activities
and possibly the National Response Center [Telephone (800) 424-8802] should
be contacted.
An example matrix which may be useful in evaluating if an immediate hazard
exists on-site has been included as Table 2-1. The effectiveness of this
type of format will depend on the quantity and quality of available data.
Limitations
If uncertain of the nature and significance of the threat, contact the
agency responsible for site activities and evaluate the situation with them
before contacting the National Response Center. The focus at this point is
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TABLE 2-1
EXAMPLE OF A SIMPLE PROCEDURE FOR
EVALUATION OF SHORT-TERM HAZARDS AT TANK AND DRUM SITE
Location
Zone A
Zone C
Zone A & B
Zone C & D
Type
Liquid
Drummed
Waste
Liquid
Tank Waste
Solid
Drummed Waste
Solid
Tank Waste
Inherent
Hazards
(A)
High
High
Low
Low
Quantities
Present
(B)
High
High
Low
Low
Likelihood
Of Contact
(C)
High
High
Low
Low
Character-
istics Of
Concern
(D)
Acute
Toxicity
Highly Reac-
tive
Acute
Toxicity
Flammable
Toxic
Explosive
Toxic
Threat/
Exposure
Potential
(E)
Very
High
High
Moderate
Low
A. From toxicity data and information on presence of caustic and flammable
wastes (Rated low to high)
B. From data on concentrations in wastes and environmental media (Rated low
to high)
C. From information on human activity at or near site and review of
plausible pathways of exposoure (Rated from low to high)
D. Define characteristics of public health concern (toxicity, reactivity,
ignitability, etc.)
E. Weighing information in previous columns (fire, explosion, direct
contact, and acute toxicity)
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defining and reducing very eminent and obviously dangerous conditions.
Waste material is not generally removed and typical actions could include
fencing and other security precautions.
2.3.3 CONDUCT PRELIMINARY EXPOSURE ASSESSMENT
Purpose
The level of hazard posed by the site is assessed for each of the identi-
fied receptors, and the need for further action is determined. This
assessment will be used and further evaluated during the limited FS to
determine if a no action alternative is appropriate.
Techniques
The following steps may be used to perform this preliminary assessment:
• Identify probable waste sources and types from labels or site
history. Information available on the type of waste in tanks or
drums and the condition of the waste containers should be noted.
The example matrix presented as Table 2-2 may be used for this
purpose. Relevant information may have been collected as part of
Task 2.3.1 (Initial Site Visit). However, no detailed tank or drum
inventories have been conducted, nor have tank or drum contents been
sampled. Therefore, identifying specific wastes present may not be
possible.
• Identify the pathways of contaminant migration for each waste source
(surface water, ground water, air transport, ditches, etc.)
• Identify receptors of the migrating contamination (nearby residents,
wells, wetlands, endangered species, etc.)
• Determine if a remedial action is necessary to mitigate the threat
to human health or the environment.
Evaluation of the actual or potential threat may include a qualitative
evaluation of conditions such as the likelihood of migration, amount of
contaminant migration, and time frame of the exposure. In most cases,
drums and tanks containing concentrated waste without proper maintenance
and controls can be presumed to present an actual or potential threat to
the public health or environment.
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Limitations
Data available at this stage of the investigation may allow only a very
cursory assessment of exposure and threats to public health and the
environment.
2.3.4 DETERMINE NEED FOR CONTINUED LIMITED ACTIVITY
Purpose
The decision to conduct a limited RI/FS for tanks and drums should be
re-evaluated in light of the detailed review of data and the initial site
visit. While the basic objectives of a limited RI/FS may still be valid,
it may be more appropriate to expand the scope to include other wastes
found on site (e.g., in lagoons or within the soil). The cost-
effectiveness of a focused fast-track tank and drum project must be
compared with the value of integrating the tank and drum portion into the
overall site RI/FS.
Techniques
Criteria for making a decision on whether to continue a limited RI/FS for
tanks and drums or to expand the scope to include the entire site will
obviously vary depending upon site-specific conditions. Some areas which
should be focused upon are summarized below:
• Public Health and Environmental Risk - Does fast-track handling of
drummed and tanked waste significantly reduce potential public
health and environmental risk?
s Cost-Effectiveness - Based upon new information, is there a
potential for implementing a remedial program for the entire site on
a more cost-effective basis than a limited approach?
• Schedule - Does new information show that the schedule for
implementing a limited remedial action would not differ much from
that of a larger scale action?
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Limitations
In deciding whether to expand the scope of the limited RI, the types of
remedial technologies involved with handling the different contaminated
areas on-site must be considered. In most cases, the remedial technologies
for disposal of buried wastes, waste piles and waste spills (contaminated
soil and water) are different than those for tank and drum wastes. Where
these different types of wastes are present, the combination of remedial
technologies may be difficult and may not be cost effective. However,
wastes contained in surface impoundments may be similar or related to
wastes in tanks and drums on the same site. Previous operators of the site
may have used the surface impoundments to hold certain waste residues
removed from the tanks/drums, or may have used impoundments as an inter-
mediate step in a waste reclamation process. In cases such as these, it
may prove cost-effective to combine remedial technologies for the similar
types of wastes.
If the preliminary assessment indicates that migration and/or significant
exposure from hazardous materials from tanks and drums cannot be reasonably
expected in the short term, the limited RI should still continue since the
tanks and drums are still in an uncontrolled environment with the potential
to cause harm or damage.
In very unique circumstances, it may be possible to discontinue the limited
RI/FS. For example, all drums may be empty, crushed, and/or filled with
contaminated soil. With this situation the drums would no longer pose as
immediate a threat and could be addressed in the full RI/FS along with
contaminated soil, ground water, etc.
2.3.5 DEFINE DATA NEEDED TO CONDUCT LIMITED FEASIBILITY STUDY
Purpose
The data needed to evaluate the feasibility of potential remedial
technologies (identified previously) are compared with the data collected
up to this point in the limited RI. If the limited RI data base is
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sufficient to conduct the feasibility study, the final component of the
limited RI can be omitted and the limited FS initiated directly. If there
are deficiencies in the data base which would restrict the performance of
the limited FS then additional data will be required.
Techniques
The types of data needed to evaluate remedial technologies are often
described in existing reference documents. A summary of data needs can be
prepared for techniques applicable to tank and drum remedial actions.
Table 2-2 has been prepared and presents a list of data needs for
evaluation of on-site disposal and/or treatment of tank and drum wastes.
This type of information would be useful for many components of the limited
FS (e.g., developing costs and design evaluation criteria). If treatment
options are being considered, the applicability of various technologies to
the site-specific waste characteristics should be reviewed.
Comparison of the data needs with the existing data base will identify any
data gaps. The data gaps for each of the technologies should be
consolidated into a master list and then evaluated for significance of the
missing data. Although certain data may not be directly available, it is
often possible to estimate certain parameters or quantities without
compromising the validity of a feasibility evaluation. However, current
EPA policy is that data must be adequate enough to prepare a +50/-30
percent cost estimate.
Limitations
Not applicable.
2.4 CONDUCT DETAILED FIELD INVESTIGATION
Once potential remedial technologies have been developed and data gaps
defined, a limited field investigation is performed to gather the required
data to evaluate the technologies. The following steps can be followed for
the final stage of the limited RI.
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TABLE 2-2
EXAMPLES OF DATA NEEDS FOR EVALUATION
OF POTENTIAL REMEDIAL ACTIVITIES
• Flood prone (Is the site located in the 100-year floodplain?)
• Seismic (Is the site located within 200 feet of a fault which has had
displacement in recent geologic history?)
• Groundwater vulnerability (Does groundwater under site have a rapid
rate of travel, i.e. greater than 100 feet per 100 years?)
• Is the site in a wetland?
• Is the site in area with karst, subsidence or landslide activity?
• Is the depth to the seasonally high groundwater elevation beneath the
site relatively shallow (i.e., less than 10 feet)?
• Is the groundwater beneath the site used for individual or municipal
water supply?
• Is the site topography relatively steep (i.e., greater than 30
percent)?
• Is the site located in the vicinity of a surface water body or a
groundwater recharge area?
t Have springs or seeps been identified in the area of the site?
• Has underground mining previously been performed in the vicinity of
the site?
• Is the site located in an area with weak and unstable soils?
• Is the hydraulic conductivity of the bedrock beneath the site
relatively high (e.g., as would be expected within a sandstone or
fractured zone)?
• Is the site located in close proximity to a residence, school,
hospital, commercial area, or other sensitive receptors?
§ Is an adequate buffer zone present around the site?
t Is the site located in close proximity to a public water supply
(e.g., reservoirs, watersheds or supply lines)?
• Are there unique and protected land uses adjacent to the site, e.g.
parks, historic sites, etc.
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2.4.1 PREPARE PROJECT OPERATIONS PLANS
Purpose
Prior to beginning on-site elements of the limited RI, certain planning and
preparation must be completed. The development of project operations plans
will assist the user in initiating the limited RI, performing the limited
RI in a safe and effective manner, and in being prepared for emergency
situations should they arise.
Techniques and Limitations
The major components of a project operations plan include a sampling plan
and a health and safety plan. In addition, a quality assurance/quality
control (QA/QC) plan may be included as part of the project operations plan
or as a separate document. Normally a quality assurance plan is formulated
outside of the project operations plan and quality control is addressed
within the project operations plan.
2.4.1.1 Sampling Plan. A sampling plan is developed to describe what data
will be obtained, what sampling will be performed, and how these tasks will
be completed. The plan is then reviewed by all involved parties to ensure
that data requirements will be met and that the data will be collected in a
proper and effective manner.
It is important to define specific objectives of the sampling program in
the plan. How data will be used in the limited FS should be indicated.
Also, the waste categories will be clearly defined with a description of
the relationship of these categories to the limited FS and project
implementation activities.
Many guidance documents exist for preparing a sampling plan (see Section
5), as well as sampling plans used for completed projects. A typical plan
for a tank and drum site would address the following topics:
• Goals of sampling effort
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• Use of sampling data (to select treatment or disposal options)
• Types of surveys to be performed (detailed drum inventory, detailed
tank survey, air monitoring, tank wall thickness and integrity,
etc.)
• Number and type of samples (primarily wastes from tanks and drums)
and constituents for analysis
• Sample analyses/compatibility testing: organic/inorganic,
reactivity, flash point, halogen content, PCB, cyanide, sulfide,
etc.
• Methodology describing sampling procedures
The characterization of types of wastes on-site is used to prepare design
reports, feasibility studies, cost estimates for cleanup, and contract
documents. Drum sampling prior to remedial action is generally limited to
a random sampling of the above-ground drums; tank sampling may be more
complete. The number of drums and tanks to be sampled is dependent upon
the total number on-site, costs, schedule, and physical condition of the
drums or tanks.
There are basically three strategies for drum sampling:
1. Sample all drums (probably requires staging)
2. Random sample with little or no staging
3. No sampling
The first strategy is the most thorough and also the most costly. It is
usually not practical for a limited RI/FS. The second strategy, as indi-
cated, is the most practical and has been the practice/policy at several
drum sites. Costs are kept fairly low and a limited data base is provided.
The random sampling approach does not provide a complete data base which
would be available from a full drum sampling program. However, a random
sampling program does provide a useful data base without the costs and
potential problems of a full sampling program. The staging and equipment
requirements for a full sampling program can extend the duration of the
limited RI and can be costly. No sampling avoids cost and schedule issues
but provides no direct analytical data on the drums.
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OSWER Directive 93fciGO-3
Some of the key issues to consider when weighing the potential advantages
and disadvantages of a particular drum sampling program are summarized
below:
1. A full sampling program will require drum staging or at least
considerable drum handling during the remedial investigation
activities. This will require special equipment and contingency
planning, including a complete health and safety plan and equipment
plus full decontamination facilities. These would not be necessary
with a more limited sampling program.
2. It would be very expensive to conduct a full sampling program of
drums. For example, just the decontamination facilities alone can
run $10,000 to $30,000 for equipment and personnel and $0.50 to
$1.00 per gallon for disposal of the wash water. Added to this
would be the obvious cost of sampling and analytical activities.
3. Before a cleanup contractor can remove drummed wastes off-site it
may be necessary to sample each drum for the following reasons:
- determine compatibility for bulking
- provide information for preparing manifest for shipment in order
to meet EPA and DOT requirements [see 40 CFR 262.11(c)]
- provide additional information (if required) for the TSD facility
receiving the waste
- ensure overall safety in handling, packaging and transporting
wastes
Since remedial contractors must sample all drums for manifesting
prior to transportation and disposal, it is usually cost-effective
to postpone a comprehensive drum sampling until the remedial
contractor is ready to initiate on-site activities. As a result
random sampling is performed to provide a data base for the limited
FS and primarily for preparation of contract documents.
4. Random sampling, while providing a limited data base can be a
useful alternative to full sampling. The data can be used to
expand the general knowledge of the site, but more importantly, it
has a useful function in preparing competitive bid documents.
5. No sampling of drums is obviously the least expensive way to
conduct a limited RI. However, without even a random sampling data
base, it becomes difficult to prepare a competitive bid package and
ultimately contract documents. Additionally, further planning and
design activities have to progress with little or no information on
the characteristics of drum wastes.
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uo\AtK Directive SJSO 0-3
A drum sampling program should be limited to approximately 5-10 percent of
the containers. The reasoning is that on an abandoned drum site, the
containers probably have accumulated at the site over a period of years,
possibly from many difference sources. Drums may be full of spent cleaning
solutions containing unknown material or manufacturing by-products.
Additionally, many of these sites functioned as recycling centers with the
more homogeneous or quality material being sold as a product. If a
manufacturer had a by-product of any worth or volume, it probably would
have been recycled directly and, due to transportation costs, would not be
shipped in individual drums. Also, because of the wide range in the types
of materials that may have been accepted at a site, random sampling would
not be statistically significant, but would only indicate the waste
category of the container sampled. Random sampling could, however, help
delineate between a site with a wide range of heterogeneous waste and one
with wastes of a homogeneous nature. This may provide evidence identifying
a site where waste was produced on site and the drums were used for
storage.
Random sampling can also provide some insight into the types of waste
categories that might be encountered at the site. Again, statistically
these data will have limited value in providing an accurate projection of
all the waste types or quantities, but this data base can be combined with
the drum inventory, presented in Section 2.4.2, to develop reasonable
estimates. This information is particularly important for preparing
contract documents and may be useful for the limited FS.
A "stratified" random sampling technique for drums may be applicable for
many sites. The approach differs somewhat from a pure random sample
program in that selection criteria are developed for groups of drums rather
than treating the entire site as one group. For example, a stratified
random sample approach may group drums found on-site into the following
categories:
• Drums of similar color and condition with labeling suggesting one
source/generator
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OSWER Directive 9380 0-3
• Drums with polyliners suggesting similar types of wastes
• Areas of drums which have been obviously separated from other drums
• Miscellaneous drums not falling into other defined groups
A random sampling procedure would be developed for each group. A
"stratified" random sampling procedure developed for the different groups
could result in a data base more representative than a pure random sample
selection which considers all drums on-site as a single group. The results
of a stratified random sampling program may suggest that wastes found in
similar drums or in one area are similar or dissimilar.
Random sampling of drums at two NPL sites involved 6 and 20-25 percent of
the drums, respectively. A considerable amount of detail was available for
one site and it was possible to determine the number of specific types of
drums and containers at various locations at the site. This information
was valuable to potential contractors in determining equipment needs and
drum removal costs. Also, using the data derived from the random sampling
effort, it was possible to develop a gross categorization of waste types
found at the site (Table 2-3). At the other site a similar approach
resulted in a characterization that provided an accurate engineer's cost
estimate for total cleanup.
Tank sampling has shown to be an advantage when addressing waste categories
and evaluating remedial action alternatives. This is primarily due to the
relative cost-effectiveness of a sample taken from a 20,000 gallon tank as
compared to the same sample from a 55 gallon drum. More importantly the
data on bulk quantities of waste can be very useful in the limited FS along
with helping in the preparation of contract documents.
In tank sampling, two key points should be made. The first is that tanks,
more so than drums, can maintain an internal explosive atmosphere, and as
such require special tools (cold cutting). Therefore, under an RI level of
effort, only tanks with access ports should be sampled. Secondly, tanks,
because of relative volume and quiescent condition, tend to stratify. It
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TABLE 2-3
CATEGORIZATIION OF WASTE TYPES AT AN NPL
SITE BASED ON RANDOM SAMPLING* OF DRUMS
Solids 19%
Acids 16%
Non-chlorinated Solvents 14%
Resins 9%
Aqueous Waste 7%
Alkali Waste 7%
Cyanide Waste 6%
Waste Oil 6%
Paint Waste 5%
Sludges 4%
Chlorinated Solvents 2%
Glycols 2%
Empty 1%
PCB Oil 1%
Based on a random sampling of 20 to 25 percent of drums,
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OSWER Directive 9380 0-3
is not uncommon for as many as three phases (oil, liquid and sludge) to be
discovered. A sample should be collected from each phase. The level of
sample analysis for either tanks or drums is generally limited to that
which is necessary to determine compatibility and that required for
disposal. Compatibility analysis is usually restricted to the tank waste
during the RI study but will be performed on all of the tank and drum waste
by the contractor as part of the consolidation and bulking protocol.
Appendix B includes an example of a drum and tank sampling protocol for
waste compatibility, and is followed by Appendix C, which presents the
protocol for bulking and consolidation of identified compatible waste
groups. Depending on the structure of any random drum sampling, a
compatibility analysis could be included as part of the drum sampling
program. The main categories of compatibility analysis include the
following:
t Ignitability (flash point)
• Radioactivity
• Determination of oxidizing or reducing agent
t Reactivity
• Density
• Concentration of organic halides
• PCBs
• pH
• Cyanides
• Sulfides
In order to further categorize wastes in terms useful for evaluating
potential treatment and/or disposal technologies, additional waste
characterization is needed. While compatibility characterization is a
useful first step more specific criteria are required for waste
categorization. Waste categories useful in evaluating various treatment
and disposal technologies are listed in Table 2-4.
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TABLE 2-4
WASTE TREATMENT DISPOSAL CATEGORIES
AQUEOUS WASTES
• Acid: pH < 2.0
• Base: pH > 12.0
t Base with sulfur
• Base with Cyanide
SLUDGES
• PCB Contaminated Classified as liquid
(50-500 ppm and > 500 ppm)
SOLIDS
ORGANIC LIQUIDS
• High halogen Content (> 2%)
• Low halogen Content (_< 2%)
• PCB Contaminated Liquid
(50-500 ppm)
• PCB Contaminated Liquid
(> 500 ppm)
CONTAMINATED WATER
• 2 < pH < 12
• Inorganic
• Organic
t PCB Contaminated Liquid
(< 50 ppm)
t PCB Contaminated
(> 50 ppm)
SLUDGE/SOLIDS
• Organic Low Halogen
• Organic High Halogen
• Inorganic
• PCB Contaminated (< 50 ppm)
• Flashpoint (< 70 °F)
• Flashpoint (70 - 140 °F)
• Flashpoint (> 140 °F)
SPECIAL WASTES
t Water Reactive
•Air Reactive
• Radioactive
• Strong Oxidizer
• Strong Reducer
• Lab Packs
• Explosives
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References have been made to Appendices B and C, example of a "Drum Han-
dling, Drum Sampling, Special Waste Handling, and Tank Sampling Protocol,"
and example of a "Bulking and Consolidation Protocol." Appendix B presents
compatibility testing procedures which must precede the actual bulking and
consolidation procedures included in Appendix C. The material presented in
these appendices can be used during planning activities for sampling,
during the actual execution of sampling activities, or during project
implementation. The protocols should be tailored to the specific needs of
the user. For example, random sampling for drums could include
compatibility testing if a "stratified" approach were used. However, the
use of a more general random selection approach may limit the usefulness of
a compatibility analysis. Compatibility analysis will always be required
before bulking or consolidating wastes.
In general, field analyses are typically less costly to perform than full
laboratory analysis. Sample shipping and chain-of-custody is minimized for
the majority of samples.
The user should be aware that any field analysis of samples will not
produce the litigation-quality documentation available through a
laboratory. Instead, field analysis can be used to develop information to
proceed with the project while a small percentage (e.g., 25 percent) of the
samples are sent to a laboratory for analysis and verification.
Additionally, field screening techniques are of limited value in complex
samples (e.g., oily sludges) and are not available for all contaminants.
For example, few field instruments measure inorganics. Additionally,
because of the concentrated nature of these samples, a laboratory equipped
to handle such high-hazard samples (such as EPA's hazard laboratory at
NEIC) may be required.
2.4.1.2 Health and Safety Plan. A health and safety plan is developed to
establish the procedures that will be followed during the execution of the
detailed field investigation. This plan is developed from earlier health
and safety protocols (See Section 2.2.2) and information assembled from
activities such as the initial site visit (Section 2.3.1). EPA's guidance
on health and safety can be found in Standard Operating Safety Guides (EPA,
1984).
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OSWER Directive 9380 0-3
To confirm the basis for the site worker respiratory protection protocol
contained in the health and safety plan, both on- and off-site air quality
monitoring should be initiated at the onset of the project mobilization and
maintained during on-site activities. Additionally, due to the nature of
waste materials commonly found in tanks and drums and their ability to
rapidly degrade ambient air quality, it is important to continue air
monitoring both on- and off-site during the limited RI so that potential
impacts from handling wastes can be evaluated.
A specific air monitoring program must be established for each site based
on the nature of the wastes present and site conditions. Sampling may be
performed for organics (volatile compounds), inorganics (cyanide gas), or
airborne particulate (asbestos). Methods currently used to monitor air
quality at tank and drum sites include:
• Direct reading methods
- Organic Vapor Analyzer (OVA)
- Photoionizatin detector
- Infrared gas monitors
- Explosive gas indicator
• Delayed quantification techniques
- Collection of samples using air sampling pump and sorbent
charcoal, glass filters, or other media.
Other components of the health and safety plan include training program
(for drum and tank entry and sampling), contingency plan (for drum breach,
drum explosion, etc.) and guidance on area and access restrictions.
Table 2-5 has been prepared as an example to develop procedures for safely
sampling tanks and drums. The operations presented in this table are
general in nature and must be modified or supplemented based on actual site
conditions. Because of the hazards inherent in these operations, safety
plans should be extremely conservative.
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OSWER Directive 9380 0-3
TABLE 2-5
EXAMPLE OF PROCEDURES FOR TANK AND DRUM SAMPLING: SAFETY ASPECTS
Protective Equipment:
Potential Hazards:
Hard hat, safety shoes, safety glasses, rubber gloves,
face shield, protective suit, respirator*, lifeline
(for tank sampling).
Fire and explosion, inhalation of toxic or flammable
vapors, skin contact with waste.
Operations
1. Inspect tank or drum
2. Monitor vapor concentrations
3. Ground tank or drum
4. Minimize exposure
5. Remove drum cap
6. Measure vapor
7. Insert sampler
Work Procedures
Examine tank or drum for signs of pres-
sure buildup, shock, sensitivity, etc.
Collect grab samples to determine
concentrations of organic compounds.
Clean surface area of tank and attach
ground.
Position employees upwind from tank
hatch or drum.
Slowly remove cap or bung, and allow
vapor to escape. For drums, use of a
remote or non-sparking bung removal
apparatus should be considered.
Collect grab samples to evaluate concen-
tration and flammability of vapor and
gases. If vapors are hazardous wait 5
minutes and retest.
For Tanks: Lower sampler (Bacon Bomb-
ASTM D-720) to collect samples of:
a. upper sample - middle - upper third
b. middle sample - middle of tank
*In some cases, the use of self-contained breathing apparatus is required when
the contents of a tank are unknown or suspected to be a high hazard. Under
no circumstances should the user enter the tank. This table does not address
tank entry procedures. See Appendix B for further details.
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OSWER Directive 93800-3
TABLE 2-5 (Continued)
EXAMPLE OF PROCEDURES FOR TANK AND DRUM SAMPLING: SAFETY ASPECTS
Operations
8. Collect sample
9. Retrieve sample
10. For Tanks: Cover tank
Work Procedures
c. lower sample - near bottom
For Drums: Insert glass sampling thief
into bung hole until solid material is
encountered.
For Tanks: Pull out bottle stopper
with sharp jerk of sample line and
allow bottle to fill.
For Drums: Place finger over end of
thief and remove from drum.
For Tanks: Raise sampler, wipe off
surface of sampler and place cloth in
disposable plastic bag. Tag sample and
record data on forms for drums:
Place bottom of thief in glass con-
tainer and release thumb for thief.
Repeat steps 8 and 9 until sufficient
sample is collected (200 ml).
Carefully close tank cover.
11. For Drums: Dispose of thief
12. Monitor vapor concentrations
Insert thief in bung hole and replace
bung. NOTE: if wastes are to be trans-
ferred, a screen must be placed on pump
intake to prevent damage by glass
pieces.
Collect grab sample to evaluate
concentration of vapor post-closure.
*In some cases, the use of self-contained breathing apparatus is required when
the contents of a tank are unknown or suspected to be a high hazard. Under
no circumstances should the user enter the tank. This table does not address
tank entry procedures. See Appendix B for further details.
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OSWER Directive 93800-3
2.4.1.3 Quality Assurance/Quality Control Plan. A quality assurance plan
is an assemblage of management policies, objectives, principles, and
general procedures to be followed in producing environmental monitoring
data of known and acceptable quality. Quality control refers to the
routine activities and checks, such as calibration and duplicate analysis,
conducted under the quality assurance program.
EPA's guidance on preparing quality assurance plans is found in Guidelines
and Specifications for Preparing Quality Assurance Project Plans, (EPA,
1983). The sixteen components of a quality assurance plan according to the
EPA guidance are:
1. Title page with provision for approval signatures
2. Table of contents
3. Project description
4. Project organization and responsibility
5. QA objectives for measurement data in terms of precision, accuracy,
completeness, representativeness, and compatibility
6. Sample procedures
7. Sample custody
8. Calibration procedures and frequency
9. Analytical procedures
10. Data reduction, validation and reporting
11. Internal quality control checks
12. Performance and system audits
13. Preventive maintenance
14. Specific routine procedures to assess data precision, accuracy and
completeness
15. Corrective action
16. Quality assurance reports to management
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OSWER Directive 9380 0-3
Some of these components of the quality assurance plans are actually
quality control procedures. For example, the "Calibration Procedures and
Frequency" section of the QA plan may merely reference the applicable
standard operating procedure (quality control) found in the sampling plan
or health and safety plan.
2.4.2 PERFORM TANK AND DRUM SURVEY/INVENTORY
Purpose
This task will provide information describing the number, type, and
condition of drums, the type of wastes in the drums (liquid, sludge, solid,
etc.), and the source of the drums. Additionally, important information on
tanks can be obtained by a survey from the air or ground. This information
will play a major part in the selection and development of the remedial
program, evaluation of disposal technologies, and development of bid
documents. Preliminary information was developed during the initial site
visit (e.g., estimated number of drums). This physical survey is more
detailed and comprehensive than the initial site visit.
Techniques
A drum survey is an actual physical inventory and evaluation of drum
wastes. It is different from random sampling in that no detailed chemical
analyses are performed. The drum survey must be tailored to the size and
nature of the site. Two major techniques, aerial survey and ground survey,
are typically used to perform this task. There are advantages and
disadvantages associated with each of these methods. Usually an aerial
survey will supplement a ground survey. The characteristics of these two
types of surveys are summarized in Table 2-6. Examples of techniques for
examining, handling, staging, (if applicable) and labeling drums are
contained in the references in Section 5.0. It should be noted that
depending on the number of drums and access to them, it may not be possible
to inspect every drum. Tasks typically performed include:
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OSWER Directive 9380 0-3
TABLE 2-6
ASPECTS OF AERIAL AND GROUND DRUM SURVEYS
ASPECT
Drum Count Possible
Identify Drum Type
Identify Overpacks and Polypaks
Label Identification
Evaluate Drum Integrity
Note Presence of Pails, Buckets,
Boxes, etc.
Note If Drums Have Bulged
Number Drums
Cost of Survey
METHOD
AERIAL GROUND
YES
PARTIAL
PARTIAL
PARTIAL
DIFFICULT
YES
DIFFICULT
NO
LOW
YES
MOST OR ALL DRUMS
YES
YES (IF PRESENT)
POSSIBLE
YES
YES
YES
MODERATE TO HIGH
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OSWER Directive 9380 0-3
• Drum count and aerial classification (number of drums and location
on site)
• Note drum type (bung or lid, steel or plastic)
t Presence of polypacks and overpacks (If these types of drums are
present on site, the contractor should realize that the drums
probably contain wastes which are capable of degrading steel
containers or contain drums of low structural integrity.)
• Label identification (An attempt should be made to record all
labeling on drums to assist in the identification of the drum
contents. If proper manifesting occurred during site operation,
this effort may produce very good results. However, because waste
products are often placed in used containers, the labels should not
be the sole basis for classifying the drum wastes.)
• Noting drum integrity and evidence of leakage (Drum integrity can be
evaluated by carefully sounding the drums, examining them for
degradation, and other non-intrusive techniques.)
t Note if drum ends bulge
• Numbering drums (for future identification)
An example drum inventory form that could be prepared prior to initiation
of the survey is presented in Table 2-7, although a form allowing more
information on drum identification and condition may be of value. A
computer-compatible form may be useful to allow easy data entry. This is
particularly true for sites with a large number of drums. Information
could be derived from a detailed drum inventory on probable waste
categories based on the type of drum. These are presented as follows:
• Empty - drums with less than 1 inch of residual solids in the bottom
can be crushed and disposed of as an empty drum (see discussion
below)
• Lab packs - these are 55 gallon ring top drums which contain
numerous small containers of unknown laboratory wastes.
• Overpack - these are 80-85 gallon oversized drums used to hold a
standard (damaged) drum
t Polyliner - these are generally 55 gallon drums which contain a
plastic bladder usually containing highly caustic (acid or alkaline)
wastes
• Polydrums - these are fiber polylined disposable drums which contain
caustics.
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OSWER Directive 9380 0-3
TABLE 2-7
EXAMPLE DRUM INVENTORY FORM
LOCATION
Zone A
Zone B
Zone C
Bldg #1
TOTAL
EMPTY
75
3
12
0
90
LAB PACKS
(ACTUALLY
SEEN)
2
0
1
10
13
OVER-
PACKS
25
40
0
0
65
POLY/
LINER
15
0
6
50
71
POLY-
/DRUM
15
0
7
50
72
BUNG
TOP
50
140
15
80
285
RING
TOP
40
40
12
0
92
OTHER
CONTAINER
ioa
0
0
15C
25
MISCEL-
LANEOUS
250b
200b
450
TOTAL
482
223
253
205
1163
NOTES:
a. Unlabeled five gallon containers
b. Piled drums, access restricted, quantity is estimate
c. Unlabeled one gallon containers
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OSWER Directive 9380 0-3
• Bung top - this is a standard 55 gallon drum with the typical 2-3
inch screen hole on the top, used to carry liquids such as spent
solvent waste
• Ring top - these are the standard 55 gallon drums that are open top
usually containing solids or resins
Under certain conditions, empty drums may be disposed of at a sanitary
landfill. However, possible restrictions on the disposal of materials
found at NPL sites should be reviewed with appropriate agencies. Addi-
tional information on the definition of empty drums can be found in 40 CFR
261.7. Also, limitations on the reuse of drums can be found in 40 CFR
173.28.
Staging of drums (the process of moving drums from various locations to one
area in a logical and systematic manner) is not recommended because of high
costs and hazards associated with this activity. Staging should be
considered only under the following conditions:
t Very obvious hazards if left unstaged (incompatible labeled drums
next to each other)
• Drums are leaking
t There are severe access restrictions
t Drums can easily be grouped by type (a possible advantage during the
development of bid documents)
If staging is required, a staging plan should be developed and reviewed by
all involved parties. In planning staging areas, the size and goals of the
operation, accessibility of drums in their original locations and the
hazards associated with the drums must be considered. There may be up to
five staging areas that can be used:
• Initial staging area - organize drums and store prior to sampling
• Opening area
• Sampling area
• Holding area - temporary storage area prior to characterization of
contents
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OSWER Directive 9380 0-3
• Bulking area - should be located as near to the site's exit as
possible
The number of areas used and movement of drums should be minimized. Drums
are generally staged in rows which allow ease of access and handling.
The major elements of a tank survey include determination of:
0 Number of tanks
• Tank location
• Tank volume and size
• Structural integrity (using visual examination or methods such as
x-ray and ultrasound)
t Accessibility (Is there sufficient ground space and overhead
clearance to allow use of articulated boom crane? Can personnel
climb into tanks?)
• Volume of waste in tanks (methods include sounding, probing, and
visual inspection)
t Nature of waste in tanks
• Existing mechanical plant (pumps, compressors, pipes), piping, and
other connections between tanks.
Limitations
The drum survey is designed to gather as much information as possible
without actual analytical activities. Drum sampling may or may not be
performed during the limited RI. Drum staging should be avoided except for
very unique or special occasions.
Due to the questionable integrity of certain tanks on-site, only limited
data may be obtained from these tanks. Additionally, special equipment and
tools may be required to open and/or sample these and other tanks. This
could include the use of an articulated boom crane to provide access to the
tank, use of remote opening devices, and use of self-contained breathing
apparatus (SCBAs) by personnel.
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OSWER Directive 9380 0-3
2.4.3 CONDUCT SITE CHARACTERIZATION
Purpose
Information describing site conditions other than tanks and drums are
required for remedial alternative evaluation and planning. These data
are obtained as part of site characterization activities.
Techniques
Typical site characterization tasks include:
• Property line, topographic, stadia and aerial surveys (to define
site limits, access, drainage, relief, and layout.)
• Confirmation of site utilities and facilities (to determine how
existing facilities will affect work, what utilities are needed,
etc.)
t Identification of areas of contamination (may be completed by visual
inspection, sampling, geophysical survey, infrared photography,
etc.)
• Description of subsurface conditions. (Existing boring logs, well
reports, etc. may be available. If these are not available,
information is obtained through a boring and soil testing program,
which is not usually a part of a limited RI.)
Limitations
This information may have been collected during the initial site visit so
that no further site characterization is required.
2.4.4 CONDUCT SAMPLING PROGRAM
Purpose
This activity executes the sampling program developed as a result of those
activities described in Section 2.4 Prepare Project Operations Plans. As
previously discussed, all tanks should be sampled, whereas random sampling
drums may be the preferred approach.
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OSWER Directive 9380 0-3
Sampling of drums and tanks prior to removal at a site provides more
information on waste type and volume so that accurate contract documents
can be prepared and a safe and efficient removal operation can be
conducted. Unit price contract documents can be prepared with limited
sampling data if sampling was done to verify the disposal categories and
volumes of waste.
Data from a sampling program and laboratory analysis would include:
t Volume of waste
• Type of waste (solid, liquid, sludge, etc.)
• Presence of stratified layers in tanks
• Chemical composition of wastes in tanks (and possibly randomly
selected drums)
• Characterization of waste by disposal categories (Section 2.4)
• Correlation between drum labels or shipping manifests and drum
contents
• Waste compatibility or treatability (Section 2.4)
Techniques
Detailed drum and tank sampling procedures previously developed are
presented in the references listed later in this manual (Section 5).
Additionally, examples of drum handling and sampling, special waste
handling, and tank sampling protocols used during remedial actions at an
NPL site are included in Appendix B and C. Suggested guidance provided in
these appendices should be tailored to fit the structure of the planned
sampling activities and site-specific requirements.
As waste sampling is being performed, many of the compatibility tests can
be performed on-site to reduce turn-around time and make drum staging (if
necessary) more efficient. However, most compatibility testing will focus
on tank wastes since it is typically the practice to sample all tanks
whereas random sampling is only performed on drums.
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OSWER Directive 93800-3
Because there are generally fewer tanks present on-site, and tanks are
usually more accessible than drums, the tank inventory and sampling process
may be simplified. In most cases, it is possible to sample and inventory
all bulk storage tanks during the limited RI. This information will be
valuable in determining the appropriate type of treatment and disposal
technologies for the tank wastes and preparing contract documents.
Limitations
Very strict health and safety procedures should be followed during all
field activities of the limited RI, particularly during sampling
activities (Section 2.4).
2.4.5 REVIEW ANALYTICAL RESULTS FOR CONFORMANCE WITH QA/QC PROGRAM
Purpose
EPA has developed QA/QC protocol and evaluation methodology to verify the
accuracy and reliability of analytical data. The analytical data generated
during the limited RI must be examined in accordance with these methods to
assure their reliability and subsequent usefulness.
Techniques
Step-by-step QA/QC validation protocol have been developed by EPA (Section
2.4.2.3).
Limitations
Not applicable
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OSWER Directive 9380 0-3
2.4.6 EVALUATE ALL DATA AND PREPARE LIMITED REMEDIAL INVESTIGATION REPORT
Purpose
The evaluation of data is an ongoing process throughout the limited RI.
However, once all field work has been completed and the data base is
essentially complete, a final analysis is conducted. The activities of the
limited RI and the results of the data evaluation are then presented in a
remedial investigation report. During this final analysis the scope of the
limited RI/FS is again reviewed.
Techniques
This evaluation of data should focus on the needs of the limited FS
(described in Section 3). The objectives of various data collection
activities are reviewed and then compared to the actual results of the
limited remedial investigation. It is important to ensure that the data
obtained satisfies the earlier defined objectives. If the objectives have
been adequately met, the quality of the limited FS, which is based upon
data obtained during the limited RI, will be enhanced.
A remedial investigation report on the tank and drum operable unit should
integrate and present a discussion of activities and observations made
during the limited RI, and include an evaluation of these data. Detailed
discussion of the contents of a limited RI report are presented in EPA
guidance documents referenced later in Section 5.0. A typical report for a
tank and drum site could contain (but is not limited to) the following
major elements:
• Site Background Information
t Nature and Extent of Problem
t Limited Remedial Investigation Summary
• Overview of Report
0 Demography
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OSWER Directive 9380 0-3
• Land use
• Natural Resources
• Climatology
t Updated Base Map
t Hydrogeologic Features
• Surface Features
• Tank(s) Features
• Drums Features
• Site Health and Safety Features
• Bench and Pilot Tests (if applicable)
t Potential Receptors
• Public Health Issues
t Environmental Issues
• References
i Appendices
Evaluations of the expanded data base could indicate that the magnitude
and/or complexity of the hazardous waste and environmental problems at the
site are too great to remain within the scope of the limited RI/FS
approach. If this is the case, a full-scale, comprehensive RI/FS may need
to be considered in lieu of a limited single operable unit approach.
Limitations
Not applicable.
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OSWER Directive 9380 0-3
3.0 LIMITED FEASIBILITY STUDY
There are four major components of the limited FS. These are:
• Identify major remedial technologies (Section 3.1)
• Screen initial remedial technologies (Section 3.2)
t Conduct detailed evaluation of potential remedial action
alternatives (Section 3.3)
• Conduct comparative summary of potential remedial action
alternatives (Section 3.4)
The process of identifying, reviewing, and screening remedial technologies
is ongoing throughout limited RI/FS activities. During the limited RI
phase, technologies that are potentially applicable to the site are
identified. Then, as the limited RI progresses, site limitations and waste
characteristics are identified which preclude various remedial measures.
This screening leads to the list of remedial alternative strategies to be
addressed in the limited FS.
There are two major screening and evaluation phases of the limited FS. The
first phase involves the identification and screening of alternative
remedial technologies for each major alternative strategy. During this
phase the technologies are screened based on technical feasibility and
reliability, costs, environmental and public health effects. The results
of the first phase define the components of each alternative for remedial
action.
The second phase involves the development and evaluation of complete
alternative plans of remedial action. The evaluation in this phase is
based on more detailed cost, environmental, public health, and technical
data, along with a consideration of regulatory and institutional concerns.
It is important to understand the difference in the meaning of the two
terms "technology" and "alternative". A remedial technology is typically
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OSWER Directive 9380 0-3
specific to a waste type or a group of similar waste types. For example,
incineration is a remedial technology potentially applicable to organic
materials. A remedial action alternative is specific, in this case, to an
operable unit at a site. One remedial action alternative could be
comprised of many different remedial technologies, e.g., an off-site
alternative may involve the incineration of organic wastes, the treatment
of aqueous wastes and the land disposal of various sludges and solids.
A limited FS is a necessary and logical element in the procedure to develop
specific remedial action alternatives for an NPL site. The purposes of a
limited FS for a drum and tank site are:
t To identify technologies or remedial measures which are most
appropriate for implementation at the site. Within each remedial
measure further analysis may be required to evaluate the cost
effectiveness of alternative remedial technologies (e.g., high
temperature incineration, recycle, etc.)
• To develop alternatives to abate, stabilize, or minimize release of
wastes from drum and tank sites
• To evaluate the cost-effectiveness of alternative remedial measures
for treatment, storage, disposal or destruction of wastes within
drums and tanks at a site
t
To incorporate these technologies or remedial measures into overall
remedial action plans for the site and evaluate their comparative
features.
This evaluation and selection process must be consistent with CERCLA and
Section 300.68 of the National Contingency Plan (NCP).
Specific guidance for conducting feasibility studies at NPL sites can be
found in EPA's Guidance Document for Feasibility Studies Under CERCLA (EPA,
1985). Guidance for conducting feasibility studies under CERCLA and
procedures for evaluating hazardous waste sites with surface tanks and
drums are contained in the literature (See references for Sections 3.2,
3.3, and 3.4 that are presented in Section 5). This section presents an
3-2
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OSWER Directive 93800-3
approach for conducting a limited FS at a surface tank and drum site. A
guidance logic diagram which displays the sequence of tasks is presented as
Figure 3-1.
This section is organized to correspond to the individual tasks shown in
Figure 3-1; text subsection numbers for these tasks are directly
cross-referenced to the figure to provide easy orientation for the user.
For planning purposes one can assume that a calendar period of 1-2 months
would be required to complete a limited FS. One should also assume that
the limited FS can begin during the limited RI. The time requirements for
the various tasks will vary from site to site.
3.1 IDENTIFY MAJOR REMEDIAL TECHNOLOGIES
Purpose
The purpose of this task is to review the data collected as part of the
limited RI and to identify the conceptual treatment and/or disposal techno-
logies and strategies available for the different waste types found at a
surface tank and drum site. The major waste types which would be defined
in the limited RI are reviewed in Section 2.4.1. A preliminary review of
potential remedial actions would be included in the limited RI. This
review would include an identification of potential remedial technologies
(Section 2.2.4) along with a refinement of this list based upon unavoidable
and restrictive site features. The objective of this task is to further
identify and define "conceptual" technologies and strategies which are
potentially feasible for major waste types known or suspected in drums and
tanks.
Techniques
During this task, the possibility of consolidating the individual waste
types into a smaller number of composite wastes should be evaluated. It is
essential that consolidation procedures available in the literature be con-
firmed in the field by sample compositing or other small scale techniques.
3-3
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OSWER Directive 9380 0-3
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3-4
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OSWER Directive 9380 0-3
Data available from the sampling program conducted in the limited RI
(Section 2.4.4) should be used to evaluate the potential for waste bulking.
A more detailed discussion of bulking is presented in an example bulking
consolidation protocol, included as Appendix C.
The user should identify the remedial technologies that address cleanup of
the project site with respect to the contamination migration pathways. For
surface tanks and drum sites, remedial technologies are primarily those
which provide for direct control of the wastes. Conceptual technologies
can be different for tanks than for drums. Materials stored in tanks have
the potential for a broader spectrum of control technologies because:
• It is more cost-effective to manage bulk quantities than small
drummed quantities
• Experience has shown that there is more uniformity to wastes in a
tank because the material was either a raw product or had the
potential for recycling or incineration. Bulking in tanks from
drums or bulk shipments was typically done at these sites to
maintain a certain quality or characteristic for reuse or processing
for reuse.
Typical conceptual technologies for various categories of drum and tank
sites include:
t Physical/chemical/biological treatment (or pretreatment) to reduce
the hazard
• Incineration to destroy the waste
• Processing, such as solidification, then land disposal (review
current policy with EPA and regulatory agencies)
• Deep well injection (review current policy with EPA and other
regulatory agencies)
• Recycle and reuse with or without pretreatment
• Direct land application (review current policy with EPA and other
regulatory agencies)
The designation of appropriate treatment methods will depend largely on the
form of wastes (e.g. solid, liquid, or sludges) and concentration of the
3-5
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OSWER Directive 9380 0-3
waste materials as well as various site characteristics. Hence, special
attention may have to be directed toward the evaluation of physical phase
separation procedures as a means of increasing waste suitability for a
particular disposal option.
A matrix has been developed to relate the type of wastes to be handled at
drum and tank sites to the types of waste treatment and disposal systems
available. The treatment methods available for review are shown in Table
3-1. Only those treatment methods which have potential applicability to a
given waste type and/or disposal categories (based on best engineering
judgment and past experience) should be reviewed. This information has
been developed as a planning guide and assigned designations should always
be re-evaluated in terms of waste and site specific information.
Each activity or option has been designated either: (1) a reasonable
option, or (2) a non-reasonable option. A "reasonable option" designation
is given for a particular waste if, from a technical perspective, a
treatment/disposal option has been shown to be feasible and reliable. For
example, the treatment of aqueous wastes from an uncontrolled hazardous
waste site by physical/chemical processes has a fairly well established
"track-record." A non-reasonable designation is given for a particular
waste stream when a treatment/disposal option would not be technically
feasible for a drum and tank site or is only feasible under unique
conditions.
After an initial determination of the technical feasibility of a remedial
technology, a determination should be made of whether the alternative is
either prohibited from selection as a matter of law (such as off-site
disposal of hazardous waste from a Superfund site at a facility not in
compliance with Subtitle C of RCRA) or is otherwise inconsistent with
another environmental standard. An alternative which is legally prohibited
for Superfund actions may not be selected. On the other hand,
identification of an apparent inconsistency with another standard or
criteria does not rule out selection of an alternative but should trigger a
more thorough inquiry into the ability of that alternative to achieve
adequate protection of health and the environment. EPA has proposed a
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OSWER Directive 9380 0-3
TA8LE 3-1 CATEGORIES AND POTENTIAL
TREATMENT/DISPOSAL TECHNOLOGIES
ON-SITE
PREP
ACTIVITIES
TREATMENT AND DISPOSAL
TANK AND DRUM
WASTE CATEGORIES
AQUEOUS WASTES
• Acid- pH < 2 0
• Base-pH> 120
• Base vlth Sulfur
• Base vith Cgenlde
ORGANIC LIQUIDS
• High Halogen content (>2*
Organic liquids Including
* Lov Halooen content CD-2X)
• Otis non-PC8 oont«mftu(t4
PCB Contaminated Liquid
4 <50-500i>nm)
PCB Contaminated Liquid
* ( > 500 ppm)
CONTAMINATED WATER
• 2 < pH < 1 Z
• Inorganic
• Organic
. PCB Contaminated Liquid
( < 50 ppm )
• Pesticide
SLUDGE/SOLIDS
* Organic Lov Halogen
Organic High Halogen
* Inorganic
• Flash point (< 70 °F>
• Flashpoint (>70-I40°F)
. Fl«sh point (> 140° F)
PCB Contemi noted Solid
* (
PCB Co ntami noted Solid
' (>50-500 ppm)
PCB Contaminated Sol Id
* (»500ppm)
• Pesticide
• Petroleum Residues
SPECIAL WASTES
• Strong Oxidlzvr
• Strong Reducer
. Lib Pacts
• Explosives
i
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Pnesed v«ste shell be separated tnd handled u individual waste items
Mixed vesta shall be classified under the more restrictive disposal category
t • Reasonable Oatton
2 ' Not Reasonable! Impractical,Tecnnlcellg Infeasi&ie)
• • Further delnled analysis is warranted
3-7
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OSWER Directive 93800-3
policy on compliance with other environmental laws which, when final, would
restrict EPA from selecting alternatives which did not attain or exceed
applicable or relevant federal standards, except in certain limited
circumstances."
The delineation of on-site or off-site treatment processes is also
important from a planning perspective. In some cases the designation for
similar waste classes and treatment/disposal options indicate that on-site
options are not as favorable/reasonable as off-site options for tank and
drum sites. The following issues summarize the reason for this difference:
t Off-site options are usually already existing and design, capital,
and start-up costs and schedule considerations are not a factor.
• Infrastructure, i.e. utility, support requirements for some on-site
treatment/disposal options may be difficult to satisfy on some
sites.
• Physical site features may be restrictive for on-site activities.
• Temporary on-site or mobile facilities may not have the through-put
capability of more permanent off-site facilities.
• The off-site cost may be considerably less since the capital costs
for a facility erected on-site should be credited entirely to the
waste managed at that site, whereas if an off-site alternative is
selected, the capital costs are spread over all uses of the facility
over time. Even though transportation costs must be incorporated
into an off-site alternative, this is often far outweighed by
capital costs, review schedules and practicality.
0 On-site disposal would require extensive engineering and design, and
may include meeting post-closure monitoring and maintenance
requirements. These factors render on-site disposal more difficult
from cost, schedule and effort perspectives.
On-site treatment may be limited to pretreatment for the purpose of
consolidating specific waste types or characteristics such as phase
separation, coalescing for oil extraction, chemical incompatibility,
neutralization, solidification and bulking.
The types of solidification/fixation technologies that could be used for
either on or off-site are dependent on two basic properties of the waste:
1) physical state, i.e. liquid, sludge and solid, and 2) chemical nature,
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OSWER Directive 9380 0-3
i.e. organic and inorganic. The application of these technologies is
directly related to the final disposal of the material. Solidification
generally refers to techniques that reduce the leachate production
potential by physical processes whereas fixation techniques typically
reduce leachate potential by chemical processes. These terms are often
used interchangeably and both are often referred to as stabilization
techniques.
In many cases, the relative cost per volume (or economy of scale) to
provide the extra handling and meet the analytical requirements for
chemical fixation can be very high. Chemical fixation is more widely
applicable for inorganic wastes such as, fly ash, scrubber residue, and
metal tooling and plating by-products. The inorganic wastes can be readily
mixed with lime, fly ash and ready-mix concrete. Solidification/fixation
technologies have been more widely applied to inorganic wastes than organic
wastes, however, some developing techniques have been successfully applied
to various types of organic wastes. Solidification/fixation of wastes can
be performed either on or off-site and is typically appropriate before
final disposal.
Commonly utilized off-site treatment and disposal systems include physical/
chemical treatment, land disposal, and incineration. Recycle/reuse has
limited applicability for drum wastes, because one would not expect to find
significant volumes of "pure" waste. It can be more readily applied to
tank wastes, in part because of the larger volume and consistency of waste.
Where unusual or uncertain waste characterization or composition makes
determination of probable treatment efficiencies questionable, it may be
necessary to conduct bench-scale treatability studies or other tests in
order to ensure full-scale success. For example the BTU value of a waste
may need to be determined if incineration costs are to be accurately
developed or knowledge of the percent solids of a sludge may be necessary
for the evaluation of some technologies. Additionally, a study utilizing a
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OSWER Directive 9380 0-3
small activated carbon column may be conducted to determine removal
efficiency for various organics. Evaluated treatment systems which require
such pilot- or bench-scale verification should be identified, along with
the time and materials needed for their execution.
Planning for the handling of empty drums should also begin at this stage of
the limited FS. Depending upon waste characteristics and earlier uses and
activities at a site the condition of drums can vary. Some drums may be
severely deteriorated and highly contaminated, while others may be clean
and never used. Typically, an empty drum is defined as a drum which has
one inch or less of residue left in the bottom of the drum (refer to 40 CFR
261.7 for further details). If the drum is not cleaned further it can be
crushed and disposed of as a bulk hazardous waste. If the drum is cleaned
it may be recycled/reused or disposed of (possibly in other than a
hazardous waste landfill). The cleaning requirements are very strict
(refer to 49 CFR 173.28) for the reuse of drums that contained hazardous
waste. The cost of drum cleaning would have to be balanced with the
alternative cost of crushing and direct disposal.
3.2 SCREEN INITIAL REMEDIAL TECHNOLOGIES
Section 300.68(h) of the NCR requires that these potential technologies be
screened using the following criteria:
• Technical, reliability and feasibility (Section 3.2.1)
As a result of the technology screening, inappropriate technologies are
eliminated from further detailed analysis. The remaining technologies are
screened for:
• Environmental and public health impacts (Section 3.2.2)
• Cost (Section 3.2.3)
For a simple site, one that has a few hundred drums and one or two above-
ground storage tanks, the user should proceed directly to Section 3.3
because the low volume typically limits the applicability of many options.
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OSWER Directive 93800-3
3.2.1 EVALUATE TECHNICAL RELIABILITY AND FEASIBILITY
Purpose
The purpose of this task is to evaluate the feasibility and reliability of
the remedial technologies given the location and conditions of the
hazardous waste site and of the surface tanks and drums on the site.
Additionally, potential limitations due to state-of-the-art applications or
limited "track record" will be defined.
Techniques
The user should identify the level of technology development, performance
record, and inherent construction, operation, and maintenance problems for
each technology considered. An example of an unreliable technology might
be an off-the-shelf process or package system that is waste specific. On
many drum sites the waste is not homogeneous. On such wastes, waste-
specific process trains would have a limited application. Technologies
which are unreliable, offer inferior performance, or are not demonstrated
processes should be eliminated from further consideration. Technologies
available at permitted off-site waste management facilities can, for the
most part, be considered proven technologies.
Technologies that are in experimental or developmental phases may be
acceptable, however, they should be evaluated very carefully particularly
with regard to waste specificity restrictions. Experimental processes for
a drum and tank site could include on-site, bio-assimilation, or any such
"treatment" process with unique performance requirements. In order to get
a reasonable estimate on technical reliability and feasibility development,
or experimental processes, may require fairly extensive pilot testing.
Some may show promise on a specific waste stream or in test operation. In
most cases, however, these could only handle a fraction of the material
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OSWER Directive 93800-3
(particularly drum wastes) found at the site because of the very
heterogeneous nature of wastes and specificity of many treatment processes.
The potential applicability to large volumes of homogeneous tank waste may
be better than for use on drum wastes.
Limitations
Limitations of various remedial technologies applicable to surface tank and
drum sites are presented in Planning and Implementation of Response Actions
for Hazardous Waste Sites with Drums, U.S. EPA, Contract No. 68-03-3113. A
general screening methodology for evaluating the limitations of remedial
technologies at any type of site (not necessarily a tank and drum site) is
presented in the Handbook for Remedial Actions at Waste Disposal Sites
(EPA, 1982).
3.2.2 EVALUATE ENVIRONMENTAL AND PUBLIC HEALTH EFFECTS
Purpose
The purpose of this task is to evaluate the identified technologies that
have significant adverse environmental effects and/or are not likely to
achieve adequate control of the hazardous wastes at the surface tank and
drum site. Potential positive environmental features should be defined as
well.
Techniques
As indicated, this analysis should focus on both negative and positive
impacts. Some alternative technologies may have emissions/discharges
requiring careful control, while others may require more materials handling
and increase the risks of exposure or accidents. From a positive or
beneficial impacts perspective, some technologies could be more effective
in site cleanup and/or waste destruction.
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OSWER Directive 93800-3
Potential adverse environmental and public health impacts which may
preclude the use of an alternative should be identified. This is most
effectively accomplished by conceptually identifying the major steps
involved in implementing each alternative and then determining if any will
result in adverse environmental or public health impacts. Positive impacts
of an alternative should be considered against any potential adverse
impacts from an alternative's implementation. Representative site and
waste characteristics which could be considered in this analysis are
presented in EPA's Guidance Document for Feasibility Studies Under CERCLA
(EPA, 1985).
Inconsistency with other environmental requirements, such as the following
examples, may indicate that an alternative may not adequately protect
public health and the environment.
• Air emissions of chemicals that would exceed Clean Air Act regula-
tions or state requirements for toxic compounds
• Discharges to surface soils that would exceed land disposal
regulations
• Discharges to ground water that would violate federal or state
regulations
• Discharge to surface waters that would violate any applicable
federal or state regulations
Limitations
When conducting this environmental screening, certain limiting factors
should be considered to control the level of effort expended. Due to the
limited scope of typical operations, major environmental issues are not
usually expected from drum and tank remedial actions. For example there
would be little excavation of material that would enhance the
volatilization of organics.
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OSWER Directive 9380 0-3
The objective of the evaluation is not to extensively evaluate substan-
tially similar technologies but rather to consider the major differences
between alternatives. For example, similar on-site alternatives can be
eliminated if those technologies being considered will result in un-
acceptable discharges to the environment. It should be noted that this
analysis pertains to on-site remedial actions and transport to off-site
facilities. It is assumed that off-site treatment and disposal would be
performed in compliance with all applicable environmental regulations by
regulatory permit conditions.
3.2.3 EVALUATE COSTS
Purpose
The objective of cost screening is to evaluate identified technologies, and
define those that have costs which are significantly greater (e.g., an
order of magnitude) than other alternatives, and do not provide
substantially greater environmental or public health benefits.
Techniques
The screening can be divided into three basic tasks: (1) estimation of
costs for each technology; (2) present worth analysis of each technology,
if applicable, and (3) cost comparison of the technologies.
Costs consist of all financial outlays required for implementation of the
action including engineering, design, construction, operating and mainte-
nance expenditures, general and administrative expenses, material
transportation and disposal, and other costs as appropriate. Major cost
categories and components of cost categories are highlighted in the
Guidance Document for Feasibility Studies under CERCLA (EPA, 1985).
Additional costs may exist, depending upon the particular remedial alter-
native under investigation. These costs should be identified and evaluated
on a case-by-case basis. Also, there may be situations where revenues
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OSWER Directive 9380 0-3
could be realized as a result of some recovery value of a particular waste
and these would be considered in the cost analysis.
A present worth analysis may be necessary to compare alternatives that have
expenditures which occur over different time periods. EPA's Costing
Procedures Manual should be referenced for procedures on conducting present
worth analysis.
The focus of this screening analysis is on relative differences in costs.
Therefore, the required detail is not as extensive as a more comprehensive
design/feasibility type study.
Limitations
When preparing screening cost estimates, the objective in calculating the
costs is to achieve at least an accuracy of -50 to +100 percent.
3.2.4 REFINE LIST OF POTENTIAL REMEDIAL ACTION ALTERNATIVES
Purpose
This task consolidates the results of the screening activities described in
tasks 3.2.1, 3.2.2, and 3.2.3. The principal objective during this task is
the development of a list of potential remedial action alternatives that
appear reasonable in terms of:
• Technical feasibility and reliability
• Minimizing actual or potential environmental and public health
impacts from the tanks and drums
• Capital, operation and maintenance costs
Techniques
Treatment technologies with severe constraints due to design limitations,
marginal track records or application to only a small fraction of the waste
would be initially screened from the candidate list of potential
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OSWER Directive 93800-3
technologies. Further screening using the criteria of preliminary cost,
general environmental and public health effects would eliminate those
technologies with relatively poor ratings from further consideration.
Technologies with high relative costs with no significant environmental or
technical benefits should be screened out. Those options with unacceptable
adverse environmental impacts or public health risks would be eliminated.
The remaining technologies would have no major limitations from a technical
feasibility and reliability perspective while at the same time appearing
reasonable in terms of cost and environmental and public health issues.
These remaining technologies would be combined to form various alternative
remedial actions for handling the identified tank and drum waste found
on-site.
The categories of basic remedial alternative strategies should include:
• Alternatives for off-site treatment or disposal
• Alternatives which attain applicable or relevant federal public
health and environmental standards
t Alternatives which exceed applicable or relevant federal public
health or environmental standards
• Alternatives which do not attain applicable or relevant federal
public health or environmental standards but will substantially
reduce the likelihood of present or future threats from hazardous
substances
t Consideration of the no action alternative to assess the public
health and environmental threats that exist at a particular waste
site
Limitations
There may be a tendency to "over analyze" the potential list of alter-
natives in terms of the previously defined screening criteria. This entire
screening process should not require a very detailed and/or laborious
effort. Many of the relative ratings and decisions can be based upon good
engineering, economic, and scientific judgments and experience.
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OSWER Directive 93800-3
3.3 CONDUCT DETAILED ANALYSIS OF POTENTIAL REMEDIAL ACTION ALTERNATIVES
The objective of this detailed analysis is to develop sufficient
information to permit the comparative evaluation of alternative remedial
actions and, if requested, recommend a remedial action for a specific drum
and tank site. In order to address the evaluation criteria outlined in the
NCP, four major areas of analyses are recommended in the evaluation of
alternative remedial actions:
1. Technical features (Section 3.3.1)
2. Costs (Section 3.3.2)
3. Environmental and public health features (Section 3.3.3)
4. Regulatory and institutional issues (Section 3.4.4)
Depending upon the complexity of the tank and drum site, this evaluation of
alternative actions should proceed in a straightforward and timely manner.
The evaluation is not meant to be exhaustive but rather provide sufficient
documentation for the support of a remedial action.
3.3.1 PERFORM TECHNICAL ANALYSIS OF ALTERNATIVES
Purpose
The purpose of the technical analysis will be to evaluate the potential
remedial action alternatives from an engineering standpoint. To ensure
that specific technical criteria are met, emphasis will be placed on proven
technologies. Even with proven technologies, a significant degree of
variation can exist between the success of techniques for different wastes
and in different hydrogeological/site specific settings.
Techniques
The user should evaluate each of the remedial action alternatives to
specify major equipment sizes and specifications, personnel and utility
requirements, and specific waste disposal strategies. Using the
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OSWER Directive 93800-3
information developed, the user should compare the alternative actions
using the following technical criteria:
Performance - Effectiveness in accomplishing design objectives,
useful life
Reliability - Dependable in meeting design objectives, degree of O&M
requirements to keep operational
Implementability - Suitable conditions for construction (both
on-site and external to the site), time (to implement, to achieve
beneficial results)
Safety - On-site personnel, nearby communities, and surrounding
envi ronment
A tabular summary can be useful for presenting the key positive and
negative features of an alternative within each of the technical evaluation
criteria.
Additional guidance regarding the details of appropriate technologies for
actions at tank and drum sites and use of the technical comparison criteria
is available in the referenced literature (Section 5). Specific informa-
tion on particular technologies and procedures can also be obtained from
vendors, equipment manufacturers, and cleanup contractors.
Limitations
The "track record" of some innovative and proprietary techniques for
remedial action is often very limited. Therefore, the database for eval-
uating their reliability, performance and implementability can be scarce.
One should not unnecessarily expand the scope of technical analyses with a
search for data on unproven technologies. Good engineering judgment should
be made based upon the data obtained from vendors, literature, and cleanup
contractors.
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OSWER Directive 9380 0-3
3.3.2 PERFORM COST ANALYSIS OF ALTERNATIVES
Purpose
The purpose of this analysis is to develop cost estimates for the
alternative remedial actions using the information developed during the
technical analysis of these alternatives. These cost estimates are
site-specific and provide the basis for comparing the economic features of
various remedial actions, not for budgeting the cleanup effort.
Techniques
Costs consist of all capital outlays, operating and maintenance expendi-
tures, general and administrative expenses, and other costs required for
implementation of the action including engineering, des-ign, and
installation, as appropriate. Cost data developed during the screening
analysis of remedial technologies are very useful and applicable for this
more detailed analysis.
EPA's draft Compendium of Cost Remedial Technologies at Hazardous Waste
Sites (EPA, 1984) reviewed cost categories unique to drum sites. Base
costs were defined considering three broad categories:
1. Drum removal (including retrieval, staging, overpacking, and
loading)
2. Transportation (on-site handling, demurrage and off-site transport)
3. Ultimate disposal/treatment (tipping fees, surcharges and taxes)
Items were defined which affect the cost within each of these three broad
categories. For example, drum removal costs were affected by drum con-
dition, waste type, drum size, access, etc.; transportation was basically
influenced by material weight and volume relative to distance; and disposal
and treatment were influenced by both the physical and chemical character-
istics of the waste.
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OSWER Directive 9380 0-3
When evaluating the cost-effectiveness of various approaches or alter-
natives, many scenarios must be considered and flexibility should be
maintained.
For example, there are various factors which can influence the overall cost
for handling and treating/disposing drum wastes. Some general items one
should consider when reviewing various scenarios are summarized below:
t It is generally less expensive to handle and transport drum waste if
they are bulked as compared to overpacked
• Disposal facilities generally charge more to handled drummed waste
than an equivalent amount of bulked waste
• Compatibility limitations of various wastes will restrict the amount
of drum waste that can be bulked
There are many similar cost components for both on- and off-site remedial
alternatives. For example, drum staging and sampling, and many site prepa-
ration/mobilization costs are similar. However, there are some major cost
components which are different for both on- and off-site approaches. For
example, transport requirements could be a major cost component for an
off-site alternative, whereas an on-site alternative may have relatively
minor transport costs.
To analyze the costs for each alternative remedial action, the user should1
perform the following steps:
• Estimation of Costs - estimate capital (direct and indirect) and
annual operating and maintenance costs of the remedial alternatives.
• Economic Analysis - using estimated costs, calculate stream of
payments and present worth for each remedial action alternative (for
most short-term remedial actions, e.g., six months, this is not a
major concern unless there are long-term maintenance and/or
monitoring requirements).
• Sensitivity Analysis - evaluate risks and uncertainties in cost
estimates.
• Input to Cost Analysis - identify input data and reliability
necessary to evaluate costs of remedial action strategies.
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OSWER Directive 93800-3
Information regarding the procedures involved with these steps is presented
in the Guidance Document for Feasibility Studies under CERCLA (EPA, 1985).
References listed in Section 5.0 provide additional information on the
costs of different technologies. This information, plus vendor/contractor
input, should be used to develop the cost estimates. Additionally, the
results of remedial activities at other tank and drum sites can provide
cost data which are very useful for comparative purposes. A range of
discount rates may be useful during the sensitivity analysis.
Limitations
The objective in calculating the costs is to achieve an accuracy within -30
to +50 percent. Failure to adequately estimate the cost for items such as
contractor mobilization/demobilization, stand-by-costs, as well as waste
transportation and disposal and laboratory analyses can substantially
impact this objective.
A potential area of cost uncertainty is the estimated quantities for
various waste disposal categories (based upon the data obtained during the
limited RI). The basis for conducting random sampling is presented in
Section 2.4 and while providing useful information, the applicability of
the data for some uses can be limited. Depending upon the approach of any
previous drum sampling, one should define the confidence limitations of
extrapolating projections for the entire site from a potentially limited
database. As long as one is aware of the potential limitations of the
database, this knowledge can be applied consistently for all alternatives
reviewed. This is particularly important to consider in the cost analysis
of alternatives that are particularly sensitive to the estimated quantities
of particular wastes.
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OSWER Directive 9380.0-3
3.3.3 PERFORM ENVIRONMENTAL AND PUBLIC HEALTH ANALYSIS
Purpose
Section 300.68(j) of the NCP requires that the alternative remedial action
selected for implementation at a surface tank and drum hazardous waste site
effectively mitigate and minimize damage to and provide adequate protection
of public health, welfare, and the environment. This activity, as required
by the NCP, evaluates the effectiveness of alternative remedial actions in
terms of environmental and public health issues. This analysis not only
focuses on the mitigative effectiveness of alternatives but also considers
possible positive and negative secondary/indirect effects.
Techniques
For the particular site and alternative remedial actions being considered,
the user must first make three basic determinations. These are:
1. The requirement for an environmental assessment of adverse impacts
2. The level of detail required in the assessment
3. The scope of the assessment
The environmental analyses for drum and tank sites are fairly straight-
forward. On-site remedial alternatives typically require more detailed
environmental analyses than off-site alternatives. For both concepts there
are many similar areas of concern, such as spillage and volatile emissions
during drum handling and staging. Additionally, reuse or destruction,
whether on- or off-site, is environmentally desirable.
On-site remedial actions should go through a fairly extensive environmental
review. An area of concern for on-site disposal is the risk and potential
effect of failure (e.g., if a liner and leachate collection system fails,
will wastes migrate during high ground water conditions?).
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OSWER Directive 9380 0-3
Off-site remedial actions involve receiving facilities and transport
operations. Environmentally sensitive areas along nearby transport routes
have to be considered, along with potential impacts at the final site of
treatment and/or disposal.
The Guidance Document for Feasibility Studies under CERCLA (EPA, 1985)
provides information regarding these determinations. Literature cited in
the references provides useful information regarding implementing and
summarizing the assessment.
Limitations
This analysis should not be an exhaustive research exercise. It's focus
should be clearly on effectiveness of alternatives in mitigating potential
environmental and public health issues of concern.
3.3.4 PERFORM REGULATORY AND INSTITUTIONAL ANALYSIS OF ALTERNATIVES
Purpose
This analysis allows a comparative review of the extent to which those
alternatives under consideration are consistent with other environmental
requirements and take into account various institutional constraints.
Techniques
The user should identify and meet with the appropriate officials at the
federal (regional), state, and local levels to discuss the alternative
remedial actions being considered for the surface tank and drum site.
Information on the responsibilities, authorities, and potential roles of
federal agencies during the planning and implementation of a remedial
action is presented in Guidance Document for Feasibility Studies under
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OSWER Direcfue 9380 0-3
CERCLA (EPA, 1985). EPA is developing policy on the use of permanent
remedies (such as treatment or destruction) and addressing when disposal in
double-lined facilities are appropriate.
In determining what cleanup levels or technologies provide adequate
protection of public health and the environment, EPA considers other
environmental laws and regulations that are applicable or relevant to the
site. EPA has proposed a policy which would require cleanup actions to be
consistent with these other laws and regulations except when certain
specified situations exist.
Off-site storage, treatment, or disposal facilities must have an applicable
RCRA permit or be in compliance with RCRA. A RCRA compliance inspection
must have taken place within the previous six months and must demonstrate
that there are no significant violations that affect the satisfactory
performance of the facility.
In selecting an operable unit, which is not by itself the final action
necessary at a site (such as cleanup of drums and tanks at sites where
contaminated soil or ground water exists), the decision document will
indicate what additional problems will be addressed in future operable
units.
Limitations
Environmental permits are not required for on-site Superfund remedial
actions.
3.4 CONDUCT COMPARATIVE SUMMARY OF POTENTIAL REMEDIAL ACTION ALTERNATIVES
Purpose
The National Contingency Plan (NCR), Section 300.68(j) states: "The
appropriate extent of remedy shall be determined by the lead agency's
selection of the remedial alternative which the agency determines is cost-
effective." While an important objective is to keep costs to a minimum,
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OSWER Directive 9380 0-3
the primary goal of the program is to provide adequate protection of the
public health and the environment. In addition, EPA considers which
alternatives will be most cost effective in the long term, not just if a
remedy just has lower initial capital cost. For example, the destruction
or treatment of a waste may be preferred to land disposal even though the
cost of the former may be higher. This decision would be based on the need
to assure the long-term protection of the public health and the environment
and taking into account the long-term cost of operating and maintaining the
integrity of physical structures necessary to securely contain waste.
Techniques
The results of the detailed analyses of the alternative remedial actions
should be organized and summarized for comparison. The analysis should be
conducted with a precision that is consistent with the degree of knowledge
about the problem or expected results. The framework must be tailored to
meet the needs of each particular site evaluation by adapting the
evaluation criteria to reflect site-specific conditions, hazards, or public
concerns.
A summary table is a useful tool in organizing and presenting the results
of a composite evaluation of remedial actions involving multiple criteria.
A sample summary table for remedial actions at a hypothetical abandoned
tank site is presented in Table 3-2. Accompanying the summary table would
be a narrative explanation for each evaluation criterion, presenting the
advantages and disadvantages for each alternative remedial action.
Limitations
Certain comparison criteria are qualitative and subjective. Thus,
different perspectives may result in different comparison results. A
tendency in these types of comparative evaluations is to over-emphasize the
relative importance of a particular evaluation criterion, such as costs.
However, increasing attention should be given to alternatives that are
based upon the destruction, treatment, and/or reuse of the waste material.
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OSWER Directive 9380 0-3
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OSWER Directive 9380 0-3
This summary comparative analyses can provide the basis for this type of
evaluation.
Depending upon the degree of confidence and the extent of the database for
drums, it may be advisable to prepare two summary tables; one for tanks and
the other for drums. The database for tanks will probably be more
comprehensive. The database for drums could be limited to that obtained in
the random sampling program (refer to Section 2.4.1).
3.5 PREPARE LIMITED FOCUSED FEASIBILITY STUDY REPORT
A draft FS report should be prepared that summarizes the feasibility study
of alternative remedial actions for the surface tank and drum hazardous
waste site. The typical section headings for this report are presented in
Table 3-3. It is not necessary to limit the report to the listed items.
In this report it is not necessary to provide details on site background if
a full RI/FS is being conducted. A reference to this document with only a
brief summary of a pertinent feature is appropriate.
The Guidance Document for Feasibility Studies under CERCLA (EPA, 1985)
provides additional information regarding what should be included in the
report and why.
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OSWER Directive 9380 0-3
TABLE 3-3
LIMITED FEASIBILITY STUDY REPORT
INTRODUCTION
t Site Background Information
• Nature and Extent of Problems
• Objectives of Remedial Action
SCREENING OF REMEDIAL ACTION TECHNOLOGIES
Technical Criteria
Environmental/Public Health Criteria
Institutional Criteria
Other Screening Criteria
Cost Criteria
Remedial Action Alternative Development
REMEDIAL ACTION ALTERNATIVES
• Alternative 1 (No Action)
t Alternative 2
• Alternative x
ANALYSIS OF REMEDIAL ACTION ALTERNATIVES
Non-cost Factors
Technical Evaluation
Environmental Evaluation
Institutional Requirements
Public Health Evaluation
Cost Factors
SUMMARY ANALYSIS OF ALTERNATIVES
RECOMMENDED REMEDIAL ACTION (Optional)
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OSWER Directive 9380 0-3
4.0 TANK AND DRUM SITE REMEDIAL DESIGN/REMEDIAL ACTION
This section provides the reader with the basic approach and procedures of
tank and drum site remedial action design. It is not intended to be a
comprehensive guidance document on the development of contract (or
subagreement) documents and the implementation of a remedial action. The
user should consult EPA's Superfund Remedial Design and Remedial Action
Guidance (February 1985) for a more complete manual on the design and
construction requirements for Superfund activities. Federal-lead contracts
should follow the Federal Acquisition Regulations (48 CFR Chapter 15 and 48
CFR Chapter 1, Subpart 1.3), while state-lead subagreements should follow
the Agency's "Procurement Under Assistance Agreements" regulation (40 CFR
Part 33). In addition, detailed guidance on state procurement under
Superfund cooperative agreements can be found in Volume II of the manual
State Participation in the Superfund Remedial Program to be issued in
September 1985.
4.1 APPROACH
The normal method of executing site cleanup is to use either formal
advertising or competitive negotiations to procure the services of a
responsive and responsible contractor. In fact, on state-lead projects
formal advertising must be used to procure construction services during
remedial implementation unless the EPA official responsible for the
obligation of funds (AA or RA) approves an alternative procurement method
in advance. Formal advertising cannot be waived in the Superfund remedial
program by a claimed emergency situation since EPA handles Superfund
emergencies under the removal rather than the remedial program.
Furthermore, a declaration of an emergency under state law does not
necessarily constitute an emergency under the EPA Superfund program.
The owner must prepare contract documents which define the work to be done
and provide a basis on which contractors competitively bid to perform the
work. It is essential that these contract documents completely and
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OSWER Directive 9380 0-3
accurately define all the work required. The Construction Specification
Institute (CSI) format may be used in preparation of contract documents for
drum and tank sites. This format keeps hazardous waste site design and
procurement consistent with the more conventional construction projects.
The CSI format breaks the work into divisions. Division 0 establishes the
general project and contractual procedures, and the technical
specifications are included in Divisions 1 through 16 (see Section 4.4).
Material presented in these sections focuses principally on issues
involving tank and drum sites.
4.2 CONTRACTING PROCEDURE
The bidding and contract requirements define the conditions under which the
contractor must perform the work for the owner (i.e., the entity which
provides the funds). A number of pricing options may apply to a particular
contract. These include firm fixed price (lump sum) or unit quantity and
time and materials.
For fund financed remedial actions (state-lead projects), the recipient
must use the formal advertising procurement method. Formal advertising
requires, at a minimum, the following:
• A complete, adequate, and realistic specification or purchase
description of what is required
• Two or more responsible bidders who are willing and able to compete
effectively for the business
• A procurement that lends itself to the award of a fixed-price
contract
• The selection of the successful bidder, made principally on the
basis of price
4.2.1 FIXED-PRICE (LUMP SUM) CONTRACT
With this type of contract, the contractor responds with a single fixed
cost price (which includes labor, overhead, and profit) to perform the work
described in the project plans and bid documents. This method requires the
owner to develop definitive performance specifications for the bidding
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OSWER Directive 9380 0-3
process and also requires the greatest amount of sampling and analysis to
prepare the bid. This contract is applicable to such work as:
• Mobilization - This includes the up-front costs such as insurance,
bonding requirements, obtaining project-specific licenses and
permits, and the development of site-specific contingency and health
and safety plans.
• Site Preparation - This includes typical conditions related to
activities such as roadways, clearing, grading and staging areas and
decontamination pad construction.
• Temporary Facilities - These include support facilities such as
trailers, clean zone equipment, laboratory and utility hook-ups.
t Demobilization - This provides for the payment of basic closure
costs for decommissioning of utilities, final grading and reporting
requirements
4.2.2 UNIT PRICE CONTRACT
This type of contract requires that the owner estimate quantities of
materials to be disposed of or treated in the bid documents. Potential
contractors bid on a per unit basis which includes labor, overhead, and
profit.
Unit pricing is more applicable to the waste handling and disposal areas of
the work. The basic concept provides for a fixed unit price, per gallon,
cubic yard and/or tons, to be set at the time of bid. This unit price
would be applied or spread over an estimated quantity of units rather than
a set quantity, since on a tank and drum site only a very small percentage
of the containers may be sampled or even opened. Waste categories and
quantities are estimated based on site history and previous experience.
These quantities are only estimates; the actual quantities on-site will not
be known until the last container is removed. Therefore, the unit price
system provides a mechanism for the contractor to be paid for all
quantities found, independent of any deviation from original estimates.
Unit pricing requires that the price quoted for each unit include the cost
for on-site material handling, laboratory analysis, labor and equipment,
repacking/overpacking, on-site consolidation and building, manifesting and
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OSWER Directive 9380 0-3
off-site transfer, and off-site treatment and/or disposal. These price
quotes are generally considered firm unless there is a significant change
in conditions or, more specifically, if there is a major increase or
decrease in the original estimate. The basically accepted rule of thumb is
to provide a 15 percent margin. Deviations above or below this margin
would lead to renegotiation. In developing the unit price bid, the
contractor will generally spread fixed costs evenly over the original
estimated quantity. Therefore, if the actual quantity significantly
underruns the original estimate, the contractor will not receive
compensation for all of the fixed costs incurred. If the quantity is much
greater than the original estimate, the owner may be entitled to a cost
reduction. Adjustments in price occur through negotiation at the time the
change is recognized. The unit price concept provides a basis by which
bids can be compared and maintains a built-in flexibility to accommodate
change.
4.2.3 TIME AND MATERIALS CONTRACT
Under this type of contract, the contractor is paid a fixed rate (including
labor, overhead, and profit) for each hour performed and actual cost of
materials. Because this contract contains the least incentive to perform
efficiently, it should be used if no other contract is suitable.
It reimburses the contractor for all costs incurred for a specific scope of
work. This approach does not provide a mechanism by which bids may be
compared, and it requires a much greater level of management by the owner.
The owner also assumes all of the risk under this option.
4.3 CONTRACT PROVISIONS
Provisions must be in a contract to address both the specific work items
comprising the known project scope and the procedures for defining and
handling out of scope activities. In addition, specific clauses or their
equivalent are required in each contract by 48 CFR Chapter 15, and Chapter
1, Subpart 1.3 and/or 40 CFR 33 for fund-financed actions. As with any
construction related contract, changes in the work may occur under a
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OSWER Directive 9380 0-3
hazardous waste site cleanup type contract due to differing site
conditions.
4.3.1 CHANGE ORDERS
A change order is a written order issued by the owner or its designated
agent to its contractor authorizing an addition to, deletion from, or
revision of a contract. A change order is necessary to modify, within the
scope of the project, the contract cost or scope of work; to interrupt or
terminate the project; to revise the completion date; or, in general, to
implement any deviation from the original contract terms and conditions.
Change orders are issued after the execution of the contract. Proper
management of change orders is a key element to avoiding delays, increased
costs, and potential contractor claims.
Change orders may be required for the following conditions:
• Differing site conditions
- Subsurface or latent physical conditions at the site differing
materially from those indicated in the contract
- Unknown physical conditions at the site, conditions of an unusual
nature, or those differing materially from those ordinarily
encountered and generally recognized as inherent in work of the
type provided for in the contract
• Errors and omissions in plans and specifications
- Errors are items which are described incorrectly on the plan or in
the specifications
- Omissions are items which are neither shown nor specified
• Changes instituted by changes in regulatory requirements, such as:
- Changes requirements for protecting historical or archaeological
objects
- Revisions to building codes
- Revisions to zoning and land use plans
- Revisions to federal regulations and policies
- New congressional legislation
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OSWER Directive 9380 0-3
• Design changes, such as modifications to existing design which will
offer a savings in excess of all costs associated with the change
order, including future operation and maintenance costs
t Overruns/underruns in quantities
• Factors affecting time of completion, such as:
- Suspension of work (temporary)
- Direct acceleration
- Time extension for delay beyond the contractor's control
- Constructive acceleration
• Changes in contract administration procedures, such as:
- Progress payment terms
- Retainage release
- Occupancy
- Testing
- Acceptance
- Warranties
t Resolution of claims
t Emergency conditions:
- Acts of God
- Civil disturbance
Tank and drum sites are unique in the that there are many unknowns about
the conditions of the site and the waste that will be encountered, all of
which may necessitate change orders. For example, if lab packs or other
unique categories of waste materials (e.g., reactive or shock sensitive)
are known or suspected to be on-site, then the contract document should
specify such. However, when a contract includes specific provisions for
unique site/waste conditions, but none are found, the contract should
address limited compensation. While no unique or special site/waste
conditions may be found, the contractor may have had to mobilize special
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OSWER Directive 9380 0-3
support equipment or plan for unique contingencies; for example, the
construction of on-site temporary storage facilities along with the staging
of special handling equipment for shock sensitive waste. These are
legitimate costs which should be paid for by the owner even though no shock
sensitive wastes are found. Another example calls for detailing the work
by using the existing information. In this instance, a reasonably
competitive price should be received for known and definable work items.
Modifications, as they occur, can be handled by change order.
Ultimate responsibility for change order administration rests with the
owner. Specifically, the owner is responsible for:
• Determining whether a contract change order is warranted, based on
the terms of the existing contract and a review of the circumstances
responsible for the alleged changed
• Negotiating a fair and reasonable price for price contract changes
• Maintaining accurate and complete cost records for the change,
including records of negotiation
t Adequately documenting for future reference a description of the
agreed change and reason for this change
• Maintaining current and accurate fiscal projections of contract and
project completion costs
• Executing contract change order documents efficiently and in a
timely manner
• Resolving disputes which may arise as a result of a proposal for a
change
t Assessing the impact of change orders on progress toward project
completion and acting to mitigate resulting project delays
In order to expedite review and approval of change orders, contractors
must:
• Adequately describe the reason for each change request
• Submit change order proposals in accordance with the procedures set
forth in the contract documents, and enter into meaningful
negotiations on a necessary contract change
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OSWER Directive 9380 0-3
t Furnish and certify the accuracy and completeness of cost and
pricing data on enable the owner to determine the necessity and
reasonableness of the cost proposed
Project delays and disputes resulting from change order administration can
be limited by effective and frequent communication between the owner and
contractors.
4.3.2 SPECIAL PROVISIONS
There are areas of a project that are unique to the site that are not
necessarily unknown but fall under the term "considerations." These are
"considerations" of work items specific to the project that the owner
expects the contractor to take into account in preparing the bid. For
example, it is possible to encounter deteriorated drums, which are not
structually sound, at a site. If the contractor moves these drums, spills
may occur. It is not practical for the owner to be involved in the
decision on how every drum should be handled, typically this is left up to
the experience of the contractor. However, the owner does not want to be
responsible for the contractor's mistakes that result in spills, so the
owner under such a scenario would put a provision in the contract
requesting that the contract provide a contingency plan for handling spills
and that the contractor reflect this in the bid price. This builds a
maximum level of care into the contractor's drum handling operation.
The owner may also want to make the contractor aware of other conditions
that the owner will not take responsibility for, but that the contractor
should take under consideration. These could include provisions for:
t Conducting cleanup operations during the summer and winter months
under level "B" protection
• Allowing for periods of inclement weather when scheduling cleanup
activities
• Providing enough support equipment (e.g., air compressors) to allow
optimum use of on-site personnel with the level "B" protection
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OSWER Directive 93800-3
• Safety and contingency procedures to handle the discovery of very
unique situations not detected in previous sampling activities or
field work (e.g., radioactive material which may require involvement
of the Nuclear Regulatory Commission)
Experienced contractors should be familiar with these and other standard
operating conditions at tank and drum sites; however, it is in the owners
best interest to include such items in the contract.
4.4 DESIGN REQUIREMENTS
As stated previously, the bid document presents the basis for conducting
project design and implementation. In general, a tank and drum remedial
design will contain the General Condition section; the up-front boilerplate
or contractual language similar to most construction projects. The next
section of source of information is the Technical Specifications section
which outlines specifically how the work will be conducted. Table 4-1 is a
typical table of contents of the Technical Specifications section. Much of
the material under Divisions 1 and 2 present the basic project
requirements, which closely coincides with the lump sum items. Division 13
focuses on the special conditions of tank and drum waste and details how
these materials are to be handled. Because each drum probably contains
waste with unique characteristics, the common basis for design and
specifications for tanks and drums is health and safety.
Drums are handled individually by specially designed equipment. All drums
are sampled and tested for reactivity and potential compatibility. Drums
on-site are probably not Department of Transportation (DOT) approved;
therefore, if an individual container is to be removed, it must be repacked
or overpacked. To the maximum extent possible, compatible wastes are
consolidated and the original drum is crushed for disposal as bulk waste
material at secure land disposal facilities. Depending upon drum
conditions, empties could be recycled once strict regulatory requirements
have been met (see 49 CFR 173.28).
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OSWER Directive 9380 0-3
TABLE 4-1
TABLE OF CONTENTS FOR DRUM DISPOSAL
TECHNICAL SPECIFICATIONS
DIVISION 1 - GENERAL REQUIREMENTS
01010 Summary of Work
01018 Site Utilities
01030 Special Project Procedures
01060 Regulatory Requirements
01150 Measurement and Payment
01203 Job Site Administration
01300 Submittals
01590 Temporary Facilities
01700 Contract Closeout
DIVISION 2 - SITE WORK
02100 Site Preparation
DIVISION 13 - SPECIAL CONDITIONS
13571
13572
13573
13574
13575
13576
13577
13578
13579
13580
Drum Handling Protocol
Drum Sampling Protocol
Bulking and Consolidation Protocol (Analytical
Procedures Included)
Securing of Radioactive Waste
Securing of High Hazard Waste
Disposal of Chemical Waste
Collection and Handling of Sludges
Transport of Hazardous Material
Sorting, Identification, Packing and Disposal of
Packaged Laboratory Chemical Wastes (Lab Packs)
Securing, Identification, Transport, and Disposal of
Pressurized Cylinders Containing Toxic, Explosive,
and/or Other Material
APPENDIX
Waste Transport Route
Summary of Waste Categorizations Found On-Site
Personnel Safety/Protection Standards
Special Category of Wastes for Disposal
A
B
C
D
E
High PCB (>500 ppm), Low Flashpoint Liquids
PCB-Contaminated Solids
Waste Resins
Glycols
Classification of Sludge Materials
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OSWER Directive 9380 0-3
5.0 REFERENCE GUIDE
The references included in this section are organized according to the
section titles of this guidance manual. References are not duplicated even
though many apply to several areas. In searching for additional material
on a particular subject, do not limit your search to the section headings
covering your specific area of interest. Some sections do not have
additional referenced material and therefore are not listed. Review the
references listed under other headings to complete your search within this
manual. Some references are cross referenced when the reference is
particularly applicable to more than one section.
Note that Section 3.3.1 contains a lengthy compilation of articles
regarding potential alternative technologies that may be considered while
searching for available alternative remedial actions. The list is
intentionally long to provide the users of this manual with the wide range
of alternatives available and to stimulate additional creative thinking
along the lines of alternative treatment and disposal techniques,
especially for alternatives to land burial of hazardous wastes.
FOREWORD
U.S. Environmental Protection Agency. 1983. Draft Survey and Case
Studies of Remedial Actions at Hazardous Waste Sites. Washington,
DC: JRB Associates and Environmental Law Institute. Prepared for
U.S. Environmental Protection Agency Municipal Environmental
Research Laboratory, Cincinnnati, Ohio.
. 1985a. Guidance on Remedial Investigations Under
CERCLA. Washington, DC: EPA Hazardous Waste Engineering Research
Laboratory (Cincinnati), Office of Emergency and Remedial Response,
and Office of Waste Programs Enforcement. Prepared by: JRB
Associates. May.
. 1985b. Guidance on Feasibility Studies Under CERCLA.
Washington, DC: EPA Hazardous Waste Engineering Research Laboratory
(Cincinnati), Office of Emergency and Remedial Response, and Office
of Waste Programs Enforcement. Prepared by: JRB Associates. May.
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OSWER Directive 9380 0-3
2.0 LIMITED REMEDIAL INVESTIGATION
2.1 DEVELOP SITE DESCRIPTION AND DATA BASE
Hillenbrand, E. and B. Burgher. 1982. Spill Incidents at Hazardous
Material Storage Facilities: An Analysis of Historical Data From
the PIRS and SPCC Data Bases. In: Management of Uncontrolled
Hazardous Waste Sites National Symposium. EPA et al. Washington,
DC. November 29 - December 1.
See EPA (1985a) under Foreword
2.2 SITE FAMILIARIZATION AND PROJECT APPROACH
U.S. Environmental Protection Agency. OERR Environmental Response
Branch. 1984. Standard Operating Safety Guides. Washington, DC:
EPA. November.
2.2.2 PREPARE INITIAL HEALTH AND SAFETY GUIDE
Bareis, D.; Cook, L.; and Parks, G. 1983. Safety Plan for
Construction of Remedial Actions. In: Proc. National Conference on
Management of Uncontrolled Hazardous Waste Sites. Washington, DC.
October 31 - November 2.
Buecker, D.A. and Bradford, M.L. 1982. Safety and Air Monitoring
Considerations at the Clean Up of a Hazardous Waste Site. In:
Management of Uncontrolled Hazardous Waste Sites National Symposium.
EPA et al. Washington, DC. November 29 - December 1.
Sax, N.I. Ed. 1979. Dangerous Properties of Industrial Materials.
5th Ed. Van Nostrand: New York, 1979.
International Technical Information Institute. 1976. Toxic and
Hazardous Industrial Chemicals Safety Manual for Handling and
Disposal with Toxicity and Hazardous Data. Tokyo, Japan:
International Technical Information Institute.
Merck & Co. 1968. Merck Index, An Encyclopedia of Chemicals and
Drugs. 9th Ed. Rahway.
Meyer, E. 1977. Chemistry of Hazardous Materials. Englewood
Cliffs, NO: Prentice-Hall, Inc.
NIOSH. 1984. Occupational Safety and Health Guidance Manual for
Superfund Activities.
Roos, K.; Scofield, P. 1983. Health and Safety Considerations:
Superfund Hazardous Waste Sites. In: Proc. National Conference on
Management of Uncontrolled Hazardous Waste Sites. Washington, DC.
October 31 - November 2.
U.S. Army Corps of Engineers. 1982. Safety and Health Requirements
Manual. Washington, DC.: USACOE. EM-385-1-1.
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OSWER Directive 93800-3
U.S. Environmental Protection Agency. 1979. Safety Manual for
Hazardous Waste Site Investigations (draft). Denver: Office of
Occupational Health and Safety, and the National Enforcement
Investigation Center.
See U.S. Environmental Protection Agency (1984) under Section 2.2
and (1985a) under Foreword
Wallace, L.; Martin, W. 1983. Hazardous Wastes Worker Health and
Safety Guidelines. In: Proc. National Conference on Management of
Uncontrolled Hazardous Waste Sites. Washington, DC. October 31 -
November 2.
2.2.3 PREPARE COMMUNITY RELATIONS PLAN
U.S. Environmental Protection Agency, OERR. 1983. Community
Relations in Superfund: A Handbook (interim version). Washington,
DC: U.S. Environmental Protection Agency. September.
2.2.4 IDENTIFY POTENTIAL REMEDIAL TECHNOLOGIES
Neely, N.; et al. 1981. Survey of On-Going and Completed Remedial
Action Projects. Cincinnati: EPA 600/2-81-246. September.
Wagner, K.; et al. undated. Planning and Implementation of
Response Actions for Hazardous Waste Sites With Drums (draft final).
Cincinnati: U.S. Environmental Protection Agency, MERL, ORD.
Contract No. 68-03-3113.
2.3 PERFORM INITIAL SITE CHARACTERIZATION
2.3.3 CONDUCT PRELIMINARY EXPOSURE ASSESSMENT
Heer, J.; Hagerty, D. 1977. Environmental Assessment and State-
ment. Van Nostrand Press.
See U.S. Environmental Protection Agency (1985a) under Foreword.
2.3.5 DEFINE DATA NEEDED TO CONDUCT LIMITED FEASIBILITY STUDY
See U.S. Environmental Protection Agency (1985a) under Foreword.
2.4 CONDUCT DETAILED FIELD INVESTIGATION
2.4.1 PREPARE PROJECT OPERATIONS PLANS
de Vera, E.R.; Simmons, B.P.; Stephens, R.D. and Storm, D.L. 1980.
Samples and Sampling Procedures for Hazardous Waste Streams.
Cincinnati: EPA-600/2-80-018. January.
McNeil, D. 1979. Barrels of Chemicals Rot as Disposal Fails. New
York Times. July 5.
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Tewhey, J., Sevee, J.; and Fortin, R. 1982. Silresim: A Hazardous
Waste Case Study. In: Management of Uncontrolled Hazardous Waste
Sites National Symposium. Washington, DC: EPA et al. November 29 -
December 1.
U.S. Environmental Protection Agency, ORD. 1983. Interim
Guidelines and Specifications for Preparing Quality Assurance
Project Plans. EPA-600/1-83-004. NTIS PB83-170514. February.
See U.S. Environmental Protection Agency (1985a) under Foreword and
(1984) in Section 2.2., and Wagner et al. (undated) under Section
2.2.4.
2.4.2 PERFORM TANK AND DRUM SURVEY/INVENTORY
Ember, L.R. 1979. Needed: Hazardous Waste Disposal (But Not in My
Backyard). ES&T.
Ritthaler, William E. 1982. Callahan Uncontrolled Hazardous Waste
Site: During Extreme Cold Weather Conditions. In: Management of
Uncontrolled Hazardous Waste Sites National Symposium. EPA et al.
Washington, DC. November 29 - December 1.
Wetzel, R.; Wagner, K.; and Tafuri, A. 1982. Drum Handling
Practices at Abandoned Sites. In: Management of Uncontrolled
Hazardous Waste Sites National Symposium. EPA et al. Washington,
DC. November 29 - December 1.
See also Wagner et al. (undated) under Section 2.2.4.
2.4.3 CONDUCT SITE CHARACTERIZATION
Barbara, M.; Morahan, T.; and Teets, R. 1983. Site Security and
Waste Removal Activities at an Abandoned Hazardous Waste Site. In:
Proc. National Conference on Management of Uncontrolled Hazardous
Waste Sites. Washington, DC. October 31 - November 2.
2.4.4 CONDUCT SAMPLING PROGRAM
Dahn, C.J. 1980. Chemical Compatibility and Storage Considerations
for Process Systems Hazards Analysis. J. of Hazardous Materials,
4:121-127.
Hina, C.; Garlauskas, A.; and Carter, T. 1983. Techniques for
Identification and Neutralization of Unknown Hazardous Materials.
In: Proc. National Conference on Management of Uncontrolled
Hazardous Waste Sites. Washington, DC. October 31 - November 2.
King, M.V.; Eller, P.M.; and Costello, R.J. 1983. A Qualitative
Sampling Device for Use at Hazardous Waste Sites. Proc. of The
American Industrial Hygiene Association and American Conference of
Governmental Industrial Hygienists Hazardous Waste Sysmposium.
Philadelphia. May.
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Lynn, J.P. and Rossow, H.E. 1970. Classification of Chemical
Reactivity Hazards. Alexandria, VA: National Technical Information
Center.
Myers, L.C. 1980. The Chemical Reactivity Test-A Compatibility
Screening Test for Explosives. J. of Hazardous Materials. 4:77-87.
Simmons, B.P.; Tan, I.; Li, T.H.; Stephens, R.D.; and Strom, D.L.
1982. A Method For Determining the Reactivity of Hazardous Wastes
(preliminary). Cincinnati, OH: U.S. Environmental Protection Agency.
Turpin, R.D. 1982. Oxidation/Reduction Potential Field Test Kit
for Use at Hazardous Material Spills. In: Proc. Hazardous Material
Spills Conference. April.
Vecera, M. and Gasparic, J. 1971. Detection and Identification of
Organic Compounds. New York: Plenum Press
Wolbach, C.D. 1983. Protocol for Identification of Reactivities of
Unknown Wastes. In: Proc. National Conference on Management of
Uncontrolled Hazardous Waste Sites. Washington, DC. October 31 -
November 2.
See Wagner et al. (undated) under Section 2.2.4.
3.0 LIMITED FEASIBILITY STUDY
3.1 IDENTIFY MAJOR REMEDIAL TECHNOLOGIES
Chemical Manufacturers Association. 1981. Drum Consolidation
Protocol. Washington, DC: CMA.
Freestone, F.J. and Brugger, J.E. 1980. Incineration of Hazardous
Wastes at Uncontrolled Dumpsites. In: Proc. National Conference on
Management of Uncontrolled Hazardous Waste Sites. Washington D.C.
October.
Ghassemi, M.; Yu, K.; Quinlivan, S.; and Freestone, F.J. 1980.
Comparative Evaluation of Processes For the Treatment of
Concentrated Wastewaters at Uncontrolled Hazardous Waste Sites. In:
Proc. National Conference on Management of Uncontrolled Hazardous
Waste Sites. Washington D.C. October.
Hatayama, H.K.; Chen, J.J.; de Vera.E.R.; Stephens, R.D. and Storm,
D.L. 1980a. A Method for Determining the Compatability of
Hazardous Wastes. Cincinnati, OH: EPA 600/2-80-076. April.
. 1980b. Hazardous Waste Compatibility. In: Disposal of
Hazardous Waste—Proceedings of the Sixth Annual Research Symposium.
Cincinnati, OH: EPA 600/9-80-010.
5-5
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OSWER Directive 93800-3
Houston, R.C. 1980. Incineration of Hazardous Waste at Sea. In:
Proc. National Conference on Management of Uncontrolled Hazardous
Waste Sites. Washington, D.C. October.
Thorsen, J.W. et al. 1983. Classification Protocol For Waste at
Remedial Action Sites. University of Wisconsin Municipal and
Industrial Waste Sixth Conference. Madison, Wisconsin.
September 14-15.
3.2 SCREEN INITIAL REMEDIAL TECHNOLOGIES
3.2.2 EVALUATE ENVIRONMENTAL AND PUBLIC HEALTH IMPACTS
Vanderlaan, G.A. 1981. A Fast Track Approach to Impact Assessment
at Uncontrolled Hazardous Waste Sites. In: Proc. Second National
Conference on Management of Uncontrolled Hazardous Waste Sites.
October.
See ORB Associates (1983) under Section 3.3.4.
3.2.3 EVALUATE COSTS
Rishel, H.L.; Boston, T.M.; and Schmidt, C.J. 1984. Cost of
Remedial Response Actions at Uncontrolled Hazardous Waste Sites.
Park Ridge, NJ: Noyes Data Corp.
U.S. Environmental Protection Agency. 1984. Compendium of Cost of
Remedial Technologies at Hazardous Waste Sites (draft). Washington,
D.C.: EPA Office of Emergency and Remedial Response. February.
Vanderlann, G.A. 1983. The Impact of Limited Competition on
Removal Project Cost Budgets. In: Proc. National Conference on
Management of Uncontrolled Hazardous Waste Sites. Washington, DC.
October 31 - November 2.
Walsh, J.J.; Lippitt, J.M.; and Scott, M. 1983. Costs of Remedial
Actions at Uncontrolled Hazardous Waste Sites - Impacts of Worker
Health and Safety Considerations. In: Proc. National Conference on
Management of Uncontrolled Hazardous Waste Sites. Washington, DC.
October 31 - November 2.
3.3 CONDUCT DETAILED ANALYSIS OF POTENTIAL REMEDIAL ACTION ALTERNATIVES
3.3.1 PERFORM TECHNICAL ANALYSIS
Alberti, B.N. et al. 1982. Peroxidase for Removal of Hazardous
Aromatics from Industrial Wastewater. In: Biological Detoxification
of Hazardous Wastes. Exner, J.H. ed. Ann Arbor, MI: Ann Arbor
Sience.
Anderson, C.E. 1972. Potassium Permanganate Control of Certain
Organic Residues in Air and Wastewater. In: Symposium, Progress in
Hazardous Chemical Handling and Disposal. Institute of Advanced
Sanitation Research International.
5-6
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OSWER Directive 9380 0-3
Andres, D.R. 1977. Managing Hazardous Wastes: Disposal System
Swallows Cyanide. Waste Age, 8(ll):65-66, 68. November.
Augustine, R.L. 1969. Oxidation Techniques and Application in
Organic Synthesis. Vol. 1. New York: Marcel Dekkar, Inc.
Barry, J. 1981. The World's Largest Hazardous Waste Treatment
Plant: Is it Safe for Louisiana? Dangerous Properties of
Industrial Materials Report. (7)12 September-October.
Berkowitz, J.B.; Funkhouser, J.T.; Steven, J.I.; and DeRenzo, D.
1978. Unit Operations for Treatment of Hazardous Industrial Wastes.
Park Ridge, NJ: Noyes Data Corporation.
Bidleman, O.T.F. and Williams, R.R. 1978. Toxaphene Degradation in
Estuarine Sediments. J. Ag. Food Chem. 26:280-282.
Bureau of National Affairs, Inc. 1982. Biotreatment of Ammonia.
Environment Reporter. Washington, DC: BNA.
Bouwer, E.J. 1981. Anaerobic Degradation of Halogenated 1 and 2
Carbon Organic Compounds. Environ. Sci. Tech. 15:596-599.
Brunotts, V.A.; Emerson, L.R.; Rebis, E.N.; and Doy, A.J. 1983.
Cost Effective Treatment of Priority Pollutant Compounds With
Granular Activated Carbon. In: Proc. National Conference on
Management of Uncontrolled Hazardous Waste Sites. Washington, DC.
October 31 - November 2.
Christinsen, D.C. et al. 1980. Enhanced Photo Degradation of
Persistent Halogenated Organic Materials. In: Proc. of the 34th
Industrial Waste Conference. Purdue University. Lafayette, IN
Cytox. undated. CTX Bioxtreatment System, Technical Data Sheet.
Allentown, Pennsylvania, .
Deever, W.R. et al. 1978. Composting Petroleum Refinery Sludges.
Port Arthur, TX: Texaco, Inc.
Dinapoli, J.J. 1982. The Exhumation Program for the SCA
Wilsonville Site. In: Management of Uncontrolled Hazardous Waste
Sites National Symposium. EPA et al. Washington, DC. November 29
- December 1.
Epstein, E. et al. 1980. Enhanced Biodegradation of Oil and
Hazardous Residues. In: Proc. of the Conference on Oil and Hazardous
Material Spills. Silver Spring, MD: Information Transfer, Inc.
Farb, D.G. 1978. Upgrading Hazardous Waste Disposal Sites:
Remedial Approach. Cincinnati, OH: SW-677, U.S. Environmental
Protection Agency.
5-7
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OSWER Directive 9380 0-3
FMC Corporation. 1979. Industrial Waste Treatment with Hydrogen
Peroxide. Philadelphia: Industrial Chemicals Group.
Comma, M.H. et al. 1971. Kinetics of Chemical Oxidation of
Dipyridylium Quarternary Salts. Agri. and Food Chem. 19:302 March.
Halbouty, M.T. 1979. Salt Domes Gulf Region, United States and
Mexico. Second Edition. Houston, Texas.
Haller, H.D. 1978. Degradation of Monosubstituted Benzoates and
Phenols by Wastewater. J. WPCF 50:2771-2777.
Hill, R.D. et al. 1981. Four Options for Hazardous Waste Disposal.
Civil Engineering. 51(9):82-85 September.
Hill, R.D.; Schomaker, N.B.; and Wilder, I. 1980. U.S.
Environmental Protection Agency Research Program: Uncontrolled
Hazardous Waste Sites. In: Proc. National Conference on Management
of Uncontrolled Hazardous Waste Sites. Washington, DC. October.
Hooper, M.W.; Geiselman, J.N.; and Nael, T.E. 1983. Mined Cavities
in Salt - A Land Disposal Alternative. In: Proc. National
Conference on Management of Uncontrolled Hazardous Waste Sites.
Washington, DC. October 31 - November 2.
Hopper, R. 1979. Beyond RCRA: Awful as it Sounds Feds Need More
Hazardous Waste Authority. Waste Age. 10(1):36-40 January.
Huddleston, R.L. et al. 1982. Evaluation of Subsurface Effects of
Long-Term Land Farming. In: Land Disposal of Hazardous Waste.
Proc. of the 8th Annual Research Symposium. MERL, EPA 600/992-002.
Huddlestion, R.L. et al. 1976. The Disposal of Oily Waste by Land
Farming. Presented to the Management of Petroleum Refinery
Wastewater Forum. Tulsa, OK. January.
J.J. Keller & Associates, Inc. 1981a. Hazardous Materials Guide -
Shipping, Materials Guide and Transport. Neenah, WI.
. 1981b. Hazardous Waste Services Directory -
Transporters, Disposal Sites, Laboratories and Consultants. Neenah,
WI.
. 1981c. Hazardous Waste Management Guide - Regulations,
Compliance and Management Guidelines. Neenah, WI.
Kinacannon, C. 1972. Oily Waste Disposal by Soil Cultivation
Process. Washington, DC: EPA R-2-72-110.
Krupa, M.J. et al. 1980. Biological Methods for Detoxification of
Hazardous Organic Materials. National Conf. on Hazardous and Toxic
Waste Management. Newark, NJ: New Jersey Institute of Technology.
June 1980.
5-8
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OSWER Directive 9380 0-3
Lubowitz, H.R. and Telles, R.W. 1981. Securing Containerized
Hazardous Wastes with Polyethylene Resin and Fiberglass
Encapsulates. EPA 600/2-81-138. July.
Lubowitz, H.R. et al. 1981. Securing Containerized Hazardous Waste
with Welded Polyethylene Encapsulates. EPA-600/2-81-139. July.
Malone, P.G.; Larson, R.J.; and Meyers, I.E. 1980. Stabilization/-
Solidification of Waste From Uncontrolled Disposal Sites. In: Proc.
National Conference on Management of Uncontrolled Hazardous Waste
Sites. Washington, DC. October.
McDowell, C.S. et al. 1980. Biological Methods for In Situ Cleanup
of Oil Spill Residues. Presented at Coastal and Offshore Oil
Pollution Conferences. The French/American Experience. New
Orleans, LA. September.
Morrison, A. 1981. Can Clay Liners Prevent Migration of Toxic
Leachate? Civil Engineering ASCE 51(7):60 July.
Mullins, D.E. et al. 1981. Preliminary Studies Evaluating
Composting as a Means of Pesticide Disposal. Hazardous Waste
Proceedings of the 7th Annual Research Symposium. Inland Disposal.
Philadelphia.
Munemon, M. et al. 1980. Simultaneous Removal of Hazardous Metals
from Wastewater and Disposal of Resultant Sludge. Toxic and
Hazardous Waste Disposal. 3:97-105.
Murry, D.E. and Reitz, H.M. 1978. Development of a Hazardous Waste
Disposal Facility. Presented at Applied Research and Practice on
Municipal and Industrial Waste First Conference. Madison, WI.
September 10-13.
Neely, N.S. et al. 1981. Remedial Actions at Uncontrolled
Hazardous Waste Sites. In: Land Disposal of Hazardous Waste.
Proceedings of the Seventh Annual Research Symposium. Philadelphia.
March 16-18.
Rose, W.W. et al. 1968. Fate of Pesticides in a Composted
Agricultural Waste. Washington, DC: National Canners Association.
Sanders, D. 1979. Deep Well Disposal of Hazardous and Toxic
Wastes, Tulsa City-County Health Department. In: Proc. National
Conference on Hazardous Materials Risk Assessment, Disposal and
Management. Miami Beach, FL.
SCS Engineers. 1979. Selected Biodegradation Techniques for
Treatment and/or Ultimate Disposal of Organic Material. Cincinnati,
OH: EPA 600/2-79-006.
5-9
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OSWER Directive 9380 0-3
Sikora, L.O. et al. 1982. Degradation of Pentachlorophenol and
Pentachloronitrobenzene in a Laboratory Composting System. Land
Disposal of Hazardous Waste. Proc. of the 8th Annual Research
Symposium. MERL, EPA 600/9-82-002.
Sills, M.A.; Struzziery, J.J.; and Silbermann, P.T. 1980.
Evaluation of Remedial Treatment, Detoxification and Stabilization
Alternatives. Proc. National Conference on Management of
Uncontrolled Hazardous Waste Sites. Washington, DC. October.
Srivastava, V.K. and Haji-Djafari, S. 1983. In-Situ
Detoxicifcation of Hazardous Wastes. In: Proc. National Conference
on Management of Uncontrolled Hazardous Waste Sites. Washington,
DC. October 31 - November 2.
Tolman, A. 1978. Guidance Manual for Minimizing Pollution from
Waste Disposal Sites. Cincinnati, OH: EPA 600/2-78-142.
Tracy, K.D. et al. 1979. Mutant Bacteria Aids Exxon Waste Systems.
Hydrocarbon Processing.
Troop, W.M. 1977. Alternative Methods of Phenol Wastewater
Control. J. Haz. Mat. 1:319-329.
TRW Systems Group. 1973. Recommended Methods of Reduction, Neut-
ralization, Recovery or Disposal of Hazardous Waste. Volume 3. PB
224-582. August.
U.S. Environmental Protection Agency. 1982. Handbook for Remedial
Actions at Waste Disposal Sites. Washington, DC: EPA 625/6-82-006.
June.
. 1983. Assessment of Current Status of Using Mined
Space for Long-Term Retention of Nonradioactive Hazardous Waste.
Cincinnati, OH: RFP CI 83-0094.
Wassmann, T.H. 1983. Cavity Utilization in the Netherlands.
Hengelo, The Netherlands.
Whinney, W.N. 1980. Evaluation of Alternatives for Disposal of
Heavy Metal Solution Containing Nitrate. Proc. of U.C.C.-ND and GAT
Waste Management Seminar (Union Carbide Corporation and Good Year
Corporation). Published by Oak Ridge National Laboratory,
Tennessee.
Zitrides, T.G. 1978. Mutant Bacteria for Disposal of Hazardous
Organic Wastewater. Pesticide Disposal Research and Development
Symposium. U.S. Environmental Protection Agency. Reston, VA.
September.
. 1981. Method Converts Organic Wastes to an Inert
Powder. Chem. Engr. 88(21):99,101.
5-10
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OSWER Directive 93800-3
. 1981. Alternatives to the Land Disposal of Hazardous
Wastes. Governor's Office of Appropriate Technology. California.
. 1981. Hazardous Waste Market-Handling, Storage &
Disposal. New York: Frost & Sullivan, Inc.
. 1982. Mutant Bacteria in Cleaning Up of a California
Formaldehyde Spill. Chem. Eng. 89(18).
. 1983. Management of Hazardous Industrial Wastes:
Research and Development Needs. (NMAB-398). National Materials
Advisory Board, Commission on Engineering and Technical Systems,
National Research Council Washington, DC.
See Wagner et al. (undated) under Section 2.2.4.
3.3.2 PERFORM COST ANALYSIS OF ALTERNATIVES
Environmental Law Institute. 1983. Remedial Action Cost
Compendium. July.
Environmental Law Institute/JRB Associates. 1983. Survey and Case
Studies of Remedial Actions at Hazardous Waste Sites (final draft).
Prepared for: U.S. Environmental Protection Agency Office of
Research and Development. April.
JRB Associates. 1983. Remedial Action Costing Procedures Manual.
McLean, VA: JRB Associates. August 26.
McGraw-Hill Information Systems Company. 1983. Dodge Guide. New
York: McGraw-Hill.
Robert Snow Means Company, Inc. 1983. Building Construction Cost
Data 1983. Kingston, MA.
SCS Engineers. 1981. Costs of Remedial Response Actions at
Uncontrolled Hazardous Waste Sites. Prepared for: U.S. Environ-
mental Protection Agency Office of Research and Development. April.
U.S. Environmental Protection Agency. 1981. Remedial Actions at
Hazardous Waste Sites: Survey and Case Studies. Washington, DC:
EPA 430/9-81-05 SW-910, Oil and Special Materials Control Division.
January.
U.S. Office of Managment and Budget. Circular No. A-94. Revised
3/27/82.
Werner, J.D.; Yang, E.J.; and Nagle, E. Remedial Action Management
and Cost Analysis. In: Proc. National Conference on Management of
Uncontrolled Hazardous Waste Sites. Washington, DC.
See U.S. Environmental Protection Agency (1982) under Section 4.2.3
and JRB Associates (1983) under Section 3.3.4.
5-11
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OSWER Directive 9380 0-3
3.3.3 PERFORM ENVIRONMENTAL AND PUBLIC HEALTH ANALYSIS
TetraTech, Inc. undated. Water Quality Assessment: A Screening
Procedure for Toxic and Conventional Pollutants, Volume I and II.
3.3.4 PERFORM REGULATORY AND INSTITUTIONAL ANALYSIS
Anderson National Standard Institute, Inc. Safety Requirements for
Working in Tanks and Other Confined Spaces. New York: ANSI-Z117.1.
NIOSH. Criteria for Recommended Standard: Working in Confined
Spaces. Washington, DC: Publication No. 80-106.
OSHA. General Duty Clause, Section 5 A-l of Occupation Safety and
Health Act (Public Law 91-596). Washington, DC.
Shea, K. 1976. Hot Spot in Oregon. Environment. 18(10):6
December.
See U.S. Environmental Protection Agency (1985b) under Foreword
4.0 TANK AND DRUM SITE REMEDIAL DESIGN/REMEDIAL ACTION
Camp Dresser & McKee Inc. 1981a. Draft Design Report for Surficial
Cleanup and Disposal of Chemical Wastes at the Pollution Abatement
Services Site - Oswego, N.Y. Boston: COM. November.
. 1981b. Contract Documents & Specifications Surficial
Cleanup and Disposal of Chemical Wastes P.A.S. Oswego, N.Y. Boston:
COM. November.
Cooper, E.W. 1983. Emergency Removal Action at the Bankrupt
Crystal Chemical Plant, Houston, Texas. In: Proc. National
Conference on Management of Uncontrolled Hazardous Waste Sites.
Washington, DC. October 31 - November 2.
Moran, B.V. and Turner, J.R. 1983. Lessons Learned by the Corps of
Engineers on Two Superfund Remedial Projects. In: Proc. National
Conference on Management of Uncontrolled Hazardous Waste Sites.
Washington, DC. October 31 - November 2.
Nadeau, P.F.; Dehn, W.T.; and Goldstien, P. 1983. Status of
REM/FIT EPA Contracts. In: Proc. National Conference on Management
of Uncontrolled Hazardous Waste Sites. Washington, DC. October 31
- November 2.
Paige, S.F. et al. 1980. Preliminary Design and Cost Estimates for
Remedial Actions at Hazardous Waste Disposal Sites. In: Proc.
National Conference on Management of Uncontrolled Hazardous Waste
Sites. Washington, DC. October.
5-12
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OSWER Directive 9380 0-3
Pease, R.W. Jr.; Menke, J.L.; and Welks, K.E. 1980. Management of
Abandoned Site Cleanups: Wade Property, Chester, Pennsylvania.
Proc. National Conference on Management of Uncontrolled Hazardous
Wastes Sites. Washington, DC. October.
Robbins, J.C. 1983. Minimizing Liability Exposure When Contracting
Hazardous Waste Services. In: Proc. National Conference on
Management of Uncontrolled Hazardous Waste Sites. Washington, DC.
October 31 - November 2.
U.S. Environmental Protection Agency. 1985. Superfund Remedial
Design and Remedial Action Guidance. Washington, DC: EPA Office of
Emergency and Remedial Response. February.
. 1985. State Participation in the Superfund Remedial
Program.Washington, DC: EPA. Scheduled to be issued in September.
5-13
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OSWER Directive 9380 0-3
APPENDIX A
EXAMPLE OF A SITE PERSONNEL
PROTECTION AND SAFETY EVALUATION FORM
FOR USE DURING
INITIAL SITE VISITS
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OSWER Directive 9380 0-3
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OSWER Directive 9380 0-3
APPENDIX B
DRUM HANDLING. DRUM SAMPLING. SPECIAL WASTE HANDLING,
AND TANK SAMPLING PROTOCOL
Drum and Special Waste Handling Protocol
A Personnel involved in handling and transporting drummed waste shall
work in teams containing no fewer than two people. Visual contact
shall be maintained between members of the working team at all times.
All team members shall be able to communicate between themselves and
with the Safety Officer by two-way radio at all times on the work site,
B Preliminary Classification
1. Prior to physically handling a drum, the following preliminary
classifications check list shall be completed:
a. Is the drum radioactive?
b. Does the drum exhibit leakage or deterioration, i.e., is it
unsound?
c. Does the drum exhibit apparent internal pressure?
d. Is the drum empty?
e. Does the drum contain markings which would indicate that the
contents are potentially explosive?
2. The results of the preliminary classification checklist shall
dictate which specific procedures specified below shall be
followed.
C Leaking or Deteriorated Drums
1. The contents of drums that exhibit leakage or apparent deteriora-
tion such that movement will cause rupture (determined by the
Safety Officer) shall immediately be transferred to a repack drum.
Equipment, including transfer pumps used in the repack operation,
shall be of explosion proof construction.
2. Leaking drums containing sludges or semi-solids, drums that are
structurally sound but which are open and contain liquid or solid
waste, and drums which are deteriorated but can be moved without
rupture, shall be immediately placed in overpack containers.
B-l
-------
OSWER Directive 9380 0-3
D Bulged Drums
1. Drums which potentially may be under internal pressure, as
evidenced by bulging, shall be sampled in place. Extreme care
shall be exercised when working with and adjacent to potentially
pressurized drums.
2. Should movement of a pressurized drum be unavoidable, handling
shall be by a grappler unit constructed for explosive containment.
The bulged drum shall be moved only as far as necessary to allow
seating on firm ground or shall be carefully overpacked.
3. Openings into pressurized drums shall be plugged and the bung holes
fitted with pressure venting caps set at 5 psi release.
E Drums Containing Explosive or Shock Sensitive Waste
1. Drums that contain wastes that have been identified by sampling, or
are suspected by visual examination to be explosive in nature,
shall be handled with extreme caution. Initial handling shall be
by a grappler unit constructed for explosive containment. Drums
shall be palletized prior to transport to high hazard interim
storage and disposal area.
2. If at any time during remedial activities, an explosive, pursuant
to provisions of Title 18, U.S. Code, Chapter 40 (Importation,
Manufacture, Distribution, and Storage of Explosive Materials, 1975
Explosives List) is identified, it should be secured and the
appropriate state and federal agencies notified.
3. Identification of an explosive substance during the course of a
remedial action is usually based on the experience of the on-site
personnel. Potentially explosive materials usually may be
identified by their physical characteristics -- texture, color,
density, etc., as well as the way they are packaged or labeled.
Most explosives are solids. In some cases they are packaged in
water-tight containers to exclude water, while in other cases they
are packaged wet to preclude explosion.
4. Prior to handling or transporting drums containing explosive
wastes, personnel working in the area shall be removed to a safe
distance. Continuous contact with the communication base shall be
maintained until handling or transporting operations are complete.
An audible siren signal system, similar to that employed in
conventional blasting operations, shall be used to signify the
commencement and completion of explosive waste handling or
transporting activities.
F Drums Containing Radioactive Waste
1. Drums containing radioactive wastes shall not be handled until
radiation levels have been determined by an initial field survey
conducted by the contractor. Survey shall include direct gamma
readings and laboratory analysis of drum surface wipe samples.
B-2
-------
OSWER Directive 9380 0-3
2. Depending on the level of radiation encountered, handling and
transport may require special shielding devices to protect
personnel. Following handling and transport, equipment used shall
be surveyed by the Safety Officer and decontaminated to background
levels prior to recommencing work. Surveys shall also be made of
the ground surface in the vicinity of original drum storage to
identify potential soil contamination by spilled or leaked
radioactive waste. Prior to recommencing work in the area,
radioactive soil areas shall be isolated to prevent tracking of
radioactive contaminants about the site.
6 Packaged Laboratory Wastes (Lab Packs)
1. Drums known or suspected of containing discarded laboratory
chemicals, reagents or other potentially dangerous materials in
small volume, or individual containers shall be handled with
extreme caution. Until otherwise categorized, they shall be
considered explosive or shock sensitive wastes. Initial handling
shall be by a grappler unit constructed for explosive containment.
Drums shall be palletized and overpacked if required prior to
transport to the Lab Pack staging for sorting, identification,
repacking and/or stabilization.
2. Prior to handling or transporting Lab Packs from the existing drum
area, personnel working in the immediate area shall be removed to a
safe distance. Continuous contact with the communication base
shall be maintained until handling or transporting operations are
complete. An audible siren signal system, similar to that employed
in conventional blasting operations will be used to signify the
commencement and cessation of Lab Pack handling or transporting
activities.
H Air Reactive Wastes
1. If the presence of an air reactive substance is verified or even
suspected by a contractor, the material should be immediately
segregated and transported to a separate high hazard interim
storage and disposal area.
2. Air reactive wastes may be discovered during opening or sampling
operations. Air reactive substances normally require special
packaging. They may be stored under water or some other liquid to
minimize air contact. They may also be found in sealed ampules,
corrugated drums, stainless steel canisters, or specially lined
drums. Some chemicals, such as white phosphorus or barium oxide,
react with oxygen in the air, while others, such as sodium, cesium
or various metal hybrids, react with the moisture or water vapor in
the air. Many of these compounds are explosive when they come in
contact with air or water.
B-3
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OSWER Directive 9380 0-3
I Gas Cylinders
1. Gas cylinders, when encountered, should be stored and disposed of
on a specific case basis depending on the integrity of the
cylinders and type of substance they are expected to contain.
J Empty Drums
1. Empty drums containing less than 1 in. of solid residual waste and
those resulting from on-site bulking and repack operations shall be
loaded by grappler into transport equipment and placed within the
empty drum staging area. Residuals, where possible, shall be
transferred to repack containers prior to movement. Additional
information on the definition of empty drums can be found in
40 CFR 26L7. Also, limitations on the reuse of drums can be found
in 49 CFR 173.28.
K General Drum Handling Procedures
1. The handling, movement, and transport of drums should be by use of
mechanical equipment only; no drums should be handled manually.
2. Remote drum handling equipment shall consist of a grappler equipped
backhoe or front end loader. Drum transportation should be with
front end loaders or fork lifts with modified carrying platforms.
Portions of equipment that contact drums or canisters should be
constructed of non-ferrous metals or contact portions should be
coated or lined to preclude spark generation.
Handling and transport equipment should be equipped with full
frontal and side splash and explosion shields. Class ABC fire
extinguishers shall be fitted to the body of each piece of
equipment.
Equipment should be maintained in first class condition. The
ignition manifold and exhaust components shall be maintained to
prevent backfiring or generation of sparks within the exhaust
gases.
B-4
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OSWER Directive 93800-3
DRUM SAMPLING PROTOCOL
A General Drum Sampling Protocol
The protocols for drum sampling performed at two NPL sites are presented in
Figures I to VII (at the end of the Appendix). These protocols are a
systematic plan for the identification, segregation/isolation, consolida-
tion, and bulking of unspecified waste materials stored at an abandoned
hazardous waste site. The analytical methods and references for the waste
testing are presented in Figure VII. These methods are provided for
guidance only. The protocol established herein is designed to provide
analytical data, compatibility and consolidation information consistent
with cost effective environmentally sensitive removal and disposal of
hazardous waste from the site. The quality assurance for these activities
should be consistent with the procedures specified in "Enforcement
Consideration for Evaluation of Uncontrolled Hazardous Waste Disposal Sites
by Contractors" (U.S. EPA, National Enforcement Investigation Center, April
1980).
The following are the standard materials and equipment required for
sampling:
1. Personnel protection equipment
2. 500 ml, wide-mouth amber glass bottle with teflon cap liner
3. A uniquely numbered sample identification label affixed to sample
container
4. Chain of custody data sheets
5. 4-ft. x 3/4-in. ID glass sampling thief
6. Remotely operated, pneumatic ram or check key device
7. One gallon covered cans half-filled with absorbent (for off-site
shipment only)
During the initial reconnaissance and characterization, any customized
containers, suspicious looking drums, or drums labeled as containing
hazardous materials (explosives, etc.) should be clearly marked for special
handling. Maximum care and caution shall be exercised when opening drums
containing materials of an unknown origin. A drum should not be moved or
opened unless it has been ascertained beyond reasonable doubt that the drum
is structurally sound and an external gross gamma scan is negative.
Drums should be sampled in place. All drums and mechanical equipment
should be grounded prior to the commencement of sampling. If the bung can
be removed, sampling contained liquids shall be by a glass thief, which
shall them be broken and discarded within the barrel. A barrel that has a
badly rusted bung, or that cannot be sampled as above, shall be safely
B-5
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OSWER Direct.ve 9380 o J
entered with a hydraulic penetrating device operated remotely. All
openings shall be plugged except during sampling operation.
B Specific Sampling Procedure Using a Glass Thief
1. Remove cover from sample container.
2. Insert glass tubing almost to the bottom of the drum or until a
solid layer is encountered. About 1 ft. of tubing should extend
above the drum.
3. Allow the waste in the drum to reach its natural level in the tube.
4. Cap the top of the sampling tube with a tapered stopper, ensuring
liquid does not come into contact with stopper.
5. Carefully remove the capped tube from the drum and insert the
uncapped end in the sample container. Do not spill liquid on the
outside of the sample container.
6. Release the stopper and allow the glass thief to drain completely
and fill the sample container. Fill the container to about 2/3 of
capacity.
7. Remove tube from the sample container, break it into pieces and
place the pieces in the drum.
8. Cap the sample container tightly and place prelabeled sample
container in a carrier.
9. Replace the bung or place plastic over the drum.
10. Transport sample to on-site laboratory for analysis.
C Sample preservation and packing procedures for drummed waste samples
1. No preservatives shall be used.
2. Place sample in a ziplock plastic bag.
3. Place each bagged container in a 1-gallon covered can containing
absorbent packing material. Place lid on can.
4. Mark the sample identification number on the outside of the can.
5. Arrange for the appropriate transportation mode consistent with the
type of hazardous waste involved.
D Considerations for Analytical Program
At the certified laboratory, each of the waste phases from all tanks should
first be tested for compatibility. Many wastes, when mixed with others,
can produce potentially adverse human health and environmental conditions
B-6
-------
Directive 93800-3
such as: (1) heat generation, (2) violent reaction, (3) release of toxic
fumes and gases, (4) release of toxic substances in case of fire or
explosion, (5) fire or explosion, and (6) generation of flammable or toxic
gases.
A summary list of potentially incompatible waste materials or components
and the adverse consequences of mixing waste in one group with waste in
another group is presented in Appendix C. The mixing of a Group A waste
with a Group B waste may have the consequences noted.
The results of the compatibility characterization should be used to sort
bulk waste into compatibility categories for ultimate disposal. A
composite sample of each compatibility category will then be analyzed for
all major chemical components.
B-7
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OSWER Directive 9380 0 3
TANK SAMPLING PROTOCOL
A Regulatory Requirements
1. Guidelines have been developed to ensure the safety of the opera-
tions personnel which shall be consulted by the contractor. These
are as follows:
a. OSHA - "General Duty Clause", Section 5 A-l of the Occupational
Safety and Health Act (Public Law 910596).
b. NIOSH - "Criteria for Recommended Standard; Working in Confined
Spaces", Publication No. 80-106.
2. In addition, reference material shall also be used, such as the
Anderson National Standard Institute, Inc. (1430 Broadway, New
York, NY 10018) "Safety Requirements for Working in Tanks and Other
Confined Spaces", ANSI-Z117.1
B Tank Structural Survey
The external structural characteristics of each tank and tanker shall be
observed and uniquely recorded and potential sampling points shall be
evaluated for safety, accessibility and sample quality.
C Tank Entry Procedure
1. Prior to opening a tank for internal inspection, the tank entry
team shall:
a. Review safety procedures and emergency contingency plans with
the Safety Officer.
b. Ensure that tank is properly grounded.
c. Remove all sources of ignition from the immediate area.
2. All members of the tank entry team shall be fitted with
self-contained breathing apparatus.
3. Each tank shall be mounted using appropriate means and the manway
covers removed using non-sparking tools.
4. Obtain and record the following information at each potential
sampling location.
a. Lower explosion limit (LEL) reading directly above the sampling
port and the tank head space.
b. Organic vapor concentration directly above the sampling port
and in the tank head space.
B-8
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OSWER Directive 9380 0-3
c. Percent oxygen concentration directly above the sampling port
and in the tank head space.
d. Physical characteristics of tank contents (liquid, sludge, or
solid).
e. Distance from sampling port flange to the surface of tank
contents.
f. Presence of toxic vapors.
g. Accumulation of pyrophoric deposits.
h. Ionizing radiation.
i. Additional potential physical hazards.
5. After the above information has been obtained, each opening shall
be closed and secured.
D Profiling of Contents
1. Personal protective equipment and respiratory protection shall be
determined by the Safety Officer based on information gained from
the reconnaissance work specified above. Minimum protection shall
be Level C.
2. Material and equipment required for profiling and/or sampling are
as follows:
a. Personal protection equipment as specified in Health & Safety
Plan
b. OVA, Organic Vapor Analyzer, or equivalent
c. Exp1osimeter/Oxygen meter
d. Geiger counter
e. Flashlight (explosion proof)
f. Trowel-stainless steel
g. Weighted sampler
h. Gem scoop
i. Bottom sediment sampler
j. Alumi num foi1
k. Glass thief
1. Log book
B-9
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OSWER Directive 9380 0-3
m. Intrinsically safe high volume blower
n. Wide mouth amber glass (550 ml) bottle with teflon cap liner
o. Sample identification labels affixed to sample bottle
p. Chain-of-Custody forms
q. Metal paint can (1 gallon) half-filled with absorbent
r. Camera
3. Prior to commencing any profiling, the tank head space shall be
cleared of any toxic or explosive vapor concentration using a high
volume blower. No work shall start in any tank if the LEL exceeds
10% (as methane).
4. The preliminary safety guidelines outlined above shall be observed.
5. Profiling Procedure
a. Determine the depth of any and all liquid solid interface using
a weighted probe line.
b. Determine the depth of any bottom sludge layer using a weighted
probe line.
c. Collect liquid samples from 1 ft. below the surface, from mid
depth of the liquid, and from 1 ft. foot above any bottom
sludge layer. Samples shall be collected a weighted bottle
sampler (ASTM Method D270).
d. Visually compare the three samples. If no visual phase
difference is observed, perform field test as required to
verify that no phase differences are present in the tank.
Field tests selected shall be determined by the type of
material found in the tank (organic, aqueous) and include:
Specific Conductivity
Specific Gravity
Refractive Index
PH
Solubility (water, methanol, methylene chloride)
Viscosity
e. If any sampling indicated a phase difference, a systematic,
interactive sampling procedure shall be performed by halving
the distance between two discrepant sampling points until the
depth of the phase change can be determined. This phase
difference shall be verified by field tests specified in d
above.
f. Verify the profile information from at least one other access
port when possible.
B-10
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OSWfcR Directive 9380 0-3
g. The mutual incompatibility of all phases shall be verified.
h. Determine the volume of wastes in each phase and the volume and
depth of any sludge.
Sampling Procedure
1. The method utilized to sample the tanks shall be based on the
physical characteristics of the material. Liquid materials shall
be sampled with a weighted bottle or glass thief; gels and sludges
shall be sampled with a scoop or bottom sediment sampler.
2. Liquids shall be sampled as follows:
a. Determine the depth to any and all liquid/solid interfaces
using a weighted probe line or glass thief.
b. Determine the depth of the bottom sludge layer using a weighted
probe line or glass thief.
c. For liquids with a depth of greater than 5 ft.:
1. Collect samples from 1 ft. below the surface, from mid
depth of the liquid, and from one-foot above any bottom
sludge layer. Using a weighted bottle sampler (ASTM Method
D270).
2. If a visual examination of sample indicates phase
difference, a systematic, interactive sampling procedure
shall be performed by halving the distance between two
discrepant sampling points until the depth of the phase
change can be determined.
d. For liquids with a depth of 5 ft or less:
1. Collect liquid samples using a glass thief inserted in the
full depth of the liquid.
2. Transfer the liquid sample to a glass sample bottle and
dispose of thief in tank.
3. A maximum of three composite samples shall be obtained from
each sampling port.
3. Sludges shall be sampled using a scoop of modified bottom sediment
sampler. A maximum of three sludge samples from each sampling port
shall be obtained at various depths within the tank.
4. Between each sampling event, the samplers shall be cleaned, rinsed,
and dried prior to use.
5. Samples shall be placed in 500 ml wide mouth amber bottles. The
bottles shall not be filled beyond 2/3 capacity.
8-11
-------
OSWER Directive 9380 0-3
6. Sample bottle openings shall be covered with aluminum foil and
capped with teflon lined caps.
7. Sample identification information and locator information shall be
recorded in a log book. A descriptive narrative shall accompany
each sample obtained from the tanks.
B-12
-------
Figure I. Waste segregation protocol.
Bulking and Consolidation Protocol
OSWER Directive 9380 0-3
(Solid)
I
External Scan for Radioactivity
Positive
Isolate
Confirm Structural Integrity of Drum
Damaged
Leaking
On Site Consolidation
if Available
Overpack
Characterize Drum Contents
with Brass Probe Rod
(Liquid)
I
Label and Inventory
See Fig
Label and Inventory
See Fig III
B-13
-------
OSWER Directive 9380 0-3
Figure II. Solid materials.
Bulking and Consolidation Protocol
Open Drum
I
Scan for Radioactivity
Alpha, Beta, Gamma
Positive
Isolate
Confirm Solid
Negative
or Free Liquid
(Unspecified Solid)
1
See Consolidation Protocol
for Compatibility Categories
(Appendix C)
i
Composite PCB Testing
Resegregate (Liquid) or
See Fig III | 1 . |"
See Fig IV
>50
ppm PCB
For SD and— determine flashpoint (1 7) for ultimate disposal requirements for solid materials
PCB
B-14
-------
Figure III. Liquid materials.
OSWER Directive 93800-3
Bulking and Consolidation Protocol
Open Drum
Scan for Radioactivity
Alpha, Beta, Gamma
Positive
Isolate
Negative
Test for Penoxides, Oxidizers
and Strong Reducing Agents
>, Resegregate (Solid) or (Other)
[See Fig IllijSee Fiv IV [
Test for Water Reactivity,
Solubility and Density
Water Reactive
Isolate
(Water Insoluble)
(Organic Liquid)
t
(Water Soluble)
<10%
1
(6) Tesl
HiO -M .
I
Test for Water Content
j)Spot Test for Organic Hahdes|
Negative Test
Positive Test
Density H2O
<2% Halide
Retest
<7 0
(Aqueous)
I
Test for pH ]
>7 0
>2% Halide
(Aqueous Acid)
(Organic Liquid)
Low Halogen
See Consolidation Protocol
for Compatibility Categories
Specified - See Fig V
(Organic Liquid)
High Halogen
I
J
rj 5) Composite PCB Testing
<2% Hahde/
50 ppm
< PCB
Hahde/
50 ppm
< PCB
(Unspecified Aqueous)
Base/Neutral
y
I (To) Test for Sulfide I
>
h i k
|^2^ Test for Cyanide
V)Retest|
, \
Positive J^Wpstf-
Negative I
(Aqueous Base/Neutral)
pH <12o|pH >120
Positive
—
-------
OSWER Directive 93800-3
Figure IV Other materials
Miscellaneous
Dispose
Unknown
or Forbidden
Materials
Treat
Stabilize
Consolidate
Bulking and Consolidation Protocol
Other Materials
Multi-Phase
Compatibility Testing
Individual Phases*
Solid
See Fig II
Liquid
See Fig. Ill
*lf phases are incompatible, they must be separated and repacked
B-16
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OSWER Directive 9380 0-3
Figure V.
Consolidation protocol for compatibility categories specified
Bulking and Consolidation Protocol
Compatibility Testing of
Individual Drum or Solid
Samples
Liquids
Incompatible
10 Drum or 6000 Ib
Composite*
Solids
10 Drum
Composite
Composite PCB
Analysis
Reanalyze Individual Samples
From Fig IV
Sludge
> 5 ppm PCB
Reanalyze Individual
Samples
< 50 ppm PCB
"Composite is based on the threshold value for determining PCB waste and field detection limits
"Quantities based on typical truck capacity, may vary at specific sites
B-17
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OSWER Directive 9380 0-3
FIGURE VI
DISPOSAL CATEGORIES
(In diamonds on Figures I to V)
R RADIOACTIVE MATERIAL (Solid or Liquid)
OX STRONG OXIDIZER
RD . STRONG REDUCING AGENT
WR WATER REACTIVE MATERIAL
A AQUEOUS ACID pH <2.0
B AQUEOUS BASE pH >12.0
PCB
50-500 PCB CONTAMINATED LIQUID 50-500 PPM
ppm
PCB
>500 PCB CONTAMINATED LIQUID >500 PPM
ppm
OH ORGANIC LIQUID WITH HIGH (>2%) HALOGEN CONTENT
OL ORGANIC LIQUID WITH LOW (<2%] HALOGEN CONTENT
SD SOLID MATERIAL UNCONTAMINATED (<50 PPM) WITH PCB
PCB
S AQUEOUS BASE CONTAMINATED WITH SULFIDE
CN AQUEOUS BASE CONTAMINATED WITH CYANIDE
0 OTHER MISCELLANEOUS MATERIALS INCLUDING EXPLOSIVES
AND AIR REACTIVE SUBSTANCES
NA NEUTRAL AQUEOUS, 50 PPM PCB, 2
-------
FIGURE VII
ANALYTICAL METHODS
(In circles in Figures I to V)
OSWER Directive 9380 0-3
DESIGNATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
METHOD
RADIOACTIVITY, ALPHA, BETA, GAMMA
OXIDATION REDUCTION POTENTIAL (ORP)
CONFIRMATION TEST FOR PERIOXIDES AND
OTHER OXIDIZING AGENTS
CONFIGURATION TEST FOR REDUCING AGENTS
TEST FOR WATER REACTIVITY AND SOLUBILITY
TEST FOR WATER CONTENT
SPOT TEST FOR PRESENCE OF HALOGENS
TEST FOR HALOGEN CONTENT
pH ANALYSIS
SPOT TEST FOR SULFIDE
CONFIRMATION TEST FOR SULFIDE
SPOT TEST FORCYANIDE
CONFIRMATION TEST FOR CYANIDE
COMPATIBILITY PROCEDURE
COMPOSITE PCB ANALYSIS
CHEMICAL CHARACTERIZATION AS REQUIRED
FOR DISPOSAL
IGNITABILITY
REFERENCE
*MUHWS (110)
MUHWS (112)
DCP (5.9)
*TBQIA (564)
DCP (5.1)
DCP (5.20
*SIOC (174)
DCP (5.6)
DCP (J5.3)
*LEAD ACTIVE PAPER
DCP (5.50)
*DCP (5.4)
*SM (412E)
DCP (5.8)
DCP (5.7)
Section 13573,
1.03B
SW-846 (1010, 1020)
*See Analytical Notes.
B-19
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OSWER Directive 9380 0-3
FIGURE VII
ANALYTICAL METHODS
(Continued)
DCP - Drum Consolidation Protocol, A Hazardous Waste Site Management
Plan (Chemical Manufacturers Association, Washington, D.C., 1982)
MUHWS - National Conference on Management of Uncontrolled Hazardous Waste
Sites (U.S. EPA Hazardous Materials Control Research Institute),
October 1981
SIOC - The Systematic Identification of Organic Compounds, Shriner et
al., 5th Edition, Jon Wily & Sons, New York, NY, 1964
TBQIA - Text Book Quantitative Inorganic Analysis, Kolthoff, I.M., 3rd
Edition, McMillion Co.
SM - Standard Methods for Examination of Water & Waste Water, 15th
Edition, 1980
SW-846 - Test Methods for the Evaluation of Solid Waste Physical/Chemical
SW-846, U.S. EPA, 1984.
B-20
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APPENDIX C OSWER Directive 9380 0-3
EXAMPLE OF A
BULKING AND CONSOLIDATION PROTOCOL
Purpose
The concept of the bulking and consolidation protocol is to segregate
wastes based on water content, acidity, water solubility, and reactivity in
anticipation of ultimate disposal.
Technique
The protocol (a) assumes the waste contains complex mixtures of solids and
liquids of unknown source and concentration; (b) subdivides the liquids
into general disposal categories; (c) determines that wastes within a group
are compatible by actual compatibility testing; (d) provides that each
compatibility group composite is tested for PCB to ensure that contaminated
material is disposed of properly; and (e) provides that compatible
materials are then bulked in batches for disposal ("Disposal Units") - for
liquids and solids, 50 drums or 30,000 Ibs, respectively. All solid
material should be moved off-site in individual containers only.
Other points considered in this approach include the following:
• Radioactive waste shall be identified both at the initial stage of
site evaluation as well as during the sampling of individual con-
tainers .
• Waste containing peroxides, and toxic gas-forming compounds
(cyanide, sulfide) should be identified and segregated for special
treatment. Consolidation at a later date may be advisable but only
after performing the compatibility testing procedure as outlined in
the protocol.
• Tests for water solubility, reactivity and water content shall be
used to classify organic, aqueous-soluble organic and inorganic
wastes. (The organic/aqueous and aqueous wastes include
emulsions). Very often density is an indication of structure
(i.e., if liquid is heavier than water, halogen is probably
present).
• Samples shall be tested for organic halogen content, however, the
test procedures done in the field only detect gross amounts; 1-2
percent. Samples shall be retested for PCBs before disposal, and
C-l
-------
OSWER Directive 9380 0-3
before one contaminates larger batches. This is why lab size con-
solidated mixtures are tested prior to consolidation to avoid
contamination.
• Wastes containing multiple phases shall be treated separately and
all phases analyzed.
• The compatibility test shall be performed on-site by mixing small
samples (left over from analyses). Visual observation for
precipitation, or phase separation and temperature measurement (to
test for chemical reactions) shall be made.
• All of these analytical tests shall be performed on-site using
relatively simple procedures and equipment. Analysis for EP
toxicity and PCBs shall be done by the contractor.
• The analytical procedure for determining halogen content shall
determine gross halogen content (>1%). Tests for PCBs shall be
done to determine ultimate disposal if disposal is in a non-PCB
approved incinerator. Tests shall be conducted on the lab
composites prior to mixing drum contents so one can isolate the
contaminating container and/or change the mixing sequence as
required to avoid PCB contamination.
A simplified logic diagram for the consolidation protocol is presented in
Figure 1.
Chemical characterization in anticipation of ultimate disposal, is designed
to test composite samples taken from individual drum sample aliquots. No
bulking or consolidation should be done until the result of the analyses of
the "lab scale" composite are reviewed to preclude the inadvertent
contamination of a consolidated lot by a highly concentrated component such
as PCB. The testing and analytical procedures to be used on the
consolidated materials should be that required for transport and disposal
of material which will vary dependent on the method of disposal.
Following chemical characterization, those wastes that for chemical or
physical reasons cannot be bulked should be consolidated in approved drums
pending disposal. The Contractor should, as far as practical, use the full
volume of each drum. Shipment from site of partially empty drums of solid
waste should be kept at a minimum.
Limitations
Not applicable
C-2
-------
Figure 1. Simplified logic diagram waste consolidation protocol.
Unspecified Waste
OSWER Directive 9380 0-3
Chemical/Physical Characteristics
I
Determine Specific Disposal Categories
Compatibility Testing
Consolidation
Bulking
Off-Site Disposal
Isolation of Noncompatible Wastes
for Special Handling of On-Site
Treatment
R Radioactive
OX Strong Oxidizer
RD Strong Reducing Agent
WR Water Reactive Material
A Aqueous Acid
B Aqueous Base
CN Cyanide Waste
S Sulfide Waste
C-3
-------
OSWER Directive 9380 0-3
COMPATIBILITY OF HAZARDOUS WASTE GROUPS
Group 1-A
Acetylene sludge
Alkaline caustic liquids
Alkaline cleaner
Alkaline corrosive liquids
Alkaline corrosive battery fluid
Caustic wastewater
Lime sludge and other corrosive
alkalies
Lime wastewater
Lime and water
Spent caustic
Group 1-B
Acid sludge
Acid and water
Battery acid
Chemcial cleaners
Electrolyte, acid
Etching acid liquid or solvent
Liquid cleaning compounds
Picking liquor and other
corrosive acids
Spent acid
Spent mixed acid
Spent sulfuric acid
Potential consequences: Heat generation, violent reaction.
Group 2-A
Group 2-B
Asbestos waste, and other toxic
wastes
Beryl 1ium wastes
Unrinsed pesticide container
Waste pesticides
Cleaning solvents
Data processing liquid
Obsolete explosives
Petroleum waste
Refinery waste
Retrograde explosives
Solvents
Waste oil and other flammable
and explosive wastes
Potential consequences: Release of toxic substances in case of fire or
explosion.
C-4
-------
Group 3-A
OSWER Directive 9380 0-3
Group 3-B
Aluminum
Beryllium
Calcium
Lithium
Magnesium
Potassium
Sodium
Zinc powder and other reactive
metals and metal hydrides
Any waste in Group 1-A or 1-B
Potential consequences: Fire or explosion; generation of flammable
hydrogen gas.
Group 4-A
Group 4-B
Alcohols Any concentrated waste in
Water Groups 1-A or 1-B
Calcium
Lithium
Metal hydrides
Potassium
Sodium
S02, C12, SOC12, PC13, CH3,
SiCl3 and other water
reactive wastes
Potential consequences: Fire, explosion, or heat generation; generation
of flammable or toxic gases.
C-5
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OSWER Directive 9380 0-3
Group 5-A
Alcohols
Aldehydes
Halogenated hydrocarbons
Nitrated hydrocarbons and other
reactive organic compounds and
solvents
Unsaturated hydrocarbons
Group 5-B
Concentrated Group 1-A or 1-B
wastes
Group 3-A wastes
Potential consequences: Fire, explosion or violent reaction.
Group 6-A
Group 6-B
Spent cyanide and sulfide
solutions
Group 1-B wastes
Potential consequences: Generation of toxic hydrogen cyanide
or hydrogen sulfide gas.
C-6
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OSWER Directive 9380 0-3
Group 7-A
Chlorates and other strong
oxidizer
Chlorine
Chlorites
Chromic acid
Hypochlorites
Perch!orates
Permanganates
Peroxides
Group 7-B
Acetic acid and other organic
acids
Concentrated mineral acids
Group 2-8 wastes
Group 3-A wastes
Group 5-A wastes and other
flammable and combustible
wastes
Potential consequences: Fire, explosion, or violent reaction.
Source: "Law. Regulations and GUI'del_ines_fo_rDandling of
Hazardous Waste."
California Department of Health, February 1975.
C-7
-------
U.S. Environmental Protection Agency y
Region 5 Library (PL-12J) ''
77 West Jackson Blvd., 12th Floor
Chicago, IL 60604-3590
-------
u I
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