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"^.f'.-fr.'r^'.-?* £m«rg(»ncy DIRECTIVE NUMBER: 9523.o-5 EFFECTIVE DATE: ORIGINATING OFFICE; - » fr.,?1Ktj?(.\fJ.3Sjlt*!»Ji,!S!V-=W* 16..W-".••*"> ^ ------- v EPA Wasnmgton, OC 2C460 OSWER Directive Initiation Request 9523.00-5 Name of Contact Person Art Day Man Cooe - Branch .eao O'fice i_J OEBR D OSW i_i OUST LJ OWPE D AA-OSWEfi Signature of C'f>ca Permit Applicant's Guidance -Manual for Hazardous Waste Lana Treatment, Storage, ana Disposal Facilities Summary of Directive SUMMARY . n To provide guidance for preparation of Part A and Part B permit applications for hazardous waste land treatment, llorage In6 disposal facilities regulated under RCRA 1976 Some of the standards in effect when the Manual was published have been replaced, i.e., some guidelines are obsolete while others remain current. it, Treatment, Storage, Disposal, Landfill, Groundwater Monitoring Typt of Directive (Minutl. Policy Qtrtctnt. Announcement, etcj Status D Draft O F.nat G New LJ Revision Do«»tnis Dir»ctiv« Sup*ri«M Prtvtom Otfectiva(s;> [ | Yes j_'j No Does it Supplement Previous Directives!' |J Yes 'Yes • to Either Question, VVnat Directive (number nt/ei view Plan D AA-OSWER D OUST D OERB D OWPE Q OSW O Regions D OECM D OGC D OPPE D Other ,'Specifyl I "—i U9vv i—_i nvgions • ' U jTh.s Request Meets OSWER Directives System Format ISigrature of Lead Office Directives Officer _..--.. ••«^M««» >*>w»« N^^w^ri ^11 WlvltVW* JT ISigr-ature of Lead Office Directives Officer ' Date Signature of OSWER Directives Officer Date ------- &EPA United States Environmental Protection Agency Office of Solid Waste and Emergency nesoonse .Vasnmgton DC 20450 October 1983 Draft Permit Writers5 Guidance Manua! for Hazardous Waste Land Treatment, Storage, anc Disposal Facilities Volume 2 For Internal Use Only ------- OSWtR -. 95*3 • PERMIT WRITER'S GUIDANCE MANUAL FOR HAZARDOUS WASTE LAND TREATMENT,- STORAGE, AND DISPOSAL FACILITIES Volume 2 This Document has not been Peer and Administratively Reviewed within EPA and is for Internal Agency Use/ Distribution Only. • Project Officer Jon R. Perry Land Disposal Branch Office of Solid Waste Washington, D.C. 20460 OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE U. S. ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 ------- DISCLAIMER This Drait Final Raport was furnished to the Environmental Protection Agency by the GCA Corporation, CCA/Technology Division, 3edfora, ;iassacnusects 01730, in fulfillment of Contract No. 68-02-3168, Assignment No. 37-(3). The opinions, findings, and conclusions expressed are those of the authors and not necessarily Chose of the Environmental Protection Agency or the cooperating agencies. Mention of company or product names is not to be considered as an endorsement by the Environmental Protection Agency. ------- ACKNOWLEDGMENTS The authors express their appreciation to the staff of the Office of Solid Waste, Land Disposal Branch, including Mr. Jon Perry, the EPA Project Officer, and Messrs. Art Day and Mike Flynn, for their assistance and helpful guidance throughout this program. We also acknowledge tne collective group of authors whose work is cited throughout this document including researchers associated with the EPA Municipal Environmental Research Laboratory in Cincinnati, and organizations such as K. W. Brown and Associates, Inc.. GeoTrans, Inc., and Matrecon, Inc. This manual was prepared by the GCA/Technology Division of GCA Corpor- ation, Bedford, MA. The principal authors were Charles W. Young, Peter H. Anderson, Stephen V. Capone, John P. Patinskas, Ronald K. Bell, Lisa A. Baci, Nancy H. Krusell, and Pablo Huidobro. We thank other GCA staff members who contributed to this document, including Messrs. Thomas J. Nunno, Daniel J. Goode, and Michael R. Jasinski. We also axtend our appreciation to the staff of the GCA Technical Publications Department, managed by Ms. Sharon Pleskowicz, for their dedicated assistance in preparing this document. 1 1 l ------- CONTENTS Acknowledgments ..,..,. iii Figures viii Tables xxiv 1.0 Introduction 1-1 1.1 Purpose 1-1 1.2 Use, Content, and Format of This Manual 1-1 1.3 Other Guidanca Manuals 1-2 1.4 Procedures for Updating and Revising This .-ianuai . . i-2 2.0 Overview of RCRA and the Regulations 2-1 2.1 RCRA and Subtitle C 2-1 2.2 The Code of Federal Regulations . . 2-4 2.3 Regulations Addressed in the Manual and Their Applicability 2-6 3.0 Administrative Processing of Parmit Applications and Preparation of Draft and Final Permits 3-1 3.1 Introduction 3-1 3.2 Initial Review of Permit Application 3-3 3.3 Preparation of the Draft Permit 3-11 3.4 Procedures to Generate the Final Permit 3-17 4.0 Model Permit for Hazardous Waste Treatment, Storage, and 4-1 4-3 --9 4-15 4-20 4-21 4-26 4-31 4-35 4-39 4-42 4-43 4-48 5.0 Ground Water Protection 5-1 5-4 Characteristics 5-13 5.3 Waste Management Area, Point of Compliance, and Well Locations 5-31 5.4 Description of Any Ground Water Contamination . . . 5-43 5.5 Detection Monitoring Program 5-58 Lu-ap 4.1 4 2 4.3 4.4 4.5 4 6 4. 7 4 8 4.9 /. in 4.11 4 12 G pound 5.1 5.2 Module Va - Waste Pile Which Closes as Landfill , . Module XIV - Land Treatment Identification of Uppermost Aquifer and ------- CONTENTS (continued) 5.6 Compliance Monitoring Program 5-88 5.7 Corrective Action Program 5-98 5.8 References 5-106 5.9 Example Maps and Cross-Sections and Descriotion of Example Geology 5-108 5.10 Technical Adequacy Checklist 5-115 6.0 Surface Impoundments 6-1 6.1 Waste Description ------- CONTENTS (continued) 8.0 Land Treatment 8-1 8.1 Treatment Demonstration 8-3 8.2 Land Treatment Program 8-63 8.3 Design and Operating Requirements 8-119 8.4 Food-Chain Crops Requirements .... 3-151 8.5 Establishment of Vegetative Cover at Closure .... 8-167 8.6 Special Requirements for Ignitable or Reactive Wastes 8-176 8.7 Special Requirements for incompatible Vastas .... 3-L95 8.3 Technical Adequacy Checklist 8-209 9.0 Landfills 9-1 9.1 Waste Description 9-3 9.2 Design and Operating Requirements 9-10 9.2.1 Liner System Design 9-10 9.2.2 Laachate Collection and Removal System . . . 9-60 9.2.3 Liner and Leachate Collection and Removal System Ixeraption 9-109 9.2.A Control of Run-On 9-113 9.2.5 Control of Run-Off 9-127 9.2.6 Management of Units Associated With Run-On and Run-Off Control Systems 9-134 9.2.7 Management of Wind Dispersal 9-136 9.2.8 Subpart F Exemption 9-142 9.3 Inspection Requirements 9-147 9.4 Landfill Closure and Post-Closure 9-187 9.5 Handling and Disposal of Ignitable or Reactive Wastes ". 9-203 9.6 Special Requirements for Incompatible Wastes .... 9-229 9.7 Disposal of Liquid Waste in Landfills 9-242 9.8 Special Requirements for Containers and Lab Packs . 9-265 9.9 Technical Adequacy Checklist 9-279 10.0 Completeness Checklist . 10-1 RCRA Permit Application Completeness Checklists for Parts A & B 10-2 vii ------- Number Page " I ' —I |J.IM 3.1.1 The RCRA permitting process 3-2 3.2.1 Form letter for request of Part B 3-5 3.2.2 Sample notice of deficiency for existing HWM facility . . . 3-9 3.2.3 Sample form letter for informing the applicant that his/her application is considered to be complete 3-10 3.0.1 Basic ground water monitoring and response program elements 5-3 5.1.1 Part 265 regulations applicable to interim status ground water monitoring ... 5-6 5.1.2 Worksheet for evaluating the interim status monitoring program and results 5-10 5.2.1 Applicability of regulations to aquifer characterization " 5-15 5.2.2 Worksheet for evaluation of the uppermost aquifer and flow properties 5-23 5.2.3 Worksheet for assessment of geological information .... 5-25 5.2.4 Worksheet for assessment of hydrogeological information ._. 5-26 5.2.5 Worksheet for assessment of topographic base map information 5-27 5.2.6 Worksheet for assessment of geologic/hydrogeologic map information 5-28 5.2.7 Worksheet for assessment of bedrock information . . 5-29 5.2.3 Worksheet for assessment of information included in a cross-section 5-30 viii ------- FIGURES (continued) Number Page 5.3.L Applicability of regulations to waste management area, point of compliance, and well locations 5-33 5.3.2 Worksheet for asaessmenc of Information presented co establish the waste management area 5-34 5.3.3 Possible ground water flow patterns 5-37 5.3.4 Example flow patterns and facility orientations which influence location of monitoring wells 5-39 5.3.5 Spacing of wells in uppermost aquifers of varying permeability contrast 5-40 5.3.6 Compliance point monitoring for multipla regulated units 5-42 5.3.7 Compliance point monitoring for facility only partially utilized 5-44 5.3.8 Worksheet for evaluating the proposed location of down- gradient wells at the point of compliance 5-45 5.3.9 Worksheet for assessment of background well information . . 5-47 5.4.1 Applicability of regulations-to characterization of the plume of contamination 5-49 5.4.2 Worksheet for evaluating the information submitted regarding any existing plume of contamination 5-57 5.5.1 Applicability of regulatory requirements to the detection monitoring program 5-60 5.5.2 Worksheet for determining the adequacy of the selected indicator parameters 5-64 5.5.3 Worksheet for evaluating background contamination values and procedures for their determination 5-67 5.5.4 Worksheet for evaluating proposed statistical comparison procedures 5-69 5.5.5 Well screens placed at various elevations 5-72 5.5.6 Dense contaminants flowing below the screened portion of monitoring wells 5-73 ix ------- FIGURES (continued) Number Page 5.5.7 5.5.8 5.5.9 5.5.10 5.5.11 5.5.12 5.5.13 5.5.14 5.5.15 5.6.1 5.6.2 5.6.3 5.7.1 5.7.2 5.9.1 5.9.2 5.9.3 5.9.4 5.9.5 Light contaminants flowing above the screened portion of monitoring wells Well screen located throughout full depth of aquifer . . . Worksheet for assessment of information on well design and cons true c_on . Worksheet for assessment of well installation information Observation well construction summary ..... Worksheet for assessment of well development method . , . . Worksheet for assessment of sampling procedures Worksheet for assessment of information on sample analysis Worksheet for assessment of chain of custody procedures . • Applicability of regulations to the compliance monitoring program Worksheet for evaluating the" list of hazardous constituents. proposed for incorporation in the ground water protection standard ........ Worksheet for evaluating ground water performance standard concentration limits ... Applicability of regulations to the corrective action program Worksheet for evaluation of proposed corrective action procedures Example surficial materials map Example bedrock geologic map Example ground water regime Example geologic cross section A - A1 Example geologic cross section B-B* 5-75 5-76 j~ i i 5-79 5-80 5-81 3-83 5-84 5-85 5-91 5-93 5-94 5-101 5-103 5-110 5-111 5-112 5-113 5-114 ------- FIGURES (continued) Number Page 6.1.1 Worksheet for evaluating the adequacy of the listing of hazardous wastes for existing surface impoundments . . . 6-3 6.1.2 Worksheet for evaluating Che adequacy of :he lijciag JE hazardous wastes for new surface impoundments 6-9 6.2.1 Applicability of Part 264 regulations to surface impoundment liners .... b-13 6.2.2 Evaluation of proposed liner systems 6-16 6.2.3 Permeability of four clay soils to standard aqueous penneant 6-33 6.2.4 Relationship between permeability, density, and moisture content for an idealized clay soil 6-41 6.2.5 Worksheet for evaluation of liner location with respect to water table 6-47 6.2.6 Worksheet for evaluation of synthetic liners 6-48 6.2.7 Worksheet for evaluation of clay liners 6-51 6.2.8 Worksheet for evaluation of admixed liners 6-54 6.2.9 Worksheet for evaluation of foundation design and integrity 6-56 6.2.10 Worksheet for determining the adequacy of the applicant's submittal for a liner system exemption 6-63 6.2.11 Applicability of Part 264 regulations to impoundment overtopping 6-65 6.2.12 Precipitation depth associated wich the 100-year, 24-hour storm 6-67 6.2.13 Worksheet for determination of the magnitude of the 100-year storm event 6-68 6.2.14 Solution of the SCS Runoff Equation 6-70 6.2.15 Worksheet for evaluating run-on volume computations .... 6-73 6.2.16 Worksheet to evaluate adequacy of applicant's plans to prevent overtopping 6-75 xi ------- FIGURES (continued) Number Page 6.2.17 Evaluation of structural integrity of dikes 6-80 6.2.18 Worksheet for evaluating adequacy of dike design, construction, and naintanance 6-84 6.2.19 Applicability of Part 264 requirements to the subpart F exemption 6-38 6.2.20 Worksheet for determining adequacy of applicant's submittal for an exemption from Subpart F requirements 6-90 6.3.1 Standards applicable to surface impoundment inspection during installation 6-94 6.3.2 Worksheet for determining the adequacy of general inspection information 6-96 6.3.3 Inspection of liner and cover system materials before and during installation 6-97 6.3.4 Worksheet for determining the adeauacy of inspection procedures before and during installation 6-108 6.3.5 Inspection of syntnecic liners and covers after installation 6-113 6.3.6 Inspection of soil-based and admixed liners and covers after installation : 6-115 6.3.7 Moisture-density curve of a cohesive soil 6-117 6.3.8 Worksheet for determining the adequacy of inspection procedures after installation 6-112 6.3.9 Systems or conditions to be inspected weekly and after storms 6-125 6.3.10 Worksheet for determining the adequacy of weekly and after storm inspection procedures ... 6-129 6.5.1 Worksheet for evaluating the applicant's contingency plan for removinz nhe surface impoundment from service . , . . 6-139 6.6.1 Applicability zz reguiac; -quirements to closure of surface impoundments 6-142 6.6.2 Key steps in storage impoundment closure 6-145 xii ------- FIGURES (con Number 6.6.3 Worksheet to evaluate the adequacy of the proposed storage impoundment closure plan ................ 6-148 '.:apounaraenc -ioaure ......... 6-151 6.6.5 Worksheet for evaluating the adequacy of the applicant's closure plan for disposal impoundments ......... 6-155 7.1.1 Worksheet for evaluating the adequacy of the listing of hazardous wastes for existing waste piles ........ 7-7 7.1.2 Worksheet for evaluating the adequacy of the listing of hazardous wastes for new waste piles .......... 7-3 7.2.1 Aoplicability of Part 264 requirements to obtaining an exemption from the liner standard and ground water protection requirements ................. 7-10 7.2.2 Worksheet for evaluation of an application for exemption from liner standard (§264.251) and Subpart F requirements ..... . ............ , , . . 7-13 7.3.1 Applicability of Part 264 requirements to liner design . . '-20 7.3.2 Evaluation of proposed liner system ............ 7-21 7.3.3 Permeability of four clay soils to standard aqueous permeant ........................ 7-23 7.3.4 Relationships between permeability, density, and moisture content for an idealized clay joii ........... 7-32 7.3.5 Worksheet for evaluation of liner location with respect to water table ....................... 7-39 7.3.6 Worksheet for evaluating clay liners ........... 7-40 7.3.7 Worksheet for evaluating admixed liners .......... 7-43 7.3.3 Worksheet for evaluation of synthetic liners ....... 7-45 7.3.9 Worksheet for evaluation of foundation design and integrity ........................ 7-43 7.3.10 Applicability of Part 264 requirements to leachate collection and removal systems ............. 7-53 xiii ------- FIGURES (continued) Number Page 7.3.LL Evaluation of leachate collection and removal system -> T i -. 7.3.13 7.3.14 7.3. 15 7.3.16 7 • 3 • I 7 7. 3. IS 7.3.19 7.3.20 7.3.21 7.3.22 7.3.23 7.3.24 7.3.25 7.3.25 7.3.27 7.3.28 7.3.29 Mtarr.ar. i-'-e -iraincaa svsca^ ^rian'-aLions considered Ln Typical hazardous waste pile profile simulated using HELP Trench condition — bioe load coefficient . Worksheet cor calculation of load bearing capacity of Illustration of prevention of piping bv graded filters . . Worksheet to determine adequacy of design of drainage Worksheet for determining the adequacy of filter fabrics Worksheet for determining the adequacy of pipe perforation Worksheet for evaluating a submittal for a liner and Regulations applicable to the control of run-on and Technical topics addressed EOT run—on control Worksheet for determination of the magnitude of the 25-year storm event for evaluation of run-on control . . Solution of the SCS run-off eauation . 7-56 7-58 7-61 7-67 7-71 7-72 7-82 7-86 7-89 7-91 7-92 7-95 7-102 7-105 7-106 7-108 7-111 7-113 xiv ------- FIGURES (continued) Number Page 7.3.30 Worksheet for evaluation of calculated peak run-on discharge rate 7-116 7.3.31 Technical issues associated wich run-off concrol 7-119 7.3.32 24-hour, 25-year rainfall event (inches) 7-120 7,3.33 Worksheet for ivaluacing che .aagnicuae of che selected storm event 7-121 7.3.34 Worksheet for evaluating run-off volume computations . . . 7-123 7.3.35 Worksheet for determining che adequacy of the applicant's plan to manage units associated with run-on and run-off control . 7-128 7.3.36 Regulations applicable to the control of wind dispersal of particulate matter at waste piles 7-130 7.3.37 Evaluation of proposed wind dispersal control system . . . 7-131 7.3.33 Worksheet for evaluating the adequacy of wind dispersal control measures 7-133 7.3.39 Standards applicable to Subpart F exemption 7-136 7.3.40 Worksheet for evaluation of the adequacy of applicant's submittal for an exemption from Subpart F based on installation of a double-lined pile 7-137 7.3.41 Worksheet for evaluation of che adequacy of the applicant's submittal for an exemption from Subpart F based on inspection of the liner 7-141 7.4.1 Standards applicable to waste pile inspection 7-144 7.4.2 Worksheet for determining the adequacy of the applicant's inspection plan 7-147 7.4.3 Inspection of liner and cover system materials before and during installation 7-148 7.4.4 Worksheet for determining the adequacy of inspection procedures before and during installation 7-159 7.4.5 Inspection of synthetic liners and covers after installation 7-164 ------- FIGURES (continued) Number page 7.4.6 Inspection of soil-based and admixed liners and covers after installation 7-166 7.4.7 Moisture-density curve of a cohesive soil 7-168 7.4.8 Plasticity chart 7-170 7.4.9 Worksheet for determining the adequacy of inspection procedures after liner installation 7-174 7.4.10 Inspections weekly and after storms 7-176 7.4.11 Worksheet for determining Che adequacy of the applicant's plan for inspection during operation 7-180 7.5.1 Applicability of regulations to treatment of Che waste pile 7-184 7.6.1 Applicability of regulations to management of ignitable and reactive wastes 7-188 7.6.2 Flow diagram for evaluating the technical adequacy of the application for -nanageraent of ignitable or reactive waste 7-192 7.5.3 Worksheet for evaluating the-applicant's subraittal on ignitable and reactive waste identification ...'.... 7-199 7.6.4 Worksheet for evaluating ignitable and reactive waste treatment procedures 7-204 7.6.5 Worksheet for evaluating management of ignitable or reactive wastes in containers 7-206 7.7.1 Applicability of regulations to incompatible wastes .... 7-210 7.7.2 Flow diagram for assessing the compatibility of hazardous wastes using procedures specified in EPA-600/6-80-076 . . 7-215 7.7.3 Worksheet for determination of hazardous waste compatibility 7-217 7.7.4 Hazardous waste compatibility chart 7-218 7.7.5 Worksheet for evaluating management procedures for incompatible wastes 7-221 xvi ------- TTC'JRES ' continue a) lumber Page 7.8.1 Applicability of regulations Co waste pile closure .... 7-224 7.8.2 Worksheet for evaluating waste pile closure procedures . . 7-226 8.1.1 Worksheet for evaluating the adequacy of listing hazardous wastes and constituents being or to be land treated at existing facilities 8-21 3.1.2 Worksheet for evaluating Che adequacy of listing hazardous wastes and constituents Co be land treated at new facilities 8-22 8.1.3 Worksheet for items to be simulated by treatment demonstration cests/evaluacion 8-25 3.1.4 Decision -hart co determine creatability of hazardous organic constituents—based on soil rsspiration studies 8-44 3.1.5 Effect of creatraent frequency on Che evolution of CO? from Norwood soil amended with petrochemical sludge and incubated cor 130 aays at 30°C and 18 percent moisture 3-45 8.1.6 Worksheet for evaluating the adequacy of field tests for demonstrating hazardous constituent treatment 8-48 8.1.7 Effect of resting time before tilling on emissions after subsurface injection , . , 8-52 8.2.1 Components of the land treatment program 8-75 8.2.2 Worksheet for evaluating completeness of description of wastes for land creaCment program 8-76 8.2.3 Worksheet for assessing completeness of applicant's waste application rate and methods 8-80 8.2.4 Estimated storage days based only on climatic factors . . . 3-82 8.2.5 Relationship between soil cexture and che amount of limestone required Co raise Che pH of New York soils to 7.0 8-90 8.2.6 Worksheet for evaluating applicant's unsaturated zone monitoring plan 8-97 xvii ------- FIGURES (continued) Number Page 8.2.7 General relationship between soil particle size and minerals content 8-107 8.2.8 Atterberg limits 8-110 3.3.1 Worksheet for determination of the magnitude of the 25-year storm event 3-123 o.J.2 Typical intensity-duration-frequency curves 8-126 8.3.3 Solution of the SCS runoff equation 8-128 8.3.4 Worksheet for determination of peak run-on discharge rate for evaluation of run-on control 8-131 3.3.5 Technical issues associated with run-off control 8-134 8.3.6 24-hour, 25-year rainfall event (inches) 8-135 8.3.7 Worksheet for evaluating the magnitude of the selected storm event 3-136 8.3.8 Worksheet for evaluating run-off volume computations . . . 8-138 8.3.9 Worksheet for evaluating management of unit's run-on and run-off control systems . -» 8-141 8.3.10 Worksheet for evaluating wind dispersal control measures . 8-143 3.3.11 Worksheet for evaluating the applicant's inspection program 8-145 8.4.1 Worksheet to evaluate similarities of conditions under which food-chain crop demonstrations are made 8-160 8.4.2 Worksheet to assess food-chain crop demonstration made by greenhouse tests .......... 8-161 8.4.3 Worksheet to assess food-chain crop demonstration made by field teats . , 8-162 8.4.4 Worksheet for evaluating adequacy of permit application where waste(s) containing cadmium will be or are being treated 8-164 8.6.1 Flow diagram for evaluating the technical adequacy of the application for disposal of ignitable or reactive waste 3-180 xviii ------- FIGURES (continued) Number Pa ge 8.6.2 Worksheet to evaluate applicant's plan for handling ignitable or reactive wastes 8-192 8.7.1 Flow diagram for assessing the comoatibilitv of hazardous vasce anir.g prccadaraa specified in A Method for Determining che Compatibility of Hazardous Wastes .... 8-201 8.7.2 Worksheet for determination of hazardous vasta ^spauij! ::_•:•/ 8-202 8.7.3 Hazardous waste compatibility chart 8-204 8.7.4 Worksheet for evaluating applicant's submittal for meeting special requirements for incompatible wastes 8-207 9.1.1 Worksheet for evaluating the adequacy of Che listing of hazardous wastes for existing facilities 9-7 9.1.2 Worksheet for evaluating the adequacy of the listing of hazardous wastes for new facilities 9-8 9.2.1 Applicability of Part 264 requirements co iiner systems . . 9-14 9.2.2 Evaluation of proposed liner systems 9-15 9.2.3 Land subsidence in the Tular-e-Wasco area, California, 1926- 1962, due to withdrawal of ground water 9-34 9.2.4 Example soil grain size analysis 9-39 9.2.5 Soil classification based on grain size 9-40 9.2.6 Atterberg limits 9-42 9.2.7 Casagrande's plasticity chart showing several representative soil types 9-44 9.2.8 Calculation of settlement from the phase diagram 9-47 9.2.9 Profile of distortion settlement of a uniformly loaded flexible foundation on an elastic solid such as a saturated clay 9-49 9.2.10 Profile of distortion settlement of a uniformly loaded flexible foundation on a cohesionless soil 9-49 9.2.11 Worksheet for evaluating design of liner system 9-51 xix ------- FIGURES (continued) Number Page 9.2.12 Applicability of Part 264 requirements Co leachate collection and removal systems 9-62 . 9.2.13 Evaluation of leachata collection and removal jy3tam design 9-63 9.2.14 Alternative drainage system orientations considered in solving for maximum leachara depth ..... 9-66 9.2.15 Relationship between h /L and c 3 e/k 9-67 max 3 9.2.16 Hazardous waste landfill profile simulated using HELP . . . 9-70 9.2.17 Pipe installation - conditions and loading 9-76 9.2.13 Trench condition - pipe load coefficient 9-80 9.2.19 Projecting condition - pipe load coefficient 9-81 9.2.20 Worksheet for calculation of load bearing capacity of underground leachate collection system piping 9-91 9.2.21 Illustration of prevention of piping by graded filters . . 9-95 9.2.22 Worksheet CO determine adequacy of design of drainage and filter layers .... - 9-98 9.2.23 Worksheet for determining the adequacy of filter fabrics proposed by the applicant 9-100 9.2.24 Worksheet for determining tha adequacy of pipe perforation or sloe design 9-101 9.2.25 General purpose nozzle and penetrator nozzle 9-103 9.2.26 Worksheet for determining the adequacy of the applicant's submittal for a liner and leachate collection system exemption 9-111 9.2.27 Regulations applicable to the control of run-on and run- off at hazardous waste landfills 9-114 9.2.28 Technical topics addressed for run-on control 9-115 9.2.29 Worksheet for determination of the magnitude of the 25- year storm event for evaluation of run-on control .... 9-117 xx ------- FIGURES Ccontinued? Number Page 9.2.30 Typical intensity-duration-frequency curves 9-120 9.2.31 Solution of the SCS run-off equation 9-122 9.2.32 Worksheet cor evaluation of calculated peak run-on discharge rate 9-125 9.2.33 Technical issues associated with -vr.-^rf control 9-128 9.2.34 24-hour, 25-year rainfall event (inches) 9-129 9.2.35 Worksheet for evaluating the magnitude of the selected storm event 9-130 9.2.36 Worksheet for evaluating run-off volume computations . . . 9-132 9.2.37 Worksheet for determining the adequacy of the applicant's plan to manage units associated *ith run-on and run-off control 9-137 9.2.38 Regulations applicable to the control of wind disoersal of particulate matter at hazardous *aste landfills 9-139 9.2.39 Wind dispersal control options 9-140 9.2.40 Worksheet for evaluating the-adequacy of wind dispersal control measures 9-141 9.2.41 Applicability of Part 264 requirements Co Che Subpart F exemption 9-144 9.2.42 Worksheet for determining adequacy of applicant's submittal for an exemption from Subpart F 9-146 9.3.1 Standards applicable to landfill inspection 9-149 9.3.2 Worksheet for determining the adequacy of general inspection information 9-151 9.3.3 Inspection of liner and cover system -natarials before and during installation 9-152 9.3.4 Worksheet for determining the adequacy of inspection procedures before and during installation 9-163 9.3.5 Inspection of synthetic liners and covers after installation 9-169 xxi ------- FIGURES ("continued) Number Page 9.3.6 Inspection of soil-based and admixed liners and covers after installation 9-171 9.3.7 Moisture-density curve of a cohesive soil .... .... 9-172 9.3.3 Plasticity chart 9-174 9.3.9 Worksheet for determining the adequacy ^f Inspection procedures alter installation 9-178 9.3.10 Inspections weekly and after storms 9-180 9.3.11 Worksheet for determining the adequacy of weekly and after storm inspection procedures 9-134 9.4.1 Regulations applicable co closure of hazardous waste landfills 9-190 9.4.2 Examine background data 9-191 9.4.3 Characterize the cover system 9-192 9.4.4 Evaluate post-closure plan 9-193 9.4.5 Worksheet for evaluating closure and post-closure procedures . ~. 9-198 9.5.1 Applicability of regulations to handling and disposal of ignitabie and reactive wastes 9-205 9.5.2 Flow diagram for evaluating the Technical adequacy or the application for disposal of ignitabie or reactive waste 9-210 9.5.3 Worksheet for evaluating the applicant's aubmittal on ignitabie and reactive waste identification 9-217 9.5.4 Worksheet for evaluating ignitabie and reactive waste treatment procedures 9-222 9.5.5 Worksheet for evaluating disposal procedures for containerized ignitabie wastes 9-226 9.6.1 Regulations applicable to handling and disposal of incompatible wastes at landfills 9-230 xxii ------- FIGURES (continued) Number Page 9.6.2 Flow diagram for assessing Che compatibility of hazardous wastes using procedures specified in EPA-600/2-80-076 . . 9-235 9.6.3 Worksheet for determination -£ hazardous waste . . ........ .... ........ 9-236 9.6.4 Hazardous waste compatibility chart .......... . . 9-238 9-6.5 Worksneec tor evaluating disposal procedures for incompatible wastes ................... 9-240 9.7.1 Regulations applicable to management of liquid wastes at landfills ........................ 9-244 9.7.2 Assessment jf cechnicai adequacy of the applicant '3 plans 9.7.3 9.3.1 9.3.2 9.3.3 Worksheet for evaluating disposal procedures for liquid Applicability of regulations for containers ... Technical aspects of container disposal in landfills . . • Worksheet for evaluating disposal' procedures for containers and lab Backs ~. 9-261 9-267 9-270 9-276 xxiii ------- TABLES Number Page 2.1 The RCRA Table of Contancs 2-2 2.2 Parts of Title 40 of Che CFR Regarding Permitting and Hazardous Waste Handling and Disposal 2-5 3.3.1 Checklist of Documents to Include in Administrative Record 3-18 e •> Water Analysis Summary Report 5-8 5.10.1 Technical Adequacy Checklist 5-116 6.2-i Effects of Exposure on Selected Polymeric Membrane Liners in Water Containing a Low Concentration }f a Dissolved Organic Chemical cor 17.2 Months 6-21 6.2.2 Chemical Resistivity or Synthetic Liner Materials ..... 6-22 6.2.3 Synthetic Liner-Industrial Waste Compatibilities 6-24 6.2.4 Relative Membrane Liner Permeability Based on Testing with Hazardous Wastes 6-27 6.2.5 Failure Catagoriss 6-28 6.2.6 Polymeric Membrane Liner Resistance to Natural Elements 6-32 6.2.7 Swell Potential Versus Atterberg Limit Values in Three Clay Soils 6-36 6.2.8 Resistivity of Clay-Soil Liner Material to Specific Chemical Compounds 6-38 6.2.9 Admixed Liner Industrial Waste Compatibilities 6-43 6.2.10 Runoff Curve Numbers for Hydrologic Soil-Cover Complexes 6-71 6.2.11 Representative Values of Manning's Roughness Coefficient 6-74 xxiv ------- 7AI2Lw3 .ccmtinuea; Number Page 6.3.1 Equivalence of Liner and Cover System Layers in 6.6.1 6.9.1 7.3.1 7.3.2 7.3.3 7.3.4 7.3.5 7.3.6 7.3.7 7.3.3 7.3.9 7.3.10 7.3.11 7.3.12 7.3.13 7.4.1 7.6.1 7.6.2 7.6.3 7.9.1 Compatibility of Selected Waste Categories with Different Waste Solidification/Stabilization Techniaues Technical Adequacy Checklist Swell Potential Versus Atterberg Limit 'Mines in Three Clay Soils Resistivity of Clay-Soil Liner Material to Specific Chemical Compounds Admixed Liner Industrial Waste Compatibilities Chemical Resistance of Plastics Used for Piping Trench Transition Widths for 6- and 8-Inch Diameter Pipes Installed in Sand and Gravel ... Minimum Crushing Strength (3-Edge Bearing Strength .... Maximum Long-Term Deflection of F/AY 46 psi PVC Values of Load Coef f icients ,- Cg , for Concentrated Loads Vertically Centered Over Conduit Percentge of Wheel Loads Transmitted to Underground Pipes Values of Run-Off Coefficient, C Retardance Coefficient, Cr Run-Off Curve Numbers for Hydrologic Soil-Cover Complexes . Representative Values of Manning's Roughness Coefficient Equivalence of Liner and Cover System Layers in Consideration of Inspection Requirements Igni table Wastes Reactive Wastes Technical Adequacy Checklist U 77 3-153 6-166 7-27 7-28 7-34 7-65 7-68 7-74 7-77 7-79 7-30 7-110 7-110 7-114 7-125 7-150 7-193 7-196 7-200 7-229 XXV ------- TABLES <,continued) Number 3.1.1 Example Format for Listing Wastes that will be Treated in 8.1.2 8.1.3 8.1.4 8.1.5 8.1.6 8.1.7 3.1.8 8.1.9 8.1.10 8.1.11 8.1.12 8.1.13 8.1.14 8.1.15 8.1.16 3.1.17 8.1.18 General Information to be Included in Field Test Descriptions Required Information for Treatment Demonstration ' Treatment of Hazardous Constituents by Land Treatment Processes Qualitative Assessment of Che Land Treatability of Hazardous Material Groups Sources of Industrial Hazardous Waste Streams Industry Groups Currantly Operating Hazardous Waste Land Treatment Units List of Pertinent Nonhazardous Constituents or Substances Utility of Data Sources for Making Treatment Demonstration . Key Land Treatment Reference Sources Test Methods for Assessing Specific Waste-Site Interactions ......... Suggested Soil Parameters to Monitor Prior to and After Waste Application Interpretation of Soil Chemical Tests Suitability of Various Textured Soils for Land Treatment of Hazardous Industrial Wastes Example Hazardous Waste and Hazardous Constituent Pre treatment Methods for Hazardous Wastes Rates of Degradation of Phenol and Phenolic Compounds . . . Response of Soil Microbial Populations to Application of o / 8-10 8-15 8-16 8-16 3-i3 3-19 8-20 3-24 3-27 3-30 3-32 . 8-33 8-34 8-35 8-36 8-40 8-41 8.1.19 Response of Soil Microbial Populations to Application of Various Alcohols 8-41 xxvi ------- TABLES (continued) Number Page 8.1.20 Decomposition of Carboxylic Acids in Soils ......... 3-42 8.1.21 Percent Degradation After 10, 20, and 30 Years for Organic Constituents with Various Half-Lives in Soil ....... 3-47 3.1.22 Optimum Values of Selected Soil Factors for 3iodegradation . 8-47 8.1.23 Matrix of Experimental Conditions for Land Treatment Simulation 3an . ................. 8-54 8.1.24 Relative Ranking of Chemicals Potentially Released from Hazardous Waste Treatment, Storage, and Disposal Facilities by Vapor Hazard Ratio .................. 8-55 8.2.1 Format for Reporting Application, Rate, and Capacity Limiting Constituents .................. 3-68 8.2.2 Format for Identifying Limiting Constituents ........ 8-68 8.2.3 Example Waste Application Schedule ............. 8-70 8.2.4 Format for Reporting the Results of Soil Sampling and Analysis ...................... ... 8-73 8.2.5 Waste Components :o be Compared in Determining Application, Rate, and Capacity Limitin-g Constituents ......... 8-77 3.2.6 Computation of Number of Applications Per Year Based on Organic Constituent Degradation ............. 8-78 3.2.7 Advantages and Disadvantages of Various Systems of Waste Application ... .................... 8-81 3.2.3 Summary of Land Treatment Experiences in the Hydrocarbon Processing Industry ................... 8-83 3.2.9 Alternative Management Techniques to Replace the Role of Crop Cover in a Land Treatment System .......... 8-86 3.2.10 Normal Range and Toxic Concentration of Trace Elements in Plants ........................ 8-87 8.2.11 Some Organics that Become Acidic When Wet ......... 8-92 3.2.12 Suggested Unsaturated Zone Monitoring Sampling Scheme . . . 3-99 8.2.13 Examples of Possible Responses to the Detection of Hazardous Constituent Migration ............. 8-100 xxvii ------- TABLES (continued) Number Paze 8.2.14 8.2.15 8.2.16 8.2.17 8.2.18 8.2.19 8.3.1 3.3.2 3.3.3 3.3,4 8.4.1 8.4.2 8.6.1 8.6.2 3.6.3 8.7.1 8.8.1 9.2.1 9.2.2 9.2.3 9.2.4 Example of Soil Characteristics to be Included in Applicant's Treatment Zone Description Temperature and Precipitation Data ....... ..... Freeze Dates in Spring and Fall Growing Season Length United States Department of Agriculture (USDA) Soil Textures Interpretation of Soil Chemical Tests Values of Run-Off Coefficient, C Retardance Coefficient, C r Runoff Curve Numbers for Hydrologic Soil-Sover Complexes . . Representative Values of n, Manning's Roughness Coefficient . . , . Example Cadmium Loading Rate Table Plant Uptake and Translocatiun of Pesticides from Soils . . Ignitable Wastes Overview of Hazardous Waste Treatment Processes Listing of Known Incompatible Waste or Waste Components . . Technical Adequacy Checklist for Reviewing Part B Land Treatment Permit Applications Effects of Exposure on Selected Polymeric Membrane Liners in Water Containing a Low Concentration of a Dissolved Organic Chemical for 17.2 Months ... Chemical Resistivity of Synthetic Liner Materials Synthetic Liner- Indus trial Waste Compatibilities Relative Membrane Liner Permeability Based on Testing with Hazardous Wastes 3-103 Q 1 f* ', j I. -* -» 8-105 2-106 8-109 8-112 3-125 3-125 3-129 8-139 3-156 3-159 8-182 8-185 8-137 8-197 8-210 9-19 9-21 9-22 9-25 xxviii ------- TABLES Number 9.2.5 9.2.6 9.2.7 9.2.3 9.2.9 9.2.10 9.2.11 9.2.12 9.2.13 9.2.14 9.2.15 9.2.16 9.3.1 9.4.1 9.5.1 9.5.2 9.5.3 9.7.1 . 9.7.2 9.7.3 9.9.1 Failure Categories Polymeric Membrane Liner Resistance to Natural Elements . . Chemical Resistance of Plastics Used for Piping Transition Widths for 6-Inch and 8-Inch Pipe Installed in Sand and Gravel Minimum Crushing Strength . . „ Maximum Long-term Deflection of F/AY 46 psi PVC Values of Load Coefficients, C3 , for Concentrated Loads Vertically Centered Over Conduit Percentage of Wheel Loads Transmitted Co Underground Pipes . Values of Run-Off Coefficient, C Retardance Coefficient, C,. Run-Off Curve Numbers for Hydrologic Soil-Cover Complexes Representative Values for Manning's Roughness Coefficient Equivalence of Liner and Cover System Layers in Consideration of Inspection Requirements Cover Material General Performance Criteria Evaluation . . • Ignitable Wastes Reactive Wastes Overview of Hazardous Waste Treatment Processes Compatibility of Selected Waste Categories with Different Waste Solidification/Stabilization Techniques Present and Projected Economic Considerations for Waste Stabilization/Solidification Systems Compatibility of Hazardous Liquids and Selected Sorbent Materials Technical Adequacy Checklist RCRA Permit Application Completeness Checklists for Parts A & B 9-26 9-30 O-7/i 9-77 9-83 9-86 9-88 9-39 9-119 9-119 9-123 9-133 9-154 9-196 9-212 9-215 9-218 9-250 9-255 9-259 9-280 10-2 XXIX ------- SECTION 8.0 LAND TREATMENT This Section presents guidance on evaluating application information submitted 'in support of the Land rreairraenc Taciiicy standards specified in Subpart M of Part 26*. -The federal requirements are reproduced and the application information requested by the Part B Permit Applicants' manual is summarized. This Section is subdivided into the following seven major subject areas: 8.1 Treatment Demonstration 8.2 Land Treatment Program 8.3 Design and Operating Requirements 8.4 Food-Chain Crop Requirements 8.5 Closure and Post-Closura Cara 8.6 Special Requirements for Ignitable or Reactive Wastes 8.7 Special Requirements for Incompatible Wastes A Technical Adequacy Checklist is provided at the end of the Section in subsection 8.8. References cited in each of the first seven suosections are listed at the end of the subsections. The information requirements of §270.20 are reprinted* below to provide an overview of the issues to be considered in reviewing a land treatment permit application. §270.20 Specific Part B Information Requirements for Land Treatment Facilities "Except as otherwise provided in §264.1, owners and operators of facilities that use land treatment to dispose of hazardous waste muse provide the following additional information: (a) A description of plans to conduct a treatment demonstration as required under §264.272. The description must include the following information: *A11 regulatory citations are reproduced or quoted from Che Federal Register. 8-1 ------- (1) The wastes for which Che demonstracion will be -iade and the potential aazaraous constituents in the waste; (2) The data sourcas Co be used co raaKe cne demonstration (e.g., literature, laboratory data, field data, or operating data); (3) Any specific laboratory or field test chat will be conducted, including: (i) The type of test (e.g., column leaching, degradation); (ii) Materials and methods, including analytical orocadures ; 'iii) "ixpect^d time 2o~ oorapietion; (iv) Characteristics of the unit that will be simulated in the demonstration, including treatment zone characteristics, climatic conditions, and operating practices. Cb) \ ^ascription Df a land creacmenc program, as required under §264,271. This information must be submitted with the plans for the treatment demonstration, and updated following the treatment demonstration. The land treatment program must address the following items: (1) The wastes to be land treated; (2) Design measures and operating practices necessary to maximize treatment in accordance with ^264.273(a) Including: (i) Waste application method and rate; (ii) Measures to control soil pH; (iii) Enhancement of caicrobial or chemical reactions; (iv) Control of moisture content; (3) Provisions for unsaturated zone monitoring, including: (i) Sampling equipment, procedures, and frequency; (ii) Procedures for selecting sampling locations; (iii) Analytical procedures; (iv) Chain of custody control; (v) Procedures for establishing background values; (vi) Statistical methods for interpreting results; (vii) The justification for any hazardous constituents recommended for selection as principal hazardous constituents, in accordance with Che criteria for such selection in §264.278(a); (4) A list of hazardous constituents reasonably expected to be in, or derived from, the wastes to be land created based on waste analysis performed pursuant to §264.13; (5) The proposed dimensions of the treatment zone; (c) A description of how the unit is or will be designed, constructed, operated, and maintained in order to meet the requirements of §264.273. This submission must address the following items: (1) Control of run-on; (2) Collection and control of run-off; (3) Minimization of run-off of hazardous constituents from the treatment zone; (4) Management of collection and holding facilities associated with run-on and run-off control systems; (5) Periodic inspection of the unit. This information should be included in the inspection plan submitted under §270.14(b)(5); (6) Control of wind dispersal of particulate matter, if applicable; 8-2 ------- (d) If f3od-chain crops are Co be grown in or on the treatment zone of the land treatment unit, a description of how che demonstration required under §264.276(a) will be conducted including (1) Characteristics jf Che rood-chain crop for which the demonstration will be made. (2)' Characteristics of the waste, treatment zone, and waste application method and rate to be used in the demonstration; (3) Procedures for crop growth, sample collection, sample analysis, and data evaluation; (4) Characteristics of the comparison crop including the location and conditions under which it was or will be grown; (e) If food-chain crops are to be grown, and cadmium is present in the land-treated waste, a description cz how che retirements jf ! 254. ,:76(b,) will be complied with; (f) A description of the vegetative cover to be applied to closed portions of the facility, and a plan for maintaining such cover during the post-closure care period, as required under §264.280(a)(8) and §264.280(c)(2). This information should be included in the closure plan and, where applicable, the post-closure care plan submitted under § 270.14(b)(13); (g) If ignitable or reactive vastes vill be placed in or on the treatment zone, an explanation of how the requirements of §264.281 will be complied with; (h) If incompatible wastes, or incompatible wastes and materials, will be placad in or on the same treatment zone, an explanation of how §264.282 will be complied with." In using this manual to evaluate permit applications it is important to recognize that the recommended specifications and techniques presented are guidance, not regulations. During che permitting process there will be considerable negotiation to determine best facility design and operating practices for a subject land treatment unit. Owners and operators may design and/or operate their facilities differently than the methods recommended herein, which is acceptable as long as sufficient information is presented in the permit application to demonstrate compliance with specified performance requirements. 3.1 TREATMENT DEMONSTRATION 8.1.1 Federal Requirement Plans for conducting a treatment demonstration and presenting complete demonstration results, unless applying for a two-phase permit, must be included in the Part B permit application for facilities that use land treatment to dispose of hazardous waste. Section 270.20(a) states that the Part B application must include: "(a) A description of plans to conduct a treatment demonstration as required under §264.272. The description must include the following information: (1) The wastes for which the demonstration will be made and the potential hazardous constituents in the waste; 8-3 ------- (2/ The data sourcas ".o b^ u^ed :j .ISK.& cne aemonscration (e.g., Literature, laboratory data, field data, or operating data); (3) Any specific laboratory or field test that will be conducted, including: (i) The type of test (e.g., column caching, degradation); (ii) Materials and methods, including analytical procedures; (iii) Expected time for completion; (iv) Characteristics of the unit that will be simulated in the demonstration, including treatment zone characteristics, climatic conditions, and ooerating prscticas." Applicants who use existing available data to complete the treatment demonstration or who are issued short-term demonstration permits must submit the demonstration results with rhe ?art 3 porai; application. Applicants who are issued a two-phase permit are required to submit the demonstration results upon completion of testing. The following discussion addresses short-terra and two-phase permits. The technical standards of Part 264 for the treatment demonstration, covered under §264.272(a), (b), and (c), are as follows: "(a) ?or each waste chat will be applied to the treatment zone, the owner or operator must demonstrate, prior to application of the waste, chat Hazardous constituents in the waste can be completely degraded, transformed, or immobilized in :he treatment zone. (b)- In making this demonstration, the owner or operator may use field tests, laboratory analyses, available data, or, in the case of existing units, operating data. If the owner or operator intends to conduct field tests or laboratory analyses in order to make the demonstration required under paragraph (a) of this section, he must obtain a treatment or disposal permit under §270.63. The Regional Administrator will specify in this permit the testing, analytical, design, and operating requirements (including the duration of the tests and analyses, and, in Che case of field tests, the horizontal and vertical dimensions of the treatment zone, monitoring procedures, closure and clean-up activities) necessary to meet the requirements in paragraph (c) of this section. (c) Any field test or laboratory analysis conducted in order to make a demonstration under paragraph (a) of this section must: (1) Accurately simulate the characteristics and operating conditions for the proposed land treatment unit including: (i) The characteristics of the waste (including the presence of Appendix VIII of Part 261 of this chapter constituents); (ii) The climate in the area; (iii) The topography of the surrounding area; (iv) The characteristics of the soil in the treatment zone (including depth); and (v) The operating practices to be used at the unit. (2) Be likely to show that hazardous constituents in the waste to be tested will be completely degraded, transformed, or immobilized in the treeatment zone of the proposed land treatment unit; and 8-4 ------- (3) 3e conducted in a manner thic procects auman health and -he environment considering: (i) The characteristic.' of ;he waste Co be tested; (ii) The operating and monitoring measures :a*en during the course jf che cesc; (iii) The duration of the test; (iv) The volume of waste used in the test; (v) In the case of field tests, the potential for migration of hazardous constituents to ground water or surface water." When the applicant intends to conduct field or laboratory analyses to make the treatment demonstration, the owner or operator must first obtain a treatment or disposal permit. Under such conditions, a short-term Detroit covering only field testing and/or laboratory insiyses .oay be issued, or a two-phase facility permit may be issued covering the treatment demonstration and facility design, construction, operation, and maintenance. Section 270.63, presented below, defines the nature of these permits and the conditions under which they should be issued. Section 270.63, Permits for land treatment demonstrations using field test or laboratory analyses, states: "(a) For the purpose of allowing an owner or operator to meet the treatment demonstration requirements of §264.272 of this Chapter, the Director may issue a treatment demonstration permit. The permit must contain only those requirements necessary to meet the standards in §264.272(c). The permit may be issued either as a treatment or disposal perrai* covering only the fiej.d test or laboratory analyses, or as a.two-phase facility permit covering the field tests, or laboratory analyses, and design, construction, operation, and maintenance of the land treatment unit. (1) The Director may issue a two-phase facility permit if he finds that, based on information submitted in Part B of the application, substantial, although incomplete or inconclusive, information already exists upon which to base the issuance of a facility permit. (2) If the Director finds that not enough information exists upon which he can establish permit conditions to attempt to provide for compliance with all of the requirements of Subpart M, he must issue a treatment demonstration permit covering only the field test or laboratory analyses. (b) If the Director finds that a phased permit may be issued, he will establish, as requirements in the first phase of the facility permit, conditions for conducting the field tests or laboratory analyses. These permit conditions will include design and operating parameters (including the duration of the tests or analyses and, in the case of field tests, the horizontal and vertical dimensions of the treatment zone), monitoring procedures, post-demonstration clean-up activities, and any other conditions which the director finds may be necessary under §264.272(c). The Director will include conditions in the second phase of the facility permit to attempt to meet all Subpart M requirements pertaining to 8-5 ------- unit design, construction, operation, and maintenance. The Director will establish these conditions In cne second phase of the permit based upon the substantial but incomplete or inconclusive information contained in the Part 8 application. (1) The first phase of the permit will be effective as provided in §124.15(b) of this Chapter. (2) The second phase of the permit will be effective as provided in paragraph (d) of this Section. (c) When the owner or operator wno nas been issued a two-phase permit has completed the treatment demonstration, he must submit to the Director a certification, signed by a person authorized to sign a permit application or report under §270.11, that the field tests or laboratory analvses hav»>. K«en carried ouc in accordance with the conditions specified in phase one of the permit for conducting such tests or analyses. The owner or operator must also submit all data collected during the field tests or laboratory analyses within 90 days of completion of those testa or analyses unless the Director approves a later date. (d) If the Director determines that the results of che field tests or laboratory analyses meet the requirements of ?264,272 of this Chapter, he *iil .nodify tne second phase of the permit to incorporate any requirements necessary for operation of the facility in compliance with Part 264, Subpart M, of this Chapter, based upon the results of the field tests or laboratory analyses. (1) This permit modification may proceed as a minor modification under §270.42, provided any such change is minor, or otherwise will proceed as a modification under §270.41(a)(2). (2) If no modifications of the second phase of the permit are necessary, or if only minor modifications are necessary and have been made, che Director will give notice of his final decision to the permit applicant and to each person who submitted written comments on the phased permit or who requested notice of the final decision on the second phase of the permit. The second phase of the permit then will become effective as specified in §124.15(b). (3) If modifications under §270.41(a)(2) are necessary, the second phase of the permit will become effective only after chose modifications have been made." 8.1.2 Summary of Necessary Application Information The following summarizes the information to be submitted in the Part B permit application for land treatment facilities. Information requirements identified are those presented in EPA's Permit Applicants' Guidance Manual for Hazardous Waste Land Storage, Treatment, and Disposal Facilities.1 The applicant is required to submit a treatment demonstration plan that describes how hazardous constituents contained in or derived from wastes to be disposed of at the facility will be degraded, transformed, or immobilized in the treatment zone. This applies to both new and existing facilities. All treatment demonstrations should contain two components; a plan and the results. 3-6 ------- 3.1.2.1 Treatment Demonstration Plan— Items to be included in the plan .are: (1) description of wastes for treatment demonstration, (2) data sources to make demonstration, and (3) when used, a description of laboratory and field test designs. 8.1.2.1.1 Wastes for Treatment Demonstration Plan— Part 1 - The applicant must list the hazardous wastes that will be land treated. In addition, nonhazardous wastes that wi.il be applied ;o che same treatment ione or plot as che hazardous waste(s) should also be listed. The Permit Applicant's Guidance Manual recommends that wastes be listed in the format shown in Table 8.1.1. 2XAMPLS FORMAT FOR LISTING WASTES THAT WILL BE TREATED IN THE HWLT UNIT Name of waste Generating process :: source Monthly or annual quantity EPA hazardous waste ID number Oil/Water Separator Sludge Leaded Tank Bottoms Treated Wastewater Crude Topping Unit Leaded Gasoline Storage Refinery Wastewater Treatment Plant 50 m Ton /Mo 100 m Ton/Yr X051 K052 50,000 m Ton/Mo Nonhazardous Part 2 - List hazardous constituents (see Appendix VIII, Part 261) present in or expected to be derived from each hazardous waste to be land treated and pertinent nonhazardous constituents of wastes to be applied to same portion of the treatment zone. "Pertinent" nonhazardous constituents means any nonhazardous constituent that will likely affect the degradation, transformation, or immobilization of hazardous constituents. Part 3 - For each waste identified in Part 1 above, the following information should be included in the application: • concentration of each hazardous and pertinent nonhazardous constituent, • concentration of volatile hazardous constituents, • percent water content, • specific gravity or bulk density, 8-7 ------- • oH. • electrical conductivity, • total acidity or alkalinity, and • total organic carbon. 8.1.2.1.2 Data Sources for Treatment Demonstration—Published literature, laboratory studies, field c^sta, and existing operating data may be used to make the treatment demonstration. The applicant should explain which data source will be used to make the treatment demonstration and expected results. 8.1.2.1.3 Laboraco-^ and Tisid last design—If laboratory and/or field tests are used to make the treatment demonstration, the following information should be provided, respectively. Part 1 - An explanation covering the following information should be provided for each laboratory test performed: « name of test, • objective of test, • materials and methods, • schedule of completion, • list of experimental conditions, and • description of data reduction, analysis, and presentation. Part 2 - When field cests are to be used to make the treatment demonstration the applicant should prepare a written description containing the following: • objectives of test, • scale drawings delineating number and size of plots, • statistical design of the test(s), • dimensions of each plot treatment zone, • test plot preparation, • waste application rate and method on each plot, • irrigation methods and scheduling, • methods for establishing and maintaining vegetation (if vegetated), • meteorological data collection and recording techniques, 8-8 ------- • procedures cor ~oni^ori.;g JOI.L, son pore liquid, run-off, vegetacion, ground water, and ambient air, as applicable, • schedule of daily events and activities, • rationale for design and management of field tests, • expected test results and data presentation, and • clean-uo procedures apon completion of field tests. 8.1.2.2 Treatment Demonstration Results— Results obtained from the treatment demonstration should be submitted with the Part B oermit ^opllr.stion. Ihij Applies Co both single-phase and cwo-phase permits, with submittal of results upon completion of testing for the latter. 8.1.2.2.1 Wastes and Waste Composition—If wastes used in treatment demonstration differ from those submitted in treatment demonstration plan, the applicant should identify these wastes and provide physical and chemical char- acterizations of each. Pretreatment or mixing of vastas should also be noted. 8.1.2.2.2 Degradation/Trans formation—The applicant should provide the results of any literature review, existing operating data, laboratory tests, and/or field tests demonstrating the rate (time) and extent (percentage) of specific organic hazardous constituent and bulk organic fraction degradation. Part 1 - Review of existing literature - The applicant should provide a concise discussion of how data contained in the literature are appropriate to use to make the treatment demonstration. .lost important factors to be discussed are representativeness of data to proposed treatment facility. Part 2 - Existing Operating Data - Applicant should submit the following operating information as appropriate to make the treatment demonstration for the proposed new or existing land treatment facility: • description of existing facility, • operational records, • waste composition, • waste application rate and methods, and • data demonstrating degradation of hazardous constituents and/or bulk organics. Part 3 - Laboratory Test Results - Applicant should submit the following information when laboratory tests are used to demonstrate organic hazardous constituent degradation: • name of test, 8-9 ------- • ooiective of tast, • test methods and materials and experimental conditions, • test results (including visual presentations, i.e., graphs, figures, and tables), and • accompanying discussion to aid interpretation of results. Part 4 - Field Test Results - When field tests are conducted to demonstrate hazardous organic constituent or bulk organic degradation or transformation, the applicant should submit the following information: • obiectiv*» ^,nd tr.-^s t(_ ), • description of experimental design and procedures (applicant is directed to present information contained in Table 8.1.2), • test results (including visual presentations, i.e.., graphs, figures, and tables), and » accompanying discussion to aid interpretation of results. TABLE 8.1.2. GENERAL INFORMATION TO BE INCLUDED IN FIELD TEST DESCRIPTIONS Location of test plots relative to the land treatment ^nic. Number and size of test ploto. Dimensions of treatment zone for field test plots. Preparation of field test plots. Soil properties. Waste application rate on each plot. Method of waste application and- soil incorporation techniques. Irrigation methods and frequency. Rainfall and temperature data collected during the test. Sampling schedule and procedures. Analytical methods. Statistical methods. Photographs of test plots. 8.1.2.2.3 Immobilization—The applicant should submit results from any literature review, existing operating data, laboratory tests, and/or field studies that demonstrate organic (for persistent compounds) and inorganic hazardous constituent immobilization in the treatment zone. 8-10 ------- Part 1 - Review of existing literature - If the applicant elects to demonstrate constituent .immobilization using iaCs raported in the literature, a concise written analysis should be presented explaining ------- degradation, transformation, or immobilization. Because it can result in t release of untreated hazardous constituents, the extent of organic compound volatilization must be examined to verify actual constituent creatment. The applicant should submit the vapor pressure (mm of Hg) of each organic hazardous constituent present in the waste to be land treated. Estimates or test results of gaseous losses should be expressed as the mass or concentration of volatilized compound per unit area of soil as a function of time. Data sources for estimating volatilisation include published literature, existing operating data, laboratory tests, and field studies. Part 1- Published literature - If existing literature is used to estimate volatilization losses, the applicant should submit support materials, such as tables or figures, any calculations, description of assumptions and their rationale, and a discussion of data representativeness. Part 2 - Operating data - The applicant should submit the following when existing operating data are used to estimate hazardous constituent gaseous losses : • descriotion of the facility, • pertinent operational records, • waste composition, • waste application ratas, and • results of hazardous constituent volatilization. Part 3 - Laboratory tests - The following information should be provided in the application if laboratory tests are used to estimate hazardous constituent vaporization: • name of test, • test methods and materials, including experimental design, • test results, including visual presentation, i.e., graphs, figures, and tables, and • accompanying discussion, as needed, to interpret results Part 4 - Field tests - When field tests are conducted, the applicant should submit a description of the following information: • test objectives, • test methods and materials, including experimental design, • test results, including visual presentations, i.e., graphs, figures, and tables, and 8-12 ------- « accompanying discussion, as needed, Co interpret results. The information identified in Table 8.1.2 should be presented with the discussion on test procedures. 8.1.2.2.5 Toxicity— (a) Microbial Toxicity - Biological degradation and transformation are fundamental processes of the treatment facility. These processes are carried out by soil microbes. Microbial toxicity of the waste and hazardous constituents must be determined to assess the extent of waste treatment. If a waste is highly toxic to the microbial population, the waste will not be biodegraded unless it is applied to the soil at a rate below the Chresnold of toxic affects. Daca sources that can be used to determine raicrobial toxicity are published literature, existing operating data, laboratory tests, and/or field studies. Part 1 - Published literature - The applicant should submit an analysis of the scientific literature or previous studies that contain information concerning the toxicity of the waste or hazardous constituents to soil microbes. Part 2 - Existing operating data - For this data source, the applicant should provide the following: • a description of the existing facility, • operational records, • waste composition, • waste application rates, and • data assessing toxicity of the waste. Part 3 - Laboratory tests - The applicant should submit the following information when laboratory tests are conducted to evaluate microbial toxicity: • name of test, • test methods and materials, including experimental design, • test results, and • accompanying discussion, as needed, to interpret data. Part 4 - Field test - If field tests are conducted to determine whether the hazardous constituents of the waste will be toxic to soil microbes, the following information should be provided: • statement of test objective, 8-13 ------- « case rnetnods and macerials, including Che information identified in Table 8.1.2. and * tast results, including visual presentations, i.e., graphs, figures, and tables. (b) Phytotoxicity - If plants are to be grown on or in the treatment zone during its active life, the applicant should submit data addressing the phytotoxicity of nondegradable organics or immobilized inorganics to planted crops. Part 1 - Review of existing literature - A concise summary of the literature review, including a description of specific plant species grown, waste application races ana methods, waste composition, soil type, and test procedures should be submitted by the applicant. Part 2 - Existing operating data - For this data source, the applicant should provide the following information: • a description of che existing facility, • operational records, • waste application rates and methods, and • data assessing toxicity of the waste. .-arc 3 - Greenhouse test results - If greenhouse studies are conducted to assess phytotoxicity, the applicant should provide Che following: • test results (identifying concentrations causing a decrease in plant growth), • description of test methods and materials, • experimental design, • waste application rates and methods, • waste application schedule, and • plant species tested. Part 4 - Field test results - When field tests are performed to determine phytotoxic levels, test results identifying hazardous constituent concentrations that inhibit plant growth should be submitted. A description of the field test(s) addressing the issues identified in Table 8.1.2 should also be included in the written submittal, as well as a statement of test objectives and an accompanying discussion, as needed, to interpret test results. 8-14 ------- 8.L.3 Guidance on Evaluating Application Information The owner or operator of the land treatment unit must demonstrate that hazardous constituents in or derived from the waste(s) applied on or in the treatment zone soil will be completely degraded, transformed, or immobilized. Land treatment of the hazardous constituents relies on the dynamic physical, chemical, and biological processes occurring in the soil of the treatment zone. Table 8.1.3 identifies the components of the treatment demonstration that should be included in ""he ^arnit application. TABLE 8.1.3. REQUIRED INFORMATION FOR TREATMENT DEMONSTRATION Treatment demonstration plan Treatment demonstration results • Wastes for treatment demonstration • Wastes and waste composition • Data sources for treatment demonstration • Degradation/transformation » Laboratory and field case aesign • Immobilization • Volatilization • Toxicity: Soil Microbes Plants 8.1.3.1 Wastes for Treatment Demonstration Plan— Part 1 - List of hazardous wastes - The treatment demonstration must be made for wastes that are representative of those that will be land treated at the proposed disposal jite. The applicant should identify the type and name of the waste, process or source generating the waste, monthly or annual quanities expected to be handled, and EPA Hazardous Waste ID number. The list presented by the applicant should be compared with the hazardous wastes identified in Part 261, Subpart D, §§261.30 through 261.33; Appendix VII of Part 261; and any applicable state hazardous waste regulation. Hazardous wastes will contain organic and inorganic compounds. In general, land treatment should be confined to wastes that are principally organic. These wastes are more readily treated by the primary soil processes of biological degradation and chemical transformation. Inorganic compounds and heavy metals are unaffected or slowly affected by the degradation and transformation processes. These constituents must be immobilized in the treatment zone. With respect to persistent hazardous organic constituents, these compounds must be immobilized in the treatment zone to enable complete degradation. Table 8.1.4 summarizes the processes involved in land treatment of hazardous constituents, while Table 8.1.5 describes qualitatively the treatability of major hazardous material groups. 8-15 ------- TABLE 8.1.4. TREATMENT OF .iAZARDOL'S CONSTITUENTS BY LAND TREATMENT ?? PROCESS!^ Hazardous constituent Organics Metals Inorganic Cations Inorganic Anions Degradation3/ transformation X Immobilization Adsorption/ Ion precipitation exchange X X X X X X Plant uptake^* X X X X alnciudes biological, chemical, and photochemical-dagradacion. ^Removal by crop harvesting. TABLE 8.1.5. QUALITATIVE ASSESSMENT OF THE LAJTO T2£ AT ABILITY3 JF HAZARDOUS MATERIAL GROUPS 2 Hazardous material group Land treatability potential Solvents and related organics such as High trichloroethylene, chloroform, and PCBs and PBBs Limited Pesticides High Inorganic chemicals such as ammonia, cyanide, Limited acids, and bases Heavy metals Limited Waste oils and greases High aHigh land treatability does not infer immunity from environmental damage. Only through proper design and management of a land treatment unit can the desired level of treatment be obtained and the migration of hazardous materials be prevented. 8-16 ------- In addition to listing hazardous wastes, the applicant should identify nonhazardous wastes that will be treated in the same land treatment plot as the hazardous waste. Although a treatment demonstration is not required for the nonhazardous waste, the presence of these wastes in the same plot may affect hazardous constituent degradation, transformation, and/or immobilization. Part 2 - List of hazardous constituents - The applicant should identify the hazardous constituents present in the waste. This list should be based on the results of a complete analysis of the wastes to be land treated at the facility. Analytical procedures described in Test Methods for Evaluating Solid Waste^ should be followed for determining the presence of hazardous constituents. Appendix VIII of Part 261 identifies ccnsticuencs ciiac ii?A nas determined co j& nazaraous. To verify the list of hazardous constituents identified by the applicant, the reviewer should consult the Hazardous Waste Land Treatment (HWLT) manual and Characteristics of Hazardous Waste Streams6 which provide lengthy discussions of the general characteristics of various industrial waste streams. Table 3.1.6 lists the waste streams described in the referenced documents. Appendix A of she HWLT aanuai^ presents the results of a survey of existing hazardous waste land treatment facilities in the United States. Table 8.1.7 summarized industry groups currently operating land treatment un i t s. The applicant should also provide information on the presence of pertinent nonhazardous constituents in the wastes to be applied at the treatment unit. As previously described, pertinent nonhazardous constituents can be any compounds or substance that may affect the degradation, transformation, or inmooilization of hazardous constituents. Table 8.1.8 lists the more common pertinent nonhazardous constituents or substances and the impact they might have on hazardous constituent degradation, transformation, or immobilization. Section 6 of the HWLT manual5 identifies waste streams that contain the pertinent nonhazardous constituents listed in Table 8.1.8. Worksheets for evaluating the adequacy of listing hazardous constituents to be land treated are presented in Figures 8-1.1 and 3.1.2 for existing and new facilities, respectively. Part 3 - Waste characterization - Analytical methods to determine the waste characteristics identified in Section 8.1.2.1.1, Part 3 are described in Section 5 of the HWLT manual^ and Test iMethods for Evaluating Solid Waste.^ The applicant should identify the specific test used to determine each waste characteristic as well as sample collection and preparation techniques. The values reported for each characteristic will aid in determining application rates and frequencies and whether soil conditioning (e.g., pH control, soil moisture control) prior to and subsequent to waste application will be required. 8.1.3.1.1 Data Sources for Treatment Demonstration—Treatment demonstrations can be made using information derived from published literature, laboratory tests, field studies or existing operating data. Applicants will frequently make the treatment demonstration using data obtained from a combination of 3-17 ------- TABLE 8.1.6. SOURCES OF INDUSTRIAL HAZARDOUS WASTE STREAMS^ Specific sources of hazardous waste Nonspecific sources of hazardous waste Textile Mills Lumber Paper Printing Inorganic Chemicals Alkalies and Chloride Inorganic Gases Inorganic Pigments Other Inorganic Chemicals Organic Chemicals Plastics Synthetic Rubber Synthetic Fibers Pharmaceuticals Soaps, Detergents, and Cosmetics Paint Formulation Gum and Wood Chemicals Cyclic Crudes and Intermediaries Cyclic (benzenoid) Intermediates Synthetic Organic Dyes Synthetic Organic Pigment Cyclic Crudes Other Organic Chemicals Pesticides Adhesives Explosives Inks Petroleum Products Petroleum Refining Petroleum Re-refining Syncrudes Rubber Products Leather Tanning and Finishing Stone, Clay, and Glass Metal Smelting and Refining Metal Finishing Industries Electroplating Metal Heat Treating Coating Solvent Degreasing Machinery Electronic Components Batteries Electric Utilities Solvent Bearing Wastes Solvent Use in Degreasing Operations Solvent Use in Product Formulation and Synthesis Solvent Use in Dry Cleaning Plants Paint Bearing Wastes Heavy Metal and Cyanide Bearing Wastes Electroplating Operations Metal Heat Treating Metal Recovery Scrubber Sludges from Blast Furnaces and Coke Ovens 8-18 ------- TABLE 8.1.7. INDUSTRY GROUPS CURRENTLY OPERATING HAZARDOUS WASTE LAWD TREATMENT UNITS5 SIC Code* 29 28 49 34 97 24 36 20 22 39 35 26 13 44 76 02 30 33 37 51 82 Description Petroleum refining and related industries Chemicals and allied products !71">"*ric -as, ana sani ca ry services Fabricated metal products, except machinery and transportation equipment National security and international affairs Lumber and wood products, except furniture Electrical and electronic machinery, equipment, and supplies Food and kindred products Textile mill products Miscellaneous manufacturing industries Machinery, except electrical Paper and allied products Oil and gas extraction Water transportation Miscellaneous repair services Agricultural production - livestock Rubber and miscellaneous plastics products Primary metal industries Transportation equipment Wholesale trade - nondurable goods Educational services Xu.iber of unj.cs 105 " <•> 16 12 9 7 5 *f 4 3 3 3 2 2 2 1 1 1 1 1 1 aStandard industrial classification code. 8-19 ------- TABLE 8.1.8. LIST OF PERTINENT MONHAZARDOUS CONSTITUENTS OR SUBSTANCES Conscicuent or substance Potential impact Organic Matter Water Inorganic Nutrients (Nitrogen, pnospnorus, boron, and sulfur) Inorganic Acids and Bases Inorganic Salts Hal ides (Fluorine, chlorine, bromine, iodine) Nonhazardous3 Metals (Cobalc, copper, lithium, managanese, palladium, zinc) High organic content in waste stimulates microbial activity, resulting in nutrient depletion if soil is not fertilized periodically Also increasing organic content of soil increases water holding capacity which mav lead lo prolor.gaa p<=ruas ana anaerobic conditions during wet weather Excess water can create anaerobic conditions resulting in reduced degradation Also addition of excess water may result in constituent leaching and/or increased surface runoff Wastes devoid of inorganic nutrients accelerate nutrient depletion and must be countered by increased soil fertilization Alternatively, excessive concentrations in waste applied may have detrimental effects on soil microbes and plants and also may damage physical properties, of soils Additions of these constituents upset soil pH balance such that pH management must be intensified Soil accumulation of inorganic salts and halides may retard microbial activity or inhibit plant growth during active period Also, salt accumulation will alter physical and chemical characteristics of soil Ealide accumulation due to application of excessive concentrations can be toxic to soil microbes and cover crops Elevated soil metal concentrations can retard microbial activity or inhibit plane growth aNonhazardous means metal is not listed in Appendix VIII of Part 261, 8-20 ------- .ISTING Or ;UZARDOUS PASTES AND CONSTITUENTS—EXISTING FACILITY Has this part of Che applicant's subraittal been reviewed and evaluated? Ye s No Date Does the Part B information agree completely with che information proviuea previously in the Part A application? Yes No Are waste names and EPA LD numbers identified? if as No Are locations identified showing where wastes are or will be applied within the land treatment unit? Yea No If all answers are ves. -his part 31 :he applicant's subraittal is adequate. However, if any differences exist between che Part A and °arc 3 applications continue below— Are only subsets of the wastes listed in the Part A application going to be iana created? Yes No Are previously identified wastes (in Part A) treated or somehow transformed before land treatment? Yes No Have any of the wastes been delisted? Yes No Have any of the treatment zones or portions thereof been closed? Yes No Are all apparent discrepancies explained in the Part B application? Yes No Has che applicant submitted a revised Part A application? Yes No Describe any deficiencies in the applicant's submittal, if they exist. Figure 8.1.1. Worksheet for evaluating Che adequacy of listing hazardous wastes and constituents being or to be land treated at existing facilities. 8-21 ------- LISTING OF HAZARDOUS WASTES AND CONSTITUENTS—NEW FACILITY Has this part of Che applicant's subraittal been reviewed and evaluated? Yes No Dace Have both Part A. and Part 2 applicacions been submitted? Yes No Are waste names and EPA ID numbers identified? Yes No Are locations identified showing where wastes will be applied within the land treatment unit? Yes No Are there any apparent discrepancies in the informacion provided in the Part A and B applications? Yes No Will only subsets of che wastes listed in the Part A application be land treated? . Yes No Will any waatas liscaa in the Part A application be treated or transformed prior to land treatment? Yes No Describe any deficiencies in the applicant's subraittal, if they exist. Figure 8.1.2. Worksheet for evaluating the adequacy of listing hazardous wastes and constituents to be land treated at new facilities. 8-22 ------- these sources. Table 3.1,? i-anc.Jlcs -ne advantages and disadvantages associated with the types of data sources to be used to make a treatment demonstration. Laboratory tests or field studies conducted to demonstrate the treatability of specific hazardous constituents must be performed under conditions similar to those present or expected at the land treatment unit. Also, if existing literature is used, data obtained from published documents must be representative of conditions at the treatment facility. The following conditions/characteristics of che proposed or existing land treatment unit must be described in the application if published literature is used or simulated if tests are performed: (i) characteristics of wastes co oe land-treated (see Part 3 of Section 8.1.2.1.1 above), (ii) characteristics of the treatment zone, including depth, soil texture, pH, cation exchange capacity, organic matter content, moisture content, and depth to seasonal high water table, (iii) topography of the treatment zone including =-,lope, (iv) local climate, including monthly temperature, precipitation, evaporation, and wind pattern data, and (v) operating practices, including waste application method and rate, tilling depth and frequency, and soil conditioning practices (e.g., prf adjustment, fertilization, soil water regulation). The permit reviewer should verify that each of these items are addressed in the treatment demonstration. Figure 8.1.3 provides a worksheet to aid in the review of these permit application information requirements. In addition to determining that the data used to make the treatment demonstration are generated under conditions that are similar or representative of those present or expected at the land treatment unit, the reviewer should confirm that all activities described in the treatment demonstration are going to be implemented under the land treatment program. This check is to ensure completeness of the application and to verify consistency between theoretical/experimental operation and actual operation of the land treatment facility. Literature Data Sources When treatment demonstration schemes are based on literature reviews, the permit reviewer must confirm that the information is represencative and directly applicable to the proposed facility. Treatment demonstrations based on studies reported in the literature must be carefully examined to ensure that climate, soil characteristics, waste types, and application rates associated with the proposed facility are similar to those reported in the literature. It is essential that the literature data be representative of the proposed site characteristics. Also, the information used to make the 8-23 ------- TABLE 8.1.9. UTILITY OF DATA SOURCES FOR MAKING TREATMENT DEiMONSTRATION Data source Advantage Disadvantage Literature When available, existing lit- erature is readily obtained and inexpensive. Laboratory Test Field Tests Operating Data Can be well controlled; can simulate specific inter- actions at microcosm level. Provides more holistic approach than laboratory studies, can closely simulate actual land treatment unit conditions. Closest approximation of actual conditions. Excellent for existing facilities. Very little documentation/ test results are presently available. Also, informa- tion that is available may not be specific to waste(s) to be created, generaliza- tions have to be made to make extrapolations. Small scale and generally unidimensional; one or two factor analysis limits utility. Time consuming to obtain, environmental factors (e.g., precipitation, tem- perature) uncontrollable. Not usually well documented, very site specific. There- fore, utility is limited for other sites. 8-24 ------- Yes No Wa*t« Characteristics: Concentration of hazardous conatituents and pertinent nonh«zardou« -or»i::.:':».it~ Concentration of volatile hazardous constituents W*cer c Specific gravity or bulk density pH or w*«ta Electrical conductivity Total acidity or alkalinity Total organic maroon Tre»ca«ot 3on« Charact »rucic3 . Oapcn of zone Soil texture Soil pH Cation exchange capacity Organic ucter content Moisture content Depth to leaaonal high groundvacer table Surface slope of treatment zone Local Climate: Temperature range .monthly; Precipitation Evaporation Wind pattern* Operating Practice*: Application rate Application method Tilling frequency and depth Soil conditioning pH adjmtment fertilization •oil water control Figure 8.1.3. Worksheet for items to be simulated by treatment demonstration tests/evaluation. 8-25 ------- demonstration should be derived from well designed scientific studies where replicated experiments, employing representative sampling and experimental controls, were conducted. All statements and ~onclusions made within the application should be documented with citations in the text and bibliography. In addition to providing information on hazardous constituent degradation, transformation, or immobilization, published literature can be us-ed (and is recommended) to design laboratory and field experiments. Literature sources used t-> make portions of che treatment demonstration should nave been subjected to a thorough peer review. References providing relevant information on the principles and fundamentals of land trsat-rerc of industrial aad municipal wastes are identified in Table 8.1.10. Information presented in the cited references may not provide specific answers for a particular application. However, key design and operating principles, measurement techniques, and various waste characteristics are described that can be applied, through engineering and scientific knowledge and professional experience, to determine the technical adequacy of most permit applications to be reviewed. Because the land :rsatment of hazardous waste is an emerging field, results of laboratory and field tests identifying chemical constituents tnat are resistant to degradation or immobilization generally are not well documented in the literature. Therefore, pilot studies conducted in che laboratory or field should be encouraged at the preapplication meeting, particularly when dealing with unknown or uncommon wastes or hazardous constituents. During the preapplication meeting it should be made clear that field tests or laboratory experiments be performed not only to identify optimum operating conditions but also to define the 'jpper or lower values for all factors that limit waste degradation, transformation, and immobilization. Existing Operating Data When available, existing operating data provide an affective means of making the treatment demonstration. Because many of the initial Part B applications are going to be submitted for existing land treatment units, existing operating data will likely be used to demonstrate waste treatment. Existing data presented in the application must include results from soil-core (including treatment zone), soil-pore liquid, ground water, run-off, and air monitoring. The monitoring data submitted must be comprehensive and clearly demonstrate hazardous constituent degradation, transformation, or immobilization within the treatment zone. It should be recognized that the monitoring'data can be used to demonstrate the treatability of wastes that are similar to those previously disposed at the treatment unit. Additional documentation will be required to demonstrate the treatability of new and different wastes planned for disposal at the unit. 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S - 3 3 a! . 3 TJ 41 y> (M tf ac u x < ^ u 'Ji J a» — > * •** Ml 0 « • "5 VI 3 -3 w A/1 u • o < a. a r n i = 2 . • < g a, 3 _^ -a O • « 5 S - * -3 .< 4 X O M 3 -' ^ 41 ^ -> 33 - 41 9* - - i C*. -< . — . • «• ^ a * ^ 2 ^ u ui * . -- 3 -• s • * a. -. I w j • - s w a. 3 -. . w w M <« -M — J »» O i-t ^y3~ v •3 > 4 w 4 V b "y M V W - fl W 4 5 •< • 4 i 1 7 X « 3 5 | | "o i r <^ s s U w X U • • ^ u 1 - - ? » ° — e a — " 3 a •• « u 2 a II U 3 34 w u « a. £ a 0 » >1 •> 3 ** 5 a « 3 a v v 3 — w -9 -o u a. - a e s o a 53 j * i JT -• » 5 5 3 5 j •a 1 - u 3 a U '•* wl X ^J rg — I "1\ 3 i. a 4 < J C - V f 41 4 z - 30 • 3> 3 — . ^ -^ u 3 V >• U 3 V V -1 Z ^ c 4 1) j: 5 a « w i X 4 * r f 30 4 e o - A o /I 1 u ', 3 3 a. 5 T u •v **. 3 jj — •3 " ^ 3 u 3 w 3 4 7 a ^ > 9) — V 2 ••> :e -3 y -3 x as V 3 il f- a. V 3 ^ S •41 ^* | U C x — J 3 & a 5 V •o 3 8-28 ------- similar or can be reasonaolv ^orrslstad to c.-.ose presenc at che land treatment unit, and clearly demonstrate hazardous constituent degradation, transformation, or immobilization. Table 8.1.11 identifies various test methods for assessing specific waste-site interactions involving constituent degradation, transformation, or immobilization. Also identified in the table are the sections of the HWLT manual that describe each test. Note that the applicant is not required to use these tests to make the treatment demonstration. Although these test methods have been recommended to the applicant in the Permit Applicants' Guidance Manual,^ other test methods can be used as long as they are fully described and sufficiently documented by the applicant and satisfy the same objectives. Soils in which laboratory, field test, or greenhouse studies are performed should be similar to the soil of the actual or proposed treatment zone. In general, a soil series classification, including a description of the "A" horizon, will usually adequately define the necessary similarities of soils. A soil series is a subdivision of a soil family. The series identifies a group of soils having similar thickness, texture, structure, color, organic concent, and reaction (acid, neutral, or alkaline).? The "A" horizon of a soil is the top mineral layer located at or adjacent to the surface, just below the organic horizon. The characteristics of the "A" horizon within and among soil series can vary (see Appendix G of HWLT manual). Therefore, treatment demonstration tests should be performed in soils that have characteristics similar to the "A" horizon of the treatment zone soil. The characteristics of the "A" horizon can be determined from a local Soil Conservation Service (SCS), Soil Survey Report or consultation with a SCS soil scientist. It is important to recognize that extrapolation of field test results must be made with discretion because they are limited to the environmental conditions existing during testing. Testing should be performed under a wide range of conditions that are expected at the units. This includes seasonal variations, where applicable. vlso, replicate sampling to statistically verify test results should be conducted. However, uncontrollable variables such as temperature, precipitation, and wind speed and direction make testing under reproducible conditions difficult, as well as data interpretation. Although it is not required, tests should be conducted or extrapolations made to determine the limitations of the treatment unit. Once the limits have been identified, contingency plans can be developed to accommodate expected or unexpected phenomena when they occur. Examples of situations requiring a contingency course of action include: continued periods of heavy rainfall, increasing surface ponding and run-off; ground freezing during winter months, slowing or stopping waste degradation; or ice cover formation, resulting in anaerobic soil conditions (note that when the ice cover melts an odor problem can result due to anaerobic decomposition under reducing conditions). 8-29 ------- TABLE 8.1.11. TEST METHODS FOR ASSESSING -SPECIFIC WASTE-SITE INTERACTIONS VFROM HWLT MANUAL5) Waste-sice Tesc method aWLI manual section Degradation of waste Accumulation in soil of nondegradables • Leaching hazards Volatilization hazards Acute toxicity Chronic toxicity Plant uptake Pretreatment Respiroraetry 7.2.1.1 Field studies by soil testing 7.4.1 Waste analysis (inorganics) 5.3.2.3.1 Respirometry (organics) 7.2.1.1 Soil chin layer chromatography 7.2.2.1 Soil leaching columns 7.2.2.2 Field soil leachate cesting 7.4.2 Environmental chamber 7.2.3 Field air testing 7.4.4 Xespiroraetry (soil biota) 7.2.1.1 Beckman MicrotexTM System 7.2.4.1.1 Greenhouse studies (planes) 7.3.2 Microbiological mutagenicity assays 5.3.2.4 Greenhouse studies 7.3 Assessment of processes generating waste 5.2 8-30 ------- In addition Co demonstrating complete hazardous constituent degradation, transformation, or immobilization, the treatment demonstration will aid in defining site management activities such as waste aoplication Tsthods ana rates, soil pH and moisture control, fertilization needs, and soil aeration. To assess the impact of waste applications on the test soil, it is suggested chat the parameters identified in Table 8.1.12 be measured prior to and after each or a series of waste applications. A detailed discussion of the importance of measuring each of the parameters identified and ctieir impact on the soil processes involved in the treatment of hazardous waste is presented in the references cited in the last column of the table. A general interpretation of some of the more important soil chemical tests is presented in Table 8.1.13. Analytical methods to determine each soil paraaecsr identified ars praaentaa ^a lesc Methods for Evaluating Solid Waste^ and Methods of Soil Analysis.IP.^ In addition to assessing the parameters identified in Table 8.1.12, which are primarily chemical components, soil texture should also be evaluated. Section 3 of the HWLT manual provides a discussion of the suitability of various textured soils for land treatment of hazardous industrial wastes. Table 8.1.14 (reprinted from the HWLT manual) identifies the advantages and disadvantages of applying hazardous waste to several soil texture classes. This information can be used to identify operational concerns that should be addressed by the facility design (see subsection 8.3). 3.1.3.2 Treatment Demonstration Results— The applicant must submit the results of any tests conducted to make the treatment demonstration. The following discussion provides guidance for evaluating the data submitted to show hazardous constituent degradation, transformation, or immobilization. To ensure that aach hazardous waste and hazardous constituent identified in the Part 8 permit application have been addressed by the treatment demonstration, a checklist should be prepared that identifies how each hazardous constituent will be degraded, transformed, or immobilized in the treatment zone. Table 8.1.15 presents an example checklist to be developed during the treatment demonstration review process. Completion of such a checklist will provide an accounting of how each hazardous waste and hazardous constituent will be treated at the unit. Emphasis should be placed on documenting the degradation, transformation, or immobilization of highly water soluble hazardous constituents that are leachable and compounds with high vapor pressures that may be lost through volatilization. 8.1.3.2.1 Wastes and Waste Composition—If for any reason the wastes used in the treatment demonstration differ or have been pretreated or mixed, the applicant should have provided the same information outlined in Section 8.1.2.1.1. In some cases, the applicant may pretreat the waste as part of the treatment demonstration to try to: (1; improve treatability, (2) reduce waste volume, (3) add soil amendments, or (4) eliminate untreatable or unacceptable waste constituents. Pretreatment can be accomplished by physical, chemical, or biological processes. The reviewer is referred to the HWLT manual and references therein cited for a discussion of waste pretreatment. Table 8.1.16 provides a synopsis of various pretreatment techniques as they relate to waste amendment prior to land treatment. 8-31 ------- TABLE 8.1.12. SUGGESTED SOIL PARAMETERS TO MONITOR PRIOR TO AND AFTER WASTE APPLICATION3 Prior to After one or serias jf Pirametsr application applications PH Cation exchange capacity Organic matter Soluble salts (TDS or EC)b Soil moisture content Soil fertility (N,P,K)c Yes Yes Yes Yes Yes Yes Yes, Yes, Yes, Yes, Yes, Yas, after series after series after series after each after each after series References for discussion of 2, 2, 2 2, 2, 2, parameter 5 5 5 5 5 5 ,7 ,7 ,7 ,7 ,7 , / ,8, ,8, ,8, ,3, ,8, ,8, 9 9 9 9 9 9 aAdapted from Reference 3. ''TDS—total dissolved solids, EC—electrical conductivity. cNitrogen, phosphorus, potassium. 8-32 ------- INTERPRETATION OF SOIL CHEMICAL TESTS3 Test result Unterpretation pH of saturated soil paste <4.2 4.2-5.5 5.5-8.4 >8.4 Too acid for most soil Tiicrobas and plants co do well Suitable for acid-tolerant soil microbes and plants Suitable for most soil microbes and plants Too alkaline for most soil microbes and plants, indicates a possible sodium problem Cation exchange capacity (CSC) , raeq/100 g 1-10 12-20 --20 Sandy soils (limited adsorption) Silt loam (moderate adsorption) Clay and organic soils (high adsorption) Electrical conductivity (ECe), mmhos/cm at 25°C, of saturation extract 2 2-4 4-8 8-16 No salinity problems Restricts growth of very salt-sensitive crops Restricts growth of many crops Restricts growth of all but salt-tolerant crops Only a few very salt-tolerant crops make satisfactory yields aAdapted from Process Design Manual for Land Treatment of Municipal Wastewater, U.S. EPA, Report No. 625/1-77-008, October 1977. 8-33 ------- TABLE 8.1.14. SUITABILITY OF VARIOUS TEXTURED SOILS FOR LAND TREATMENT OF HAZARDOUS INDUSTRIAL WASTES5 Texture* Advantages Disadvantages Sand Loamy sand Loam Silt loam Silt Silty clay loam Very rapid infiltration Usually oxidized and dry Low runoff potential High infiltration Low to medium runoff Moderate infiltration Fair oxidation Moderate runoff potential Generally accessible Good CEC Moderate infiltration Fair oxidation Moderate runoff potential Generally accessible Good CEC Low infiltration Fair to poor oxidation Poor CEC Good available water Medium Co low percolation Fair structure High CEC Silty clay Good to high available water Clay lo«« Medium to low percolation Good structure Medium to poor aeration High CEC High available water Very low cation exchange capacity (CEC) Very high hydraulic conduc- tivity rate Low available water Little soil structure Low CEC Moderate to high hydraulic conductivity rate Low to medium available water Fair structure Some crusting Fair to poor structure High crusting potential Poor structure High runoff Medium to low infiltration Some crusting potential Moderate runoff Often wet. Fair oxidation Medium to low infiltration Moderate to high runoff Often wet (continued) 8-34 ------- TABLE 8.1.14 fcontinued) Texture* Advantages Disadvantages Clay Low percolation High CEC High available water Sandy clay Medium to low percolation Medium to high CEC Sandy clay Medium to high available water loam Good aeration Low infiltration Often massive structure High runoff Sometimes low aeration Fair structure Moderate to high runoff Medium infiltration a8ased on 'J.S.D.A. taxtarai classification scheme. TABLE 8.1.15. EXAMPLE HAZARDOUS WASTE AND HAZARDOUS CONSTITUENT TREATMENT DEMONSTRATION CHECKLIST Constituent Treatment process Data source Phenol Hexachloroethane Cadmium Chromium Biodegradation Adsorption by soil colloids Adsorption Ion exchange Soil respirometer tests Extractability tests Laboratory soil column leaching test Literature review 3-35 ------- "1 7* kij I o ^ «£ y "^J z •^ li. s 1 ^-M id ^ ^ -J < as id ' a£ a. , vO — * _ 3O U 3 < i H i i -n 9 2 w , S ^, y }>i £ e ^ % ! t Q •j e 3 „ }- 0 3 U 4 •• 3 a a-o >* c 9 W — e u 4 3 U 4B) O a -^ II ?! •w * ^ > 4 > lij e • 1 €? ^ « ii r 4U ' ^ 9 ^ % y J i a £•• ^ C 9 3 ii (^ ? 4 "i * J * if 1) 0 W 0 z « » 0 2 •0 V > ^ — 3 U 0 < J> — •u 's 3 T 0 — s % W 7* 3 5 - 1 F e1 3 •— "^ •M Ul - y a — | | 5 y « 4 O t - -3 = S-J U -• -i « 3 i 4 " » i - - «< 0 e = c | ii - 0 W V w 4 w 3 :> Jf *" S 22 4 a 0 9 tl V « « « 2 22 U 9 C «3 C .0 .J w S) 5 3 » « - O w u 3 •> * 4- T- i < < J *, 4"J 3 M ^ W 3 e • 3 y ••? n y « u •5 y — ^ 'J i * W 0 U i ^ n V 9 * =41 fl O -9 >» C w ^J Si, ••• 3 91 % U 3 - 3 ^ ••J •J •M I U * 5> 3 w S "** •J 41 U « « •5 2 4 2 t> ^ e » •• w •* V M * 'J -» H 2, •5 3 01 „ w 3 "• i "• I • n rjiuaoim J "^ a 4 «4 ^ 3 y — C •3 — « *J > C 5 * U * s 1 * «3 Jo > • V > « i ~ 3 *j 4 N « £ e « « S •i, ^ 3 9) ^ J W 3 'S ~y ~3 ~s c f r — ; i i 4 e * 0 — t. 4 'e 'o a 3X4 « 3< « V >. • U W — •— 3 O O — 3 — ~ * a 4 M o • U « ? u "j « s — M > . 1 • 3 *• 3 • 4 U .. « 3 - 3 «-? w • • "5 > — 5 o 0 y c a — C -J U '- U £ - - w « - !_« 2 i3 * J * "" 2 2 1 n 2 2 i ii v o U ti • & *3 >• « • III r u - c joes — 44 V 4 4 '•J — U ^ >• •^ W 3 w T 3 — — H ^ 3 a ? u J > J! y « 5 3 >• — j i 5 1 a 3 0 0 • >* e 3 4 0 7> — 3 0 — >• •• — U 4 V U *t ^ 3 y •— 0 I ' w « 3 w S v a 4 •— -Sj — "3 o ^ 9 J > C 0 . ^ W tf — ••• 3 jt ^ W 3 a ^ *3 7 ™ J •" « 11 « 4 X|j woj) ffnovnffp 1 0 u — " 1 40* 0 ? 0 *• 3 3 •* 1g 1 2 J 2 2 •J i ~ 0 0 » > § M — >• 3 4 n 2 40) V T3 3 a . w w 3 a *3 •"! 3 ^ !• ^ •^ •>• r jj U 1 0 • - o 5 «. > s 'o — — w 3 (J it ^ — 1 3 e 0 J, *•, 3 jj 9 »• ~ 3 ~ 7 334 U 1 w J i- 1 2 2 2 * 5 *" 0 s > e « 3 — M >< - - 9 V a ~ 8-36 ------- , ! 7 1 2 t- a ** i, * _o £ . e ! ! * 3 •a % c: •H 1 3 y J j ' ' * • 44 00 « 9 U a JI| o — e u 4 3 »- — "5 e > £5 «« flj II 1 II s II * 1 J. y 3 a •0 « > -3 T r a e- J j at J f £ 5 •? • • w -- -» «• 44 Q 44 — « • • i u u u a 443. ? y w — > O 934 a — e e 44 o * — — s a a "a a » w S o a ! 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CO [I 1 a Ii — ! 'I a ,' < ll i* '1 il ,'! il It ;i 1 j' !| ii I f (- J \ 4 i i 1 II if n M II • II * s. 41 - 1 * 3 9 — S Jl H 1 1 • *• >• >• I S | * u - i'i *•) i * * 1 — 1 • 'o ~n 9 11 ! 1 2 33i2:, f 3 f f 3 1 1 f * 1 i| ' ' - J - j I » •S i — 41 >. •fl *j • y „ ^ •* I - « 5 S fli? i 1 • - fl2 * 2 ? "Si 1 1 -•• *• - v - c M I J w * ,ta •_*•«« II i • • ** « 3 Sj'fl-y 'i I---:* s~3«4ta 1 '1 5 S3 ** I 5 »w30 ?:ii J I* If .«,'*; Hi5 :i«=f • I 111], ij S i is a IT" - • - • S 1~ >S - • • " ^ «o«S"'-=; i%! !5-si I If ||'! H if! 3 2 *1 *l 3 ,.5 !| oi =>. Irs5 - - * M ? 2 '*«2e«ii. 1 S- - « - • 0 §• j.- ._ 0 • M w. • -?r r ^ -5 s ..-=,- -**?ro22*! I ' * » »•«-«««£ » 3 « 0 » - J ?"T i| l|«| s si l«|| iiSliS=«ii i « a a. f 4 5 - > ,j} * , . 7 1 1 5 3 3 |J e ' | • 15 *^ 3 ** f » -^ y a -, ?* « '1 «03l55«55 " a n . i *>^j~ z >z z > 5 -9 5 3 i IP 1 — — 2 '( -; 1 !) I J 1 | 3 ' ' y- i — *rf / 1 £ *J 1 m t| ' 3 1 » 3 3 ^ . " Isi- J Ja a 5 « i 5 « !; V 1 '' a i n i it i " 0- II = 1 - |M * * a s «| | s s , o « •*•*•; 0 * '' 5 II - '7 J ! -a |j ill1 p' « » i i i « !M il i II J - c T ;; * •* 1 5 " c m e '" "S S . 8=» j = * ? :: « *- !5^= -15 § | ;t :I * '- » 1 3 - - - r £ = 2 5 ! o 5 a « * • t i • ?• "^ - «; 2 1^ S e f-S « -iE " j*o Ii>2 «« 3 2 . £ != 5^1^ | |5± | |=| jj ,, '| '( .[ -4 **1 i; -H ^ i w 1 V) , 3 1 -a I c | ^ il ^ =3 N -2 i i-j atment o V u e_i V. O ^> •-M . X cfl . fl ^ _%, ^ ~! 5 •H • *^ 2 5 u - O O 0. N Ii S 0 g'J S2 = 5 s ~ •« * *J3 • 5J X J 3 ) Z i 1. . CO a 4J •J} !B ' 3 8-38 ------- Hazardous constituents contained in wastes to be land treated should be carefully evaluated to assure creacabiiicy. Because biodegradation is the principal treatment mechanism, wastes containing significant quantities of halogenated organic compounds, inorganic acids, bases, salts, and heavy metals are noc well suited for land treatment. Wastes containing these types of constituents are not readily biodegraded and will accumulate in the soil, limiting a facility's service life and increasing the potential for ground water contamination due to leaching. The following discussion addresses the various treatment methods and -najor environmental concerns associated with the operation of a hazardous waste land treatment facility. 8.1.3.2.2 Degradation/Trans formation—Organic hazardous constituents aoolied in or on the treatment zone tsav '->«» -^grcded by oioiogicai, cnemical, or pnococnemicai processes. Biodegradation, however, is the principal treatment mechanism. Biodegradation is accomplished by soil microbes, and when a vegetative cover, is present by plant metabolism. Chemical degradation or transformation of hazardous constituents results from compound oxidation, reduction, hydrolysis, isomerization, and polymerization. Phung.-I. et al.8 provide a discussion of the factors affecting chemical Cransformacion ana cite references for additional information. Photochemical degradation is generally a minor component of land treatment of hazardous wastes because the waste is usually incorporated into the soil. Photochemical degradation occurs only at the soil surface where wastes that have been surface spread are directly exposed to incident radiation. Chemical reactions, primarily altering organic compounds, are induced by solar radiation. For a more'detailed discussion of photochemical degradation see Phung, T. et al.8 and references cited therein. Because chemical and photochemical degradation play minor roles in hazardous constituent degradation, these processes will only be briefly addressed in the following discussion. Principal determinations to be made by the treatment demonstration are the rate and extent of organic hazardous constituent degradation or transformation in the treatment zone. The extent of degradation will determine whether land treatment is an acceptable means of disposal, whereas the rate of degradation will determine frequency of waste application. Part 1 - Existing literature - The reviewer should consult the literature and possibly other (Federal, State, and local) regulatory agency personnel to gain an understanding of potential problem waste constituents that resist degradation or are difficult to immobilize. Section 6 of the HWLT manual and the Design of Land Treatment Systems for Industrial Wastes - Theory and Practice? provide useful information on microbial degradation rates of various classes of organic compounds (e.g. phenols, substituted biphenyls, polynuclear aromatics, solvents, and alcohols) and the mobility of various metals in soil. The following discussion highlights pertinent information presented in the references (refer to the texts themselves, however, for a more detailed explanation). 8-39 ------- Table 8.1.17 presents a compilation of research rasulcd showing ricas 3 degradation of phenol and phenoli- compounds. Trie results are expressed in te.rms of percent degradation occurring in a certain number of days. Application rates are also shown. Although the information provided is based on small scale analyses, it can provide a starting point for estimating and evaluating rates of degradation and application loadings more precisely. TABLE 8.1.17. RATES OF DEGRADATION OF PHENOL AND PHENOLIC COMPOUNDS (ADOPTED FROM REFERENCE 9) Compound Application rate Degradation rate Phenol o-Cresol m-Cresol p-Cresol 2,4-xylenol 2,5-xylenol 3,4-xylenol 3,5-xylenol Thymol Pyrocatechin Resorcinol Hydroquinone a-Naphthol (3-Naphthol 1 , 4-Naphthoquinone 0.03* of soil weight 0.05% of soil weight 0.05% 0.05% 0.05% 0.05% 0.05% 0.05% 0.05% 0.05% 0.05% 0.05% 0.05% 0.05% 0.05% 100% in 6 days 100% in 8 days 100% in 11 days 100% in 7 days 100% in 4 days 100% in 14 days 100% in 9 days 100% in 11 days 100% in 3 days 100% in 1 day 100% in 2 days 100% in 1 day 100% in 5 days Very little in 90 days 100% in 9 days It is noted that phenol rate of application reportedly has a strong influence on microbial activity.9 phenol application rates equivalent to 0.01 to 0.1 percent of the soil weight have actually caused an increase in microbial activity, resulting in complete degradation of the organic compound. As the loading is increased to 0.1 to 1.0 percent of soil weight, however, an increasingly strong inhibitory effect has been recorded. Consequently, treatment demonstration testa should be performed to assess the impact of organic concentrations on soil organisms. Organic hazardous constituent concentrations similar to those expected in the waste to be applied at the land treatment facility should be used during testing. Tables 8.1.18 and 8.1.19 identify relations between microbial activity and application of various solvents and alcohols, respectively. The phrase 'critical soil level* identified in the tables is the dose that causes a reduction in vierobial numbers and diversity. Doses above critical levels result in long-term adverse soil response. Application rates below the critical level have little or no effect, and microbial populations are actually stimulated by the addition. 8-40 ------- TABLE 6.1.18. RESPONSE OF SOIL MICROBIAL POPULATIONS TO APPLICATION OF VARIOUS SOLVENTS (ADOPTED FROM REFERZ^CZ: 3} Solvent Cyclohexane Hexane Heptane Pentane Formaldehyde Chloroform Ether Acetone Pyridine TABLE 8.1.19. Alcohol Methanol Ethanol 1-propanol 2-propanol Critical soil level (ppm) 840 4:0 10,000 ",:co 150-300 590 7,^00 58,000 7,900 RESPONSE OF SOIL MICROBIAL VARIOUS ALCOHOLS (ADOPTED Critical soil level (ppm) 32,000 46,000 12,000 12,000 Time period for recovery at critical dose Within 37 days Within 19 days Within 24-63 days Within 30-53 days Within 22 days Within 12 days Within 14 days Within 12 days Within 16-30 days POPULATIONS TO APPLICATION OF FROM REFERENCE 9) Time period for recovery at critical dose Within 12 days Within 11 days Within 21 days — 8-41 ------- respect to organic acids degradation, Table 3.1.20 orasents the percentage decomposition or various carboxylic acias. Joseg of 1000 ppm were appliea co ioamy sand. The highest and lowest percent loss are shown after^ 7 days and after 84 days. TABLE 8.1.20. DECOMPOSITION OF CARBOXYLIC ACIDS IN SOILS (ADOPTED FROM REFERENCE 9) Tide requirec Compound Percentage decomposition Cdays) Acetic acid Acetic acid Pyruvic Pyruvic Succinic acid Succinic acid Glucose Glucose 52-76 71-87 47-83 70-93 52-39 71-95 75 87 / 84 7 34 T 84 7 84 ^ In general, organic compound groups may be ordered as follows based on increasing ease of biodegradation: Halogenated Hydrocarbons (e.g., pesticides) Aromacics (e.g., polynuclear aromatica, PNA) Alkanes, carboxylic acids Alcohols Part 2 - Operating data - Demonstration of hazardous constituent degradation using existing operating data will likely be based on analysis of soil-core and soil-pore liquid samples. Test results presented in the application should identify the rate and extent of degradation of the organic hazardous constituents present in the waste being land treated. This means of making the treatment demonstration will very likely be exercised by existing hazardous waste land treatment facilities that have been collecting such information since startup. Part 3 - Laboratory tests - Waste degradation is principally accomplished by aerobic microbial decomposition. One method of assessing biodegradation is to monitor microbial activity following waste application and measure waste decomposition products. A soil respirometer is one technique available to 8-42 ------- evaluate the degradation of organic compounds in a waste-soil mixture. A soil respirometar can be used co indicate microoiai activity and relative waste decomposition based on the rate of CQ^ evolution. Figure 8,1.4 displays a decision making process to determine hazardous waste treatability based on soil respirometry studies. Other raetnods to determine organic material degradation are infrared gas analysis, and gas chromatography. 12 Results obtained from these analyses can be used to gauge application rate and frequency, rate of required nutrient (fertilizer) addition, and rate of waste degradation in different soil types or temperatures. The time required for aerobic decomposition is primarily a function of waste composition and loading and soil characteristics.° More detailed explanations of biodegradation, including soil respirometry and its methodology, are provided in the HWLT manual. Laboratory tests allow the examination of soil treatment processes under several different environmental conditions within a reasonable time period. Although laboratory tests can be designed to simulate actual conditions, they are somewhat one dimensional and do not reflect the complex interactions that occur in the field. As a result, field studies may be necessary to verify certain laboratory generated data. Laboratory results should be clearly presented. Data should show rate of degradation, i.e., amount of orgnic decomposition over time, and extent of degradation, i.e., percent degradation as a function of time (see Figure 3.1.5 as example). Laboratory tests should determine the extent and rate of degradation for all organic hazardous constituents, focusing on those constituents which are less susceptible to degradation. In addition, the half-lives of each organic hazardous constituent should be determined, as discussed below. Two basic techniques are used to assess organic constituent degradation. They involve: (1) measuring C02 evolution from the soil incubated in a chamber and, (2) analyzing soil samples for organic constituents. The former, which .is not constituent specific, is used to determine the rate of degradation of the bulk organic fraction of the waste applied to the soil. The latter technique can be used to determine specific constituent degradation by chemical analysis of a soil extract. Sections 5 ana 7 of the HWLT manual describe the analytical techniques and calculation methods for assessing organic hazardous constituent degradation. To assess the amount of constituent that will accumulate due to repeated applications, it is important to determine the half-life of each organic hazardous constituent to be applied at the treatment unit. Half-life is defined as the time required to degrade 50 percent of the waste constituent. Half-Ufa values should be used to determine acceptable yearly waste loading rates. The organic hazardous constituent with the longest half-life should be used to calculate site loading rates. Section 7 of the HWLT manual presents a. detailed discussion of the techniques used to determine organic hazardous constituent half-lives. 8-43 ------- -J3 O T3 .•a u J_l 4J T3 O -J _J Ui !8 "y c o •3 11 'J5 -3 _^Q 1 1 VJ 3 3 ------- a D a <3 C « a < a <: a <3 C a *c • o • o •o o T3 O O 3 *J U to o 2£ w x, 0 CJ U C 01 C 0-1-3 < Q 9 <3 Q <3G • <3Q « _ ^ U ^D o a • - _ ^ ^j ^^ ^•A ^Mk L 4 L 3 3 r« "* 5 2 "^0 ** -o s >> ------- In general, application races for hazardous constituents vi'ch ha if-Lives of no more Chan 1 year -an be twice Che amount applied annually so long as applications are separated in time equal Co one half-life cor the constituent. Table 3.1.21 presents estimates of che nercenc degradation of organic constituents vith various naif-lives after 10, 20, and 30 years. Note that constituents with half-lives of 1 year or less are degraded by more than 99 percent after 10 years. Although the information presented in Table 8.1.21 is- very general and not constituent or soil-specific, it illustrates how to evaluate half-life degradation data submitted by the applicant. Table 3.1.22 presents values of selected soil factors that are generally considered optimal for biodegradation. Note chat chese conditions are for'a generic class of organic wastes, under an aerobic environment. Other conditions or values, as determined bv the trsataent aetaonscration, may be •SOTS affsccive co creac che hazardou-s constituents applied. Each land treatment facility should be evaluated on a case-by-case basis. Part 4 - Field studies - Field studies may be necessary to confirm test results obtained under laboratory conditions. Field tests should be conducted to determine bulk organic fraction degradation. In addition, field tests should be performed co assess the degradation of any persistent compounds identified by a laboratory :ast or literature search. Recommended soil sampling and analytical procedures to be employed as part of the field tests are discussed in Sections 5 and 7 of che HWLT manual. Field test plots should be as small as possible, generally no more than 500 m^. Larger plots may be necessary, however, Co accommodate specialized waste application equipment or other machinery as required to conduct the field tests. Figure S.I.6 presents a worksheet that can be used for evaluating field test designs submitted by the applicant. Completion of the worksheet will provide an assessment of the completeness and appropriateness of the applicant's selected field tests to demonstrate hazardous organic constituent degradation. Test results provided by the applicant should include the percent degradation or transformation as a function of time for each waste application treatment. Section 7 of the HWLT manual provides a lengthy discussion of how to interpret degradability results obtained from laboratory and field tests. 8.1.3.2.3 Immobilization—Inorganic hazardous constituents and organic hazardous constituents that are resistant to degradation must be immobilized in the treatment zone. Even organic hazardous compounds that are readily biodegraded must be retained in the treatment zone long enough to allow complete decomposition. Substance mobility in the treatment zone depends on compound solubility and certain characteristics of the soil, primarily soil pH, organic matter content, and the types and amounts of clay. With respect to metals, most species are insoluble above soil pH of 7. In addition to insolubility, metals are immobilized by adsorption, precipitation, and chelation and metal-organic complex formation. The following identifies the relative mobility of certain metals based on soil clay and mineral surface adsorpfton: 8-46 ------- TABLE 8.1.21. PERCENT DEGRADATION AFTER 10, 20, AND 30 YEARS FOR ORGANI* CONSTITUENTS «'ITH VARIOUS HALF-LIVES IN SOIL (ADOPTED FROM HWLT MANUAL5) Percentage of substance degraded Half-life in soil 3 6 1 2 3 4 5 10 20 30 months months year years years years years years years years After 10 years 100 99. 99. 96. 89. 81. 75. 50. 25. 16. 9999 90 38 56 25 0 0 0 6 After 20 years 100 99. 99. 98. 96. 93. 75. 50. 33. 9999 90 96 83 75 0 0 3 After 30 years ;GO 99. 99. 99. 98. 37. 52. 50. 9999 90 39 44 5 5 0 TABLE 8.1.22. OPTIMUM VALUES OF SELECTED SOIL FACTORS FOR BIODEGRADATION Soil factor Range of values or types Texture Temperature Moisture content Aeration PH Microbes Sandy clay, silt loam, or sandy clay loam soils 10° to 30°C (ca 40° to 85°F) Between wilting coefficient and field capacity Periodic tilling will be adequate to promote soil aeration 6 to 7 pH Natural populations in undistributed soils appear to be adequate; microbial inoculations may be required 8-47 ------- yes ao FIELD TEST DESCRIPTION FOR TREATMENT CEMCNSTiUTIOtf Does the field case description state Che test objective? Has the applicant provided 4 scale drawing showing the location of test plot* relative to the proposed land treatment unit? yes no Are the number *nd siz« of ;he ce*c plots indicated? ______ yea no la the statistical design of the test stated? ______ ye» ao Are the horizontal and vertical dimensions of the treatment zone of the test piot(s) provided? yes ao Has the applicant described how the tsst plots vill be prepared (e.g., tillage, liming, fertilizer, inatailacioa of monitoring squipmenc, jurface vater control)? _______ _____ yea no Are waste application rates, methods of application, and soil incorporation techniques described? _______ ______ yea no If used, art irrigation methods and scheduling described? ______ yes no If plots will be vegetated, are methods for establishing and maintaining vegetation stated? _______ ______ yea no Are methods for measuring and recording daily meteorological data presented? ______ _ yea no Has che applicant described procedures for monitoring soil, soil-pore liquid, runoff, vegetation, groundwater, and aabient air, a« -ppiicaola? ______ _____ yes no Has a schedule of daily events and activities been presented? _____ ______ yes no Has the applicant described a design and management rationale to preclude the migration of hazardous constituents to ground or surface water? __ _____ yes no Are expected teat results"and data presentation described? _______ ______ yes no Has the applicant described the clean-up procedures to be implemented upon completion of field tests? yes no Figure 8.1.6. Worksheet for evaluating Che adequacy of field tests for demonstrating hazardous constituent treatment. 8-43 ------- Most Mobile: ?b and Cd Less Mobile: Mn, Zn, Cu, Co, Ni, and Cr Least Mobile: Al, Fe, and Mg Metal precipitation occurs when concentrations of cations and anions in the soil solution become sufficiently high whereby specific types will associate to form solid chemical compounds with limited solubility. Concentration levels at which precipitation occurs is compound-specific. Insolubilization of the precipitates leads to metal immobilization. Metals fixation based on chelation and metal-organic complex formation may be generally ordered as follows: Order of chelate stability: Hg > Cu > Ni > Pb > Co > Zn > Cd > Fe > Mn > Mg > Ca Decreasing order for organic bonding: Cu >Fe >Zn >Ca To ensure complete degradation or immobilization by adsorption or complexation, the hazardous constituent must remain in the treatment zone. With respect to organic hazardous constituents, the liquid infiltration rate and soil permeability must be determined to assess whether these compounds move through the treatment zone too quickly to allow complete degradation. Once an organic compound has leached below the zone of aeration where microbial degradation is most active, subsequent degradation in the lower soil horizons is markedly reduced. Incompletely degraded organic compounds reaching these zones can be l------- Pare 2 - Existing operating data - Section S.I.2.2.3 identifies the data elements to be submitted by the applicant who elects to demonstrate immobilization of hazardous constituents using existing operating data. Important data to be compared are analytical results of collected leachate and composition of wastes applied. Analytical techniques selected by the applicant should be capable of detecting known hazardous constituents of the waste applied and any hazardous constituent expected to be derived from the waste as a result of treatment. Concentrations of any hazardous constituent detected in the collected leachate should be coraoared with background levels to determine any significant difference. Section 9 of the HWLT manual provides a discussion of various sampling techniques employed in monitoring the soil-pore liquid. Sampling and analytical techniques used by the applicant should be evaluated by reviewing Sactirm e of ;he tiWLT manual and Taat Mathodj for Evaluating Solid Waste Physical/Chemical Methods.4 Part 3 - Laboratory tests - Laboratory tests to assess constituent mobility or potential leachability include soil thin-layer chromatography and column leaching. Soil thin-layer chroraatography is a technique used to assess the relative mobility of a substance by comparing the distance traversed by a given compound to the distance traversed by the wetting front. Column leaching is a laboratory jr field measurement technique used to assess relative pollutant mobility under saturated soil conditions. If the soil profile of the treatment zone is nonuniform, laboratory mobility tests should be performed under conditions reflecting the expected multilayered soil profile. Part 4 - Field tests - Demonstration of hazardous constituent immobilization- can be accomplished by studies performed on field test plots. A description of the field studies should oe included in the application Chat contains the information identified in Table 8.1.2. Specific field tests to make this (immobilization) demonstration are discussed in Section 7 of the HWLT manual. Results submitted by the applicant should clearly show the following: • the concentration of hazrdous constituents in the soil as a function of. depth at various times during the field test, • the concentration of hazardous constituents in the soil-pore liquid at various depths, over time, • the concentration of hazardous constituents in rainfall run-off as a function of the depth of rainfall, and • the concentration of hazardous constituents in the ground water underlying the field test plots. Submittal of these results will provide an accounting of the migration of hazardous constituents through and out of the treatment zone. Figure 3.1.6 presents a worksheet that can be used for evaluating field test designs submitted by the applicant. Completion of the worksheet will reveal the completeness and appropriateness of the applicant's selected field 8-50 ------- Cases to demonstrate hazardous constituent immobilization. Section 7 of the HWLT manual provides a discussion of the intarpratation of hazardous constituent immobilization studies performed in the laboratory or field. 8.1.3.2.4 Volatilization—Volatilization of hazardous compounds can occur during waste application and subsequent cultivation when underlying soil layers are exposed to the atmosphere. Surface spreading and subsurface injection are Cwo common waste application techniques. Studies have shown that air emission releases are greater when wastes are spread on the surface than when injected into the top soil layer. IXiring surface spreading, volatilization is a gas-phise resistance phenomenon, whereas when wastes are injected below the soil surface, vaporization is governed by liquid-phase and gaseous-phase resistance and diffusion through the porous soil. ^xperiaaca gained from cue xana treatment of refinery oily sludges,^ which presently is one of the most common waste types land treated, indicates that hydrocarbon emissions are released in proportion to the quantity of their volatile hydrocarbon content. It has also been learned that volatilization is minimized by delaying tilling after subsurface injection. Figure 8.1.7 displays test data revealing a marked decrease in atmospheric emissions by delaying tilling 2 days, from 4 to 6 days after soil injection. as Simulated laboratory tests should investigate the following factors they affect volatilization of the wastes applied: • Volatility of waste (the most important parameter affecting emissions), • Application method (subsurface injection results in lower air emission release), • Application rate (loading rate is inversely related to emission release, especially when waste contains high moisture content), • Air temperature (emission release will increase as temperature increases), • Soil temperature (same as air temperature), • Soil type (relationship to emissions not clearly defined, but differing release races from same waste applied to different soils have been recorded), • Soil moisture (emission release tends to increase with soil moisture), • Air moisture (direct relationship between relative humidity and emission release), • Air flow (emission release directly related to air velocity). 8-51 ------- e o 01 •"1 c u 3 aj JTJ •J) V) V3 D u o 01 -a •Jl V '-i •J 1! 13A31 u 3 30 8-52 ------- Ail iaooracory experiments co oe performed as part of Che treatment demon- stration should be conducted under.carefully controlled conditions using an en- vironmental chamoer tnat assures quantitative sampling and exclusion of outside interferences. The experimental apparatus should include equipment co regulate air flow, temperature, and moisture, and soil temperature ^nd moisture. Monitoring equipment and analyzers must be employed to record hydrocarbon emissions (qualitatively and quantitatively), soil temperature and moisture, and air flow, temperature, and relative humidity. Table 3.1.23 presents an example matrix of experimental conditions for land treatment simulation tests. Replicate testing should be performed to determine statistical variations and representativeness of data generated. Section 9 of the HWLT manual provides a brief discussion of air monitoring at hazardous waste land treatment facilities. For a more detailed discussion, refer to references 13 through 17. Beyond actual testing, theoretical aauations have been derived to estimate air emission release rates from land treatment facilities. Discussion of these estimation techniques are provided in references 14 and 18. The Office of Solid Waste, Land Disposal Branch, is currently researching the viability and accuracy of using mathematical equations to estimate air emission release rates. Table 8.1.24 lists the vapor pressure of chemicals 'that are contained in hazardous wastes representing 95 percent of the total U.S. hazardous waste disposal volume. The chemical listing resulted from a compilation of wastes identified in EPA's RCRA Part A permit application data base. Wastes disposed of in amounts greater than 10,000 metric tons were reviewed with respect to their chemical constituents and associated chemical, physical, and toxicological characteristics. The vapor hazard ratio (VHR) presented in the table is useful for comparing the relative air hazards imposed by different chemicals. The VHR is defined as the ratio (ppra/ppra) of a chemical's equilibrium vapor concentration ae 25°C (computed from vapor pressure data) to its Threshold Limit Value (TLV); the lower the ratio, the lower the potential hazard. For example, if judged on the basis of TLV alone, ethyl ether, with a TLV of 400 ppm, might be deemed safer than 1,2-tr^ns-dichloroethylene, with a TLV of 200 ppm. When volatility is taken into account, it is apparent that 1,2-trans-dichloroethylsne, with a VHR of 2072, represents more of a potential air hazard than ethyl ether, with a VHR of 1711. Presentation of these data should not be interpreted to mean that VHRs have to be determined for the wastes to be land treated. The information provided in the table is for reference only. The primary purpose here is to list the vapor pressure of hazardous constituents frequently handled. 8.1.3.2.5 Toxicity—When biodegradation is relied on to treat wastes and/or a vegetative cover is established during the active portion of the unit, waste application races and frequency must be carefully evaluated to prevent acute and/or chronic toxicity of soil microbes and plant populations. It should be recognized, however, that high intensity applications of inorganic constituents or organic constituents that resist degradation may be applied to the soil. Under these circumstances, treatment is based almost completely on substance immobilization. Under such conditions, the toxic effects of the constituents on soil microbes and vegetative cover are disregarded. 8-53 ------- 2: 3 00 •o s •n 3 0 3.« tf 3^, V w 3 --* 3 1 w . Vt w » 33- e . 3 O l~l -f f\ ,O r>, ^» tn ^0 8-54 ------- id eg ?~t y^L en a* 2 :> en 3 O O >-< 3 H as •< < C&J 33 as en >> M .-J — -3 e-> < -t T4 "^ Z CJ rjj ^£ 5 "** ri, „, ; <; 3^ cj en z a = Q u z O M CJ < z as —4 o § ^ as • ^J Z -™^ c er"J t'J ^i -J a: ai H -T ?N , CO H 1 0 as u -— » £ •3 a. IM O. N S eg flu j= a. u Q a. fl •^ ^^ :> S 1 _ J ^J H a. 5) y *— « ta cj jj oj 4 nj D in a M CM -rt Ofl O U 23 iJ 0 S 0. a. a a. S) -^ S) •* 1) 3 e _, eg u 's ^ CJ C as vO vO ^O*1-'*^^OeO33*^w^^-3^^C>O^^CO^-J^Jp r^ w 0 0 0 « • ^NOu^^OOOO-^^NOO^AOOO— • *T in r*j ^0 ^ ^n f"** r^ ^ ^^ e*o /~* c^t ~* <*> in rvi — •> f~i 41 C j; 4j 41 f 41 41 -a , 4> jcco • Htutg o -a — < 41 eg-H^ (j , .-< -o _< xenOug-<— (OJuu— 'w»-ig--< , J5 r-'OtgCjSCDJ-i^'-'ilUT) UQ U^ (UCj33— «ajoa)'j--i — "OtjO i i- ii aj u •O 41 U —.>,>, TJigCtJ VMOiaiCNOC eg •^OO UH— U»*--'OO4!CCOCC «— 'U'J 10*^ O4JO>\'— U--egOC t. a ycNj;— «••»—< Bw>,uDuj:>,o>,L,ja^aO3N - u >, a x O X *H >» --^ XU-^JSODfOtfljCOfl) *a,^'OtJ to*X>3rQrCX>O'------- 1 3J 3 ,' U U — . S. -3 a, u a. M S flj ^- -c a. -^ o a. •3 ^> S _j a. r- a. i u u M a u «J 3 CS >—s u ^ 2 -3 w .-M •-( i) ' a, a; x 3 i 00 O C! i 5«4 ~ ^4 •H J o 3 a. ~i . a. 3 a. C ^ *™^ eg O > •j -T ,-N • •••i 1 oo j a ' _; | £Q <£ s*"1 ! 01 a e "ip U .•^ B 41 ^ CJ C *0 as O -^ ^1 ^ — » ^O ^J — ' C*> OiN, 0 M QJ ^ »^ 4) J3 «-^ "O •o y js — i ij -3 u >, >, O •-( 4) 1 1) J= JM 4) "4 W O tf) (^ g vvcuuucum ^C014J'"*O{TJil — • ••< ^ 1 C — « k- U (9"O X!M OjC u — .^ u •-( £ . u 0 1 >,4) 4j L4 W ^^ 4) • M CN f^ ««4 U »•> 41 . y U «U'~^— , 4) O O — • -O U — < JZ Xi UP j= -^ O O *J O O y u 3 ^; 4) — « — ' — ' 4) O-4OO>> -£ — C 4;.^vwuUj£ 'JO U c jr o — < o *J --4 •-< N 4) O u <8 — i 0) MLJ C 13 O J3 Ol4)tJ4J4)4) •^— !—•-•«— >^>Nfl) X-1 0-4^4) O >,SO— U — — 'ij - . 3 U j; c--*^"^'^ 41 .— -j ^« 4J 4J4>UO)O)0'C------- -? OJ pa .Jjj u 5 00 _j 33 H 1 0 U .-> S -o a a a j= a. u 0 a. "S 1> S -i a, f- a. u 59 " <8 41 in g i- CN •-* CL <&J X 30 O w S u O g 3. ago. 4> S ^ i- -i o u uo cax4) .a — j ja 4-i « g — « .-4 u •-< — ' *j ,C 4) O — < X — i 1 4;— 'njj;— i--J— ^ ^^ cO y x-fl— "4>o_sj>,e •------- (a) Microbial Toxicity - The likelihood of acute coxicicv occurring can be evaluated oy a review of the Literature or laboratory testing, the latter involving soil respiration experiments to demonstrate the effect of various concentrations or toxic compounds on indigenous soil microbes. Potential chronic effects impartad by long-term waste application and hazardous substance soil accumulation must also be investigated. Determination of chronic toxicity effects by laboratory tests is very time consuming. Consequently, the applicant may refer to the literature to discover the effects of long-term exposure to toxic compounds on soil microbes. Section 7 of the Hazardous Waste Land Treatment manual provides informative discussions •of laboratory cests cnat can be used to determine the effects of acute exposure to hazardous substances and techniques for assessing chronic effects. Note that the microbial toxicity assessment can be made simultaneously with the hazardous constituent J3gradstion/;ransformation dasaoas cra (b) Phytotoxicity - If plants, food-chain or nonfood-chain crops, are to be grown in or on the treatment zone of the land treatment unit during its active life, the permit application should include a demonstration of the effects of waste additions on seed germination and plant establishment and yield. Establishment of a vegetative cover may be part of the unit design to immobilize or transform 'hazard waste constituents or to control soil moisture content and wind dispersal of particulate matter. Demonstration of the effectiveness of this treatment technique may be based on an analysis of the literature, laboratory or greenhouse studies, field tests, and operating data. In addition to demonstrating adequate treatment, the applicant must provide an analysis of plant viability in or on the treatment zone. Greenhouse studies investigating seed germination, root development, and above ground growth can be used to determine acute toxicity effects of plants to be grown during the active period of the treatment unit or following closure. Section 7 of the HWLT manual provides guidance on acceptable experimental procedures and methods of assessing plant viability and potential phytotoxicity. Figure 8.1.6 provides a worksheet that can be used by the permit writer to evaluate the applicant's field test plan to assess whether waste applications will have a toxic affect on soil microbes or vegetative cover. 8.1.4 Draft Permit Preparation If the owner or operator intends to conduct field tests or laboratory analyses to make the treatment demonstration required under §264.272(a), he or she muse obtain a treatment or disposal permit under §270.63. This subsection describes the items to be included in the draft permit as they pertain to the treatment demonstration. Section 4 of this manual presents the Permit Module (XIV) for Land Treatment Facilities which should be used in conjunction with Permit Module (XIII) for the Land Treatment Demonstration to prepare the draft permit for the entire complex. The Treatment Demonstration component (see Module XIII in Section 4) of the draft permit is comprised of the following three conditions: Waste Identification (Condition A), Design and Operating Requirements (Condition B), 3-58 ------- ana Testing dad analytical rroceaures vCondition C). Condition A of Che Permit Module specifies that the Treatment Demonstration -nus t ?a r^acie for :he wastes and potential hazardous constituents in or derived from the wastes to be treated, as identified by the applicant. Note that only those wastes for which it will be demonstrated are completely degraded, transformed, or immobilized are allowed to be treated at the site. If the owner or operator plans Co treat wastes not listed in the application, he or she will have to obtain another permit to demonstrate that they also can be completely degraded, transformed, or immobilized by the land treatment unit. Condition A reads as follows: Waste Identification. The Permittee must conduct a land treatment demonstration in accordance with the requirements of 40 CFR 264.272 for the wastes listed in Attachment . nay field test or laboratory analysis conducted in order to make this demonstration must be likely to show that the hazardous constituents listed in Attachment will be completely degraded, transformed or immobilized in the treatment zone of the existing or proposed land treatment unit. Condition B of the Treatment Demonstration Permit Module XIII stipulates treatment demonstration design and operating requirements when any field test or laboratory analyses are conducted. The draft permit should specify, at a minimum, the following: • the horizontal and vertical dimensions of the treatment zone, » monitoring procedures, * closure and clean-up activities, and • description of conditions that accurately simulate the characteristics and operating conditions for the proposed land treatment unit. Condition B of Permit Module XIII reads as follows: Design and Operating Requirements. The Permittee shall conduct the demonstration in accordance with the requirements pf 40 CFR 264.272(c) as specified in the attached plans and specifications. Condition C of the Treatment Demonstration Permit Module specifies testing and analytical procedures. The condition can be implemented by reference to the applicant's proposed testing and analytical program. To be acceptable for substitution as a written permit condition, the referenced portion of the applicant's submittal should specify the following: • type of test(s), including duration, 8-59 ------- • -aara rid !,5 i.iu ia;.-^U6, including analytical procedures, and • ' expected time for completion of tests and analyses. Condition C oi Permit Module XIII reads as follows: Teating and Analytical Procedures. The Permittee shall conduct the demonstration using the testing and analytical procedures and data sources specified in Attachment in accordance with requirements of 40 CFR 264.272(c). 8-60 ------- .-.a ;arancas 1. U.S. Environmental Projection Agency. Permit Applicants' Guidance Manual for Hazardous Waste Land Storage, Treatment, and Disposal raciiities. Draft Report. Office of Solid Waste, Land Disoosal Branch, Washington, D.C. March 1983. 2. Spyridakis, D. E. , and E. B. Welch. Treatment Processes and Environmental Impacts of Waste Effluent Disposal on Land. I_ii Land Treatment and Disposal of Municipal and Industrial Wastewater, pp. 45-83. Edited by R. L. Sanks and T. Asano. Ann Arbor Sciatica, Ana .^rbor, MI. 1976. 3. U.S. Environmental Protection Agency. Damages and Threats Caused by Hazardous Material Sites. Oil and Special Materials Control Division. Washington, D.C. EPA Report ilO/9-«0-00<.; ITSO. 4. U.S. Environmental Protection Agency. Test Methods for Evaluating Solid Waste Physical/Chemical Methods. U.S. Environmental Protection Agency, Office of Solid Waste, EPA Report SW-846. July 1982. 5. U.S. Environmental Protection Agency. Hazardous Waste Land Treatment, prepared by K. W. Brown and Associates, Inc. for U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, Solid and Hazardous Waste Research Division, Cincinnati, OH. Report Mo. SW-874. 1983. 6. U.S. Environmental Protection Agency. Characteristics of Hazardous Waste Streams. Prepared by K. W. Brown and Associates, Inc. for Municipal Snvironmencai Research Laooratory, Office of Research and Development. Cincinnati, OH. December 1982. 7. Brady, N. C. The Nature and Properties of Soils. 8th Ed. MacMillan Publishing Company, Inc. New York, NY. 1974. 8. Phung, T., et al. Land Cultivation of Industrial Wastes and Municipal Solid Wastes: State-of-the-Art Study. Volume I, Technical Summary and Literature Review. Prepared by SCS Engineers for U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, Cincinnati, OH, EPA Report-600/2-78-140a. August 1978. 9. Overcash, M. R., and D. Pal. Design of Land Treatment Systems for Industrial Wastes, Theory and Practice, Ann Arbor Science. Ann Arbor, Michigan. 1981. 10. Black> C. A., ed. Methods of Soil Analysis, Part 1, Physical and Mineralogical Properties, Including Statistics of Measurement and Sampling, the American Society of Agronomy, Inc., Madison, Wisconsin, 1965. 11. Black, C. A., ed. Methods of Soil Analysis, Part 2, Chemical and Microbiological Properties. The American Society of Agronomy, Inc., Madison, Wisconsin. 1965. 8-61 ------- 12, Van-Cleve, X., et al. A Comparison of Four Methods for Measuring Respiration in Organic Material. Soil Biol. Biochem. 11:237-246. 1979. 13. Minear, R. A., et al. Atmospheric Hydrocarbon Emissions from Land Treatment of Refinery Oily Sludges. Prepared by Radian Corporation for the American Petroleum Institute, Washington, DC. May 1981. 14. Thibodeaux, L. J., and S. T. Hwang. Landfarraing of Petroleum Wastes — Modeling the Air Emission Problem. Snv'r, Prog. 7ol, i, No. i, February 1382. pp. <+2-46. 15. Hwang, S. T. Toxic Emissions from Land Disposal Facilities. Envir. Progr. Vol. No. 1. February 1°82. nn, '-6-5Z* 16. Francke, H. C., and F. E. Clark. Disposal of Oil Wastes by Microbial Assimilation, Oak Ridge National Laboratory. Oak Ridge, IN. UC-11/4-1934, Contract No. W-7406-eng-26. May 16, 1974. 17. Sunoco Corporation, Summary of Results from Che Toledo, Ohio Refinery Landfarm Tests. SUNTSCH Environmental Group, Marcus Hook, PA. pp. 9-<+9, undated. 13. Farino, W., et al. Evaluation and Selection of Models for Estimating Air Emissions from Hazardous Waste Treatment, Storage, and Disposal Facilities, Draft Final Report. Prepared by GCA/Techno logy Division for U.S. Environmental Protection Agency, Office of Solid '.Jaste, Land. Disposal Branch, Washington, D.C. October 1982. 8-62 ------- o.: L.AND IREAIMENT PROGRAM 3.2.1 Federal Requirement As required by §270.20(b), the Part B oersi<: application muse include: "(b) A description of a land treatment program, as required under §264.271. This information must be submitted with the plans for the treatment demonstration, and updated following the treatment: demonstration. The land treatment program must address Che following items: (1) The wastes to be land treated; (2) Design measures and operating practices necessary to maximize treatment in accordance with §264.273(a) including: (i) Waste replication jecnoa ana rate; (ii) Measures to control soil pH; (iii) Enhancement of microbial or chemical reactions; (iv) Control of moisture content; (3) Provisions for unsaturated zone monitoring, including: (i) Sampling equipment, procedures, and frequency; (ii) Procedures for selecting sampling locations; (iii) Analytical procedures; (iv) Chain of custody control; (v) Procedures for establishing background values; (vi) Statistical methods for interpreting results; (vii) The justification for any hazardous constituents recommended for selection as principal hazardous constituents, in accordance with the criteria for -such selection in §264.273(a); (4) A list of hazardous constituents reasonably expected to be in, or derived from, the wastes to be land treated based on wasca analysis performed pursuant to $264.13; (5) The proposed dimensions of the treatment zone." Fulfillment of the requirements of §270.20(b) necessitates compliance with several Part 264 standards. As identified above, §264.271 is Che specific technical standard for the land treatment program. The standard is as follows: "(a) An owner or operator subject to this subpart must establish a land treatment program that is designed to ensure that hazardous constituents placed in or on the treatment zone are degraded, transformed, or immobilized within the treatment zone. The Regional Administrator will specify in the facility permit the • elements of the treatment program, including: (1) The wastes that are capable of being treated at the unit baaed on a demonstration under §264.272; (2) Design measures and operating practices necessary to maximize the success of degradation, transformation, and immobilization processes in the treatment zone in accordance with §264.273(a); and (3) Unsaturated zone monitoring provisions meeting the requirements of §264.278. 8-63 ------- (b) The Regional Administrator vili specify in the facility permit the hazardous constituents that must be degraded, transformed, or immobilized under this subp^rt . '.'azaraous constituents are constituents identified in Appendix '/III of Part 261 of this chapter that are reasonably expected to be in, or derived from, waste placed in or on the treatment zone. (c) The Regional Administrator will specify the vertical and horizontal dimensions of the treatment zone in the facility permit. The treatment zone is the portion of the unsaturated zone below and including the land surface in which the owner ~r operator intends to maintain che conditions necessary for effective degradation, transformation, or immobilization of hazardous constituents. The maximum depth of the treatment zone must be: (1) No more than 1.5 metars <'5 faec) frcsj -:he iniciai soi.i suriaca; and (2) More than 1 meter (3 feet) above the seasonal high water table." Section 264.271(a)(2) states that the owner or operator must design and operate the land treatment unit to maximize treatment in accordance with §264.273(a), which states: "(a) The owner or operator must design, construct, operate, and maintain the unit to maximize the degradation, transformation, and immobilization of hazardous constituents in the treatment zone. The owner or operator must design, construct, operate, and maintain the unit in accord with all design and operating conditions that were useH in ;he treatment demonstration under §264.272. AC a minimum, the Regional Administrator will specify the following in the facility permit: (1) The rate and method of waste application to the treatment zone; (2) Measures to control soil pH; (3) Measures to enhance microbial or chemical reactions (e.g., fertilization, tilling); and (4) Measures to control the moisture content of the treatment 11 Section 264.271(a)(3) states that the owner or operator must meet the unsaturated zone monitoring requirements of §264.278. This section requires that: "(a) The owner or operator must monitor the soil and soil-pore liquid to determine whether hazardous constituents migrate out of the treatment zone. (1) The Regional Administrator will specify the hazardous constituents to be monitored in the facility permit. The hazardous constituents to be monitored are those specified under §264.271(b). (2) The Regional Administrator may require monitoring for principal hazardous constituents (PHCs) in lieu of the constituents specified under §264.271(b). PHCs are hazardous constituents contained in the wastes to be applied at the unit that are the most 3-64 ------- difficult ".: : :2.;_ :cr._ __^ r-.".o -•"•= ooaioinea erreccs of degrada c ion , crans format ion, and immobilization. The Regional Administrator will 'establish PHCs if he finds, based on waste analyses, treatment demonstrations, or other data, that effective degradation, transformation, or immobilization of the PHCs will assure treatment at at least equivalent lavels for the other hazardous constituents in the wsates. (b) The owner or operator must install an unsaturated zone monitoring system that includes soil monitoring using soil cores and soil-pore liquid monitoring using devices such as lysimeters. The unsaturated zone monitoring system must consist of ^sufficient number of sampling points at appropriate locations and depths to yield samples that: (1) Represent the quality of background soil-pore liquid quality and the chemical make-uo of soil that has not been affected by laakaga from ;ne treatment zone; and (.2) Indicate the quality of soil-pore liquid and the chemical make-up of the soil below the treatment zone. (c) The owner or operator must establish a background value for each hazardous constituent to be monitored under paragraph (a) of this section. The permit will specify the background values for each constituent or specify the procedures to be used to calculate the background values. (1) Background soil values may be based on a one-time sampling at a background plot having characteristics similar to those of the treatment zone. (2) Background soil-pore liquid values must be based on at least quarterly sampling for one year at a background plot having characteristics similar to chose of the treatment zone. (3) The owner or operator must express all background values in a form necessary for the determination of statistically significant increases under paragraph (f) of this section. (4) In taking samples used in the determination of all background values, the owner or operator must use an unsaturated zone monitoring system that complies with paragraph (b)(l) of this section. (d) The owner or operator must conduct soil monitoring and soil-pore liquid monitoring immediately below the treatment zone. The Regional Administrator will specify the frequency and timing of soil and soil-pore liquid monitoring in the facility permit after considering the frequency, timing, and rate of waste application, and the soil permeability. The owner or operator must express the results of soil and soil-pore liquid monitoring in a form necessary for the determination of statistically significant increases under paragraph (f) of this section. (e) The owner or operator must use consistent sampling and anal/sis procedures that are designed to ensure sampling results that provide a reliable indication of soil-pore liquid quality and the chemical make-up of the soil below the treatment zone. At a minimum, the owner or operator must implement procedures and techniques for: 3-65 ------- v;.; Sample collection; (2) Sample preservation and shipmenc; (3) Analytical procedures; and (b.) Chain of custody control. (f) The owner or operator must determine whether there is a statistically significant change over background values for any hazardous constituent to be monitored under paragraph (a) of this section below the treatment zone each time he conducts soil monitoring and soil-pore liquid monitoring under paragraph (d) of this section. (I) In determining whether a statistically significant increase has occurred, the owner or operator must compare the value of each constituent, as determined under paragraph (d) of this section, to the background value for that constituent according >:o the staEijticsl procedure .specified in the facility permit under this paragraph. (2) The owner or operator must determine whether there has been a statistically significant increase below che treatment zone within a reasonable time period after completion of sampling. The Regional Administrator will specify that time period in the facility permit after considering the complexity of the statistical test and the availability of laboratory facilities to perform the analysis of 3OJ.1 and soil-pore liquid samples. (3) The owner or operator must determine whether there is a statistically significant increase below the treatment zone using a statistical procedure that provides reasonable confidence that migration from the treatment zone will be identified. The Regional Administrator will specify a statistical procedure in the facility permit that he finds: (i) Is appropriate for che distribution of the data used to establish background values; and (ii) Provides a reasonable balance between the probability of falsely identifying migration from the treatment zone and the probability of failing to identify real migration from the treatment zone. (g) If the owner or operator determines, pursuant to paragraph (f) of this section, that there is a statistically significant increase of hazardous constituents below the treatment zone, he must: (1) Notify the Regional Administrator of this finding in writing within seven days. The notification must indicate what constituents have shown statistically significant increases. (2) Within 90 days, submit to the Regional Administrator an application for a permit modification to modify the operating practices at the facility in order to maximize the success of degradation, transformation, or immobilization processes in the treatment zone. (h) If the owner or operator determines, pursuant to paragraph (f) of this section, that there is a statistically significant increase of hazardous constituents below the treatment zone, he may demonstrate that a source other than regulated units caused the increase or that the increase resulted from an error in 3-66 ------- 3 amp l^ng, _ir.3./L_j, ,.- = v2j.odc .on. ^ni^e t.ie owner or operator m make a demonsCracion under this paragraph in addition to, or in 1 of, submitting a permi: aodificacion application under paragraph (g)(2) of this section, he is not relieved of the requirement to submit a permit modification application within the time specified in paragrapn (gA2) or this section unless the demonstration made under this paragraph successfully shows that a source other than regulated units caused the increase or that the increase resulted from an error in sampling, analysis, or evaluation. In making a demonstration under this paragraph, the owner or operator must: (1) Notify the Regional Administrator in writing within seve days of determining a statistically significant increase below the treatment zone that he .intends to make a determination under this paragraph; (2> Wicnin 90 aays, submit a report to the Regional Administrator demonstrating that a source other than the regulated units caused the increase or that the increase resulted from error in sampling, analysis, or evaluation; (3) Within 90 days, submit to the Regional Administrator an application for a permit modification to make any appropriate changes to the unsaturated zone monitoring program at che facility; and (4) Continue to monitor in accordance with the unsaturated zone monitoring program established under this section." 3.2.2 Summary of Necessary Application Information 8.2.2.1 Wastes for Land Treatment Program— The application should contain a listing of all hazardous wastes, hazardous constituents, and pertinent aonhazardous constituents that will be or currently are (for existing facilities) applied in or on the treatment zone(s) of che subject land treatment facility. 3.2.2.2 Waste Application Rates and Methods— Part 1 - For each waste constituent listed in Section 8.2.2.1, the applicant should assess its application limit (AL), rate limit (RL), and capacity limit (CL). EPA1s Permit Applicants' Guidance Manual^ recommends that chis information be presented in the format provided in Table 8.2.1. Part 2 - For each waste constituent identified in Section 3.2.2.1, list respective waste concentrations and quantity required (as per hectare basis) to reach each constituent's AL, RL, and CL. Table 8.2.2 shows the recommended format for presenting this information. An asterisk or other footnote should be used to identify application limiting constituent (ALC), rate limiting constituent (RLC), and capacity limiting constituent (CLC). Part 3 — The application should include a monthly application schedule based on the following: • application limiting constituent, 8-67 ------- TABLE 8.2.1. FORMAT FOR REPORTING APPLICATION, RATE, AND CAPACITY LIMITING CONSTITUENTS Wasce Constituent Limit Value Discuss ion Phenol AL RL 1.1 x 103 kg/ha 70 kg/ha/vr Concentration _>_5GO ag/kg soil are phytotoxic and inhibit microbial activity Optimum degradation rate is 70 kg/ha/yr Lead AL RL r* T None None 2.2 x 10- rcg/fta Not to exceed 1000 mg/kg TABLE 8.2.2. FORMAT FOR IDENTIFYING LIMITING CONSTITUENTS (ALCs, RLCs, AND CLCs ARE MARKED WITH AN ASTERISK) U-a a f A was ce Constituent 1. Water" 2. Phenol 3. Lead Concentration in Wast a (mg/kg) 8.5 x 1Q5 200 500 Amount of Waste to Reach AL kg/ha /Application 5.6 x 106* N/A Amounc of Waste to Reach RL kg/ha/yr 3.53 x 106 3.5 x 105* N/A Amount of Waste to Reach CL kg /ha N/A N/A 4.5 x 103* N/A, not applicable. Pertinent nonhazardous substance. 8-68 ------- \ * race limiting conscicuenc, • capacity limiting constituent, • waste generation rate, • seasonal restrictions on application, • expected life span of unit, and • waste application -sethod. Table 3.2.3 shows the recommended format for presenting the waste application schedule. ?art 3 - The application should contain a description of waste handling and application methods that includes the following: • methods and frequency of waste collection and transport, • location, type, and capacity of onsite storage containers, • waste application equipment, • application restrictions (e.g. weather, rate of degradation), and • plot configuration (plot rotation). 8.2.2.3 Measures co Control Soil pH— The following information addressing the control of traataent sone soil pH should be presented in the permit application: • current or antecedent soil pH (mean and range) of treatment zone, • minimum and maximum treatment zone soil pH values that promote maximum degradation, transformation, or immobilization, and • description of soil monitoring scheme and amendment procedures to control treatment zone soil pH at optimum levels. 8.2.2.4 Measures to Enhance Microbial or Chemical Reactions— The applicant should describe how the treatment zone(s) will be conditioned to enhance microbial or chemical degradation, transformation, or immobilization of hazardous constituents applied with or derived from wastes placed in th« land treatment unit. 8.2.2.5 M**«ures to Control Soil Moisture in the Treatment Zone— Estimate* of expected monthly waste gains and losses at the land treatment unit should be included in the application. Procedures for estimating or data sources for each of the following should be described in 8-69 ------- TABLE 8.2.3. EXAMPLE WASTE APPLICATION SCHEDL*L£ Number of Hectares (ha) [•ioucniy rfasce Receive Wasce Application Generation Rate Applications Rate Month kg/month ha kg/ha/month January February March April May June July August September October November December TOTALS kg/yr ha xg/ha/year Total Amount of Available Land: ha Expected Life Span of the Unit: years Expected total Quantity of Waste Applied per ha: kg/ha 8-70 ------- cne application: precipitation, avapocranspiracion, run-off, percolation, irrigation needs, and storage requirements. All support calculations and assumptions should be included in the application. 8.2.2.6 Unsaturated Zone Monitoring— Under.1270.20(b)(3) the applicant La required to submit an unsaturated zone monitoring plan that will demonstrate compliance with the requirements of 5264.278. At a minimum, the plan should address the following nine parts. Unsaturated zone monitoring is required for each plot placed in service. Part 1 - Sampling location - On a scale drawing of the land treatment unit, the applicant should show the location and depth of soil-pore liquid sampling devices and locations and depths for taking soil samples. Part 2 - Sampling frscuency - A jcnedule identifying the sampling frequency of tne soil-pore liquid and soil below the treatment zone should be included in the permit application. Factors affecting sampling frequency such as waste application rate, waste application schedule, climatic factors, and the hydraulic conductivity of the treatment zone should be addressed by the applicant. Part 3 - Sampling equioment - The applicant should identify and describe the equipment (.including procedures and materials) that will be used to obtain both soil core samples and soil-pore liquid samples. Part 4 - Equipment installation - A step-by-step description of the procedure used for installing soil-pore liquid monitoring devices should be included in unsaturated zone monitoring plan. Part 5 - Sampling procedures - Explain in a step-by-step fashion how samples of soil-pore liquid and soil will be obtained using the equipment described above. The number of samples taken at each sampling event, as well as compositing procedures, if used, should be described. Part 6 - Analytical procedures - Analytical procedures that will be used to determine the concentration of each hazardous constituent in collected samples and the name of the laboratory chat will perform the analyses should be identified in the application. Part 7 - Chain-of-custody control - The applicant should explain in a step-by-step fashion the plan for maintaining chain-of-custody control throughout sampling, transportation, analysis, and reporting. Part 8 - Background - A detailed description of the procedures for determining both soil background and soil-pore liquid background values, including the location and depth of background samples, sampling procedures, analytical methods, and results should be contained in the application. Part 9 - Statistical methods - The statistical methods that will be used to determine a significant difference between background sample concentration and monitoring sample concentrations for both soil and soil-pore liquids must be included in the unsaturated zone monitoring plan. 8-71 ------- (a) Time Period for Determining Increases Over Background - In accordance wth §264.278(f)(3), Che applicant must submit results that show a significant increase over background values within a reasonable ciae frame. (b) Principal Hazardous Constituents - The applicant can elect to monitor only principal hazardous constituentsTPHCs) instead of all hazardous constituents listed in Section 8.2.2.1. If this is the case, the application should identify the PHCs and supporting justifying documentation. 8.2.2.7 Treatment Zone Description— A description of the dimensions and soils of the treatment zone including each of the following four Parts should be submitted in the permit application. Part 1 - Soil survey - A mao ~.r plot plan of the land treatment unit that delineates Che horizontal boundaries of the treatment zone(s) and labels the series classification of the soils contained therein should be included in the application. Part 2 - Series descriptions - Soil series descriptions should be submitted that include the following information (this applies to undisturbed native soils, disturbed soils, fill materials, or previously waste-treated soil): • soil profile description, • physical setting with slope and climatic data, • mineralogy, • land use and vegetation cover, • estimated soil properties including: USDA texture shrink-swell potential Atterburg limits erosion factors permeability flood frequency and duration available water capacity depth of seasonal high water pH table salinity frost action potential Part 3 - Results of soil sampling and analysis - The applicant should submit the results of analyses of the soils within the treatment zone. The submittal should also include sample location, collection and preparation, and analytical methods. Table 8.2.4 presents the recommended format for reporting results of soil sampling and analysis. Part 4 - Depth of treatment zone - For each plot of the treatment unit, the applicant mu*t specify the dimensions of its treatment zone. Vertical dimensions should be expressed in meters below the initial soil surface and meters above the seasonal high water table. 8-72 ------- CO yj ^ ~ 1 ^ ** O "a. z a ?— * *s ^ ^( f f\ -iJ ..* => -3 a CO •&J C £ rj co •si aJ :C 5"1 O z f . ^ 0 o- u £ H 5 QJ p B ^ • ^ oo M «§ 6-1 41 a V • — u U] 4J 2 3 — * ^ J) *y "3 | ^ >» "S s * 09 V 4J 1 u nj O. a o ti U S S •- 3 -1 = MP4M »~«3 3 i-« S M 3 fl = awuu <-i a. wa. jZ J2 jZ JZ^joO 30 « ^2630303 3A ^XMf* S AO ^3M?^^< 4 V " 41 ' — DOO «-«3 -S 3X--13 OT3 U u X --. 3TJ - U«X 3"O H3 30O«T3 Uo w OOO k" 3 w^ ti*^ "so ^j- fl u-o w^: u a -5u-j3w v a 3 «--j uu - = «a3-jj -s - naa -r ~J M4 nX^U 1 a* U4 u uvco u v} 1)4; u 3»D t3Sw •< !03J *^S*J «-J 3iw vO'sg.tj -1— 3 ^3^ -ji — — '3 43)3-— — • S •— OJC03 -«~ us i. •• •* XwS *j uX w 3 w •" a. 3 •- u 3 "- '>euu "- yj- -0 u •- o a 3 v< o. •-. 3 u « UKO "i O -j u -n •-> 3 a) w .- 3 ^ ... a T> ro ii e a u -o cj a 41 OUC3 U S _O 0 a •- e j: u - i s ..« <» * 8-73 ------- i._.j Juiaanca jn Evaluating Application Information The applicant must develop a land treatment program chat is designed ensure that hazardous constituents placed in or on che treatment zone are degraded, transformed, or immobilized in the treatment zone. Figure 8.2.1 identifies the required components of the land treatment program. Establishment of operating conditions and work practices should be based on results obtained from the treatment demonstration. 8.2.3.1 Wastes for Land Treatment Program— Evaluation of the wasceCs) capaole of being treated by the land treatment unit should be based on the results of the treatment demonstration. Wastes containing hazardous constituents that have been shown to be completely degraded, transformed, or immobilized under the treatment demonstration can je disposed of. at fh*» pr?poaad or existing unit, as the case may be. If the owner or operator demonstrates similarities, specifically with respect to hazardous constituents between broad classes of waste, it may not be necessary to require analysis of each batch of waste that might be handled at the unit. Figure 8.2.2 presents a worksheet to assess the completeness of the information provided by applicant with respect to wastes that are or will be treated at the facility. 8.2.3.2 Waste Application Rates and Methods — Determination of waste loading rates should be based on three factors. These factors are the rate limiting constituent (RLC), application limiting constitutent (ALC), and capacity limiting constituent (CLC). The rate limiting constituent is the chemical substance or compound that controls yearly loading rates. The application-limiting constituent is the substance that restricts the amount of waste chat can be spread in a single application^ although it may be rapidly degraded, transformed, or immobilized. The third restricting factor, capacity limiting constituent, is an accumulating substance, such as a heavy metal, that sets the upper boundary for the total quantity of waste that can be applied at the site. The CLC controls the maximum design life of che treatment unit. Section 7 of che HWLT manual2 provides an informative discussion on how these three factors are determined based on the composition of che wastes Co be applied. Appendix E of the HWLT manual provides sample calculations to determine each value for a given waste. Table 8.2.5 categorizes primary waste constituents with respect to their potential application, rate, and capacity limiting characteristics. The HWLT manual also provides a technique for assessing constituent degradability as it relates to limiting application rates and frequency. Two management scenarios are discussed, one involving che maintenance of a plant cover over the active treatment zone, and the second addressing systems designed to function without a vegetative cover. Table 8.2.6 presents the computations that are required to determine the number of applications that are acceptable under either scenario, based on the expected degradability of the most persistent constituent. 8-74 ------- LAND TREATMENT PROGRAM • Waste for Land Treatment Program 3 Vasca Application Rat^s and detnoas • Measures Co Control Soil pH • Measures to Enhance Microbial or Chemical Reactions • Measures to Control Soil Moisture in Treatment Zone • Unsaturated Zone Monitoring • Treatment Zone Description Figure 8.2.1. Components of the Land Treatment Program. 8-75 ------- WASTES FOR LAND TREATMENT PROGRAM Is the following information provided for each waste being or to be land treated? YES MO Part 1 Waste Name Waste Generating Process or Source Monthly or Annual xusncity Handled EPA Hazardous Waste ID Number (if applicable) Part 2 Name(s) of Pertinent Hazardous Constituents Name(s) of Pertinent Nonnazardous Constituents Part 3 Concentration of Each Hazardous Constituent Volatility of Each Hazardous Constituent Percent Water Specific Gravity or Bulk Density PH Electrical Conductivity Total Acidity or Alkalinity Total Organic Carbon Figure 8.2.2. Worksheet for evaluating completeness of description of wastes for land treatment program. 8-76 ------- TABLE 3.2.5. WASTE COMPONENTS TO 3£ CChPARED IN DETERMINING APPLICATIC RATE, AND CAPACITY LIMITING CONSTITUENTS3(2) Potential Constituenc ALCb Organics X - Volatilization X - Leaching X - Degradation Waterc X Metals Nitrogen0 X Phosphorus0 Inorganic Acids, Bases, and Salts Halides Potential RLC X X X X Xd X X X Potanti CLC X X X X aThe actual comparison should be tabulated similarly, but using calculated loading rates and capacities in place of the X's. The lowest value under ea category corresponds Co the respective limiting constituent. ''Depending upon prevailing site conditions, the ALC may vary seasonal-/. cAlthough these constituents are not considered hazardous, they may be the ALC, RLC, or CLC for the treatment unit. "^Metals may be the RLC when biodegradation is relied on for waste treatment and/or when a vegetative cover is maintained during active life. Elevated metal concentrations may be toxic to soil microbes and plants. 3-77 ------- TABLE 3.2.6. COMPUTATION OF NUMBER OF APPLICATIONS PER YEAR BASED ON ORGANIC CONSTITUENT DEGRADATION (ADOPTED FROM REFERENCE 2) Scenario A Whan vegetation it a part of operational management, toxic organics nay limit ch« loading rate. Loading races Bust be constant 30 chat che design facility area i* adequate to handle each year's waste production. The following equa- tion applies: ^ Cl/2 where Cvr " the race of aopl icat ion of :iie -oapound ar ..raccion of interest co son (kg/ha/yr) ; ccnt " the critical concentration of the compound or fraction in soil at which yield reductions occur (kg/ha); and cl/2 * half-life (yr) • C (2) Then LA • -g- w where LR • loading rate (kg/ha/yr) and Cw » concentration of che compound or fraccion of interest in the bulk waste (kg/kg.). If ti/2 is less Chan one year, Chen che year's loading rate should be applied in 00 re Chan a single dose as follow*: Let 1/C1./2 * cne smallest integer -/tl/2 ^ Then MA where NA * number of application* per year Scenario 8 When a vegetation cover is desired only after sice closure Begins, chen applications of wa«te nay grsaciy exceed ch« toxicity threshold value. The only constraint would be that the site oust have a final vegetative cover after a given number of years following the beginning of closure. Calcula- tions are as follows: 14) where C^^ • aaximua allowable concentration of the compound or fraction of interest applied co the soil (kg/ha); n • timber of years between final waste application and crop esta- blishment (yr} ; and cl/2 " half-life (yr) . Substituting CgAX for Ccric in equation I, the loading rate can be calcu- lated using equation 2. 8-78 ------- Figure 3.2.3 presents a worksneet chat can be used co assess whether all of the information requested under Section 3.2.2.2 has been submitted in the application. Table 8.2.7 identifies the advantages and disadvantages of various waste application nsethods. Method of application should be thoroughly reviewed to determine that all disadvantages associated with the application technique to be employed have been addressed by the applicant and ways to minimize their negative impact (e.g. potential increased run-off) on the operation of the unit will be instituted. Climatic conditions and geographical latitude will affect the rate of degradation and thus application rates and frequency. During the winter months and periods of excessive rainfall, the rate of biological degradation will slow down. *.lso. application rates are expected to be lower in the northern climates compared to southern latitudes. Figure 8.2.4 can be used to make a preliminary estimate of the number of days that waste application should be suspended based on geographical location. Contingency arrangements should be made for waste storage when waste application is suspended. Storage facilities will also be necessary when equipment breakdown occurs. The permit application 3hould contain a. description of the waste handling activities to be performed when waste disposal is suspended or interrupted. Note that storage of hazardous wasces in containers or tanks are subject to the permit requirements of Part 270 and technical standards of subparts I and J of Part _64, respectively. If storage of the waste is not feasible, alternate disposal methods such as placement in waste piles, surface impoundments, or a landfill may be praccicad. Disposal in any of these alternate facilities mandates conformance with the requirements of the applicable subpart of Part 26------- RATE AND METHODS OF WASTE APPLICATION . Has Che applicant listed respective rate limiting, appli- cation limiting, and capacity limiting concentrations for Yes No each hazardous constituent? Has the rationale for determining each limit been provided? Yes No Has the necessary quantity of waste applied per hectare to reach constituents respective RL, AL, and GL been Yas No submitted? Has the applicant suomitted a monthly waste application schedule? Yes No Are the methods and frequency of waste collection and _____ transport described? Yes No lias che applicant described che location, type, and _ capacity of waste storage units associated with the Yes No land treatment unit? Is waste application equipment described? _____ Yes No Have restrictions on waste application been described? ______ Yes No Has the applicant described the planned plot configuration? Yes No Figure 8.2.3. Worksheet for assessing completeness of applicant's waste application rate and methods. 8-80 ------- TABLE 3.2.7. ADVANTAGES AND DISADVANTAGES OF VARIOUS SYSTEMS APPLICATION"1 Advantage! Disadvantages I. Surface application a.) spraying low labor requirement, low land preparation, wide selection or equiaaent, operates on rougn or wee Land b) overland flow or controlled flooding low labor, low land preparation, operate! on wet land -1 ridge and furrow rather simple system with low capital outlay, reasonably flexible, low "lergy requirement d) tank truck surface spreading low overhead, flexible, easily ragulated application rate [I. Subsurface application Mixing of sludge and loil, low odor and ponding problem*, !*•• chance of runoff contamination III. Surface spreading and nixing of dewatered sludge Can u«e conventional equipment, can apply at higher rate*, doe* not cauae flooding and ponding and aaaociated problems clogging of nozzles. power cor pumpa, .lerosoi police'.on, must flush pipe when stopping application clogging of pipes and perforations, poor atstribution over i given area or field due to slope and I solid in sludge, limited rsapplication, potential odor, auaC flush pipea when stopping application can only use sludge* with -« or -=»*, only United reapplication po»*ibl«, sol.da settle out «c heada of furrow*, needs well prepared site with slop* of only 1/2 to 1-1/22 ponding and odor problem*, deteriorates soil structure, not good under wet soil condition* limited in wet weather • need storage or alternate application ayitea, damage* soil structure resulting in compaction, high bulk density, and low infiltration complex management, require* specialized equipment, cannot be uaed in wet soil high energy co*t to dry the sludge, high operational coat* to dry and »ppiy. difficult to achieve uniform application •(Adapted from KWL" aanual. U.S. EPA, EPA Report SU-874, (2}j. 8-81 ------- O L. — C C 5J u •— (j O) ------- TABLE 3.2.3. SUMMARY OF L/iND TREATMENT EXPERIENCES IN THE HYDROCARBON PROCESSING INDUSTRY (5,6). Waste Applied: Application Method: Application rates: Frequency of application: Percent oil in soil following application: Optimum soil moisure content: Run-off collection and handling: Oily sludge including API separator sludge, DAF float, biosiudge, and tank bottoms surface spreading or subsurface injection (15-20 cm) 100 to 120 barrels/acre/application, wich a .naxijiuia or 2uO barrels under optimum conditions (e.g. climate, soil moisture, degradation) monthly, up to a total of eight times per year 5 to 10, vith a maximum of 20 15 to 20 oercent analysis of collected runoff reveals high oil and grease content such that liquid must oe treated prior to discharge or can be reappiied to treatment zone during dry periods 3-83 ------- The amount of land area required for -a jite can oa calculated as follows PR Required treatment area (Ha) * 7-5 - LRRLC Where PR * waste production or handling rate (kg/yr); and LR_ „ * waste loading rate jased on the rate limiting constituent ru'° RLC (kg/ha/yr) ha Exaraple: * 26,400 (k If the required land area is greater than the area available for treatment, then the proposed facility cannot accommodate all of the waste that is produced or expected to be handled by the site. The maximum number of annual applications is based on Che rate limiting constituent (RLC) and the application limiting constituent (ALC), and is computed as follows: LR Annual number of applications * — - 3 the smallest integer —— AL ~~ Ait Where LR^C = waste loading rate based on the RLC (kg/ha/yr); and AL * application limit based on the ALC (kg/ha/application). 26,400 (kg/ha/yr) : 5.280 Determination of facility life is based on accumulation of the capacity limiting constituent (CLC) and loading rate of the rate limiting constituent (RLC). Expected facility life can be calculated as follows: LCAPCLC Facility life (years) 3 —7-3 - LRRLC where LCAP a waste loading capacity beyond which the CLC will exceed allowable accumulations (kg/ha); and LR * waste loading rate based on the RLC (kg/ha/yr). , i 264,000 (kg/ha) _ . . B«-»U! 26.400 (kg/ha/yr)' 10 yea" If the RLC is also the CLC, then the facility life is 1 year. To increase facility life the applicant must increase the available land area proportionately. 8-84 ------- It should be recognized ChaC waste application methods and rates employed by facilities maintaining a vegetative cover uuring the unit's active life will differ considerably from land treatment units choosing not to escaolish a plane cover. Factors influencing the selection of the waste application method are: * plant tolerance to physical disturbance, • detrimental effect of ^asCa applied jn exposed vegetative matter, and • impact on plant root system. The decision to establish i plant ;over 'e.g., fooa-chain crops} aay be based on two separate functions or a combination of both. Vegetative cover can serve to 1) protect the surface soil from erosion, or 2) cycle and treat the waste material applied to the treatment zone. Table 8.2.9 identifies the specific functions a vegetative cover can provide and alternative management techniques that can be instituted in cases when it would be inappropriate to maintain a vegetative cover. The HWLT manual has identified the following concerns which may preclude establishment of a vegetative cover: (1) Maintaining concentrations of waste in soil which are not phytotoxic may limit the allowable waste application rates to levels far below the soil's capacity to treat the waste, thus underutilizing the treatment capacity of the site. (2) Where wastes are applied by spray irrigation, hazardous constituents may adhere to vegetative surfaces. (3) A crop cover may filter ultraviolet radiation which could have aided in the photochemical decomposition of certain compounds. Many factors will affect the successful establishment of a vegetative cover. These factors are essentially the same as those to enhance of microbial activity (see Section 8.2.3.4). However, the principal concern with respect to growth in or on the treatment zone is phytotoxicity, primarily resulting from heavy metal accumulation. Table 8.2.10 provides a limited compilation of the normal range of trace element concentrations found in plant leaves and identifies levels that are toxic. The information presented or similar data obtained from other sources should be used together with a review of the type and rate of hazardous constituents to be land treated at the proposed site to identify potentially phytotoxic conditions. Plant species selection will depend on existing and altered soil conditions, local climate, and intended function of vegetative cover. Plant species selected by the applicant should be evaluated with respect :o growth potential and ease of maintenance. This is best accomplished by consulting regional agronomists from the State Agricultural Extension Service of the U.S. Department of Agriculture or the agronomy department of nearby college or universities. 8-85 ------- TABLE 8.2.9. ALTERNATIVE MANAGEMENT TECHNIQUES TO REPLACE THE ROLE OF CROP COVER IN A LAND TREATMENT SYSTEM3 Plant function Alternative .nanagement Protective: Wind aroaion Water erosion Maintain a moist soil surface. Wastes often provide the necessary stability when mixed with the soil. Minimize slopes and use proper contouring to reduce water flow velocities. Some wastes, such as oily sludges, repel water and stabilize the soil against water effects. Design run-off catchments to account for increased sediment load. Run-off water may need some form of treatment before release into waterways. Cyc1i ng: Transpiration Removal 3ewacer the waste. Control applications of wastewater to a lower level. Plants have only a very minor role in this respect; for organics, manage for enhanced degradation; for inorganics, reduce loading rates. aAdapted from HWLT manual(2). 3-86 ------- TABLE 8.2.10. NORMAL RANGE AND TOXIC CONCENTRATION OF TRACE ELEMENTS IN PL ANTSa Concentrations Element A3 B 5a 3e Cd Co Cr Cu F Fe HS I Li Mn Mo Ni Pb Se V Zn of Elements in Range 0.01 - 5 - 10 - 1 - 0.2 - 0.01 - 0.1 - 4 - 2 - 20 - 0.001 - 0.1 - 0.2 - 15 - 1 - 0.1 - 0.1 - 0.02 - 0.1 - 15 - Plant Laavaa ' i.O 30 100 40 0.3 0.30 1.0 15 20 300 0.01 0.5 1.0 150 100 1.0 5.0 2.0 10.0 150 o c m 0 ry We i g n t / Toxic >10 >75 — >40 5 - 700 200 10 - 20 >20 20 - 1500 — >10 >10 50 - 700 500 - 2000 >1000 50 - 200 Low plant uptake 50 - 100 =•10 500 'Adopted from HWLT manual (2) (see Reference 2 for original citations). 8-87 ------- 8.2.3.3 Measures Co Control Soil pH— Soil pH is a. controlling factor j.n determining the nobility and solubility of many hazardous constituents and plant nutrients and will influence soil microbial activity. The pH value expresses the degree of acidity or alkalinity of a soil. The Soil Conservation Service has classified soil pH values as follows: Extremely acid Below 4.5 Very aCrongj./ acid <+. 5-5.0 Strongly acid 5.1-5.5 Medium acid 5.6-6.0 Slightly acid 6.1-6.5 Neutral 6.6-7.3 Mildly alkaline 7.4-7,8 Moderately alkaline 7.9-8.4 Strongly alkaline 8.5-9.0 Very strongly alkaline 9.1 and higher A soil pH in the range of 6.0 to 8.0 la considered optiiaal for organic compound biodegradation and heavy metal precipitation with subsequent colloid adsorption (7-11). It is noted that certain hazardous constituents (e.g., selenium) are more available to plants in neutral pH soils than in acids soils. Consequently, the availability and mobility of hazardous constituents to be treated should be evaluated under various soil pH conditions prior to actual application. This determination should be made . under the "raatment demonstration. Management of soil pH consists of three components: • Initial determination of antecedent soil • Periodic monitoring • Addition of soil amendments to maintain optimum pH range Soil sampling and analysis should be performed periodically to monitor changes in soil pH and to predict the need for conditioning. Section 8 of the HWLT manual provides a discussion on the management of soil pH. The manual identifies three common methods for measuring soil pH. They are: (1) Titration with base or equilibration with lime, (2) Leaching with a buffered solution followed by analysis of the leachate for the amount of base consumed by reaction with the soil, and (3) Subtracting the sum of exchangeable bases from the cation exchange capacity (CEC). The_JEPA TRD (SW-846) Tests Methods for Evaluating Solid.JVaste-Physical/ Chemical Methods^ should also be reviewed to evaluate the applicant's sampling and analysis protocol. 8-88 ------- The following discussion identifies raechods of controlling soil pH. The most frequently encountered situation will be to reduce soil acidity, Reduction of Soil Acidity The most common method of raising the pH of an acidic soil to the neutral level is liming. Liming is a comprehensive term which includes the addition of oxides, hydroxides, or carbonates of calcium or -aagnesiua. liae application rated will vary depending on the kind of lime to be used. The relative effectiveness of the three forms in raising soil pH are roughly in the ratio 1 ton of representative finely ground limestone to 0.7 ton of commercial hydroxide to a little over 0.5 ton of reorasentative oxide. I: LJ important to note thaC initial applications will be the heaviest. Once the desired pH level has been achieved, periodic liming at reduced loadings will be required to maintain a neutral medium. The frequency of liming will increase in regions where water percolation is high such as in humid Eastern sections of the U.S. and in arid locations that will require frequent irrigation to control soil moisture content. In both of these environments calcium and magnesium are leached from the soil, increasing its acidity. Alchough derived from agricultural experiences, Figure 8.2.5 provides a general guide to determine the amount of lime to apply to raise a soil pH to a desired value. The data presented are for the plow zone (15 to 23 cm). When the entire depth of the treatment zone, up to 1.5 meters, will be used to treat the wastes, the applicant must employ techniques that will ensure the maintenance of proper soil pH levels throughout the entire depth of £he craatment zone. This will require the incorporation of lime at depths lower than the conventional plow zone. Techniques that may be used include aurfaca liming with subsequent deep plowing co a depth greater than the conventional 23 cm plow depth or for small plots possibly excavating the top surface layer and applying a layer of lime well within the treatment zone itself. The U.S. Soil Conservation Service or the local agricultural extension service should be consulted for specific assistance in evaluating an applicant's soil pH management program. Intensification of Soil Acidity Although the need to intensify soil acidity will not occur often, there may be situations where it will be required. The reduction of soil pH or increase in acidity can be accomplished by: 1. addition of acid organic matter to the treatment zone soil, 2. addition of chemicals, or 3. application of acidic but compatible waste(s). Note that records should be kept of all soil additions to ensure that the assimilative capacity of the soil will not be altered or diminished. 8-89 ------- 7.0 X & OM(%) CEC (a)Sands (b) Sandy loams (c) Loams and silt loams 'd)Silty cioy loams 2.5 3 5 12 18 23 12 3456^89 GROUND LIMESTONE REQUIRED TO RAISE SOIL pH TO 7.0 (fons/acrt) Figure 8.2.5. Relationship between soil texture and che amount of limestone required to raise the pH of New York soils to 7.0. Representative organic matter (OM) and cation exchange capacity (CEC) levels are shown. Note that pH refers to conventional plow zone soil (15 to 23 cm). [Adopted from Reference 7,. 3-90 ------- Use of Acid Organic Matter The decomposition of soil organic matter forma both organic and inorganic acids. The presence of organic acids, such as carbonic acid (HoCC^), causes Che dissolution of limestone or calcium carbonate resulting in the removal of the bases by solution and leaching. Inorganic acids formed, such as H9S04 and HN03, are sources of hydrogen ions which increase soil acidity. Sources of acidic organic matter are pine needles, tanbark, sawdust, and peat. Sewage sludge is another 3ourca of organic matter. Use of Chemicals When use of acid organic uattar \3 tot acceptable, chemicals such as ferrous sulfate, aluminum sulfate, or other salts may be used to lower soil pH. The salt is hydrolyzed in the soil to form a strong acid (e.g. sulfuric acid) which drastically lowers the pH. Another compound used to lower pH in agricultural environments is flowers of sulfur (a form of elemental sulfur). The sulfur compound is oxidized by soil microbes producing sulfuric acid. At equivalent concentrations, microbial oxidation of the flowers of sulfur is reportedly four or five times more effective in developing acidity than ferrous sulfate.? No specific recommendation can be made as to amounts of ferrous sulfate or sulfur that should be applied because sources of soil pH are so variable. Brady7 reports that for certain plant species, 0.45 to 0.90 kilograms (1 to 2 pounds) of sulfur per 9.3 square meters (100 square feet) is required to lower the pH 1/2 unit for a medium textured soil (e.g. loam, silt-loam, silt). Use of Acidic Wastes When compatible wich other wastes being applied, incorporation of acidic wastes into the treatment zone can be an effective method of reducing soil pH. Table 8.2.11 identifies organic compounds that hydrolyze in the presence of water (e.g., soil water) to form strong acids. The safe use of acidic wastes for this purpose must be demonstrated prior to any application under normal operating conditions. 8.2.3.4 Measures to Enhance Microbial or Chemical Reactions— Measures to enhance waste treatment include incorporating the waste in the soil, soil aeration, microbial innoculations, fertilizer applications, and establishment of a vegetative cover. Waste/Soil Contact Generally, as the surface area of waste particles increases and the amount of physical contact with the soil increases, biodegradation increases. For liquid waste applications proper soil/waste mixing can be accomplished by regularly scheduled tillage. In caes where solid or semisolid wastes will be applied to the treatment zone, material shredding or pulverization prior to application will maximize the contacting surface area. 8-91 ------- a 3. 2. 11. SOME ORGANICS THAT BECOME ACIDIC WHEN WET1- Acetyl chloride - FL Acetylene tetrachloride Allyl chloride - FL Ammonium citrate Ammonium oxalate Amy I chloride - "L Amyl propionate Benzaldehyde - CL Benzotrichloride Benzene hexachloride Benzene sulfonic acid Benzyl chloride - CM Butyl chloride - FL Carbon tetrachloride Chloroform Chlorophenol Chicrosuifonic acid - CM Citric acid Dichlorodifluoromechane Diethyl ether - CL Dimethyl suifate - CM Dinitrochiorobenzene - Poison 3 Ethyl chloride - FL £chylene dichioride - FL Ethyl mercaptan - FL Hexachlorobutadiene Hexachloroethane Hexaethyl cetrapnosphate - Poison 3 Lead acetate Methylene chloride Nitrophenols Potassium oxalate n-Prcpyl aicrate Trimethyl phosohite Vinyl chloride - FG aDepartment of Transportation Hazardous Material classification: FL - Flammable liquid CL - Combustible liquid CM - Corrosive material FG - Flammable gas 3-92 ------- The treatment zone surface should be cultivated by disking, plowing, or rototilling just prior to and subsequent to waste application. As one example, experience in land treating oil refinery production wastes has shown that six cultivations are required to adequately blend the waste and soil between applications.5,6 Soil Aeration The presence of adequate free oxygen in the soil is essential to maintain biodegradation and drive chemical reactions. Soil conditioning involving creation of good drainage, periodic cultivation, and proper waste loadings will promote aerobic soil conditions. It should be noted that under certain conditions, some wastes, particularly nitrogenous wastes, will be degraded only under anaerobic conditions. Therefore, conditions that are most conductive to waste degradation or transformation should be established and maintained. Mierobial Innoculations Although not always necessary, biodegradation may be improved by innoculating the treatment zone with soil microbes. This involves amending the soil with cultured soil microorganisms indigenous to the region. Soil Fertility Inorganic nutrients must be available in sufficient quantities to sustain microbial populations. The amounts required are dependent on the levels and availability of nutrients in the waste, biodegradation races, waste application rates, and persistence of added fertilizer in the treatment zone. The availability of nutrients from a waste applied to the treatment zone, as an example, nitrogen in certain cases, is expected to be low. Consequently, nitrogen or some other nutrient deficiency may occur as a result of the waste application. The addition of a fertilizer to the waste-treated soil will be required to increase microbial activity. Vegetation Establishment of a vegetative cover crop can serve to cycle and treat certain hazardous constituents. Treatment functions performed by plants may include translocation of substances from the soil to vegetative matter and transformations within the plant. It should be noted that unless the plants are harvested or substance transformation performed by the plant results in a nonhazardous compound, the hazardous constituent taken up by the plant will be returned to the soil following death and decay. Under these conditions, treatment is only in the form of temporary storage. Area agronomists from the State Agricultural Extension Service of the U.S. Department of Agriculture or the agronomy department of nearby universities should be consulted to obtain information on local cultivation practices that will be necessary to properly evaluate the permit application. 8-93 ------- When a vegetative cover is established, Che owner ^r operator should address the impact of growing crops during the active years of the treatment unit. Factors to be evaluated include nutrient depletion, water balance impact, and effect of increased soil organic matter (i.e., root system and stubble). The mechanisms associated with chemical degradation, transformation, and immobilization are complex and multifaceted. They cannot a------- Measurement of Soil Moisture Soil moisture content can be measured directly or indirectly. Indirect techniques involve collecting a soil sample in an air tight container and transferring it to a laboratory where the sample is oven dried. The weight loss by heating represents the moisture content of the soil sample taken ia the field and is expressed as a percentage of the oven dry weight of the soil. This gravimetric technique is one of the most common methods used to determine soil moisture content on a weight percentage basis." Direct techniques measure the moisture concent of the soil in the field. Two methods for measuring soil moisture directly are electrical resistance and neutron scattering. These methods are described in Tlia Nature and Properties of Soils.? These tecnniques allow the operator to leave sampling devices in the soil for extended periods of time. This reduces the time required to determine soil moisture content considerably. These techniques are not as accurate as the gravimetric method, but they will provide the necessary information on a relative basis. 8.2.3.6 Unsaturaced Zone Monitoring— The purpose of unsacuratad zone monitoring is to provide prompt feed back on the success of treatment in the treatment zone. Feedback information should be used to adjust the unit operating conditions to maximize hazardous constituents degradation, transformation, and immobilization. With respect to Part 264 requirements, the unsaturated zone refers to the layer of soil or parent material separating the bottom of the treatment zone and the seasonal high water table or ground water table. This soil layer is usually found to have a moisture content of less than saturation. To avoid confusion, it is important to note that unsaturated zone monitoring and ground water monitoring are both required at a land treatment facility. The distinction between the two is that ground water monitoring is design-'I to determine the effect of hazardous waste leachate on the ground water, whereby unsaturated zone monitoring is performed to provide an indication of whether hazardous constituents are migrating out of the treatment zone. Identification of hazardous constituents to be monitored should be based on the results of the comprehensive waste analysis performed in accordance with §264.13. Recommended analytical methods that can be used to verify analyses performed by the applicant are presented in Test Methods for Evaluating Solid Waste.12 Hazardous constituents to be monitored include those contained in the waste and those derived following waste application. Identification of hazardous constituents that may be derived from the waste following soil incorporation should have been performed as part of the treatment demon- stration. Analysis of leachate and soil collected from soil column tests performed in the laboratory or field tests using a lysimeter or other similar device should have been conducted to determine whether hazardous constituents will be derived from the waste(s) to be land treated. 8-95 ------- 1C is noted that a. provision of the regulation states chat upon approval^ following sufficient documentation, principal hazardous constituents (?HC), which are hazardous constituents contained in or derived from the wastes to be applied that are the most difficult to degrade, transform, or immobilize, may be designated (as indicators) for unsaturated zone monitoring purposes in lieu of monitoring for all hazardous constituents contained in or derived from the waste. A methodology for determining PHCs is provided in U.S. EPA's RCRA Guidance Document for Land Treatment.15 At a minimum, a ?HC must be one of the most mobila and/or taost concentrated and persistent constituents in the treatment zone. Meeting these criteria will assure that the constituents provide a reliable indication of the success of treatment or conversely forewarning of incomplete or ineffective treatment. The applicant must provide a description of how the soil and soil-pore liquid below the treatment zone will be monitored to determine whether hazardous constituents migrate from the treatment unit. The description provided in the application should include the following: • constituents to be monitored, » Installation of monitoring system (equipment and locations), • determination of background levels, • implementation of monitoring programs, frequency sampling procedures analytical techniques • determination of significant migration from treatment zone, • notification of any significant migration, due to facility operation due to other 3ourcas(s). Figure 8.2.6 presents a worksheet that can be used to help the permit writer evaluate the applicant's description of the unsaturated zone monitoring program. A fundamental concept of a land treatment facility is that it is a dynamic system. Several parameters must be monitored periodically to ensure optimization of hazardous constituent degradation, transformation, and immobilization. Operation of the treatment unit will be modified over time as monitoring data indicate the need for adjustments. The applicant must document conditions existing (background) prior to the application of waste to the treatment zone. Collection of the background data provides a bench mark for comparison with subsequent monitoring results. For existing facilities, background levels can be determined by monitoring background or control plots operated near the treatment units. To the extent 8-96 ------- UNSATU3A7ED ZONE MONITORING Has Che applicant identified, schematically, soil-pore liquid and soil core sampling locations and depchs? Yes No Has the applicant provided a rationale and statistical assessment for sampling locations? Yes No Are sampling frequencies, caking into consideration site operating conditions and climatic factors, seated? Yes No Has che applicant described the equipment to be used to take soil-pore liquid and soil core samples? Yes No Are the procedures for installing soil-pore liquid monitoring devices described? Yes No Has the applicant described how soil samples will be taken, including sample collection, preparation, Yes No preservation, and transport? Are analytical procedures specified? Yes No Are the chain-of-custody procedures specified? Yes No Has the applicant described how soit core and soil-pore liquid background values will be determined? Yes No Are statistical methods to be used to determine whether significant increases in hazardous constituent concen- Yes No trations occur described? Has the applicant identified the time period following sampling to determine whether a significant increase Yes No in constituent concentration has occurred? Has the applicant identified the hazardous constituents ~__ to be monitored? Yes No If the applicant has elected to monitor only principal hazardous constituents (PHCs), has he or she provided Yes No a satisfactory explanation for doing so? Figure 3.2.6. Worksheet for evaluating applicant's unsaturated zone monitoring plan. 8-97 ------- possible, Che soils of Che control plocs monitored should be siraiiar Co c of the unsaturaced layer immediately below the subject treatment zone. In addition, samples obtained to determine background levels and unsaturated zone concentrations should be taken at similar soil depths. For new facilities, background levels can be determined by sampling the unsaturaced zone prior to any waste application. Unsaturated zone monitoring involves taking and analyzing soil-core and soil-pore liquid samples for the presence of hazardous constituents contained in or derived from the waste applied. These two samples are taken to complement one another. Analysis of soil-core samples will provide information on the movement of slow migrating constituents while soil-pore liquid results will provide complementary data on the movement of the -tor3 mobile hazardous constituents. Soil core and soil-pore liquid sampling should be random within a given uniform area. A uniform area generally refers to an area of the active portion of a land treatment unit that is composed of soils of a similar soil series (including similar "A" horizons) and to which similar wastes or waste mixtures are applied at similar rates. The HWLT manual (.Section 9) and RCRA Guidance Document for Land Treatment1^ provide informative discussions on unsaturated zone monitoring. Table 8.2.12 presents a matrix indentifying recommended soil core and soil-pore liquid sample locations, frequencies, depths, and numoers. The concepts of sample compositing and uniform area sampling are proposed by EPA as an attempt to minimize sampling and analytical costs and to assure statistically reliable results. The frequency of soil core and soil-pore liquid sampling should be based on waste application rates and frequency, soil permeability, and amount and frequency of precipitation. Sample preservation and shipment, and hazardous constituent (or Principal Hazardous Constituents, PHCs) analysis should be performed in accordance with the procedures included in Test Methods for Evaluating Solid Waste.12 por eacn soil series or uniform area, as applicable, an arithmetic mean and variance for each hazardous constituent (or PHC) should be determined by pooling all composite measurements. As previously stated, one of the purposes for monitoring the unsaturated layer beneath the treatment zone is to be able to detect pollution migration. Hazardous constituent migration out of the treatment zone may result from improper design or operating practices that can be altered to impede or halt additional or continued pollutant movement. Table 8.2.13 presents, as examples, a couple of different scenarios where constituent increases were recorded and what possible adjustments can be made. Section 9 of the HWLT manual identifies the following modifications to unit operations that should be considered to maximize treatment within the treatment zone: 1. alter the waste characteristics; 2. reduce waste application rate; 3. alter the method or timing of waste applications; 8-98 ------- ul CN 3 VI 3- » « » - ? - - §.2 f ! , V 9 - 133. 3.U-- ,' „ *• 3. M, * r»7ir? i J - - » -••>;=;.= ! as p 0 S 3 NJ - " UNSA JJ I \ •» :j \n : CO 33 H ! I f; I !e-j rfi •? -? i * *• *. 8-99 ------- -^ If *— ' r «! Z •-" 0 = T3 H^ f$ V H £ w < y as 3d *> 3 3 S — i M T3 3C JJ < r- -J -J Z 3 J Icj i ** • M o i *• <-> a. i y W5 1 fl a j u as I a. '•a i so -J 1 C =0 i) •-* '•n \ eg CO U 201 a. .. ! 0 «4 ! O j § 34 ^ 41 X ta a to V u • y n -o c — i « i-i • XJ cs y u 01 e 00 JJ D u a u -J 1 '-I CQ 4J S 2 ^H i^ J •^ 5 =c = -•2 .2.2 .2 •2 .23 33 ^ 4J ., _! B M N n " S •-(._, ^ *- o- - 2 2i Si - ? Sfl 211 A .jf B u a 3 a Q --1 H .5 ^ ^ -, AJ J.J J fl aj "3 30 u <« 0 — "u —" ^ . W ! *.5 *a =5 •-<-•- .^ — • *j o a) o c •- >-s 50 .2 - 5 « g 3 ^ — 4J ff tj y yj •»•* m /-i ^ *j '^ 3^3° « »S '"> '- '-! T3 'U 3 « 3 « -n -a r* —i ao < «- < , Jj 3 u "^ < O <* •- -2 ! o" u ,. •-< ._ !0 m u -> 32 S ^ - ^ - ^ - a. a "^ - o ,^. -1 ™ Q> 3, -r-< "• V Ck /^ ^^ tfl «A ^r "-% ^- j_i fl J " « * « x- 3 « -.2? 2 - s 3 g i: S C --t 2 « « a, S * c c - - as §. | so u u u "• a. a. w y «) ~ -J u O C Q i? -J) so * - a. (2 £ §. 13 * 05 fl> - -? ^ c I 5 1 I : s J ° >» U y u •- -2 '3 „ •-* ~ri ,.. c w ^^ = * 2 a - « * u aj 2; r2 " 2 * £ S £ ^ o 5 >^s CJ CxJ \J ^-^ X 4J 3 y '- 3 ^n 5* U 'J u o» Ul 30 ifl C •u -a * -C y y s x -i jj J J 4 I 8-100 ------- 4. cease application of one or more particular wasce(s) at the unit; 5. revise cultivation or management practices; and/or 6. alter the characteristics of the treatment zone, particularly soil pH or organic matter content. 1C is recommended that responses to detection of pollutant movement below the treatment zone be discussed during preapplication conferences. 8.2.3.7 Treatment Zone Description— The treatment zone refers to a defined layer of surface and subsurface soils used to degrade, transform, or iamobiiiia hazardous constituents contained in or derived from the waste applied or the leachate passing through the zone. Although the original treatment zone design will be made by the owner or operator, the reviewing authority will specify the vertical and horizontal dimensions of the treatment zone in the facility permit. The depth of the treatment zone must be: • No more than 1.5 meters (5 feet) from the initial soil surface, and • More than 1 meter (3 feet) above the seasonal high water table. Data sources available to evaluate whether these conditions are met are identified below. Soils • United States Department of Agriculture (USDA), Soil Conservation Service (SCS), Local Extension Service • United States Geological Survey (USGS) reports • Geology or Agriculture department of Local university or college Bedrock • USGS reports • State Geological Survey reports • Professional geologists in the area • Geology department of local university or college Ground water USGS water supply papers State or regional water quality agencies USDA, SCS State or Federal water resources agencies Local health department Section 8.2.2.7 identified specific items that the applicant should include in the permit application. Sections 3 and 4 of the HWLT manual provide explanation of each item and, in some cases, typical ranges of values. Soil survey (Part 1) and series description (Part 2) information (see 8-101 ------- Section 8.2.2.7) to be included in the application nay je JDtained from JSDA Soil Conservation Service County Soil Surveys. For soils that have not been surveyed, the permit writer should contact a soil scientist of the regional Soil Conservation Service office to obtain assistance in evaluating information submitted by the applicant. The following provides an explanation of the treatment zone soil characteristics (Part 2) to be included in the applicant's description of the treatment zone. Table 8.2.14 presents, as an example, relevant soil characteristics of five soils found Li Connecticut. The information provided in the table is presented as it typically appears in SCS County Soil Survey reports. Profile Description Horizonation—Horizonation refers to the sequence of soil layers of the soil profile. Soils are characterized by the sequence and composition of their soil horizons. Specific properties that need to be described include depth of each horizon and changes in textural properties. In general, soils have horizons of contrasting properties within the upper 1.5 to 1.8 metars (5 or 6 feet). The application should include a description of the depth to the upper and lower boundaries of *a.ch horizon and aoce changes in textural properties. Textural properties of each horizon should be evaluated for their suitability as the treatment medium (see Table 3.1.14 of Section 8.1.3). Relief The slope gradient, aspect, and elevation of each craacaent plot should be submitted in the application. These characteristics influence surface drainage of the unit. Climatic Data Monthly temperature and precipitation data should be submitted with the permit application. These are the two most important climatic factors affecting the treatment zone soil. Ambient air temperature will influence the extent and rate of hazardous constituent degradation, plants growing season, and extent of frost action. Precipitation will ar'fecc aerobic soil conditions, the rate soluble chemicals are leached from the soil, and the amount of surface water run-on and run-off. Tables 8.2.15, 8.2.16, and 8.2.17 provide examples of temperature and precipitation data supplied by the SCS Soil Survey reports. This information should be used to help determine application methods and frequencies, plant species selection, and design site run-on and run-off control systems. Mineralogy Soil mineralogy is closely aligned with soil texture. Figure 8.2.7, adopted from Brady,? presents the general relationship between particle size and kinds of minerals present. Quartz dominates the sand and coarse silt fractions. Primary silicates such as the feldspars, hornblende, and micas are present in the sands but tend to disappear as one moves to the silt fraction. 8-102 ------- •M z a £ • < W g co H < CJ »-H •J 0, a. < z i-^ a a Q 3 CJ Z ^^ a 03 g VJ ;j H 00 as a e < CJ z — o ^•4 »™ 0 H V) 0* PH u, as O CJ 00 w a £ Q a, 3C r*] 5g W N • *^ . rvi 00 W 3 ^« ?s « « • 3 i •9 i j ; * 4 i « i « ' « 1 J I i: i : »M |]j ' x ; | ' ^ | W S i ' - : 3 : a v i I 5 I - - ! : * c e • I* e 3 ^ « * i :r 1st i j ^ " ^ j kn : = • — -• e \\ • j « « V 3 S, M ? ,5' " I I *'*- : i "[ i i f J «| 3 J * -' * I « 5 J . 1 - 1 • * '1 ' ' 1 : .s ; : 1 i ; 1 » , ? it - - - *. 1 - : ! , 1 ' : : ' I ' , (' 1 ' i 1 I I * 1 ' ' "" ' 1 -» , i " - * - : « j ~ : . ' - • 3 ••'-.-- 22 ; = ; ; 1 I ?! * >i J J j ^j • ** 1 J J J J J j 3 3 9 a _ SI j - ' .a 33 « : -i 5 1! >• it i U ' • • : •'•••' ,,„ ; * • i •5J ?' 3 i i, ^ 7 * C: J - . « = s 5 2 ' .! 2 j ? ? T » ; : ^ 330 • • 3 2 5 : ; | ? 3 ' 3 0 3 3 H ' ° ° ^ « ==. <] ? * f - ^ . „ 3 3 ' ^ * t • i i •' i i • ^ • = 2' -I - , . 0- i ; - ,4 j ; 3 *t n, • T 7 ? . * ~ 5S* •• * '7^^ ***** i * » * * . 21 = ~ i 2 s -as ! - . , " 5 l! 1 i ij i! .1 !i J i F ?: ill: i }H • "? ~fi Iff , ,: ll f f. ! f... ^] * i«* S JB H i Jii f Si i Ilii fii fi [i !8!i . • 3 " «|77* <" -J.» a ' * • i A' -f7S »2 3 . M 3* Ail T ««' 3 *ai'T'' 2 S i i 4 ^ * « ~> H 0 I 1 i ! • 5 1 1 t 5 < a 3 1 ! 3 * e 3 • i i i 1 8-103 ------- flj H a "Z o < — i su y oJ as cu ,— s •z Lil H OS u a. fjj H , uO "^ • 00 J 3 H >M « o J) .A u U e 4i ja o > * *•» fl — o a. — i u c v v — > b 4 a. 4 .e u 4 -> V —* N a *4 V O at 4 b n V J1 fl ; i , 3 i £ c « •- •-< > x • .C b s n J> X-- « XI 3^2! * X a u t- « « > j; ^ 4J U -. 3 > ••* •m O •a o t u ^ • J{ _ •- S 3 •- 0 * u « , u V 3 - i W ' « $4 . .- s M * 1 ?- ;•; 9 • -^ * « ^' •M « 1 A U o o ) [ a ^ J V aO > u • >» i I 3 .£ 1 1 e « .£ — >t .11 ^ I a ••4 ™ fl • • 8 5 a £ aH^o./icxooooo-'^-t ^4 ^* ^ o ^ — *^ ^ ^ vO **• 00 00 ^*> ^ >Q >O ^v 20 40 ^ a i^ (^ ^ *j *s~j^O'*t5 r-^ ^ ^ ^—^d.-»--^dJOO(Ntrt w-» ^j-.n^^^^'^^^^-o ^ sO-^«'^»'3S'^-*O^>OO^ r 4j — » — w^^^«-^Oy^Or^.-*i O .4 r-jy^ooOCP*'*"^— O fl • 3 -« i/s s l( -***1^-sf>yf*n— -A te ^^^^"tt^^^^^^ "? ^P^tPl^^M^-tff^O-TfN^ **^ • ^•*QOOBP*Plke'4«'^i?t/^^ M« r>«>43««i/^0-^>49cNdaoH-M « u X » U W >, u J w « « C • u • « ^3 .a • 3 j: — vvjalf 3 u u .- «X3WO««i oj c^i-u>>a—3«a.ij>(j < ««OZsS >• * 5 •" 1) U •^ u V o 4 ^ j • c ^0 o 1/1 ^> a 3 • 3 .^ (J V e •j >, jj e 3 <3 » 41 II f * o X V w = en 01 V u u 3 0 en , •j » £ 3 V ** •O X « m 1 2 ^ O ,^ w Qu 4J e •o •2 o (J « s a 5 — • 3 9 3 S 1 i. 2 - 3" X 3 9 41 a f 5 fS •a -^ X J ^O 3 3 "" f • £ •3 — <* A — 1 4 U I 3 J3 V J3 S 4 U U - 3 W W u • a f 9 3 *4 3 w V 36 ^« e M « e a. x tj U 4 O i- J OJ 3 J3 « ^ '3 * <• • .- o X -0 -» "9 • 41 4 41 » « V 3 U V U « •0 1) J a. u ? tl S O X 4 u -. a. ao .- o 4 U < •« o u 8-104 ------- TABLE 8.2.16. FREEZE DATES IN SPRING AND FALL3 Probability Temperature*3 or lower or lower 32°F or lower Last freezing temperature in spring: 1 year in 10 later than— 2 years in 10 later Chan— 5 years in 10 later than— April 8 April 19 May 12 April 4 April 15 May 5 March 23 April 6 April 22 First freezing temperature in fall: 1 year in 10 earlier than- 2 years in 10 earlier than- 5 years in 10 earlier than- October 31 October 10 September 27 November 6 October 16 October 3 November 17 October 28 October 15 aSource: Soil Survey of Middlesex County Connecticut, U.S.D.A., Soil Conservation Service, L979. bR«corded in the period 1951-73 at Middletown, CT. 8-105 ------- TABLE 8.2.17. GROWING SEASON LENGTH3 Dailv minimum taraoeracura Probability 9 years in 10 8 years in 10 5 years in 10 2 years in 10 1 year in 10 during Higher than 24°F Da_ys_ 212 219 233 247 255 growing Higher than 28°F Jays 133 190 204 218 225 season'3 Higher than 32°F Days 147 156 1/4 192 202 aSource: Soil Survey of Middlesex County Connec™ cicut, U.S.D.A. , Soil Conservation Service, 1979. bRecjrded in che period 1951-73 at Middlecown, CT. 8-106 ------- Secondary jiiicat« nin«rals SAND SILT CLAY Figure 8.2.7. General relationship between soil particle size and minerals content. 8-107 ------- Secondary silicates dominate the fine colloidal, ciay. Other secondary minerals, such as Che oxides of iron and aluminum, are prominent in cne fine silt and coarse clay fractions. Land Use and Vegetation—Soil Surveys describe soils with respect to land use and suitability for crop cultivation. The more important factor of the two to evaluate is the suitability of soils to support vegetation. In addition to existing Soil Survey report3, local offices of the Soil Conservation Service and the Cooperative Extension Service can be contacted to provide information about vegetative management concerns, growing season length, and productivity of the soils under review. Texture Soil texture refers to the percentages of sand, silt, and clay in the soil material that are less than 2 millimeters in diameter. If a soil contains gravel or other particles coarser than sand, a modifier, for example gravelly loara, is added. Table 8.2.18 lists USDA soil texture classifications. Soil texture can be determined by laborato— T means or jimply by touch for the experienced soil scientist. Guidance for aetarraining the suitability of various soil textures as the treatment medium is presented in Table 8.1.14 (see Section 3.1.3). Atterburg Limits Atterburg limits refer to the effsct or water on soil strength and consistency. Three states of consistency are defined based on the water content of the soil. The terra consistency refers to the degree of firmness (e.g., soft, medium, firm). The three states are the shrinkage limit, plastic limit, and liquid limit. These three limits correspond to the transition points that occur when the water content of the soil increases such that the soil passes from a solid state to a semisolid state, to a plastic state, and finally to a liquid state. Figure 8.2.8 graphically displays the Atterburg limits. Atterburg limits are determined in the laboratory using standard test methods, such as ASTM D-423, D-424, and 0-427 for the liquid, plastic, and shrinkage limits, respectively. Permeability Permeability refers to the rate at which a liquid penetrates or passes through a bulk mass or layer of soil. Permeability should be determined to provide an indication of the length of time mobile constituents applied to the treatment zone will reside in the soil. The treatment zone soil should be permeable' enough Co minimize surface run-off but not so permeable that the waste constituents percolate through the soil before adequate treatment. Table 8.1.14 (s«e Section 8.1.3) describes the suitability of various textured soils for land treatment of hazardous industrial wastes. The information presented should only be used as a preliminary step to determine waste application suitability. A more detailed analysis of soil permeability of the proposed unit is recommended. EPA's RCRA Land Treatment Guidance Document^ suggests that the treatment zone contain soils having one or more of the following textures (USDA classification scheme): loam, silt loam, sandy clay 3-108 ------- TABLE 8.2.18. UNITED STATES DEPARTMENT OF AOUCULATURE (USDA) SOIL TEXTURES 1. Gravel, very gravelly loamy sand 2. Sand, coarse sand, fine sand 3. Loamy gravel, very gravelly sandy loam, very gravelly loam Loamy jana, graveliy loamy sand, very fine sand 5. Gravelly loam, gravelly sandy clay loam 6. Sandy loam, fine sandy loam, loamy very • fine sand, gravelly jandy loam 7. Silc loam, very fine sandy clay loam 3. Loam, sandy clay loam 9. Silcy clay loam, clay loam iO. Sandy clay, gravelly clay loam, gravelly clay 11. Very gravelly clay loam, very gravelly sandy clay loam, very gravelly silty clay loam, very gravelly silty clay and clay 12. Silcy clay, clay 13. Muck and oeaC 8-109 ------- UJ in < UJ oc o z H- z LJ K Z O u X LU LIQUID «TiTZ PLASTIC STATE SEMISOLiO STATE SOLID STATE LIQUID LIMIT PLASTIC LIMIT SHRINKAGE LIMIT Figure 8.2.8. Atterberg limits. (16) 8-110 ------- loam, sandy loam, silty clay loam, or clay loam. Three soil textural classes inCo or onco which hazardous wasts(s) should noc be applied are sands, clays, and silts. Sandy soils have rapid infiltration and percolation potentials that could easily lead to ground water contamination. Conversely, clay soils have extremely alow infiltration rates. This condition would increase the likelihood of surface water contamination due to water and wind erosion. Silty soils, which upon drying have a severe surface crusting problem, would have similar surface erosion concerns. Because wide variations in permeability are common even in a small area, several soil samples and infiltration and permeability tests should be conducted to characterize the treatment zone. Section 4.1.1.5 of the HWLT manual describes methods for determining soil oeraeability. Nots chat penaeaoility shouia be aecermined for each soil horizon. Available Water Capacity This is a characteristic of the soil relating to its ability to hold water and make it available to plants. Available water holding capacity is a measure of the amount of water held in the soil against the pull of gravity. Section 3.4.3 of the HWLT manual describes differences in water holding capacities and their impact on the function of the treatment zone. In general, the higher the water holding capacity, the lower the likelihood of constituent leaching. Soil pH Soil pH, which is the degree o£ acidity or alkalinity of a soil, has been discussed in Section 8.2.2.3. Table 8.2.19 presents a general guide for interpreting soil pH test results as they pertain to the viability of soil microbes and plants. Salinity Salinity generally refers to the electrical conductivity (EC) of a soil. It is a measure of a soil solution salt content. Section 4.1.2.6 of ".he HWL.T manual discusses the importance of determining soil salinity and describes test methods. Table 3.2.19 provides guidance on interpreting EC results as they relate to establishing a vegetative cover during the active years or at closure. Shrink-Swell Potential This soil characteristic is influenced by the amount and kind of clay in the soil. Soils with a high shrink-swell potential can increase constituent leaching due to the formation of deep cracks in the soil during extended periods of dry weather. Obviously, soils with low shrink-swell potentials are preferred for hazardous waste land treatment. The measurement of shrink-swell potential can be made in the laboratory using undisturbed bulk samples or estimated by soil scientists based on the kind and amount of clay in the soil and extrapolation of tests performed on similar soils. 8-111 ------- TABLE 8.2.19. INTERPRETATION OF SOIL CHEMICAL TESTS17 Test Result Interpretation pH of saturated soil paste <4.2 4.2-5.5 5.5-8.4 >8.4 Too acid for 20 Sandy soils (limited adsorption) Silt loam (moderate adsorption) Clay and organic soils (high adsorption) Electrical Conductivity (EC), mrahos/cm at 25°C of saturation extract 2 2-4 4-8 8-16 No salinity problems Restricts growth of very salt-sensitive crops Restricts growth of many crops Restricts growth of all but salt-tolerant crops Only a few very salt-tolerant crops make satisfactory yields 8-112 ------- arosion Factors Soil losses due to erosion should be evaluated Co assess the pocancial for hazardous constituent release from Che sica. Section 8.3.3.2 describes the Universal Soil Loss Equation technique for determining soil losses per unit area of land. Flood Potential The proposed site should be evaluated to assess the likelihood of flooding. Soil surveys conducted by the Soil Conservation Service will identify flood-prone areas. Flooding is rated in general terms Chat describe the frequency and duration of flooding and Che *:irne of /*»ar such flooding is 3osc likely. Taoie 8.2.14 presents an example of this site characteristic for some soils found in Connecticut. Water Table Depth In general, water cables are deeper in arid regions Chan humid regions. Water Cable depths also tend to follow surface topography; deeper beneath interstream areas and shallower :'.n lowlands. 3 rn addition, the water Cable generally coincides wich Che surface of perennial streams. Furthermore, water cables are usually shallower in relatively impermeable soils (e.g., clays) Chan in relatively permeable soils (e.g., coarse sand).8 The applicant should identify for Che treatment zone, Che depth to seasonally high water table. The Soil Conservation Service defines high water Caole as Che highest level of a saturated zone more than 15 centimeters (6 inches) thick for a continuous period of more Chan 2 weeks during mosc years. Estimates of depth to seasonally high water cable are based mainly Che relationship between grayish colors or mottles in che soil horizon and che depth to free water observed. Information on depth to seasonal high water table may be obtained from regional offices of the Soil Conservation Service, U.S. Geological Survey, Water Resources Branch of U.S. Department of the Interior. Frost Action Potential The Soil Conservation Service states Chat the freezing and thawing action accompanying frost affects soil structure and increases aggregate formation. The resultant increase in particle size increases the rate of water movement through the soils of the frost zone thereby increasing che likelihood of soluble chemical leaching. Frost action potentials are typically provided in SCS County Soil Survey reports (see Table 8.2.14 as an example). 8.2.4 Draft Permit Preparation Condition A of the Land Treatment Permit Module XIV contains chree components. The three parts, (1) list of wastes to be treated, (2) treatment zone operating conditions, and (3) treatment zone design can be stipulated by reference to segments of che applicant's submittal. The first component of 8-113 ------- Condition A requires chat Che permit: -ontain ;he j.ist of vasces Co be treated chat have been demonstrated under §264.272 as being completely degraded, transfortaed, or immobilized in the treatment zone. Part 2 of Condition A stipulates that the permit must specify the following, which can be incorporated into the draft permit by reference to that applicable part of the application: • rata and method of waste application • measures to control soil pH » procedures Co enhance microbial or chemical reactions • measures to control moisture content Part 3 of Condition A requires that the permit specify the vertical and horizontal dimensions of the treatment zone. The three parts of Condition A of Permit Module XIV are as follows: 1. The Permittee shall establish a treatment program for the wastes listed in Table XIV-1 as required by 40 CFR 264.271(a). The treatment program rausC include the design measures and operating practices specified in condition XIV.8 and the unsaturaced zone monitoring provisions specified in XIV.E. The treatment program must be capaoie of degrading, transforming, or immobilizing the hazardous constituents listed in Attachment . 2. The Permittee shall design, construct, operate, and maintain the treatment unit in accordance with the requirements of 40 CFR 264.273(a), as specified in the attached plans and specifications. 3. The Permittee shall construct the treatment zone as specified in Attachment . In addition to specifying the provisions of Condition A of Module XIV, the permit writer must also stipulate unsaturated zone monitoring conditions (see Condition D of Module XIV, as presented in Section 4). These conditions outlined below, may be incorporated into the permit by reference to applicable parts of the Pare B permit application submittal. 1. The Permittee shall establish an unsaturated zone monitoring program for Che hazardous constituents listed in Attachment , as required by 40 CFR 264.273. [Note: Unless the Regional Administrator requires monitoring for principal hazardous constituents (PHCs) in accordance with the provisions of §264.278(a)(2), this list of hazardous constituents should be the same as the one specified in condition A of Permit Module XIV.7.] 8-114 ------- 2. The Permittee shall install an unsaturaeed zone monitoring system as required by 40 CFR 264.278(b); as specified in the attached plans and specifications. [Note: The attached plans and specifications should demonstrate compliance with the requirements of §264.278(b). At a minimum, these plans should contain the information required by §270.20(b)(3) including sampling equipment, procedures, and frequency, and procedures for selecting sampling locations.] 3. The Permittee shall establish a background value for each hazardous constituent to be monitored Mnder Condition XIV.C.I as required oy 40 CFR 264.278U), as specified in Attachment . [Note: The Attachment should demonstrate how the Permittee will comply with the requirements of §264.278(c).] 4. The Permittee shall conduct soil monitoring and soil-pore liquid 'monitoring as required oy 40 CFR 264.278(d), as specified in Attachment . [Note: The Attachment should demonstrate how the Permittee will comply with the requirements of §264.278(d). The permit should specify the frequency and timing of this monitoring in accordance with the conditions outlined in §264.278(d).] 5. The Permittee shall follow the sampling and analysis procedures specified in Attachment as required by 40 CFR 264.273(c). (Note: This Attachment should demonstrate compliance with §264.278(e).] 6. The Permittee shall determine whether there is a statistically significant change over background values for any hazardous constituent to be monitored under Condition XIV.E.I aach time the monitoring required by Condition XIV.E.4 is conducted, as required by 40 CFR 264.278(f). This determination shall be made using the statistical procedures outlined in Attachment [Note: This Attachment should demonstrate compliance with the requirements of 40 CFR 264.278(f). The permit writer should specify the time period for making the determination in accordance with$264.278(f)(2).] 7. If the Permittee determines, pursuant to Condition XIV.E.6, that there is a statistically significant increase of hazardous constituents below the treatment zone, he shall notify the Regional Administrator of this finding and apply for a permit modification in accordance with the provisions of 40 CFR 264.278(g). 8-115 ------- other than che regulated an 11^^^ <*« * source increase resulted from an error in samnH °T ChaC Che « specified by 40 CFR 264.278(h) mpUng' analy^s, or evaluation 8-U6 ------- 8.2.5 Re ferences I. U.S. Environmental Protection Agency. Permit Applicants' Guidance Manual for Hazardous Waste Land Storage, Treatment, and Disposal Facilities. Draft Report. Office of Solid Waste, Land Disposal 3ranch. Washington, D.C. March 1983. 2. U.S. Environmental Protection Agency. Hazardous Waste Lana Treatment, prepared by K. W. Brown and Associates, Inc., for U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, Solid and Hazardous Waste Research Division, Cincinnati, OH. Report No. SW-374. 1983. 3. Black, C. A., ed. Methods of Soil Analysis, Parts 1 and 2, The American Society of Agronomy, Inc., Madison, Wisconsin. 1965. 4. Whiting, D. M. Use of Climatic Data in Estimating Storage Days for soil Treatment Systems. Environmental Protection Agency, Office of Researcn and Development. EPA-IAG-D5-F694. 1976. 5. Huddleston, R. L. Solid Waste Disposal: Landfarming. Chemical Engineering, February 25, 1979. pp. 119-124. 6. Landfarming Fills an HPI Need. Hydrocarbon Processing, June 1980. pp. 97-103. 7, Brady, N. C. The Nature and Properties of Soils. 8th Ed. MacMillan Publishing Company, Inc. Mew York, NY. 1974. 3. Phung, T. , et al. Land Cultivation of Industrial Wastes and Municipal Solid Wastes: State-of-the-Art Study. Volume I, Technical Summary and Literature Review. Prepared by SCS Engineers for U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, Cincinnati, OH. EPA-600/2-78-140a. August 1978. 9. Page, A. L. Fate and Effects of Trace Elements in Sewage Sludge When Applied to Agricultural Lands. A Literature Review Study. EPA-670/2-74-005. U.S. Environmental Protection Agency. January 1974. 10. Dowdy, R. H., and W. E. Larson. The Availability of Sludge-borne Metals to Various Vegetable Crops. J-. of Env. Quality, 4: 278-282. 1975. 11. Chan«y, R. L., P. T. Hundemann, W. T. Palmer, R. J. Small, M. C. White, and A. M. Decker. Plant Accumulation of Heavy Metals and Phytotoxicity Resulting from Utilization of Sewage Sludge and Sludge Composts on Cropland, pp. 86-97. In: Proc. Nat'l Conf., Composting Municipal Residues and Sludges. Information Transfer Inc., Rockville, MD. 1978. 12. U.S. Environmental Protection Agency. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. U.S. Environmental Protection Agency, .Office of Solid Waste. Report No. SW-846. July 1982. 8-117 ------- 13. Kirby, G. N. Corrosion Performance of Carbon Steel. Chemical Engineering, March 12, 1979. 14. Farino, W. J. and C. W. Young. Suitable Methods for Drum Disposal at Hazardous Waste Landfills, prepared by GCA/Technology Division for Office of Solid Waste, Hazardous Waste Management Division. January 1933. 15. U.S. Environmental Protection Agency. RCRA Guidance Document Land Treatment, Draft: Report. Office of Solid Waste, Washington, DC. January 1983. 16. Cernica, J. N. Geotechnical Engineering- CBS Collie ?uoiisning. 1932. 17. U.S. Environmental Protection Agency. Process Design Manual for Land Treatment of Municipal Wastewater. EPA-625/1-77-008. October 1977. 8-118 ------- 3.3 DESIGN AND OPERATING REQUIREMENTS 8.3.1 Federal Requirement: Section 270.20(c) requires the applicant Co provide: "(c) A description of how the unit is or will be designed, constructed, operated, and maintained in order to meet the requirements of 5254.273. This suomission muse address the following items: (1) Control of run-on; (2) Collection and control of run-off; (3) Minimisation o£ run-off of hazardous constituents from the treatment zone; (4) Management of collection and holding facilities associated with run-on and run-off control systems; (5) Periodic inspection of the unit. This information should be included in the inspection plan submitted under §270.14(b)(5); (6) Control of wind dispersal of particulate matter, if applicable." The corresponding Part 264 standards, which are contained in §264.273(b) through (g), stipulate that: "(b) The owner or operator must design, construct, operate, and maintain the treatment zone to minimize run-off of hazardous constituents during the active life of the land treatment unit.' (c) "he owner or operator must design, construct, operate, and maintain a run-on control system capable of preventing flow onto the treatment zone during peak discharge from at least a 25-year storm. (d) The owner or operator must design, construct, operate, and maintain a run-off management system to collect and control at lease the water volume resulting from a 24-hour, 25-year storm. (e) Collection and holding facilities (e.g., tanks or basins) associated with run-on and run-off control systems must be emptied or otherwise managed expeditiously after storms ;o nsaintain che design capacity of the system. (f) If the treatment zone contains particulate matter which may be subject to wind dispersal, the owner or operator must manage the unit to control wind dispersal. (g) The owner or operator must inspect the unit weekly and after storms to detect evidence of: (1) Deterioration, malfunctions, or improper operation of run-on and run-off control systems; and (2) Improper functioning of wind dispersal control measures." 8.3.2 Summary of Necessary Application Information 8.3.2.1 Surface Water Control Plans— A scale drawing of the land treatment unit depicting the location of surface water and/or soil erosion control structures that will be used to control run-on and run-off should be included in the permit application. 8-119 ------- Equipment design features and specifications should be submitted along witn calculations for sizing lurface *racer control structures based on specified (see §264.273(c) and (d)) storm frequency, duration, and intensity. 8.3.2.2 Minimizing Run-off of Hazardous Constituents— Specific measures to minimize the concentration of hazardous constituents in surface water run-off from the treatment zone should be identified in permit application. 8.3.2.3 Management of Accumulated Run-off and Run-on— The applicant snould submit a monthly tabulation of run-off and run-on storage requirements and a concise explanation of how the collected liquid will be managed for disoosal. Mota that "ha applicant must determine whether :he collected iiquid is a hazardous waste or not according Co the criteria of Part 261. 8.3.2.4 Control of Wind Dispersal— A wind erosion control plan designed to minimize the wind dispersal of soil, soil-waste mixture, or waste particulate matter must be included in the application. 8.3.2.5. Inspection of Land Treatment Unit— The applicant should submit a schedule for periodic inspections of the land treatment unit to determine the adequacy of surface watar control and wind erosion control measures. The name or title of the person(s) responsible for conducting inspections, a list of items to be inspected, procedures for responding to observed inadequacies, and records for inspection results should also be included in the application. 8.3.3 Guidance on evaluating Application Information To satisfy the facility design, construction, operation, and maintenance requirements, the applicant must provide a description of the following: • Surface water control plans, addressing: "aciiicy surface run-on control system Facility surface run-off control and collection systems • Minimizing run-off of hazardous constituents • Management of accumulated run-off (and run-on) • Control of wind dispersal • Inspection of land treatment unit Where applicable, facility design and operating parameters should be based on the results of the treatment demonstration. Examples would include surface water run-on and run-off experiences gained from field studies or 8-120 ------- existing units; effectiveness of wind dispersal controls impieraencea during field tests or at existing units; and procedures tested under field studies co minimize run-off hazardous constituents. 8.3.3.1 Surface Water Control Plans — Because of their interrelationship, evaluation of run-on and run-off control systems are discussed together. Water is the primary conduit for hazardous constituent release from the treatment zona. Therefore, the design and operation ,of surface water control systems are essential in limiting ground water or nearby surface water contamination. The land treatment unit must be designed to prevent run-on of surface water during periods of intense rainfall. The primary purpose for controlling run-on is to prevent-excess water from entering the treatment zone. Excess water, resulting in soil saturation, will create anaerobic conditions that will reduce microbiai degradation, hinder waste application and tilling operations, and increase the likelihood of hazardous constituent leaching from the unit. Just as important as controlling run-on, the land treatment unit must be designed and operated to control run-off. Uncontrolled run-off released from the site can, if it contains unacceptaole levels of hazardous constituents, result in contamination of nearby soils and surface waters. The RCRA Land Treatment Guidance document^ and Chapter 8 of the HWLT manual provide guidance on the design, operation, and maintenance of run-on and run-off control systems for hazardous waste land treatment units. As required under Part 264, the land treatment facility operator or owner must design, construct, operate, and maintain a run-on control system capable of preventing flow onto the treatment zone during peak discharge from at least a 25-year storm. The amount of run-on, and also run-off, expected as a result of precipitation will depend on: • soil cover (vegetated or nonvegetated), • watershed surface slope, • soil permeability, • antecedent soil moisture content, and • seasonal temperatures (e.g., soil freezing). The relationship between run-on or run-off and these factors' are covered in the HWLT manual and introductory hydrology text books.3,4 Surfac* run-on can be effectively controlled by contour grading surrounding land to divert surface overland flow away from the treatment zone. Diversion o£ potential surface run-on will reduce excess infiltration through the treatment zone, thus minimizing leaching during periods of precipitation. Surface run-on diversion involves creating earth benns and excavating diversion ditches along the upslope side of the treatment zone that direct flow toward natural drainageways downs lope from the unit. Diversion ditches must be designed to accommodate the characteristics of the contributing 8-121 ------- watershed such as area, annual rainfall, land use, soil type, and topography. Aa required, they muse be designed to handle the 25-year storm intensity. Determination of peak discharge should be determined on a unit-specific basis, taking into consideration local rainfall intensity and the size and terrain of surrounding watershed. The amount of rainfall expected from a local or regional 25-year storm event can be obtained from the National Oceanic and Atmospheric Administration or local Agricultural Extension Service. The permit writer's worksheet for assessing the adequacy of the applicant's determination of storm magnitude is present in Figure 8.3.1. Two methods commonly used to calculate the volume of run-on or run-off during and after rainfall are the "rational method" and the Soil Conservation Service (SC.S) method. The Rational Method The rational method calculates peak run-off based on the following expression: Q » cia where Q a peak run-off rate in cubic feet per second (CFS) c * run-off coefficient which is actually the ratio of the peak run-off rate to the average rainfall rate for a period known as the time of concentration i =» average rainiaj.1 intensity in inches per hour for a period equal to the time of concentration a = drainage area in acres Use of the rational method for determination of design run-on quantity is appropriate since the Part 264 regulations require control of the peak discharge rata. Q, as calculated using the rational method, is defined as the peak discharge rate associated with the selected storm event. The rational method formula is based on the following assumptions:3 (1) the maximum run-off rate is a function of the average rate of rainfall during the time of concentration, (2) the maximum rate of rainfall occurs during the time of concentration, and (3) the variability of the storm pattern is not taken into consideration. The time of concentration (tc) is defined as the flow time from the most remote point in the drainage area to the point in question. The time of concentration is calculated as follows: 8-122 ------- I Determination of Magnitude of the 25-year Storm Event - Has this part of the applicant's submittal been read and evaluated? Yes No - What storm magnitude was selected by the applicant? - What depth of rainfall is this storm event equivalent Co? inches based on what references? I I H Independent Check j u What is the local rainfall depth associated with the 25-year storm? inches baaed on what reference? Is the rainfall depth established by the applicant at least as great as this determination? Yes No Then, likewise, this aspect of the applicant's submittal is or is not acceptable is acceptable is not acceptable Figure 8.3.1. Worksheet for determination of the magnitude of the 25-year storm event. 8-123 ------- 41b I/' " 0 Where cc » cima of concentration in minutes b • coefficient Lo a overland flow length in feet c a run-off coefficient (see Table 8.3.1) i * rainfall intensity in inches per hour during :ime -• f concentration The equation is valid only for laminar flow conditions where the product iL0 is less than 500. The coefficient b is found as follows: 0.0007i •*• G , „,. b . £ sl/3 o whera 3O a surface s Lope Cr = a coefficient of retardance Values of Cr, are given in Table 8.3.2. The runoff coefficient (C) is influenced by a number of variables, such as infiltration capacity, interception by vegetation, and depression storage.3 As used in che rational aethod, the coefficient C represents a fixed ratio of run-off to rainfall, while in actuality it is not fixed and may vary for a specific drainage basin with time during a particular storm, from storm to storm, and with change in season. Table 3.3.1 lists some values of the run-off coefficient for various soils and surface covers. The rainfall intensity (i) is derived from the average intensitv (in/hr) of a storm for a given frequency (25-year in this case) for the time of concentracion. Following determination of tc, the rainfall intensity is usually obtained by making use of a set of rainfall intensity-duration- frequency curves such as shown in Figure 3.3.2. Drawing a line from the abscissa at the appropriate value of tc and then projecting upward to intersect the desired frequency curve, i can be found by projecting this intersection point horizontally to intercept the ordinate.3 if an adequate number of years of local rainfall records is available, curves similar to Figure 8.3.2 may be developed. Otherwise, data compiled by the National Oceanic and Atmospheric Administration, the Department of Agriculture, or other local government agencies can be used. A more indepth discussion of surface run-on and run-off computations using the rational method is presented in References 3 and 4. 8-124 ------- TABLE 3.3.L. VALUES OF RUN-OFF COEFFICIENT^1 Earth Surface Cover Mm. Max. Sand, from uniform grain size, no fines, to well graded, some clay or silt Loam, from sandy or gravelly ca clayey Gravel, from clean gravel and gravel sand mixtures, no silt or clay Co high clay or silt content Clay, from coarse sandy or silty to pure colloidal clays Bare Light Dense Bare Light Dense Bare Lignt Dense Bare Light Dense Vegetation Vegetation Vegetation Vegetation Vegetation Vegetation Vegetation Vegetation 0. 0. 0. 0. 0. 0. 0. 0. 0. 0. 0. 0. 1 n 10 05 20 10 05 25 15 10 30 20 15 n. 0. 0. 0. 0. 0. 0. 0. J. 0. 0. 0. 50 40 30 60 45 35 65 50 -t-0 75 60 50 NOTE: Values of C for earth surfaces are further varied by degree of satura- tion, compaction, surface irregularity and slope, by character of sub- soil, and by presence of frost or glazed snow or ice. TABLE 8.3.2. RETARDANCE COEFFICIENT Cr (3) Surface Cr Smooch asphalt 0.007 Concrete paving 0.012 Tar and gravel paving 0.017 Closely clipped sod 0.046 Dense bluegrass turf 0.060 8-125 ------- 10 •± 6 z U! z z a: 100 year FREQUENCY 50 year FREQUENCY 20 year FREQUENCY 10 year FREQUENCY 5 year FREQUENCY I I 20 40 60 fO DURATION,minutes 100 120 Figure 8.3.2. Typical intensity-duration-frequency curves.3 8-126 ------- The SCS Method The SCS run-off equation is a. method of estimating direct run-off from storm rainfall of a duration of 1 day or less. The equation is: x (P - Ia) + S where Q * accumulated direct run-off P « accumulated rainfall (potential maximum run-off) Ia » initial abstraction including surface storage, interception, and infiltration prior to run-off S * potential maximum retention To simplify uae of the -aquation, the following empirical relationship is ofcen used in the SCS run-off equation: I» - 0.2S (4) Substituting 0.2S for Ia, the equation becomes : q . (p ~ °'2S)2 (5 q P + 0.8S ^5 and is the rainfall run-off equation used for estimating direct run-off from storm rainfall. S values have been transformed into curve numbers (CN) to allow for graphical solution of run-off. Figure 3.3.3, reprinted from Reference 6 (USDA, Soil Conservation Service, 1973), provides ihe graphical solution using the curve number method. Research has been conducted to correlate curve numbers with various hydrologic soil cover complexes, as illustrated in Table 3.3.3, also reprinted from Reference 6. The information in the table is useful in determining run-off from a vegetated unit or closed facility, but not from an unvegeCated active land treatment unit. In that case, an estimate of S is necessary to determine the appropriate curve number, from the equation: rv 100° CN S * 10 > The Part 264 regulations for run-on control require that the system be "capable of preventing flow onto the active portion of the landfill during peak discharge from at least a 25-year storm." The SCS has developed the following equation to estimate peak discharge: qp - (KAQ)/Tp (7) 8-127 ------- I* <• II 2 2 OO 0.0 OJOO QO : * O.O. Z O O ui u. u. O Z ------- Land use and treatment or practice Fallow Straight row Row crops Straight row Straight row Contoured Contoured Contoured and terraced Contoured and terraced Small grain Straight row Straight row Contoured Contoured Contoured and terraced Contoured and terraced Close-seeded legumes or rotation meadow Straight -row Straight row Contoured Contoured Contoured and terraced Contoured and terraced Pasture or range No mechanical treatment No mechanical treatment No mechanical treatment Contoured Contoured Contoured Meadow Woods Farmstead* Roads4 Dirt Hard surface Hydrologic condition Poor Good Poor Good Poor Good Poor Good Poor Good Poor Good Poor Good Poor Good Poor Good Poor Fair Good Poor Fair Good Good Poor Fair Good ~ Hydrologic A 77 72 67 70 65 66 62 65 63 63 6L 61 59 56 53 64 55 63 51 68 49 39 47 25 6 30 45 36 25 59 72 74 B 86 31 78 79 75 74 71 76 75 74 73 72 70 77 72 75 69 73 67 79 69 61 67 59 35 53 66 60 55 74 82 84 soil group C 91 88 85 84 82 80 78 84 83 82 81 79 78 85 81 83 78 80 76 86 79 74. 81 75 70 71 77 73 70 32 87 90 D 94 91 89 88 36 82 81 38 37 85 34 82 31 89 35 85 33 83 30 89 84 80 88 83 79 78 83 79 77 86 89 92 alncluding rights-of-way. 8-129 ------- where qg = peatc rate jf iiscnarge A a drainage area Q » storm run-off (as determined from Figure 8.3.3) K " a constant, and In is Che time to peak flow and is calculated as: TP = -T + L (8) where D * storm duration, and L * drainage area lag The value of q_ can be approximated by making some simplifying assumptions. For instance, Che value of q_ is maximized as Tp is minimized. For a given storm event, say tne 25-year storm, Tp is minimized if L, the lag time, is arbitrarily set equal to zero. Substituting a value of 484 for K will then provide the estimate of the upper bound on peak run-on discharge rate. If the applicant's calculation of peak discharge is at least as great using any procedure, the estimate should be conservative. In other cases, the permit writer will have to exercise judgment, or follow the exact computation procedure proposed by SCS for estimating peak discharge rate. In the latter case, it is recommended that the permit writer refer to References 6 (Kant, 1973) or 7 (Mockus, 1969). The permit writer's worksheet for evaluating che applicant's calculation of -peak run-on rate is presented in Figure 8.3.4. Erosion Control Erosion control is an important part of the surface water control plan. Vegetation planted near and on the sides of diversion ditches will stabilize the soil, securing their structural integrity. However, vegetation can cake between 1 and 2 years Co become firmly established. During that period, mulch and hay bales should be used to stabilize these areas. Mulch can be pegged in place on steeper slopes. Erosion control also prevents siltation that can clog diversion ditches, resulting in surface ponding which should be avoided. References 8 through 11 listed in subsection 8^3.5 should be reviewed to obtain a more thorough understanding of the erosion control techniques described above. 8.3.3.2 Minimizing Run-off of Hazardous Constituents- Surface run-off must be controlled to minimize the release of hazardous constituents from the unit. Surface run-off from the treatment zone can occur during waste application, periods of heavy rainfall, or following a moderate to heavy snowfall with subsequent rapid melting. Under normal conditions, surface run-off should not occur during waste application. Approaches to minimize surface water run-off include proper facility siting and design and 8-130 ------- Calculation of peak run-on rate for design a torn event Has this part of the appiicanc's sufamittal been read _____ and evaluated? Yea What technique was used to calculate the peak. — Using this technique, what quantity (note units) or rate and duration of run-on is the proposed system designed to handle? i Independent Check Using the Rational Method ! "~ Define Necessary Parameter Values - 1. Surface slope, So " __ "N 2. Retardance coefficient, Cr « ' Calculate che 3. Rainfall iatensity during tiae / value of b of concentration, i * ______ in*/hr J from £q. 2; b m _^_^ (noca data source) 4. Maximum overland flow length, LQ * ft. 5. Run-off coefficient, C * (from Table 8.3.1) —»•> Calculate time of concentration, tc from Eq. 1; tc « min Is the value of tc calculated from the value used in 3. to determine i? Yes No If yes, recalculate i, b-, and cc 6. Drainage area, a » ______ acres -H*- Calculate peak run-on rate, Q - Cia * cfs Figure 8.3.4. Worksheet for determination of peak run-on discharge rate for evaluation of run-on control. 3-131 ------- implementation of good management practices, such as application scheduling and periodic cultivation. Noes cnac .-aanagement practices complement a facility design and should not be considered as an alternative or suostitute. The success of minimizing surface run-off from the unit is pradicated on a carefully thought-out facility design. The land treatment unit should be designed such chat liquids contained in the waste applied infiltrate the soil before moving laterally (overland flow) to the perimeter of the site. I.-, addition, cue unit should be managed whereby loading rates and frequency of application are scheduled such that: • waste is noc applied during periods when the soil is saturated, • waste is not applied to the treatment zone when the surface soil is frozen, or • waste is not applied during periods of heavy precipitation. Surface run-off resulting from excessive precipitation can be minimized by maintaining a relatively level treatment zone surface and periodic cultivation. I: 13 recommenced that the surface slope be less than 5 percent. Grades greater than 5 percent will significantly increase overland flow velocities with a subsequent increase in soil erosion. However, it is also important to avoid water and waste ponding. Standing water can create anaerobic conditions and/or excessive leaching of waste constituents. In most cases, a 1-percent grade should be sufficient to ensure noneroding run-off ind prevent water and waste ponding. With respect to cultivation, contour tillage across the slope rather than with it is preferred. Cultivation improves soil granulation, which maintains porosity, aids infiltration, and prevents surface crusting. Tillage also improves waste degradation by aerating the soil and increasing waste/soil contacting. In addition to surface water run-off, hazardous constituents adsorbed to soil particles or particles of the waste material themselves can be released from che treatment zone by soil erosion losses. Soil loss per unit area due to water erosion can be calcuated using the Universal Soil Loss Equation. The equation is: A-RKLSCP where A, che computed soil loss per unit area, is the product of the following factors: R a rainfall and run-off erosivity index K * soil erodibility factor, tons/acre L * slope-length factor S » slope gradient (steepness) factor 8-132 ------- C s crop rsanageraenc v/egecacive cover) factor P * erosion-control practice Input values for each factor and sample calculations are presented in Evaluating Cover Systems for Solid and Hazardous Waste. ^-~ 8.3.3.3 Management of Accumulated Run-off and Run-on— To avoid migration of contaminated run-off, land treatment facilities muat be designed and operated to collect and subsequently manage surface run-off from the treatment unit. It should be noted that the run-off standards do not distinguish between active areas, undeveloped areas (surrounding land), or closed areas of the land treatment facility. Run-off, as defined under 3260.10, .seans any rainwater, leachate, or other liquid that drains over land from any part of a facility. A facility, as defined under §260.10 means all land and structures used for treating, storing, and disposing of hazardous waste. Concerning the collection of run-off as required under §264.273(d), the Agency proposes the following:13 « Active area run-off should definitely be collected and managed as a hazardous waste, as explained in the Permit Applicants' manual.^ • Run-off from closed areas should also be collected, although it need not be assumed to be a hazardous waste. * Run-off from access roads and building roofs need not be collected. The technical issues associated with the management of accumulated run-off are identified in Figure 3.3.5. Magnitude of the 24-Hour, 25-Year Storm Event Facilities must be designed to handle the run-off volume associated with at least the 24-hour, 25-year storm. Figure 8.3.6 indicates the depth of rainfall for this event throughout che United States. The permit writer's worksheet for evaluating the magnitude of the selected scorm event is presented in Figure 3.3.7. Calculation of Run-off Volume The volume of run-off expected for this storm event can be calculated using che SCS Method or the Rational Method, as described in subsection 8.3.3.1. The Part 264 regulations for run-off require that the run-off management system "collect and control at least the water volume resulting from a 24-hour, 25-year storm." Because the rational method only calculates peak discharge, use of the SCS method may provide a more straightforward approach to calcula- ting' the total run-off water volume associated with the design storm event. First, Q is estimated using the graphical method shown in Figure 8.3.3. Then the total run-off volume associated with the storm event is approximated as: 3-133 ------- RUN-OFF CONTROL SYSTEM DESIGN AND CONSTRUCTION SYSTEM OPERATION AND MAINTENANCE DETERMINATION OF MAGNITUDE/INTENSITY OF 25-YEAR, 24-HR STORM EVENT INSPECTION REQUIREMENTS CALCULATION OF RUN OFF VOLUME FROM DESIGN STORM EVENT MAINTENANCE DESIGN OF RUN-OFF COLLECTION/DIVERSION SYSTEM MANAGEMENT OF HOLDING FACILITY TO MAINTAIN DESIGN CAPACITY DESIGN OF RUN-OFF HOLDING OR TREATMENT FACILITIES TANKS - SEE PART 264 SU8PART J IMPOUNDMENTS - SEE PART 264 SU8PART K AND SECTION 6.0 IN THIS MANUAL Figure 8.3.5. Technical issues associated with run-off control. 8-134 ------- 8-135 ------- Determination of Magnitude/Intensity of 24-hr, 25-year storm event - Has this part of the applicant's aubmiccai been read and evaluated? - What storm magnitude was selected by che applicant' - What depth of rainfall is this storm event equivalent to? based on what references Independent Check - What is the rainfall depth associated with Che 24-hr, I 25-year stora - based on what reference Is the rainfall depth established by the applicant at least as great as this determination? Then, likewise, this aspect of the applicant's submittal is or is not acceptable Yes No Yes inches inches No is acceptable is not acceptable Figure 8.3.7. Worksheet for evaluating the magnitude of the selected storm event. 8-136 ------- v » L2 where V is in fc3, and A * area of the active land treatment unit in square feet The average flow rate can be approximated by assuming that this quantity of run-off flows for a duration of 24 hours. If peak discharge is of concern or used as a design basis in the applicant'=5 presentation, then the computation techniques specified for determining peak run-on rate would be applicable. The permit writer's worksheet for evaluating run-off volume computations is presented in Figure 8.3.3. Design of Run-off Collection/Diversion System This design will be site-specific depending on topography, site layout, and other factors. The design may include an open channel with an impervious floor flowing by gravity to a collection or storage basin. Alternatively, if the topography is less favorable, collected run-off may have to be puraoed tc some point where continued gravity flow is aot Longer possible to lift the collected run-off into a storage tank or impoundment. Such storage is envisioned to be necessary to allow for determination of whether the collected run-off is hazardous* A discussion of the management of these storage facilities follows. If the applicant proposes Co divert and collect sconnwater run-off by installation of an open channel or culvert, it will be necessary to check the proposed dimensions to assure that the design run-off volume can be carried without overtopping of the channel. Open channel flow can be calculated using the Manning formula, wherein: Q3 _LAR2/3sl/2 where n 3 Manning's roughness coefficient A * cross-sectional area of flow R. a A/WP, the hydraulic radius (where WP a the wetter perimeter), and S - the channel slope. Values of n for a variety of surface materials area listed in Table 3.3.4. Th* applicant is required to provide an explanation of now collecte-i liquid will be managed for disposal. As part of the submittal, the time required to empty the facilities must be estimated and the method of disposal of collected run-off (i.e., treatment, evaporation) must be described. 8-137 ------- Calculation of run-off volume from design scora event Has this part of Che applicant's .ubmictai oeen read and evaluated? Using this technique, what quantity (note units) or rate and duration of runoff is the proposed system designed to handle Independent Check Using the SCS Method Define parameter values: • Select a value of S • Calculate CN from CN 10 + S Yes No What technique was used to calculaca riin-off Is the run-off volume prssented in terms consistent with the regulation, i.e., the run-off volume associated with :he 24-hour, 15-year storm? Yes No • Interpolate Q from Figure 8.3.3 inches Calculate V, volume of run-off: • A * active portion area » sq.ft. • V - QA/12 * cu.ft. Is the volume of runoff used as the design basis at lease as great? Yes No Figure 8.3.8. Worksheet for evaluating run-off volume computations, 8-138 ------- TABLE 8.3.4. REPRESENTATIVE VALUES OF n, MANNING'S ROUGHNESS COEFFICIENT16 Mature ;f curfaca Neat cetnenc surface Wood-stave pipe Plank flumes, planed Vitrified sewer pipe Metal flumes, smooth Concrete, precast Cement mortar surfaces Plank flumes, enplaned Common-clay drainage tile Concrete, monolithic Brick with cement mortar Cast iron Cement rubble surfaces Riveted steel Canals and ditches, smooth earth Metal flumes, corrugated Cana 1 s : Dredged in earth, smooth In rock cuts, smooth Rough beds and weeds on sides Rock cuts, jagged and irregular n Min 0.010 0.010 0.010 0.010 0.011 0.011 0.011 0.011 0.011 0.012 0.012 0.013 0.017 0.017 0.017 0.022 0.025 0.025 0.025 0.035 Max 0.013 0.013 0.014 0.017 0.015 0.013 0.015 0.015 0.017 0.016 0.017 0.017 0.030 0.020 0.025 0.030 0.033 0.035 0.040 0.045 8-139 ------- 3-un-Trf :o I lac caa from cne active portion of z landfill rnusc be analvsad no determine Che presenca ar.d concencration of hazardous constituents. If coiLecced run-off proves hazardous, as defined in Part 26L, it must be managed as a hazardous waste. To do so will often require storage of the collected run-off in a tank, container, or surface impoundment. If so, these facilities must be designed, constructed, and operated in conformance with "he Standards of ParC 264. The permit applicant must adequately demonstrate his proposed method of emptying or otherwise managing run-off collection facilities after storms to maintain the design capacity of these systems. The regulations require diversion of run-on as opposed cj :o llaccion. Therefore, an adaquati monitor ir.g -na inspection plan for run-on facilities will often be adequate to demonstrate proper management of these systems. However, some part of the applicant's submittal should designate how the system will be maintained if problems are found during inspection. The permit applicant should also identify what actions will be taken when systems are found to be operating incorrectly or not at all. In addition, preventive procedures to be implemented, such as routine maintenance, should be described. Figure 8.3.9 provides a worksheet to assess the management practices associated wicn the Land treatment run-on and run-off control systems. 8.3.3.4 Wind Dispersal Control Measures— Ihe land treatment unit must be designed and operated to prevent wind dispersal of particulate matter from che site that .-night contain nazardous constituents. Note chat control of wind dispersal also applied during closure and pose-closure care, as required by § § 264.280(a)(8) and 264.280(c ) (2) , This concern arises because hazardous waste will generally oe placed on or just below the soil surface. Measures to control wind dispersal of particulace matter include: • timing of waste applications, • maintenance of surface soil moisture content, • use of chemical soil stabilizing agents, • use of wind breaks, and/or • establishment of a vegetative cover. Factors.that affect particulate matter dispersal are local prevailing wind direction, type of waste co be disposed, and operating techniques being or to be employed at the site. Familiarization with each of these will enable proper steps co be taken co minimize the effects of wind dispersal. Scheduling of applications to avoid periods of excessive wind speed and turbulence will minimize wind dispersal of particulate matter. Also, di.------- MANAGEMENT OF UNITS ASSOCIATED WITH RUN-ON AND RUN-OFF CONTROL SYSTEMS Has this part of Che applicant's submittal been read and evaluated? yes no Are Che provisions for maintaining the run-off design capacity described? yes no Are automatic control and/or alarm systems used to initiate emptying procedures ana diert personnel to yes no potential problems? Does the run-off management plan include provisions for testing run-off collected from active portions of the site for hazardous constituents? yes no Does the application describe how run-off found to be hazardous will be treated or disposed? Does the application describe how non-hazardous run-off will be disposed of or discharged? yes no yea no Figure 3.3.9. Worksheet for evaluating management of unit's run-on and run-off control systems. • 8-141 ------- In addition to implement!.-.3 ^ooa .-nanagement techniques, Che soil should be stabilized using either water to wet the surface or chemical soil staoilizing agents. Information about surface soil stabilizing techniques using water or chemical agents is presented in references 1 and 17. One method of maintaining soil moisture content at effective levels, is to apply accumulated run-off. If chemical stabilizing agents are aoplied to the treatment zone, they should be carefully evaluated to determine that they do noc adversely affect the treatment process or cause environmental damage. Figure 8.3.10 presents a worksheet to aid in the evaluation of the applicant's proposed wind disoersal control -aeasuras. 8.3.3.5 Inspection of Land Treatment Unit— Aa part of the inspection plan required under §270.14(b)(5), the owner or operator of a land treatment unit must submit a schedule for periodic inspection of the facility to determine the adequacy of surface water and wind dispersal control measures. In addition to the general inspection requirements specified in §270.14(b)(5) , the inspection plan for land treatment facilities must include provisions whereby the unit will be inspected weekly and after storms to detect evidence of the following: 1. deterioration, malfunctions, or improper operation of run-on and run-off control systems, and 2. improper functioning of wind dispersal control measures. The weekly inspection procedures should be specific. The applicant should describe whac, how, and where Che control systems will be checked. Specific criteria that will be used to evaluate the proper operation of these systems should be stated. The use of a form requiring written completion by the person conducting the inspection should be included in the application for review. Also, any employee responsible for inspections should be identified by name or title. 8.3.3.5.1 Sun-on and Run-off Control Systems—Inspections of run-on and run-off control systems will vary in complexity in relation to the complexity of the systems' designs. In general, run-on control systems are simply intended to divert the surface water flow around/away from the treatment unit. In most cases, it will consist of trenches that may or may not be lined. Alternatively, the run-off control system is primarily designed to collect and contain all liquid overland flow from the active portion of the treatment unit and deliver it to some type of holding or treatment facility prior to disposal or reapplication. A run-off control system is likely to be of a more sophisticated design than a run-on control system since it will be handling liquid that has been in contact with the hazardous waste. The following two basic concerns should be investigated during any inspection: • The physical integrity of the system with respect to original construction, and • The capacity of the system compared to original design. 8-142 ------- CONTROL OF rfIND DISPERSAL Has this part of che applicant's submittal been read and evaluated? yes no Are che methods to control wind dispersal described? yes no Are waste applications and subsequent disking going to be scheduled to minimize wind dispersal of particulaCe matter9 ;'es no If wind breaks are going co be used, has the applicant described what they are, where they will be located, yes no and how maintained? If a vegetative cover is going to be established, has the type of cover and associated maintenance been described? ^ yes no If soil moisture control will be implemented to minimize wind dispersal, has the applicant described the frequency of irrigation and vater supply source? yes no If chemical agents will be used to stabilize the soil, has the applicant identified wnat tney are, what impact they may have on the treatment process and application yes no schedule? Has the applicant identified what actions will be caken when control systems are found not to be operating as intended? yes no Has the applicant provided a. description of -mat pre- ventive measures will be implemented, such as routine maintenance, to minimize or reduce the likelihood of yes no malfunctions? Figure 8.3.10. Worksheet for evaluating wind dispersal control measures. 8-143 ------- For either run-en or run-off -oncroi systems, inspections of integrity should address: • The liquid collection trench, the slope of culverts or piping, breaches, and tight joints. • If the conveyance system is lined, the liner material should be checked for adhesion tj substrate, holes, wear points, and cracks. • If mechanical equipment are part of the system 'e.g., pumps, valves, gates) they should be checked for leaks, malfunction, or other damage. For run-on control systems, inspections to confirm continuance of design capacity should address: • The presence of sedimentation, debris, or other materials chat could inhibit system flow. » The condition or cerrain dovmgradient from the system exit chat could cause liquids to back up inco the system. For run-off control systems, inspections to confirm continuance of design capacity should investigate: 9 The presence of sedimentation, or encrustation in Che system. • The operation of mechanical equipment in the system. • The status (full/empty) of holding or treatment systems downstream of the run-off control system. To the extent that the holding/treatment equipment associated with a run-off control system are identified as storage, treatment, or disposal facilities under Part 264, they too muse have an inspection plan as required by §270. 14(b)(5) and §264.15. 8.3.3.5.2 Wind Dispersal Control Systems—As previously discussed, there are various options to control wind dispersal of particulate matter at a land treatment facility. In some cases, a combination of methods will be implemented. AC a minimum, inspection procedures should include close visual observation of all wind dispersal control systems on a weekly basis. During periods of high winds or when wastes are very susceptible to wind dispersal, the frequency of inspection should be increased. Any individual assigned to inspect Che facility should have the authority to require immediate repair or cleaning of wind dispersal control systems. Cleaning would be necessary where fences or burlap screens are installed to catch wind blown material. Figure 3.3.11 provides a worksheet for assessing the adequacy of the inspection plan, as it relates to the referenced two control measures. 8-144 ------- INSPECTION REQUIREMENTS Has) this part of che applicant's aubmitcal been reviewed tad evaluated? Does Che application include a schedule identifying vnen Che unit will be inspected to determine Che adequacy oc yea surface water control and wind dispersal control aeasure*? Are individuals responsible for conducting Che inspections _ identified? yes Are Che icems Co be inspected listed? Does the application describe the procedures for responding Co observed inadequacies? yet Are recordkeeping procedures described? yes Do weekly and post storm run-on and run-off inspection procedures address: I. Inspection of liquid collection trenches, culverts or piping systems for proper slope, breaches and yea tight joints? 2. Inspection of lined conveyance systems for adhesion _ Co substrate, holes, vear points, and cracks? yes 3. Inspection of mechanical equipment for leaks, _ malfunction, or other damage? yes Oo run-on control system inspection procedures include: I. Inspection for the presence of sedimentation, debru, and other material chat could inhibit flow? yes 2. Inspection of the downgradient terrain co identify _ potential causes of liquid backup? yes Do run-off control system inspection procedures include: I. Inspection for Che presence of sedimentation or _ encrustation? yes 2. Inspection* to determine Che proper operation of __ mechanical equipment? yes 3. Inspeccions to determine the status (full/empty) _ of holding or creataent systems? ye* Wind Disp«rsal Control Systems: !• Does Che inspection plan include procedures for weekly visual inspections of wind dispersal control systems' yes 2. Dee* Che frequency of inspection increase during _ periods of high winds? yes Figure 8.3.11. Worksheet for evaluating Che applicant's inspection program. 8-145 ------- Although specific requirements are not soecified in Par; 270 or 264, Che owner or operator of the unit should, ac a minimum, initiate the following response when surface water control or wind dispersal control measures fail: 1. suspend waste application, 2. institute backup system or control measures, 3. contact local authorities (state Hazardous Waste Agency or Coordinator, and fire and police departments, as necessary), 4. once che prooiem is under control determine the reason for failure and take corrective action. 8.3.4 Draft Permit Preparation Condition B of the Permit Module XIV (see Section 4) addresses design and operating requirements of the land treatment facility. Condition 3 is comprised of six components that address: (1) minimization of run-off of hazardous constituents during the active life of the land treatment unit, (2) control of surface water run-on, (3) control and management of run-off, (4) management of run-on and run-off collection and handling systems, (5) control of wind dispersal, and (6) plans to inspect site ac regular intervals. The components of Condition B may be implemented as permit requirements by reference to a sermit attacnraent that includes the design and operating plans and specifications proposed in the permit application. To be suitable for substitution in the permit condition attachment, the submitted application information should include the following for each of the six components: • Minimization of run-off of hazardous constituents: plans to delay waste application when treatment zone soil is saturated plans to suspend application when surface soil is frozen plans to suspend application during periods of heavy precipitation schedule of surface soil tillage or establishment of a vegetative cover [Note: The attached olans and specifications should demonstrate that the treatment zone will be designed, constructed, operated, and maintained to minimize run-off of hazardous constituents during the active life of the land treatment unit.] 8-146 ------- Control of surface water run-on: designs for contour grading surrounding land construction of diversion terms or ditches all calculations of peak rate of discharge (Note: The attached plans and specifications snouid demonstrate that the control system is capable of preventing flow onto the treatment zone during peak, discharge from at least a 25-year storm.] Control and aLanasretnent of run-o'f: - designs for minimizing run-off all calculations of peak run-off volume engineering plans for controlling run-off [Mote: Tha attached plans and specifications should demonstrate the run-off management system will collect and control at least the water volume resulting from a 24-nour, 25-year storm.] Management of run-on and run-off: all calculations supporting tne design and sizing of run-off collection facilities management plans for holding or treatment facilities procedures for assessing whether run-off is a hazardous waste that must be handled accordingly [Note: The Attachment must demonstrate how the Permittee will comply with §264.273(e).] Control of Wind Dispersal: plans for timing of applications measures to maintain soil moisture content plans to use soil stabilizing agents or vegetative cover - design and construction of wind breaks [Note: This condition only applies if the treatment zone contains particulate matter which may be subject to wind dispersal. The Attachment must demonstrate how the Permittee will comply with S264.273(f).] 8-147 ------- Insoection of Land Treatment Unit: plans to inspect the unic weekly and after storms [Mote: §270.14 requires Che general inspection schedule submitted under §264.15(b) to address the requirements of §264.273(g). The Attachment should demonstrate compliance with §264.272(s)- Parme condition VI.E (see Module II) requires the Permittee to remedy any deterioration or malfunction discovered during an inspection and to keep records of inspections.] 8-143 ------- 8.3.5 References 1. U.S. Environmental Protection Agency. RCRA Guidance Document, Land Treatment, Draft Report, Office of Solid Waste. Jaunary 1983. 2. U.S. Environmental Protection Agency, Hazardous Waste Land Treatment, prepared by K. W. Brown and Associates, Inc. for U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, Solid and Hazardous Waste Research Division, Cincinnati, OH. Report No. 3W-374. 1983. 3. Clark, J. W., et al. Water Supply and Pollution Control. 2nd ad. International Textbook Comoany, Scranton, P.\. l?~1 , 4. Viessnsan, W. Jr., et al. Introduction to Hydrology, Intext Educational Publishers, New York. 1972. 5. Seelye, E. E. Data Book for Civil Engineers Design, John Wiley and Sons, Inc. New York, NY. 1960. 6. Kent, X. M. A Method for Estimating Volume 2nd .late of Runoff in Small Watersheds. U.S. Department of Agriculature, Soil Conservation Service. SCS-TP-149. Revised April 1973. 7. Mockus, V. National Engineering Handbook. Section 4 - Hydrology. Chapter 10. Estimation of Direct Runoff from Storm Rainfall. U.S. Department of Agriculature, Soil Conservation Service. Reprinted witft Minor Revisions, 1969. 3. U.S. EPA, Erosion and Sediment Control, Surface Mining in the Eastern U.S., Part 2, Design. EPA Report 625/3-76-006. October 1976. 9. U.S. EPA, Design and Construction of Covers for Solid Waste Landfills. Municipal Environmental Research Laboratory, EPA Report 600/2-79-165. August 1979. 10. U.S. EPA, Process Design Manual for Land Treatment of Municipal Wastewater, EPA Technology Transfer Series, EPA Report 625/1-77-008. October 1977. 11. Brady, N. C. The Nature and Properties of Soils. 8th Ed. MacMillan Publishing Company, Inc. New York, NY. 1974. 12. Lutton, R. J. Evaluating Cover Systems for Solid and Hazardous Waste, Prepared by U.S. Army Engineer Waterways Experiment Station for U.S. Environmental Protection Agency, Solid and Hazardous Waste Research Division, Cincinnati, OH. EPA Report SW-867. September 1982. 13. U.S. Environmental Protection Agency, Internal Memorandum from Art Day to Kenneth A. Shuster, Trip Report - Region V - Permit Applicant's Program, June 13, 1983. 8-149 ------- 14. U.S. Environmental Protection Agency. Psrrait Applicant: 3 Guidance Manual for Hazardous Waste Land Storage, Treatment, and Disposal Faciliries. Draft Report. Office of Solid Waste, Land Disposal Branch. Washington, D.C. March 1983. 15. U.S. Weather Bureau, 1961b, Rainfall-frequency atlas of the United States for durations from 30 minutes to 24 hours and return periods from 1 to 100 years, Tech. Paper 40. 16. Daugherty, R. L., and J. 3. Franzini. Fluid Mechanics and Engineering Applications, 6th Edition, McGraw-Hill Book Company, New York. 1965. 17. Versar, Inc. Technical .VsaidCance j.n tne Coal BAT Review-II; Special Report: Revegetation of Goal Strip Mines, U.S. EPA Contract No. 68-01-5149. November 26, 1979. 8-150 ------- 8.4 FOOD-CHAIN CROPS .-LEQUIREMENTS 3.4.1 Federal Requirement Sections 270.20(d) and (e) stace that: "(d) If food-chain crops are to be grown in or on Che treatment zone of the land treatment unit, a description of how the demonstration required under §264.276(a) will be conducted including: (1) Characteristics of the food-chain crop for which the demonstration will be made. (2) Characteristics of the waste, treatment zone, and waste application method and rate to be used in the demonscrat ion; (3) Trocaduras for crop growth., sample collection, sample analysis, and data evaluation; (4) Characteristics of the comparison crop including the location and conditions under which it was or will be grown; (e) If food-chain crops are to be grown, and cadmium is present in the land-treated vaste, a description of how the requirements of $264.276(b) will be complied with." The corresponding Part 264 standards, covered under §264.276, state thac: "The Regional Administrator may allow the growth of food-chain crops in or on the treatment zone only if the owner or operator satisfies the conditions of this section. The Regional Administrator will specify in Che facility permit the specific food-chain crops which may be grown. (a)(l) The owner or operator must demonstrate chat there is no substantial risk to human health caused by the growth of such crops in or on the treatment zone by demonstrating, prior to the planting of such crops, that hazardous constituents other than cadmium: (i) Will not be transferred to the food or feed portions of the crop by plant uptake or direct contact, and will not otherwise be ingested by food-chain animals (e.g., by grazing); or (ii) Will not occur in greater concentrations in or on the food or feed portions of crops grown on the treatment zone than in or on identical portions of the same crops grown on untreated soils under similar conditions in the same region. (2) The owner or operator must make the demonstration required under this paragraph prior to che planting of crops at the facility for all constituents identified in Appendix VIII of Part 261 of this chapter that are reasonably expected to be in, or derived from, waste placed in or on the treatment zone. (3) In making a demonstration under this paragraph, the owner or operator may use field tests, greenhouse studies, available data, or, in the case of existing units, operating data, and must: (i) Base the demonstration on conditions similar to those present in the treatment zone, including soil characteristics (e.g., pH, cation exchange capacity), specific wastes, application rates, application methods, and crops to be grown; and 8-151 ------- ', li.) Describe Che procedures used in conducting any tasts, including the sample selection criteria, sample size, analytical methods, and statistical procedures. (4) If the owner or operator intends to conduct field tests or greenhouse studies in order to make the demonstration required under this paragraph, he must obtain a permit for conducting such activities. (b) The owner or operator must comply with the following conditions if cadmium is contained in wastes applied to che treatment zone: (l)(i) The pH of the waste and soil mixture must be 6,5 or greater at the time of each waste application, except for vasta containing cadmium ac concantrscions of 2 ag/kg ;dry weight) or less; (ii) The annual application of cadmium from waste taust not exceed 0.5 kilograms per hectare (kg/ha) on land used for production of tobacco, leafy vegetables, or root crops grown for human consumption. For other food-chain crops, the annual cadmium application rate must not exceed: Annual Gd application rate Time period (kilograms per hectare) Present to June 30, 1984 2.0 July 1, 1984 to Dec. 31, 1986 1.25 Beginning Jan. 1, 1987 0.5 (iii) The cumulative application of cadmium from waste must not exceed 5 kg/ha if the waste and soil mixture has a pH of less than 6.5; and (iv) If the waste and soil mixture has a pH of 6.5 or greater or is maintained at a pH of 6.5 or greater during crop growth, the cumulative application of cadmium from waste must not exceed: 5 kg/ha if soil cation exchange capacity (CSC) is less than 5 meq/lOOg; 10 kg/ha if soil CEC is 5-15 meq/lOOg; and 20 kg/ha if soil CEC is greater than 15 meq/lOOg; or (2)(i) Animal feed must be the only food-chain crop produced; (ii) The pH of the waste and soil mixture must be 6.5 or greater at the time of waste application or at the time the crop is .planted, whichever occurs later, and this pH level must be maintained whenever food-chain crops are grown; (iii) There must be an operating plan which demonstrates how the animal feed will be distributed to preclude ingestion by humans. The operating plan must describe the measures to be taken to safeguard against possible health hazards from cadmium entering the food chain, which may result from alternative land uses; and (iv) Future property owners must be notified by a stipulation in the land record or property deed which states that the property has received waste at high cadmium application rates and that food-chain crops must not be grown except in compliance with paragraph (b)(2) of this section." 8-152 ------- a.4.2 Summary of Necessary Application Information 8.4.2.1 Food-Chain Crop Deraonscracion— If food-chain crop3 are to be grown during the active life of che treatment unit, the applicant must demonstrate that hazardous constituents will not be transferred to food or feed portions of che crop, or that hazardous constituents will not occur in greater concentrations in or on the food or feed portions of crops grown on the treatment zone than in or on identical portion of the same crops grown on untreated soils under similar conditions in the same region. Under either option, the owner or operator must address all potential food-chain contamination pathways including crop uptake, physical adherence to crop, and direct ingestion of contaminated crops by grazing animals. The application should contain a description of how the food-chain crop demonstration will be made using information available from the literature, greenhouse tests, field studies, or in the case of existing units, operating data. Note that any tests conducted to measure crop uptake must be based on specific waste and application rates used or expected to be used at the unit. The owner or operator must obtain a permit prior to conducting any field Casts or greenhouse studies. Part 1 - Existing literature - When published Literature is used to make the food-chain crop demonstration, the applicant should explain how the reported data relates to the treatment facility and can be extrapolated to make the demonstration. Part 2 - Greenhouse tests - The following issues should be submitted by the applicant if greenhouse tests are co be conducted :o make the food-chain crop demonstration: Crop characteristics - The common and scientific name of the crop or crops to be grown should be identified along wich the potential food or feed portions of the plant. Waste characteristics - If not previously submitted (see Sections 8.1.2.1.1. or 8.2.2.1), the applicant should list hazardous constituents in the waste and their respective concentration. Assessment of potential crop uptake - The applicant should explain how the potential for crop uptake will be assessed. If existing information from the literature will be used, the applicant should state and describe the data sources. If greenhouse or field tests will be used to evaluate plant uptake, a description of proposed test procedures addressing the following should be submitted: • test location; • test schedule; • number and size of )ts or containers; 3-153 ------- • number of treatment raplicat ions; • number of treatments; • rate of waste application; • soil characteristics; • soil preparation; • sampling and sample preparation methods; * analytical methods; • data interpretation methods; and • method of data presentation. Potential for external contamination - The application should contain in explanation of how external (surface) contamination of the food or feed portion of the crop will be precluded and how this will be substantiated in the demonstration. Potential for ingestion by food-chain animals - A description of how food chain animals will be prevented from ingesting hazardous constituents and how this will be substantiated in She demonstration should be submitted by the- applicant. Part 4 - Field tests - If field tests will be used in the food chain crop demonstration, the applicant should describe how each test will be designed and conducted, including the information described below: Plot configuration - A scale drawing showing the test plot layout, location, and dimensions should be presented. Crop characteristics - The applicant should identify the plant species and variety of the crop, the edible portion of the crop, and existing information concerning plant uptake of the hazardous constituents present in the waste by the crop being tested or by similar crops. Waste characteristics - The following information should be provided for each hazardous constituent present in the waste to be used during the demonstration (note that wastes used to make the demonstration should be similar Co those proposed to be land treated): • concentration, • volatility, • water solubility, and • persistence. 8-154 ------- Treatment zone cnaracc2rij;i^c - .'»r. evaluation or cna erfect of che following soil properties have on plane uptake of hazardous constituents shouia be Bade and presented in the application: • soil pH, • soil organic matter, • soil texture, and • soil cation exchange capacity. Waste application rate and method - Application rates and method that will be used in the food-chain crap iasonstracion jnouia be described in the application. Sample collection procedures - The following sampling procedures should be described by the applicant: harvest or sample collection, method of collection, quantity of sample collected, methods for obtaining representative samples, and sample preservation and transport. Analytical procedures - A detailed explanation of analytical methods, chain-of-custody control, and expected detection levels of Che constituents being analyzed should be submitted as part of the demonstration program. . Data evaluation methods - The following factors should be evaluated and results presented as part of the food-chain crop demonstration: • dilution effects due to growth, • variability between individual plants, • variability between waste application rate, • bioconcentration through plant uptake, • quantity taken up by crops, • persistence of hazardous constituents in plant tissues, and • concentration of hazardous constituents in edible portions. 3.4.2.2 Wastes Containing Cadmium— Part 1 - If cadmium is contained in the wastes to be land treated on plots growing food chain crops, the applicant must submit the information presented in Table 8.4.1. 8-155 ------- IABLS 8.4.1. EXAMPLE CADMIUM LOADING RATS TA3Lc Waste name and EPA ID No. 1. 2. 3. Annual wasca Annual cadmium Cd in waste application race loading Bg/kg kg /ha kg /ha Part 2 - The applicant should submit the following if animal feed is the only food-chain crop to be grown: • plant species and variety to be grown, • antecedent or native soil pH, • methods and frequency of soil pH adjustments (when required), • management plan to control cadmium release from unit, and • notice in land deed that soil has received cadmium-containing vastaal The following should be submitted if animal feed will not be the only food chain crop grown: • plant species and variety to be grown, • antecedent or native soil pH, • taechods and frequency of soil pH adjustments (when required), and • an operating plan for controlling applications of cadmium-containing waste(s). 8.4.3 Guidance on Evaluating Application Information 8.4.3.1 Food-Chain Crop Demonstration— If food-chain crops, which include tobacco, crops grown for human consumption, and crops grown for animals whose products are consumed by humans, are Co be grown, the reviewer should first determine whether the owner or operator plans to demonstrate: (1) that hazardous constituents will not be transferred to food or feed portions of the crop, or (2) that hazardous constituents will not occur in greater concentrations in or on the food or feed portions of crops grown on the treatment zone than in or on identical portions of the same crops grown on untreated soils under similar conditions 3-156 ------- '..a ihe same _-2giJn. [Nccs ^nac ^rowcn of rood-chain crops during the active years is optional.] As described in 8.4.2, Che applicant may make che demons eraCion using field cescs, greenhouse studies, available literature, or in che case of existing units, operating data. It is noted, however, that in most cases, field testing or operating data will be required to make the second demonseration option identified above. In evaluating the demonstration, it is particularly important to verify that test conditions simulate actual or expected site operating conditions. Consequently, the permit reviewer should compare the site design and operating conditions described in Section 8.3 and the conditions under which greenhouse or field studies to make the food-chain crop demonstration will be performed. Detailed discussions of greenhouse and fiald test experimental designs *.re oresantad In •Ireenhouae T-jchniquas for 3oil-Plant-Fertilizer Research^- and the Hazardous Waste Land Treatment manual?, respectively.In addition, a qualified agronomist should be consulted to help evaluate experimental designs and plant species selection. Agronomists may be found at local colleges or universities or state agricultural experiment stations or extension service offices. Results obtained from the demonstration must be statistically valid to ensure that the demonstration was thorough and adequate to confirm that there will be no substantial risk to human health caused by the growth or food-chain crops in or on the treatment zone. Part 270 requires that the owner or operator obtain a permit under$270.63 for conducting the food-chain crop demonstration. (See Section 3.1 for specific requirements for obtaining the demonstration permit.] The demonstration must be made for all hazardous constituents (i.e., constituents listed in Appendix VIII of Part 264) that are reasonably expected to be in or derived from the waste being or to be land treated. As stated above, any greenhouse study or field test performed to make the required demonstration must simulate conditions that are representative of the geographical location of the proposed or existing land treatment unit. For existing units, it is likely that operating data will be used to make the required demonstration. The following sources may be consulted to obtain representative values of the environmental parameters to be simulated and to gain an understanding of the effects of waste application on plant growth and constituent uptake: Soil Conservation Service, Agricultural Extension Service and Experiment Stations; U.S. Weather Bureau; and local colleges and universities. In addition, information on plant uptake of various substances can be found in the literature (1,2,3,4,5,6), as required under §270.20(d)(1) . The applicant must provide a description of the plant species and varieties to be grown at the site. The description should include an explanation of the following for each plant species identified: • tranalocation of hazardous constituents, • growth season, and • harvesting techniques and ultimate disposal. 8-157 ------- Table 3.4.2 provides, for illustrative purposes, a orief listing of pl uptake mechanisms involved in Che translocacion of pesticides fraa soils. Similar information should be presented by the applicant. If the hazardous constituent is trans location within the plant, the applicant should document where and how the constituent will be transformed to a nonhazardous form, or if not, how ic will be prevented from entering the food-chain such that it will not cause a substantial risk to human health. If the owner or operator elects to demonstrate that the concentration of hazardous constituent(s) in or on the food or feed portions of crops grown in or on the treatment zone will not be greater than corresponding portions of identical crops grown on untreated soils under similar -ondlcions in che same region, thsy susc fully describe Che characteristics of the comparison crop(s). The comparison crop essentially reflects the control group of a basic experimental design. The comparison crop serves as the base condition whereby any significant deviation from it would constitute a statistically meaningful change. Growth of the comparison crop(s) under field or greenhouse conditions. should be identical to the growth of the demonstration crop(,d) with che exception that the hazardous waste(s) under review is not applied to the soil. The worksheet presented in Figure 8.4.1 or similar list developed by the reviewer, should be used to systematically determine that both groups of plants are grown under identical conditions, except for the difference of treated and untreated soils. Figure 3.4.2 and 8.4.3 present worksheets that can be used to evaluate the adequacy of the permit application with regard to the information required for greenhouse tests and field tests performed to -nake the food-chain crop demonstrations, respectively. With respect to identifying potential consumers or uses of particular crops, the following sources should be consulted: • Local Agriculatural Extension Service • State Department of Agriculture • State University Agriculture Department • Buyers such as grain dealers and co-operatives • Local farmers 8.4.3.2 W««tes Containing Cadmium— Special interest is paid to cadmium because of its potential transfer through the food chain and adverse human health effects. Land treatment of cadmium-containing municipal and industrial wastes can result in an accumulation of cadmium in the soil. 3-158 ------- TABLE 8.4.2. PLANT UPTAKE AND TRANS LOCATION OF PESTICIDES FROM SOILS Insecticide Aldrin Dieldrin Isodrin Endrin Hepcachlor Hepcachlor epoxide Chlordane Endosulf an Toxaphene SHC Lindane DDT Diazinon OimechoaCe Disulfoton Phorace Parachion Chloroneb Arsenic Lead Aosor bed by root Ye 3 Ye 3 Yes Yes Yea Yea Yes Yes Probable Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Trans Located from root Yes Yes Probable Yes Yes Yes Improbable Yes Improbable Ye 3 Yes Probable Yes Probable Yes Yes Probable Yes Yes Yes Compounds found < Parent Yes Yes Improbable Yes Yes Yas Unknown* Yes Unknown* Yas Yes Probable Yes Unknown Yes Yes Probable Yes Yes Yes after translocat ion Metabolites Yas Probable Yes Yes Yes Unknown Unknown Unknown Unknown Yes Yes Yes Probable Probable Yes Yes Unknown Yes — *None, or has never been investigated. Adapted from Phung et al. (3). 8-159 ------- Untreated Soil Case znvironmencal Parameter/Condit ion Plane Species Treated Soil Case Air Tempera cure Air Humidity Soil Temperature Soil Mo is Cure Soil pH Soil Fertility: Nitrogen Phosphorous Potassium Soil Texture Cation Exchange Capacity Soil Depch Insolation (hours daily) Figure 8.4.1. Worksheet to evaluate similarities of conditions under «/hich food-chain crop demonstrations are made. 3-160 ------- Has the applicant identified the £«,.» -j f , — — c- ~ j •*. nw iijuincr r*rt^™«.to,; i -3 4. jr:.crr a Fl8uce 8'4'2' 8-161 yes n, the yes nc no yes no ------- Has the applicant presented tne layout, location, and dimensions of teat plots on a scale drawing? yes no Does Che application identify the species and variety of the crop, the edible portion of the crop, and previous information concerning hazardous constituent uptake? yes no" Are the concentration of hazardous constituents in the waste, the volatility, and water solubility of the hazardous constituents, and the persistence of chase constituent in soil deacnoea in the application? yes no Has the applicant presented an evaluation of Che soil properties that will affect plant uptake of hazardous _______ constituents? yes no Has the applicant described waste application rates and methods of application? yes no Does the application contain a description of all sample collection procedures associated with the demonstration? yes no Are analytical procedures and sensitivities described in the application? _ yes no Has the applicant provided an explanation of the statistical methods to be used to evaluate results and identified how results will be presented? yes no Figure 8.4.3. Worksheet to assess food-chain crop demonstration made by field tests. 3-162 ------- The presence of cadmium in the waste to be applied will have been decermined by the waste analysis required under the Treatment Demons t rat: ion (see subsection 8.1). If cadmium will not be present in the waste co be Land treated, proceed to subsection 8.5. However, if cadmium is present in the waste continue with the review under this section. The owner or operator must comply with certain management practices that are designed to limit the entry of cadmium into the food chain. The specific requirements of §264.276(b) chat oiust oe compiled with (if the waste to be applied contains cadmium) are presented above. To demonstrate compliance with the requirements of §264.276(b), the owner or operator must describe how he will maintain soil pH and cation exhange capacity at prescribed levels. Section 8,2.3 provides infcraatijn on evaluating these two parameters. An informative discussion of the relationship between food-chain crops and cadmium is presented in the Office of Solid Waste's Guidance Manual for the Classification of Solid Waste Disposal Facilities? and U.S. EPA's Process Design Manual for Land Treatment of Municipal Wastewater.^ One of the more important concerns at a site where cadmium is contained in the waste to be treated is the facility operating plan. The operating plan designed to preclude ingest ion by humans and prevent possible health hazards resulting from alternative future uses of the land should be reviewed to determine the chain of possession ot the crop after harvest. The distribution of any food-chain crop grown at the land treatment unit oiust be carried out such that there is no chance of ingestion by humans (e.g., it could be sold directly to a dairy farm or feed lot where it would be fed to cattle). Concerning possible health hazards from cadmium entering the food-chain as a result of alternative future land uses, the site should not be used as vegetable farms or home vegetable gardens that could result in significant dietary increase of cadmium. Acceptable provisions in the facility operating plan could include dedication of the site as a puolic park following closure or removal of the contaminanted soil. Figure 8.4.4. presents a worksheet that can be used to evaluate the adequacy of permit applications for land treatment units that will or are handling cadmium-containing waste. 8.4.4 Draft Permit Preparation Condition C of Module XIV (see Section 4) outlines the conditions to be specified in the permit. Foremost in permit preparation is the requirement that the permit writer specify that only those food-chain crops the owner or operator has demonstrated will not have contaminated levels above those found in similar crops grown on untreated soils under similar circumstances in the same region may be grown at the land treatment facility. Conditions of the permit relating to food-chain crops may be stipulated in che permit by reference to portions of the permit application. This pertains specifically to information describing: • plant species, • waste characteristics, 8-163 ------- Has the applicant specified the concentration of cadmium in wastes Co be applied, annual application rates, and soil loading of cadmium resulting from the application rates used? yes no" Does the application provide a description of the following: Species and variety of crop to be grown? yes no Initial or native soil pH? ^^^^ yes no Methods and frequency for adjusting soil pH (if necessary)? yes no If animal feed is the only food-chain crop produced, has the applicant provided a description of an operating plan fcr preventing uirecc numan consumption of produced animal feed and a plan to safeguard against cadmium entering the human food-chain resulting from future ______ _____ alternative land use? yes no Also, has the owner or operator identified that the land deed vili be changed :o indicate that the site has received elevated applications of cadmium and that food-chain crops should aot be grown except in accordance _____ with §264.276(b)(2)? yes no If animal feed will not be the only food-chain crop produced, does the application include an operating plan for controlling applications of cadmium to the soil? yes no Figure 8.4.4. Worksheet for evaluating adequacy of permit application where waste(s) containing cadmium will be or are being treated. 8-164 ------- • assessment of potential crop uptake, • potential for external human contamination 3nd ingestion by food-chain animals, • sampling and analytical procedures, and • treatment zone characteristics (if field study). Jnaer the food-chain crop provisions, the permit must specify how the site will be managed to limit the entry of cadmium, when contained in the waste, applied into the food chain. The permit should specify loading rates to prevent the build up of cadmium in the 'rroatrcent -one ioii. As with trie food-chain permit conditions, portions of the Part B permit application may be referenced in the permit to stipulate conditions for controlling applications of cadmium-containing waste. Condition C of Module XIV states that: If the Permittee has successfully demonstrated in accordance with 40 CFR 264.276(a) and Cb5 chat there is no substantial risk to human health from the growth of food-chain crops in or on the treatment zone, the permit writer may allow the growth of such crops. This decision should be documented in the administrative record. When cadmium is contained in wastes applied co the treatment zone, the permit writer should include a condition that requires compliance with §264.276(b). This condition should refaranca the Attacnment required by §270.20 which must demonstrate how the requirements of §264.276(b) will be complied with. 8-165 ------- 8.4.5 References 1. Allen, S. £., et al-. Greenhouse Techniques for Soil-Plant-Fertilizer Research. Bulletin Y-I04, National Fertilizer Development Center, Tennessee Valley Authority, Muscle Shoals. Alabama. May 1976. 2. Brown, K. W., et al. Hazardous Waste Land Treatment. Prepared by K. W. Brown and iasociataa, Inc. for LI.a. Environmental Protection Agency, Municipal Environmental Research Laboratory. Solid and Hazardous Waste Research Division. Cincinnati, OH. Report No. SW-374. February 1983. 3. Phung, I., et al. Land Cultivation of Industrial Wastes and Municipal Solid Wastes: State-of-the-Art Study. Volume I, Technical Summary and Literature Review. Prepared by SCS Engineers for U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, Cincinnati, OH. EPA-600/2-78-140a. August 1973. 4. Sanies, R. L., and T. Asano, eds. Land Treatment and Disposal of Municipal and Industrial Wastewater. Ann Arbor Science, Ann Arbor, Michigan. 1976. 5. Overcash, M. R., and D. Pal. Design of Land Treatment Systems for Industrial Wasces - Thee nd Practice, Ann Arbor Science, Ann Arbor, Michigan. 1981. 6. Sidle, R. C., et al. Heavy Metals Application and Plant Uptake in a Land Disposal System for Waatewater. J. Environ. Qual., Vol. 5, No. 1. 1976. pp. 97-102. 7. U.S. Environmental Protection Agency. Guidance Manual for the Classification of Solid Waste Disposal Facilities. Office of Solid Waste. Washington, D.C. November 1979. 8. U.S. Environmental Protection Agency. Process Design Manual for Land Treatment of Municipal Wastewater. EPA Report-625/1-77-008. October 1977. 8-166 ------- 8.5 ESTABLISHMENT OF VEGETATIVE COVER AT CLOSURE 8.5.1 Federal Requirement Section 270.20(f) requires Che owner or operator to include in Che permit application (as part of the facility closure plan): "A description of the vegetative cover to be applied to closed portions of the facility, and a plan tor maintaning such cover during the post-closure care period, as required under §264.280(a)(8) and §264.280(c)(2). This information should be included in the closure plan and, where applicable, the oost-ciosur. ; The corresponding Part 264 standards, $264.280(a)(8) and §264.280(c)(2), require that the owner or operator: §264.280(a) "(8) Establish a vegetative cover on the portion of the facility being closed at such time that the cover will not substantially impede degradation, transformation, or immobilization of hazardous constituents in the treatment zone. The vegetative cover must be capable of maintaining growth without extensive maintenance." and, §264.2SO(c) "(2) Maintain a vegetative cover over closed portions of the facility;" 8.5.2 Summary of Necessary Application Information [Note: This item should also be included in the closure and post-closure cara plans described in Sections IV 2(c) and (d) of Chis document]. In addition to providing the following information, the applicant should submit a written description of procedures employed to establish and maintain a vegetative cover on closed portions of the land treatment unit: • common and scientific name and species and variety of plants to be established as the cover crop, • documentation of selected plant species viability, and • identification of minimum percentage of cover that will be maintained. 8-167 ------- 8.5.3 Guidance on Evaluating Application Information The primary purpose of establishing a vegetative cover at closure is to minimize wind and water erosion. Plant root systems stabilize the surface soil, minimizing erosion. Secondarily, the plane cover can aid in the treatment of hazardous constituents. Section 264.280(a)(8) requires the owner or operator to establish a vegetati'/e cover a- sucn time that the cover will noc substantially impede degradation, transformation, or immobilization of hazardous constituents. Because certain operating practices to maximize treatment, such as tilling, cannot be performed without damaging or destroying Che "egatative cover, cne owner or or»eri£3r zusc postpone seeaing until sufficient waste treatment has occurred following the last application. Results from unsaturated zone monitoring, treatment zone analyses, and data on run-off liquid quality, should be uaed in judging the degree of treatment achieved. Correspondingly, once the cover is established, operating practices to enhance waste treatment that are inconsistent (e.g., tilling) with establishment and maintenance of the vegetative cover should be discontinued. 1C is important co note that the owner or operator can be exempted from the vegetative cover closure requirement of §264.280(a)(8) and post-closure care requirements of §264.280(c)(2) if it is demonstrated that the level of hazardous constituents within Che treatment zone is not significantly greater than background values. Procedures to make this demonstration are similar to corresponding standards used for unsaturated tone monitoring under §264.278 (see Section 8.2.3.a), tiowever, only soil core monitoring is necessary, not soil-pore liquid monitoring. The RCRA Guidance Document for Land Treatment 1- describes a scheme for demonstrating that no statistically significant increases in hazardous constituents over background levels exist in the entire treatment zone. The document also describes the sampling protocol for unsaturated zone monitoring during the post-closure care period. The suggested scenario, for soil-core monitoring, involves a geometrically progressive sampling schedule at 1/2, 1, 2, 4, 8, 16, and 30 years after the pose-closure care period begins. Soil core samples should be taken at various depth increments- within the treatment zone, rather than just below the treatment zone as required for unsaturated zone monitoring during the active years. Concerning soil-pore liquid monitoring, which only continues for 90 days after the last waste application, at least two sampling events should occur. The reason for this latter condition is that the Agency expects that the fast-moving constituents that the soil pore liquid monitoring system is designed to detect should migrate out of the land treatment zone soon after cnese constituents are applied if they are to migrate at all. The owner or operator of the land treatment unit may be exempted from Subpart F requirements (see Section 5) if he or she can demonstrate the following: 8-168 ------- 1. that hazardous constituents are no longer present in :he c'reaciaent sone at statistically significant amounts, and 2. that no hazardous constituents (or PHCs) have migrated below the treatment zone during the active life of the land treatment unit. As mentioned above, results from unsaturated zone monitoring and treatment zone analyses may be used to document these conditional requirements. Although §270.20(f) only specifically calls for information on the establishment and maintenance of a vegetative cover, the applicant must also submit information on all of the other closure and post-closure requirements of §264.280^.1) for closure and J264.^oO(c/ for post-closure. The application snouid contain a description of how these requirements will be complied with. In general, these requirements simply specify that design and operational activities performed during the facility's active years be continued or maintained during closure and post-closure care periods. Briefly, the operations, other than establishment and maintenance of a vegetative cover, to continue are: Closure • Sustain waste degradation transformation, and immobilization* « Continue to minimize run-oft • Maintain run-on control system • Maintain run-off management system • Continue to control wind dispersal (if needed) • Continue food-chain crop management • Continue unsaturated zone monitoring7 Post-Closure • Sustain waste degradation, transformation, and immobilization* • Maintain run-on control system • Maintain run-off management system • Maintain wind dispersal controls (if needed) • Continue food-chain crop management • Continue unsaturated zone monitoring" *Except Co Che extent that such operations are inconsistent with che establishment of a vegetation cover. Operations include tilling of the soil, control of soil pH and moisture content, and fertilization. Soil-pore liquid monitoring may be terminated 90 days after the last waste, application. 8-169 ------- or operators of land treatment facilities must also comply vith the general closure requirements provided under Subpart G. these requiremen address the closure performance standard (§264.111), the closure plan (§264.112), time allowed for closure (§264.113), disposal or decontamination of equipment (§264.114), certification of closure (§264.115), post-closure care period ($264.117), post-closure plan (§264.118), and notices (§264.119 and §264.120). In addition, the applicant must also comply with the applicable general information requirements of §270.14(b)(13). Even though the exemptions identified above may be implemented, establishment of a vegetative cover is a good management practice. A vegetative cover will control wind dispersal of particulate matter and provide soil stabilization which will minimize erosion. The purposes of establishing and maintaining a vegetative cover are to: * physically stabilize the soil, • reduce infiltration of precipitation,* • retard surface run-off, • minimize wind and water soil erosion, and • enhances site appearance. The success of establishing 3. vegetative cover hinges on selecting plant species that have good seed germination and growth characteristics and are indigneous to the area. In order to ensure continued compliance witti the post-closure requirement, plant species selected must also be easily maintained without extensive maintenance (e.g., frequent fertilization, liming, and watering). To provide an opportunity for plant species to become established, the top soil layer comprising the root zone must be conditioned both physically and chemically to ensure a high success rate of seed germination and vigorous growth. The soil oiuac provide adequate moisture, nutrients, and aeration. Many treatment zone soils may require conditioning prior to seeding and some level of periodic maintenance following germination. Soil conditioning includes: • addition of organic matter, • periodic cultivation, • chemical nutrient addition, and • soil pH and moisture control. *Infiltration is seasonally reduced by intercepting and evapotranspiring some of the precipitation. 3-170 ------- In cases wnere cne treatment zone soli is act acceptable, even after condicioning, for vegetative growth, :-~ "ay be amended ay the addition of clean top soil. Actually, in some- situations, factors promoting plant growth and thus improve the likelihood for che establishment of a vegetation cover will be enhanced by the waste applications. For example, the following benefits can result from the waste disposal activity: an increase in soil organic matter content, soil pH, and potassium, calcium, magnesium, and zinc levels. In order to determine types of vegetation that would be suitable for a particular site, soils analyses must be conducted. Investigations should be made to determine pH and fertility of the treatment zone surface soil (down to 5 to 10 cm) or soil brought into be used for cover. Methods for performing chase analyses are generally available from county offices of the Soil Conservation Service. Experiences gained with the land cultivation of municipal solid waste and industrial wastewater and sludges have revealed that nitrogen and phosphorus deficiencies can occur in the soil which will adversely affect seed germination, growth, and metal uptake by plants.2,3 ,4, 5 in order to establish and maintain Che vegetative cover required, soil amendments using chemical or natural fertilizers will likely be necessary. Chapter 3 of the Hazardous Waste Land Treatment Manual? presents an in-depth discussion on che establishment of a vegetative cover at closure. Issues addressed in the manual include management objectives, species selection, seedbed preoaration, seeding and plane establishment, and soil fertility. To ensure successful establishment and ease of maintenance, plant species selection should be based on suitability with local climatic (seasonal) and soil conditions. Information regarding plant species selection and cultivation practices can be obtained from agronomists of the State Agricultural Extension Service, U.S.D.A. or plant science professors at nearby colleges and universities. A^ discussed in tne ACRA Guidance Document,^ the Agency believes that, in many cases, the closure activities at land treatment units and establishment of a vegetative cover may be accomplished within 180 days. However, each facility will be unique and should be evaluated on a case-by-case basis. A .key concern when establishing the vegetation is to assure adequate cover. The surface soil should be completely covered to avoid bare spots that may initiate soil erosion which could expand to the extent that widespread erosion and elimination of portions of the vegetative cover results. The first steps to assuring adequate cover are seeding rate and timing. The seeding rate, that is the quantity of seed applied per arce, depends on the seed species, method of seeding, and surface soil conditions at the time of closure. The current practice for calculating seeding rates is based on the quantity (pounds) of seed required to produce 20 live seeds per foot.2 8-171 ------- Other seeding races -ay ze .iccepcaoie, aowever. The reviewer should concacc the Local agricultural extension service office or Soil Conservation Service for information on proven seeding rates for the region. The timing of seeding will depend on whether1the plant species selectad is a cool or warm season species. Cool season species do best when planted in late summer or early fall. Warm season species are generally planted during lace winter or early spring.2 The chosen mixture of ^eeda ana soil amendments can be hydroseeded, that is, sprayed onto Che land surface in a water mixture. Hydroseeding is one of Che least expensive and Che most coat-effective method of seeding a landfill. Following seeding, a mulch consisting of hay, straw, or vood chips c.tn be blown onto the 3,4,5,8,9,10 Disease and insect resistance should also be considered during vegetation selection. Although it is not a specific requirement, field studies investigating seed germination, root development, vegetative growth, and plant viability should be conducted on small plots of tne treatment zone during its active life. Results obtained from such studies will be valuable for the selection of the best vegetative cover to »3tablish during closure. It is suggested chat this topic be discussed during Che pre-appiication meeting. EPA has developed a 39-step approach for evaluating the adequacy of closure and post-closure plans and engineering reports with respect to hazardous waste landfills.^ The review procedure is specifically intended for use by staff members in Che Regional EPA offices and state offices. Although the cover evaluation procedures are directed towards landfills, certain aspects relate directly Co the closure of land treatment facilities. Specifically, these include steps 25 through 39, described as follows: Closure: Step 25. Evaluate Soil Step 26. Evalute pH Level Step 27. Evaluate Nitrogen and Organic Matter Step 28. Evaluate Other Nutrients Step 29. Evaluate Species Selection 8-172 ------- ana Trees Seep 31. Evaluate Time of Seeding SCep 32. Evaluate Seed and Surface Protection Post-Closure: Step 33. Evaluate Design/Maintenance Step 34. Evaluate Maintenance of Vegetation Step 35. Evaluate Provisions for Condition Surveys Step 36. Evaluate Plan for Erosion Damage Repair Step 37. Evaluate Plan for Vegetation Repair Step- 33. Ivaluace Plan for Drainage Renovation Step 39. Evaluate Plan for Other Cover Deterioration Evaluate vegetation (Steps 25-32) - Establishment and maintenance of vegetation raquriaa an evaluation ^J.T soil type, nutrient and pH levels, climate, species selection, mulching, and seeding time. Species should be selected on the basis of environmental and biological strengths and limitations. Evaluate maintenance procedure (Steps 33-35) - Regular maintenance intervals should be planned to repair erosion damage and to maintain the vegetative cover. Provisions should also be made for site monitoring by a qualified individual to periodically inspect the cover condition. Evalute contingency plan (Staps 36-39) - A contingency plan should be established to deal with future unforeseen problems such as excessive wind and water erosion, loss of vegetation, and drainage system failures. The permit reviewer should evaluate the effectiveness of the applicant's post-closure plan to address such prooterns in a timely manner. 8.5.3 Draft Permit Preparation In addition to compliance with Che closure plan requirements of §264.112, the permit issued must specify that the land treatment unit be closed in accordance with 40 CFR §264.280. If the Permittee successfully demonstrates in accordance with §264.280(d) that the level of hazardous constituents in the treatment zone soil does not exceed the background value of those constituents by a statistically significant amount, he is not subject to regulation under §§264.280(a)(8) and (c). The Permittee who satisfies the requirements of §264.280(d) is also not subject to regulation under Subpart F, if the monitoring program established under Condition E of Permit Module XIV indicates that hazardous constituents have not migrated beyond the treatment zone during the active life of the land treatment unit. Condition M of Permit Module II outlines general facility closure requirements. Conditions of the permit, which can be implemented by reference Co portion* of Che Part B permit application, should specify che following: • plant species to be grown, • procedures to ensure vegetative establishment, and • techniques to maintain the cover during the post-closure care period, 8-173 ------- Jepenaing on the sice and hazardous constituents applied, particularly persistent organic compounds, the permit writer may wish Co state in the facility permit, the level of treatment, specifically degradation or transformation, required prior to start of post-closure care. The degree of treatment achieved may be determined from unsaturated zone monitoring results, treatment zone analyses, and run-off liquid quality data. 8-174 ------- 1. U.S. Environraencai Protection Agency. RCRA Guidance Document, Land Treatment. Draft Report. Office of Solid Waste. January 1983. 2. U.S. Environmental Protection Agency. Hazardous Waste Land Treatment. Prepared by K. W. Brown and Associates, Inc., for U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, Solid and Hazardous Waste Research Division. Cincinnati, OH. Report No. SW-374. 1983. 3. Phung, T., et al. Land Cultivation of Industrial Wastes and Municipal Solid Wastes: State-of-the-Art Study. Volume I, Technical Summary and Literature Raviaw. rraparea oy SCS Engineers for U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, Cincinnati, OH. EPA-600/2-78-140a. August 1978. 4. Overcash, M. R., and D. Pal. Design of Land Treatment Systems for Industrial Wastes, Theory and Practice, Ann Arbor Science. Ann Arbor, Michigan. 1979. 5. Parr, J. r., et ai. Land Treatment of Hazardous Wastes, Noyes Data Corporation, Park Ridge, New Jersey. 1983. 6. Tolman, A. L., et al. Guidance Manual for Minimizing Pollution from Waste Disposal Sites. Prepared by A. W. Martin, Associates, Inc. for U.S. Environmental Protection Agency, Municipal Environmetal Research Laboratory, Cincinnati, OH. EPA Report No. EPA-600/2-78-142. August 1978. 7. Lutton, R. J. Evaluating Cover Systems for Solid and Hazardous Waste, Prepared by U.S. Army Engineer Waterways Experiment Station for U.S. Environmental Protection Agency, Solid and Hazardous Waste Research Division, Cincinnati, OH. EPA Report SW-867. September 1982. 8. Page, A. L. Fate and Effects of Trace Elements in Sewage Sludge when Applied to Agricultural Lands. A Literature Review Study. U.S. Environmental Protection Agency, EPA-670/2-74-005. January 1974. 9. Allaway, W. H. Agronomic Control Over Environmental Cycling of Trace Elements, Adv. Agron. 20:235-274. 1968. 10. Chaney, R. L., and P. M. Giordano. Microelements as related to plant deficiencies at toxicities. pp. 234-279. In: L. F. Elliot and R. J. Stevenson (ed.) Soils for Management of Organic Wastes and Waste Waters. American Society of Agronomy, Madison, WI. 1977. 11. U.S. Environmental Protection Agency. Evaluating Cover Systems for Solid and Hazardous Waste, Second Edition. EPA Report No. SW-867. September 1982. 8-175 ------- 3.3 .SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTES B.b-l Federal Requirement Section 270.20(g) states: "If ignicable or reactive wastes will be placed in or on che treatment zone, an explanation of how the requirements of §264.281 will be complied with." The corresponding Part 264 standards, §264.281 states that the owner or operator must not apply ignitable or reactive waste to the treatment zone unless: "(a) The waste is immediately incorporated into the soil so that: (1) The resulting waste, mixture, or dissolution of material no longer meets the definition of ignitable or reactive waste under §§261.21 or 261.23 of this chapter; and (2) Section 264.17(b) is complied with; or (b) ""he waste is managed i.n such a way that it is protected from any material or conditions which may cause it to ignite or react." Section 261.21 states: "(a) A solid waste exhibits the characteristic of ignitability if a representative sample of the waste has any of the following properties: (1) It is a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume and has flash point less than 60°C (140°F), as determined by a Pensky-Martens Closed Cup Tester, using the test method specified in ASTM Standard D-93-79 or D-93-80 (incorporated by reference, see §260.11), or a Setaflash Closed Cup Tester, using the test method specified in ASTM Standard D-3278-78 (incorporated by reference, see §260.11), or as determined by an •equivalent case method approved by the Administrator under procedures set forth in §§260.20 and 260.21. [261.21(a)(D amended by 46 FR 35247, July 7, 1981] (2) It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard. (3) It is an ignitable compressed gas as defined in 49 CFR 173.300 and as determined by the test methods described in that regulation or equivalent test methods approved by the Administrator under§§260.20 and 260.21. (4) It is an oxidizer as defined in 49 CFR 173.151. (b) A solid waste that exhibits the characteristic of ignitability, but is not listed as a hazardous waste in Subpart 0, has the EPA Hazardous Waste Number of D001." 8-176 ------- if a representative sample of ;he *ascd nas any oi che following properties: (1) It is normally unstable and readily undergoes violent change without :etonating. (2) It reacts violently with water. (3) It forms potentially explosive mixtures with •;a."3r. (4) When -ni::ad »i:h wacer, ic generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment. (5) It is a cyanide or sulfide bearing waste which. vHen exposed to pH conriiti^r.c j«cweea 2. ana j.2.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment. (6) It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement. (7) It is readily capable of detonation or explosive decomposition or reaction at standard ".eraoerature and pressure. (3) It is a foroidden explosive as defined in 49 CFR 173.51, or a Class A explosive as defined in 49 CFR 173.53 or a Class 3 explosive as defined in 49 CFR 173.38. (b) A solid waste that exhibits the characteristic of reactivity, but is not listed as a hazardous waste in Subpart D, has the EPA Hazardous Waste Number of D003." Section 264.17(b) states: "(b) Where specifically required by other Sections of this Part, Che owner or operator of a facility that treats, stores or disposes ignitable or reactive waste, or -aixes incompatible waste or incompatible wastes and other materials, must take precautions to prevent reactions which: (1) Generate extreme heat or pressure, fire or explosions, or violent reactions; (2) Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health or the environment; (3) Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosions; (4) Damage the structural integrity of the device or facility; (5) Through other like means threaten human health or the environment. (c) When required to comply with paragraphs (a) or (b) of this Section, the owner or operator must document thac compliance. This documentation may be based on references to published scientific or engineering literature, data from trial tests (e.g., bench scale or pilot scale tests), waste analyses (as specified in §264.13), or the results of the treatment of similar wastes by similar treatment processes and under similar operating conditions." 3-177 ------- Summary or Necessary Application Information The applicant should submit a derailed written plan for managing ignitable or reaccive wastes that will be placed in or on che treatment zone. The plan should include: • name and chemical composition of waste, • provisions for immediate sail ;.acorporacion of waste, • test results showing chat wastes are no longer ignitable or reactive following soil incorporation, and v handling proceaures and safety precautions for preventing conditions which may cause the waste to ignite or react. 8.6.3 Guidance on Evaluating Application Information The provisions of 5264.281 require good operating practice to ensure the safe handling of any ignitable or reactive wastes that might be applied Co che land treatment unit. As ^tatad in :he /art 264 standard, the owner or operator must handle such waste such that it is incorporated into the soil immediately, or managed in a way such that :he material will not ignite or react. The management techniques to meet the latter condition Jill vary depending on specific waata cypes. If an applicant provides information cnat none of the wastes intended for land treatment are reactive or ignitable, the provisions discussed in this section do not apply. Information chat vould be acceptable includes the re-julca of Casts or analyses conducted on the wastes by the land treatment facility owner or operator, or the waste generator. Documentation based on information or data in the scientific or engineering literature is also acceptable. If the applicant has demonstrated that all wastes are neither ignitable nor reactive, the permit writer must indicate in the permit that ignitable or reactive wastes are not permitted for receipt or application at the land treatment facility. The characteristic of ignitability is exhibited by a solid waste if it has any of the four properties listed in §261.21(a) (see Section 8.6.1 above). Specifically, §261.21(a)(1) addresses liquids, §261.21(a) (2) addresses nonliquids, §261.21(a)(3) addresses compressed gases, and §261.21(a)(4) addresses oxidizers. The provisions of §261.21(a)(1) identify three ASTM standard methods that can be used to determine ignitability. They are: • ASTM Standard D-93-/9 • ASTM Standard D-93-80 • ASTM Standard D-3278-78 8-178' ------- These -sechods 1:2 aijo iascrioea in Secc^oi 1*1.1 :: TJS.. .-leiinoas tor Evaluating Solid Waste, Physical/Chemical Methods.^ Descriptions and Cesc methods for ignitable compressed gases and oxidi^srs are also described in Section 2.1.1 of the referenced report. The characteristic of reactivity is exhibited by a. solid waste if it has any of the eight properties listed in §261.23(a) (see Section 3.6.1 above). Those properties are based largely on the definition employed by the National Fire Protection Association. The NFPA's headquarters are in Batterymarch Park, Quincy, MA 02269 and there is also a Washington, D.C. Office. Telephone numbers are: General and Executive Offices (617) 328-9290 Publication Saxes (617) 770-3002 Washington, D.C. Office (202) 484-8200 Detailed information on identification and testing of reactive wastes is provided in Section 2.1.3 of Test Methods for Evaluating Solid Waste, Physical/Chemical Metho'ds. In addition to using the methods referenced in the regulations, the permit applicant may use other methods to determine ignitability or reactivity if he has petitioned and received approval from the Administrator, as allowed under §260.20 and §260.21. If che permit reviewer encounters methodologies whose acceptability can not be determined, the Manager of the Waste Analysis Program (WH-565), Waste Characterization Branch, Office of Solid Waste, Washington, D.C. 20460 (202) 755-9187 should be contacted for assistance. Documentation that the precautions of §264.17(b) will be effective is required by §264.17(c). Specifically, §264.17(c) requires that; "When required to comply with paragraphs (a) or (b) of the Section, the owner or operator must document that compliance. This documentation may be based on references to published scientific or engineering literature, data from trial tests (e.g., bench scale or pilot scale tests), waste analyses (as specified in §264.13), or the results of the treatment of similar wastes by similar treatment processes and under similar operating conditions." The owner or operator of a land treatment facility who is treating ignitable or reactive wastes must document that the treatment employed will not itself be hazardous. The permit application may be judged deficient if the required documentation is not submitted or if it is judged co be inadequate. Figure 8.6.1 presents the major topics that are discussed in this section. The permit reviewer should first determine which of the technical topics are applicable to the facility and operation of concern. For instance, if the applicant proposes to manage the waste in conformance with the requirements of §264.281(b), than the discussion about treating, rendering, or 8-179 ------- LIST OF IGNITABLE AND/OR REACTIVE WASTES IMMEDIATE INCORPORATION OF WASTE INTO SOIL MANAGEMENT OF WASTE TO PREVENT IT FROM IGNITING OR REACTING METHODS TO TREAT, RENDER OR MIX THE WASTE 30 THAT IT IS NO LONGER IGNITABLE OR REACTIVE TEST FOR COMPATIBILITY TEST TO DETERMINE IF WASTES ARE IGNITABLE OR REACTIVE Figure 8.6.L. Flow diagram for evaluating Che tecnnical adequacy of Che application for disposal of ignicable or reactive waste. 3-130 ------- mixing Che waste so that it is no longer ignitaoie does noc applv. if anv ?f the associated copies are noc adequately adarsssea by -ne applicant, ;he application and the proposed disposal methods may be tecnnically deficient. 8.6.3-1 Lists of Ignitable and Reactive Wastes — In Part 261, Subpart D, (Lists of Hazardous Wastes], ignitable wastes are denoted by an "(I)" and reactive wastes are denoted with an "(R)". Table 8.6.1 lists the hazardous vastss, by SPA Hazardous Waste number, that are identified in Subpart D as being ignitable. Table 8.6.2 lists the hazardous wastes, by EPA Hazardous Waste number, that are identified in Subpart D as being reactive. At a minimum, if the applicant indicates that any of these wastes will be treated ac "ha facility, ae .aust document TOW compliance with §264.281 will be achieved. The permit reviewer should refer to A Method for Determining the Compatibility of_Hazardous. Wastes2 for assistance in evaluating the application. This reference provides a list of 174 chemicals which are extremely reactive and therefore should not be mixed with ^atar, or other chemicals or waste materials. If these "extremely reactive" compounds are mixed with water or -nost other compounds, heat may be generated, or toxic and/or flammable gases may be produced. In addition, explosions may occur, or highly unstable mixtures may result. If the following materials are mixed with water, flammable gas will be generated: « Metals, such as sodium and potassium * Nitrides • Sulfides, Inorganic • Strong Reducing Agents Reference 2 also provides a list of materials which ara combustiole and flammable and a list of materials which are explosive. 8.6.3.2 Methods to Treat, Render, or Mix Waste so that it is no longer Ignitable or Reactive— There are a number of methods available to treat, render, or mix wastes so that they are no longer ignitable or reactive. Several treatment processes which previously were only used in the organic or inorganic chemical industry are being considered for broader applications in the treatment of hazardous waste. Over 50 processes have been demonstrated to be aoplicable *.o hazardous waste treatment, although the technical and economic feasbility of a number of these processes has not been demonstrated on a commercial scale. Table 8.6.3 identifies several of the most promising nonbiological treatment methods along with general information regarding feed stream requirements, output streams, and the current state of technology.3-8 xhe applicant may propose to employ one or a combination of these methods to treat ignitable or reactive wastes prior to, application. 8-181 ------- lABLS 3.6.L. IGNITABLE WASTES EPA hazardous waste No. Hazardous waste F003 F005 U001 U002 U003 LJ008 'JO.12 UO12 U019 U239 'JO 5 6 •J055 U169 U085 U0.31 U159 U074 U031 U156 U055 U056 U057 U074 U085 U092 uuo Spent nonhalogenacea soivencs Spent nonhalogenated solvents Acataldehyde Acacic acid, ethyl aster Acetone Acetonitrile Acrylic acid Aniline ^enzenamine Benzene Benzene, dimethyl- Benzene, hexahydro- Senzene, (1-metnylethyl), Benzene, nitro- 2,2-bioxizane t-butanol 2-butanone 2-butene, 1,4-dichloro- n-butyl alcohol Carbonochloridic acid, methyl ester Curanene Cyclohexane Cyclohexanone I,4-dichloro-2-butene 1,2:3,4-diepoxybutane Dimethylamine Dipropylamine (continued) 8-182 ------- TASL r a .concinuea; EPA. hazardous waste No. Hazardous waste U001 U008 U117 'J112 LJ113 U115 U117 U125 U213 U125 U124 U140 152 U092 U045 U153 U154 U154 LJ186 U045 UL56 U159 U161 U162 U161 U169 U171 Ethanol Ethanenicrile Echane, 1,1-oxybis Echyl acacaca Echyl acrylace Echlene oxide Echyl echer 2-curancarboxaldehyde Furan, cecrshydro- Furcura1 Furfuran Isobucyl alcohol Me ehacry tonic rile Mechanamide, N-mechyl Mechane, cnloro- Mechanethiol Mechanol Mecnyl alcohol 1-mechyl oucadiene Methyl chloride Methyl chlorocarbonate Methyl ethyl ketone Methyl isobutyl ketone Methyl tnethacrylate 4-methy1-2-pentanone Nitrobenzene 2-ni tropropane (concinued) 3-183 ------- TABLE 8.6.1 (continued) EPA hazardous waste No. Hazardous waste U115 U186 U194 JLiO U171 U140 LJ002 'J152 J008 I'll 3 U162 U194 J213 IJ15 3 U239 Jxirane 1,3-pentadiene 1-propanamine 1-propanamine Propane, 2-nicro 1-propanol, 2-raechyl- 2-propanone 2-propenenicriLe, 2-mechyl 2-propenoic acid 2-propenoic acid, ethyl aster 2-propenoic acid, 2-mechyl-, methyl ester n-propylamine Ie trahydrofuran Thiomethanol Xylene 8-184 ------- TABLE 8.0.2. REACTIVE WASTES EPA hazardous waste number Hazardous waste F007 F008 F009 F010 F011 tcon K013 K027 K045 KOA7 P009 P065 P112 P081 P009 PI 12 P112 Spent cyanide plating oatn solutions ... Plating bath sludges ... Spent stripping ^nd cleaning oacn solutions ... Quenching bath sludge ... Spent cyanide solutions from salt bath ... Sotcom stream from wastawater ... aeryionitrile Bottom stream from the acetonitrile column ... Cencrifuge and distillation residues from toluene dusocyanate production Wastewater treatment sludges from the manufacturing and processing of explosives Spent carbon from the treatment of wastewater containing explosives Pink/red water from TNT operations Ammonium picrate Mercury fulminate Methane, tetranitro- Nitroglycerine Phenol, 2,4,6-trinitro-, ammonium salt Tetranitromethane Zinc phosphide (continued) 8-185 ------- TABLE 8.6.2 fcontinued) EPA hazardous waste number Hazardous waste U006 U223 •JO 20 U023 U024 U023 LT160 LF033 U033 U133 U096 U006 U133 U086 U189 U205 U189 U205 U223 U234 Acetyl chloride Benzene, 1,3-diisocyanacomechyL oenzenesulfonyl chloride Benzene, (crichloromecny1) Benzene, 1,3,5-trinicro- Benzotrichloride 2-buCanone peroxide Carbon oxyfluoride Carbonyl fluoride Examine Alpha, alpha-dimechyI benzylhydroperoxide Echanoyl chloride Hydrazine Hydroperoxide, 1-mechy1-1-phenyethyl- Phosphorous sulfide Selenium disulfide Sulfur phosphide Sulfur selenide Toluene diisocyanate Sym-crini trobenzene 8-186 ------- -? it! 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" X * 2 ?i « O -3 3 M 3 *• *J — 3 * • C5 • -P4 ** 4J « • 3 a 9 2 ; 5 a 5 - 1- 4 i i I S e " u • • 9 a J « V 3 -3 a • -a u » to 4J «« 4 to tl O -3 » "3 **« 3 41 M y x • " -. - * j - w a a a * a « -a 0 -• 4 41 *-* •* x a* .£ to * u • y d A 3 4 V —I * y «j *»af J! M v - 4 9 4 a o a — 4 -» .* a, i a a a a -9 a. a •*• o o •* „ .-*- -* w -j a, M 9 4 -« 4 4 4 a -9 -9 4 -a •« .a to 4 M V M * IM " to HO • O O 9 U A • • • ?4 «• "9 : • : ^ .^ • ^ V -9 « M — W 9 ••rf M w • ); noiwetel eniua or -aic uacte liquid • lorry, o Jga. I 0 a* 3 a -M o w -^ J a — a • • w 9 a ,2.2 *»» W . 3 W •-* • MX 4 ~*4 3 *j i S S * • <44 g ° - 4 • 1* to • V 3 SSfr 5-43 cj j= n. a — o 4 -4 y w ••* 4 • "9 V •"• -5S ^ * 3 a M a 9 y 8-L88 ------- a u -9 o u « o.» — a.N- o •5: *j ••« 3 *- -g 3°~ - a a , o - t* « ^ » M r « r?? 1 -« 0 •4 V ^ X 3 11 O •- 12"S * s O 4J U -, 3 a •3 -^ Jt £ *• 3 U - - 3 vJ — -a 3.2 h v a. X : § a u ^ ^ a — ^ ?2 •=-s j .. -• •« ,. u 3 > ^* W u • •« O 0. V) J y ^ J» S! 2 i*i a i 33 .2. -1 ". a a . 3 v u _ I j * . 2 ' : * •« — 2 T5 i - V * <3 -" 3 • U a j *-a««»,._, - o - i r i <: "U 5 I £ 2. 1 y . ; a :•: ?i ; 23-3 - «•" i * a •< - U H I S3 o o 3 J5 ^ M ••4 •*« 0 » a J! O -3 . - • 5 « 1 . • SI i.2 ? « u i IS8 a • o -v u a 3 * a ^f X M U .^ I- n • 9 f ? 3 e O , «M • O a • o ^ i u < « : •9 • 3 i s | a w x a o u 3 |fg>: a s - ^ i 8-189 ------- The applicant may pro-pose to render ignitable or reactive compounds nonignitable or nonrsactive by diluting :ha -asce wi.cn ocner compatible material. However, dilution has the obvious disadvantage in that hazardous reactions may result if the materials being mixed are incompatible. In addition, dilution with liquids is undesirable because of added liquids to the land treatment unit and greater attendant leachate generation. If other than a small quantity of waste requires dilution, the reviewer may elect to require an alternative treatment process to ainimize che application of liquids that might affect the units water balance. There are a number of data sources which may assist the reviewer in evaluating an applicant's oropos«d method of waste treatment, when required, including references 3 through 17 listed in subsection 8.6.5. The reviewer should refer to Chapters 8 and 9 of Metry9 which lists an additional 200 references on physical and chemical treatment of hazardous waste. 8.6.3.3 Test for Compatibility— The permit reviewer should refer to A Method for Determining the Compatibility of Hazardous Waste^ which addresses hazardous waste compatibility. A hazardous waste compatibility chart (see subsection 3.7.3 of this manual) is presented which illustrates the compatibility of 41 binary combinations of hazardous chemical wastes. The reason for incompatibility is also noted for each combination. Further discussion of incompatible wastes is presented in subsection 3.7.3. 3.6.3.4 Testing of Ignitable and Reactive Waste— After a treatment process has been employed, the applicant must test or document by some other means that che waste is no longer ignitable or reactive. If testing is to be employed, the applicant must specify what testing procedures he will use. Available methods to test for ignitability are set forth in §261.21. Two test methods are acceptable for determining the flash point: Pensky-Martens Closed Cup Tester using the test method specified in ASTM standard D-93-79 or D-93-80, or a Setaflash Closed Cup Tester, using the test method specified in ASTM Standard D-3278-78. To test if a treated waste has the characteristics of reactivity, the applicant should base his demonstration on tests for: water reactivity, flash point/flamability, oxidation/reduction potential, pH, and the presence of cyanide or sulfide. The testing procedures employed should conform with the ASTM standards and test methods incorporated in Test Methods for Evaluating Solid Waste.1 8.6.3.5 Site Management to Prevent Ignition— Th« applicant must specify handling methods to avoid heat, sparks, rupture, or any other condition that might cause ignition of the waste. The applicant should specify the types of handling equipment and management procedures that will be employed. All equipment should be constucted of nonsparking materials. 8-190 ------- If an applicant proposes to place an ignitable wasta Ln the sase treatment unit with another waste cype, it aus t be determined whether thi-s other waste type may react exothermicaily vith water and generate sufficier.c heat to cause ignition. However, wastes which are reactive with water shoul. not be treated at the unit. Section 264.281(a) requires that any reactive waste be incorporated into the soil immediately after application so that th. resulting waste, mixture or dissolution of material no longer meets the definition of ignitable or reactive waste under §261.21 or §261.23. Nonetheless, the reviewer should check to be certain that any wastes which i to be co-disposed with an ignitable waste are nonreactive. In Part 261, Subpart D - Lists of Hazardous Wastes, the wastes that are reactive are designated by an "(R)" hazard code. Also, any waste which has an SPA hazardous waste number of 2:002 ^xnibits trie characteristics of reactivity. rhe reviewer should cross-check those wastes which will be co-disposed with i: ignitabla waste with the wastes in the Subpart D list which are reactive (listed in Table 8.6.1 of this section). However, not all of the waste in t:v Subpart D list which are designated to be reactive, will react exotherraical !•-• with water. A wasta is reactive if it exhibits any of the eight properties listed in §261.23. Figure 3.5.2 presents A worksheet that can be used to evaluate the applicant's plan to properly handle ignitable or reactive wastes to be disposed of at the land creatment unit. 3.6.4 Draft Permit Preparation Condici-n G of Permit Module XIV (see Section 4) covers the special requirements for ignitable or reactive wastes, if chey are to be handled a~ the land treatment facility. Permit conditions co be specified may be implemented by reference to applicable sections of the Part 3 permit application. Items covered by Condition G are as follows: G.I. The Permittee shall not place ignitable or reactive waste in a land treatment unit unless the practice described in Attachment are followed, as required by 40 CFR 264.231. (Note: The attachment must demonstrate how the facility will handle ignitable and reactive wastes as required by 40 CFR 264.281. If the application does noc address this, the permit writer should write specific conditions co implement this provision or should condition the permit so as noc to allow this practice.] G.2. The Permittee shall document compliance with Condition G of Perai: Module XIV as required by 40 CFR 264.17(c) and place this documentation in rhe operating record (see Module II, Condition L.I [Note: Condition G of Module XIV applies only to facilities that store ignitable or reactive waste in land treatment units.] 3-191 ------- SPECIAL REQUIHfMINTS JOR IGNITA3LE OR REACTIVE WASTES Are any wastes Co be land created ignitable or reactive? yes no If ignicahle or reactive wastes are going to be created, has the applicant provided a description of how the waste will be incorporated into the soil and how the waste/ soil mixture will be tested to determine that it is no • longer ignitable or reactive? yes Does the application provide a description of how the requirements of §264.17(b) will be net? yes no If the owner or operator elects co comply with §264.281(b), does che application describe how tne site will be managed to prevent tne waste aoolied from igniting or reacting? yes no .gure 3.5.2. Worksnaet to evaluate applicant's plan for handling ignitable or reactive wastes. 3-192 ------- 8.6.5 References 1. U.S. Environmental Protection Agency. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. U.S. EPA, Office of Solid Waste. Second Edition. SW-846. July 1982. 2. Hatayama, H. K., et. al., A Mathod for Cecermining the Corapatability of Hazardous Wastes. U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, Cincinnati, Ohio, EPA-600/2-80-076. April 1980. Z. JRB Associates, Inc., Techniques for Evaluating Environmental Processes Associated with the Land Disposal of Specific Hazardous Materials, Volume I: Fundamentals. EPA Contract No. 68-01-5052, March 31, 1982. 4. DeRenzo, D. J., Unit Operations for Treatment of Hazardous Industrial Wastes. Noyes Data Corp., 1978. 5. Schalit, L. and G. Staples, Fostering Industrial Innovative Technology to Attain Agency Goals: Technological Opportunities, Volume II, Prepared for Office of Research and Development, U.S. Environmental Protection Agency. Science Applications Inc., (SAI - 0/2-SO-523-LJ), 1980. 6. Pytlewski, L. L., et al., The Reaction of PCBs with Sodium, Oxygen, aad Polyethylene Glycol, In: Proceedings of che Sixth Annual Research Symposium on Treatment of Hazardous Wastes, March 17-20, 1980, Chicago, Illinois, U.S. EPA—Municipal Environmental Research Laboratory. EPA-600/9-80-011. 7. Edward, B. H., et al. Emerging Technologies for the Destruction of Hazardous Waste. Ultraviolet 10 Zone Destruction. In: Proceedings of • the Seventh Annual Research Symposium on Land Disposal of Hazardous Wastes. Philadelphia. U.S. EPA—Municipal Environmental Research Laboratory. (EPA-600/9-81-002b), 1981. 8. Miller, R. A., et al., Evaluation of Catalytic Wet Oxidation for Treatment of Hazardous Wastes. In: Proceedings of Seventh Annual Research Symposium on Land Disposal of Hazardous Wastes. Philadelphia. U.S. EPA—Municipal Environmental Research Laboratory. (EPA-600/9-81-002b), 1981. 9. Metry, Amir, A., The Handbook of Hazardous Waste Management. Technomic Publishing Company, Inc., Westport, CT., 1980. 10. TRW Systems, Inc. Recommended Methods of Reduction, Neutralization, Recovery, or Disposal of Hazardous Waste. Volume I-XVI. U.S. Environmental Protection Agency, Washington, D.C., 1973. 11. EPA-600/2-82-001C, Treatability Manual. Volumes I-IV. U.S. Environmental Protection Agency, Washington, D.C., Sept. 1981. 8-193 ------- 12. Battalle Memorial institute. Program for the Management of Hazardous Waste. Volumes 1 and 2. U.S. Environmental Protection Agency, Office of Solid Waste Management Programs. Washington, D.C., 1974. 13. Booz-Allen Applied Research, Inc. A Study of Hazardous Effects and Disposal Methods. U.S. Environmental Protection Agency. Cincinnati, OH, 1972. 14. Bretherick, L., Handbook of Reactive Chemical Hazards. CRL Press, Inc., Cleveland, OH, 1975. 15. Fire Protection Guide on Hazardous Materials. Sixth Edition. National Fire Protection Association, Boston, Massachusetts, 1975. 16. Nfermerow, N.L., Liquid Waste of Industry: Theories, Practice, and Treatment. Addison-Wesley Publishing Co., Reading, MA, 1972. 17. Toxic and Hazardous Industrial Chemicals Safety Manual for Handling and Disposal, with Toxicity and Hazard Data. The International Technical Information Institute, Torahoraon-Tachikawa Bldg. 6-5, 1 Chome, Nishi-Shimbashi, Minato-KW, Tokyo, Japan, 1975. 8-194 ------- 3.7 SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES 8.7.1 Federal Requirement Section 270.20(h) states: "If incompatible wastes, or incompatible wastes and material; will be placed in or on the same treatment zone, an explanation j, how §264,282 vill be complied with." Section 264.232 states: "The owner ->r operator iusc not piace incompatible wastes, or incompatible wastes and materials (see Appendix 7 of this part for examples), in or on the same treatment zone, unless §264.17(b) is complied with." Section 264.17(b) states: Where specifically required by other Sections of this Part, the owner or operator of a facility that treats, stores or disposes ignitable or reactive waste, or mixes incompatible waste o incompatible wastes and other materials, must take precautions to prevent reactions which: (1} Generate extreme heat or pressure, firs or explosions, or violent reactions; (2} Produce uncontrolled coxic aiists, fumes, dusts, or gases in sufficient quantities to threaten human health or the environment (3) Produce uncontrolled flammaola fumes or gases in sufficient quantities to pose a risk of fire or explosions; (4) Damage the structural integrity of the device or facility; (5) Through other like means threaten human health or the environment. (c) When required to comply with paragraphs (a) or (b) of this Section, the owner or operator must document that compliance. This documentation may be based on references co puoiishea scientific or engineering literature, data from trial tests (e.g., bench scale or pilot scale tests), waste analyses (as specified in §264.13), or the results of the treatment of similar wastes by similar treatment processes and under similar operating conditions." 8.7.2 Summary of Necessary Application Information The application must include a written plan thac explains the procedures and precautions for handling incompatible wastes and -naterials if such wastes will be placed in or on the same treatment zone. The plan must contain the following information: • name of incompatible materials or wastes, • explanation of incompatibility, 8-195 ------- • composition of incompatible iacari?lj i-d «a_,u3, • rate and schedule of incompatible waste or material applications co the treatment zone, • step-by-step procedures for managing incompatible wastes or materials to prevent undesirable reactions or effects, and • laboratory or field data demonstrating that incompatible wastes can be safely managed at the land treatment unit using Che proposed procedures. 8-. 7 . 3 Guidance on Evaluating Application Information If wastes from different waste streams are to be applied to the same treatment zone, che owner or operator must demonstrate prior to application that the waste from different streams are compatible. Table 8.7.1, adapted from Appendix 7 of Part 264, presents a partial listing of potentially incompatible vastes, -'asta components, ana materials, along with the harmful consequences which result from mixing materials in one group with materials in another group. The potential consequences identified may result from mixing of an A material with a B material within the same Group number. Under certain conditions, waste identified as being incompatible may be applied to the same treatment zone. For example: • adding acid to water, then wacar Co acia, or • a strong acid mixed with a strong base. Characterization of wastes to be land created is required of the applicant under §264.13. Waste analysis methods employed by the applicant can be verified using Test Methods for Evaluating Solid Wasta.- Published scientific or engineering literature, data from actual testing, or results from the treatment of similar waste by similar treatment processes and under similar operating conditions can be used to determine that the applicant will comply with the requirements of §264.17(b). There is no characterization of incompatibility in 40 CFR 261. Rather, Appendix V of Part 264 presents examples of potentially incompatible wastes. A definition of incompatible wastes is provided in §260,10 of Suboart B of Part 260. Technical references are also available that identify incompatible waste combinations, as discussed below. It is the responsibility of the land treatment owner or operator to identify whether or not wastes are compatible. For commercial off-site land treatment facilities, the variety of wastes received will likely result in 3-196 ------- to i I -J H CO < 2 as 1 I 33 '•3*5 s »• -3 - . •?•::.•: 4 - 11 * 3 - | 52 2^ ^: :i 32»J i " ' < <« II urn S 5 a u -• x w o V - w « * a I I H VI TJ f:-:|s--i3H : -?&s8»!:*iS I •- •- S ! 2 '•" 3 - 8 S S si ^j«sa-mi oo S -, i — S s-s,.l! |: •s = -!~f ::!*:: d Jj 3 - 7 w 3 = o a u « i! 3 •Ji 8-197 ------- some cases of incompacibilicy. For on-site land treatment facilities, those operated by the waste generator, it is more likely thac the wastes will be compatible. If it is shown chat all wastes are compatible with each other and wich other materials treated at the site, the permit application is sufficient with respect to the requirements of §264.282. Based on a literal interpretation of the regulations, only a waste that has already been identified as a hazardous waste can be further identified as an incompatible waste. Specifically, the §260.10 definition states than an incompatible waste "means a hazardous waste which..." and Aopendix 7 of Part 264 states "Manv hazardous vsatas, whan auxed with...." The intent of cne regulations is fairly clear, however, if any two (or more) materials or wastes cannot be formed into a homogeneous mixture that neither separates nor is altered by chemical interaction (Webster), they are incompatible and must not be placed in or on the same treatment zone, unless the requirements of §264.17(b) are met. Thus, it is the responsibility of the permit applicant to compare each waste (hazardous and nonhazardous) to be treated at the facility for compatibility with each other. Documentation that the precautions of §264,17(b) will be effective is required by §2S4.l7(c). Specifically, §264.17(c) requires that: "When required to comply with paragraphs (a) or (b) of this Section, the owner or operator must document that compliance. This documentation tnay be based on references to published scientific or engineering literature, data from trial tests (e.g., bench scale or pilot scale tests), waste analyses (as specified in §264.13), or the results of the treatment of similar wastes by similar treatment processes and under similar operating conditions." The owner or operator of the land treatment facility must supply documentation that the procedures employed will not allow incompatible wastes to be placed in or on the same treatment zone. The permit application is deficient if the required documentation is not submitted or if it is judged to be inadequate. If the application indicates that incompatible wastes will not be placed in or on the same treatment zone, then procedures to insure that they will not should be stated. Also, if an application indicates that a waste will be treated so that it is no longer incompatible prior to application, documentation that the treatment complies with §264.17(b) is required. To augment the information on incompatible wastes presented in Appendix V of Part 264, the permit application reviewer is referred to two additional technical reports to determine if the applicant has correctly investigated the compatibility of the materials and wastes to be handled. These documents are identified below, and a brief description of the contents of each is provided. A Method for Determining the Compatibility of Hazardous Wastes (EPA-600/2-80-076, April 1980)2 was prepared for the EPA's Municipal Environmental Research Laboratory bv researchers at the California Department of Health Services. The abstract of the report states: 8-198 ------- ''This report describes a method for determining che compatibility of che binary combinations jf hazardous wastes. The method consiacs of Cwo main parts, namely: (1) Che step-by-scep compatibility analysis procedures, and (2) the hazardous wastes compatibility chart. The key element in the use of the method is the compatibility chart. Wastes Co be combined are first subjected through the compatibility procedures for idnetification and classification, and the chart is used Co predict che ' compatibility of the wastes on mixing. The chart consists of 41 reactivity groups of hazardous wastes designated by Reactivity Group Numbers (RGN). The RGN ara •Ksolayed ..-. binarv combinations ;n :he jhart, and che compatibility of the combinations is designated by Reaction Code (RC). The mechod is applicable to four categories of wastes based on available compositional information: (1) compositions known specifically, (2) compositions known nonspecifically by chemical classes or reactivities, (3) compositions known nonspecifically by common or generic names, of- wastes, and (4) compositions unknown requiring chemical analysis.'' The 79 references and 5 appendices provide a significant amount of data on the compatibility of various chemical wastes. The other document, Techniques for Evaluating Environmental Processes Associated vith Land Disposal of Specific Hazardous Materials, Volume II, Incompatible Wastes,j March 31,1982, was prepared for the EPA Office of Solid Waste by JRB Associates, Inc., McLean, Virginia. This document discusses processes that enhance pollutant migration potential through the liquid phase in soils. Three general processes were identified. They are: • direct solubility effects between waste constituents, • chemical reactions between waste constituents which generate reaction products which ara -aore mobila than the original waste constituents, and • processes whereby waste interactions with the environment decrease the soil's ability to attenuate pollutant migration. Conclusions and 18 references are included. Razardoua Waste Compatibility Because many types of hazardous wastes are extremely reactive, the compatibility of hazardous wastes to be combined must be thoroughly evaluated. Combining wastes which are incompatible may result in: 3 (1) heat generation, (2) fire, (3) toxic gases, such as HCN or ^S, (4) flammable gases, such as H2 or C2H2, (5) explosion due to extremely vigorous reactions or reactions producing enough heat to detonate unstable reactants or reaction products, (6) violent polymerization resulting in generation of extreme heat and flammable gases, and (7) solubilization of 8-199 ------- toxic substances including metals. Consequencly, the applicant TIUSt idanrirv Che methods he vill 3rsploy for estimating the potential consequences of nixins different classes of wastes. Insufficient or inaccurate information about a waste or wastes is the primary cause of inadvertently combining incompatible wastes. Regardless of efforts to adequately characterize wastes via the waste analysis plan, properties of some wastes may change with time and temperature, thereby producing acre or different hazardous components.3 A second cause of accidents is indiscriminate handling of waste, such as haulers "topping off" their load on the way to the disposal site. As previously mentioned, A Method for Determining the Compatibility of Hazardous Wastes^ i3 a valuable resource document for determining the compatibility of binary waste combinations. The method provided in this report consists of two main parts: (1) stepwise compatibility analysis procedures, and (2) use of a hazardous waste compatibility chart. Wastes under consideration are first identified and classified and then the compatibility chart is used to assess the compatibility of the wastes upon mixing. The remainder of this section provides background information for employing the compatibility analysis presented in the cited reference (2). The five general steps necessary to determine the compatibility of two waste types are summarized below. Discussion of implementation of these steps is as reported by Hatayaraa, •sc al.4 Figure 3.7.1 summarizes the steps to be taken to determine hazardous waste compatibility. Step 1: Waste Characterization The first step in determining the compatibility of two different waste types is to accurately characterize the wastes. The applicant should provide as much information as possible about waste composition as required for compliance with §264.13 (Waste Analysis Plan) and as part of the list of hazardous wastes incorporated in the application [§270.20(a)(1) and (b)(l)]. Step 2:* List Name of Compounds or Classes of Compounds or Generic Name of Waste "Starting with one waste, Waste A, list the names of or the classes of compounds found in the wastes, or list its generic name on the vertical axis of the Worksheet for Determination of Hazardous Waste Compatibility (Figure 8.7.2). The composition of a waste is Known Specifically when the constituents are listed by chemical names such as ethylene glycol, sodium nitrate, etc. The composition is Known Nonspecifically by Classes when the constituents are identified only by chemical classes or reactivities such as alcohols, caustics, mercaptans, etc. The composition is Known Nonspecifically by Generic Name when the waste is classified as spent caustic, tanning sludge, copper plating waste, etc." *Quoted from Hatayaraa, H. K., et al. EPA-600/9-80-010, March 1980. (Reference 4.) 8-200 ------- PROCEDURE FOR HAZARDOUS WASTE STEP DETERMINING COMPATIBILITY 1 : WASTE CHARACTERIZATION STEP 2: LIST NAME OF COMPOUNDS OR CLASSES OF COMPOUNDS OR GENERIC NAME OF WASTE STEP 3: DETERMINE REACTIVITY GROUP NUMBERS STEP 4: REPEAT STEPS 2 AND 3 FOR OTHER WASTES OF CONCERN STEP 5: USING COMPATIBILITY CHART, DETERMINE CONSEQUENCES OF COMBINING TWO WASTES Figure 8.7. 1. Flow diagram for assessing che compacibilicy of hazardous wasce using procedures specified in A Method for Determining the Compacibility of Hazardous Wastes. (Reference 2) 8-201 ------- Waste A Waste B Name of Waste EvaJ nation Source Source Date WASTE A Name Reactivity Group No. Figure 8.7.2. Worksheet for determination of hazardous waste compatibility. Source: Reference 2 8-202 ------- 5cep 3:* Determine Reactivity Group Mumpers "When Che composition of Waste A is Known Specifically by chemical names, consult the List of Chemical Names [in Appendix I of Reference 2] to obtain the Reactivity Group Number (RGN) for each chemical constituent. The RGNs are then noted on the Worksheet. If a compound is not on the list, a synonym can be found in various chemical references (Merck, 5 Hawley^). When a. sui-sola synonym cannoc oe found, the RGN of the component may alternatively be determined baaed on its chemical class or reactivity. When the composition of the waste is Known Specifically Hy ll.tsa^s, •-.on -"•',.-. ths Ll.;c :f "/,'aai.a Constituents oy Chemical Class and Reactivity [in Appendix II of Reference 2] to determine the corresponding RGN. When the composition of the waste is Known Nonspecifically by Generic Name, go to the Industry Index and List of Generic Names of Wastes [in Appendix III of Reference 2] to obtain the corresponding RGN and note it on the worksheet." Step 4.:* Repeat Steps 2 and 3 for Other Wa3te(a) of Concern "Repeat Steps 2 and 3 for Che second waste, Waste 8, and note the information on the horizontal axis of Che Worksheet." 3tap 5:* Using Compatibility Chart, Determine Consequences 3 f ComDining Two Was tes "Consult the Hazardous «aste Compatibility Chart (Figure 8.7.3) and note the Reaction Codes (RC) between all binary combinations of RGN of Waste A and Waste 8. If any RC corresponds to any binary combination of RGN between Wastes A and 3, then Wastes A arid 3 are incompatible and should not be mixed." Limitations of the Method Although this procedure jhould provide a useful aid in determining the compatibility of hazardous waste, the method must be used with caution because there are numerous factors which will influence waste component reactions. Among these are temperature, catalytic effects of dissolved or particulate metals, soil reactions, and reactions between the waste and surfaces it may be in contact with.3 Consequently, the reviewer may elect to require that the applicant perform laboratory compatibility analysis prior to actual co-disposal of wastes. Compatibility with Treatment Zone Processes In addition to assessing the compatibility of wastes to be applied at the treatment facility, it is important to evaluate the impact of wastes applied on the soil processes responsible for hazardous constituent degradation, *Quoted from Hatayama, H. K., et al. EPA-600/9-80-010, March 1980. (Reference 4.) 8-203 ------- A/o Cumpt/undt Oti/n s ind Hs ij rn ' f F M. F CT CT ' CT R«*KMf AfHIII. SffOAf CT of ar\ *i 10* **tMr Mrt Mix turn Com«iM«if *it«r (07 Wl«r (nct»« Sy*> .exTREMCLT » ! 10 nu! " Figure 8.7.3. Hazardous waste compatibility chart. Source: Reference 1 8-204 ------- REACTIV TY CODE CCNSEQLENCES r— ' 1 II 10 17 >* H MB«MI~I->P F G GT GF E P S U ! weat generation Fi re nnocuous and non-flammable Toxic gas generation Flammable gas generation Explosion Violent oc 1 ymer i zat I zr\ Sol ubi 1 i zat ion of toxic substances May be hazardous but unknown Example: .9 I i* "F 1 N ' « j E ' F r* H c% M CF .'n c^ .-f r " U r'^ u c''H|crM t I I i i | ' M I 1 H % * H r i J 1 M F Mf t H "fiT "H Mc CF H GT Cf H M » CF ^ » < J 1 rt r.» '•j M f f i ! ' H C'H H ", \ "o I l H ? H , rt f », CF H DO NOT MIX WITH *MY CMfMIClL 14 15 1 t* I 17 1 14 l» JO H E f CF H H t H, « Gf E °'H H H e 1 E « CF J« Heat generation, fire, and toxic g; n if 1 <<• \ri "' "" 1 ! 1 11 "or ;», % , >*, u 1 "H F lOt i CT CT H GF H M ' ' H M M ,ni ( t I « t IOJ '„ '» • '» "l '»J Hi "t C'H C«J " C'H ", *'a ">( 10* c'c, '» o* wtsrc y*rt»ui. 11 11 U 15 i» >' ii :* jo Ji j; u J4 101 101 ioj IM >oj 10* 10' Figure 8.7.3. (continued) 8-205 ------- transformation, and immobilization. Although this consideration should be addressed under the Treatment Demonstration (see subsection S.I), it is mencionec hera because it rauac be considered wnen assessing the compatibility of wastes to he handled at the land treatment facility. Issues to be addressed include the effect of co-disposal of wastes on soil microbes, soil pH, soil fertility, adsorption properties (e.g., CEC) of treatment zone soil, and increased volatilization of organic constituents. Reactions between different waste types may result in increased soil acidity, decreased soil fertility, increased soil temperature, and possibly destruction of soil microbe populations. All of thase concerns snouici oe addressed by c.'.e hazardous waste treatment demonstration conducted in accordance with §264.272. Figure 8.7.4 presents a worksheet to be used by the permit writer for evaluating an applicant's submittal for meeting special requirements for incompatible wastes. 3.7.4 Draft Permit Preparation Condition H of Permit Module XIV (see Section 4) addresses the special requirements for incompatible wastes if they are to be treated at the land treatment facility. Permit conditions to be specified may be implemented by reference to applicable portions of the Part 3 permit application. Items covered by Condition H are as follows: H.I The Permittee shall not place incompatible wastes, or incompatible wastes and oiaterial, in or on the same treatment zone unless the procedures specified in Attachment are followed, as required by 40 CFR 264.17(b). [Note: The attachment must specify how the Permittee will handle incompatible wastes so as to comply with 40 CFR 264.17(b). If the application does not address this, the permit writer should write specific conditions to implement this provision or should condition the permit so as not to allow this practice.] H.2 The Permittee shall document compliance with Condition H.I of Permit Module XIV as required in 40 CFR 264.17(c) and place this documentation in the operating record (see Module II, Condition L.I). [Note: Condition H of Module XIV applies only to facilities chac store incompatible wastes in land treatment units*] 8-206 ------- SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES Have acceptable procedures been used Co accurately characterize the wastes? yes no~ Were wastes properly catagorized by reactivity group numbers? yes no" Was waste compatibility identified using the Reference 2 compatability chart or other acceptable means7 yes Does the compatibility assessment include all wastes identified in Section 8.1? yes no no If wastes are incompatible and will be placed in or on che same treatment zone, will che requirements of §264.17(b) be mec? yes no Figure 8.7.A. Worksheet for evaluating applicant's submittal for meeting special requirements for incompatible wastes. 8-207 ------- 1.7.5 References 1. U.S. Environmental Protection Agency. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. U.S. Environmental Protection Agency, Office of Solid Waste, EPA Report SW-846. July 1982. 2. Hatayama, H. K., et al. A Method for Determining the Compatibility of Hazardous Wastes. EPA-600-2-80-076. April 1980. 3. JRB Associates, Inc. Techniques for Evaluating Environmental Processes Associated with Land Disposal of Specific Hazardous Materials, Volume II, Incompatible Wastes. Prepared for the U.S. EPA Offica j£ Solid Waste. March 31, 1?32. 4, Hatayama, H. K., et al. Hazardous Waste Compatibility. Presented in Disposal of Hazardous Waste, Proceedings of the Sixth Annual Research Symposium. EPA-600/9-80-010. March 1980. 5. Merck and Company, Inc. 1976. The Merck Index. 9th Edition, Rahway, MJ, 5. Hawley, G. G. 1971. The Condensed Chemical Dictionary. 8th Edition. Van Nostrand Reinhold Company, New York, Cincinnati, Toronto, London, Melbourne. 8-208 ------- 3.3 TECHNICAL ADEQUACY CHECKLIST The cecnnical adequacy checklist presented in Table 8.8.1 provides a summary of Che basic information needed to determine the completeness and merit of Part B permit applications submitted for new and existing land treatment facilities. The checklist is organized according to the Part 270 permit requirements. Completion of the checklist will enable determination of application deficiencies, whera '•hey ray exijc. Deficiencies should be noted and identified in the Notice of Deficiency (NOD) Co be issued to the applicant pursuant to §124.3(c). 8-209 ------- o —* 1- 5 ! I * i p ^ ] V U >» o *=, ZD ,— ' 3 *^ ^« u M .^ 30 30 jj 3 | ! 3 £ ; 2 1 1 | I 1 a 3 M « 1 J I •v _: 1 J . * S ^ MM - 1 « ^ * - 2 ~ ' * _ ! • • 1 f - e u • ^ * V — '— "^ -1 I : Z « * - - ^ Ji - Z "" w ^ •* T 3 y ^ w ^f 5" i 3 •" " it ~ - ?* ^* a 3 _ - A _ IP - ' " U - j t -. T -. -5 C * •« 3 | 3 a r ~" -^ — " - J ^ 7 i : - = J- rJ a _^ -" f 3 y X 3 — i 2 i u •N - 5 f -1 f 2 "s » i < _J 8-210 ------- 1) 3 S 3 •J 33 3D ClJ a. ^ s a. v » , * ^ « J js e I :? J V * s .-• 3 S « — 1 S I I " » ? ? ? *« •* s 3 « = - > I r 3 a ' * — - ^ • ^ « 5 «(j «• «o 4l -" < /I ^- J « •/)•* 3 J! £ S £-- == -* «/> 4 8-211 ------- "3 II 3 ! •3 ~ 33 oo V V X I V k> 3 w I " 3 3 a. £ u j J ! 3 3 « ; 1 1 - > <• V • X m < o VI ft § • 1 3 V J 4 3 ^ * w V 3 3 w n J „" M M J| J 5 3 j 1 S' ae i = ? 3! S oj 3 X I •» ' i " ~ ? * « I* ' '' J 1 3 J J V ** "" w «• 5 5,3 ? ( 3 * - 1 u - 3 = -S 4 1 » -T ^ z (N a u "3 "3 j ! : ? -* » w ^ = j» = u ! a « b M u u x 3 !£ * AI 3 3 ^ j § j» 1 Jf | ! • ~= i 2 ! 3^ i 3 . 5 i 3 I \ r : u * j I 2. i i f i "= * ?? = Ii » - ^ ; it - ^^ ( 8-212 ------- y 3 -= T w U s y u — a u 0) 3 03 oo a -I 3! »•: JJS o - ^ :l 1 ! i« ^5 ^ S 3 ~ *• « - 6 * i si 8-213 ------- .^ 3 2 •<-4 •J -^ OO eo a 3 < H C j -3 V W •• V 3 w V 3 3 • •• 'J * • * V C a v V M «l W tfs 333 - (j -r w y » U -) J 3 • i* 2 a. « « • 3 * — X 4 > V c -3 v 1 i •a w • w k* tf • 3 -^ •• ^^3 i • 11? 3 « — a^ u -* » -^ u " *• ^ 3- M e 2 S | 8 I 1 i i i 1 1 1 i 1 j ! • a o ? ? s . II § 1 : 5 s 1 ' s • i s . J 4 : ? - 5 I 5 I i * i ?« f . - - : r ? i 6 « i -*8 3 : ! 2 ; - i s : . r s« s s i • - ; 3 J i I j f= i J , ; i !. i j 1 i J , ] " ; ! a > lin =S-2*511 23,,, J*3* 3'2;! S ' " - S 2 • fc >• a ul « s «-• _ * * «• •* • C .J 9«— * U 'J 3 "*'l|ii «• "•«« " » » £, , a* fl S ^ 2 • « * 5 • m 2 , I 1 8-214 ------- SECTION 9.0 LANDFILLS This -.3<-~.^n pr«is------- "5270.21 Specific Part 3 Information Requirements -sr Landfills Except as otherwise provided in 5264.L, owners and oserators of facilities chat dispose of '".^zaricuo -asLe ..n ianuciij.s must provide the following additional information: (a) A list of the hazardous wastes placed or to be placed in each landfill or landfill cell; (b) Detailed plans and an engineering report describing how the landfill is or will be designed, constructed, operated and maintained to comply with the requirements of §264.301. This submission must address the following items as specified in §264.301: (1) The liner system and leachate collection and removal system (except for an existing portion of a landfill). If an exemption from the raquirsraancs e-r : linsr and « j.eachate collection and removal system is sought as provided by §264.301(b), submit detailed plans and engineering and hydrogeologic reports, as appropriate, describing alternate design and operating practices that will, in conjunction with location aspects, prevent the migration of any hazardous constituent into the ground water or surface water at any future time; \2) Control of run-on; '2) Control at run-orf; (4) Management of collection and holding facilities associated with run-on and run-off control systems; and (5) Control of wind dispersal of particulace matter, where applicable; (c) If an exemption from Subpart F of Pare 264 is sought, as provided by 5254.202(a), ;he owner or operator must submit detailed plans and an engineering report explaining the location of the saturated zone in relation co the landfill, the design of a double-liner system that incorporates a leak detection system between the liners, and a ieachate collection and removal system above the liners; (d) A description of how each landfill, including the liner and cover systems, will be inspected in order to meet the requirements of §264,303 (a) and (b). This information should be included in the inspection plan submitted under 5270.14(b)(5). (e) Detailed plans and an engineering report describing the final cover which will be applied to each landfill or landfill cell at closure in accordance with §264.310(a), and a description of how each landfill will be maintained and monitored after closure in accordance with §264.310(b). This information should be included in the closure and post-closure plans submitted under §270.14(b)(13) . (£) If ignitable or reactive wastes will be landfilled, an explanation of how the standards of §264.312 will be complied with; (g) If incompatible wastes, or incompatible wastes and materials will be landfilled, an explanation of how §264.313 will be complied with; (h) If bulk or noncontainerized liquid waste or wastes containing free liquids is to be landfilled, an explanation of how the requirements of §264.314 will be complied with; 9-2 ------- (i) If containers of hazardous waste are to be Landfillaa, ^n explanation or how cne requirements of 3264.3L5 or §264.216, as applicable, will be complied -i;h." 9.1 WASTE DESCRIPTION 9.1.1 The Federal Requirement The Part 270 information requirements are: §270.21 "Except as otherwise provided in §264.1, owners and operators of facilities that dispose of hazardous waste in 1andf\l 1- must provide -_hs following aaaicionai inrormation: (a) A list of the hazardous wastes placed or to be placed in each landfill or landfill cell" Sufapart N, Landfills (§§264.300-264.339) of Part 264 does not contain specific requirements for waste identification. However, in Subpart 3, General Facility Standards, the orovisions of §264.13, General Waste Analysis, require owners and operators of all waste facilities to identify ail wastes handled. Specifically, cne requirements of §264.13(a), (b), and (c) apply to landfills and those requirements are: §264.13 General waste analysis "(a)(l) Sefore an owner or operator treats, stores, or disposes of any hazardous waste, he must obtain a detailed chemical and physical analysis of a representative sample of the waste. At a minimum, this analysis must contain all the information which must be known to treat, store, or dispose of cne waste in accordance with the requirements of this Part or with the conditions of a permit issued under Part 270, and Part 124 of this Chapter. (2) The analysis may include data developed under Part 261 of this Chapter, and existing published or documented data on the hazardous waste or on hazardous waste generated from similar processes. (3) The analysis must be repeated as necessary to ensure that it is accurate and up to date. At a minimum, the analysis must be repeated: (i) When the owner or operator is notified, or has reason to believe, that the process or operation generating the hazardous waste has changed; and (ii) For off-site facilities, when the results of the inspection required in paragraph (a)(4) of this Section indicate that the hazardous waste received at the facility does not match the wa*ce designated on the accompanying manifest or shipping paper. (4) The owner or operator of an off-site facility must inspect and, if necessary, analyze each hazardous waste movement received at the facility to determine whether it matches the identity of the waste specified on the accompanying manifest or shipping paper. 9-3 ------- (b) The owner or operator mist develop and follow 3 written waste analysis plan wni.ch describes che procedures which he will carry out to comply with paragrapn (a.j of this Section. He must keep this plan at the facility. At a minimum, the plan must specify: (1) The parameters for which each hazardous waste will be analyzed and the rationale for che selection of these parameters (i.e., how analysis for these parameters will provide sufficient information on the waste's properties to comply with paragraph (a) of this Section; (2) The test methods which will be used to tast for these parameters; (3) The sampling method which will be used to obtain a representative sarsplj it ;ne ------- The a DO I icant Is idv^jaa rr.ac .'a^cie inai-'sis .r. rcr-ia: icr. -j .-^qjirec in tae Par!: A application Bander }270.tJ!j)) and in response to the general facilinv information requirements (under 5270.li(b)(2)). The Pare A application muse include: • Specification of the hazardous wastes to be disposed of • Quantity of wastes to be disposed at the facility • Quantity of wastes to be disoosed annually • General description of processes to be used for such wastes If an existing facility with interim status submits a Part 3 -.pplication which indicates a aifrerent listing than in the original Part A application, a revised Part A application is also required. In this case, the Part B application should note the changes. 9.1.3 Guidance on Evaluating Application Information The requirement for 3. waste description is applicable to existing and new landfills and is intended to assure that che facility can adequately dispose of the proposed waste materials. For existing facilities operating under interim status, the list of current and expected wastes should include ail the wastes shown on the previously submitted Part A of the permit application. If the list shows fewer wastes than the Part A, then sitEer "he waste must have been specifically delisted since the Part A_ was submitted or the applicant must state in the application that the wasce will no Longer be accepted for disposal at the landfill. rhe list should be judged inadequate if neither of these criteria are met. For existing facilities operating under interim status, if the list contains more wastes than indicated on the previously submitted Part A, then the application must include a revised Part A. The application is incomplete if the revised Part A is not included. If the landfill is a unit of a larger facility, the Part A application will incorporate a listing of all wastes handled in all portions of the facility by EPA ID number. The wastes to be landfilled may be a subset of this list, or may result from processing or treatment of the noted wastes. Consequently, some or all of the wastes to be landfilled may not have an EPA ID number. An applicant could have difficulty supplying a detailed list of wastes that-have been placed in areas of an existing facility that have been inactive for long periods of time. (If such a facility portion is closed before January 26, 1983, it is not a regulated unit and, therefore, the information requirement is not applicable unless ground water contamination is evident.) For existing active portions, the applicant should be expected to indicate whether the wastes were bulk or containerized, solid or liquid. The owner's records may also indicate 'the type of waste (e.g., empty raw materials packages) or the type of process or operation that generated the waste (e.g, 9-5 ------- distillation column bottoms). In some cases, "he landfill may still be disposing of wastes from the same company or processes and :!-,e owner or operator can use that current information to help identify and characterize the wastes placed in inactive areas of the facility. Experience in the review of historical records indicates that a disposer's records will typically contain enough information to determine the physical characteristics of wastes disposed and a generic description of the waste. However, records do noc usually supply much information on where at the site a specific waste was buried or information that would allow a definitive hazardous/nonhazardous determination.2 Thus, a judgement on the adequacy of a list of wastes previously disoosed of at a facility may nave to be .aade on a .ase-oy-case oasis after discussions with the owner or operator. New facilities must submit a Part A application with their Part 3 permit application. The information on waste types and quantities contained in the Part A will generally be sufficient to meet the listing criteria for Part B. However, unless the permit application for a new facility includes both a Part A and a Part 3, the subraittal ^ust be judged incomplete. The regulations require a list of only the hazardous wastes. However, in some cases it may be advantageous to have information on the nonhazardous wastes that will be disposed. This is especially important if hazardous and nonhazardous wastes are to be intermingled, because a showing of compatibility must be provided in the permit application. The most frequent reasons for listing a waste as hazardous will be that the waste exhibits a characteristic identified in Subpart C of Part 261, that it is specifically listed in Subpart D of Part 261, or chat it contains a compound listed in Appendix VIII of Part 261. However, the applicant may list a waste as hazardous based on his knowledge of the waste or on the generator's knowledge of the waste, even if it does not meet any of the criteria in Part 261 that would require it to be listed. Sampling and analytical procedures recommended for hazardous waste characterization are presented in SW-346—Test Methods for Evaluating Solid Waste.3 For wastes placed in portions of a facility that have long been inactive, the applicant may be unable to identify hazardous constituents in that waste. Because the information on hazardous constituents is used to determine the adequacy of other parts of the permit application (especially ground water monitoring), the permit application reviewer will have to make case-by-case judgements of adequacy whenever such situation's are encountered. Worksheets for evaluating the technical adequacy of the applicant's waste listings are presented for existing facilities and new facilities in Figures 9.1.1 and 9.1.2, respectively. Completion of these worksheets will allow the permit application reviewer to proceed through the first part of the Technical Adequacy Checklist provided in subsection 9.9. 9-6 ------- LISTING OF HAZARDOUS WASTES--EXIST I.VG JACILITY Has cms part of che applicanc's subrniccal been reviewed and evaluated? Ye s No Dace Does che Pare B information agree completely with che listing information provided previously in che Part A application? Yes No Are waste names and EPA ID numbers identified? Yes No Are locations identified wichin the landfill co show where wastes are or will be disposed of? Ye s No If all answers are yes, this part of the applicant'3 jubmictai is aaequace. However, if any aifferences exist between the Part A and Part B applications- Are only a subset of the wastes listed in Part A co be landfilled? Yes No Are one or more of the previously identified wasces (in Pare A) to be treated or somehow transformed j?efore landfill ing? Yes No Have any of che wasces been delisted? Yes No Have any of the subject landfill portions been closed? Yes No Is che apparenc discrepancy explained in che Part B application? Yes No Has che applicant submitted a revised Part" A application? Yes No Describe any deficiencies in che applicanc's submittal, if they exist. Figure 9.1.1. Worksheet for evaluating che adequacy of che liscing of hazardous wasces for existing facilities. 9-7 ------- LISTING OF HAZARDOUS WASTES— MF>' TACILIIV Has this part of Che applicant's submittal been reviewed and evaluated? Ye s No Dace Have bocn Part A and Part B applications been submitted? Yes No Are waste names and EPA ID numbers identified? • Yes No Are locations identified within the landfill to show where wastes are or will be disposed of? Yes No Are there any apparent discrepancies in information provided in Parts A and 3? Ye s No Are- only a subset of the wastes listed in Part A to be landfillad? Yes Mo Will any wastes listed in Part A be created or transformed to different wastes that will ultimately be landfillad? _____ Yes No Describe any deficiencies in the applicant's submittal, if they exist. Figure 9.1.2. Worksheet for evaluating the adequacy of the lisring of hazardous wastes for new facilities. 9-8 ------- 9.1.4 Draft Pennit Preparation As noted in Module XV, Condition A, the pennit writer imst specify the wastes that can be disposed of in given landfill units at the applicant's facility. In the body of the pennit, rather than by attachment, the wastes or classes of wastes that are allowed for disposal must be stipulated. If any of these wastes are currently identified by EPA identification numbers, these .numbers should be included in the listing of wastes. If any special requirements are attendant with the noted wastes because of reactivity, ignitability, incompatibility, or other concerns, applicable permit conditions or attachments should be cross-ra£'»ranc3d a- ^naicton A. Permit condition >* -sd a-^acniaencs related to liner selection based on waste/chemical resistance should also be referenced at permit condition A. The fact sheet (or statement of basis) accompanying the draft permit should include a paragraph at the beginning to summarize the waste description or list incorporated as condition A in permit module XV. Other information wnich may be appropriate to explain briefly at this point in the fact sheet is the amount of waste expected to be handled on an annual oasis. 9.1.5 References 1. U.S. Environmental Protection Agency. Permit Applicant's Guidance Manual for Hazardous Waste Land Storage, Treatment, and Disposal Facilities. Volume 1, Office of Solid Waste, Washington, O.C., 1983. 2. Telephone conversation. J. McNeish, Intera Environmental -Consultants, Inc., and S. Caoone, GCA/Tachnolo^y Division. February 7, 1983. 3. U.S. Environmental Protection Agency. Test Methods for Evaluating Solid Waste—Physical/Chemical Methods. SW-846. Second Edition. July, 1982. 9-9 ------- 9.2 DESIGN AND OPERATING REQUIREMENTS Section 264.301 specifies design and operating standards for Landfill components such as liners, leachate collection facilities, run-on and run-off control facilities, and wind dispersal control systems. Because of che broad coverage of the design and operating standards, the forthcoming discussion is subdivided to address each of these system components. The remainder of this subsection is presented in the following manner: 9.2.1 Liner System Design 9.2.2 Leachate Collection ind ^e^oval i/ic-am 9.2.3 Liner and Leachate Collection and Removal System Exemption 9.2.4 Control of Run-on 9.2.5 Control of Run-off 9.2.6 Management of 'Jnitj Associated with Run-on and Run-off Control Systems 9.2.7 Management of Wind Dispersal 9.2.3 Subpart F Exemption The following subsections are incorporated under each of these sections: 9.2._. 1 The Federal Requirement 9.2._.2 Summary of Necessary Application Information 9.2._.3 Guidance on Evaluating Application Information 9.2._.4 Draft Permit Preparation 9.2._.5 References The third subsection of each of the first eight sections provides guidance on evaluating the technical adequacy of the application and includes worksheets for making this determination. The fourth subseccion incorporates guidance on preparing Che draft permit based on the submitted application information and model permit modules presented in Section 4 of this manual. 9.2.1 Liner System Design 9.2.1.1 The Federal Requirement— Paragraph(b) of §270.21 requires that the applicant's plans and/or engineering report on landfill design, construction, operation, and maintenance must address: 9-10 ------- . -1 The iiner systam. . . The liner standards of 5264.301 stace cnac: "(a) A landfill (except for an existing portion of a landfill) must have: (1) A liner that is designed, constructed, and installed to prevent any migration of wastes out of the landfill to the adjacent subsurface soil or ground water or surface water at anytime during the active life (including the closure period) of the landfill. The liner must be constructed of materials that prevent wastes from passing into the liner during the active life of the facility. The liner must be: (i) Constructad of aac«rial3 znat nave appropriate chemical properties and sufficient strength and thickness to prevent failure due to pressure gradients (including static head and external hydrogeologic forces), physical contact with the waste or leachate to which they are exposed, climatic conditions, the stress of installation, and the stress of daily operation; (ii) Placed upon a foundation or base capable of providing support to the liner and resistance to pressure gradients above and below the linar co prevent failure of the liner due to settlement, compression, or uplift; and (iii) Installed to cover all surrounding earth likely to be in contact with the waste or leachate; ..." 9.2.1.2 Summary of Necessary Application Information— The Part 3 Permit Applicants' Manual'1 directs the applicant to provide the following information on liner system design: (a) Hydrogeologic Data, including: • the location of the landfill bottom wich respect to the water table • data showing seasonal variation and highest recorded level of the water table (b) Material of Construction (c) Chemical Properties of Liner (d) Physical Strength and Thickness (e) Foundation Design/Integrity, including: • regional and site geologic data • summary of seismic conditions at the site • hydrogeological data describing aquifers at the site 9-11 ------- • an evaluation of surface water run-on and run-off • geotechnical data on foundation soils • a summary report, including: Detailed boring logs Typical soil profiles Site and regional geology - Fault map Results of analyses and description of methods Sol-ution cavity potential Sinkhole potential Liquefaction potential Uplift potential • description of liner bedding material (f) Areal Extent of Liner ''g) Liner System Integrity, considering: • waste/liner compatibility * internal/external pressure gradients • climatic conditions • installation stresses • daily operational stresses. The foundation investigation is expected to incorporate subsurface exploration by means of test borings, trenches, or geophysical surveys. Other field testing may also be appropriate, such as pumping, permeability testing, and tests for density, shear strength, and bearing capacity. Soil testing in the laboratory is appropriate to classify the soil and establish index and engineering properties such as Atterberg limits, grain size distribution, and soil compressibility. Settlement analyses should be conducted and reported to demonstrate total and differential settlement, primary and secondary consolidation, creep, and liquefaction. This foundation analysis is expected to be prepared by a local foundation expert (e.g., civil or geotechnical engineer). To illustrate liner system integrity, the applicant is asked to submit compatibility testing results. This information should include the test method, description of procedures, chemical and physical waste characteristics, raw test results, and interpretation of results. Perspective is provided in the Part 5 Manual on primary and secondary leachates and physical classes of wastes. These latter factors influence the selection of a method for collecting representative samples of leachates and wastes. The 9-12 ------- Agencv has deveU-oad "jsc ''.at::o-z '-'j-iC ;:..r as-esirer.: . f -aste/synthetic liner compatibility. .-i copy of cne procedure is included as an Appendix Co ihc. RORA Technical Guidance Document for Landfills^. A detailed engineering report is requested in the Part B Manual Co illustrate the proposed liner system's ability to withstand internal and external pressure gradients during the active life of the landfill. To demonstrate adequate strength and thickness, the applicant is asked to consider waste/liner compatibility, bottom heave or blow out, slope stability and creep, strength loss due to several factors, possible puncturing or tearing of the Liner, and live loads on the liner. Finally, if the facility has a projected active life of greater than 30 years, the applicant is asked to provide information on the aOil uner proposed is low :ha .yncnecic liner (in keeping with guidance in the RCRA Technical Guidance Document^). in this case, the application information requirements are as stated for clay liners in Section 6.0, Surface Impoundments. It is recommended that the permit writer review subsection 2.1.3 of the landfill chapter of the Part B Permit Applicants' Manual! because the Agency has requested extensive information on liner system design. 9.2.1.3 Guidance on Evaluating Application Information— 9.2.1.3.1 Introduction—Figure 9.2.1_Ls a flow chart that indicates the applicability of tne Part 264 requirements to the design of liner systems. This section provides technical guidance :o assist in answering the major questions posed in the cnart. An overview of the related subject matter addressed in this section is presented in Figure 9.2.2. Each topic presented in Figure 9.2.2 is discussed to provide a general understanding of liner design, installation, and performance factors which must be considered in evaluating the technical adequacy of an applicant's proposed liner system. Synthetic liners are emphasized because, if properly selected and installed, they will minimize the volume of waste which passes into the liner during the active life and, therefore, will promote leachate collection and removal through the leachate collection system. The reader is referred to the Technical Resource Document (TRD) on "Lining of Waste Impoundment and Disposal Facilities" (SW-870)3 which provides a comprehensive treatment of this subject. Much of the following text is based on information from the TRD. 9.2.1.3.2 Seasonal Variation of Water Table and Maximum Recorded Height- Information Requirement (a)—Several basic ground water hydrology references are available which discuss the concept of the ground water table and seasonal variation in ground water table elevation. These include Chow (1964),* Bouwer (1978),5 and Freeze and Cherry (1979).* The ground water table is the location of transition from the unsaturated zone near the ground surface to the saturated zone at depth. Since a capillary fringe often exists at this location, the water table is best defined as the surface at which fluid pore pressure is equal to atmospheric pressure. 9-13 ------- = ^ +t UHEN1AT HAZARDO ACH GRO Af ANY __. +£ ~*j * 2 - 1: •' -» — UJ o < - |!j :5 * ~ "' - l J ' i * if I v» f /"i< \-§f / i \. ^ f -'' uJ a. ^^^ f ^\ >— 5? f S "r— »• Sr* 1 ^ s * 1 Is _i Z <- _J u. 5 u 5 j- f— z a. J (/ -= 3 = - 2 -- - * * u. UJ « ^ \ •" / i£ ~ * S-*4 u* — g l - * /- — z r 3^0 X — Urt dj i— X a; Z -w < r oe yi S 3 — u, • | i O> UJ < l J oc u. o >- EX >» UJ Z 1- «o- 3 ££ < * j Z C» <^ 23§ UJ W l^> 3 z ° Z uJ UJ V> 3» foe ^ 21 UJ Otf -j — < a. o ^J O t— -J -ij — J W • |l i / 3 * \ ^/^ -^ ~* ^. \ ^^ V||/ i i i em equ 264 u -3 _3 -3 'J 3 30 ------- 9-15 ------- Water cable location is assessed based on well Level measurement.*. State water resource departments are the best source of historical records for ground water elevations in localized areas. These agencies -nay be affiliated with Che U.S.G.S. or state environmental departments. Often, conservation commissions may keep such records for their city or town. State water resource departments install and maintain monitoring wells to collect ground water table elevation data. In some states, records may cover as many as 100 ye.ars of measurements. In most states, measurements are made on a monthly basis. These information sources should be used as the basis for the applicant's demonstration of maximum recorded water table elevation, as well as seasons'. water table variatio". 9.2.1.3.3 Liner Materials, Chemical Properties, Strength and Thickness - Information Requirements (b), (c), (d), (f), and (g)—Topics grouped under this heading are discussed together because of strong interrelationships which exist among them. The chemical makeup of the liner is a determining factor in waste/liner compatibility. Incompatibility between the iiner and waste or leachate may manifest itself as a reduction in liner strsngth, 3r as an increase in liner penneaoiiicy. The strength of a synthetic liner may also be influenced by internal or external pressure gradients, stresses during installation and operation, or climatic conditions. These topics and associated evaluation methods are addressed in the next 4 subsections. Waste/Liner Compatibility Use of synthetic membrane liners for containment of hazardous wastes in landfills is an emerging technology. In past applications, synthetic liners have been used for lining of surface impoundments holding relatively homogenesous wastes in comparison to the range of wastes and leachates that could be generated in a landfill cell. Manufacturer's compatibility data may be adequate for single wastes and specific synthetic material blends, but will be of little value in evaluating the compatibility of a given liner with several different waste types or leachates generated from mixing of several different wastes. In recognition of the fact that selection of synthetic liners for hazardous waste landfill applications is tenuous based on currently documented data, the EPA has established a laboratory test method for assessing waste/liner compatibility. Test Method 9090, currently in draft form and subject to revision, is incorporated as an Appendix to the RCRA Technical Guidance Document for Landfills.2 As stated there, the EPA prefers chemical testing of liners using this method to account for the possible interaction of many waste or leachate types with the liner. Therefore, in all cases, except the most straightforward applications, it is incumbent upon the owner/operator to conduct such testing to provide evidence of waste/liner compatibility. Applicants will often require expert assistance in conducting this testing and in evaluating the results to assure that a proposed liner can be used with success. 9-16 ------- Tesc .iethoa 9090—in cnis :ese, i ^ampl^ of cne iiner nacerial is exposed Co che expected chemical environment for a period of 120 days and physical properties, tested before and after liner exposure, are compared. The physical parameters tested include tsar rssisc.ir.ca, puncture resistance, cansne strength, hardness, and elongation at break. Appendix VIII of the Liner TRD (SW-870) incorporates tabulations of ASTM test methods used to measure all physical properties specified in method 9090. Any significant change in these properties after sample exposure is considered to be indicative of incompatibility between the waste and liner. An important aspect of the test is collection and use of a representative sample of the waste or leachate. Collection of a representative sample will be difficult in the case of a new facility where the owner/operator plans to combine several wastes in the same call- In chic ^aae, cne permit reviewer jiiouia carefully evaluate the owner/operator's proposal for generation of a representative sample of waste or leachate. In the case of an interim status facility with existing units, leachate collected from an existing unit may be representative of leachate generated in a unit to be opened if waste types to be accepted are documented as similar. Taar cesiatance measures Che force required to tear a specimen of the liner with or without a controlled flaw, and serves as an indication of che mechanical strength of the sheeting. Puncture resistance measures the force required to puncture che liner sheet with a standard probe. It is intended to indicate che susceptibility to puncture from poorly graded materials above and below che liner. Hardness is a measure of the ability of the liner to resist indentation by a small probe of specified shape and dimensions. Tests of tensile strength and related properties may include the following measurements, depending on she type of polymeric sheeting tested: • tensile strength at fabric break (if fabric-reinforced), • elongation at fabric break (if fabric reinforced), • tensile strength at yield (if a crystalline liner), « elongation at yield (if a crystalline liner), • tensile strength at break of sheeting, • elongation at break of sheeting, • modulus of elasticity at specified elongations, e.g., 100 percent and 200 percent. These ceats are performed according to ASTM and FTMS protocols (see Appendix VIII and Table 3-7 in SW-870). Results are plotted over the time period 0 to 120 days. Submitted data should include raw, tabulated, and plotted results. Saw data are particularly important to allow the permit reviewer to assess the validity of the applicant's interpretation of results. 9-17 ------- Discussions in cne RCRA Technical Guidance Document for Landfills2 suggest chat any significant deterioration in any of cnese measured properties) should be considered aa evidence of incoraoatibility -in I as? i -cr.v Dicing demonstration is tnaae to show Chat deterioration exhibited by Che test results will noC impair liner integrity over the facility's life. The cumulative effects of possible deterioration should be extrapolated over the facility's operating Life in any determination such as this. Existing Compatibility Test Results—The liner TRD (SW-370) reports test resuiCd for liner exposure and immersion in hazardous wastes. In one series of tests, liners were exposed to strong acid wastes, a strong alkali waste, an oil refinery tank bottom waste, a lead waste from gasoline, saturated and unsaturated hydrocarbon wastes, and a oesticide v.ista Significant changes in ultimate elongation of butyl rubber (see Table 4-21 in SW-870) w«re found after 3 years of exposure to strong acids or caustic. Minor changes were noted for all waste/liner combinations although the statistical significance of the changes is uncertain. The S-100 modulus was noted to change for CPE and CSPE liner specimens exposed to caustic solution. Deterioration was also noted for other combinations. Several physical properties were tested to determine the compatibility of several liner types with a dilute aqueous organic waste (0.1 percent tributyl phosphate in deionized water). Those results are worth noting here because they reflect the type of data that would be reported in performing Test Method 9090 (although the test period _i_s longer than required under tfethod 9090). Table 9.2.1 reprints information from TaDie 4-28 or the Liner ISD. Some fairly significant changes tn physical properties are evident. The tear resistance of all liner types suftered significantly. Tensile strength and elasticity ara also noted to have deteriorated. These results would indicate that use of CPE, CSPE, or PVC with this waste would be unacceptable considering the significant changes in physical properties noted. Even use of butyl rubber or HDPE would be uncertain based on these test results, for the specific liner/waste combination considered. Factors Affecting Liner Deterioration—Liner deterioration is aost often caused or associated with one or more of the following:7 • Swelling of the coating compound used on the liner, • Degradation of the polymer used in the liner fabrication, • Crosslinking of the polymer in the coating. Swelling of the liner compound may lead to softening, a reduction in tensile strength, « loss of elasticity or possible elongation, and an increase in permeability. Degradation of the membrane polymer can increase swelling. Crosslinking of the polymer causes stiffening, usually loss of tear strength, and sometimes loss of tensile strength as well. Although fabric reinforcement may enhance liner tensile strength, the reinforcement may be affected by wastes which can permeate the coating. 9-18 ------- TABLZ 9.2.1. EFFECTS OF EXPOSURE ON SELECTED POLYMERIC MEMBRANE LINERS IN WATER CONTAINING A LOW CONCENTRATION OF A DISSOLVED ORGANIC CHEMICAL* FOR 17.2 MONTHS SOURCE: TABLE 4-^3 OF SW-870-5 Polymer Type of compound^ Liner number Initial thickness, mil Analytical properties: •/aignc jam, ", Physical properties:0 Final chickness, rail Change, % Butyl XL 44 63.0 21.9 64 + 2 CPEd TP 77 30.0 107.2 48 +60 C?Ed XL 100 35.8 34.4 41 + 15 CS?Ed TP ^, C 33.1 31.6 38 + 15 ?vcd T? 59 33.1 46.2 36 +9 HDPEd CX 105 31.9 0.56 31.5 -1 Tensila strength, % retention 107 10 b3 <*3 31 88 Elongation at break, 7, retention 115 155 79 79 89 101 Stress at 100% elongation, % retention 74 6 46 30 13 " 52 Tear resistance, % retention ... 14 29 39 23 81 Hardness change, Durometer points ~2A -60A -20A -14A -33A -1A Puncture test: Stress, Z retention 73 20 85 112 48 101 Elongation, % retention 126 127 125 131 133 107 a0.1% Tributyl phosphate in deionized water. bTP=thermoplastic, XLacrosslinked, CX3partially crystalline thermoplastic. cData for tensile, elongation, S-100, and tear are the averages of measurements made in both machine and transverse directions. dCPE - chlorinated polyethylene CSPE - chlorosulfonated polyethylene PVC - polyvinyl chloride HOPE - high-density polyethylene 9-19 ------- Preliminary Selection of Synthetic Liner Material^—Given che emerging scaCus of synthetic liner use for hazardous waste management, 2 ccmprenensive and reliable guide on waste/liner compatibility is not currently available. However, some existing knowledge can be summarized to provide some general information on liner selection. To date, quite a bit of data has been compiled on liner swelling (i.e., weight gain) after immersion or exposure to wastes. Table 9.2.2 provides a summary of some of this information (based on References 3, 8, and 9) and indicates wasce/liner combinations of high, medium, or low resistivity. The results from Reference 3 are based on immersion tests (of up to 81 days) using reagent grade chemical baths according to the ASTM D471 Immersion Method. Resistivity ratings presented in the table were defined on the following basis: Resistivity % Weight Loss or Rating Gain High 0.1 - 11.5 Moderate 7.0 - 23.0 Low 20.0 - 250+, and dissolution or deterioration Qualitative rankings (good, fair, poor) of waste/liner compatibility are presented for generic industrial waste cypes (caustic petroleum sludge, acidic steel-pickling waste, etc.) in the Liner TRD (SW-870). Rankings for synthetic liner/generic waste combinations ara caproducad here in Table 9.2.3. This information is presented for general guidance only. If a situation arises which is apparently covered by one of the ratings, it should not relieve the applicant of conducting laboratory tesfing. Compatibility information is available through che flexible membrane liner industry. Considerable data on the use of polymeric materials has been collected. Generally, however, this information is representative of situations which are not as complex as those that may arise in permitting situations. Generally, the compatibility of the liner and one constituent are considered in manufacturer's information. However, some liner fabricators may be willing to share previous experience or case history information which they have on file. Manufacturer's waste/liner compatibility data have been summarized and statistically evaluated by A. T. KearneylO for the EPA Office of Solid Waste. Liner ratings provided by manufacturers were converted to numerical scores and were also ranked using a pass-fail system. EPA is continuing research of liner characteristics and will issue updates on existing data as information becomes available. The RCRA Technical Guidance Manual "Landfill Design - Liner Systems and Final Cover" should be consulted in addition to SW-870, the Liner TRD. Additional information sources that may be of value in assessing waste/liner compatibility are listed in subsection 9.2.1.5, References, numbers 11 through 15. 9-20 ------- 01 ; a , ! S, i.ls ;J 5J:I ;i ;------- -J T3 u -a C a y tfl y 4) '* c -1" & 2 5* a. o * ! - " ' V3 M ,H^ i. _J i—t 33 *"^ § 2j 8 Ed i V3 •tff* ^* -3 < ^^ 1 I J 3D -i C -o ... -^ 3 O -u — « 0) SO u 0) •o i y •-< aj 5> ... -j _ - X •-. 3 0 P u g ._ 1 ^^ ^ '-i W 1 » O ! O. 04 V) i) Ut f* „.. ' W 3Q ••; -• •- -o T3 U U 3 ••« ------- Synthetic Liner Permeability The regulations require use of a liner :hac prevents wastes from passing into the liner during the active life of the facility. Synthetic liners come closest to meeting the condition of impermeability, although none have been identified which are completely impermeable. A review of manufacturer's literature indicates that liner permeability is rarely specified. In some cases, the percent water absorption is specified but the associated test period is not. The TRD on liners (SW-870)3 reports a variety of test results for synthetic membrane liners exonsed :o '-.asardous waste leachates which are indicative of liner susceptibility to waste or leachate permeation. These tests were designed, in part, to measure changes in volatile and extractable content of exposed liners, changes in weight, and changes in other measured parameters, as discussed below. In these experiments, membrane liner samples were exposed co hazardous waste leacnate in immersion tests, pouch tests, and tub tests. The wastes included cvo strong acid wastes, a strong alkali waste, an oil refinery tank bottom waste, a lead waste from gasoline, saturated and unsaturated hydrocarbon wastes, and a pesticide waste. As part of the immersion tests, eight membrane liners were exposed below 1 foot of waste. After 1 year and 3.i_years of exposure, the membrane samples were analyzed for voiaciias and axtraczabies (i.e., the higher the percentage of extractables and volatiles, the greater the membrane permeability). The results of this testing showed that butyl rubber, elasticized polyolefin, polyester and polyvinyl chloride contained a lower percentage of volatiles (2.9-4.3 percent) Chan chlorinated polyethylene, chlorosulfonated polyethylene, athylene propylene rubber, and neoprene (6.3-13.6 percent) when exposed to a pesticide waste. Exposure to other wastes produced similar results. Concurrent with these tests, supplemental liners were hung in the wastes and the effects of exposure were evaluated by determining the increase in weight, analyzing the exposed specimen, and measuring selected physical properties. The amount of pesticide waste absorbed by butyl rubber, elasticized polyolefin, fabric reinforced ethylene propylene rubber, polyester, and PVC was less than 5.1 percent. Chlorinated polyethylene, chlorosulfonated polyethylene, non-fabric reinforced elasticized polyolefin, and neoprene shoved significantly higher absorption of pesticide waste, ranging fro* 11.4 to 20.4 percent. Absorption rates were similar for other wastes with some exceptions. One notable exception was the butyl membrane. This membrane exhibited low absorption for the pesticide, acidic, and caustic wastes but a high absorption capacity for the oil wastes. In the immersion tests, measurement of the volatile content of the membranes were analogous to the results of the absorption test. 9-23 ------- la a pouch cesc, small pouches were fabricated o_ut of chlorinatad polyethylene, chlorosulfonatad polyethylene, eiasticized polyolefin, polybutylane and polyvinyl chloride. (At the praser.c ciae, only poucnes made of thermoplastic and crystalline sheetings have been successfully fabricated into pouches and tested.) These pouches were filled with wastes and other test fluids and Chen sealed and immersed in deionized water. The permeabilities of the membranes to water and to pollutants were determined by observing, respectively, the change in weights of the bags and the pH and electrical conductivity of the daionizad water. After 552 days of testing, measurements of the electrical conductivity and average flux showed that PVC lining materials had the greatest permeability of the membranes tested. Chlorinated polyethylene and chlorosulfonated polyethylene were found to hava less permeability than PVC but greater oerraability ;;-4an etnyiene propylene ruboar ana poiyoucylene. An analysis of the physical properties of the pouch wall materials after 1150 days of exposure confirm the above conclusions. As part of the tub tests, two samples of polyolefin liner were exposed to an oily waste; failure occurred by cracking at the folds of the sheet. In a preliminary immersion test, this liner had appeared to perform satisfactorily with the waste, althougn the manufacturer had not recommended the liner for use in waste oil impoundments. Performance was noted to vary significantly depending on location of the liner specimen in the tub. The worst performance was noted when the sample was located at the waste - air interface. The unexposed sample retained its properties during the 43-month exposure period. Based on all testing reported in the TRD (SW-370), Che following general conclusions are noted regarding ralative permeaDiiity of membrane liners. PVC liners exhibit relatively high perraeatrility in the presence of some hazardous wastes in spite of the fact that they have shown low permeability in the presence of sanitary wastes. PVC membranes are attacked by many organic chemicals including hydrocarbons, solvents, and oils. Other liners which appear to have a relatively high permeability are chlorinated polyethylene and chlorosulfonated polyethylene. Ethylene propylene rubber, polybutylene, polyester, and butyl rubber appear to be the least perraeaole of the membranes tested. Neoprane and elasticized polyolefin appear to have a medium level of permeability. These results are summarized in Table 9.2.4. Because chey are general in nature, they should not be used as the basis for accepting or rejecting a liner proposed for use in containing a particular waste. Resistance to Pressure Gradients and Stresses During Installation and Operation EPA believes (R.CRA Technical Guidance Document on landfills)2 that synthetic membrane liners should be at least 30 mils thick; thinner liners are reported to b« readily damaged. One of the primary reasons for failure is tearing, puncture, or stretching during installation or operacion. In general, damage may result from physical, biological, or chemical failure, as presented in Table 9.2.5, from section 4.6 of the liner TRD. The following discussion briefly describes each category and provides recommendations on how to avoid such failure. Additional information may be found in SW-870^ and the RCRA Technical Guidance Document.2 The previous discussion of waste/liner compatibility can be referenced for guidance on chemical damage. 9-24 ------- i US U -H <-, O a a >< -3 33 JJ s D - > — ••4 ... U .fl SJ ,TJ ** Cl ^ i 06 M CU a 4 ~ "ai • •* X •3 S «8 0 Cv TJ CU 4J CO V CU --i *J AJ tlj 31 L! 3 3 tO u o <0 31 4J C • u " ^30. 13 31 CO a 0) _i , u -, co ifl 3 to llazardou .a o /— « S • H o . CO • S •-< o — .a * L, - * S8 O Li - -3 •31 X U "~ 4 . "^ — ^ 1 V •- 3 1 - 5J 4> 3 ./i c °- i e - o co « f o "" c s j ^ ^ a i. -^ "ool J:"«cg> -Oj3j o _ a. U "° I , °' «» a. eg I CO y " cu (j 9 e c "S e ^ I <= x 5 CU CU O 9 "* Li N ^H 1*4 1 *J O (0 -• X C I <0 30 a ej o.--< ••^ O CU CU ! 1 '- " " £ L, C ^ 1 •" <« - ------- TABLE 9.2.0. POLYMERIC MEMBRANE LINER RESISTANCE TO Co u re a: j * -o 7 6. Resistance Co: Liner type Temperature Weathering Sunlight Ozone Butyl rubber High tolerance Good - Good for extremes in temperature CPE - ' Good - Poor CSPE Good heat Good Tends to shrink; some Good resistance also tends to harden on aging due to cross- linking ay ultraviolet radiation* alasticized polyolefin Some diffi- Excellent culties in low temperature and high wind Spichlorohydrin Good thermal Good - Good rubbers ("3 and ICO) scaoiiity— high tolerance for tempera- ture extremes Ethylene propylene Tolerates Excellent Excellent resistance to Excellent rubber (EPDM) extremes of ultraviolet radiation temperature Polyethylene - b (HDPE, LOPE) PVC - Poor Poorc 'Fabric reinforcement reportedly reduces distortion resulting from shrinkage when exposed to the heat of the sun. ^Unprotected clear polyethylene degrades readily with outdoor exposure, but the addition of 2 to 3 percent carbon black can improve ultraviolet light protection. cThe PVC polymer is affected by ultraviolet exposure. The sun's heat volatilizes the plasticizer; although the addition of carbon black prevents deterioration from exposure to ultraviolet light, it causes increased absorption of solar energy, thus vaporizing more of the plasticizer. Soil or other cover materials may be used to bury the liner and protect it from ultraviolet exposure. 9-30 ------- ?.2.1.3.-» Foundation design and Ir.tagr.rv • lajonac-on Requirement ve)~~ .Following confirmation of waste/liner compatibility and inherent liner strength, acceptance of the proposed liner system will rest on evaluation of the foundation design and analysis. Si.nca compression, sectieraenc, or uplift of the foundation could cause liner damage, the applicant must establish the long term stability of the liner foundation. This section addresses essential factors in this analysis, including: • regional and site specific geologic conditions • seismic conditions, location of faults • hydrogeologic conditions, description of aquifers • evaluation of surface run-on or run-off • geotechnical engineering, classification, and characterization of foundation soils Geologic Conditions Regional «nd site-specific geologic data submitted with the application should include: • geologic setting • type(s) of bedrock and depth(s) • subsidence history, and • potential for sinkholes. Information on geologic setting and bedrock characteristics will likely be presented in the form of geologic maps as well as aerial photographs and descriptions. Subsidence history could be shown by a historical map sequence or through research. The potential for sinkholes is partially derived based on the type of bedrock underlying the area in conjunction with other site specific conditions such as surface water characteristics, soil types, rainfall, wells and ground water consumption, etc. The scope of technical information expected to be submitted in support of this information requirement is reviewed here. Various considerations, such as data qua' Lty and data interpretation are noted. It is recommended that the permit reviewer refer to the basic references sited in this discussion for more detailed information. Geologic Setting and Bedrock Description--A detailed discussion of applicable information on geologic setting is provided as part of the ground water section of this document (see Section 5.0). Specific technical information which pertains to foundation design and integrity is summarized. 9-31 ------- Geologic raaps snouia be included in che application co indicate bedrock and gurficial geology of the area. In addition, tne applicant should have consulted with a certified geologist concerning local -onaicions which might not appear on a general map, or which might appear in a different location. The application should include as much site specific geologic information as possible* Bedrock information provided should include: • the physiographic province in which the bedrock is located (Coastal Plain, Appalachian Highlands, etc.), • rock name, group, and type (for example, liiaascone +a in tne -arnonate .-OCK group wnicn falls into the sedimentary rock type, granite is an igneous rock type in the granite-granodiorite family), • formation name, • age (the era, period, or epoch which best describes the age of the rock), « thickness of eacn type of bedrock unit, • texture—size and shape characteristics, such as fine, sub-rounded, angular, etc. Also, the fabric/matrix make-up (elastic, sorted, fissile, shaley, etc.), » structural features of note., such as georaorphologic characteristics (faults, joints, salt domes, geosynclines, karst, caves, etc.) and petrologic characteristics for igneous and metaraorphic rocks: lava, dikes, veins, cones, craters, batholiths, plutons, etc.). For sedimentary structures this would include: dunes, clastic dikes, cross-bedding, deformation, etc.; and • Orientation—the altitude and direction of the formation in terms of strike and dip. Surficial information should include: • The soil type designated according to the unified soil classification system notation (for example "GW" represents well-graded gravels and gravel-sand mixtures with little or no fines; "SC" represents clayey sands or poorly graded sand-clay mixtures). Sediments may also be classified into several sediment group*, for example, alluvium is in the group comprised of terrigenous elastics, • The physical characteristics of the soil (i.e., is it dry, moist, compacted, cemented, man-made, etc.), • Formation name for the soil deposit, • Depth of surficial deposits, 9-32 ------- « Age of the soil, • Thickness of Che deposit, 9 Texcure of Che deposit, • Genesis of the surficial deposits should be noted, such as whether it was organic in origin, volcanic, glacial, eolian, evaporitic, chemically precipitated, detrital, etc.; and • The environment in which the soil formed should be defined: fluvial, lacustrine, glacial, marine, eolian, evaporitic, deltaic, estuarine, alluvial fan, etc. This information, along with mapping of the geologic units (both bedrock and surficial deposits), will enable the applicant's geologise to assess the geologic setting for the landfill. Specific characteristics of the area's soils and bedrock, such as permeability and ability to hold water, should be assessed in the application. Subsidence History—Subsidence of an area may oe linked to various geologic features as well as human activity. Therefore, both geologic and human influence should be carefully evaluated for each site. For landfills, the permit reviewer should be concerned with possible subsidence resulting from several causes, as discussed later in chis subsection under Foundation Analysis. Subsidence directly related to human activity and geohydrologic . conditions may occur in an aquifer system intar-layerea with plastic clays if che aquifer system is developed to the extent that the ground water table is significantly lowered. Subsidence will also be dependent on the existing and potential amounts of water withdrawn for the area. This will depend on the size and capacity of the aquifer, its potability or suitability for industrial uses, and potential future uses. Although subsidence potential is site-specific, there are certain areas in which the phenomenon of subsidence has been demonstrated in rather extreme fashion. These include Long Beach, California; the San Joaquin Valley in California; and Mexico City, Mexico. In these instances, subsidence has been shown to occur at races of almost 1 meter every three years. These situations involved aquifer systems containing layers of soft clay, silt, or peat. Upon development of the aquifer systems, the cohesive layers compacted causing the ground to sink. Subsidence cannot be avoided if the water table is continually lowered in areas containing compressible, cohesive soils. Consequently, landfills should not be located in such areas. Figure 9.2.3 illustrate* the degree of subsidence which occurred due to ground water withdrawal over a period of 36 years in an area of California.22 Potential for Sinkholes—Sinkholes occur in areas referred to as karst topography. They are formed as depressions on the ground surface overlying soluble rock material which has collapsed or dissolved. In some cases, limestone immediately below the soil may be dissolved due to seepage of 9-3 j ------- JO .10 Figure 9.2.3. km Land subsidence in Che Tulare-Wasco area, California, 1926-1962, due co withdrawal of ground water. Lines show equal subsidence in meters and are dashed where approximate. Source: Reference 22. 9-34 ------- water. This process oiay be accaieracaa 37 ^ocai factors sucn as abundanc rainfall or limestone solubility. More rcicsoniy, o^nKnoies form wnen the surface collapses into a large cavity below. Surface water may drain through the sinkholes Co the ground water table. Lakes may oe formed when subterranean outlets become clogged or if the sinkhole forms in an area with a high ground water table. The most notable karst areas are in regions where limestone deposits underlie the surface. However, in some localities, dolomites or dolomitic limestones, gypsum ana rock salt of limited areal extent may also develop such features. Because limestone deposits are abundant in nature, it might be expected that karst topography is widespread. In actuality, however, only a relatively small number of localities experience full development of karst. Four conditions that contribute to the development of karst should be examined by Che permit reviewer. They are:^ 1. The presence of soluble rock near the surface, sucn as limestone; 2. Soluble rock wnich is dense, highly jointed, and thinly bedded; 3. Areas where entrenched major valleys exist below uplands which are underlain by soluoie, well-jointed rock; and 4. Areas with at least a moderate amount of rainfall. 3y far the -aost common ana widespread topographic form in a karst region is the sinkhole (other names which might be used for associated forms of sinkholes include solution pans, jvaiasf poljes>. Often, such sinkholes may be present in great numbers and may vary greatly in size. In fact, thousands of sinkholes exist in the karst terrain" of southern Indiana, Florida, and other states.-^ Lowering of the ground water table due to development of aquifer systems has been known to cause rapid subsidence which may result in sinkholes. In one example, an area underlain by dolomite covered with a tnicx layer of weathered material developed sinkholes after lowering of the water table as part of a mining program. These sinkholes developed over zones where the surface of the dolomite was irregular and characterized by pinnacles of unweathered rock separated by accumulations of weathered material and debris from mining. Sinkholes started to form with the development of large voids between the pinnacles. This was due partly to drying of the debris resulting from lowering of the water table. In addition, the debris was washed into the dolomite openings at deeper levels. Because sinkholes form in karst topography, locations in such areas should be carefully evaluated. Locations where sinkhole formation is of concern are those which have humid climate, limestone bedrock, and ground or surface waters which contain carbon dioxide from vegetative soures or are under pressure. These locations include Florida, the Great Valley area of Virginia and Tennessee, southern Indiana, west-central Kentucky, and 9-J5 ------- nortn-centra1 Tennessee. Aerial photographs aav be checked tc ISSI^L in evaluating trie sinkhole potential or a s_ite. Additional information on evaluating the potential for sinkholes can o< ^juna in References 23 and 2-+, Seismic Conditions The applicant must provide data and interpretative discussion concerning the potential for ground shaking and surface rupture at the site. A ^aa .showing fault areas should be submitted, especially for sites located in areas listed in Appendix VI to Part 264 (Political Jurisdications in which Compliance with the Seismic Standard must be Demonstrated). Such a map may be compiled using aerial photographs of the site, published information, a walking tour of the site, and/or 3 jubjurface investigation of the site. Ihese techniques are briefly described in this section. The submitted map should show distances to known faults and summarize seismic activity to date. Activity occuring in Holocene time is especially important (approximately the last 11,000 years). The application should demonstrate the location of faults with, respect to che site in question; most importantly, if faults are located within 3,000 feet of the site. Pertnic reviewers should evaluate cne existence of faults based on the most conservative interpretation of the information presented. Permit applications covering sites in areas where seismic activity is of concern .nay include aerial pnotos or they may be requested as additional data needed for sufficient review. Aerial photo analysis should be oerfor~ed ^y one trained in aerial photographic interpretation. Because aerial photos vary with season of flight, type of film, photo scale, cloud cover, etc., review will necessitate analysis of such factors. Aerial pnocos will be mosC useful if they cover a 5 mile radius around the site. Published information which would aid in seismic interpretation should also be included in the application and should have been interpretated by one skilled in seismic studies. Sources of data should be noted and referenced in the application. If there is doubt in regard to data quality or seismic evaluation techniques, a site tour should be recommended. Applicants with sites which appear to be within 3,000 feet of a fault must provide information showing that no faults (or lineations) pass within 200 feet of portions of the facility where treatment, storage, or disposal of hazardous waste will be conducted. Such evidence might be available from a comprehensive geologic analysis which would likely include a seismic survey. If this is not conclusive, a subsurface investigation should be conducted. A comprehensive geologic analysis entails surface geophysical surveys, evaluation of borehole records, ground-penetrating radar, seismic refraction techniques, and other methods to determine exact fault location. A map should be included in the application showing results of the study. Seismic surveys can provide elevations and thickness of hydrogeologic units, as well as fault/lineation location. Such information is useful in the geologic analysis as well. 9-36 ------- 2or2noi.es nay oe installed by tne applicanc Co supplement knowledge of site geology gained from the coranrshansive geologic analysis. In addition, some sore of digging, such as trenchine, -nay pr^v.d; /.dcasdary information. Trenching aay be required in cases where the comprehensive geologic analysis or borehole logs do noc provide conclusive evidence of the absence of faults within 200 feet of the portions of the facility where treatment, storage, or disposal of hazardous waste is proposed. The permit reviewer should check trenching maps to verify that trenching has been performed oeroendi.cular to known faults that were found to -sas.s viihir: 5,000 feet of such portions of the facility. In evaluating seismic data, the permit writer should be aware that such data also pertain to geologic ?nd hvdri1 -".';: -.cnsiiieraCiOns. Therefore, as an indir.acirn jjj •j^p^c-iLion integrity, the application should document that seismic daca were evaluated by a geologist familiar with the area and with seismic analysis. References 25 through 30 contain data which may aid in the application review process for seismic conditions. Hydrogeologic Conditions The application information should present definitive characterization of aquifers directly below the site and within proximity of the site. Througn the use and presentation of test borings, trenching results, geophysical surveys, and published information, the applicanc should be expected to define potentially impacted aquifers to Che following extent: » Aquifer dimensions • Aquifer elevation and seasonal fluctuations • Aquifer flow characteristics including velocity, volume and directions • Ground water uses and potential uses (e.g., drinking or industrial consumption) • Relative locations and permeability of confining strata « Test data such as pump tests, drawdown curves, hydraulic conductivity, transraissivity, hydraulic gradient determinations, etc. The information submitted to establish ground water monitoring plans under Jubpart F should be comprehensive enough to support this information requiremenC. Surface Water Run-on and Run-off Characterization of overland flow patterns is an important consideration in the foundation anaysis to account for the potential liner damage resulting from foundation erosion. The permit applicant should conduct a hydrologic study to evaluate run-off quantities and patterns upgradient of and within the 9-37 ------- site boundaries. Such faccors as precipitation, irifi Icrac ion capacity, area of Che drainage basin, overland flow lengtn, ana arainage basin gradient are used CO calculate overland 6'ow. The peak rate of overland flow across the landfill can be estimated using the Rational Method or the Soil Conservation Service (SCS) method. A detailed discussion on applying these techniques is provided in subsection 9.2.4.3 to address the regulatory requirements of §264.301(c) and §264.301(d) for run—?n and run-off management, respectively. Geotechnical Evaluation The permit loolicatfon -•>" •'=?v. -T j.ioul-i c:va>.aace cne applicant's geocecnnicai data submitted co demonstrate the stability of the liner foundation and subgrade (or liner bedding material). Information provided on soil classificacion, soil engineering properties, solution cavity potential, sinkhole potential, liquefaction potential, and uplift potential must be evaluated. References 31 cnrougn 35 are valuable basic reference sources on soil mechanics and ~eotechnical engineering. They should be reviewed for a more thorough understanding of the subject matter presented here. The permit applicant should conduct sufficient testing to classify foundation soils and characterize the engineering properties of the soil. Index properties that should be evaluated include grain size distribution, Atterbers; li.-?.i;a, rpecific gravity, density, and moisture content. Engineering properties that should be evaluated include strength, permeability, compressioilicy ^nd others. A settlement analysis is required to estimate total and differential secc4eraent, immediate settlement, primary and secondary consolidation, creep, and liquefaction. Bearing capacity and stability of foundation soils can then be assessed based on this information. Index Properties— A sieve or mechanical analysis is performed to determine the grain size distribution of a soil. A typical grain size analysis Is plotted in Figure 9.2.4, reprinted from the SCS Engineering Field Manual.33 Information which can be obtained from this chart includes the total percentage of a given size, the total percentage larger or finer than a given size, and the uniformity or range in size of a given soil. Soils are classified as coarse or fine based on the amount of material passing a number 200 sieve (0.074 mm opening). A material is coarse if more than 50 percent (dry) is retained on the ?200 sieve; fine if more than 50 percent passes the sieve. Coarse materials consist of sand ana gravel and possibly some small portion of fines. If the fines content is less than 5 percent, the engineering properties will be a function of the coarse materials only. 9-33 ------- I M - , i • ' —*"f~'—r—^-*._ 9-39 ------- Soil ; lass i. £ icacion 3 /scans :r.ac anc. iave found -nose widespread use include Che AASHTO (American Association of State Highway and Transportation Officials) system and the Unified Soil Classification System, These and others and their definition by grain size fractions are illustrated in Figure 9.2.5, after Cernica (1982). 34 Cla«ifi«iion Syuem K Unified ,«*,o MIT ASTW LSDA X) 10 i C.ra»«l 75 4 4 Grain Sue i nm i ! 01 0 0 1 0 X) 1 ) OiX Sind Fines IN<|I jnd Jay i '5 0075 (jnvel b^no 1 Silt •' 'r. rs : ------- n = ~ x 100 (expressed as a percentage) The void racio cnanges as a function of the volume of voids because che volume of solids is generaily assumed to remain constant. The void ratio may range from 0.5 to 0.9 for sands or gravel and between 0.5 to 1.5 for clays, although higher values can be encountered for clays. Soil Moisture Content—The water or moisture content, w, is defined as the ratio of the weight of water (Ww) to the weight of soil (*'3), or: W W wa — x 100 (expressed as a percentage) (3) 3 The degree of saturation, S, is defined as the ratio of Che volume of water (Vw) to the volume of voids (Vv), or: V S 3 ~ x 100 (expressed as a percentage) (4) v A soil will never be fully saturated, aven if submerged, because a certain amount of air will remain within the soil mass. However, the water content can exceed 100 percent, especially for fine grained soils and will have a significant effect on the engineering properties of clays. The optimum moisture content is the value of w where the soil reaches maximum density under a given compactive force. Soil .Density—Relative Density, D^, is defined as: . « 100 (S) max mm where v - dry unit weight of soil in densest state Y . a dry unit weight of soil in loosest state rain * The relative density may be considered as an indication of the stability of a soil. For instance, a granular soil with low density may be subject to settlement upon vibration. In the field, density is characterized using the Standard Penetration Test described later. Cernica (1982) presents the following relationships for soil density: SR (%A Soil Designation 0-15 very loose 15 - 35 loose 35 - 70 medium dense 70 - 85 dense 85 - 100 very dense 9-41 ------- iric jraviry, --, 15 cae ratio oc cne unit weignt • che unic weight of water (vw) ac 4°C. Most soil particles .6 Co 2.8. Organic soils (silts) may oc che son co have specific gravities ranging from have a lower specific gravity. Atterberg Limits—The Accerberg Limits provide a great deal of information for cohesive soils. The concept was introduced by A. Atterberg and modified and amplified by Terzaghi and Casagrande. As water is added to a dry clay, it will be transformed from a solid or seraisolid state to a plastic state and then to a liquid state. The water contents ac these points of change are termed the shrinkage limit (SL), plastic limit (PL), and liquid limit (LL) (e.g., the Atterberg limits) as demonstrated in Figure 9.2.6. DRY SL PL LL SI PI PERCENT WATER IN THE SOI L Figure 9.2.6. Atterberg limits. The shrinkage limit is che maximw» water content ac which a reduction in water content will not cause a decrease in the volume of the soil mass. The plastic limit is the watar content at which a soil will begin to crumble when roiled into a thread approximately 1/&. inch in diamter. The liquid limit is the water content at which a pat of sail, cut by a groove of standard dimensions, will flow together over a distance of 1/2 inch under the impact of 25 blows in a standard liquid limit apparatus. The Shrinkage Index (SI) is the difference between the plastic and shrinkage limits, or: SI PL - SL (6) The Plasticity Index is the difference between the liquid and plastic limits. PI * LL - PL (7) and indicates the range of water content over which the soil will remain plastic. Engineering Properties—It will be important to evaluate the applicant's assessment of soil engineering properties to ensure the acceptability of the liner foundation and subgrade materials. The soil index properties should be reported, especially Atterberg limits and moisture content for cohesive soils that may be part of foundation soils. The liner subgrade will generally be a cohesionless soil such as sand and tae grain size distribution should be 9-42 ------- rsporcea. in -sr.sral, ;ne engineering properties of Che in-s itu or iraolaced foundation soils below the subgrade will be the ,-nosc important Co the stability of the liner system. Therefore, TIOSC of cr-.* -•*-.;: i.-.l.ig uiscussion addresses these types of founuation soils. This discussion of soil properties and their affect on the engineering behavior of soils is based on information presented in: Engineering Field Manual for Conservation ?r-acc i: as . U.S. Department of Agriculture, Soil Conservation Service. April, 1975.33 If the soil is coarse (either sand or gravel) but has a fines content of from 12 to 50 percent, the behavior characteristics -* :u,« portion smaiier than the J/4Q sieve will -iic^rnii.ia *.ne secondary characteristics of the material. If this portion of the material is clayey, the material is coarse grained with clayey fines. If not, it is coarse grained with silty fines. To determine whether the material is classed as clay or silt, the plastic limit and liquid limit are measured. A Plasticity Chart, Figure 9.2.~ from Cernica (1982)^4, is made with che LL as the abscissa-and ?I as the ordinata. A line ------- 50 For ciauilnahon 01 iiiK-jrjmc soils 4nU nntr tr4t.tKm ut >.o.irsv Allerrwrp lipnn pludinj in h.i irca are ^orOrrlinc dauiiujno requiring ui£ ot dual *v tnbols Lqullion ul ,1 lints '0 -K) 50 6"0 LiQuid iimii LL 90 100 CH Inorganic clays of high plascicity, fat clays CL Inorganic clays ot Low co medium plasticity, gravelly clays, sandy clays, siity clays. Lean :.jvs MH Inorganic silts, aicacaoua or diacomacac-us fine sands or silts, elastic silcS ML Inorganic silts, very fine sands, rock r.our, silty or ciav«y fine sands OH Organic clays of nedium co high plasticity OL Organic silts and organic silcy clays jf .ow plasticity Figure 9.2.7. Casagrande's plasticity chart showing several representative soil types. Source: Cernica (1982), Reference 34. 9-44 ------- Shear strangch j- jCii leoenas on "vo a iercencj, ;rj.c:ion ana cohesion. rriccion is the resistance to sliding of one block of nonplastic soil against another. The friction in soil is complicated by sucn factors as the irregulaCiry of the planes, interlocking of ^pposit.-! particles, ana size and shape of tne son grains. Cohesion is the result of the tnagnetic-1ike attraction of particles that manifests itself as the plasticity and stickiness of soils. It resists one particle of soil sliding on another, but cohesion resistance does not increase with increased load. Both friction and cohesion of soils increase with increased density. Resistance to internal erosion or piping is correlated with resistance to surface erosion. Soils vith a si?h jnsc^r^ibiiicy Jj jiieac erosion also have a hign piping pocential ana, therefore, are critical to earth structure safety. In contrast, soils with a low susceptibility to surface erosion such as the more plastic soils do not present an internal erosion problem. Cracking may be caused by dewatering of a soil. As the soil dries, it shrinks and develops cracks. The finest materials hav« the highest cracking potential. Plasticity is only an indirect indicator of cracking potential because higher plasticity leans finer .-aacanal. If nonplastic materials have the same grain size as plastic materials their cracking potential is essentially equal. Cracking due to movement of embankments is a result of both the amount of movement and the deformability of "-he material. Deformabilicy of embankments is a result of both the olasticity of the aiaterial and the water content at which the embankment is built. Generally, the lower the water content when compacted, the more brittle the embankment and Che higher the cracking potential. Permeability depends on both the size and volume of pores in a soil. Hence, it increases as grain size increases and decreases as density increases. Compressibility of a soil is a measure of decrease in volume when subjected to load. Compressibility depends on the volume of voids in the soil, and increases with decreasing density. The amount of settlement that will occur in a soil depends on its compressibility and on the magnitude of the load to be placed on it. Because of grain-to-grain contacts, coarse grained soils may be nearly incompressible under static loads but may settle from shock or vibration. The finer grained soils are susceptible to settlement if dewatered. Highly plastic soils may swell under low loads if moisture content increases. The swelling capacity may be estimated from the plasticity index of a soil. Soils with a plasticity index of more than 20 usually have a medium to high swell potential; those with a plasticity index more than 35 normally fall in the very high swell category. The strength of soils after swelling is greatly reduced. 9-45 ------- Upon drying from saturation to the shrinkage limit, soils with a low shrinkage Limit will shrink more than those with a high shrinkage limit. If possible, the placement of soils with a high shrink-swell potential should be restricted to zones where moisture content will remain fairly constant. • The ultimate bearing capacity of a soil is the average load per unit area rsquirad to produce failure by rupture of a supporting soil mass. Bearing capacity is important in evaluating the ability of the foundation to successfully support the liner, wastes, and cover materials at closure. 1_C T 3t! r' -' -~ ~— TV ,-. ,,-• ' ,,,-r- _, , jppjL*v.^uC wxi.i. conduct an engineering analysis based on laboratory or field testing of soils. Laboratory tests are necessary to determine soil index properties and include: Tesj: Grain Size Analysis ASTM Designation 0421,' 0422 D2217 D1L40 Purpose of Test Soil classification Atterberg Limits Water Content Compaction Unconfined Compressive Strength Triaxial Compress ive Strength Direct Shear D423 0424 D427 D2217 D2216, 02974 D698 D1557 02166 D2850 D3080 Determine the plasticity and shrink-swell characteristics. Assess sensitivity to changes in moisture content. Results may be considered as part of all engineering analyses. Measure water content Identify the characteristic moisture/density relationship for the soil. Measure cohesive soil shear strength Measure characteristic stress- strain relationship for soil Measure soil shear resistance In-s itu or field tests that the applicant may conduct during performance of borings or excavation of test pits and trenches include: 9-46 ------- ASTM Des igna Standard Penetration Vane Shear Pressuremetar Saturated Hydraulic Conductivity Plate Load Cone Penetration D1586 D2573 .-•urpose or iest Measure relative soil density; indicaca bearing capacity Measure shear strength of cohesive soils; sensitivity to remolding Not currently Measure stress-strain, Young's specified Modulus, cohesive strength Several - See Measure saturated hydraulic Appendix to RCRA Technical Guidance Documents D1194 Measure bearing capacity Soil classification, strength, compressibility, and bearing capacity. Foundation Analysis—The permit applicant must conduct a settlement analysis to estimate primary and secondary consolidation, creep, and differential settlement. Consolidation occurs when a load is imposed on a highly compressible porous saturated soil (e.g., clay) forcing excess water to drain from the soil. Primary consolidation is governed by soil permeability which controls the flow of draining water. Secondary consolidation is believed to result from slippage between gra is bonded by adsorbed water. Settlement due to consolidation can be calculated from the relationships illustrated in Figure 9.2.8, a phase diagram from Holtz (1981). T VOIDS SOLIDS I 4- 1 VOIDS jsouosK AH Figure 9.2.8. Calculation of settlement from the phase diagram. Source: Reference 35. 9-47 ------- At Che initial time condition (middle of figure), the volume of solids, V is equal to 1 (and remains 1 at the end of consolidation). The vcl-irae of voids changes from the initial value, eQ) by the amount e, to ef, the final volume of voids. It can be demonstrated that the settlement, S, is equal to: H = € H (8) 1 > e o v o The stresses, changes in void ratio, percentage of settlement, or amount of settlement must be computed for each compressible stratum. The sum of the estimated settlements for each stratum is equal to the total settlement for the soil dapch of concern. The confined compressibility test is the laboratory method used to evaluate consolidation.31 Creep is a term used to define deformation of clay soils in response to shearing stress. The creep strength identifies the sheering stress which will result in continuous progressive deformation. Shear tests should be used to evaluate the potential for creep. Differential settlement in cohesive soil can be attributed to consolidation as discussed above. Differential settlement of cohesive soils can also result from distortion in which a load on the soil causes the soil mass to deflect downward and bulge laterally, as shown in Figure 9.2.9. The shape of the curve can be computed by methods of elasticity.36 differential settlement of cohesionless soils by distortion results in a downward deflection curve as shown in "Figure 9.2.10. The soil near the edge of the loaded area is unconfinea laterally and is pushed aside by the lateral pressure of the sand nearer the center of the area. Methods for calculating the slope of the settlement curve are not available. However, experiments show that the wider the loaded area, the flatter the curve at the center. Cohesionless soils are also susceptible to excessive settlement if the soil is subject to vibrations. The greatest settlement will occur from a pulsating frequency between 500 and 2500 impulses per minute.31 The frequency of unbalanced forces in many types of machinery, such as steam turbines, diesel power trim units, and air and gas compressors lie within this range. Ordinarily the settlement will be small if the relative density is greater than 70 percent, but if the vibration is severe, settlement can occur until the relative density is nearly 90 percent.36 The potential for settlement should be carefully evaluated using density determination techniques previously described in this section. Vibration compaction techniques can be used during installation to minimize the potential for later settlement during facility operation. Other causes of settlement include shrinkage due to drying, consolidation due to lowering of the water table, structural collapse, erosion into openings and cavities, biochemical and chemical attack, mass collapse of drainage systems, and expansion due to frost and clay expansion. Predictive models for 9-48 ------- Figure 9.2.9. Profile of distortion settlement of a uniformly loaded flexible foundation on an elastic solid such as a saturated clay. Source: Reference 36. o. Narrow load 6. Wide load Figure 9.2.10. Profile of distortion settlement of a uniformly loaded flexible foundation on a cohesionless soil. Source: Reference 36. 9-49 ------- ng cne amount of iat:lament are generally unavaiiaole. However, standard foundation and geocachnical analyses can be used to estimate Che suscepcibility to settlement from such causes. The technical adequacy worksheet for evaluating the suitability of the liner system design is presented in Figure 9.2.11. The worksheet should be completed before addressing the technical adequacy checklist in subsection 9.9. 9.2.1.4 Draft Permit Preparation— Condition B.I of Permit Module XV addresses design, construction and installation of the liner system for new portions of the landfill. The condition is implemented through reference to a permit attachment that includes plans and specifications for the proposed liner system. The submitted application information :an be insercaa as cne permit condition actacnraent provided the applicant has adequately addressed the following: • Hydrologic data • Construction materials • Liner cnemical properties » Physical strength and thickness • Foundation analysis • Liner systam integrity considerations The attachment should demonstrate that Che wastes will be prevented from entering the liner throughout the active tifa of the facility. 9.2.1.5 References— 1. U.S. Environmental Protection Agency. Permit Applicants' Guidance Manual for Hazardous Waste Land Storage, Treatment, and Disposal Facilities. Office of Solid Waste, Washington, DC. Volume I. 1983, 2. U.S. Environmental Protection Agency. RCRA Technical Guidance Document. Landfill Design: Liner Systems and Final Cover. July 1982. 3. U.S. Environmental Protection Agency. Lining of Waste Impoundment and Disposal Facilities. Prepared by Matrecon for the U.S. EPA. Second Edicion. SW-870. September 1982. 4. Chow, V. T. Handbook of Applied Hydrology. McGraw-Hill, New York. 1964. 5. Bouwer, H. Ground Water Hydrology. McGraw-Hill, New York. 1978. 9-50 ------- EVALUATION OF LINER SYSTEMS Liner Location Versus Water Tabls Slavation Has this part of the applicant's submittal been reviewed and evaluated? Yes No Dace Did the applicant address: • Seasonal variation in the water table height? Yes No • Maximum water ^abl* haign;? Yes No • Liner location in relation to water table? Yes No Were onsite monitoring wells used to identify ground water levels? Yes No Was water table information obtained from state and local __^_ agencies? Yes No and, if so: How do these data compare with onsite monitoring data? What is the minimum distance expected between the liner and the water table? Does this distance insure that damage will not occur through uplift? Yes No .Figure 9.2.11. Worksheet for evaluating design of liner systems. 9-51 ------- Synchecic Liner/Wasce Compatibility Was EPA Test Method 9090 used Co evaluate comoacib il i:-/"1 Yes No What steps were taken to insure representativeness of the waste(s) and leachate(s) tested? Were the measures adequate? Yes No What lab(s) performed the test(s)? Was liner manufacturer compatibility daca used in place of laboratory test data? Yes No If yes, ia the landfill intended for only one type of waste? Yes N'o Was liner manufacturer corapatibility data compared co laboratory test results? Yes No Was compatibility evaluated in terras of: • Tear resistance? Yes No • Puncture resistance? _____ Yes No • Tensile strength? Yes No « Hardness? Yas No • Elongation? Yes No Describe any differences in liner properties listed above resulting from exposure to waste or leachate. Figure 9.2.11 (continued) 9-52 ------- If deterioration is indicated, che liner should be judged inadequate unless the applicant can demonstrate chat Che decarioration w'.ll r.ct affect liner integrity. Synthetic Liner Permeability Did the applicant address synthetic liner permeability? _____ Yes No What laboratory test procedures and/or data sources were used? ______________ Describe any properties identified that indicate susceptibility to waste or leachate penetration (e.g., changes in volatile or extractable liner materials, swelling, changes in weight, etc.). Are data supplied by Che applicant consistent with permeability data contained in SW-370? Yes No Figure 9.2.11 (continued) 9-53 ------- Resistance of Synchecic Liners to Pressure Gradients Strssjcs, and Environmental Factors During Installation and Operation Is the liner at least 30 mils chick? Yes No Is che liner protected from physical failure by at lease 6 inches of bedding material above and below the liner? Yes No Did che applicant document that the bedding material is no coarser than sand? Yes No Were herbicides proposed for use to prevent possible punccure from plant growth? Yes No Does che liner design allow for shrinkage and expansion due Co freeze-chaw and wet-dry cracking? Yes No Did che applicant address liner abrasion vear? Yes No Does che liner material contain a bactericide to prevent microbial attack? Yes No Did che applicant address liner exposure co sunlight or ultraviolet light? Yes No Are any scaps taken co .ainimize any poterrtially harmful effects of temperature extremes? Yes No Are chere any techniques used to prevent liner abrasion from windblown particles? Yes No Are exposed liner ends securely held in place to prevent wind damage? Yes No Describe any data gaps relating to the questions listed above. Figure 9.2.11 (continued) 9-54 ------- •Foundation Design and Incagri:y Did Che applicant define Che following index properties for liner foundation materials? Yes No • Grain size distribution? Yes No • Atterberg limits (for cohesive soils)? Yes No • Specific gravity? Yes No • Density? Yes No • Moisture content? Yes No Has the applicant addressed Che following engineering properties: • Bearing capacity? Yes ~No" • Shear strength? Yes ~No~ * Cohesion? Yes No • Permeability? Yes No • Compressibility? Yes No Did the foundation analysis provide an adequate evaluation of: • Erosion potential? Yes No • Cracking potential? Yes No • Secondary consolidation? Yes No Figure 9.2.11 (continued) 9-55 ------- « ^rea p' Yes N'cT • Differencial sec clementr Yes No Did Che applicant address: « Solution cavity potential? Yes " ~~No~ • Sinkhole potential? Yes No • Uplift potential? Yes No • Liquefaction potential? Yes No Did che applicant's foundation analysis include an estimation of: • Consolidation? Yes No • Creep? Yes No • Differential settlement? Yes No Describe any data inadequacies relating to the questions listed above. Figure 9.2.11 (continued) 9-56 ------- -i. ~raa"3, '.. '-.. J.HC .'. .-.. .rherry- 3* cur. ^ -'^ le r. ."ranci.ce naii., New Jersey. 1979. 7. Latter Correspondence from Mr, Henry Haxc 'Matrecori) co :ir. Arthur Day (2PA Office of Solid Waste). February 13, 1983. 8. Lee, J,, Selecting Membrane Pond Liners, Pollution Engineering, January, 1974. 9. Kumar, J. , and J. A. Jedlicka. Selecting and Inscailing Synthetic Pond-Linings. Chemical Engineering, February 5, 1973. 10. Kearney Management Consultants. Chemical Property Data and Liner/Waste Cotaoatibilitv Data- 'rc-'.: A-sslgm-enc .iOG-Cu6, £?A Contract »------- 19. Haxo, H. £. , Jr. Preservation on Synthetic .ler.brane uiners. Conducted at the U.S. EPA Training Projr-.n: ~-r ?.I?.A ?er-nic Applicants. £?A Region VI. Dallas, TX. April 2S, 1983. 20. Gascon, L. (Gascon Containment: Co., El Dorado, KA) , and 5. Wright (Wright and Kohli Construction, Houston, IX). Membrane Liner Installation: Criteria and Techniques. Presented at the Watersaver Company, Inc. Flexible Membrane Lin<2j Seminar. oraintree, MA. Marcn lo, 1983. 21. Correspondence from J. P. Stevens Company, Inc., to Wacersaver Company. September 1973. 22. Leet, L. D. and S. Judson. Physical Geology. 4th Edition. Prentice-Hall, Inc. Englewood Cliffs, NJ. 1971. 23. Thornbury, W. ?. Regional Geomorphology of the United States. John Wiley and Sons, Inc., Mew York, June 1967. 24. Thornbury, W. ?. Principles of Geomorphology. John Wiley and Sons, Inc., Mew York, 1966. 25. Earth Manual, U.S. Department of Interior, U.S. Government Printing Office, Washington, D.C., 1974. 26. Zohdy, et al. Aoplication of Surface Geopnysics to Groundwater Investigations, U.S. Geological Survey Techniques of Water Resources Investigations. Book 2, Chapter D.I, 1974. 27. Roux. Electrical Resistivity Evaluations at Solid Waste Disposal Facilities. SW-729. U.S. Environmental Protection Agency, 1978. 28. Telford, et al. Applied Geophysics, Cambridge University Press, Cambridge, 1977. 29. Dobrin. Introduction co Geophysical Prospecting, McGraw-Hill, Inc., New York, 1976. 30. Keys and McCary. Application of Borehole Geophysics to Water Resource Investigations, U.S. Geophysical Survey Techniques of Water Resource Investigations. Book 2, Chapter E.I, 1971. 31. Terzaghi, K. and R. B. Peck. Soil Mechanics in Engineering Practice. Second Edition. John Wiley & Sons, Inc. Sew York. 1967. 32. Scott, R. F. Principles of Soil Mechanics. Addison-Wesley Publishing Company, Inc. Reading, MA. 1963. 33. Engineering Field Manual for Conservation Practices. U.S. Department of Agriculture, Soil Conservation Service, April 1975. 9-58 ------- 34 35. Arnica, John N. Winston. 1982. Gsocechnical Engineering. Hole Rin^ ^ , - ' -- - ^*- noic' tUnehart and 36. Sowers, G. B. Foundations. York. 1970. 9-59 ------- 9.2.2 Leachate Collection and Removal Sv;cam 9-2.2.1 The Federal Requirement — Paragraph(b) of §270.21 requires thac Che applicant's plans and/or engineering report on landfill design, construction, operation, and maintenance must address: "(1) The ... leachate collection and removal .system ... ' The landfill standards of Part 264 scace that: "(a) A landfill (excaot for an ^xiseinz; ;.orc~on 31 a landfill) muse nave: (1) .... (2) A leachate collection and removal system immediately above the liner that is designed, constructed, maintained, and operated to collect and remove leachate from the landfill. The Regional Administrator will specify design and operating conditions In trie permit to ensure chat the Leachate depth over the liner does not exceed 30 ~m (one foot). The laachate collection and removal system mu s t be: (i) Constructed of materials that are: (A) Chemically resistant to the waste managed in the landfill and the leachate expected to be generated; and (3) Of sufficient strength and thickness co prevent collapse under tne pressures exerted by overlying wastes, waste cover materials, and by any equipment used at the landfill; and (ii) Designed and operated to functir- without clogging through the scneduied closure of the- landfill." 9.2.2.2 Summary of Necessary Application Information— The Part B Manual^- instructs the applicant to suomit engineering reports and detailed drawings to support the proposed design of the leachate collection and removal system. Specific information requested includes: (a) System design and maceriala of construction • detailed drawings; facility layout, slope, spacing, design of sumps • type of collection pipes '• calculations illustrating maintenance of less than I foot of leachace head except during storm periods. (b) Chemical resistance • compatibility of pipes and sumps with leachate and wastes 9-60 ------- !,c) Strengtn and tnickness • demonstrate chat the system can withstand incurred live and dead Loads, accounting for pipe perforations or slots. • account for pipe deflection, buckling, and compression (d) Prevention of clogging • engineering design calculations to assure functioning without clogging through closure. 9.2.2.3 Guidance on Evaluating Aoolication Tr.iormatijn— figure 9.i.i2 is a Clow chare which indicates the applicability of the Part 264 requirements to laachate collection and removal systems. The guidance which follows on evaluating the technical adequacy of Che applicant's proposed leachate collection system addresses the major regulatory requirements identified in the flow chart. Subsection 9.2.3 provides guidance on evaluating an sapLicant's submittal in cases where an exemption from che Leachate collection system requirement is sought. At Least four aspects of leachate collection system design and operation will be addressed by che applicant and should be rigorously reviewed by the permit writer. These include: • System design and materials of construction design drawings pipe materials , calculation of Leachate head above the bottom liner • chemical resistance of system materials • strength and thickness of materials, and • leachate collection system clogging Figure 9.2.13 presents a summary of technical topics addressed in the remainder of this section to assist the permit reviewer in evaluating the applicant's proposed design. 9.2.2.3.1 Leachate Collection System Design and Materials of Construction-- System Design The applicant should have submitted engineering drawings illustrating the full areal extent of the leachate collection system and profiles of all piping and appurtenant structures such as manholes or cleanouts. The inside diameter 9-61 ------- 71 3 73 >-, •Jl U 1. o *J V) 3 3 u •*4 3 O" a u ~3- vO U -5 .a ^ •j u 3 £0 9-62 ------- .EACHATE ;CL.£C7;CN 3YSTE.1 DESIGN AND MATERIALS OF CONSTRUCTION SYSTEM MATERIALS STRENGTH AND THICKNESS JF SYSTEM MATERIALS LEACHATE SYSTEM CLOGGING MECHAN/SMS • PHYSICAL • CHEMICAL/BIOCHEMICAL • BIOLOGICAL RECOMMENDED TECHNIQUES • PLANS AND PROFIL£ • PIPE MATERIALS * CALCl'L.-TiC.V :f ,£AC,-iArE DEPTH ABOVE LINER CuNSiOESEO • PLASTIC • CLAY • CONCRETE * ASBESTOS-CEMENT ASPECTS OF THE OETcRMIMAT!ON • COMPRESSION • DEFLECTION • SUCKLING PREVENTION • SIZING/SELECTION OF FILTER AND DRAINAGE MEDIA • SELECTION OF PIPE PERFORATION OR SLOT SIZE • MONITORING AND INSPECTION CORRECTION MECHANICAL OR CH£MIC- CLEANING Figure 9.2.13. Evaluation of leachate collection and removal system design. 9-63 ------- of che pipe snould be indicated along with slot or perfo'-acicn size. These plans and orociles should be drawn co scale, such as I" - 2C' or -C', so cnac che details of Che design are clear. The profiles should indicate che location, depth, and thickness of foundation, subgrade, filter, and drainage layers, and the orientation of collection pipes with respect co che synthetic liner. The slope of all piping should be indicated in terms of percent slope (rise/run x 100) or inches of rise or fall for each foot of pipe length. References 2 (Metcalf and Eddy) and 3 (ASCE Manual of Practice 37) provide detailed information on design of subsurface piped drainage systems. The spacing of all pipe laterals and interceptor piping should be visible from the plans and/or profile drawings, wnichever orovides a -ord straightforward view. The verti-^i sxtsnt of wastes and soils to be placed aoove the collection system should be indicated on the profile drawings. Calculations should be provided that illustrate that the flow capacity of the collection system is capable of handling expected leachate flows over the life of the facility. Appendix V of the Liner TRD (SW-870)4 presents a method of designing or evaluating che capacity of leachate collection systems. Selection of the design leachate flow rate snould demonstrate consistency wich che storm event selected for designing the run-off collection system facilities. Pipe Materials The selected pipe materials should be indicated, preferably on the plans and drawings. Possible materials inclTKle clay, PVC and other plastics, asbestos-cement, concrete, and others. The pipe class and wall thickness and bedding materials should be indicated so that pipe strength can be evaluated. If additives or special treatments or cpacings will be used in pipe manufacture, these factors should als<3 be specified. Leachate Depth Above the Bottom Liner The S.CRA Technical Guidance Document for landfills^ expresses the Agency's perception that "a [leachana collacrion system] design incorporating 4-inch diameter cues on 50 to 200 foot (15 to 60 meter) centers will effectively minimize head on the liner system." However, the guidance manual recommends that the owner/operator incorporate design calculations in his application to demonstrate that no more than 1 foot of head will exist above the liner at any time, except during storm periods. The EPA TRD (SW-868), Hydrologic Simulation On Solid Waste Disposal Sites,6 provides a procedure for estimating the amount of moisture percolation through different types of landfill covers and, therefore, is only applicable for determining leachate depths after landfill closure. The EPA TRD (SW-869),? Landfill and Surface Impoundment Performance Evaluation, provides an analytical technique for determining the flow capacity of sand or gravel drainage layers. 9-64 ------- -W-oo?—."toore :W--f one torn slope.7 Clearly, bo t ton slope iws little influence at slope greater than 5 or 6 percent, but such slopes are expected to be 9-65 ------- 3 =L£ACHATE (LIQUID) IMPINGEMENT RATE ' * * I I I i « DRAIN LAY^R - LINER SLOPE I * M i I I I ) !i =L£ACHATE DEPTH I L = DISTANCE BETWEEN LATERALS Figure 9.2.14. Alternative drainage system orientations considered in solving for maximum leachate depth. Source: Reference 7. 9-66 ------- 0.10 0.08 0.08 h 0.04 0.02 0.4 Figure 9.2.15. Relationship between h max /L and c = e/k Source: Reference 7. 9-67 ------- uncommon. At slopes expected in practice of I to 2 percent, h^ax/Tu will be sensitive to minor changes in slope and will increase as the impingement rate, a, increases or as the permeability, kg, decreases. In applying these equations, SW-869 assumes steady state liquid impingement over 1 year's time. The permit reviewer should recognize that the worst case may be represented by estimating h.,jax attendant with a rare storm event (say 25 or 50 years'1 ovsr a 24-hour period. The applicant should estimate shore term leachate depths expected in such instances so that the adequacy of the system design can be better evaluated. If unacceptably high leachace depths are shown to occur in such instances, the oermit reviewer should request resolution D£ the prooLera, possibly by requesting installation of a more permeable drainage layer or closer positioning of the lateral drainage pipes. The permit reviewer should also closely consider the applicant's assumptions regarding the fraction of rainfall which infiltrates to the drainage layer or rainfall losses attributed to evapotranspiration. Underestimation of tne leachate production rate (e) could result from the following: • Failure to account for drainage of sludges placed in the facility. • Poor maintenance and operation of the run-on and run-off control system during the active phase of operation. « Failure of the impervious cap after closure. In addition, the impingement rate couW be altered locally (in one cell for example) by the propagation of channel-s through the waste materials which might deliver the leachate to one area of the leachate collection system and overload it. Since observation of hydrostatic head is the criterion by which clogging of the collection system is determined, it is critical that these factors ara accurately assessed in the initial design phase. HELP - The Hydrologic Evaluation of Landfill Performance Model—The following discussion is based on two documents which present documentation and a user's guide for the HELP model. Both are currently in draft form and were prepared at the U.S. Army Corps of Engineers Waterways Experiment Station by: • Walski, T. M., et al. - User Guide for the HELP Model^ • Schroeder, P. R., et al. - Documentation for the HELP Model9 The presentation provided here is intended as an introduction and overview only. If the permit applicant has used the HELP model or if the application reviewer chooses to use it as an independent check on the applicant's calculations, then it is strongly recommended that the permit application reviewer obtain copies of the User Guide and the Documentation. 9-68 ------- The -iyarcicgic {valuation ?' .ar.zzi*'. TT r :^ rrr.ar.cu , .i^Lr; computer Program is a quas i-two-dimens ional hydrologic model or water movement across. 'Inco. chrough, and out of landfills. The "noaal uses c i imatoiogic, soil, and landfill design data and incorporates a solution technique wr.icn accounts for the effects of surface storage, run-off, infiltration, percolation, evapocranspiration, soil moisture storage, and lateral drainage. The program estimates run-off drainage and leachate expected to result from a vide variety of landfill designs, including open, partially open, and closed landfill cells. Most importantly, in consideration of this topic, the model can be used to estimate the buildup of leachaca .ibove ;he bottom iiner of trie landfill. The following discussion is from Reference 9: "The HELP model performs a sequential daily analysis to determine run-off, evapotransoiration, ^rcoiation, iau ".jceral drainage cor the landfill ^cap, cell, leachate collection system, and liner) and obtain daily, monthly, and annual water budgets. The model does not account for lateral inflow and surface run-on. "The HELP model requires cliraatologic data, soil characteristics, and design specifications to perform the analysis. Climatologic input data consist of daily precipitation values, mean monthly temperatures, Tiean monthly solar radiation values, leaf area indices, root zone or evaporative ~one iepths, and mincer cover factors. Soil characteristics include porosity, field capacity, wilting point, hydraulic conductivity, water transmissivity evaporation coefficient and Soil Conservation Service (SCS) run-off curve number for antecedent moisture condition II. Design specifications consist of the number of layers and their descriptions including type, thickness, slope, and maximum lateral distance to a drain, if applicable, ana whether syntnecic merabrances are to be used in the cover and/or liner. The HELP model maintains five years of default climatologic dat-a for 102 cities throughout che United States. Any of seven default options for vegetation may be specified. The model also stores default soil characteristics for 21 soil types for use when measurements or site specific estimates are not available. "The model is ordinarily used in the conversational mode. This enables users to interact directly with the program and receive output through the terminal immediately. Use of the model does not require prior experience with comouter programming; "hough, some experience would assist the user in logging on the computer system and manipulating data files. The model can also be run in the batch mode; however, this requires more computer programming experience and extreme care in preparation of input data files." Figure 9.2.16 illustrates the landfill layers and profiles that can be considered in applying HELP.9 in Che current case, the evaluation is concerned with open, active landfill portions. If the topmost layer is identified as a waste layer, the program assumes that the landfill Is open. For this case, an SCS run-off curve number* must be specified as well as the fraction of the potential surface run-off that is collected and removed from the landfill surface. *The SCS method for calculating run-off is discussed in subsection 9.2.5. 9-69 ------- PRECIPITATION EVAPOTRANSPtRATION r- VEGETATION f RUNOFF iNFiLTRATION VEGETATIVE LAYER LATERAL DRAINAGE LAYER LATERAL DRAINAGE (FROM COVER) BARRIER SOIL LAYER (FROM BASE OF COVER) or a. 09 I LATERAL DRAINAGE LAYER LATERAL DRAINAGE (FROM 3ASE OF LANDFILL) BARRIER SOIL LAYER OflAJN MAXIMUM DRAINAGE DISTANCE a: UJ PERCOLATION (FROM BASE Of LANDFILL) Figure 9.2.16. Hazardous wasce landfill profile simulated using HELP, Source: Reference 9. 9-70 ------- T'-.a -iEL? -noael perrorns =. i3i_/ - equfep.t iai. analysis co compute ail output :at3. As nany as 9 soil or waste Layers can be simulated chroujr.out a :i~e period from 2 co 20 years. The noaei incorporates a lateral ctrainaee sc".^.c-, which was developed co cover a vide range cf Landfill jcctom cesign specifications, namely, slopes from 0 co 10 percent, drainage layer lengths from 25 to 200 feet, and SCS run-off curve numbers from 20 to 100 (see subsection 9.2.4.3.2). The liner leakage fraction and Che fraction of run-off from open sites can vary from 0 to 1. Optional forms of input and output are possible using the HELP program. Input climatological and soil data can be formulated by the user or default values can be used. Leachate system design data must be specified by the program user. Output can be obtained in the form of daily values or monthly totals, each with a summary of the simulation. To obtain results indicating the head of leachate above the bottom liner, output must be formulated in terms of daily values. The accompanying simulation summary prints annual totals, monthly and annual averages, and peak daily values. In summary, the HELP program can be used co estimate the depth of leachace dbove the bottom liner for a variety of landfill designs, time averages, and storm events. The results may be used to compare designs or to design leachate drainage ana collection facilities. Review of the two referenced documents is recommended. Assistance in running Che program can be received from the developers at Che Waterways Experiment Station. They can be reached by commercial telephone at (601) 634-3710 or via the FTS system at 542-3710. The DRAINFIL Model—The DRAINFIL model is a landfill water balance technique developed by Wayne Skaggs at North Carolina State University.10 Calculations conducted by EPA illustrate close comparison in results between DRAINFIL and HELP.11 ORAINFIL can be used co determine leachate depth above the bottom liner of the landfill cell. 9.2.2.3.2 Chemical Resistance of System Materials—The components of the leachate collection system which snould be evaluted for their resistance to chemicals in the landfill are the bottom liner and drainage tiles or pipes. The chemical resistance of liners is discussed in subsection 9.2.1.3. Chemical resistance of drainage conduit is discussed below. The following types of pipe are commercially available for collection system drain construction.12 • vitrified clay Clay drain tile Clay pipe (standard and extra-strength perforated) 9-71 ------- concrete (bell and spigot or coneue ^nd groove join Perforated concrete Asbestos -cement Perforated sealed joint Plastic Acrylonitrile-Butadiene-Styrene (ABS) SCyrene-rubber (SR) Polyethylene (PE), straight wall or corrugated Vitrified Clay Vitrified clay cila or pipe is an excellent choice for leachata collection systems due co its resistance to chemical attack. Vitrified clay is resistant to internal and external attack from gases, solvents, and alkalies. This type of pipe has demonstrated long service life in both sewage conveyance and drainage collection applications. It should be noted, however, that some mineral components of clay pipe may be attacked under acid conditions. To evaluate resistance to" acid attack, representative sample of pipe material could be tested by the ajrplicant using a method such as :he acid-soluble extraction zachnique specified by ASTM 301-79. Asbestos-Cement and Concrete Pipes^ Asbestos-cement and concrete pipes are susceptible to corrosion under acid conditions. Although some corrosion is acceptable, excessive acidity can result in premature failure of the pipe. There are three oossible uechoas of avoiding corrosion failure when asbestos-cement or concrete pipe are planned for use: • Alter the composition of Che pipe materials • Apply acid resistant barriers • Increase the wall thickness. Type II Portland cement is superior Co Type I in resisting sulfate attack in sewer systems* However, the type of cement does not seem to be a factor in the resistance of concrete pipe to acid attack. For concrete pipe, extra wall thickness can be used to increase pipe life under acidic conditions. Another method is to use limestone or dolomite aggregate co increase Che amount of acid soluble material in Che concrete, chereby prolonging Che life of the pipe in corrosive environments. The 9-72 ------- "rrc-s-on rtts .'- -oi^mice or ii:nescone aggregate can 3e exoected co be approximately one-fifth as great as granite aggregate. ">a ^rac: ;.:j; us ing li.f.es ton» ^r dolomite aggregate in pipe varies with the acid if -f - ~ leachate ind The ^.viil^b ili^y ana alrcaj. j.nicy or cne aggregate. Protective barriers have been used on concrete and asbestos-cement pipe with varying success. Available coating and lining materials include bituminous and coal tar products, vinyl and epoxy resins, and paints. The linings must be applied such that the pipes are comolecelv laalad. '-.ny _,:ia seepage or diff^j.^ri chrougn cne lining ac any point, even through a pinhole, will react with the cement, thereby destroying the effectiveness of the liner. In leachace collection systems designed with cement and concrete pipe, linings may have lo be applied to both the inner and outer surfaces. Plastic Pipel3,14 Plastic pipe is well established in the drainage industry primarily due to low cost and ease of installation. In addition, quality control of joint construction is usually better than for other materials. In general, plastics have excellent Tesistance to veak nineral acids and are unaffected by inorganic salt solutions. Since olascics do aot corrode in Che electrochemical sense, they are not affected by slight changes in pri, tiinor inpurities, or oxygen content. Table 9.2.7, from Reference 13, identifies cne chemical resistance of ABS, PVC, and PE to selected chemicals. Aeryionitrila butadiene styrene polymers (ABS) have good resistance to weak acids but are not satisfactory wi-ch oxidizing acids. They should not be •:sad vich j.i Icrinacea nyarocarbons but nave good resistance to aliphatic hydrocarbons. Polyvinyl chlorides have excellent resistance to non-oxidizing and weak acids, but should not be used with oxidizing acids. Resistance is also good to weak and strong alkaline materials. PVC has poor resistance to chlorinated hydrocarbons. Styrene rubber is resistant to attack by ozone, sunlight, oils, gasoline, and aromatic and halogenatad solvents. Styrene rubber -an 2e attackea by oenzene and ketones. Polyethylene is the lowest cost plastic commercially available. Mechanical properties are relatively poor and such pipe must be fully supported. Carbon-filled grades are the most resistant to sunlight and weathering. Polyethylene has excellent resistance to acids ana bases. However, ic is readily attacked by aromatics and derivatives), alcohols, ketones, and hydrocarbons. 9.2.2.3.3 Strength and Thickness of Leachate Collection System Materials—The leachate collection system design must recognize that the drainage pipe may be the weakest structural component of the overall system. Therefore, materials selection and wall thickness design must account for expected dead and live loads above the pipe. 9-73 ------- TABLE 9.2.7. CHEMICAL RESISTANCE OF PLASTICS USED FOR PIPING3 Source: Reference 13. Polypropylene polyethylene 10% H2S04 50% H2S04 10% HC1 10% HN03 10% Acetic 102 NaOH 50% NaOH NH^OH NaCl FeCl3 CuSC4 NH4H03 Wee H2S Wet C12 Wet S02 Gasoline Benzene CC14 Acetone Alcohol Excellent Excellent Excellent Good Excellent Excellent Excellent Excellent Excellent Excellent Excellent Excellent Excellent Excellent Excellent Excellent Poor Poor Poor Excellent Excellent Excellent Excellent Excellent Excellent Good Excellent Excellent Excellent Excellent Excellent Excellent Excellent Good Excellent Excellent Poor Fair Poor Excellent Excellent Excellent Excellent Excellent Sxcaiiant Excellent Excellent Excellent Excellent Excellent Excellent Excellent Excellent Poor Excellent Poor Poor Poor Poor Poor aRatings are for long-term exposures at ambient temperatures (less than 1003F) ^Acrylonitrile butadiene scyrene polymer. cPolyvinyl chloride, type I. 9-74 ------- i?A TRD ^W-"?''"1- -r-r'-^s i : :-.sr 2--:" = -. v= :. ;; --j.^r. criteria :or ,„ ..-ecc-_jn p-ps=s -onsiaering ^oads :rom overlying waste fill. The following discussion is based on chat rererenca .-SC£ '-'3? 3",-' inzortiat ion presented .a 'Clogging of Leacnate Colleccion Systems 'J-ed \^ Ja:-zri3-J3 <'dsc = -aru 7i.3posai Facilities',-^ ;ne Clay Pipe Zn^n^ering Manual,1-0 and manufacturer's liceracure.^' > ^ In the analysis of structural stability under an imposed Loading, the pipe is considered to be either rigid or flexible. Examples of rigid oipe include clay and concrete. Plastic and fiber glzsz *>:& examples of flexiole pipe construction material. For rigid, pipe, corapressive strength is tne overriding design loading criterion. Deflection and buckling of pipe walls are more important considerations for flexible pipe. Ijivia ire gan------- Soil llnvr WO«f« (w) S« • a) T«£NCH CONDITION wa»i« fill a 1/2 s. 21/2 9, • 3cssri! 6) PROJECTING CONDITION Figure 9.2.17. Pipe installacion - conditions and loading. Source: Reference 4 (SW-870) 9-76 ------- TABLE 9.2.8. TRANSITION WIDTHS FOR 6-INCH AND 8-INCH PIPE INSTALLED IN SAND AND GRAVEL --•orh , r ".c:-.i:.., f 1~] 5 6 a '0 L2 14 16 '.3 20 22 24 26 28 30 Transition 6-inch pipe 1.59 1.69 1.86 2.02 2.17 2.31 2.44 2.56 2.68 2.80 2.91 3.01 3.12 3.22 widch (ft) 8-inch pipe 1.93 2.03 2.22 2.40 2.56 2.71 2.86 3.00 3,13 3.26 3.38 3.50 3.62 3.73 9-77 ------- -"ere: -V - vertical load per unit length acting on •:.-.» ?;re ::;^ :.-, earth loads ;r. Lb/:C v = unit weignt of earth per unit volume in Lb/ft^ B * Trench width or pipe width, depending on installation conditions, in ft C a Diraensionless coefficient to account for: (1) Ratio of the fill height to the width of the trench or conduit. (2) Shearing forces between the earth prism directlv ^bov? -he -;ra and adjacent orisms. \jy uirection and amount of relative settlement between interior and adjacent earth prisms. Allowable Load for Rigid Pipes Loads must be calculated for either crench or Jroj^cting conditions. Marston'3 formula for calculating loads on rigid oioe in trench -oncutions ,s: W = C. w 3,2 U4) d d 'jhars: '<«' and w are previously defined 3j = Trench vidth ac :he top oJL the pipe in ft C^ - Dimensionless coefficient tnat is a function of tne ratio of fill height to the width of the crenc.n and of the friction coefficient between the Uackfill and :he sides of the trench. Cd is computed as: -2Ku(Z/B,). Cd'^^lK- ^ (15) ^nere: e is the base of natural logarithms K = Rankines ratio of lateral pressure to vertical pressure Z s height of backfill above pipe (see Figure 9.2.17) u * coefficient of friccion between backfill material and sides of the trench In land based nazardous waste management applications, the pipe load is caused by both the waste fill and the trench backfill. (Live loads are discussed later.) These two components of the total vertical pressure are computed separately and then added to obtain the total vertical pressure acting on the pipe. The modified Marston's equation used is: 9-78 ------- wnere: W, B w, and C, are previously defined d d w, * unic weight of waste fill (values range from 45 Co 55 Ib/fc for municipal waste with soil cover) 3 H, * height of waste fill, ft, and -2Ku(2/3) C - a d us Tho cerni C.^s, a Load coefficient, is a function of the ratio of che depth of the trench," Z, to the width of the trench, Bd (see Figure 9.2.17), and che friction between the backfill and the sides of the trench. With che exception of coefficients -K and u, terras used in Equation 15 are identified by the density of che cover materials and by che dimensions of che installation. The coefficients K and u, used in determining Cj and ~,s, are dependent on the type of backfill -.acenaii usea. Typical values of che product Ku are: • 0.19 - granular materials without cohesion • 0.165 - sand and gravel • 0.13 - unsaturated clay • 0.11 - saturated clay • 0.15 - saturated topsoil To expedite the calculation of pipe loads under trench conditions, graphical techniques can be used to determine Cd and Gys. Working graphs for calculating Cd and Cus are provided in Figure 9.2.13 and Figure 9.2.19, respectively. Load can then be determined using the modified Marston equation. Projecting conditions exist whenever the pipe is covered with fill above the ground surface or when the trench width is wider than the "transition width." Under projecting conditions, the load can be calculated using che modified Marston equation by assuming che trench width, Bd, co be equal to the transition width. After calculating the load on the pipe, the next scan is to iacsrmine ;he adequacy of the pipe in bearing che load. rhe anility of rigid pipe to safely resist the calculated load depends on its inherent strength, the distribution of the vertical load, the type of bedding material used, and the lateral pressure acting against the sides of the pipe. Compressive strength is the primary loading design parameter for rigid pipe. 9-79 ------- COEFFICIENT Cd (GRAPH QKJ , rc-> 1-52 345 0-10 0-15 0-200-250-3 0-4 0-50-607 ].0 ,.5 COEFFICIENT Cd (GRAPH ON RIGHTD Curve A—C.-forKH' — 0.19 for jruiubr saiznaLs wiuiout coaesion B—C,«for AV = 0.165 max. for saad and gravel C—C------- 0-02 0-03 0-05 OO7 0-10 LOAD COEFFICIENT, 0-20 0-30 0-50 0-70 1-00 Values of load coefficient CM (trench uniform surcharge) Figure 9.2.19. Projecting condition Source: SW-870. 9-81 - pipe load coefficient. ------- -,:_:ic ,i;e as in .r.r.arsr.c jruo^ing icrangca measured :>y cne three ed^e bearing test (ASTM Method C301). Minimum crus'-.i-g Dreiser: for j:ancari ana d.xcra strengtn perforated and nonperforaced vitrified "lav --.02 13 ;r~'v':..:s-. rablp °.2.° To represent actuai riaia conditions, a 'loaa factor" is used to convert minimum crushing strength to field support strength. The load factor is dependent on the pipe bedding material. Recommended load factor values are (Reference 16 (Clay Pipe Manual)): Class A-l (plain concrete = 2.8 Class A-l (reinforced concrete) = 3.4 Class A-ll (reinforced concrete, p = 0.4 oercs'nc'1 = ?.4 Class A-ll (reinforced concrete, p = 1.0 percent) = 4.8 Crushed atone encasement = 2.2 Class B * 1.9 Class C * 1.5 Class D * 1.1 The field supporting strength is calculated as: Field supporting strength = minimunr-t:rushing strength x load factor (13) Because of limitations in the 3-edge twsaring test in simulating actual field conditions, a factor of safety must be applied to the field supporting strength to calculate a safe supporting strength. The safe supporting strength is calculated as: c . . , Field supporting strength ,,,.., Sate supporting strength 3 = ——%—^3 — (19 > rr ° * Factor of safety ASTM Designation C12-82 recommends using a safety factor of between 1.0 and 1.5. Allowable Load for Flexible Pipe The load on flexible pipe is also calculated by a version of Marston's equation. The flexible pipe load differs from the load imposed on rigid pipes in that the soil at the sides of the pipe is compacted to the extent that it will deform under the vertical load imposed on the pipe itself. Therefore. the side fills can be expected to carry 3. proportional snare of the total load. Under these circumstances, the trench load formula may be modified to: W = B (B w C + w H, C ) (20) c d d c t us 9-82 ------- C-1 •^ r^ ^ -ii as in , ., z -•* 2£ <£ '*J -i£ --] 'O ^1 I "O ^ ij & — ~ v) -J s 3 — « M « D 'Y3 ;j-< Z2 U ^ 3fi ^; i i" — ™* -J — U Z 3 S '-0 * ^J ^- ^J 2 H 1 ! I i f i ? 1 « 1 U 1 w 1 • 1 V ! "O O. 1 bl >-< 1 « ( g >. I a — i w U 1 i •o i a i -4 1 "M 1 -1 1 4J ) •- 1 1 •9 < JS V I u u I op u 1 v 0 1 u U 1 3) 3J ' a. i a 1 U 1 U 1 X I i i i i V 4J •** V X - 41 a cj •3 -0 W D "2 4- (0 U V3 --4 0) a j= a i? 2 t a) .rf ^u w U •J •- 9 ^ Z J! U 41 C . -. u -C "- M^ -3 *H <9 - 2 a •^.^ Z w a» V -* w ^— * 1^^ j_( j3 " u i j a z j! ^ flj U C • •« M — * ^-O->l i 1 1 1 1 3P.-1.-1-^J3!N5OJ^-«I ! 1 1 1 1 — ^ CN "N~"J CN^1^^^ OOOOOOO3 3 --^O333?tfaoO>Of*^CN ONCJSJV^^r-.CNSOyO^aOC-l O r^ ,0 CM - 03000300OOO00033 OOOOOOOOij^3O3 33O3 OO3^< vf-O5<"^JO~»r».3j^3^o O"l (N CN CN CN CN CN r^ ^i *& ^f irt i/^ ^3 ^9 ^* m^r ^ao OcNi/"iao -^^yrvO ^sOS\cN -^— ^-^'-^CNCNCN^*^^^^* 9-83 ------- wnere: V, i , -, v, , n-ana J ira previously aefined d t r _5 3 = Outside diamecer of pipe, f c , (see Figure - . ? . ! " N As with rigid pipes, Che coefficients Cd and Cus may be calculated using working graphs provided in Figures 9.2.18 and 9.2.19. Under projecting conditions, the load on flexible aioe can be assumed co b« equal to the weight of a pri^m of ovanying waste fill with a width BC and a height, Hj, plus the weight of a similar prism of gravel above the pipe (see Figure 9.2.17). The following equation can be used to determine the load: W - (wfHf * w Z) (21) where: W, w , H,, w and Z are previously defined After calculating the load, it miot ':e determined whether excessive deflection will occur. Flexible pipe derives its ability co support a load from its inherent strength plus che passive resistance pressure of the soil at the sides as the pipe deflects and moves outward against the side fills. This type of pipe fails by excessive deflection and collapse or buckling, rather Chan by rupture as is the case with rigid pipes. Flexible pipes must be designed ca withstand vertical pressure at the top of the pipe without excessive aeflectian. The Iowa formula is a well-accepted equation for calculating flexible pipe deflection under earth loading and is given as: (22) 2 El * 0.061 E'r where: Ay » horizontal and vertical deflection of the pipe (in.). A maximum long term deflection of between 5 and 10 percent is recommended D » a factor, generally taken at a conservative value of 1.5, compensating for the lag or time dependent behavior of. the soil/pipe system (dimensionless) W * vertical load acting on the pipe per unit of pipe length (Ib/in.) r " mean radius of the pipe (in.) E • modulus of elasticity of the pipe materials (psi) E' * modulus of passive soil resistance (psi) (normally estimated to be 300 psi for soils with Proctor density of 65 percent, and 700 psi for soils with Proctor density of at least 90 percent) 9-84 ------- K * bedding constant, reflecting Che suoport the -*i-?. -?c3i-v»s frsa tha '3 a c torn ~f :na :rancr. ;insr.cic;:i^=s, , d conservative value of O.iO is normally assigned) I - moment of inertial of pipe wall per unit of length (in.Vin.); for any round pipe, I-t-^/12 where t is the average thickness (in.) The first term In the denominator of oquacion 22, £1, reflects the influence of the inherent strength of the pipe on deflection. The second tens, 0.061 E'r-3, reflects the influence of the passive soil pressure on the sides of the pipe. It is recommended that the value of El «hould never be lass *han 10 to 15 p'sr-nr.: of n.OSl 3"r~. uue co cne variety of flexible pipes available, manufacturers should be consulted for data on pipe strength. Example values of El for 4 types of pipe are as follows : 4-inch Schedule 40, El - 16.2 4-inch Schedule 80, SI * 47.4 6-inch Schedule 40-, 21 =» 23.4 6-inch. Schedule SO, 21 - 105.3 Reference 4 presents a graphical technique which can be used to evaluate deflection in flexible pipe. Several examples are also provided. Manufacturers often provide tabulated data to give the design engineer a quick indication of the adequacy and applicability of flexible pipe. Table 9.2.10 illustrates the caoabilii::/ of ?VC pipe with 3. stiffness of 46 psi under projection conditions. The table illustrates that deflection will be less than 7.5 percent for depths up to 12 feet. At greater depths, greater defleciton is possible depending on soil type. The capacity of flexible pipe to support vertical stresses may in some cases be limited by buckling. In most cases, the allowable deflection will be exceeded before buckling becomes the limiting factor. In some cases, buckling modulus of passive soil resistance. Specific information on buckling characteristics should be obtained fron Che pipe manufacturer. Perforated Pipe Perforations reduce the ability of rigid and flexible pipe to carry load and resist deflection under both trench and positive projection conditions. This effect can be accounted for by assuming and using an increased load per unit length of pipe. The following equation is recommended: ^ 12 Design load - - x Actual load (23) 12 - L where: Lp - Cumulative length of perforations in inches per foot 9-85 ------- 9-86 ------- *orxing or M.ovtr.g '-ye -oaas Live loads due to construction equipment are a key consideration in leachate collection system design. Dijcushions wicn j.anariii operators and designers suggest that failures of many leachate collection systems may result from construction equipment loading. EPA TRD SW-870 suggests a minimum vertical separation of 4 feet between the loaded surface and che cop of the pipe. Concentrated live loads such as a truck wheel load can be calculated as follows:i6 P F W - C —- (24) sc s L vhsrs: W ~ 1 ^~.d -r. ~.u,e pipe lr* pounas per iinear root sc P = concentrated load in Ibs F = impact factor; a minimum value of 1.5 is recommended L = effective length of pipe, ft. It is recommended that an effective' length of 3 feet be-used for pipe greater crtan j feet long, and actual length for pipe shorter than 3 feet C = load coefficient; the load coefficient is a function of pipe width, effective pipe length, and fill height The load coefficient, C_, is a function :>f 3C/2H and L/2H. Load coefficient values can be obtained fro* Table 9.2.11 for several combinations of pipe size and depth. However, Cs cannot be obtained from this cable for small pipe (6 to 8 inch diameter) at depths greater than 3 or 4 feet. For depths up to 8 feet the live load can be approximated from the data presented in Table 9.2.12. The wheel load must first be determined and then the percentage of that load applied to a unit length of pipe is obtained from Table 9.2.12. This load must then be corrected using an impact factor of 1.5 or greater. Based on the information presented in these tables and an impact factor of 1.5, the live loads calculated for 6-inch and 3-inch diameter pipe under a IC-con truck are presented below: Pipe load, Ibs/linear foot 6-inch pipe 8-inch pipe 1 3070 3600 2 1370 1680 3 700 860 4 +00 500 5 290 340 6 200 240 7 120 170 8 100 120 9-87 ------- 00 30 o O fM «!• 03 wo — CM <-! *»• OOOO OOOO co *r co o T fo CO 5 .1 ------- [ TABLE 9.2.12. PERCENTAGE OF WHEEL LOADS TRANSMITTED 10 UNDERGROUND PIPES3 Source; Reference 16 Oeodirfl P'Ot SackMi ! Silt or Pioe 13" 21"; 24": 27"' 30" 33"' 36"' 39"' 42" *>!t : 64i 31 1.0, 1.2 1.5 1.8 2.1 2.4 2.7 3.0 3.3 3.5 3.9 42 1 2 3 4 ; 5 6 ' 7 8 i 12.8 5.7 2.9 ' 1.7 1.2 0.8 | ! 0.5 i 0.4 : 15.0 '' j ?6 2.1 1.4 1.0 07 05 173 3.3 43 2.5: 1.7 1.1 08i 0.6 ! 200 9 6 1.2 3.1 2.1 1.4 < i n: 0.8! 22. S 11.5 14 3.9 2.6 1.3 1.3 10 243 13.2 7.5 4.6 3.1 2.1 1.6 1.2 26.4 15.0 3.5 5.3 3.5 2.5, 1 9 ' 1.4 27.2 156 93 5.8 3.9 2.3 ' 1 1.3 28.0 16.8 10.2 6.5 44 3.1 23 1.3 28.5 17.8 11.1 7.2 4.9 3.5 26 2.0 290 187 11 3 79 5.3 3.8 29 2.2 29.4 19.5 125 3.5 5.8 4.2 3.2 ' 2.3 29.8 20.0 12.9 88 6.1 4.3 3 3 2.5 29.9 205 135 92 6.4 44 ? S 2.5 Tabulated figures show percsncage of wheel load applied to one linear foot of pipe, but make ao allowance for impact factor. 9-89 ------- These .^aas =re :aicaiacea assuming 3J percent or tne 20-con ioaa is distributed over che rear axle, each rear wheel carrying one-naif rnis Load or 16,000 pounds. From th'ese data, it is evident that increasing depths o? c^var substantially raducs che i.ive load. The techjnical adequacy worksheet for evaluating the calculations of load bearing capacity for the leachate collection system piping is presented in Figure 9.2.20. The worksheet should be completed before addressing the technical adequacy checklist provided in Section ?.9. 9.2.2.3.4 Leachate Collection System Clogging—The following text identifies physical, chemical, and biological phenomena which can cause clogging of leachate collection facilities. Such clogging could result in Laacr.ata a<=p:_ns 2~?-~Z£~ :r.ati . .f^o*. aoove the oottom liner, the limit specified in the regulations (§264 .301(a)(2)). - Leachate build-up, in combination with a bottom liner failure, could lead to extensive contaminant exfi1tration. The discussion which follows is taken from Reference 15, "Clogging of Leachate Collection Systems Used in Hazardous Waste Land Disposal Facilities." Clogging Mechanisms Physical Clogging Mechanisms—Pipe drainage system failures, or partial failures, due to physical causes are usually associated with unstable soil conditions which cause shifts in pipe alignment and grade, collapsed tubing, oulled joints, and plugging, according to the Bureau of Reclamation. Other failure mechanisms which may be more common to land disposal operations induce crushing of pioe due tc equipment loads, damage due to frost action or nyarostratic uplifc, or migration of f-ine grained soils into and through che drainage filter envelope surrounding the pipe. The failure of drains due to clogging by soil sediment deposits is a common problem and will depend on the nature of the soil surrounding the drain. Such sedimentation may occur in noncohesive soils or soils with a high content of silt and fine sand. The effects of undesirable soil types which may be adjacent to or wl^iin the leachata collection jyscem can be mitigated by: (1) proper selection of the filter and drainage layer soil particle size gradations to exclude the smaller mobile particle sizes; and (2) incorporation of adequate facilities for cleanout of the system if it becomes clogged. Procedures for the selection of filter and drainage envelope particle size gradations- are discussed in a following subsection. However, in some cases, especially immediately after construction, some fine particles may wash out of the filter envelope if fines are not kept to a minimum. Thus, the design of cleanout facilities, also discussed later, is recommended as a precautionary measure. Chemical and Biochemical Clogging Mechanisms—The potential or probability for clogging of leachate collection systems is difficult to quantify because of widely variable site specific waste, soil, and operating conditions. Therefore, the clogging mechanisms discussed below may act only in limited cases depending on conditions at the site. The clogging agents discussed 9-90 ------- LEACHATE COLLECTION SYSTEM/LOAD SEARING CAPACITY Has Chi3 part of the applicants subraictal been read and evaluated? Yes No rias cne applicant addressed this issue? Yes No ,»hat source of information has the applicant used to assess the structural strength of the leachate collection system? What is the anticipated dead load? Ib/ft What is the anticipated live load? Ib/ft What are the proposed pipe trench conditions; trench or projecting? Based on independent calculations, will the piping withstand the anticipated total load? Yes No Figure 9.2.20. Worksheet for calculation of load bearing capacity of underground leachate collection system piping. 9-91 ------- include calcium and manganese carbonate, various iron pracipi taces , and biochemically generated ferric and manganese hydroxides (ochre). Calcium carbonate precipitates have been found to cause plugging problems around well screens, in drainage layers, and within pipes. 19, 20 Incrustation occurs when the concentrations of both the calcium and bicarbonate ions are present in excess of their equiliorium concentrations. 20 jn wells, during normal pumoing "erisds. pressure cnanges accelerate the conversion jf cne oicaroonate ion to the carbonate ion by permitting escape of carbon dioxide from solution. 20 xhe carbonate combines with calcium to form calcium carbonate precipitate- These mechanisms are shown by the following reaction scheme. 20 Ca** + 2HC03" - - CaC03 (solid) + CC>2 (gas) + H20 (25) Investigators have formulated an expression to determine the likelihood that incrustation of calcium carbonate will occur on a site-specific basis. The resultant formula relates pH, total alkalinity (T.A.) or bicarbonate alkalinity, and calcium hardness as follows: 20 Incrustation Potential = (T.A. as ppm CaCO-; ) (ca.lcj.um hardness as ppm CaCO-^) (26) Ratio (I. P. R.) 10.3 x IQll (H + ) If the resultant I.P.R. value is less than 1, no calcium carbonate problem should exist. On the other hand, if tne I.P.R. value equals 1 or more, calcium carbonate incrustation is a po-e-ential problem. Manganese has also een shown to "form chemical precipitates (manganese carbonates) responsible for clogging. Manganese forms carbonates (rhodochrosite) , sulfides, and silicates that are fairly insoluble in neutral and basic solutions. Precipitation may occur whenever the pH increases, provided carbonate is present in sufficient concentrations. Research performed on well systems and subsurface drains used for agricultural land drainage indicates that a predominant clogging phenomenon experienced worldwide is the formation of iron deposits. Observations of iron incrustation in drain pipes has been reported as far back as 1937 (Germany) . 21 Geological investigations and experience with subsurface wastewater treatment systems indicate that insoluble iron and manganese compounds are transformed under anaerobic or reducing conditions into nore soluole ferrous and manganous forms. If the soil drains and these compounds are exposed to oxygen, insoluble compounds are formed and precipitate out of solution. These colored precipitates are referred to as soil mottles. Discussions with Dr. Ron Lavigne22 aiso indicated that formation of iron precipitates in leachate collection systems is likely when oxygen is brought into contact with leachate. Dr. Lavigne noted that leachace drawn 9-92 ------- from piezoraecar caps located in the anaerobic zone of a pilot leachate collection system in 3arre, Massacnusects was clear in color upon withdrawal. When Che clear leachate was exnosed to air 2 "ruct" precipitate oegan to form. Dr. Lavigne indicated that problems with passing the precipitate would occur if air were not excluded from the collection system. Reduced soluble forms of iron and manganese are metabolized by aerobic iron bacteria as an energy source producing large quantities of ferric and manganese n^droxides -.-hich ^ntvins snd JI.QI.ogicaj. j.y precipitate within and at the water entry slots of drains. In Che absence of these autotrophic (self-sufficient) bacteria, chemically-precipitated Fe(OH)3 is found to be porous and less of a clogging agent unless it is clumped in large oart ides. 19, 2 3, 2^ Iron sulfida deposits (FeS) produced from available Fe'l"2) are known to adhere to organic soil matter forming a relatively impervious mat within drain envelopes, and have been found capable of clogging the entry slots in corrugated plastic tubing.25 3ther researcn indicates that the presence of certain -tomplexing agents in association «ith iron (re1"11) can influence the production of ochre. These organic complexing agents; i.e., tannins, humic acids, and certain aromatic hydroxyl compounds such as phenols, are known to complex iron and reduce ochre development when the Fe + 2 content is >4 ppm.25 However, these compounds have also been found to form collodial iron complexes in water, free of iron bacteria, that may adhere to drains and act as sites for additional accumulation or ferric ^Fe'3) compounds and subsequent trapping of particulate matter such as sand grains.^ xj^e iron complexation problem is particularly severe when the pH is between 7.C and 7.3.23,24 jn studies using iodine as a biocide to control these clogging agents, iodine was also found to complex with iron and form a clogging agent. ^ Soil types have a predominant influence on the potential for clogging due to these biochemical mechanisms. Studies conducted in Florida have indicated that the types of soils showing the most potential for ochre formation are: 26,27 fj_ns sands and silty sands, organic soils and organic pans, mixed profiles containing organic matter, gullies, flood plains of rivers, and depressions containing organic residues. Soils with the least potential for ochre formation are silty clay loams that are deficient in Fe + 2 £n c^e soil solution because of the high amount of energy required to reduce the iron present. Additionally, soils containing glauconite, iron oxide or magnesium oxide are known to seal over drain joints or perforations due to the various chemical actions that may take place within these soils.28 Biological Clogging Mechanisms—Research efforts ind operational experience witn microbiaj. removal or hazardous waste compounds, porous media wastewater treatment, wastewater tile fields, soil absorption beds, and agricultural drainage and irrigation systems are indicative of biological clogging mechanisms that may be encountered in leachate collection systems. 9-93 ------- "r. ;;^aies or tow vOLume irrigation systems by Ford, a filamentous 3 forming organism identified as '/itraoscil1j and a common, universally distributed soil bacteria called Pseudoroonas (specifically, Lcs associated polvsacchari.de slices) were snown to act as clogging agents in the absence of iron. 1-9 Additionally, Ford has suggested that a clear jelly-like slime, dominated by bacteria of the genus Enterobacter, may contribute to an increase in drain entry resistance by clogging the zone abutting the drain envelope.24 Extensive investigations by '------- if cr vu >*. z a a <« a; h- 2 K < a o" II a. Q. '-u O O II i- o o 01 ^ 3 ao u II «j Uj OJ CJ u 01 9-95 ------- •-"rirari^n 1. The LJ percent size (315) of a filter -nataria1 should be 'ac lease four or five times Che \5 percent size (L>I) of a protected soil « D (of filter) D15 (of soil) > 4 C° 5 (23) The first criterion is for the control of piping (hvdraulic failara,1 j f joii into the filter layer and rhe drainage system, while the second criterion is meant to guarantee sufficient permeability to prevent the buildup of large seepage forces and hydrostatic pressure in filters and drainage layers. Other criteria c.->.r. "-•' _ pir.if .^n --.; aaaition to or in lieu of those noted aoove. Ihe U.S. Army Corps of Engineers31 recommends the following for protecting nonplastic soils: D , size of filter material -L2 - - - < 5 '-IN D , size or protected soil — D_. size of filter material < 25 (30) D,_ size of protected soil — These criteria are based on experience witn and design of dams and other earthworks that require slope stability, and design of underground drainage systems. The U.S. Army Corps of Engineers31 also allows d relaxation of the above criteria for medium to nignly plastic clays without sand or silt lenses, which would require multiple stage filters by the above criteria. These criteria state that for these clay soils, the 0^5 size of the filter may be as great as 0.4 mm and the above DJQ criterion may be disregarded. This relaxation in criteria for protecting medium to highly plastic clays will allow the use of a one-stage filter system; however, the filter material must be well graded, and to ensure nonsegregation of the filter macdriai, a coefficient of uniformity (ratio of D^Q to DIQ) of not greater than 20 is required. In contrast to the Corps criteria stated above, Sherard et al.32 note that certain types of clay may erode by a process called "dispersion" or "deflocculation." Cedergren30 indicates that the chance of piping failure of drainage systems using dispersive clays can be greatly reduced by providing adequate filters to retain erodible soils. In some cases two or three filter layers may be required for such systems. Field tests of soils should be performed to establish safe piping ratios (^15 filter/Ds5 soil) for systems using dispersive clays. The U.S. Bureau of Reclamation33 has also developed filter grading criteria for high head-rapid pressure dissipation applications. These criteria address piping and permeability in a manner similar to those 9-96 ------- mentioned above. In addition, the Bureau recommends separate criteria for uniform grain size filters and differentiates between angular and rounded graded filter media. Bureau criteria also suggest tnat all filter materials pass a 3-inch screen to minimize particle segregation and bridging during placement. A key consideration in using all the above criteria is that the grain-size curves of filter and protected layers be somewhat oarallel. This objective is expressed by the reiationsnip given in equation 10 of the Corps criteria.31 The technical adequacy worksheet for evaluating the suieabiiitv of drainage ^.nd :i1r.3' layer Jlesig:; using natural materials (.gravel, stone, sand, etc.) is presented in Figure 9.2.22. The worksheet should be completed before addressing the technical adequacy checklist in subsection 9.9. Use of Filter Fabrics—When filter fabrics (geotextiles) are used in place of graded filters, the protective filter may only be about 1 mm in thickness. Caution should be exercised to ensure that no holes, tears, or gaps are permitted co form in the fabric. Cedergren-30 suggests :hat if ;he Dg5 of a soil is larger cnan the near maximum opening size of the fabric (035 fabric), little soil should move through the fabric mesh. Demery3^ has shown that if the permeability of the protected soil is less than the permeability of the filter fabric, the soil controls the hydraulic response of the system. WiLLardson indicates that it is wise to maintain the ratio of filter permeability to soil permeability (k filter/k soil) greater than 1.0 to minimize the hydraulic gradient at the interface.35 rn general, the permeability of synthetic filter fabrics lies in the range of 5 x 10"^ to L0~l cm/sec. Thus, in most cases a ratio of k filter/k soil greater than 1.0 can be easily achieved. The advantages to using synthetic fabric filters in place of granular filters are cost, durability, and consistency. With increases in costs of graded aggregate and its installation, synthetic filters are competitive with graded filters. Probably the most important advantage to fabric filters is quality control during construction. The properties of fabric filters will remain practically constant independent of construction practices, whereas graded filters can become segregated during placement. Although synthetic filters do have certain advantages they are not problem free. Benz et al,36 indicated in studies of drainage envelopes that some synthetic fabric envelopes did tear under test. Broughton et al.37 indicated that Remay filters (27 g/m^) suffered considerable abrasion damage in transport and field handling requiring patching of the filter. In other cases37 drainage pipes (tiles) were found blocked by sand deposits which apparently entered through the joint between two sheets of filter material. In addition, bacterial plugging (iron bacteria) of synthetic filters has been noted by Demery. 4 Compatability of filter materials and leachate will also be a subject of concern in specific cases, and should be accounted for during system design. 9-97 ------- .EACHATE COLLECTION SYSTEMS—SELECTION AND SIZING OF FILTER AND DRAINAGE MEDIA • Has this part of the applicants submittal been read and evaluated? Yes No • Are soils and/or scone media proposed for adjacent filter and drain layers? Yes N*o (If filter fabrics are proposed, see Figure ) • Are the size gradations characterizing these soil layers presented by the applicant? Yas ."Jo • What criteria or equations has the applicant used to demonstrate that movement of fines (and media clogging) will not occur? • riave equations recommended by EPA been ased to assure acceptability of adjacent layers? Yes No • If no, conduct an independent check using those relationships Independent Check a. 015 filter/Dsj soi.1 = _ < 5? Yes No b. D15 filter/Di5 soil = _ >_ 5? _ _ Yes No c. D50 filter/D50 soil = _ = 25? __ _ Yes No • Is the applicants proposal acceptable in preventing _ _ drainage media clogging by fines? Yes No Figure 9.2.22. Worksheet to determine adequacy of design of drainage and filter layers. 9-98 ------- The technical adequacy worksheet for determining the suitability of geocexcile filter materials is presented in Figure 9.2.23. Selection of Pipe Perforation or Slot Size—When drainage systems are embedded in filter and drainage layers, no unplugged ends should be allowed and the filter materials in contact with the pipes muse be coarse enough to be excluded from joints, holes, or slots.30 -r^e u.s. Army Corps of Engineers^! use the following criteria for gradation ->f filter materials in relation co pipe openings. For slots: slot width For circular holes: D0, filter material D filter material — = 1.2 (31) _ nole diameter -1.0 The U.S. Bureau of Reclamation^ usas Cne following criterion for grain size of filter materials in relation to openings in pipes: D , of the filter nearest the pipe > 2 ' (33) maximum opening or pipe drain — Cedergren^U suggests that these equatipns represent a reasonable range over which satisfactory performance can be expected. The U.S. Bureau of Reclamation^8 additionally recommends that the maximum opening in pipes not exceed 1/8 in. (3 mm). Control of opening size is difficult in open joint construction practice, thus making perforated pipes more reliable. Modern trenchers often employ double hydraulic rams to maintain pressure on pipe ends during placement and spacing lugs are required. However, even with this modification, pulled joints still occasionally occur so that the additional precaution of covering the top half of the pipe with a plastic cover is recommended. 33 other solutions to this problem include wrapping open joints in synthetic filter fabrics. The technical adequacy worksheet for determining the suitability of the applicant's design for pipe slot or perforation size is presented in Figure 9.2.24. Correction of Clogging It is likely that proper engineering design and careful operation of a leachate collection system can significantly reduce the risk of clogging and allow for repair if clogging occurs. Recommended engineering components or methods for system maintenance, cleaning, and repair include: 9-99 ------- ACCEPTABILITY OF FILTER FABRICS (GEOTEXTILES) a Have the filter fabrics proposed by the applicant been evaluated? Yes No • Has the applicant demonstrated a suitable inspection plan to assure that the filter will be frae of holes, cears, or gaps oefore and after installation? Yes No • Has the applicant noted the maximum on^rsing size jf ;>\e Jaoric, ana ir so what is it? What is the Dgj of the adjacent protected soil? Is 035 soil greater than the maximum opening of the fabric, thus preventing movement of soil into the fabric? Yes 'Jo If the filter permeability is known, what is the reported value? If the adjacent soil permeability is known, what is the reported value? Is the ratio kfii Yes No Figure 9.2.23. Worksheet for determining Che adequacy of filter fabrics proposed by the applicant. 9-100 ------- LEACHATE COLLECTION SYSTEMS—SELECTION OF PIPE PERFORATION OR SLOT SIZE • Has this part of the applicants submittal been read and evaluated? ies ' No • Has the applicant addressed this topic to assure that the leachate collection pipe openings will not clog? No Independent Check - What is the proposed slot width or hole diameter? Whac is ;ne Dg^ of the adjacent filter material: Are the criteria of equations 31, 32, and 33 satisfied? 035 filter/slot width = 1.2? Yes No 035 filter/hole diameter = i.O? Yes No Dgj filter/max, pipe drain opening > 2.0? Yes No Is the applicant's proposal acceptable? Yes No Figure 9.2.24. Worksheet for determining the adequacy of pipe perforation or slot design. 9-101 ------- • perforated drainage niof.s ' ? . .-. i:.-iJ.-j ..-:•/ -~-.tr;::.., „,.- .-VC/ vtrr. 3a.aJ.3d ^31.-;^ o t a .ainimum diameter of "3 in. co facilitate mechanical or chemical cleaning, • manholes located at ~ajjr ^ipe incersections or bends to allow for access, inspection, and mechanical or chemical cleaning, • incorporation of valving, ports, or other appurtenances necessary co introduce biocides and/or cleaning solutions, and • automatic leachata level monitors and (possibly) alarm systems. Following construction, scheduled periodic maintenance is recommended. After the initial lift of waste has been placed, che ^r'.inaee =•.-•:,-cm jr.oui- oe insoected. rle.ar.ec! :-.'i :jjica, unc repaired if necessary. Subsequently, periodic testing and cleaning should be conducted, possibly once per year. In addition, leachate levels and flow rates should be continuously monitored and correlated with rainfall so that inconsistencies indicating clogging can be immediately investigated. Clogged drainpipes can ;>e restored Co a free flowing condition by pnysicai or chemical cleaning except in cases vhere Dlockage is due Co crashing jf the drain. In this case, drain replacement would be required. Also, except under unusual circumstances, it would not be feasible co clean large areas of drainage layers which had become clogged. Of the two physical methods of drain cleaning, hydraulic jets have generally been considered superior to "mechanical cleaning systems (.e.g., Rota-rooters) wnich are often used with success in the cleaning of sanitary sewer lines, or mechanical "pigs" which are used for cleaning water .-nains. Physical methods for removal of ochre and other associated iron clogging agents within drains have been extensively used in Europe, and to some degree in the United States. These methods employ a high or low pressure jet cleaning system placed within the drains. 39 jn Europe, the high pressure system is used for the more seriously clogged drains while low pressure units are restricted to removing silt and iron deposits.39 Preliminary tests by Ford, using a high pressure (1100 to 1300 psi at the pump) system, found that condiserable damage to the sand-gravel envelope surrounding the drains and subsequent deposition of sand and gravel within the drains was occurring.39 These observations prompted interest in a low pressure system for ochre removal in Florida. From a group of 21 low pressure nozzle types, two nozzles (as shown in Figure 9.2.25) were rated highest on the basis of propelling distance, cleaning efficiency, water requirements, and ease of construction.39 The overall performance of these low pressure nozzle cleaning systems was found to be adequate in removing deposits which primarily consisted of ochre and FeS within 4 to 5 inch plastic drains of up to 550 ft in length.39 it was noted that jetting should be performed at a slow entry rate and with a 9-102 ------- / ,30' r 1.23 PROPELLING JET\ CLEANING JET .123" _A /094" sy ^ ^UNNCR-^ J^ \y PROPELLING JET 125 063" RUNNER 3. 7 Figure 9.2.25. General purpose nozzle (top) and penetrator nozzle (boctom) Source: Reference 39. 9-103 ------- nydrauiic nead above crie drain. -^ However, low pressure jetting was noC totally effective in removing- large accumulations of FeS on organic matter abutting Che drain envelope.39 Subsequent testing with hi^h pressure systems has shown that removal of the more mature ochre deposits is not entirely possible.^0 Recent tests in Wisconsin indicate that water jets can be used to effectively clean drain pipes which, for test purposes, were filled completely with silt and clay.41 For deposits which are not readilv -shoved ':y watsr jets or other -nechanicai aeans, chemical cleaning techniques have been tested. These methods fall into two broad classifications: (1) chemically dissolving the accumulated material, or (2) controlling the iron bacteria responsible for these deposits. Chemically dissolving the accumulated material appears to be a function of several variables. Calcium and magnesium carbonate deposits have been known to dissolve readily in well systems using hydrochloric (muriatic) acid.42 However, these same deposits have been shown to react with sulfuric acid treatments producing only slightly soluble sulfates in water.^2 Hydrochloric acid has also proved effective for removal of iron and manganese hydroxide and oxide deposits from well systems and irrigation systems (although these deposits will precipitate from solution if the pH goes above 3).1^>42 Apparently, in the treatment of these hydroxide or oxide accumulations, the chlorine (either as a hypochlorite-Cl-? dissolved in Ca(OH)2 or NaOH, or as the gas-C^) effectively kills the bacteria associated with these deposits, and also oxidizes re (II).19 In a study of recovery wells around the Army Creek Landfill in New Castle County, Delaware, which were clogged by ochre deposits, a polyphosphate solution containing 100 Bounds of activated carbon (Calgon^M) and 5 pounds of granular dry chlorine gave good results in rehabilitating these wells.43 Additional effective treatment methods for ochre deposits within subsurface agricultural drains include the use of gaseous sulfur dioxide, sulfuric acid, and sulfamic acid.23,40,42,44,45 Experimental research with sulfuric acid has shown that several factors may affect the eventual removal of ochre from drain lines; i.e., tne organic matter content, the amount of acid solution in relation to the amount of ochre, and the concentration of the acid.^O Generally, at higher organic contents, more acid is required for successful removal of ochre.40 Additionally, a drawback in the use of gaseous SC>2 and sulfuric acid is the inherent problem of handling these materials. Studies by Lidster and Ford^O using dry pallatized suifamic acid (at concentrations equivalent to that of sulfuric acid) have shown good results in attempts at dissolving ochre into solution. Sulfamic acid is inactive in its dry form and, thus, easier to handle than sulfuric or hydrochloric acids. The second alternative method of chemical cleaning is direct control of iron bacteria through the use of biocides. Compounds tested experimentally in the field include:19 (i) acrolein, a three carbon aldehyde which is 9-104 ------- identified is .2 '~azaraou3 -asca me! . ::".ersf;ra , ecu*.: ^e inappropriate, \;,- quart arnary ammonium salCs; a nonoxidizing biocide which killed Che bacteria but also had to be limited :o certain types of problems because these sales form undesirable complexes, (3) iodine vhich vas a good bi.oci.de, but which forms complexes with iron that may clog, and (4) hydrogen peroxide (^2^2^' which when combined with Fe forms a superoxide radical which was found to be a good biocide. Otherwise, t^C^ was a poor biocide for sulfur slime and other slimes that did not contain Fe . In summary, numerous methods for reclaiming drainage systems have been attempted, oorae nave snown great success with certain clogging agents, while others are not as effective or are dangerous to handle. As indicated by Ford, 19 prevention is the best method for controlling chemical- microbiological slimes and associated 9.2.2.4 Draft Permit Preparation — Condition 8.2 of Permit Module XV (see Section 4) addresses design and operation of leachate collection and removal systems. The condition is implemented through reference to a permit attachment that includes plans and specifications for Che proposed leachate collection system. To be suitable for substitution in Ihe permit condition attachment, the submitted application information should include ihe following: • engineering plans which show the full extent of the leachate collection system in plan and profile views, • all calculations and results— demonstrating the depth of leachate above the bottom liner, • all calculations supporting selection of pipe of sufficient strength Co withstand overburden live and dead loads, • all conclusions and associated documentation illustrating the resistance of leachate collection system materials to wastes, • all calculations, assertions, and drawings necessary to illustrate design procedures to prevent leachate system clogging and allow for correction of clogging if it occurs. 9.2.2.5 References — 1. Permit Applicants Guidance Manual for Preparing Part B Applications for Hazardous Waste Management Facilities (Draft). U.S. Environmental Protection Agency. April 1983. 2. Metcalf and Eddy, Inc. Wastewater Engineering - Collection, Treatment, and Disposal. McGraw-Hill. 1972. 3. American Society of Civil Engineers and the Water Pollution Control Federation. Design and Construction of Sanitary and Storm Sewers. Manuals and Reports on Engineering Practice No. 37. 1974. 9-105 ------- V.o. invironment Protac:: ion Agency. Lining of Waste Impoundment and Disposal Faciltities. Prepared by Matrecon for the U.S. SPA. Second Edicion. SW-870. September 1982. 5. U.S. Environmental Protection Agency. Draft RCRA Guidance Document. Landfill Design: Liner Systems and Final Cover. July 1982. 6. Perrier, E. R., and A. C. Gibson. Hydrologic Simulation on Solid Waste Disposal Sites. Prepared for che U.S. Environmental ?rocection Agency by the U.S. Army Corps of Engineers Waterways Experiment Station. Second Edition. SW-868. September 1982. 7. Moore, C.A. Landfill and Surface Impoundment Performance evaluation. Prepared for the U.S. Environmental Protection Agency by Geotechnics, Inc. Second Edition. SW-869. September 1982. 8. Walski, T. M., et al. User Guide for the HELP Model. Prepared for the U.S. Environmental Protection Agency by the Army Corps of Engineers Waterways Experiment Station. Contract No. AD-96-F-2-A140. Q. Schroetier, ?. R. et al. Documentation for the HELP Model. Prepared for the U.S. Environmental Protection Agency by the U.S. Army Corps of Engineers Waterways Experiment Station. Contract No. AD-96-F-2-A140. 10. Skaggs, R. W. Modifications to DRAINMOD to Consider Drainage from and Seepage Througn a Landfi-11. I. Documentation. August 26, 1982. 11. Correspondence from Mr. Les Qcte, U.S. 2PA Office of Solid Waste to Mr. C. Young, GCA/Technology Division. April 20, 1983. 12. Design Manual. Onsite Wastewater Treatment and Disposal Systems. U.S. EPA. October 1980. 13. Perry, R. H., C. H. Chilton and S. D. Kirkpatrick. Chemical Engineer's Handbook. McGraw-Hill, 1963. 14. Kirby, G. N. How to Select Materials. Chemical Engineering. November 3, 1980. 15. GCA/Technology Division. "Clogging of Leachate Collection Systems Used in Hazardous Waste Land Disposal Facilities." White Paper prepared for the EPA Office of Solid Waste. January 1983. 16. National Clay Pipe Institute. Clay Pipe Engineering Manual. July 1982. 17. Johns-Manville. Perma-Loc™ PVC Gravity Sewer Pipe. TRX-39. April 1982. 9-106 ------- ?-. ;-3 j/s:2ms. .-;r~as ;r ir. , .-=r:na--oc , ?VC, Transite , Thermopipes . TR-32Q. January 1982. 19- Ford, Harry W. The Problem of Clogging in low Volume Irrigation Systems and Methods for Control. Paper presented at the Symposium on Drip Irrigation in Horticulture with Foreign Experts Participating. Skierniewice, Poland. October 1930. 20. Baron, Donald M. A Well System Can be Designed to Minimize the Incrusting Tendency. The_ Jqrmson Driver s journal. First Quarter, 1932. pp. 8-11. 21. Beger, Hans. The Iron Bacteria In Water systems and Their Practical Significance. "as-u. '/aao^rfjcn. jo.366-869, 908-911 (as cited in Reference 22). 22. Telephone Conversation. Dr. Ron Lavigne, Reinhardt Associates, Springfield, MA with Thomas Nunno, GCA/Technology Division. June 1982. 23. Grass, Luther B. Tile Clogging by Iron and Manganese in Imperial '.'alley, California. Journal of Soil and Water Conservation, August 1969. 24(4):135-138. 24. Ford. Harry W. Characteristics of Slime and Ochre in Drainage and Irrigation Systems. Transactions of the American Society of Agricultural Engineers, 1979. Volume 22, No. 5, pp. 1093-1096. 25. Ford, Harry W. Biochemical and Physical Factors Contributing to Resistance in Drain Outflow in a Modified Spoaosol. soil and Crop Science Society of Florida, 1974, 34:11-15. 26. Ford, Harry W. Estimating the Potential for Ochre Clogging Before Installing Drains. Transactions of the ASAE. Paper No. 8-2542. Submitted and approved for publication, December 1981. pp. 1-11. 27. Ford, Harry W. Soil Conditions that Promote Iron Reduction and Subsequent Ochre Clogging in Agricultural Drains. American Society of Civil Engineers. Irrigation and Drainage Division Specialty Conference. 1982. pp. 1-7. 28. Fasken, Guy B. Engineering Field Manual for Conservation Practices, Chapter 14. Drainage. U.S. Dept. of Agricultural Soil Conservation Service. April 1975. pp. 14-48. 29. Kobayashi, Hester, and Bruce E. Rittmann. Microbial Removal of Hazardous Organic Compounds. Environmental Science and Technology, 1982. 16(3):170A-183A. 30. Cedergren, H. R. Seepage, drainage, and Flow Nets. John Wiley and Sons, 1967, pp. 178-187. 9-107 ------- ji. J.z. nrmy Jorps or Engineers. ^r^ina^e ana cirosion Control-Subsurface Drainage Facilities for Airfields. Fart XIII, Chapter 2, Engineering Manual, Military Construction, Washington, D.C., June 1955. 32. Sherard, J. L., R. S. Decker, and N. L. Ryker. Piping in Earth Dams of Dispersive Clay. Proceedings A.S.C.E. Specialty Conference on the Performance of Earth and Earth-Supported Structures, Purdue University, June 1972, Vol. 1, Part 1. 33. U.S. Bureau of Reclamation. Earth Manual, 2nd. Edition, Denver, CO, 81 pp., 1974. 34, Demery , ?. M. ?.c search Ana I/au or Plastic Filters. Proceedings of the 1980 Specialty Conference Irrigation and Drainage - Today's Challenges, July 1980, Boise, Idaho. 35. Willardson, L. S., and R. E. Walker. Synthetic Drain Envelope - Soil Interactions. Journal of the Irrigation and Drainage Division, ASCE, IR-4, Dec. 1979, pp. 367-373. 36. aenz, L. C. et al. Evaluation of Some Subsurface Drainage Envelopes. Proceedings of the National Drainage Symposium, Chicago, IL, 1976. pp. 31-33. 37. Broughcon, R. S., et al. Tests of Filter Materials for Plastic Drain Tubes. Proceedings of 3rd National Drainage Symposium, Chicago, IL, L976. pp. 24-3^. 38. Frogge, R. R., and Glen D. Sanders. USER Subsurface Drainage Design Procedure. Proceedings of the ASCE Irrigation and Drainage Division Specialty Conference on Water Management for Irrigation and Drainage, July 1977. Reno, Nevada. 39. Ford, Harry W. Low Pressure Jet Cleaning of Plastic Drains in Sandy Soil. Transactions of the ASAE. 1974, 17(5): 895-897. 40. Lidster, William A., and H. W. Ford. Rehabilitation of Ochre-(lron) Clogged Agricultural Drains. International Commission on Irrigation and Drainage. Eleventh Congress. Q. 36 pp. 451-463. 41. Telephone Conversation. Greg Woelfel, Northern Regional Engineer, Waste Management Inc. (414-476-8858) and Thomas Nunno, GCA/Technology Division. 23 April 1982. 42. Ground Water and Wells, Chapter 16, Maintaining Well Yield, Johnson Division, UOP Inc. Sixth Printing, 1980, pp. ..7-332. 43. Thomas, Abraham, et al. Physical and Chemical Rehabilitation of Containment Recovery Wells, Army Creek Landfill, New Castle County, Delaware Presented at Association of Engineering Geologists, Annual Meeting Hershey, Pa., October 1978. 9-108 ------- -Vvsrr '. ~.n\", rcr.rr.ar.ca 1 nsc-acto c c Sulfur Dioxide of Iron-.-ianganese in Pipe Drains. Irrigation and Drainage, pp. 120-125. 45. Dennis, C. W. The Failure of a Pipe Drainage System in an Organic Soil and Subsequent Remedial Measures. Land Drainage Service. Field Drainage Experimental Unit, Technical Report 78/3. November 1978, pp. 1-12. 9.2.3 Liner and Leachate ".? 11 action ana Removal System Exemption 9.2.3.1 The Federal Requirement— Part 270 requires the following application information if an exemption is sought: 5270.2Kb) (1) "... If an exemption from the requirements for a liner and a leachate collection and removal system is sought as provided by §264.301(b), submit detailed plans and engineering and hydrogeologic reports, as appropriate, describing alternate design and operating -practices that will, in conjunction with location asoects, prevent the migration of any hazardous constituent into the ground water or surface water at any future time." The Part 264 standards incorporate the following exemption criteria: "(b) The owner or operator will be exempted from the requirements of paragraph (a-) of this section if the Regional Administrator finds, based o» a demonstration by the owner or operator, that alternative design and operating practices, together with location characteristic^^ will prevent the migration of any hazardous constituents (see §264.93) into the ground water or surface water at any future time. In deciding whether to grant an exemption, the Regional Administrator will consider: (1) The nature and quantity of the wastes; (2) The proposed alternate design and operation; (3) The hydrogeologic setting of the facility, including the atten-uative capacity and thickness of che liners and soils present between the lanafiil and ground water or surface water; and (4) All other factors which would influence the quality and mobility of the leachate produced and the potential for it to migrate to ground water or surface water." 9.2.3.2 Summary of Necessary Application Information— The Part B Permit Applicants' Manual 1 specifies the following information requirements for new units: • location information relevant to assessing the potential for leachate migration, i.e., soil permeability, attenuation capacity, geology, and geohydrology, and 9-109 ------- • a descrintion of ".he '.Itar-.at ire iasigr. -.-a :c2r-.: _r.g iracci^as ana • :2mon2crat.en cnsc <~.ne proposal will prsvenc contamination of surface and ground water aC any fuCure time. 9.2.3.3 Guidance on Evaluating Application Information— It is not expected that many applicants will apply for this exemption. Additionally, it is not expected that many, if any, locations exist where such a demonstration could be adequately made. By definition, the site would first have to be located well above the existing water table in the unsaturated zone. The intermediate soil would have to be a dense cohesive fine grained material 'clay) with axtramely iOw permeaoilicy. Given the low water content and low void ratio, it is expected that high suction pressures would exist. Suction forces of this magnitude could provide a driving force for leachate migration which is one to two orders of magnitude greater than anv attendant hvdrostatic -ir*.v:-.7 :-rr- .1 :r.c>_6r. -,;e v/oi.^me of ieacnace chat would migrate jnaer cnese conditions is less than the amount that would migrate in saturated soils according to Darcy's Law, the velocity of movement of the wetting cront could be several times greater. As detailed in References 2 through 12, a great deal of information exists in this subject area. For instance, Moore notes a linearized solution to the unsaturacad flow equations in the TRD on Hydrologic Simulation (SW-869).2 of niost relevance is a guidance manual (GCA-1983)3 which illustrates the use of numerical modeling to simulate leachate flow through clay liners. Although the manual is intended for use in designing liners for storage surface impoundments, the technique could be applied to determine cne time of travel of the leachate from the unit to the nearest ground water or surface water resource. Given the physics of the situation and the available solution techniques, it seems improbable that an applicant could illustrate with validity that leachate would never reach any ground water or surface water at any future time. The guidance manual on numerical modeling incorporates a bibliography of related scientific literature. The references listed in subsection 9.2.3.5 should provide for further understanding of this topic. The technical adequacy worksheet for determining Che suitability of the applicant's alternative to the liner and leachate collection syscam is presented in Figure 9.2.26. 9.2.3.4 Draft Permit Preparation— Liner and leachate collection system exemptions are discussed in Condition B.2 of Module XV. The condition is implemented through reference to a permit attachment that provides plans and specifications for an alternative design. The permit application may be used as the attachment provided it includes an adequate description of the alternative design and operating practices and demonstrates that the design and operating practices, in combination with location characteristics, will prevent any hazardous constituents from entering the ground water or surface water at any future time. Successfully demonstrated alternative plans should also be documented in the administrative record. 9-110 ------- LINER AND LEACHATE COLLECTION SYSTEM EXEMPTION Has Che applicant applied for a liner and leachate collection system exemption? Yes No Has this part of the applicant's subraittal been reviewed and evaluated? Yes No Are any of the hazardous materials leachable? No '-'ill .ig-r-i-iw^ii- quantities of leacnatne hazardous waste be disposed in the landfill? Yes No Is the site located well above the existing water table? Yes No Has the applicant demonstrated (using engineering and hydrologic reports) that the intermediats soil layer Yes No nas an extremely low permeability? Has an accepted numerical or analytical model been used to simulate leachate flow? Yes No Does the simulation conclude that laachrs-te will never reach ground water or surface water? Yes No How do the results compare with your independent evaluation using techniques presented in SW-869 or a numerical model? Figure 9.2.26. Worksheet for determining the adequacy of the applicant's submittal for a liner and leachate collection system exemption. 9-111 ------- 1. U.S. SPA. Permit Applicants' Guidance Manual for Hazardous Waste Land Storage, Treatment, and 2ispOJal Facilities. volume I. Office of Solid Waste. Washington, DC. 1933. 2. Moore, C. A. Landfill and Surface Impoundment Performance Evaluation Manual. Submitted to the U.S. Environmental Protection Agency, Office of Water and Waste Management, by Gaotechnics, Inc. SW-86Q. Seat amber I960, 3. Goode, D. J., e t a1. Procedure for Modeling Flow through Clay Liners. Prepared for the U.S. Environmental Protection Agency by GCA/Technology Division. Draft Report. August 1983. 4. Bear, J. Hydraulics of Groundvater. McGraw-Hill, New York. 1979. 5. Clapp, R. B., and G. M. Hornberger. Empirical Equations for Some Soil Hydraulic Properties, Water Resources Research 14(4), 1978, pp. 601-604. 6. Elzeftawy, A., and K. Cartwrighc. "Evaluating Che Saturated and Unsaturated Hydraulic Conductivity of Soils." In Fermeaoility and Groundvater Contaminant Transport, ASTM STP 746, T. F. Zimraie and C. 0. Riggs, ed., American Society for Testing and Materials, 1931, pp. 168-181. 7. Green, W. H. and G. A. Ampt. Studies in Soil Physics I: The Flow of Air and Water through Soils, Journal of Agricultural Science 4, 1911, pp. 1-24. 8. Gruber, P. A. Simplified Method for the Calculation of Unsaturated Hydraulic Conductivity. ?resented_at AGU Spring Meeting, Philadelphia, PA. May 31-June 4? 1982. 9. Hamilton, J. M., 0. E. Daniel, and R. E. Olson. "Measurement of Hydraulic Conductivity of Partially Saturated Soils." In Permeability and Groundvater Contaminant Transport, ASTM STP 746. T. F. Zimmie and C. 0. Riggs, Eds., America Society for Testing and Materials, 1981, pp. 182-196. 10. Mclntyre, D. S., R. B. Cunningham, V. Vatanakul, and G. A. Stewart. Measuring Hydraulic Conductivity in Clay Soils: Methods, Techniques, and Errors, Soil Science 128(3), pp. 171-183, 1979. 11. McWhorter, D. B., and J. D. Nelson. Unsaturated Flow Beneath Tailings Impoundments. J. Geotech. Eng. Div. ASCE GT(ll), 1979, pp. 1317-1334. 12. Miller, R. D., and E. Bresler. A Quick Method for Estimating Soil Water Diffusivity Functions. Soil Science Soc. Am. J. 41, 1977, pp. 1020-1022. 9-112 ------- 9.2.4.1 The Federal Requirement— As part of "he applicant's detailed plans and engineering report, § 270.21(b)(2) requires the submission to address "control of run-on." The Part 264 standards for run-on control specify in §264.301(c) that: "The owner or operator must design, construct, operate, and -i3ir.c,-.irt a run-on control system capable of preventing flow onto the active portion of the landfill during peak discharge from at least a 25-year storm." °.2.-,2 -•,-rcsry ~L "ecessary Application Information— The Part B Permit Applicants' Manual^ instructs the applicant to: • Determine the peak flow from the upstream watershed area during the 25-year storm event, • Size and design run-on control facilities to accommodate the peak flow rate , and • Devise a plan for run-on system maintenance, restoration, and repair. 9.2.4.3 Guidance on Evaluating Application Information— A flow chart indicating the applicability of the Part 264 requirements to run-on control is provided in Figure 9.2.27. The flow chart is also applicao'.e EJ run-off control and management of run-on and run-off control units, as discussed in subsections 9.2.5 and 9.2.6. The landfill owner/operator must design, construct, operate, and maintain a run-on control system capable of preventing flow onto the active portion of the landfill during peak discharge from at least a 25-year storm. The technical issues which must be considered in evaluating the application information are presented in Figure 9.2.28. The amount of run-on (or runoff, as discussed in subsection 9.2.5) expected as a result of precipitation will depend on: e soil cover (vegetated or nonvegetated), « upstream watershed surface slope, o soil permeability, • antecedent soil moisture content, and • seasonal temperatures (e.g., soil freezing). The relationships between run-on or run-off production and these factors are covered in introductory hydrology textbooks (see Reference 2 and Reference 3). 9-113 ------- DOES THE LANDfILL DESiGN INCLUDE A RUN-ON CONTROL SYSTEM YES IS THE SYSTEM DESIGNED TO PREVENT FLOW ONTO THE ACTIVE PORTION DURING PEAK DISCHARGE FROM AT LEAST A 25-YEAR STORM YES DOES THE LANDFILL DESIGN INCLUDE A RUN-OFF CONTROL SYSTEM YES 15 THE SYSTEM DESIGNED TO COLLECT AND CONTROL AT LEAST THE WATER VOLUME RESULTING FROM A 24-HOUR, 25-YEAR STORM YES ARE RUN-ON/RUN-OFF COLLECTION FACILITY MANAGEMENT PROCEDURES SUITABLE TO MAINTAIN SYSTEM DESIGN CAPACITIES NO NO NO THE PLANS ARE TECHNICALLY NADEQUATE NO THE PLANS ARE TECHNICALLY^ ADEQUATE Figure 9.2.27. Regulations applicable to the control of run-on and run-off at hazardous waste landfills. 9-114 ------- RUN-ON CONTROL SYSTEM DESIGN AND CONSTRUCTION SYSTEM AND -MA OPERATION NTENANCE DETERMINATION OF MAGNITUDE/INTENSITY OF 25-YEAR STORM EVENT ','S'ECTiGN REQUIREMENTS MAINTENANCE OF DIVERSION STRUCTURE CALCULATION OF RUN-ON DURING PEAK DISCHARGE FROM DESIGN STORM EVENT DESIGN OF ASSOCIATED DIVERSION STRUCTURE Figure 9.2.28. Technical topics addressed for run-on control 9-115 ------- Rainfall run-on can 'z--. ::'...^rr^c ^ .• _ons "r--c: •_.-.:: ^-rcn oerms or Diversion ditches along cne upsiope side or the facility io direct flow toward natural drainageways downslope from the unit. Such diversion ditcnes or berms must b designed to accommodate, at a minimum, the aeak flew associated wi.cn the 25-year scorn, as required by the Part 264 regulations. 9.2.4.3.1 tVLagnitude of the 25-Year Storm Event—The amount of rainfall expected from a local or regional 25-year storm event can be obtained from the National Oceanic and Atmospheric Administration or local Agricultural Extension Service. A worksheet for assessing cne adequacy of the applicant's daterainacion or scorm magnitude is presented in Figure 9.2.29. 9.2.4.3.2 Calculation of Peak Run-on Discharge Rate—Two methods commonlv used to calculate the volume of run-on or run-off :xriag and arter rainfall ir« the "--tional .aecr.oa ' ana cne Soil Conservation Service (SCS) method. The Rational Method The rational method calculates peak runoff production based on che following expression: Q = Cia (34) where Q = peak run-off rate in cubic feet per second (cfs) c = run-off coefficient which is actually the ratio of the peak run-off rate to the average rainfall rate for a period known as the time of concentration i » average rainfall intensity ITT inches per hour for a period equal to the time of concentration a 3 drainage area in acres Use of the rational method for determination of design run-on quantity is appropriate since the Part 264 regulations require control of the peak discharge rate. Q, as calculated using the rational method, is defined as the peak discharge rate associated with the selected storm event. The rational method formula is based on the following assumptions:2 (1) the maximum run-off rate is a function of the average rate of rainfall during the time of concentration, (2) the maximum rate of rainfall occurs during the time of concentration, and (3) the variability of the storm pattern is not taken into consideration. The time of concentration (tc) is defined as the flow time from the most remote point in the drainage area to the point in question. The time of concentration is calculated as follows: 41b L1/3 t = ° (35) c t -i2/3 (ci) 9-116 ------- RUN-ON CONTROL Determination of Magnitude of the 25-year Storm Event — Has this oart ^f "h? ~-r>i:.c^-' - :uc~:. L^I _,een read ana evaluated? Yes"" No — What storm magnitude was selected by the applicant? — What depth of rainfall is this storm event equivalent to? laches based on what references? Tndeoendent Check , based on what reference? what is the rainfall depth associated with the 25-year storm? inches Is the rainfall depth established by the applicant at least as great as <:his determination? Yes No Then, likewise, this aspect of the applicant's submittal is or is not acceptable is acceptable is not acceptable Figure 9.2.29. Worksheet for determination of the magnitude of the 25-year storm event for evaluation of run-on control, 9-117 ------- c... = ci2e of concentration in minuces b = coefficient LO = overland flow length in feet C = run-orr coefficient (see Table 9.2.13) i = rainfall intensity in inches per hour during time of concentration The equation is valid only for laminar flow conditions where Che product iLo is less than 500. The coefficient b is found as follows: 0.0007i -i- C b = r (36) where So = surface slope Cr = a coefficient of retardance Values of Cr, are given in Table 9.2.14. The run-off coefficient (C) is influenced by a number of variables, such as infiltration capacity, interception by vegetation, and depression storage.2 AS used in the rational method, the coefficient C represents a fixaa ratio or' run-off to rainfall, while in actuality it is not fixed and may vary for a specific drainage basin with time during a particular storm, from storm to storm, and with change in season. Table 9.2.12 lists some values of the run-off coefficient for various soils and surface covers. The rainfall intensity (i) is derrved from the average intensity lin/hr) of a jtcm cor a given frequency (25-year in this case) for the time of concentration. Following determination of tc, che rainfall intensity is usually obtained by making use of a set of rainfall intensicy-duration- frequency curves such as shown in Figure 9.2.32. Drawing a line from the abscissa at the appropriate value of tc and then projecting upward to intersect the desired frequency curve, i can be found by projecting this intersection point horizontally to intercept the ordinate. If an adequate number of years of local rainfall records is available, curves similar to Figure 9.2.30 may be developed. Otherwise, data compiled by the National Oceanic and Atmospheric Administration, the Department of Agriculture, or other local government agencies can be used. A more in-depth discussion of surface water run-on and run-off computations using the rational method is presented in References 2 and 3. The SCS Method The SCS run-off equation is a method of estimating direct run-off from storm rainfall of a duration of 1 day or less. The equation is: (P - I )2 3 TT (37) (P - I ) a 9-113 ------- /'ALoc.5 -jf c\ u N —u e" F OJEF-_CIEMT, C Source: Reference 4. Earth Surface Cover Min. Max. Sand, from uniform grain size, no fines, to well graded, some clay or ;ilt Loam, from sandy or gravelly Co - ~ — ^' ^ v Gravel, from clean gravel and gravel sand mixtures, no silt or clay to high clay or silt content Clay, from coarse sandy or siity to pure colloidal clays Bare Light Vegetation Dense Vegetation Bare *• TJ ^ *• ' L,ignc vegecacion Dense Vegetation Bare Light Vegetation Dense Vegecation Bare Light Vegetation Dense Vegecation 0.15 0.10 0.05 •"v o r\ 01 A • iU 0.05 0.25 0.15 0.10 0.30 0.20 0.15 0.50 0.40 0.30 ""* ~ i" O/. ^ • ^J 0.35 0.65 0.50 0.40 0.75 0.60 0.50 NOTE: Values of C for sarth surfaces are further varied by degree of satura tion, compaction, surface irregularity and slope, by character of sub soil, and by presence of frost or glazed snow or ice. TABLE 9.2.14. RETARDANCE COEFFICIENT, Cr Source: Reference 2 Surface type Cr Smooth asphalt 0.007 Concrete paving 0.012 Tar and gravel paving 0.017 Closely clipped sod 0.046 Dense bluegrass turf 0.060 9-119 ------- 10 -V £ t 6 in z UJ z -J 25 z « lOOyaar FREQUENCY 50 year FREQUENCY -"•CG ,'fcur rrJEQUENCY 10 year FREQUENCY 5 y«ar FREQUENCY I 20 40 60 80 DURATION,minutes 100 120 Figure 9.2.30. Typical intensity-duration-frequency curves Source: Reference 2. 9-120 ------- ~vner3 Q = accumulate^ Jirecc run-ofr \in inches; ? - accumulated rainfall (potential maximum run-off). Ia = initial abstraction including surface storage, interception, and infiltration prior to run-off. * S = potential maximum retention. To simplify -isa of the equation, cne following empirical relationship is often used in the SCS run-off equation: I = n '<» a *-* • — 3 . ^ Substituting 0.2S for Ia , the equation becomes: " o = Q P * O.SS and is :he L-ainfaii run-off equation used for estimating direct: run-off from storm rainfall. S values have been transformed into curve numbers (CN) to allow for graphical solution of runoff. Figure 9.2.31, reprinted from Reference 5 (U.S.D.A. Soil Conservation Service, 1973) provides the graphical solution using the curve number method. Research has been conducted to correlate curve numbers with various hydrologic soil cover complexes, as illustrated in Table 9.2.15, also reprinted from Reference 5. If the soil cover complex is not represented in the table, S must be estimated to determine the appropriate curve numoer, using the equation: c» . The regulations for run-on control require that the system be "capable of preventing flow onto the active portion of the landfill during peak discharge from at lease a 25-year storm." The SCS has developed the following equation to estimate peak discharge: qp = (KAQ)/Tp (41) where: q = peak race of discharge A = drainage area Q = 3torm runoff (as determined from Figure 9.2.31) K = a constant , and 9-121 ------- \i\ \ V \ V v \;\: \ \ \; V A r~7$•\\\:\ !\\\\\ \ °A: \ \: \ \ ~ \\\v\\\\\ i\\\\\\\,\V\ ,\\\\\x -3 3 u en e o :NI ^ 1) 3 00 II •J £ jj i- il CJ U 9-122 ------- TABLE 9.2.15. RUN-OFF CURVE NUMBERS FOR HYDROLOGIC SOIL-COVER :OM?L£XES (ANTECEDENT MOISTURE CONDITION II, AND la = 0.2 S) Source: Reference 5 Land use and treatment or practice Fallow Straight row Row crops Straight row Straight row Contoured Contoured Contoured and terraced Contoured and terraced Small grain Straight row Straight row Contoured Contoured Contoured and terraced Contoured and terraced Close-seeded legumes or rotation meadow Straight row Straight row Contoured Contoured Contoured and terraced Contoured and terraced Pasture or range No mechanical treatment No mechanical treatment No mechanical treatment Contoured Contoured Contoured Meadow Woods Farmsteads Roads3 Dirt Hard surface Hydro logic condition Poor Good Poor Good Poor Good Poor Good Poor Good Poor Gooji Poor Good" Poor Good Poor Good Poor Fair Good Poor Fair Good Good Poor Fair Good HM«B Hydrologic it, - — 72 67 70 65 56 62 65 63 63 61 61 59 66 58 64 55 63 51 63 49 39 47 25 6 30 45 36 25 59 72 74 d d6 81 78 79 75 74 71 76 75 74 73 72 70 77 72 75 69 73 67 79 69 61 67 59 35 58 66 60 55 74 82 84 soil group C 91 88 85 84 82 80 73 84 83 32 81 79 78 85 81 83 78 80 76 36 79 74 81 75 70 71 77 73 70 82 87 90 D 94 91 89 88 86 , 32 31 88 87 85 34 32 81 89 85 85 83 33 80 89 84 30 88 83 79 78 33 79 77 86 89 92 Including rights-of-way. 9-123 ------- Tp is the time to peak flow and is calculated as: T = -7- + L (42) where: D a stonn duration, and L = drainage area lag The value of q0 can be approximated by oiaKiag some simplifying assumptions. For instance, the value of qp is maximized as Tp is minimized. For a given storm event, say the 25-year storm, T0 is minimized if L, the lag time, is arbitrarily set equal to zero. Substituting a value of 484 for K will then provide the ^st^atc* ^J ~ha apper aouna on peaK run-on aidcnarge race. If the applicant's calculation of- peak discharge is at least as great using any procedure, the estimate should be conservative. In other cases, the permit writer will have to exercise judgment, or follow the exact computation procedure proposed by SCS for estimating peak discharge rate. In the latter case, it is recommended that the permit writer refer to Reference 5 (Kent - 1973) or 6 (Mockus - 1969). A worksheet for evaluating Che applicant's calculation of peak run-on rate is presented in Figure 9.2.32. Erosion Control Erosion control is an important part of surface water diversion. Vegetation planted near and on the side's of diversion ditches will stabilize the soil. However, vegetation can tate between 1 to 2 years to become firmly established. During that period, mulch and hay bales should be used to stabilize these areas. Mulch can be pegged in place on steeper slopes. Erosion control also prevents siltation that can clog diversion ditches, resulting in surface ponding which should be avoided. References 7 through 11 listed in subsection 9.2.4.5 may be consulted to obtain a more thorough understanding of the erosion control techniques noted above. 9.2.4.4 Draft Permit Preparation— Condition B.3 of Permit Module XV addresses design and operation of run-on control systems. The condition is implemented through reference to a permit attachment that includes plans and specifications prepared for the run-on control system. To be suitable for substitution in the permit condition attachment, the submitted application information should include the following: • Documented hydrologic data identifying peak flow from the upstream watershed area resulting from the 25-year storm event. • All calculations and result.s supporting the design of the run-on control facilities to accommodate the peak flow rate. 9-124 ------- RUN-ON CONTROL Calculation of peak run-on rate for design storm evenc ".".si _hij pare of cne applicant's submitCal been read and evaluated? Yes No """.:; :^_;.;n^uo «a* aaea co calculate Che peak run-on rate — Using this technique, what quantity (note units) or rate and duration of run-on is the proposed system designed to handle n I -independent Check Using the Rational Method — Define Necessary Parameter Values - 1. Surface slope, Sc * 2. Retardance coefficient, Cr = 3. Rainfall intensity during time of concentration, i =• in./hr Calculate the value of b from Eq. 36; b (note data source) 4. Maximum overland flow length, Lo = ft. 5. Run-off coefficient, C =• (from Table ) -~»-Calculate time of concentration, tc from Eq. 35; tc * min Is the value of tc calculated different from the value used in 3. to determine i? ______ Yes No If yea, recalculate i, b, and tc 6. Drainage area, a = acres -^-.Calculate peak run-on rate, Q » Cia * cfs Figure 9.2.32. Worksheet for evaluation of calculated peak run-on discharge rate. 9-125 ------- * nil caJ.culacz.ons and supporting daCa that demons trace the effectiveness of proposed run-on control system maintenance, and repair procedures. 9.2.4.5 References— 1. U.S. EPA. Permit Applicant's Guidance Manual for Hazardous Waste Land Storage, Treatment, and Disposal Facilities. Volume !. Office of Solid Waste, 'Washington, 2.C. .1.533. 2. Clark, J. W., et al. Water Supply and Pollution Control. Second Edition. International Textbook Company. Scranton. PA. 1971. .tessraan, W;, Jr., et al. Introduction to Hydrology. Intext Educational Publishers, New York. 1972. 4. Seelye, E. £. Data 3ook for Civil Engineers-Design. John Wiley and Sons, Inc. New York, NY. 1960. 3. I-ient, K. M. A Method for Estimating Volume and Rat a of Runoff in Small Watersheds. J.o. Department of Agriculture, Soil Conservation Service. SCS-TP-149. Revised April 1973. 6. Mockus, V. National Engineering Handbook. Section ^ - Hydrology. Chapter 10. Estimation of Direct Runoff From Storm Rainfall. U.S. Department of Agriculture, Soil Conservation Service. Reprinted with Minor Revisions, 1969. 7. U-S. EPA, Erosion and Sediment Control, Surface Mining in the Eastern U.S., Part 2, Design.- EPA Report 625/3-76-006. October 1976. 8. L'.S. EPA, Design and Construction of Covers for Solid Waste Landfills. Municipal Environmental Research laboratory, EPA Report 600/2-79-165. August 1979. 9. Brown, K. W. and Assoc., Inc. Hazardous Waste Land Treatment. Prepared for the U.S. EPA, Municipal Environmental Research Laboratory. Second Edition. SW-874. February 1983. 10. U.S. EPA, Process Design Manual for Land Treatment of Municipal Wastewater, EPA Technology Transfer Series, EPA Report '625/1-77-008, October 1977. 11. Brady, N. C., The Nature and Properties of Soils - 8th Ed. McMillan Publishing Company, N.Y., 1974. 9-126 ------- 9.2.5 Control of Run-off 9.2.5.1 The Federal Requirement— As part of the applicant's detailed plans and engineering report, §270.2Kb) (3) requires the submission to address "control of run-off." The Part 264 standards for run-off control specify in §264.301(d) that: llThe —»-ner jr operator uius c uesign, construct, operate, and maintain a run-off management system to collect and control at least the water volume resulting from a 24-hour, 25-year storm." 9.2.^,2 Summary •>? "-^cassary Application j.nrormation— The Part B Manual 1 instructs the applicant to conduct the following procedures and submit the results in the application: • Determine the peak flow rate and run-off volume associated with at least a 24-hour, 25-year storm over the landfill, • Size and design run-off collection facilities to collect at teast cnis water volume, • Size and design run-off storage facilities to accommodate the calculated runoff volume 0 Devise a plan for run-off system maintenance, restoration, and repair. 9.2.5.3 Guidance on Evaluating Application Information— To avoid migration of contaminated.run-off, facilities must be designed and operated to collect and control surface run-off from the active portion of the landfill. The technical issues of concern are presented in Figure 9.2.33. 9.2.5.3.1 Magnitude of the 24-Hour, 25-Year Storm Event—Facilities must be designed to handle the run-off volume associated with at least the 24-hour, 25-year storm. Figure 9.2.34 indicates the depth of rainfall for this event throughout the United States.2 A worksheet for evaluating the magnitude of the selected storm event is presented in Figure 9.2.35. 9.2.5.3.2 Calculation of Run-off Volume—The volume of runoff expected for this storm event can be calculated using the SCS Method or the Rational Method, as described in subsection 9.2.4.3. The Part 264 regulations for run-off require that the run-off management system "collect and control at least the water volume resulting from a 24-hour, 25-year storm." Since the rational method calculates peak discharge, use of the SCS method may provide a more straightforward approach to calculating the total run-off water volume associated with the design storm event. First, Q is estimated using the graphical method shown earlier in Figure 9.2.31. Then, the total run-off volume associated with the storm event is approximated as: V « ^ (43) 9-127 ------- RUN-OFF CONTROL SYSTEM DESIGN AND CONSTRUCTION SYSTEM OPERATION AND MAINTENANCE DETERMINATION O17 MAGNITUDE/INTENSITY OF 24-HR, 25-YEAR STORM EVENT INSPECTION REQUIREMENTS CALCULATION OF RUN-OFF VOLUME FROM DESIGN STORM EVENT MAINTENANCE DESIGN OF RUN-OFF COLLECTION/DIVERSION SYSTEM MANAGEMENT OF HOLDING FACILITY TO MAINTAIN DESIGN CAPACITY DESIGN OF RUN-OFF HOLDING OR TREATMENT FACILITIES TANKS - SEE SUBPART J GUIDANCE MANUAL IMPOUNDMENTS -SEE SECTION 6.0 INSPECTION DURING CONSTRUCTION Figure 9.2.33. Technical issues associated wich run-off control, 9-128 ------- 0) -C u 01 01 •9 u-l C •H d) Ij u eg 0) r u 3 O 01 u 3 1) CJ e 01 ai 1) u 3 33 03 0) 3 0) O 3 O 9-129 ------- RUN-OFF CONTROL Determination of Magnitude/Intensity of 24-hr,. 25-year 5conn event — Has this part of the applicant's submittal been read and •=5val::sC5-i'? — What storm magnitude was selected by the applicant? —• What depth of rainfall is this storm event equivalent to? based on what reference(s) Independent Check j— Vhat is the rainfall depth associated with the 24-hr, L 25-year storm - based on what reference Is the rainfall depth established by the applicant at least as great as this determination? Yes No i nc he s inches Yes Then, likewise, this aspecc of the applicant's submittal is or is not acceptable is acceptable is not acceptable Figure 9.2.35. Worksheet for evaluating the magnitude of the selected storm event. 9-130 ------- where: V is in fc3| and A " area of Che active landfill portion in square feet The average flow race can be approximated by assuming that this quantity of run-off flows for a duration of 24 hours. If peak discharge is of concern or used as a design basis in the applicant's presentation, then the computation techniques specified for determining neak r-m-on -ate vould oe apclicabla. A worksheet for evaluating run-off volume computations is presented in Figure 9.2.36. ^ii Q£ ^an-o£f Coj.lect3.on/Di-/ersLon System--Phis design will be site specific depending on topography, site layout, and other factors. These facilities may include an open channel with an impervious floor flowing by gravity to a collection or storage basin. Alternatively, if the topography is less favorable, collected run-off may have to be pumped at some point where continued gravity flow is no longer possible to lift the collected run-off into a storage tank or -impoundment. Such storage is envisioned to be necessary to allow for determination of whether the collected run-off is hazardous. The management of these storage facilities is discussed in Section 9.2.6 which follows. If the applicant proposes to divert and collect stormwater run-off by installation of an open channel or culvert, it will be necessary to check the proposed dimensions to assure that the design run-off volume can be carried wicnout overtopping of the channel. Further, since run-off from the active area is considered hazardous, this channel will have "to be considered as an extension of the surface impoundment or tank accepting the flow, and designed in accordance with the Part 264 regulations for such facilities. Open channel flow can be calculated using the Manning formula, wherein: Q=_L_AR2/3sl/2 (4A where: n = Manning's roughness coefficient A = cross-sectional area of flow R = A/WP, the hydraulic radius (where WP = the wetted perimeter), and • S a che channel slope. Values of n for a variety of surface materials are listed in Table 9.2.16, from Reference 3. 9-131 ------- RUN-OFF CONTROL Calculation of run-off volume from design storm event — Has this part of the applicant's submittal bean read and evaluatad? Yes What technique was used to calculate run-off? Using this technique, what quantity (note units) or rate and duration of run-off is the proposed system designed to handle? Independent Check Using the SCS Method Define parameter values: • Select a value of S 1000 • Calculate CN from CN * 10 * S Is the run-off volume presented in terns consistent with the regulation, i.e., the run-off volume associated with the 24-hour, 25-year storm? Yes Mo • Interpolate Q from Figure 9.2.33 inches •Calculate V, volume of run-off: • A a active portion area = sq.ft, • V » QA/12 = cu.ft, Is the volume of run-off used as the design basis at .least as great? Yes No Figure 9.2.36. Worksheet for evaluating run-off volume computations 9-132 ------- lA^N ING'S ?,CUGHN Source: Referen Nature of surface Nflat cement -urfaca Wood-stave pipe Plank flumes, planed Metal flumes, smooth Concrete, precast Cement mortar surfaces ''lank flumes, unpianea Jommon-clay drainage tile Concrete, monolithic Brick with cement mortar Cast iron Cement rubble surfaces Riveted steel Canals and ditches, smooch earth Metal flumes, corrugated Canals : Dredged in earth, smooth In rock cuts, smooth Rough beds and weeds on sides Rock cuts, jagged and irregular ca 2 Min 0.010 0,010 0.010 0 010 \J • w *, W 0.011 0.011 0.011 0.011 0.011 0.012 0.012 0.013 0.017 1.017 0.017 0.022 0.025 0.025 0.025 0.035 FFICIENT n Max 0.013 0.013 0.014 0.017 \J • ^ JL / 0.015 0.013 0.015 0.015 0.017 0.016 0.017 0.017 0.030 3.J20 0.025 0.030 0.033 0.035 0.040 0.045 9-133 ------- 9.2.5.4 Draft pp.rnit ^-^csratiJr.— ;dS-L5n ana operation or run-orr :oncroL .systems are discussed in Permit Modules XV, Condition B.3. The condition i~ implemented ciirough reference to a permit attachment that includes plans and specifications for the proposed run-off control jystem. To oe suitable for substitution in Che permit condition attachment, the submitted application information should include the following: • Local weather service data that identify the magnitude (inches) of the 24-hour, 25-year event. • All final calculations identifying he peak flow rate and run-off volume associated with the 24-hour, 25-year event. .'.11 -i.iai calculations demonstrating the adequacy of the storage facilities to accommodate che calculated run-off volume. • All final calculations and supporting data that demonstrate the effectiveness of the run-off control system maintenance, restoration, and repair plan. 9.2.5.5 References 1. U.S. EPA. Permit Applicants' Guidar. :a Manual for Hazardous Waste Land Storage, Treatment, and Disposa* Facilities. Volume I. Office of Solid Waste, Washington, B.C. 1983. 2. U.S. Weather Bureau, 1961b, JLaiafall-frequency atlas of the United States for durations from 30 minutes to 24 hours and return periods from 1 to 100 years, Tech. Paoer 40. 3. Daugherty, R. L., and J. B. Franzini. Fluid Mechanics with Engineering Applications. Sixth Edition. McGraw-Hill Book Company. New York. 1965. 9.2.6 Management of Units Associated with Run-On and Run-Off Control Systems 9.2.6.1 The Federal Requirement— According to § 270.21(b)(4), the applicant's submitted information must explain his intended methods of: "Management of collection and holding facilities associated" with run-on and run-off control systems" The standards of §264.301(e) require that: "Collection and holding facilities (e.g., tanks or basins) associated with run-on and run-off control systems must be emptied or otherwise managed expeditiously after storms to maintain design capacity of the system." 9-134 ------- 9.2.6.2 Summary of Vecassarv .-.oo : -ca<- :.cr. "rf The applicant must prepare a plan for dewataring of collection or holding facilities associated with run-on and ,'^n-orf management systems to assure maintenance of system capacity. The time required co empty the racintias must be estimated and the method of disposal of collected run-off (i.e., treatment, evaporation) must be described. 9.2.6.3 Guidance on Evaluating Application Information— Run-off from the active landfill area must be assumed to be hazardous because it may have leached hazardous const! :uanc- from :;ie waste or it may incorporate aazaraous leachaCe. To manage the run-off properly, it will be necessary to store the collected run-off in a tank, container, or surface impoundment to allow for treatment or to allow for testing to determine if the collected run-off is not hazardous. To ^r^-.'-'ds -"~r .i-her Circumstance, these =,i-.:illcloj .nusc oe designed, constructed, and operated in conforraance with the Standards of Part 264. The permit applicant must adequately demonstrate his proposed method of emptying or otherwise managing run-off collection facilities after storms to maintain the design capacity of these systems. Run-off facilities must be sized to store the run-off expected from the 25-year, 24-hour storni. There are two general approaches for -neeting this requirement. One aooroach is to design the impoundment to contain rainfall run-off collected from previous storms as well as the specified event. The impoundment is managed such that there is no net change in the volume of run-off stored on a long-term basis. • A second alternative is to size an impoundment for the run-off expected from the specified storm and keep the impoundment empty. During and/or following a storm, the impoundment contents are drained to a second impoundment designed for long-term storage. In orier to minimize the potential for overflow, the first impoundment must be dewatered as quickly as is practicable. In demonstrating the emptying procedure, the applicant should identify and describe the function of any level sensing devices and automatic and manually operated controls. Level sensing devices generally incorporate floats or electronic' or pressure sensitive probes. The sensors can be used to automatically activate pumps and/or valves used in dewatering the impoundment. Level sensors can also be wired into an alarm system which will alert plant personnel when the water level reaches a predetermined height. The management plan must account for sediment buildup in the impoundment(s). Periodic dredging may be necessary to maintain the design capacity. Therefore, the applicant should indicate the dredging equipment to be used and the expected dredging schedule. The applicant must describe the treatment/disposal method(s) to be used for collected run-off. Several options are available. Run-off can either be treated and released via a National Pollutant Discharge Elimination System (NPDES) Permit, or treated in a zero discharge system. The regulations require diversion of run-on as opposed to collection. Therefore, an adequate monitoring and inspection plan for run-on facilities 9-135 ------- will often be adaquata co ae^on? cr-:::• :r^rar .r.anagement 3 f these svscems. .iowever, some part of the applicant s submitcal should designate how the system will be maintained if prcoiems are round during inspection. The permit application should contain a description of the inspection program to be implemented for run-on and run-off handling facilities. This description should be included in the inspection plan submitted as required under § 270.14(b)(5)• At a minimum, the program must include provisions for inspecting weekly and after storms to detect evidence of deterioration, malfunctions, or improper operation ; f .r.s run-on and run-off control systems. The permit applicant should identify what actions will be taken when systems are found to be operating incorrectly or not at all. Also. or»ventiv~ procedures to be implemented, ------- MANAGEMENT OF "NITS. ASSOCIATE -ITH ^'JN-^f •;:~ r/J'-:?? JC,-;7?vuL aYSTSMS Has this part of the applicant's submittal been read and evaluated? Is an inspection schedule provided for identifying and correcting run-on or run-off collection system problems? yes no yes no Are provisions made for maintaining the capacity of the run-on and run-off collection systems? yes Doss rha ut-piiv-acion aescnoe how run-off will be scored, treated, or disposed? yes no no Are automatic controls and/or alarm systems used to initiate emptying procedures and alert personnel to yes no potential problems? Does the run-off management plan include provisions for testing run-off for hazardous components? yes no" Does the application describe how run-off found to be hazardous will be managed? yes no Figure 9.2.37. Worksheet for determining the adequacy of the applicant's plan to manage units associated with run-on and run-off control. 9-137 ------- dust from 'jnp.aved haul roaas ana excav^- -, --i ic:_.-._^ = o. .he acoli-ant snouia describe mecnoas ot concrcl, such as cnemicai scaoil izers , vegetative covers, or wee suppression, and should estimate Che efficiency of the proposed wind aispersal control method. 9.2.7.3 Guidance on Evaluating Application Information — Particulate matter entrainment due to wind dispersal must be controlled during the active life of the facility and during the closure and post-closure care periods. A flow chart indicating the applicability of che part 26^ requirements is presented in Figura Q.1.38. Several options are available to control wind dispersal of particulate matter, as illustrated in Figure 9.2.39. Options listed below may be implemented individually or in ^crabir.atior. is r^qui^ec 1.0 prevent fugitive (a) reduction of wind-speed (wind breaks), (b) use of dust suppressant (chemical or water-amended spray application) , (c) establishment and Tiaintanance jf a vegetative cover, (d) maintenance of soil moisture (periodic irrigation). Susceptibility to wind dispersal is directly related to the moisture content of soils. Keeping the soil motst reduces the potential for wind dispersal of particulate matter. In addition, by rougning the soil surface, che wina velocity can be decreased and- some moving particles trapped. Barriers such as tree shelterbeds are effective in reducing wind velocities for short distances ana for trapping drifting soil. Picket fences and burlap screens, while less efficient as windbreaks than trees, are often preferred because they can be moved from place to place as portions of the facility open and close. Other factors that will affect particulate matter dispersal are local prevailing wind direction, type of waste to be disposed, and operating techniques to be employed ac the site. Familiarization with eacn of these will enable proper steps to be taken to minimize the effects of wind dispersal. Establishing a wind break at the edge of the site, perpendicular to the prevailing wind direction will lessen wind speeds across the unit. Use of a dust suppressant, such as water, on dry, powdery wastes will. help control dust generation during waste disposal. Also, scheduling disposal activities to avoid periods of excessive wind speed and turbulence and atmospheric instability will control wind dispersal. The technical adequacy worksheet for determining the suitability of the applicant's plan for controlling wind dispersal is presented in Figure 9.2.40. 9-138 ------- DOES OR WILL THE LANDFILL CONTAIN ANY PARTinil ATF MATTFR ^!lfl IPTT , C 1 < NO * i 5r tRjAL. ./ THE \ NO ^ REGULATIONS j nr(£ NOT (^APPLICABLE YES _L ARE WIND DISPERSAL CONTROL METHODS PROPOSED SUCH AS LANDFILL COVERS OR OTHER MANAGEMENT PROCEDURES NO ARE THE CONTROL METHODS ADEQUATE TO PREVENT PARTICULATE DISPERSAL X THE PLAN IS TECHNICALLY JNAD EQUATE THE PLAN S TECHNICALLY ADEQUATE Figure 9.2.38. Regulations applicable Co the concrol of wind dispersal of particulate matter at hazardous waste landfills. 9-139 ------- APPLICATION OF COVERS INTERMITTENT OR TEMPORARY COVERS FINAL COVER COVER MAINTENANCE AFTER CLOSURE DESIGN OF WIND rMSPERSAL CONTROL SYSTEMS OTHER MANAGEMENT TECHNIQUES WIND BREAKS OUST SUPPRESSANTS INSPECTION REQUIREMENTS DURING OPERATION Figure 9.2.39. Wind dispersal control options, 9-140 ------- MANAGEMENT OF WIND DISPERSAL Has this part of che applicant's subraittal been read and evaluated? ves no Is ^rosion pocentiai addressed for: Waste materials? yes no Landfill cover? yes no Unpaved haul roads? yes no Excavation activities? yes no Are control methods described (e.g., chemical stabilization, vegetative covers, wet suppression, wind breaks, etc.)? ' yes no Is particulate control efficiency estimated for each control method? yesJ^~ Are waste disposal operations suspended during excessively high winds? ves ~ Figure 9.2.40. Worksheet for evaluating the adequacy of wind dispersal control measures. 9-141 ------- 3...~.- 3rafc Permit Preparation— As noted in Module XV, Condition 3.5, :he permit snould soecifv -nechods for concroLliag wind dispersal if the landfill contains partLCjlace ^ac:ar vnich may be subject co wind dispersal. This condition is implemented througn reference to a permit attachment that includes plans and specifications for the proposed wind dispersal control measures. Submitted application information suitable for substitution in the permit condition attacnment should include the following: * A -^acnpcion of areas where wind dispersal controls are applicable. • A description of methods used for wind dispersal control. '•'ir.d -ispersal concroi efficiency estimates, along with calculations and supporting data. 9.2.8 Subpart F Exemption 9.2.8.1 The Federal Requirement — The Part 770 information requirements state in §270.21(c) that: "If an exemption from Subpart F of Part 264 is sought, as orovided by §264.302(a), the owner or operator must submit detailed plans and an engineering report explaining the location of the saturated zone in relation to the landfill, the design of a double-liner system that incorporates a leak detection system between the liners, and a leachate collection and removal system aDove the liners." The taxt of §264.302 specifies the requirements for double-lined landfills designed for exemption from^Subpart F ground water protection requirements. This section of the regulation states that: "(a) Tha owner or operator of a double-lined landfill is not subject to regulation under Subpart F of this part if the following conditions are met; (1) The landfill (including its underlying liners) must be located entirely above the seasonal high water table. (2) The landfill must be underlain by two liners which are designed and constructed in a manner to prevent the migration of liquids into or out of the space between the liners. Both liners must meec all the specifications of §264 .301(a) (1) . (3) A leak detection system must be designed, constructed, maintained, and operated between the liners to detect any migration of liquid into the space between the liners. (4) The landfill must have a leachate collection and removal system above Che top liner that is designed, constructed, maintained, and operated in accordance with § 264.301(a)(2). (b) If liquid leaks into the leak detection system, the owner or operator must: 9-142 ------- 1,' Mocny c.i------- IS AN EXEMPTION FROM PART 264, SUSPART F SOUGHT? NO iNFiRM COMPLIANCE WITH PART 264, SUSPART F ,YES IS DOCUMENTATION INCLUDED PROVING THAT LANDFILL AND LINERS ARE ENTIRELY ABOVE THE SEASONAL 4MH WATZR 7A3LET ,Y£S DOES THE DESIGN PROVIDE FOR TWO LINERS UNDEP. ~H£ LANDFILL? NO YES WILL THE DESIGN AND CONSTRUCTION OF THE LINERS PREVENT LIQUIDS FROM GETTING INTO OR OUT OF THE SPACE BETWEEN THE LINERS? .YES DO 80TH OF THE LINERS MEET OF THE §264.301(a)(1) SPEC \t .YES DOES THE DESIGN PROVIDE FOR THE INSTALLATION AND OPERATION OF A LEAK DETECTION SYSTEM BETWEEN THE TWO LINERS? NO YES DOES THE DESIGN INCLUDE A LEACHATE COLLECTION AND REMOVAL SYSTEM ABOVE THE TOP LINER THAT MEETS ALL THE §264.301(a)(2) CRITERIA? \ r NO YES DOES THE SUBMITTAL INCLUDE A PLAN FOR REMOVAL OF WASTES AND LINER REPAIR OR IMPLEMENTATION OF A DETECTION MONITORING PROGRAM IF LIQUIDS LEAK INTO THE LEAK DETECTION SYSTEM? THE PLANS ARE TECHNICALLY ADEQUATE Figure 9.2.41. Applicability of Part 264 requirements co the Subpart F exemption. 9-144 ------- r=~2rr?-J "o — '- ;, u i.: a r. c a provic^a -n suosectisn ? . 2 . 1 . j . ~ rcr evaluation of information on water caoLe elevation and to suosection 9.2.1.3.2 for guidance on Liner -naterials, cnemical properti.es, and liner strength and thickness. To evaluate the adequacy of the leak datsction system and/or the leachate collection system, the permit reviewer is referred to subsection 9.2.2.3 which provides guidance on system design and materials, chemical resistance, pipe strength and thickness, and media/pipe clogging. Although resistivity probes could be used for leak detection systems, the Agency strongly recommends that drainage media and piping be designed into the svstera as for leachate collection «"scsn!3. If 1 ;:.'kage occurs, cnen a system will be in place for leacnace collection and removal. The technical adequacy worksheet for determining che sui tab-.l itv if -^* apoiicane'« ->lin fcr -r>. -x^npt: i.;r. j.-on: -uoparc c' j.s presented in rigura }.L.-+2. Worksheets incorporated in subsections 9.2.1.3 and 9.2.2.3 should be used first to assess the adequacy of liners, leak detection systems, and leachate collection systems. 9.2.3.4 Draft Permit Preparation— As noted in Condition C of Permit: Module XV, permit applications that satisfy the exemption requirements should be documented in tha administrative record. The cermc shouia include, oy attachment, design and operating conditions for double liners, leachate collection and removal systems, and leak detection systems. Design and operating conditions pertinent to leak detection and subsequent required actions should be highlighted in the body of the permit. 9,2.8.5 References — 1. U.S. SPA. Permit Aoolicancs' Guidance Manual cor Hazardous Waste Land Storage, Treatment and Disposal Facilities. Volume I. Office of Solid Waste. Washington, D.C. 1983. 9-145 ------- SUBPART F EXEMPTION das this part of the applicant's subraittal been read and evaluated? Yes Mo Is hydrologic data provided which indicates the location of the seasonally high ground water table relative to vas "o Che landfill? Is the landfill and liner system completely above he high water table at all times? vas v,~ -oas ar.e xiner system design prove suitable based on use of the evaluation procedures and worksheets Yes~~No~ incorporated in subsection 9.2.1.2? Do the leaK detection and leachace collection system designs prove suitable based on use of :he evaluation Yes No procedures and worksheets incorporated in subsection Figure 9.2.42. Worksheet for determining adequacy of applicant's submitcal for an exemption from Subpart F. 9-146 ------- 9.3 INSPECTION1 .-.Iv'JlAS'iSNTS 9.3.1 The Federal Reg--: Iranian: 3 Part 270 requires the applicant to provide the following information on landfill inspection. "270.21(d) A description of how each landfill, including the liner and cover systems, will be inspected in order to meet the requirements of ??5-'i 102'j} ,nd •'•)}. Thij .;:iormation should be included in the inspection plan submitted under §270.14(b)(5)." The relevant standards of §264.303 specify: '(AJ During construction or installation, liners (except in the case of existing portions of landfills exempt from §264.301(a) and cover systems (e.g., membranes, sheets, or coatings) must be inspected for uniformity, damage, and imperfections (e.g., holes, cracks, thin spots, or foreign materials). Immediately after construction or installation: (i) Synthetic liners and covers must be inspected to ansure tight seams and joints and che absence of tears, punctures, or blisters; and (2) Soil-based and admixed liners and covers must oe inspected for imperfections including lenses, cracks, channels, root holes, or other structural non-uniformities that may cause an increase in the permeability of the liner coiter." §264.303(b) states: '(b) While a landfill is in operation, it must be inspected weekly and after storms to detect evidence of any of the following: (1) Deterioration, malfunctions, or improper operation of run-on and run-off control systems; (2) The presence of liquids in leak detection systems, where installed to comply with$264.302; (3) Proper functioning of wind dispersal control systems, where prasent, and (4) The presence of leachate in and proper functioning of leachate collection and removal systems, where present." 9.3.2 Summary of Necessary Application Information The Part B Permit Applicants' Manuali instructs the applicant to develop and submit with the application a detailed written inspection schedule. The applicant is referenced CO the Permit Applicants' Guidance Manual on th« General Facility Standards for instruction on preparation of the inspection plan. The latter manual recommends that the applicant submit the actual inspection log that he proposes to use for day to day inspection activities. 9-147 ------- 9.3.2 Guiaance_ ^n -Zv a I : a c •. • 2 Arc'.. :g;-. jn !.: ~ jnacior. Figure 9.3.1 presents a flow cnart identifying standards applicable to inspection of the landfill. 9.3.3.1 Introduction— The requirements of §264.303 identify specific inspections relevant to landfills that must be included, in addition to the general inspection requirements, as part of the overall inspection plan required by 5 2"'Q. 14CbN (* 1 and $264.15. Tb« insoectisn -rccac-rss ;-:arai:caa cc -omply with §264.303 requirements should address inspections conducted during three time periods. • before/during construction * after construction • during operation The first sentence of §264.303(a) requires inspection during construction or installation of liner and cover materials that will be placed in a new landfill. The intent is to prevent the liner or cover from failure caused from improper installation or use jf poor quality materials (see subsection 9.3.3.3). Inspection after installation is also required by §264.303(a)(1) and (2) (see subsections 9.3.3-4 and 9.3.3.5). The intent is to insure that the quality of construction is sufficient to avoid liner or cover failure. Although not specifically stated, che intent of §264.303 is to allow for rejection or rapair of che liner or cover system materials before or after they are installed if they do not conform to specifications. Therefore, in addition to describing the inspection methods, che permit application should include a description of actions that will be taken if the materials are found to be damaged or imperfect, or if the construction techniques or installation procedures prove to be unacceptable. As part of an overall inspection plan, the owners or operators should identify, by name or title, a qualified person wno will be responsible for conducting the inspection. The various materials rcanufacturers/suppliers and installation contractors involved in the construction of a landfill will typically conduct various QA/QC and inspection procedures established as a result of their experience. However, the owners or operators should indicate the presence onsite of at least one qualified inspector who represents only their interests and from whom approval of procedures or inspection results must be obtained before construction activities can proceed, or the installed facilities can be accepted for operation. During evaluation of the application, the permit application reviewer should a*k Che following questions to determine the adequacy of proposed inspection procedures. 9-148 ------- ce t- oo o1 Z LU < a -j < T j — ** : oj J 1 u. 1 ^ I ~" h ; , I U L J 3 • 1 £ < I ± z u J ^• oo 00 LU >-! o ej Z oe 1 J £ 2 c? '~j LU OO • Q- _l C on < - c_ K 3 Z — Q •~ • oe H i- a < — <^ U- S ae Z 00 Q r i. IJ — LU LU H- H- VI 1- Z < O oo — — 1 Q- >• — 1 O 00 O < 0£ Z H- o. ae < oo ^ oo > >- — PROCEDURE NER AND CO LU — oe -j Z 3 L. S 3 OO UJ >- O Z H- '— j ce LU> O a. u. OO Z •/! "~ Q» LU ae ^ 0 0 U. (_> a a PROPOSE NERS AN <*^ oo ^i PROCEDURE SYNTHETIC LU ae < i 1 J X LU H- u. < >- H- — o- - _ — oe S z ^ oo LU >- O z 00 0 1 Z V _ — Q (_> o- '— 3 UJ '5- CJ < L LU e fl^ y^ | i. H- £ — u _i oo as a. — Z LU . •^ * Z « c 5 •" ^ LJJ ae 3 ae r p o ae U. Q U. '_Lj LU a x ; li. UJ — O LU oo s _ oo O Q I— < a. < < uj O -J ae oe a _i i_> fl- Z < z < i- oo oo PROCEDURE SOIL-BASED LU C S i C Z Q - — J 2 e o LI -3 is " K- e u > 3 c_) oo LU ^ OO •^ o r™* O i ii •^ *y> Z ^" ae o L» /-\ PROPOSEI *j^ PROCEDURE! UJ ae < ' r*« to <^K i o ae UJ t < i < WEEKLY I , : oo UJ >* 1 •o m o u J *M O sj a. a. CO u CO 0) I* 30 9-L49 ------- Do cha inspection procedures indicate; (1) When (i.e., at whac scage of construccion; prior 1:0 che firsc addition of waste, Che specific procedures will be implemented? (2) Why che procedures will be implemented? (3) What specific items will be inspecCed? (4) How che icems idencified will be inspecced? (5) What conscicutes failure as a result of insoaccinn? (b) What corrective actions will be instituCed upon failure? (7) What records of Che inspections will be maintained? In §264.303(a), che term "liners ... and cover systems" is used to identify whac is incanded for inspection. AC a landfill, these "systems" may consist of multiple layers of soil and nonsoil materials. It is che intenc of 'rhe -egulacion chac all oiacenais used Co construct che various layers of liners or covers be inspecced during and after installation. The remainder of this section addresses the procedures chat should be included in an inspection plan to adequately comply with the inCencions of §264.303(a) regarding inspeccion of liner and cover layers. 9.3.3.2 Is r.ha unit an axiseing landfill? — A definicion of "existing porCion." can be found in §260.10. A.ny portion of a landfill which does ioc -neeC che criteria for existing is new and must be inspecced during and after construction of liner and leachate collection systems (see subseccions 9.3.3.3 chrough 9.3.3.5). Existing portions are not required to have liners but muse scill be inspecced on a regular basis during operation (see subsection 9.3.3.6). The definicions in §260.10 for "active portion," "closed portion," "exiscing hazardous waste management facility," "facility," "inactive portion," "landfill," "landfill cell," and "partial closure" may aid che perraic applicacion reviewer in confirming Che identification of new and existing portions of a landfill. A worksheet for evaluating the applicant's submittal in Cerras of general inspeccion information requirements is provided in Figure 9.3.2. 9.3.3.3 Doea the application contain a description of procedures for impacting liner and cover sy^Cem materials for uniformity and integrity during installation? — 9.3.3.3.1 Introduction—Figure 9.3.3 is a chart of topics presented in this part. The topics address each of the various layers thac could typical I/ be a pare of any liner or cover system at a landfill. '9-150 ------- INSPECTION REQUIREMENTS Has chis part of the applicant's submittal been reviewed and evaluated? Yes No Does the application include a detailed, written inspection schedule? Yes No Was a copy of the actual inspection log submitted? Yes No Does the i?p' :- -at icn include -nspec^ion ^rccaaures for tne time period: • Before and during construction? Yes No • After construction? Yes No • During operation? Yes No Does the inspection plan indicate actions to be taken if materials are found to be damaged or imperfect? \>3S No Does the inspection plan name a qualified person for conducting che established inspection procedures? Yes No If the liner and cover systems are composed of multiple layers, do inspection procedures provide for inspecting each layer Yes No during and after installation? Does the plan call for inspection of existing portions of the landfill as well as new areas? veg s;0 Figure 9.3.2. Worksheet for determining the adequacy of general inspection information. 9-151 ------- PENETRATIONS, FOOTINGS, PERIMETERS LINER AND COVER SYSTEM INSPECTIONS BEFORE AND DURING INSTALLATION IN SITU SOILS FOUNDATION MATERIALS STERILIZATION SYNTHETIC SHEET AND MEMBRANE FLUID LINER MATERIALS APPLICABLE TO BOTTOM AND TOP LAYERS LEAK DETECTION/ LEACHATE COLLECTION SYSTEM MATERIALS DRAINAGE/ PROTECTIVE LAYER MATERIALS VEGETATIVE SUPPORT LAYER MATERIALS SOIL-BASED AND ADMIXED VEGETATION SPECIES Figure 9.3.3. Inspection of liner and cover syscera materials before and during installation. 9-L52 ------- A single Liner landfill will consist of zhe following Layers; • In-sicu soils • Foundation materials • Liner materials • Leachata collection «,v,?cem -.iC3"iai- • Drainage/protective layer materials A double lined landfill viil have ".h« £o ^-<»•• r.g :iai: -o.-i.ii .a^ers; • Leak detection system materials • Drainage/foundation layer raaterials These additional layers wo..Id be installed above the foundation materials and below che liner materials of a single liner landfill. A cover system designed as a final cap for a landfill will consist of che following layers; • Vegetative support layer materials • Filter layer materials • Drainage layer materials • Bedding layer materials • Synthetic membrane layer materials • Low conductivity clay layer In some cases che filter and bedding layers may be omitted. In other cases a bedding layer must also be included between the synthetic and underlying clay layers. The low conductivity clay layer will typically be placed directly over the waste materials at closure. The construction materials and inspection procedures for liner systems and cover systems will be very similar (if not identical) at many landfills. The guidance her* on inspection procedures is organized according to the materials of each layer in a liner system. The inspections that should be implemented before and during installation of a layer are identical regardless of whether the layer is in a liner or a cover system. (Inspections after installation are discussed in subsections 9.3.3.4 and 9.3.3.5.) The correspondence between liner system layers and cover system layers is shown in Table 9.3.1. 9-153 ------- TABLE 9.3.1. EQUIVALENCE OF LINER AND COVER SYSTEM LAYERS IN CONSIDERATION OF INSPECTION REQUIREMENTS Liner system layers Cover system Layers In-siCu soils Foundation materials Lower liner materials in a double lined landfill laak detection system materials Upper liner materials in a double lined landfill Liner materials in a single l-'.r.ed landfill Leachate collection system materials Drainage/protective material3 No equivalent No equivalent Bedding materials Impermeable materials No equivalent Synthetic membrane materials Synthetic membrane materials No equivalent Filter and drainage materials Vegetative support material alnstalled above any liner 9-154 ------- ->i2ra equivalency LS me icacad , the inspection procedures discussed here are applicable Co both the liner and cov=r layers idenc.Jiea. 9.3.3.3.2 In-3itu Soils — Preparation of tne existing land surface sefore conscruction of a landfill cell does noC typically require complex procedures. However, inspection during construction should be conducted. These inspection procedures should confirm that: • The in-sicu soils have been orooerly j irregularities and rocks have been removed. • The finished surface is not closer to the water table Chan presented in the original olans. • The horizontal dimensions of the prepared surface agree with Che original plans. • There is no water or other liquid, noc previously anticipated, on the finished surface. • There are no previously unidentified strata or geologic formations present thac would jeopardize the function of Che Liner system. It is important to determine the moisture content of the layer before it is covered by an overlaying layer. This is especially true in areas where Che layer will be exposed to freeze/thaw cycles. The inspection procedures should provide for postponement of construction when precipitation occurs. Any standing water or dampness should be removed before construction continues. 3 Other important concerns are the presence of organic materials, gas pockets, or soluble soils. 3 if anv of these are present in the in-situ materials, they can have a detrimental effect on all overlying layers. Thus, the inspection procedures should provide that the inspector will either conduct or observe tests to confirm Chat organic materials, gas pockets, or soluble gas are not present at or near the surface of the in-situ materials. The corrective actions to be taken if these materials are identified should be described . 9.3.3.3.3 Foundation Materials — Once Che bottom surface has been prepared, foundation materials that will support the actual liner are put in place. During construction of the foundation, the inspection procedures should provide for confirmation of the following items: • Materials are in conformance with plans and specifications. • Procedures for placing materials are appropriate. • Compaction equipment and procedures conform to plans. • Work is being conducted only during appropriate weather conditions. 3, 4 9-155 ------- • Irregularities in materials or procedures are aadressea appropriately as they are encountered. In a cover system, bedding materials may be installed over lower impermeable materials (see subsection 9.3.3.3.4) to provide a foundation for the overlying synthetic membrane. In other cases, the impermeable materials in a cover system may be such that bedding materials are not necessary below the synthetic membrane layer. Regard! as.? ~:i vnich .3 tr.e case, tne five items liatad above should be identified in inspection procedures relevant to any layer immediately below the synthetic membrane layer. Depending on the design of the la-ndf: 1'. - = '1, :r.a L.aer ^yscem or cne ccvar system .-nay oe penetrated by or placed over footings, pipes, or other appurtenances.3 ,4 Further, depending on how the liner or cover will be secured at the perimeter of the landfill, ic may be necessary to prepare the perimeter for liner or cover system attachment. This preparatory work is most important when the liner or cover layer is a synthetic membrane or material. The permit application reviewer should confirm that the inspection procedures that will be conducted just prior to tne installation of such a cover or liner demonstrate knowledge of the importance of cnis preparatory work to the overall integrity of the liner or cover system. The inspection procedures should indicate that these areas will be inspected along with inspection of liner or cover foundation materials. The final step in preparing foundation materials for covering by a synthetic liner material is often that of applying a sterilizing agent to prevent the growth of plants that could puncture the liner material.3 if the application of a sterilizing agent is indicated in the liner or cover system design, the inspection procedures should include confirmation of the following items; • The contents of sterilizing agent containers were inspected for conformity upon receipt. • Appropriate storage conditions were maintained. • Application was conducted under appropriate weather conditions. • Appropriate application equipment and procedures were used. • The application rate (dosage) was as specified in the plans. • Appropriate time was allowed before initiation of liner layer installation. 9.3.3.3.4 Liner Materials—Inspection procedures during liner material placement will vary depending on whether the liner material is synthetic or a soil-based or admixed material. 9-156 ------- Svntheti- raacariais--0wners or operators of landfills who jae synthetic liners or covers will have indicated che nominal chi.ck.ness of chose materials. In addition, they should be able co obtain che quality control parameters from the manufacturers of the materials- If this information has been submitted, it can be used by the permit application reviewer in judging the adequacy of the preinstallation inspection procedures. However, reliance on the manufacturer's quality control specifications alone is not an acceptable substitute for inspection. At a minimum, the owner or operator should indicate that the materials will ie c.osei/ inspected at tne site of installation by personnel specifically representing their interests. If rigorous inspection and test procedures will be employed at the site, in addition to visual inspection, the equipment and procedures to be used should be described and the cvsa ~ ? damage jr 1..-.per rice;, on -men they are intended to ^.aencify anouid be stated. If only a representative sample of the materials is co be inspected, the permit application should justify that the portion inspected is truly indicative of the condition of all Che materials. Synthetic sheets or membranes are shipped to the site as rolls or as accordian folds. They are typically on pallets and wrapped or otherwise coveraa. It will often be necessary to score these materials at or .near che installation ,;ita. These materials should be protected from climatic extremes and vandalism during any storage period. Inspection procedures should provide for the following: * Inspection upon receipt prior to any storage. • Observation of handling -luring placement into storage. • Periodic inspection while in storage. • Observation of procedures and equipment for removal from storage and movement to installation site. • Confirmation of appropriate weather conditions for placement.3>^ • Observation of equipment and proceduras Co place liner material at che site. • Inspection of liner material after placement at the site and prior to installation. • Approval for installation to proceed. Inspection procedures that should be conducted after liner material installation are presented in subsection 9.3.3.i. The inspection items presented here are intended for implementation prior to and during placement of liner materials. Synthetic liner material manufacturers conduct various tests and inspections at their manufacturing plants as part of their QA/QC procedures. The handling and transportation of these materials to the site of installation provides opportunities for damage. Thus, inspection of the materials upon 9-157 ------- arrival at Che site should be conducted. '.'nits vhose wrappings indicate potential damage or rough handling should be more closely inspected. Shipping papers should be compared co nacenal markings and purchase orders Co insure conforraance with plan specifications. The inspection plans should specify liner acceptance criteria. It is often necessary to store the synthetic liner materials onsite. During storage, all synthetic liner materials are suscaptiola to damage from sunlishe =nd ^.araparature excursions. A frequent manifestation of this damage is blocking.3 Blocking occurs when the Liner material sticks to itself during storage. When the material is subsequently unrolled or unfolded, blocking can result in delamination or tearing of the .-aatarial. The insoecticn procedures jnoui« provide for an inspection of any proposed storage area prior to placement, of liner materials. Specific criteria which the storage area should meet should be indicated in the plan. The condition of each unit of material when first placed in storage should be noted and the inspection procedures should provide for periodic reinspection of stored liner materials. The criteria which will be used to evaluate evidence of potential damage during storage should be stated as part of the inspection procedure. A means for insuring that potentially damaged .aateriais are closely inspected •during ^subsequent installation should be indicated. Weather conditions can influence the potential for damage to synthetic liner materials during placement. Inspection procedures should provide for approval to commence p.acament based on weather conditions. High winds or extreme temperatures (hot or cold) should be Criteria for postponing olacaraent.3 Each panel ~>t the overall liner is normally shipped to the landfill in units too large to be moved manually. All mechanical equipment that will be used to assist in the movement and placement of liner materials should be inspected and specifically approved for the purpose. The inspection of mechanical equipment should include consideration of the potential for damage to both the liner material and the underlying foundation materials. After liner panels are partially unfolded or unrolled on the foundation material with the assistance of mechanical equipment, each panel is manually pulled out to its full size by a crew of workers. These workers will have cause to walk directly on the liner material. Therefore, the inspection procedures should indicate a means of insuring that proper footwear is worn by the crew. The work crew also moves the fully extended panel into final position manually. This includes placement in anchor trenches and overlapping of adjacent panels. At this point, che panel is anchored down with sandbags and/or tire* to temporarily secure it in the desired position for subsequent seaming. The inspection procedures should provide for a thorough inspection of the placed liner panel at this time. At a minimum the inspection should include: 9-158 ------- * 3'oservaci^n ~" ".".a -nt-rs jxpcsea 3urrace or cne liner material for tears, punctures, thin spots, foreign materials, damage rasulcing from blocking, and air pocicets trapped beneath the panel. • Confirmation of sufficient liner overlap for proper anchoring ac the perimeter of the landfill cell. • Confirmation of adequate overlap of adjacent panels for subsequent seaming. • Confirmation of the proper flatness of the liner panel with sufficient slack to accommodate temperature shrinkage. There should be no folds in the liner surface. Ihe procedure should provide for reinapection after correction of any problems identified. Proper seaming of adjacent panels and sealing of the liner around penetrations or footings is of overriding importance in liner integrity. Th-3, the inspection procedures should provide for close observation of seam-making procedures and subsequent testing of seams (seam testing is discussed in subsection 9.3.3.-*). The inspector should be empowered to start or stop seaming operations. During observation of field seaming operations, the inspection procedures should provide confirmation of the following:^ • .Ambient conditions are apprognate (.temperature, humidity, wind). • Use of appropriate adhesives or otner seaming equipment and materials. • Adequate cleaning of liner material before seaming. • The extent of seam overlap meets specifications, and • The use of heat and hot equipment is carefully controlled to only chose parts of the liner being seamed. The inspection procedures should specify the conditions under which the inspector will not allow seaming to be conducted. The installation crew will also be sealing synthetic liners and covers near penetrations and footings. They may also be working around the perimeters of the landfill if the liner or cover is being secured by other than the trench method.3,4 ^e inspection procedures should indicate tnat this work will be ooserved and that confirmation of compliance with design specifications and above listed items regarding seaming will be obtained by the inspector. 9-159 ------- •Some jyntr.dtic liners ars applied as a fluid and subsequent Iv "cure" :o continuous sheet or membrane after application.J 5ince these fluids are delivered co the site in sealed containers in will not be possible for an inspector to ascertain the fluid conditions on receipt, other than to check confonnance of label information and product specifications. However, inspection procedures stated in the permit application should provide for the following inspection items before and during application of these fluid synthetic liner materials; •a Container condition on receipt. • Monitoring of storage conditions. i Flaia condition when container is first opened-. • Appropriate application equipment and procedures employed. • Suitable weather conditions (temperature, moisture) for application, and • Allowance of adequate "cura" time before reapplication or initiation of next layer installation. Soil-based or admixed materials—Inspection of soil-based or admixed materials moved to the site should preferably be conducted by an geotechnical engineer at the borrow area or at the »ite. If less than every load of materials will be inspected, the permit application should contain justification of the representativeness of inspection. When onsite materials are to be used with only minimal movement (digging, grading) or preparation, the inspection procedures should indicate visual observation by a representative of the owner or operator of the uniformity of these materials during these activities. 9.3.3.3.5 Leak Detection/Leachate Collection System Materials—The materials used to construct either a leak detection or a leachate collection system will typically consist of various pipe and fittings along with aggregate materials that will be placed around the pipes during installation. Whether a system is designated as a leak detection or a leachate collection system will depend on its location in the specific landfill cell. However, the inspection procedures for either system are the same. A discussion of procedures for inspecting aggregate materials follows this discussion ("Drainage/protective layer materials"). The inspection procedures should address three inspection periods. They are: • Inspection of materials at receipt and placement in storage. • Periodic inspection during storage. • Inspection during installation. 9-160 ------- :si3 -isac :o :onsd"uc: -. ..;.!K ".^racr. ion, '.^acace -OL^ectzion svscem are mich less susceptible co damage during handling and storage Chan synthetic liner materials. Therefore, an inspection procedure chat provides on'. • for inspection of these materials as they are being assembled into the overall system may be adequate. However, the inspection procedure must provide for a comparison of the materials being used to those specified in the plan specifications at some point prior to their permanent assembly into the overall system. The inspection procedures should indicate that the following items will be confirmed during a comparison between shipping papers, purchase orders, and original plan specifications: • parts are constructed of the specified materials • parts are of the correct size and shape • parts meet the strength specifications The inspection procedures should also provide for a means to confirm that the parts being assembled into the overall system are not damaged. Further, confirmation that the proper bonding materials and assembly procedures are being used must be included in the inspection procedures. As sections are completed they should be cleaned and flushed to remove debris and identify any blockage. Collection pipes should be checked for proper jointing, adequate slope, and positioning of terminal cleanouts. The air test (ASTM C828) can be used to test nonperforated sections of the pipe for integrity. 9.3.3.3.6 Drainage/Protective Layer Materials—Landfill cells will typically have a layer of aggregate/sand/soii placed over the completed leak detection/leachate collection system and underlying liner. This layer serves the dual purpose of enhancing liquid removal from che overlying waste and providing protection for the underlying liquid handling system and liner. Because of strict material size considerations for proper performance of this layer, it is likely that the site owner or operator vill purchase the material offsite. The inspection procedure should indicate, therefore, that the material will be inspected by a geotechnical engineer either at the borrow area or upon its arrival at the site before installation. In addition, procedures should provide for observation of the equipment and procedures used to spread the layer of material. If geotextile materials are used as filters or protective layers, inspection procedures should follow the rationale presented for inspection of synthetic membrane liners. The cover system at a landfill cell will also have a layer of material for drainage placed over the synthetic liner material. In cover system service, this layer enhances removal of precipitation from over the synthetic material and assists in delivering it to a run-off control system. Since proper performance of this layer in this service is also dependent on material size gradation, inspection procedures applicable to it should be at least as detailed as those for the liner system drainage layer. 9.3.3.3.7 Vegetative Support Layer Materials5.6—xhe vegetative support layer of a cover system consists of two parts—the soil and the vegetative species. The inspection procedures should address three broad concerns: 9-161 ------- • The quality oc cne soil. • The species co be planted. • The time of seeding. The inspection procedures should provide for observation of placement and final contouring of the vegetative layer. Confirmation of the following itaras should be indicated:5 • Before placement, test soil for pH, organic content, nitrogen, phosphorus, and potassium, and compare to plan specifications. 4 Curing placement', confirm consistency of all material placed. • Assure that appropriate weather conditions exist for placement. • Assure that material thickness complies with plans and specifications. After placement and during final contouring, the soil should again be tasted for pH and nutrients. The addition of pH adjusting compounds and fertilizer should be conducted during the final contouring and surfacing if necessary. The inspector should oversee this process to insure that the appropriate materials are added, Che correct dosages are applied, and subsequent testing is conducted. The species to be planted and the time of planting are also concerns. The inspection procedures should assure that the inspector will confirm the following;5 • The seeds or seedlings to be planted are as specified by the plans. • The weather conditions are appropriate for seeding/planting. • The season of the year is appropriate for seeding/planting the specific species. • Appropriate seeding/planting equipment and procedures are employed. • Seeding/planting densities are correct for the specific species. • The seeds/seedlings are properly protected during germination/root ing. The inspection procedures should provide for frequent observation of the vegetative cover during the period of seed germination. The procedures should indicate how the progress of the vegetation will be evaluated and indicate what corrective actions will be employed the vegetation show signs of failure or is destroyed because of soil damage. A worksheet for evaluating the inspection procedures for ensuring uniformity and integrity during installation is presented in Figure 9.3.4. 9-162 ------- INSPECTION REQUIREMENTS Has this part of the applicant's submittal been reviewed and evaluated? Yes No In-situ Soils Are in-Titu soilg inspected for: • Proper grading and removal of irregularities and rocks? • Water table height? Yes No • Correct horizontal dimensions? Yes No • Unanticipated water or other liquids? Yes No • Previously unidentified strata? Yes No * Organic material? Yes No • Gas pockets? ___^ Yes No • Soluble soils? Yes No Foundation Materials Are inspection procedures designed to confirm that: • Materials conform to design specifications? Yes No • Materials placement procedures are appropriate? _ Yes No • Compacting equipment and procedures conform to plans? _ Yes No • Work is suspended during adverse weather conditions? _ _ Yes ~ Figure 9.3.4. Worksheet for determining the adequacy of inspection procedures before and during installation. 9-163 ------- t Irregularities in raaterials and procedures are appropriateLy addressed? ves v[o" Does the inspection plan address perimeter preparation prior to liner placement? Yes No Does the inspection plan address the use and application of •sterilizing agents? Yes No Synthetic Liners and Covers Do pre-installation insoection procadures jddrass: • Testing Co insure conformance co manufacturers specifications? Yes No • Visual inspection of synthetic liners upon receipt prior to storage? Yes No • Observation of handling during placement inco storage? Yes No • Periodic inspection while in storage? Yes No • Observation of procedures and equipment for removal from storage and transfer to installation site? Yes No * Confirmation of appropriate weather-conditions for placement? Yes No • Observation of liner placement procedures and equipment? Yes No • Approval for installation to.proceed? Yes No Do post-placement liner inspection procedures address: • Visual observation of surface to identify tears, punctures, thin spots, damage due to blocking, and trapped air pockets? Yes No • Confiraacion of sufficient overlap at the perimeter and adequate panels to allow anchoring and seaming? Yes No • Confirmation of proper flatness and slack requirements? Yes No Does the inspection plan call for reinspection after corrective actions? Yes No Figure 9.3.4 (continued). 9-164 ------- Do liner saam insnecfricr. pro;:caur2S -j • Ambient conditions are appropriate? • Seaming equipment, adhesives, and materials are appropriate? Yes No • Liner materials are adequately cleaned prior to seaming? i'es No • Seam overlap dimension is as specified? Yes No « '.i^at jnci .oc equipment are carefully controlled? Yes No Does the inspection plan identify conditions under which seaming will aot be allowed? Yes No If synthetic liner materials are applied as a. fluid, do inspection procedures address: • Container condition upon receipt? Yes No • Monitoring of storage conditions? Yes No • Fluid condition when container is first opened? Yes No • Use of appropriate application procedures and equipment? Yes No • Weather conditions for applications? . Yes No • Allowance of adequate cure time between applications? Yes No Soil-based or Admixed Liners • Are visual observations conducted to insure material uniformity? Yes ~No~ • Are inspection procedures conducted by a geotechnical engineer or other qualified person? Yes No Figure 9.3.4 (continued). 9-165 ------- ^a.K > :^c: : rr. • ladcnaca Jo i tec c -.on Svszsa Materials Does !iha inspection plan address: • Inspection aC recaipc and placement into storage? Yes ~No~ 9 Periodic inspection during storage? _ Yes Xo • Inspection during installation? _ _ Yes No Are the insoec-r-'cn -rcccduras ddequaca co confirm that: • Parts are constructed of the specified materials? Yes " No • Parts are of the correct size and shape? _ _ Yes Mo * ?art3 meet the strength specifications? _ _ Yes No • Parts are not damaged? _ _ Yes No Drainage/Protact ive Layer Material Are inspection procedures designed to insure that aggregate _ _ sand/soil materials will meet the size specifications? Yes No Are materials inspected by a geotechnical engineer? _ _ Yes No Vegetative Support Layer Materials Are vegetative layer placement and final contouring inspection procedures designed to evaluate: • Soil pH, organic content, and nitrogen, phosphorous, and _ _ potassium levels prior to placement? • Yes No • Material consistency during placement? _ _ Yes No • Material thickness? _ _ Yes No Figure 9.3.4 (continued) 9-166 ------- « .veatner Yes No • Planting of seeds or seedlings? Yes No • Seasonal considerations for planting? Yes No • Seeding/planting densities? Yes No • Seeds/seedling protection during germination/rooting? Yes No Does the inspection plan include procedures for evaluating vegetative cover progress? Yes ~~No~ Does the plan specify actions to be taken if progress of the vegetative cover is inadequate or if the cover is damaged? -fss ~No~ Figure 9.3.4 (continued) 9-167 ------- 9.3.?.4 Are procedures for inspection jf synthetic liners and covers for uniformity and integrity ..after installation Described?— 9.3.3.4.1 Introduction—Figure 9.3.5 is a chart of topics presented in this part. The provisions of §264.303(a)(1) require confirmation chat synthetic liners and covers have tight seams and joints and do not have tears, blisters, or punctures after they have been installed. The use of the word "tight" in the regulation with regard to seams and joints is intended to mean complete, nonleaking closure whenever edges of the liner materials ar2 joined cogetner, around penetrations, footings or other appurtenances and at the edge of the landfill cell. The inspection procedures should also indicate the steps to be taken if the inspection reveals a problem. An ideqi/.aca Inspection procedure, regardless of liner or cover construction materials, should be detailed regarding whac will be checked for, how the checks will be conducted, and where the checks will be made. Specific parameters should be stated as grounds for failure of inspection. 9.3.3.4.2 Sheet and Membrane Materials—There are standard practices and ASTM methods employed by installers of membrane and sheet synthetic liners and covers to confirm the integrity of field-installed seams and joints. The specific seam test employed varies depending on che configuration of the finished seam.3 The installer should keep a log of the test results for each seam. The specific method for synthetic material seam testing should be indicated. The inspection procedures should indicate review of the seam test log and provide for the observation of a sufficient number of tests to confirm that they are properly conducted. 9.3.3.4.3 Fluid Materials—After these materials h'ave been allowed to cure for the time period recommended by che manufacturer, they should be thoroughly inspected. Whereas sheet or membrane materials undergo QA/QC checks at the point of manufacture, fluid materials are formed into a sheet onsite and, therefore, deserve more careful inspection. There are two reasons for detailed inspections of these materials;7 • The basic mix and a polymerization activator must be mixed onsite before application, and • Application is by spray, squeegee, or trowel. Errors in mixing proportions will affect the cure time and the physical characteristics of the cured material. Manual application of the material makes the final cured layer more susceptible to thin spots. It may be appropriate in some cases for the inspection procedures to include destructive physical and chemical tests on portions of these materials after installation to insure that the material meets original specifications after placement. The inspection procedures should provide for observation of repairs to portions of these materials that are tested. 9-168 ------- SYNTHETIC LINER AND COVER INSPECTIONS i^R ''IS'-V.L.-Yr.' MEMBRANES, "HEI7C TEARS, 3LISTERS. PUNCTURES _L SEAMS AND JOINTS PENETRATIONS, FOOTINGS, PERIMETER REPAIRS REINSPECTION TESTS REPAIRS RE/NSPECTION Figure 9.3.5. Inspection of synthetic liners and covers after installation. 9-169 ------- J •'•-•'• '-re procedures described for inspecting soil-based and admixed I ineri and covers after installation for imperfections :^ac voa^a increase""^ permeability? 9.3.3.5.1 Introduction—Figure 9.3.6 is a chart of topics presented in this part. This subsection addresses inspections after installation of each Layer in cover and liner systems that are constructed of soil-based or admixed materials. 0 - ? - 2 . 3 . .1 In-5icu Spiia—As previously described, in-sicu soils do not generally require complex preparation procedures. A visual inspection should be conducted to identify any large irregularities (e.g., cracks, channels, root holes, large rocks, etc.) and to note any 'inanticipatad standing vacer or orhar MquiJ sn ;he fi^isned aurtace. Tests should also be conducted co determine whecher the finished surface is closer to the water table than originally anticipated, to check horizontal dimensions, and to identify any previously unidentified geologic strata which could jeopardize the function of che liner system. In some cases, the in-situ soil may serve as the foundation material. Foundation material inspection procedures are described belcw. 9.3.3.5.3 Foundation Material—Foundation soils must be inspected and tested Co assure chat their consistency and bearing capacity after installation and/or compaction meet design specifications. To this end, soil index properties and engineering properties that must be considered as part of the inspection plan include moisture content (i.e., Atterberg Limits), density, and bearing capacity. These properties are summarized here and explained in more detail in Section 9.2.1.3. Field laboratory methods for quantifying rhese properties are specified in proposed EPA Test Method 9100, which is incorporated as an appendix to the RCRR Technical Guidance Documents.3 Soils can be classified according to the Unified Soil Classification System which divides all soils into three major groups: coarse-grained (gravelly and sandy soils), fine-grained (inorganic silts and clays) and highly organic (organic silts and clays). In general, the coarse-grained soils are the most easily worked, and have the greatest resistance co compression. Fine-grained soils are more difficult to work, have greater compressibility, and have fair co poor shear strength. However, fine-grained soils are relatively impermeable and can serve as a secondary barrier to leachate flow. Compaction is an essential step in preparing the soil foundation for impermeable liner installation. Soils are compacted to increase soil strength and bearing capacity, reduce the void ratio (reduce settlement and permeability) and reduce shrinkage. Compaction of sidewalls is particularly important for improved strength and stability. The degree co which a soil can be compacted is determined by a soil density-water content cest generally referred co as the Proctor Test (either standard or modified). The test identifies the maximum density obtainable (for a specific energy input) as a function of soil moisture. Typical specifications for compacted fills specify the percentage of compaction based on density, but both moisture content and density may be specified. To illustrate the importance of moisture content, Figure 9.3.7 graphs density as a function of water content.9 9-170 ------- SOIL-BASED AND ADMIXED LINER AND COVE? INSPECTIONS AFTER INSTALLATION IN-SITU SOILS FOUNDATION MATERIALS LINER MATERIALS LEAK DETECTION/ LEACHATE COLLECTION SYSTEM MATERIALS DRAINAGE/ PROTECTIVE LAYER MATERIALS Figure 9.3.6. Inspection of soil-based and admixed 1-i.ners and covers after installation. 9-171 ------- m 2 - o ^ _ in 0 O » a Z LJ O u a: Ul __ o 2 •j '-w 3 il u 'J >^ *J •fi -3 i •J o £ 3 J •J u • o r- O ------- To evaluate compaction, the soil foundation can be tasted for density and moisture content. - The density muse be greater than or equal to the value specified while the moisture content muse fall within :ne working range, as illustrated by Figure 9.3.7. The application should specify a representative number of samples for analysis (e.g., one per 2000 ft^ of soil). Clay soils should be compacted to a uniform high density. For a clayey soil the minimum field density should be 95 percent of the Proctor maximum density of the fraction smaller than 4.75 mm (No. 4 sieve). The moisture concant should b*: + 1 percent of the design v— /alu^ (SW-370, p. 229).^ Acterberg Limits characterize Che plasticity of a cohesive soil. Cohesive soil consistency is greatly affected by water content: a gradual increase in water content transforms 2. dry soil from a solid state, to a jerai-soiia state, to a plastic state, to a liquid state. The plastic limit is the soil moisture content just below which the soil is barely plastic and just above which the soil flows. At the liquid limit, soil behavior is a blend of plastic deformation and liquid flow. Figure 9.3.8 is a Plasticity Chart indicating the plasticity index of various cohesive soils as a function of the liquid limit. 1-0 In general, soils with liquid limits between 35 and 60 having a plasticity index above the A-line should be considered the most favorable in terms of toughness, dry strength, and permeability. As a quality assurance check, the inspection program should include a determination of whether the soil foundation conforms to plasticity index specifications. A sufficient number of samples (e.g., one per 2,000 ft^ of soil) must be taken to ensure a statistically significant representation of the foundation -natarial. In addition to strength, a significant requirement for a soil liner is low permeability. To assess permeability, the inspection plan should include both laboratory testing and field trials. These tests should be conducted to verify that the K-value is within the required range, and should be used to correlate permeability with the density-moisture content function, thus verifying the relationship obtained during the pre-construction investigation upon which the design is based. Laboratory and In-Situ Tests for Foundation Materials and Soil Liners Foundation material laboratory and in-situ tests must be taken to ascertain whether the specified classifications and consistency have been met. Measurements of moisture content and compaction ensure that the foundation has the desired firmness. Laboratory permeability and in-situ infiltration tests should be conducted for foundations designed to serve as impermeable barriers. Available in-situ testing procedures include: • Standard Penetration Tests (ASTM D1586)—This test provides a measure of the resistance of the soil to penetration of a split-spoon sampler thereby providing an indication of the relative density and consistency of the soil. • Vane Shear Test (ASTM D2573)—This test is used to determine the in-situ shear strength of soft, saturated, cohesive soils. 9-173 ------- so, 50- 40 - For clasulitalivin in hiu--frjmvU Mill tnJrv Allrrhrif limiH ploilmg m hjithed we* m hordrritnc cliuifuiiions alumni UK ot dujl symeol* «0 50 LK)U«» limit LL KEY CH CL >ffl ML OH OL Inorganic clays of high plasclcicy, fat clays Inorganic clays of low to nadiun piascicicy, gravelly clays, sandy clays, silcy clays, lean clays Inorganic silcs, taicaceous or diacoaaceous cine sands or silcs, elastic silcs Inorganic silcs, very fine sands, rock flour, silcy or clayey fine sands Organic clays of a«dium co high plasticity Organic silts and organic silcy clays of low piascicicy Figure 9.3.8. Plasticicy chart. Source: Reference 10 (Cernica) 9-174 ------- t Prassuramecar Tests i, No ASTM designation) — This cest can be used to determine the cohesive strength of saturated clay soil. • Plate Load Tests (ASTM 01194)— This is a method used to determine the bearing strength of soil in place. • Cone Penetration Tests (ASTM D3441)—This test can be used to classify soil and estimate strength, compressibility, and bearing capacity. • Infiltration Test (ASTM D-3385-75)—This test is used to determine the water transmission characteristics of the foundation material. ^pV.'. :abl3 '.jbcracocy casts include the following: • Compaction Tests (ASTM D698 and ASTM D1557)—These tests can be used Co verify the moisture-density relationship identified in preconstruction testing. • Consolidation Testa (ASTM 02435)—These tests provide soil data used in predicting the rate and amount of settlement of structures founded on clay. * Unconfined Compression Tests (ASTM D2166)—These tests provide an approximate procedure for evaluating the shear strength of a cohesive (clay) soil. * Direct Shear Tests (ASTM D3080)—These tests provide a measure of the shearing resistance of a soil across a predetermined failure plane. • Triaxial Compression Tests (ASTM D2850)--These tests provide data for determining strength properties and stress-strain relations for soils. • Saturated Hydraulic Conductivity Tests (ASTM D-2434-68)—These tests are used to determine the permeability of saturated soil. To provide adequate quality control, the clay liner sampling and analysis program must provide a statistically valid representatation of the liner characteristics. Although actual sampling and analysis programs are highly site specific (primarily dependent upon the homogenity of the clay soil) the following example illustrates a quality control program for a hypothetical 3-foot soil liner covering 100 acres: a. For determining the moisture content prior to compaction, and the density obtained following compaction, collect and test one soil sample for every 2,000 cubic yards of compacted soil liner. b. For determining saturated hydraulic conductivity in the laboratory, collect and test one soil sample for every 16,000 cubic yards of compacted soil liner. 9-175 ------- w. for monitoring field infiltration, conduce one measurement for everv 40,000 cubic yards of compacted 30'il liner. The inspection procedures should also include a visual inspection of the foundation by a qualified technical person. Visual observations should include subgrade appearance, earthwork activities, and workmanship (e.g., look for cracks, channels, root holes, etc.); lack of vegetation; drain orientation and placement; slope characteristics and preparation; and any other parameters that might influence the adequacy of -ha foundation. 9.3.3.5.4 Admixed Liners—There are a variety of admixed (formed-in- place) liners which have been successfully used for impounding and conveying water. Types of liners include asohalt-concrste, soil csmant, and soil -Lcpr.alc, ail of wnicn are hard-surface materials. Experience in using admixes in landfill applications is limited. Hydraulic asphalt concrete (HAC) used as liners for hydraulic structures and waste disposal facilities, are controlled hot mixtures of asphalt cement and high quality mineral aggregate compacted into a uniform dense raass. They are similar to highway paving asphalt concrete but have a higher percentage of minor fillers and a higher percentage (usually 6.5 to 9.5) of asphalt cement. Hie asphalt used in HAC is usually a hard grade such as 40-50 or 60-70 penetration grade. The application should include inspection procedures which insure that design specifications are met. To provide a relatively impermeable layer, two 2-inch layers of HAC (a total chichnes*- of 4 inches) are recommended ', SW-870).3 The liner should be compacted to at least 97 percent of the density obtained by the Marshall Method or less than 4 percent void space. A void space of less than 2.5 percent has been shown to reduce permeability to 1 x 10~9 cm/a (SW-870).3 The prepared subgrades should have side slopes of less than 3:1. The soil shou .d be treated with a sterilizing agent to prevent puncture of the liner by weeds and roots. A visual inspection should be conducted to identify any surface irregularities such as cracks and lumps. If wastes are expected to be acidic, the aggregate should be cested for carbonate content. Carbonates are readily attacked by acids and should be avoided in this situation. Asphalt liners should not be used at sites receiving petroleum derived wastes or petroleum compounds. Soil cement is a compacted mixture of portland cement, water, and selected in-place soils. Permeability is dependent on soil type. A fine-grained soil produces a soil cement with a permeability coefficient of 10~6 cm/3, Coatings such as epoxy asphalt and epoxy coal tar have been used to reduce the permeability of soil cement. The inspection program should insure that the soil cement liner meets design specifications. Soils that are not organic and contain less than 50 percent silt and clay are suitable for soil cement. The inspection should insure that the soil cement liner meets design criteria for cement content, moisture content, and the degree of compaction. The optimum cement content should be determined from wet-dry and freeze-thaw cycle laboratory tests, 9-176 ------- ASTM 3>39 ana ^STM 0560, respectively. Soil cement liners may degrade under highly acidic environments. The soil cement liner anouiu oe visually inspected for inconsistencies such as cracks and lumps, »tc. Soil asphalt is a mixture of available onsite soil (usually with low plasticity) and liquid asphalt. The preferred soil type is a silty, gravelly soil with 10 to 25 percent silty fines. A high void content soil asphalt has a high permeability (~1.7 x 10~3). Soil asphalts containing cutback asphalt are noC recommended as lining materials- coil -.sen a I: ,:ada wica aspnaic ^jauijion ud .iou surriciently impermeable and requires a waterproof seal such as a hydrocarbon resistant or bituminous seal. The soil asphalt liner (with waterproof seal) should be inspected to insure that it conforms to design specifications. The inspection should include ^rnradur^s ;hicr. l.isura che raquirac ;panneauxiicy and a visual inspection of the liner to identify irregularities in the soil asphalt and the waterproof seal. Figure 9.3.9 presents a worksheet which can be used to evaluate the adequacy of "he applicant's plans for inspection after installation of liner systems. 9.3.3.6 Are procedures described for Inspections Weekly and After Storms?— 9.3.3.6.1 Introduction—Figure 9.3.10 is a chart of topics presented in this subsection. The provisions of §264.303(b) identify four physical systems that should be inspected on a weekly basis. They are: (1) Run-on and run-off control systems, (2) Leak, detection systems, (3) Wind dispersal control systems, and (4) Leachate collection and removal systems. The regulations require only new facilities to have leachate collection and removal systems. Similarly, only those new facilities seeking an exemption from the requirements of Part 264, Subpart F by using double liners will have leak detection systems. Some facilities, both new and existing, will have wind dispersal control systems, depending on the nature of the wastes disposed. All new and existing facilities will have run-on and run-off control systems. The description of weekly inspection procedures should be specific regarding what, how, and where the stated systems will be checked- Criteria that will b« used to evaluate the proper operation of these systems should be stated. The plans should indicate use of a form requiring written completion by the person conducting the inspection. An employee responsible for inspections should be identified by name or title. 9.3.3.6.2 Run-on and Run-off Control Systems—Inspections of run-on and run-off control systems will vary in complexity in relation to the complexity of the design. A run-on control system at a landfill is simply intended to 9-177 ------- teries REQUIREMENTS Has this parr of :he applicant's suomittal been reviewed and evaluated? Yes No Sheet and Membrane Materials Does the application specify standard ASTM Methods for tos^ir.g 'sanis :nd Joints; Yes No What raethod(s) are specified? Do inspection procedures call for keeping and reviewing a seam test log? Yes No Is a copy of the seam test log included in the inspection plan? Yes ~~No~ fluid Materials Does the application include detailed procedures for inspecting Liners applied as fluids? Yes No Are fluid materials checked cor conformance with specifications before application? :'es No Do inspection procedures provide for determination of liner thickness aftar installation and curing to allow for repair of thin spots? Yes No Soil-Based and Admixed Liners Do in-situ soil inspection procedures include: • Visual inspections to identify large irregularities? Yes No • Visual inspections to identify unanticipated standing water or other liquid? Yes No • Tests to identify height of liner above water table? Yes No • Checks of horizontal dimensions? Yes No Figure 9.3.9. Worksheet for determining the adequacy of inspection procedures after installation. 9-178 ------- zouncac.on soil inspection procedures incl ude: Figure 9.3.9 (continued) 9-179 "as No plasticicv i.ndex "p^cifi^ciions •are .-ec? Yes" No • Permeability determinations? ies No Are test procedures conducted to insure that admixed liners: « Meet material specifications? Yes No t Meet permeability specifications? Yes No • Are placed to the specified thickness? . Yes No • Are free of irregularities? Yes No ------- INSPECTIONS WEEKLY AND AFTER STORMS RUN-ON AND RUN-OFF CONTROL SYSTEMS LEAK DETECTION SYSTEMS WIND DISPERSAL CONTROL SYSTEMS LEACHATE COLLECTION AND REMOVAL SYSTEMS Figure 9.3.10. Inspections weekly and after scorns, 9-180 ------- ii;. [n all iiklihood it will consist of crenches ac raosc facilities, which may or may not be lined. The run-off control sysceffl id designed co collect and contain all liquid from the active portion of che landfill and deliver it to some type of holding or treatment facility. A run-off control system is likely Co b« of more sophisticated design than a run-on control system since it will be handling liquid that has been in contact with hazardous waste. Two broad concerns should be addressed by inspection procedures established for either of these systems, and include: « The physical integrity of the system remains as originally constructed. » Th» canqciiv of chs <=•;<>r*t> -iTcaim zs originally constructed. For either run-on or run-off control systems, inspections of physical integrity should address; * The liquid collection trench, culvert, or piping for maintained slope, any breaches, ana tight joints. * If che conveyance system is lined, che liner material should be checked for adhesion to substrate, holes, wear points, and cracks. • If mechanical equipment (pumps, valve, gates) is part of the ayatem, all components should be checked for leaks, operability, or oth«r damage. For run-on control systems, inspections to confirm maintained design capacity should address; • The presence of sedimentation, debris, or other materials that could inhibit system flow. • The condition of terrain downgradient from the system exit that could cause liquids to back up into che system. For run-off control systems, inspections to confirm maintained design capacity should address; • The presence of sedimentation or encrustation in the system. • The operability of mechanical equipment in the system. • The status (full/empty) of run-off holding or treatment systems. The holding/treatment systems associated with the run-off control system are identified as storage, treatment, or disposal facilities under Part 264, and must be inspected as required by §270.14(b)(5) and 5264.15. 9-181 ------- 9.3.3.5.3 Leak Detection Systems — Inspections of leak detection ^systems are required co determine if LiquiJ is prasenc, thus indicating leakage from t'-s facility. The inspection procedures should indicate now the check for liquids will oe made and what criteria will be selected as positive indication of the presence of liquids. The inspection procedures should also indicate what actions will be implemented by the inspector when liquids are found in the leak detection system. 9.3.3.6.4 Wind Dispart I ~.-;^~~ *l '; 3 terns — fhers are many design options for wind dispersal control at a landfill. In some cases, more than one system will be installed. Wind dispersal controls at landfills are necessary to prevent the dispersal of hazardous waste particles and soil that may have bean in contact with hazardous The inspection procedures should indicate close visual observation of all wind dispersal control systems on a weekly basis, at a minimum. During periods of high winds or wnen wastes are more susceptible to wind dispersal, che inspection frequency should be increased. The inspection procedures should indicate chat the inspector has the authority co require immediate rspair or cleaning of wind dispersal control systems. Cleaning would oe necessary wnere fences' or burlap screens are installed to catch any wind blown materials. 9.3.3.6.5 Leachate Collection and Removal Systems — A leachate collection and removal system is installed under the landfill cell to provide for removal of leachate and maintain the depth of leachate on the liner below 1-foot. Leachaea must be stored and/or created, after removal. Procedures for inspecting leachate collection systems, should provide for the following; • Confirmation that leachate depth above che liner is less than 1 foot at all points. • Check of depth of leachate in collection sumps. • Observation of mechanical equipment in operation (i.e., sump pumps and associated piping). • Recording of leachate depths and flow rates in all parts of the system. The intent of inspecting tnese systems weekly and after storms is to insure continued operation and to determine if the system is in the process of becoming clogged or has clogged. Detailed guidance on what constitutes adequate inspection of these systems is not possible unless che design of the system is known* However, as with other inspections, the procedures should jtate what, where, why, and how checks of the system will be made. Specific criteria that would trigger corrective actions should be stated. 9-182 ------- The inspection procedure should indicate whac specific actionj will je taken CO monicor for existing or potential clogging of the leachace collection and removal system. For instance, laachace dapcns and clow rates at several points in the system can be recorded, graphed, or handled in other ways in an effort Co identify sudden, abnormal changes. Properly designed laachate collection and removal systems are amenable to cleaning on a periodic basis through the use of hish pressure vacar (50 psi).H Such :'.n.-paction «au ..Caning anouia be conducted after first placement of waste and periodically thereafter. A worksheet for evaluating the inspection procedures conducted weekly -..id after stomna is -re-^a'aci ir. Figi.r.2 j.j.ii. 9.3.4 Draft Permit Preparation Condition D of Permit Module XV addresses monitoring and inspection requirements. The condition is implemented through reference to a permit attachment that includes inspection tsrms and scheduling, and remedial actions as appropriate. To be considered adequate for substitution in the permit condition attachment, the submitted application information should include details of procedures used and scheduling for inspecting various process operations during the following time periods: • Before construction, • During construction, and • After construction of the liner and related facilities. The attachment must also include weekly and after storm inspection procedures and schedules (during landfill operation) that address: • Run-on and run-off control systems, • Leak detection systems, where present, • Wind dispersal control systems, where present, and • Leachate collection and removal systems, where present. Reference should be made to Permit Condition II.E. which requires the applicant to remedy any deterioration or malfunction discovered during an inspection and to keep a log of inspection records. For existing landfill portion* that are exempt from liner requirements, the attachment need only address weekly and after storm inspections. Inspection requirements during the post-closure care period are discussed in subsection 9.4. 9-183 ------- INSPECTION R E Q L' IR EM E NTS Has this part of the applicant's submictal been reviewed and evaluated? vss NO Run-on and Run-off Control Systems Do weexiy ana arter storm inspection procedures address: • Inspection of liquid collection trench, culvert or piping systems for proper slooe, ^r--z^3::t -.;:: .-a.-iu joints. Yes ~~No~ • Inspection of lined conveyance systems for adhesion co substrate, holes, wear points, and cracks? Yes No • Inspection of mechanical equipment for leaks, operability . or other damage? Yes No Do run-on control system inspection procedures include: • Inspection for the presence of sedimentation, debris, and other material that could inhibit flow? Yes No * Inspection of the down gradient terrain to identify potential causes of liquid back up? Yes No Do run-off control system inspection procedures include: • Inspection for the presence of sedimentation or encrustation? Yes No • Inspections co determine the operability of mechanical equipment? Yes No • Inspections co determine the status (full/empty) of holding or treatment systems? Yes No Leak Detection System Are procedures for monitoring the leak detection system fully described?. Yes No Does the inspection plan specify actions co be taken in the event of a leak? Yes No Figure 9.3.11. Worksheet for determining the adequacy of weekly and after storm inspection procedures. 9-184 ------- *'ina -iisoersai ontrji. Syscams Does Che inspection plan include procedures for weekly visual inspections o£ wind dispersal concrol systems? , Yes No Does the inspection frequency increase during periods of high winds? Yes No" Leachate Collection and Removal Syster.s Does the inspection plan identify specific weekly and after storm inspection procedures to identify: 9 Icsachatd jepr.ns greacer cnan i cooc over the liner? Yes No" • Depth of leachata in collection sumps? Figure 9.3.11 (continued) Yes No • Mechanical equipment malfunction? Yes No • Leachate depths and flow rates in all parts of the system.7 Yes No Does the inspection plan identify specific criteria that would trigger remedial action? Yes No Do the inspection procedures identify specific actions to monitor for existing ana potential physical or chemical clogging of the Yes No leachate collection and removal system? 9-185 ------- '•--•> Ae rarences I. 'J.S. EPA. Permit Applicants' Guidance Manual for -iasardous 'v'asca Land Storage, Treatment, and Disposal Facilities. Volume I. Office of Solid Waste. Washington, D.C. 1983. 2. Capone, S. V., et al. Permit Applicants' Guidance Manual for the General Facility Standards of 40 CFR 264. Prepared by GCA/Technology Division for the U.S. Environmental Protection Agency. • '"ffic.3 of 5oi.id Waste. Washington, D.C. Draft. June 1983. 3. Lining of Waste Impoundment and Disposal Facilities, SW-870, U.S. EPA, SHWRD/MERL-CINN, September 1980. 4. Schultz, D. W., and M. P. Micklas, Jr. Placement Procedures tor Various Impoundment Liners, Solid Wastes Management, July 1982, p. 24. 5. Evaluating Cover Systems for Solid and Hazardous Waste, SW-867 (Revised Edition), U.S. EPA, SHWRD/MERL-CINN, September 1982. 6. Design and Construction of Covers for Solid Waste Landfills, EPA-600/2-79-165, U.S. EPA, SHWRD/MERL-CINN, August 1979. 7. Brocnure B-74P (05-2-79) 5M, Chevron Industrial Membrane, Commercial-Industrial Elastoraeric, Chevron U.S.A. Inc./Asphalt Division, P.O. Sox 7643, San Francisco, CA 94120. 3. J.3. SPA. RCRA Technical Guidance Documents. A Series of Manuals Published with the Land Disposal "Standards of July 26, 1982. 9. Sowers, G. B., and G. F.Sowers. Introductory Soil Mechanics and Foundations. Third Edition. MacMillan Publishing Co., Inc., New York. 1970. 10. Cerrica, T. N. Geotechnical Engineering. Holt, Rinehart , and Winston. New York. 1982. 11. Telephone conversation. Greg Woelfel, Northern Regional Engineer, Waste Management, Inc. (414-476-8858) and S. Capone, GCA/Technology Division. 18 March 1983. 9-186 ------- ?.-, LANDFILL. CLOSURE -.'!D ?C57-CLCSl?o 9.4.1 The Federal Requirements Section 270.21(e) specifies Che information that must be submitted to demonstrate the applicant's closure plans. That information includes: "Detailed plans and an engineering report describing the final cover which will be applied ro each landfill or landfill call at closure in accordance with$264.210(a>, and a description of how each landfill will be maintained and monitored after closure in accordance with §264.310(b). This information should be included in the closure and post-closure plans submitted under §270.14Cb)(11} . " The standards of §264.310 must be supported upon implementation of the closure and post-closure plans, as follows: "(a) At final closure of the landfill or upon closure of any cell, the owner or operator must cover Che landfill or cell with a final cover designed and constructed to: (1) Provide long-term minimization of migration of liquids through the closed landfill; (2) Function with minimum maintenance; (3) Promote drainage and minimize erosion or abrasion of the cover; (4) Accommodate settling and subsidence so that the cover's integrity is maintained; and (5) Have a permeaoility lass than or equal to the permeability of any bottom liner system or natural s> soils present. (b) After final closurej the owner or operator must comply with all post-closure requiremencs contained in §264.117-264.120, including maintenance and monitoring throughout the post-closure care period (specified in the permit under §264.117). The owner or operator must: (1) Maintain the integrity and effectiveness of the final cover, including making repairs to the cap as necessary to correct the effects of settling, subsidence, erosion, or other events; (2) Maintain and monitor the leak detection system in accordance with §264.302, where such a system is present between double liner systems; (3) continue to operate the leachace collection and removal system until leachate is no longer detected; (4) Mairttain and monitor the groundwater monitoring system and comply with all other applicable requirements of Subpart F of this Part; (5) Prevent run-on and run-off from eroding or otherwise damaging the final cover; and (6) Protect and maintain surveyed benchmarks used in complying with §264.309. 9-187 ------- (c) During the pose-closure care period, if liquid leaks Into a leak detection system installed under §264.302, the owner or operator must notify the Regional Administrator of the leak in writing within seven days after detecting the leak. The Regional Administrator will modify the permit to require compliance with the requirements of Subpart F of this Part." 9.4.2 Summary of Necessary Application Information The provisions of §270.2L(e) and §264.310 require the submittal of two plans; a closure plan and a post-closure plan. The closure plan muse include detailed plans and an engineering report describing the design and construction of the final cover (cap) chac ..ill oa installed on each landfill or landfill cell. Specific information items which must be addressed in the closure plan are set forth in §264.310(a) and in §264.110 through §264.115 in Subpart G of Part 264. The post-closure plan must include a description of how each landfill or cell will be maintained and monitored after it is closed. Specific information items which must be addressed in the post-closure plan are set forth in 5264.310(b) and in §264.117 through §264.120 in Subpart G of Part 264. The fundamental function of the final cover is to prevent the entry of liquids into the closed unit and, thus, leachate formation and migration of leachate from the site. The application should demonstrate that the design will:*- • Minimize migration of liquids through the closed cell or landfill. • Minimize maintenance requirements. • Promote drainage and minimize erosion or abrasion of the cover. • Accommodate settling and subsidence. • Provide a cover that has equal or less permeability than any bottom liner system or subsoil underlying the landfill. The application should also demonstrate that the owner/operator will: • Maintain the final cover (i.e., repairs due to settling, subsidence, erosion, etc.) • Maintain Che leak detection system (where such a system is installed between double liners). • Operate the leachate collection and removal system until leachate is undetected. • Maintain the ground water monitoring system. • Prevent run-on and runoff. 9-188 ------- j '.jinrain : er.cr.marxs ^szc 5 J "~~ .:--__ . .;- - 5 _ i .-r.i.ix.;s .op cover settling and subsidence, and compliance witr, 5264.309. 9,4.3 Guidance on Evaluating Application Information A flow chart is presented in Figure 9.4.1 co demonstrate the regulations which are applicable to closure of hazardous waste landfills. Information on the intent of the closure and post-closure requirements is available from preambles to the Tsdaral ?v<3gijC'' , 19 May 1980 33196 45 Sufapart G 19 May 1980 33212 45 Subpart N 12 Jan 1981 2818 46 Subpart G 13 Feb 1981 12424 46 Subpart N 26 July 1982 32314 47 Subpart N 9.4.3-1 Available References— Concurrent with the promulgation of the landfill permitting regulations, the EPA released the RCRA Technical Guidance Document, "Landfill Design, -Liner Systems and Final Cover" (Draft, Issued July 1982).2 The Guidance Document provides design specifications for a final cover design approved by the EPA as being consistent with tne intent of §244.310. The basis for that design and supporting technical data are contained in "Evaluating Cover Systems for Solid and Hazardous Waste (SW-367).3 SW-867 provides a detailed 39-step approach for evaluating the adequacy of closure and post-closure plans and engineering reports with respect to the requirements of §264.310(a). The procedure is specifically intended for use by staff members in che Regional EPA Offices and/or state offices. Procedures detailed in SW-867 are based on data contained in "Design and Construction of Covers for Solid Waste Landfills," EPA-600/2-79-165 (August 1979).^ This report provides extensive detail which is sufficient, in combination with site-specific data, co design a final cover for a landfill cell. Additional information can be obtained from conference and symposium proceedings. Although many of these paper3 specifically address caps used for remedial actions, they do provide insight into potential problems with function, design and maintenance of final covers. References 5 through 9 listed in subsection 4.5 are also useful sources of information on closure. Additional data on closure practices are likely to become available through continued research in the area of landfilling hazardous waste. 9.4.3.2 Permit Application Review Procedures— As discussed below in subsection 9.4.3.2.1, EPA Publication SW-867 provides a stepwise procedure for evaluating engineering plans for final cover construction and maintenance. The sequence of procedures is illustrated by Figures 9.4.2, 9.4.3, and 9.4.4. The first three procedures, which encompass 9-139 ------- •3 V) 3 O 0) 3 V) J 3 -3 "3 •3 73 5 30 il >T :?\ U 3 9-190 ------- O- ,_ _ r— a. uj LU < a < as ae • a uj LU — u-> LU z z z a. o z to —i — o — a: — z < z — z z o z ce U «£ t— rf ff i < ^- '— _ •< f a LU <-> O ae a. O (— LH •£ a. — LU a. LU I— (/I •-O =3 •3 -3 o z >. vox — a. UJ |_ < at < ae — ae o 3 O i-i 90 Ji y ^ -2 y 3 L. 11 LU Z x a. ^ < a ae ^r LU o <-> o a. O a. LU oe o i— a. H- vi 3 o LU (/I U. -J o o >- (/I ± uj — o — Q LU 5 S o £N 3 30 o O -J t/> OQ < LU H- ae 3 LU Q t- — LU o _i a. o — LU ae o i- a. ------- X LU > O CJ LU X t— LU < "> ~ 3 O C 3> LU- LU h- l/ _j a -i. >; M3 -> C LU C. UJ H-. OS Z 3 LU -T LU LU CJ CJ 0_ O < LU X -J t— a. a. co -U O i ^ ^ LU OS C. t— CU — < 3* I 3 OH — J C™J <£ a. :> UJ H UJ VI t— < (/) i^ < 3 CJ > UL UJ — LU X X 3 H- • C O <3^ •— LU as cj LU a. a O 2> LU U. OS O h- t~ Q- CJ l/l t/ i 0 LU a. H- r < 0 3 cj ^J • < Z ' Ul =» 0 H- UJ — < 3 't- 3 C •» «J » -co < H- -f O > — a. LU (/• UJ 3^ at o 3 CJ O CO LU as o uj a. Or* LU OS O t— CL> ^J ^O i _J -J ^r — z o as co LU t— a. * ^Z -w ) — t— • LU O LU • f- Z 1- 1 «5 — g ' 3 OS 3 . _J LU _J ~" ^> <^ J> > UJ —I LU LA \J3 a., a. LU LU h- h— co co i '' i OS .3 i •" CJ U. — Z X • — H- NESS FOR ATION EVALUATE . • •— a. J UJ i— > co i ' » » > i z o u. o LU •*• >~ UJ ^ 3 ^. UJ rsl a. LU H- co < o X o u. co 1^ cu z 1 ~3Z o o LU ^* 0 J^ zg o a. H- 3 3 — — J-> t— LU z MIGRATIO EVALUATE . -> •• a. LU H- CO ^ ^ O f/^ •v. OS a THAW AND EFFECTS *» i < 2 = H- < a u LU 'Z. -J LU LU — 1 ^-> -i 2» > <-3 UJ vl C LU o or os — -a — — ,— H-X LU 3S 3 < ox — i— <— a. ^ 3 U1O.Z 1— L-H-CJH-Zt— — L- k- LU <35»UJ>2:2 LULULUOLUZLUcOuJt— U UJ CC '{•• • • •' 3 LT\KO ^* CO 0^ O *- O CN t**J CN CN OJ r**\ c? LU cj z a. a. a. a. a. a. a OOLULULU LU LU CU u. cfillo'co'co cof co co J J j . S OS LU X LU CU LU H- CJ 9 H- CJ CO e— — J • — 3 3 u. (^ a cj — i as CO O t— 1— C3 O LU < < Z < Z < *:z303c3*:z !_) — _J — _l — 0 — LJ<«CcOLU>LUXaS CJOLUOLUQCJO LU as LU • ; • • . 3 O — ; <^ f-V J- O *t CM CN f— — 1 LU < I— < 3 Z 3 LU Z -J LU — 1 Q, • 0 < H. < 0 |_ LU O. LU CO UJ < as ce . 3 3 • t— i) --. ) CO j -JO >. 1 n £ '** ^—s i) o * -J u c; i1 3> u- N ^L U ") "3 .t LJ -n " "**! . ^^- ^ M 3 ^ 9-192 ------- o o UJ < UJ o UJ g S *2<*2 £ 2 p >- o H- "- u. u. < u. < -..-..-, _ •> x < = < < i i ° -S-|is«:5 — Y- (j K» < uj < oi < < < a a 3 3 z 3 ess O UJ I— uj Q i^, 3 co <~i Z Q. O < UJ oe _i >_ a. a. i a. a. UJ a. LU 33 Q. 3 •3 •Si U 3 10 9-L93 ------- seven steps (see Figure 9.4.2), constitute a review of -natariaij and conditions at the site under consideration. The six procedures identified in Figure 9.4.3 encompass 25 steps and pertain co tne cnaracteristics of the cover system. Figure 9.4.4 identifies procedures used to evaluate the adequacy of post-closure plans in a total of seven steps. The following discussion describes evaluation procedures and their relationship to §264.310: 9.4.3.2.1 Examine Background Data (see Figure 9.4.2) — • Examine soil test data (Steps 1-3)—Establish that the applicant has satisfactorily documented the physical characteristics, volume, and spacial distribution of the soil types to be used in the cover, These data -BUSC 're raasor.aoiy accurate since they directly affect the adequacy of the cover system and the feasibility of the cover operation. • Examine topography (Step 4)—The surface configuration is examined to assure that evaluations can be made in regard to slope stability, water erosion, and wind erosion. Topographical data are often presented in the form of cross sections showing Che thickness of the closure cover and solid waste and the limits of natural soil previously extracted for use as cover. • Examine climatological data (Steps 5-7)—Permit applications should contain data on average monthly precipitation, design storms, and evapotranspiration. Average precipitation data are generally provided for 20 years of rain_fall records. Design storm data should be provided for storms of 1-hour or longer duration, with a recurrence interval of 10 to—20 years. Since evapotranspiration is an important factor in removing moisture from the cover, the application should include ah- estimation of average monthly evapotranspiration rates. 9.4.3.2.2 Characterize the Cover System (see Figure 9.4.3) • Evaluate composition (Step 3)—Cover composition should be evaluated with regard to trafficability, gas migration, and water percolation. Since minimizing infiltration is of particular importance, it will generally be necessary to reject simple one-layer designs in favor of multilayer systems which include a clay soil layer or a synthetic membrane liner. • Evaluate cover thickness (Steps 9-13)—In addition to federal and state cover requirements, the cover thickness may be governed by the quantity of borrow available, infiltration, gas migration, trafficability and support requirements, freeze/thaw and dry/soak effects, cracking, differential settlement, membrane protection, and vegetative requirements. These factors should be addressed in permit applications. 9-194 ------- • Evaluate cover placement procedure (Steps 14-13 .'--Cover can be improved in several ways as it is constructed. Materials mav be added for better grading, hauling and spreading equipment can be operated in a manner which increases compaction, and layering can be used. Internal layering can combine favorable characteristics of several materials. Synthetic membrane liners used in this configuration should be at least 20 mils thick and should be placed in a relaxed state between smooth layers of soil to orevent d-mage. Syr,'hati~. l-lr.arc are oi-^n necessary to maintain permeability at or below that of the bottom liner system. • Evaluate configuration (Steps 19-20)—Configuration should u<= sjv.1' ",ated ;n t-rns :f -re-sun potential and infiltration control. Erosion has the effect of degrading the cover, thereby seriously reducing its effectiveness. • Evaluate drainage (Steps 21-24)—The application should address surface runoff drainage for the cover and surrounding area. Ditches and culverts snould be sized to handle the design storm runoff. The evaluator should apply design storm data to Manning's equation co check the specified dimensions. • Evaluate vegetation (Steps 25-32)—Establishment and maintenance of vegetation requires an evaluation of soil type, nutrient and pH levels, climate, species selection, mulching, and seeding time. Species should be selected on the basis of environmental and biological strengths and limitations. 9.4.3.2.3 Evaluate Post-Closure Plan (See Figure a.4.4) • Evaluate maintenance procedure (Steps 33-35)—Regular maintenance intervals should be planned to repair settling and erosion damage and to maintain the vegetative cover. Provisions should also be made for site monitoring by a qualified technical person to periodically inspect the cover condition and take ground water samples. • Evaluate contingency plan (Steps 36-39)—A contingency plan should be established to deal with future unforeseen problems such as excessive wind and water erosion, loss of vegetation, and drainage system failures. The evaluator should consider the likely effectiveness of post-closure plans to address such problems in a timely manner. The procedural information provided above was obtained from EPA Publication SW-867. Information contained in this document can be supplemented with other references listed in Section 9.4.5. 9.4.3.3 Other Sources of Information— An example of the kind of general evaluation data that can be obtained from symposia proceedings is presented in Table 9.4.1. The table is excerpted from a paper entitled "'Containment1 Strategies to Manage Abandoned Hazardous 9-195 ------- < i i i i i t t i I I I I i i i i i i I t I I I I I I I 1 1 1 I II II t I I I I I I I » i i i « as p < o as — ' u _z a 3 _j M < D S •• U as u i i i i {OJ3UOO 1 | 1 t i i 1 1 1 1 (till) • •6 a. • & g • u o o u • 3 SS 2 -9 * • e o rr *• • « 1 « c -• u -I ! r 2 • c -< ! I & - i I -rf •o; • • s % s-i — "o 9-L96 ------- Waste Sices in a Cost Iffactive Manner, presented ac cne Fiftn .Annual Madison Conference by WESTON Designers/Consultants of West Chester, Pennsylvania. 10 The table evaluates various cover materials by indicating positive performance ratings with a plus sign and negative performance ratings with a minus sign. Additional information that a permit writer can use to evaluate post-closure plans is included in Reference 3 (EPA-600/2-79-165) . Papers presented in Reference 5 by Lutton^i and Rogoshewski^ provide information on repairs to cover systems. A worksheet for determining the adequacy of closure and post-closure procedures is presented in Figure 9.4.5. Condition M of Permit Module II addresses closure and post-closure permit requirements. Performance standards of the condition are implemented through reference to a permit attachment that includes plans and specifications for the proposed closure and post closure plan. To be suitable for substitution in the permit condition attachment, the submitted application information should include: • Detailed plans and an engineering report describing design and construction of the final cover, and • A post closure plan describing maintenance and monitoring procedures following closure. 9.4.5 References 1. U.S. Environmental Protection Agency. Permit Applicants' Guidance Manual . for Hazardous Waste Land Storage, Treatment, and Disposal Facilities. Volume I. Office of Solid Waste. Washington, D.C. 1983. 2. U.S. Environmental Protection Agency. RCRA Technical Guidance Document (Draft) Landfill Design, Liner Systems and Final Cover. July 1982. 3. U.S. Environmental Protection Agency. Evaluating Cover Systems for Solid and Hazardous Waste. Second Edition. SW-867. September 1982. 4. Design and Evaluation of Covers for Solid Waste Landfills. EPA-600/2-79-165. August 1979. 5- Municipal Solid Waste: Land Disposal, Proceedings of the Fifth Annual Research Symposium (Orlando, Florida - March 26-28, 1979), EPA-600/9-79-023a, U.S. EPA, MERL/CINN, August 1979. 6. Disposal of Hazardous Waste. Proceedings of the Sixth Annual Research Symposium, (Chicago, Illinois - March 17-20, 1980), EPA-600/9-80-010, U.S. EPA, MERL/CINN, March 1980. 9-197 ------- LANDFILL CLOSURE AND POST-CLOSURE 'Has this part of Che applicant's submittal been reviewed and evaluated? Yes No Have the physical characteristics, volume, and spacial distribution of soil types been documented? Yes No '-las ;he sice uopograpny seen examined to assist in evaluating: 9 Slope stability? Yes No • Water erosion? Yes" "N------- oeen evaluated on the basis of: 9 Stace ana Federal requirements? Yes No • Quantity of borrow available? Yes No • Infiltration? Yes No * Gas migration? .'c3 .,O • Traffic support requirements? Yes" No * Freeze/thaw and dry/soak effects? Yes No • Cracking? Yes No • Differential settlement? ' "Yes No • Membrane protection? Yes No • Vegetative requirements? Yes No Do cover placement procedures include an evaluation of: • Cover composition? Yes" No • Internal layering? Yes No • Top soil? Yes No • Time of construction? Yes "No" • Proposed construction techniques? Yes No Figure 9.4.5 (continued). 9-199 ------- Has che cover configuration been analyzed in terms of • Erosion potential? • Infiltration control? Has surface J.r-ii.iags ':~tin evaluated for: * Dicch design? » Culvert design? * Gas migration? fias the vegatative cover been evaluated in terms of: • Soil type? • Nutrient and pH levels? • Climate? • Species selection? • Seeding time? Post-closure Have regular maintenance intervals been establishd to: • Identify and repair settling and erosion damage? • Maintain the vegetative cover? • Monitor ground water? Figure 9.4.5 (continued). Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No 9-200 ------- Has a contigency plan been astabiisnea :D pr-^-i-ia f-r: • Erosion damage repair? • Yes No" • Vegetation repair? Yes No~ • Drainage renovation? YesNo" • Cover deterioration repair? YesNo" Figure 9.4.5 (continued), 9-201 ------- Land Disposal: Hazardous Wasce, Proceedings of the Seventh Annual Research Symposium (Philadelphia, Pennsylvania, March 16-18, 1981), EPA-600/9-81-002b, U.S. EPA, MERL/CINN, March 1981. 3. Land Disposal of Hazardous Waste, Proceedings of the Eighth Annual Research Symposium (Ft. Mitchell, Kentucky-March 8-10, 1982), EPA-600/9-82-002, U.S. EPA, MERL/CINN, March 1982. 9. Fifth Annual Madison Conference of Aopliad ".esearcr. and Practice on Municipal ana Industrial Waste, September 22-24, 1982, (Proceedings), Sponsored by the Department of Engineering and Applied Science, University of Wisconsin-Extension, Madison, WI. 10, Wesron r^si^nsrj/CotisuiCdncs. "Containment" Strategies to Manage Abandoned Hazardous Waste Sites in a Cost Effective Manner. Paper presented at the Fifth Annual Madison Conference (see Reference 3). 11. Lutton, R. J., et al., "Case Study of Repairing Eroded Landfill Cover" 12. RogoshewsKi, P. J. and R. 3. Wetzel, "Handbook for Remedial Actions at Waste Disoosal Sites." 9-202 ------- 9.5 HANDLING AiNO DISPOSAL OF IGNITABLE OR REACTIVE PASTES 9.5.1 The Federal Requirements Paragraph (f) of §270.21 requires the following information in Che permit application: "If ignitable or reactive wastes will oe landfilled, *n explanation of how f.be standards of 5254.312 viil oe complied vith." The Part 264 standards to be supported are the special requirements of §264.312, which state: '(a; Except as provided in paragraph (b) of this section, and in §264.316, ignitable or reactive waste must not be placed in a landfill, unless the waste is treated, rendered, or mixed before or immediately after placement in a landfill so that: (1) The resulting waste, mixture, or dissolution of material no longer meets the definition of Ignitabla or reactive waste under }§261.21 or 261.23 of this Chapter; and (2) Sec'ion 264.27(b) is complied with. (b) Ignitable wastes in containers may be landfilled without meeting the requirements of paragraph (a) of 'this section, provided that the wastes are disposed of in such a way that they are protected from any material or conditions which may cause them to ignite. At a minimum, ignitable wastes must be disposed of in nonleaking containers which *re carefully handled and placed so as to avoid heat, sparks, rupture, or any other condition that might cause ignition of the wastas; must be covered daily with soil or other noncombustible material to minimize the potential for ignition of the wastes; and must not be disposed of in cells that contain or will contain other wastes which may generate heat sufficient to cause ignition of the waste." The referenced §264.17(b) requirements stipulate that: "(b) Where specifically required by other Sections of this Part, the owner or operator of a facility that treats, stores or disposes ignitable or reactive waste, or mixes incompatible waste or incompatible wastes and other materials, must take precautions to prevent reactions which: (1) Generate extreme heat or pressure, fire or explosions, or . violent reactions; (2) Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health or che environment; (3) Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosions; (4) Damage the structural integrity of the device or facility; (5) Through other like means threaten human health or the environment." 9-203 ------- 9.5-2 Summary ;f "ecassary .-ippncacion Inrorrnacion The Part 3 Permit Applicants' Manual^- requires the applicant Co submit information according to two optional requirements, as follows: • Option 1 a description of the methods of treating ignitable or reactive wastes before or immediately after placement in the landfill, results of field or laboratory tasting _Lljscrating ;hat tne wastes will be rendered nonreactive or nonignitable, and a description of how §264.17(5) will be complied with. • °T:;cn 2 'jpeiieaoie only co ignicaole wa^.es in containers) a description of how ignitable wastes disposed of in containers will be protected from materials or conditions which could cause them to ignite, including handling procedures, daily cover characteristics, and characteristics of other wastes placed in the same cell. The documentation provided should be based on scientific and engineering literature, pilot or bench scale tests, waste analyses, or the results of similar treatment based on experience or case histories. 9.5.3 Guidance on Evaluating Application Information 9-5.3.1 Regulatory Applicability and Intent— Figure 9.5.1 is a summary of applicable regulations that the applicant must address if he plans to handle and dispose of ignitable or reactive wastes. The requirements of §264.312 reflect the interim status standards (§265.312) for ignitable and reactive wastes. The interim status standards (§265.312) and the permitting standards (§264.312) for ignitable and reactive wastes have been discussed in the preambles of several Federal Register Notices. The following Moticas contain applicable information.. Federal Register Notice Date Page Vol. Section Affected 19 May 1980 33162 45 §265.17 19 May 1980 33182 45 §265.17 19 May 1980 33213 45 §265.312 12 Jan 1981 2809 46 §264.17 & §265.17 5 Feb 1981 11148 46 §264.312 20 Feb 1981 13492 46 §265.312 29 Jun 1981 33507 46 §265.312 17 Nov 1981 56592 46 §265.312 25 Feb 1982 8304 47 §265.312 26 Jul 1982 32331 47 §264.312 26 Jul 1982 32333 47 §265.312 9-204 ------- ARE IGNITABLE OR REACTIVE WASTES TO BE PLACED IN THE LANDFILL? YES WILL THE WASTES SE DISPOSED OF IN CONTAINERS? V'ES WILL THE WASTES 3E IGNITABLE OR REACTIVE AFTER PLACEMENT IN THE LANDFILL? YES APPLICABLE REGULATIONS HAVE NOT SEEN ADDRESSED ARE THE PRECAUTIONS OF §264.I 7(b) COMPLIED WITH? YES IS DOCUMENTATION OF =264.I7(b) COMPLIANCE PROVIDED? DO THE DISPOSAL CONTAINERS AND DISPOSAL PROCEDURES COMPLY WITH §264.312(fa)? NO YES APPLICABLE. REGULATIONS HAVE BEEN ADDRESSED 00 THE DISPOSAL CONTAINERS AND PROCEDURES COMPLY WITH 3264.316? NO YES YES APPLICABLE. REGULATIONS \> HAVE BEEN ^X ADDRESSED APPLICABLE /REGULATIONS N. HAVE BEE ^ADDRESSED Figure 9.5.1. Applicability of regulations to handling and disposal of ignitable and reactive wastes. 9-205 ------- The following Notices contain preamble discussions of §261.21 and §251.23. rheae sections of 40 CFR Part 261 identify criteria for ignitable and reactive wastes. Federal Register Notice Date Page Vo 1. Section Affected I i. 9 9 9 7 May Jul 3.3.1 1930 1981 . 1 Are 5 ., L J i 33109 35246 ignitable *•» .y 45 46 or reactive wastes § § § Co be placed in Che 261.21 261.23 251.21 landfill?~If an applicant provides information that none of the wastes intended for disposal in the landfill are reactive or ignitable, this section is not applicable. Information that would be acceptable includes the results of tests or analyses conducted on the wastes by the landfill owner/operator or the waste generator. Documentation based on scientific or engineering literature may also be acceptable. If the applicant has demonstrated chat all wastes are neither ignitable or reactive, Che permit writer must indicate in the permit that ignitable or reactive wastes are not permitted for receipt or disposal at the landfill. The characteristic of ignitability is exhibited by a solid waste if it has any of Che four properties listed in §261.21(a). Specifically, !251. 21 (a) (L; addresses liquids, § 261 .-2-Ka) (2) addresses nonliquids, S261.21(a)(3) addresses compressed gas*s, and §261.21(a)(4) addresses oxidizars. The provisions of § 261.21(a)(1) identify three ASTM standard methods that can be used to determine ignitability. They are: • ASTM Standard D-93-79 • ASTM Standard D-93-80 • ASTM Standard D-3278-73 These methods are also described in Section 2.1.1 of "Test Methods for Evaluating Solid Waste-Physical/Cheraical Methods" (July 1982) Second Edition, SW-8462 along with methods for ignitable compressed gases and oxidizers. The characteristic of reactivity is exhibited by a solid waste if it has any of the eight properties listed in §261.23(a). Those properties are based largely on the definition employed by the National Fire Protection Association. The NFPA's headquarters are in Batterymarch Park, Quincy, MA and there is also a Washington, D.C. Office. Telephone numbers are: General and Executive (617) 328-9290 Publicaton Sales (617) 770-3002 Washington, D.C. Office (202) 484-8200 9-206 ------- Secailea information on identification and casting of reactive wastes is provided in Section 2.1.3 of SW-346. In addition to using the methods referenced in the regulations, the permit applicant may use other methods to determine ignitability or reactivity if he has petitioned and received approval from the Administrator, as allowed under §260.20 and §260.21. If the permit reviewer encounters methodologies whose acceptability cannot be determined, SW-346 suggests contacting the Manager, Waste Analysis Program 'WH-'^S/, Wasce Jljaraccenzation Branch, Office of so Lid Waste, Washington, D.C. 20460 (202) 755-9137 for assistance. 9.5-3.1.2 Will ignitable or reactive wastes be treated before or immediate1.-' after disposal?—There are two "eaui.-emantc In J254.312va; regarding disposal if i^nitaali or reactive wastes in landfills. First, the ignitable or reactive waste -ust be treated, rendered, or mixed before or immediately after placement in the landfill so that the resulting waste, mixture, or dissolution of material is ao longer ignitable or reactive. Second, the provisions of §264.17(b) must be complied with. To satisfy :he requirement of §264.312(a), the landfill permit applicant must document in the permit application,that the materials and procedures employed at the landfill, either before or immediately after waste disposal, will be such that the waste will no longer meet the definitions of ignitable or reactive, as specified in Part 261. 9.5.3.1.3 Are the precautions of §264.17(b) complied with?—If the owner/operator proooses to treat i^nic-srble and/or reactive wastes, he raus't comply with §264.i7(b) of Subpart B of Part 264. This stipulation requires the owner to "take precautions to prevent reactions wnich...threaten human health or the environment." There are four specific types of reactions listed in §264.17(b) which must be prevented? as listed in subsection 9.5.1. 9.5.3.1.4 Is documentation of compliance with §264.17(b) provided?— Documentation that the precautions of §264.17(b) will be effective is required by §264.l7(c), as follows: "When required to comply with paragraphs (a) or (b) of this Section, the owner or operator must document that compliance. This documentation may be based on references to published scientific or engineering literature, data from trial tests (e.g., bench scale or pilot scale tests), waste analyses (as specified in §264.13), or the results of the treatment of similar wastes by similar treatment processes and under similar operating conditions." The owner or operator of a landfill who is treating ignitabla or reactive wastes must document that the treatment employed will not itself be hazardous. The permit application may be judged dificient if the required documentation is not submitted or if it is judged to be inadequate. 9-207 ------- 9.5.3.1.5 Will containers of ignitable wastes be disposed of, and if so, disposed of in compliance with §264.312(b)?—Section 264.312(b) allows landfilling of containerized ignitable waste if: • the containers are not leaking, • container handling and placement will avoid heat, sparks, rupture, and ignition of the waste, • the containers are covered daily with noncorabustible material, and * the containers are not placed in landfill cells that do or vill 'or.t^in vasras thac generate aeac sufficient to cause ignition of the ignitable waste. Note that §264.312(b) applies only to ignitable wastes in containers. A permit application which proposes to dispose of containerized reactive wastes under §264.312(b) should be judged inadequate. Reactive wastes may be disposed of in lab packs under cartain circumstances consistent with the requirements of §264.316(e), as discussed below. Otherwise, such wastes must be rendered nonreactive and disposed of in accordance with §264.312(a). 9.5.3.1.6 Do containers and handling procedures comply with §264.316(e)?— Paragraphs (a)through(d) of §264.316 deal with the disposal of any hazardous waste at landfills when the waste is in small containers in overpacked drums (lab packs). The requirements of those paragraphs and the related §264.315 requirements are discussed in subsectian 9.8. However, the requirements of paragraph (e) of §264.316 are applicable to reactive wastes in containers, as follows: • for other than cyanide- and sulfide-bearing wastes,* the waste must be treated or rendered nonreactive before containerization in lab packs, or • for cyanide- and aulfide-bearing wastes, the wastes can be containerized in lab packs without being treated or rendered nonreactive. Thus, for all reactive wastes that are not cyanide- or sulfide-bearing, the waste must be treated or rendered nonreactive before it can be placed in a landfill, regardless of whether it is in a lab pack. However, cyanide- and sulfide-bearing reactive wastes in lab packs can be landfilled without being treated or rendered nonreactive, but only if the containerization complies with paragraphs (a) through (d) of §264.316 for lab packs, as discussed in subsection 9.3. *Cyanide- and sulfide-bearing wastes are defined in §261.23(a)(5) of Subpart C of Part 261. 9-208 ------- The firsc requirement of §264.316(e) mandates that the reactive wastes (other than cyanide- and sulfide-bearing) oe treated or rendered nonreactive before concainerization in lab packs. This activity will typically be conducted by the generator and not by the owner or operator of a landfill. In these cases, the permit application should incorporate documented assurances from the generator to the landfill owner or operator that the noncyanide- and nonsulfide-bearing reactive wastes have been rendered nonreactive before lab pack containerization. The documentation should contain details of the materials and procedures chat vill ba -nployeci jy cne generator. In some cases, even cyanide- and sulfide-bearing reactive wastes may be rendered nonreactive by the generator before containerization in lab oacks. It is recommended chat the ~er~it: -^vi^wer raquesc documentation which indicates cne procedures employed to transform the cyanide- or sulfide-bearing wastes. 9.5.3.1.7 Summary The listing below is a summary of the key points which the owner/operator raus:: address to comply with the regulations governing the disposal of ignitable and reactive wastes in landfills. • Demonstrate whether the wastes to be placed in a landfill are ignitable or reactive. • Document treatment methods to render the waste nonignitable or nonreactive. • Document that procedures for handling and disposal of ignitable and reactive wastes are adequate to prevent harm to humans and the environment. • If the owner/operator does not intend to render ignitable wastes nonignitable, then he must stipulate that the waste will be containerized in nonleaking containers and disposed of in a manner that will avoid ignition or reaction of the wastes. • If reactive wastes are to be disposed of in lab packs, the owner/operator must demonstrate that the waste will be rendered nonreactive before containerizacion in lab packs unless the wastes are cyanide- and sulfide-bearing reactive wastes. 9.5.3.2 Evaluation of the Technical Adequacy of the Applicant's Subraittal— Figure 9.5.2 presents the major topics that are discussed in this subsection. The permit reviewer should first determine which of the technical topics are applicable to the facility and operation of concern. For instance, if the applicant proposes to containerize ignitable wastes in conformance with the requirements of §264.312(b), then the discussion about treating, rendering, or mixing the waste so that it is no longer ignitable or reactive does not apply. If any applicable topics are not adequately addressed by the applicant, the application and the proposed disposal methods may be technically deficient. 9-209 ------- IGNITABLE OR REACTIVE WASTE METHODS TO TREAT, RENDER OR MIX THE WASTE SO THAT IT IS NO LONGER IGN)TABLE OR REACTIVE LISTS OF IGNITABLE AND REACTIVE WASTE CONTAINERIZED IGNI TABLE WASTES TEST FOR COMPATIBILITY NONLEAKING CONTAINERS TEST TO DETERMINE • WASTES ARE IGNITABLE OR REACTIVE CAREFULLY HANDLE • CONTAINERS TO PREVENT IGNITION COVER DAILY SEGREGATE FROM HEAT GENERATING WASTES Figure 9.5.2. Flow diagram for evaluating the technical adequacy of the application for disposal of ignitable or reactive waste. 9-210 ------- 9.5.3.2-i. Listj ; f IgnJCdoia ana Reactive Wastes — In Part 261, Subpart D - Liscs of Hazardous Wastes, ignicable wastes are identified by an "(I)" and reactive wastes are identified with an "(R)". Table 9.5.1 lists the hazardous wastes, by EPA Hazardous Waste Number, which are identified in Subparc D as being ignitable. Table 9.5.2 lists the hazardous wastes, by EPA Hazardous Waste Number, which are identified in Subpart D as being reactive. At a minimum, if the applicant indicates that any of these wastes will be disposed in a landfill, he must document how compliance with §264.312 will be achieved. The oermit ravi-wer snouia rerer to EPA-600/2-80-076, A Method for Determining the Compatibility of Hazardous Wastes (Reference 3), which provides a list of 174 chemicals which are extremely reactive. If these "extremely reactive" compounds are mixed with water or -wast other compounds, heat may be ^eneratad. ;r .s:;iw a»iu/or. riaramable gases may be produced. In addition, explosions may occur, or highly unstable mixtures may result. If the following materials are mixed with water, flammable gas will be generated: 9 Metals, such 93 sodium and potassium • Sulfides, Inorganic • Strong Reducing Agents Refaranca 3 ai^o provides a list -of materials which are combustible and flammable and a list of materials which are explosive. A worksheet for determining the adequacy of the applicant's information on identification of ignitable and reactive waste is presented in Figure 9.5.3. 9.5.3.2.2 Methods to Treat, Render, or Mix Waste so that it is no longer Ignitable or Reactive — There are a number of methods available to treat, render, or mix wastes so that they are no longer ignitable or reactive. Several treatment processes which previously were only used in the organic or inorganic chemical industry are being considered for broader application in the treatment of hazardous waste. Over 50 processes have been demonstrated to be applicable to hazardous waste treatment, although the technical and economic feasibility of a number of these processes has not been demonstrated on a commercial scale. JRB has identified several of the most promising nonbiological treatment methods along with general information regarding feed stream requirements, output streams, and the current state of technology .4~9 An overview of these technologies is presented in Table 9.5.3 (after Reference 4). The applicant may propose to employ one or a combination of these methods to treat igni'ible or reactive wastes. The applicant may propose to render ignitable or reactive compounds nonignitable or nonreactive by diluting the waste with other compatible material. However, dilution has the disadvantage that hazardous reactions may result if the mixed materials are incompatible. Dilution with liquids is undesirable because of added liquids in the landfill and greater attendant 9-211 ------- TABLE 9.5.1. IGNITABLE WASTES EPA hazardous waste No. Hazardous waste F005 U001 U002 U003 U008 uci: U012 U019 LT239 U056 J055 U169 U085 U031 U159 U074 U031 U156 U055 U056 U057 U074 U085 U092 U110 Spent ncnnaiogeriatea solvents Spent nonhalogenated solvents Acetaldehyde Acetic acid, ethyl ester Acetone Acatonitrile Acrylic acid Aniline Benzenamine Benzene Benzene, dimethyl- Benzene, hexahydro- Benzene, -C-l-me thylethyl), Benzene, -nitro- 2,2-bioxlzane c-butanoi 2-butanone 2-butene, 1,4-dichloro- n-butyl alcohol Carbonochloridic acid, methyl ester Cunmene Cyclohexane Cyclohexanone 1,4-dichloro-2-butene 1,2:3,4-diepoxybutane Dimethylamine Dipropylamine (continued) 9-212 ------- TABLE 9.5.1 (continued) EPA hazardous waste No. Hazardous waste U001 U008 U117 U112 U113 U115 UL17 U125 U213 U125 U124 U140 U152 U092 U045 U153 U154 U154 U186 U045 U156 U159 U161 U162 U161 U169 U171 Ethanol Ethanenitrile dC.i^ns. - ? j. ~ o x ~ T o i ^ EChyl acetate Ethyl acrylate Ethylene oxide Ethyl ether 2-furancarboxaldehyde Furan, tetrahydro- Furtura1 Furfuran Isobutyl alcohol Methacrytonitrile Methanamid-e, N-methyl Methane, chloro- Methanethiol Mechanol Mechyl alcohol 1-tnethyl butadiene Mechyl chloride Methyl chlorocarbonate Methyl ethyl ketone Methyl isobutyl ketone Methyl methacrylate 4-methyl-2-pentanone Nitrobenzene 2-nitropropane (continued) 9-213 ------- 7A3LZ 9. j . i EPA hazardous waste No. nazaraous waste U115 (J186 U110 U171 U140 J002 U152 U008 U113 U162 U213 (J153 U239 Oxirane 1,3-pentadiene 1-propanamine 1-propanaraine Propane, 2-nitro 1-propanoL, 2—mechyl 2-propanone 2-propenenicri le, 2 2-propenoic acid 2-propenoic acid, ethyl ester 2-propenoic acid, 2-methyl-, methyl ester n-propylamine Tetrahydrofuran Thioraethanol Xylene 9-214 ------- TABLE 9.5.2. REACTIVE WASTES EPA hazardous waste No. Hazardous waste FOG: F008 JCG9 F010 F011 KG 11 K013 K027 £044 K045 K047 P009 P065 P112 P081 P009 P112 PI 12 Spent cyanide plating bath solutions ... Plating bath sludges ... jpenc stripping and cleaning bath solutions ... Quenching bath sludge ... Spent cyanide solutions from salt bath ... 3otCom stream rrom wastewater ... aerylonitri le Bottom stream from the acetonitrile column ... Centrifuge and distillation residues from toluene diisocyanate production Wastewater treatment sludges from the manufacturing and processing of explosives Spent carbon from the treatment of wastewater containing explosives Pink/red water from TNT operations Ammonium picrate Mercury fulminate Methane, tetranitro- Nitroglycerine Phenol, 2,4,6-trinitro-, ammonium salt Te tra ni trome thane Zinc phosphide (continued) 9-215 ------- TABLE 9.5.2 (continued) EPA hazardous wa s C e No. Hazardous waste U006 U223 U020 U023 U024 U023 U160 U033 U033 U133 Q096 U006 U133 U086 U189 U205 U189 U205 U223 U234 Acetyl chloride Benzene, 1,3-diisocyanatomechvl Benzenesulfonyl chloride Benzene, (trichloromechy1) Benzene, 1,3,5-trinitro- Benzotrichloride 2-butanone peroxide Carbon oxyfluoride Carbonyl fluoride Examine Alpha, alpha-dimethylbenzylhydroperoxide Ethynol chloride Hydrazine Hydroperoxide, 1-me thy1-1-phenyethyl- Phosphorous sulfide Selenium disulfide Sulfur phosphide Sulfur selenide Toluene diisocyanate Sym-trinitrobenzene 9-216 ------- HANDLING AND DISPOSAL OF IGNITABLE OR REACTIVE WASTES Has this part of the applicant's subraittal been read and evaluated? Yes ;io Did the applicant identify any wastes as being hazardous or Yes No Are chere any additional wastes listed in subsection 9.1 which are ignitable or reactive according to Tables 9.5.1 and 9.5.2? Yes No Figure 9.5.3. Worksheet for evaluating the applicant's subtnittal on ignitable and reactive waste identification. 9-217 ------- C/3 CeJ C^ y? O"~* 25 a, H z jj s <: a .aj «5 jj ™< 1 ^ CO 1 Z3 O C .J •"••-* 3 4 9 W 3 U * 'J i 4 3 — U i- 0 — i o <** y «l -4 3 79 3 J w ao t> 3 U f D £ I V 9 — ' 3 •* n u s w •9 -9 - y -* V D a i- u -i V *^ a V — V 73 V * 73 I 3 ? « 73 S 3 a - -. f X U If «l - •*) n — < 03X0 — 1 M U 3 X V w a — > u S V O fl. 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L, * 3 « 0 4 a ol *4 j 3 4 ^ u I 5 ; 4J 3 O 4 * — * 4 -"I i » 1 II 73 O U — I V O A y w 5 5 as j 2* = Aqueous aolut ions con Id -• I0t metal a or nomnetal aniona. u y S 3 4 ess oxidize** or red e components at the ace of conduct ive trodea iouereed in . trolyte. y w •+* y u O « w V (U u 4 3 ,— i .4 A* 2 n 4) 4) * O U - u J V 7 -1 u a -^ C *rf 50 aOO-a. a» D« - «•->«&•« sa. 3 4fCW4])4>- u " u 4 4J y 43 - O 00 M u * o no 1 ^u3OafU4)tMU > 3*o^^3Xa.*j^ * • 73 4 » — * •M 41 v y « — 34 V X 73 y u 3 y 3 X « IM • • X W » W -3 , v hi 3 * 73 3 -* V - — y - 73 a 4 fi - 4 1 -« J * Treats organic liquid, aludge 01 ao) id wd^tet • Nu ci>uc tnt r*j t iou limit * Hy drai yit*ble organica eaters, ethera. nitril organiphoaphuru« peat i ha logenated compound a, etc. i y X 4 O « X *rf « U 4 T3 y ^ + £ C fl w i) O •- > 3 B -•3X0 v *j O . w 4—73 a. 73 — ' D 4 0 O -« 4* b «w (M •« ^ t 00 £ U w *J 4) V 4 4 73 .a * y C X O > X 4 4J 1*4 X — « 4) 4_f O — u ------- 3 V 3 « m I » <*i a «9 Jj 3 S 3 O » i- s -u w > — -3 C — - a. * 3 5 4( - ; = — 2 y u j —" -3 T? —. -t 5 =? = J 5 ? - *J — w o > • 2-^i.;^^ « 3 a. u = " asi Ii i U — O JJ - ? * « -T Ul O JJ u e u — *J O X ^ « I " •» s s ,j 55 r- -• 23 5-- 3^ » "S. !" u » — * ¥ 3 3 3- 0-5 •u s .2 • I •3 v r •3 - ^««Ssi^.s: ^ = .- ^ s:ul 0101 u a, i 8 ^ a .M 3 i a M « V 55" 4 0 « fl S • V ZZ w .N ° S o 4J c ... -. o a 15 — U 3 o a- o °.: o-± : §-2 22 S O i» -. c ; 5 U .0 — • o 21 - <9 -^ "5 -o 2 U •* *J i 3 £ I = ° • s 91 « a c v « » a u 5 L, * 3 ao O M 3 -j fl -, * - ..2 J S7S- e - — - " a "a '3 y *d u g. r So S4T 3% § f.2 - 3 — O a I " 9-219 . ------- •» -3 J * y > J; T) V > o 9 a •o 0 n •a * 3 1 i a a S 2 <4 i. k 11 9 u •u > a o 4 > 0 a u & m , " V u • — I i 4 ^ s 3 ^ i i z o 1 a X 3Q a 3 U V - 3 U a *4 « U « J£ C J a 3 •" 3< a. a. w 3 •*) C a. ^ -. w 9B Phenol , U T! 3 'J V 0 3 1 3 3 "Jn» 30 a. a. u 3 U T3 X •^J U kJ 2 w _, -S W "y> \ x •^ 3 1^ V 1 = J1 — Cdrbonjt o — O 'J U 41 — W a. a D ^ ^ I u - -c c " 3J -. 3 3 -3 « w f 9 - v 13 II 3 m •J"! 39 - i ^ S-.2 U O M — 3 fl 3 3 3» V 0 < » e 38 ^ " "O Li e «* 3 91 ^ « - MT3 » ^ a *" - - 3 * -9 U 3 t4 « » 3 ; >. T v u -» M V -;!! -• O ** , J O •— c 3 a. .3-1 5 o W >*4 i a 3-2 S •% u U o i a -o . 0 V V -t u c w 4 o 5-3 S 3 8J- — •o a. 2 "2 i i I 8 W IM a j £•2 5-2 —• X V ? Ss r s •a * « 9 ~- u M 41 2 ?, ^3S 9-220 ------- leachace generation. If other than a small quantity of waste requires dilution, an alternative treatment process should be selected Co minimize tha landfilling of liquids. The reviewer should consider incineration as an alternative to the disposal of ignitable or reactive wastes. Incineration is particularly applicable Co ignitable materials since wastes containing solvents and other organic materials are easily incinerated. Incineration reduces waste volume so that :he remaining Tuicanal xi.i± require ^ess space when disposed of at a landfill. Incineration may reduce the potential for groundwater contamination from the ash compared to that associated with disposing of the parent waste. There are i number if a.ata jourcaa «nicn ,tiay assist the reviewer in evaluating an applicant's,proposed method of waste treatment, including References 10 through 18 which are listed in subsection 9.5.5. Chapters 8 and 9 of MeCry (Reference 10) list an additional 200 references on physical and chemical treatment of hazardous waste. 9-5.3.2.3 Test for Compatibility--Referenca 3 (Hatayaraa at aI., EPA-600/2-80-076, April 1980) addresses hazardous waste compatibility and incorporates a hazardous waste compatibility chart (see subsection 9.7 of this manual) which illustrates the compatibility of 41 binary combinations of hazardous chemical wastes. The reason for incompatibility is noted for each combination. Acurex is developing a test kit to assist in categorizing unKnown wastes into one of these 41 reactivity groups.^9 Although most applicable to distinguishing and handling otherwise unknown wastes at Superfund si:as, tne technique may also oe of value in managing wastes at RCRA facilities. 9.5.3.2.4 Testing of Ignitable and Reactive Waste—If treatment will be used to render wastes nonignitable or nonraactive and the wastes will then be handled without special consideration for ignitaoility or reactivity, the applicant must test or document by some other means that the waste is truly no longer ignitable or reactive. If testing is to be e^oloyed, the applicant must specify what testing procedures he will use. Available methods to test for ignitability are set forth in §261.21. Two test methods are acceptable for determining the flashpoint: Pensky-Martens Closed Cup Tester using the test method specified in ASTM standard D-93-79 or D-93-80, or a Steaflash Closed Cup Tester, using the test method specified in ASTM Standard D-3278-78. These procedures are documented in Test Methods for Evaluating Solid Waste (SW-346).2 To test if a treated waste has the characteristics of reactivity, the applicant should base his demonstration on tests for: water reactivity, flashpoint/flammability, oxidation/reduction potential, pH, and the presence of cyanide or sulfide. The testing procedures employed should conform with the ASTM standards and test methods incorporated in SW-846.2 A worksheet for determining the adequacy of he applicant's submittal on ignitable and reactive waste treatment is presented in Figure 9.5.4. 9-221 ------- TREATMENT OF IGNlTAdLE OR .^ACTIVE BASTES Are treatment procedures conducted prior to or immediately following placement in the landfill? YesNo Are treatment processes consistent with those described In cais subsection and cited references? YesNo During treatment operations, are orecautions ".aken -o prsvent: • Extreme heat or pressure, fire or explosions, or violent reactions? Yes No • Uncontrolled toxic -aists, fumes, dusts, or gases? Yes No • Uncontrolled flammable fumes or gases? Yes No Damage to the structural integrity of the device or facility? Yes No Has the applicant specified a test pracedure for ensuring that treated wastes are nonreactive or nonignitable? Yes No Figure 9.5.4. Worksheet for evaluating ignitable and reactive waste treatment procedures- 9-222 ------- 9,5.3.2.5 Containerized Ignitaole Waste—Rather than treat, render, or mix an ignitable waste so that it is no longer ignicable, :he applicant may propose co landfill ignicabla waste in containers. However, improper handling of ignicable wastes in containers could result in fire or explosion. Containers should be handled with nonsparking tools and equipment. The applicant should specify the safety pro-^dures that will be employed when handling ignitable wastes. When disposing of ignitable wastes in containers, the reviewer must .evaluate the application for compliance with §264.314. This standard requires chat containers placed in a landfill must be greater than 90 percent full. if such containers are ±asa cnan 90 percent full and fillers will be used, the permit reviewer should assure that the fillers are nonreactive and request supporting documentation, if necesary. Further discussion of fillers is provided in subsection 9.7 of this manual. When disposing of ignitable wastes in containers, the reviewer must also evaluate the application for compliance with §264.314(b)(1). This standard requires that "free liquids" be removed prior co placement of containerized wasce in a landfill if che landfill is not equipped with a liner and leachate collection and recovery system. The reviewer should refer to Section 8 of this document which discusses methods co remove "free liquids" from containerized waste. The applicant should specify the types of containers which will be employed to dispose of ignicable or reactive wastes. The containers should be in good condition (e.g., no apparent rusting or structural defects). The permit reviewer may elect co require that all containers meet the container requirements of che Department of Transportation Regulations ^.Suopart D - Specifications for Metal Barrels, Drum*, Kegs, Cases, Trunks, and Soxes). 9.5-3.2.6 Nonlaaking Containers—The applicant must demonstrate how he will check to determine chac all containers are in good condition. Inspection procedures Co be conducted prior to container burial should be documented in che application. If any containers are found to be leaking, the waste must be reconcainerized or removed and treated to be rendered nonignitable or nonreactive. Rather Chan open a damaged container and transfer the concents to a container in good condition, it may be advisable for Che operator to place the damaged container inside an overpacked drum. If a void space exists between the over pack and damaged container, the space should be filled so Chat the over pack is at least 90 percent full. To fill che void space, the applicant should employ a compatible absorbent material. Subsection 9.7 of this document presents further discussion of applicable fillers and absorbents. 9.5.3.2.7 Carefully Handle Containers co Prevent Ignition—The applicant must specify container handling methods co avoid heat, sparks, rupture, or any other condition that might cause ignition of the waste. The applicant should specify the types of container handling equipment and tools that will be employed. All tools and equipment should be constructed of nonsparking materials. For proper placement of the containers in che landfill, it is recommended thac a cractor barrel grappler be employed. Such equipment allows 9-223 ------- che operator to accurately place Che container in the landfill while causing a. minimal amount of damage to the container (a certain extent of container dencing is allowable providing that the structural integrity if not impaired). Tractor barrel grappler equipment has the added advantage of providing some distance between the operator and container. If containers holding ignitable waste must be opened, nonsparking remote container opening equipment should be employed. The applicant should soecifv what measures will be taken if a container is in oad condition or begins to leak during .ontainer Handling. The best procedure is to have ready access to compatible absorbent materials for control of spills. Empty containers should also be available. 9 . 5, 3 , "., q, Daily Jover of Ignitable Waste—Containerized ignitable waste placed in a landfill must be covered daily with soil or other noncombustible material (§264.312(b)) to minimize the potential for ignition of the waste. The applicant should clearly state the type of cover material to be employed and the thickness of the applied daily cover. The depth of daily cover required is dependent on the type of cover material employee. For example, for a given depth, fine grained clayey soil will seal off disposed was-te raore effectively than a coarse grained gravely soil. If a soil cover material is employed, six inches is generally a sufficient depth of cover. A manufacturer of a foam cover material claims that 2 inches of their foam product is equivalent to six inches of soil cover.20 (jse of such foams, however, must be carefully considered from the standpoint of compatibility with waste materials. 9.5.3.2.9 Segregate Containerized IgiMrtable Waste from Other Wastes which May Generate Heat—The applicant is required to demonstrate chat containerized ignitable wastes will not be disposed of in cells that contain or will contain other wastes which may generate heat sufficient to cause ignition of the waste. In general, ignitable wastes will have to be segregated from wastes which may be subject to microbrial degradation or wastes which will react with water and cause an exothermic reaction. Either of these waste types may produce sufficient heat to cause ignition of certain wastes. Waste material which may generate heat due to microbrial degradation would generally have a high organic content. This may preclude the co-disposal of waste material high in organic content such as solvents, oil sludges, municipal waste and various wastes from the organic chemical manufacturing industry. If an applicant proposes to place an ignitable waste in the same cell with another waste type, it must be determined whether this other waste type may react exothermically with water and generate sufficient heat to cause ignition. However, wastes which are reactive with water should not be disposed of in the landfill. Section 264.312 requires that any reactive waste be treated, rendered or mixed before or immediately after placement in a landfill so that the resulting waste, mixture or dissolution of material no longer meets the definition of ignitable of reactive waste under §261.21 or §261.23. Nonetheless, the reviewer should check to be certain chat any wastes which are to be co-disposed with an ignitable waste are nonreactive. In Part 261, Subpart D - Lists of Hazardous Wastes, those wastes which are reactive are designated by an "(R)" hazard code. Also, any waste which has an 9-224 ------- EPA nazaraous waste number of D003 exhibi.es the characteristics of reactivity. The reviewer should cross-chack. those wastes whi.cn will be co-disposed with an ignitable waste with the wastes in the Subpart D list which are reactive (listed in Table 9.5.2 of this section). However, not all of the waste in the Subpart D list which are designated to be reactive, will react exothermically with water. A waste is reactive if it exhibits any of the eight properties listed in §261.23. A worksheet for determining the adeauacv ?f the applicants ouomictat on ignitaoie wastes disposed of in containers is presented in Figure 9.5.5. 9.5.4 Draft Permit Preparation in .ioduie XV, Condition F, the permit must specify how the facility will handle ignitable and reactive wastes. The condition is implemented through reference to a permit attachment. To be suitable for substitution in the permit condition attachment, the submitted application should address the following two options, where applicable: * Option 1 — A description of proposed methods for treating ignitable or reactive waste before or i.timediataly after placement in the landfill. Field and laboratory test results illustrating that the wastes will be rendered nonreactive and nonignitable and a description of precautions used to prevent dangerous reactions should be provided. • Option 2 — (Applicable only Co containerized ignitable wastes) — A description of how the containerized ignitable wastes will be managed and protected from materials or conditions that could cause them to ignite. If the permit applicant does not adequately address disposal procedures for reactive or ignitable wastes, the permit writer should either write specific conditions to implement this provision or should indicate a condition that prohibits the disposal of reactive or ignitable wastes. 9.5.5 References 1. U.S. Environmental Protection Agency. Permit Applicants' Guidance Manual for Hazardous Waste Land Storage, Treatment, and Disposal Facilities. Volume I. Office of Solid Waste. Washington, D.C. 1983. 2. U.S. Environmental Protection Agency. Test Methods for Evaluating Solid Waste. Second Edition. SW-846. July 1982. 3. Hatayaraa, et. al., A Method for Determining the Compatability of Hazardous Wastes. EPA-600/2-80-076, 1980. 4. JRB Associates, Inc., Techniques for Evaluating Environmental Processes Associated with the Land Disposal of Specific Hazardous Materials, Volume I: Fundamentals. EPA Contract No. 68-01-5052, March 31, 1982. 9-225 ------- HANDLING AND DISPOSAL OF IGNITA3LE OR REACTIVE WASTES Are inspection procedures adequate to ensure chat containers are in good condition prior to burial? Yes No Are acceptable procedures presented for dealing vith leaking containers0 Yes No Are container handling procedures and equipment designs adequate Co a''ol,i hsac, jpar^o, ruptures, and ignition Yes No of the waste? Did the applicant document the characteristics and depth of the daily cover material? Yes Mo Are containerized ignitaole wastes segregated from wastes which could generate heat? . Yes No Figure 9.5.5. Worksheet for evaluating disposal procedures for containerized ignitable wastes. 9-226 ------- 'Jnit Operations for Treatment or Hazardous Industrie.- Wastes. Noyes Data Corp. 1973. 6. Schalic, L. and G. Staples. Fostering Industrial Innovative Technology to Actain Agency Goals: Technological Opportunities, Volume II, Prepared for Office of Research and Development, U.S. Environmental Protection Agency. Science Applications, Inc., (SAI-0/2-80-523-LJ). 1980. 7. Pytlewski, L. L., et al. The Reaction of PCBs with Sodium, Oxygen, and Polyethylene SI/col. In: Proceedings of the Sixth Annual Research Symposium on Treatment of Hazardous Wastes, March 17-20, 1980. Chicago, Illinois. U.S. EPA—Municipal Environmental Research Laboratory. EPA-600/9-80-011. 8. Edward, B. H., et al. Emerging Technologies for the Destruction of Hazardous Waste. Ultraviolet/Ozone Destruction. In: Proceedings of the Seventh Annual Research Symposium on Land Disposal of Hazardous Wastes. Philadelphia. U.S. EPA—Municipal Environmental Research Laboratory. (EPA-600/9-81-002b). 1981. 9. Miller, R. A., et al. Evaluation of Catalytic Wet Oxidation for Treatment of Hazardous Wastes. In: Proceedings of Seventh Annual Research Symposium on Land Disposal of Hazardous Wastes. Philadelphia. U.S. EPA—Municipal Environmental Research Laboratory. (EPA-600/9-31-002b). 1981. 10. Metry, Amir, A., The Handbook of Hazardous Waste Management. Tacnnomic °ublishing Company, Inc., Westpor-t, CT. , 1980. 11. TRW Systems, Inc. Recommended Methods of Reduction, Neutralization, Recovery, or Disposal of Hazardous Waste. Volume I-XVI. U.S. Environmental Protection Agency, Washington, D.C., 1973. 12. £PA-600/2-82-001c, Treatability Manual. Volumes I-IV. U.S. Environmental Protection Agency, Washington, D.C., Sept. 1981. 13. Battelle Memorial Institute. Program for the Management of Hazardous Waste. Volumes 1 and 2. U.S. Environmental Protection Agency, Office of Solid Waste Management Programs. Washington, D.C., 1974. 14. Booz-Allen Applied Research, Inc. A Study of Hazardous Effects and Disposal Methods. U.S. Environmental Protection Agency. Cincinnati, OH, 1972. 15. Bretherick, L., Handbook of Reactive Chemical Hazards. CRL Press, Inc., Cleveland, OH, 1975. 16. Fire Protection Guide on Hazardous Materials. Sixth Edition. National Fire Protection Association, Boston, Massachusetts, 1975. 17. Nemerow, N.L., Liquid Waste of Industry: Theories, Practice, and Treatment. Addison-Wesley Publishing Co., Reading, MA. 1972. 9-227 ------- 18. Toxic and Hazardous Industrial Chemicals Safety Manual for Handling and Disposal, with Toxicity and liazard Data. The International Technical Infonnacion Institute, Torahotnon-Tachikawa 31dg. 6-5, 1 Chome, Nishi-Shimbashi, Minato-KW, Tokyo, Japan, 1975. 19. Wolbach, C. D., U. Spannagel, and R. Whitney. Field Scheme for Determination of Waste Reactivity Groups. Prepared by Acurex Corporation for the U.S. Environmental Protection Agency. Presented in the Proceedings of the Ninth Annual Researcn Symposium—Land Disposal, Incineration, and Treatment of Hazardous Waste. Fort Mitchell, Kentucky. May 1983. 20. Sanifoam, Inc., Product Information, IJ7G ^ogan Avenue, Suite D, Costa Mesa, California, 92626, (714) 557-5070. 9-228 ------- 9.6 SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES 9.6-1 The Federal Requirement The information requirements of S270.21(g) specify chat: "If incompatible wastes, or incompatible wastes and materials will be landfilled, an explanation of how §264.313 will be complied with be submitted]." Special requirements for incompatible wastes are specified in §264.313, stating that: 'Incompatioie wastes, or incompatible wastes and materials, (see Appendix V of this part for examples) must not be placed in the same landfill cell, unless §264.17(b) is complied with." The referenced requirements of §264.17(b) are: "Where specifically required by other Sections of chis Part, the owner or operator of a facility chat treats, stores or disposes ignitable or reactive waste, or mixes incompatible waste or incompatible wastes and other materials, must take precautions to prevent reactions which: (1) Generate extreme heat or pressure, fire or explosions, or violent reactions; (2) Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health or the environment; (3) Produce uncontrolled flaamable fumes or gases in sufficient quantities to pose a risk of fire or explosions; (4) Damage the structural integrity of the device or facility; (5) Through other like means threaten human health or the environment." 9.6.2 Summary of Necessary Application Information The Part B Permit Applicants' Manual^- instructs the applicant to submit documentation including detailed plans, engineering reports, and operating plans showing that the standards of §264.313 or §264.17(b) will be complied with. The documentation may include published literature, trial tests, waste analyses, or results from past experience. 9.6.3 Guidance on Evaluating Application Information 9.6.3.1 Regulatory Applicability and Intent— Figure 9.6.1 summarizes the regulations applicable to handling and disposal of incompatible wastes at landfills. Compliance with the provisions of §264.313 requires the owner/operator to indicate in the permit application the specific steps that will be undertaken to identify incompatible wastes and insure segregation of those wastes when landfilled. The intent of §264.313 is discussed in the preambles of several Federal Register notices, as listed below: 9-229 ------- WILL INCOMPATIBLE WASTES, OR INCOMPATIBLE WASTES AND MATERIALS 8E DISPOSED OF IN THE SAME LANDFILL CELL? NO j YES THE REGULATIONS DO NOT APPLV ARE THE PRECAUTIONS OF 3264. l/(b) COMPLIED WITH? NO YES IS DOCUMENTATION OF §264.17(b) COMPLIANCE PROVIDED? THE PLANS ARE [NADEQUATE NO YES THE PLANS ARE ADEQUATE Figure 9.6.1. Regulations applicable Co handling and disposal of incompatible wastes at landfills. 9-230 ------- Federal Register Notice Page 33162 33182 33213 2809 11148 Vol 45 45 45 46 46 26 July 47 Sect ion Affected §265,17 §265.17 §265.313 and Appendix V §264.17 and Appendix V §264.313 §264.313 Reference is made above co pertinent preamble discussions in Part 265 to address regulations for incompatible wastes applicable to interim status facilities. There is no characteristic of incompatibility in 40 CFR Part 261. Rather, Appendix V of Part 264 presents examples of potentially incompatible wastes. A definition of incompatible wastes is provided in §260.10 of Subpart B of Part 260. Technical references are also available that identify incompatible waste combinations, as discussed in the following subsections. 9.6.3.1.1 Will incompatible wastes, or incompatible wastes and materials be disposed of in the same landfill eel!?"•-!£ is the responsibility of che landfill owner or operator Co identify vhether or not wastes are compatible. For most commercial landfills, the number of different wastes received will undoubtedly result in cases of incompatibility. For onsite landfills operated by the waste generator or landfills receiving only a small number of different wastes, it may be possible for the applicant to document in the permit application that all wastes are compatible. If it is shown thac all wastes are compatible with each other and with other materials in the landfill, the permit application is adequate. Based on a Literal interpretation of the regulations, only a waste that has already been identified as a hazardous waste can be further identified as an incompatible waste. The §260.10 definition states that an incompatible waste "means a hazardous waste which..." and Appendix V of Part 264 states "Many hazardous wastesd, when mixed with...". However, the intent of the regulations is to avoid combination of incompatible wastes whether they are initially hazardous or nonhazardous. Therefore, all wastes must be considered. 9.6.3.1.2 Are the precautions of §264.17(b) complied with?—There are circumstances under which incompatible wastes could be disposed of in the same landfill cell. As an example, the permit applicant could propose to place incompatible wastes far apart from each other in the same cell and place wastes or materials which are mutually compatible with those wastes between them. If the applicant can show, to the permit reviewer's satisfaction, that 9-231 ------- this aooroach is a precaucion ;nat .71.1.1 'prevent reactions -ni.cn. . . tnreaten human health or Che environment," Chen ic could be judged to adequately comply with the intent of §264.17(b). 9.6.3.1.3 Is documentation provided to demonstrate compliance with §264.17(b)?—Documentation is required by §264.17(c) to show that the precautions of §264.17(b) will be effective, as noted below: "When required to comply with paragraphs (a) or (b) of this Section, the owner or operator must document that ^omplianwa. This documentation may oe based on references to published scientific or engineering literature, data from trial tests (e.g., bench scale or pilot scale tests), waste analyses (as specified in §264.13), or the results of the treatment of similar wastes by similar treat.-ser.t .-recesses and under Similar operating conditions." The owner or operator of the landfill must supply documentation that the procedures employed will allow incompatible wastes to be disposed of safaly in the same landfill cell. The permit application is deficient if the required documentation is not submitted or if it is judged to be inadequate. If the application indicates that incompatible wastes will not be disposed of in the same landfill cell, then procedures to insure this must be stated. Also, if an application indicates that a waste will be treated so that it is no longer incompatible when disposed of, documentation is required to show that the process is effective and will result in compliance with §264.17(5). 9.6.3.2 Evaluation of the Technical Adequacy of the Applicant's Submittal— 9.6.3.2.1 Introduction—To augment the information on incompatible wastes presented in Appendix V of Part 264, the permit application reviewer should reference two additional technical reports to determine if the applicant has correctly investigated the compatibility of the wastes to be handled. These documents are identified below, and a brief description of the contents of each is provided. A Method for Determining the Compatibility of Hazardous Wastes (EPA-600/2-80-076, April 1980)2 was prepared for the EPA's Municipal Environmental Research Laboratory by researchers at the California Department of Health Services. The abstract of the report states; "This report describes a method for determining the compatibility of binary combinations of hazardous wastes. The method consists of two main parts, namely: (1) the step-by-step compatibility analysis procedures, and (-2) the hazardous wastes compatibility chart. The key element in the use of the method is the compatibility chart. Wastes to be combined are first subjected through the compatibility procedures for identification and classification, and the chart is used to predict the compatibility of the wastes on mixing. 9-232 ------- The cnart consist-s of 41 reactivity groups of nazardous wastes designated by Reactivity Group Numbers (RGN). The RGN are displayed in binary combinations on the chare, and the corapatibilicy of the combinations are designated by Reaction Codes (RC). The method is applicable to four categories of wastes based on available compositional information: (1) compositions 'c aaaitionai data on the compatibility of various chemicals wastes. Reference 3, Techniques for Evaluating Environmental Processes Associated with Land Disposal of Specific Hazardous Materials, Volume II, Incompatible Wastes, March 31, 1982, was prepared for the EPA Office of Solid Waste by JR8 Associates, Inc., McLean, Virginia. This document discusses processes that enhance pollutant migration potential through the liquid phase in soils. Three general processes were identified, including; • direct solubility effects between waste constituents • cnemical reactions between waste constituents which generate reaction products which are sore mobile than the original vaste constituents • processes whereby waste interactions with the environment decrease the soil's ability to attenuate pollutant migration. Eighteen additional references are cited in the report. 9.6.3.2.2 Hazardous Waste Compatibility—Because many types of hazardous wastes are extremely reactive, the compatibility of hazardous wastes to be combined must be thoroughly evaluated. Combining wastes which are incompatible may result in:3 (l) heat generation, (2) fire, (3) toxic gases, such as HCN or t^S, (4) flammable gases, such as H£ or C2^2> (5) innocuous gases, such as N2 or CC>2, which can cause container pressurization, (6) explosion due to extremely vigorous reactions or reactions producing enough heat to denotate unstable reactants or reaction products, (7) violent polymerization resulting in generation of extreme heat and flammable gases, and (8) solubilization of toxic substances including metals. Therefore, the applicant must identify the methods he will employ for estimating the potential consequences of mixing different classes of wastes. Insufficient or inaccurate information about a waste or wastes is the primary cause of inadvertently combining incompatible wastes. Regardless of efforts to adequately characterize wastes via the waste analysis plan, properties of some wastes may change with time and temperature, thereby producing more or different hazardous components.3 9-233 ------- A second cause of accidents is indiscriminate handling of waste which might encompass the following: • Containers which are supposedly empty may contain incompatible residual wastes. • Haulers may "top off" their load on the way to the disposal site. • Rough handling could cause container rupture or leakage that Tiigh: result in consaingling of otherwise segregated incompatible wastes. • Indiscriminate disposal of containerized incompatible wastes in the same cell could result in mixing of incompatible wastes \f containers Corrode 2nd Leas. 9.6.3.2.3 Determination of the Compatibility of Hazardous Wastes—As mentioned earlier, A Method for Determining the Compatibility of Hazardous Wastes (EPA-600/2-80-076)2 is a valuable resource document for determining the compatibility of binary waste combinations. The method provided in this report consists of two main parts: (1) stepwise compatibility analysis procedures, and (2) use of a hazardous waste compatibility chare. Wastes under consideration are first identified and classified and then the compatibility chart is used to assess the compatibility of the wastes upon mixing. The remainder of this section provides background information for employing EPA-600/2-80-076. The five general steps necessary to determine the compatibility of two waste types are summarized below. Discussion of implementation of these steps is as reported in Reference 4 by Hatayama, et al. (EPA-600/9-30-010, March 1980). Figure 9.6.2 summarizes the steps to be taken to determine hazardous waste compatibility. Step I; Waste Characterization The first step in determining the compatibility of two different waste types is to accurately characterize the wastes. The applicant should provide as much information as possible about waste composition to illustrate compliance with §264.13 (Waste Analysis Plan) and as part of the list of hazardous wastes incorporated in the application (§270.21(a)). Step 2:* List Name of Compounds or Classes of Compounds or Generic Name of Waste "Starting with one waste, Waste A, list the names of or the classes of compounds found in the wastes, or list its generic name on the vertical axis of the Worksheet for Determination of Hazardous Waste Compatibility (Figure "9.6.3). The compositon of a waste is Known Specifically when the constituents are listed by chemical names such as ethylene glycol, sodium nitrate, etc. The composition is Known Nonspecifically by Classes when the constituents are identified only by chemical classes or reactivities such as alcohols, caustics, mercaptans, etc. The composition is Known Nonspecifically by Generic Name when the waste is classified as spent caustic, tanning sludge, -opper plating waste, etc." 9-234 ------- PROCEDURE FOR DETERMINING HAZARDOUS WASTE COMPATIBILITY STEP I: WASTE CHARACTERIZATION STEP 2: LIST NAMES OF COMPOUNDS OR CLASSES OF COMPOUNDS OR GENERIC NAME OF WASTE STEP 3: DETERMINE REACTIVITY GROUP NUMBERS STEP REPEAT STEPS OTHER WASTES STEP k: 2 AND 3 FOR OF CONCERN 5: USING COMPATIBILITY CHART, DETERMINE CONSEQUENCES OF COMBINING TWO WASTES Figure 9.6.2. Flow diagram for assessing the compatibility of hazardous wastes using procedures specified in EPA-600/2-80-076.2 9-235 ------- Waate A Waits B Source Source Name of Vaste Evaluation Date Name Reactivity Group No. Figure 9.6.3. Worksheet for determination of hazardous waste compatibility, Source: Reference 2. 9-236 ------- Step 3:* Determine Reactivity Group Numbers "When Che composition of Waste A is Known Specifically oy chemical names, consult the List of Chemical Names [in Appendix I of Reference Ij Co obtain Che Reactivity Group Number (RGN) for each chemical constituent. These RGNs are then noted on che Worksheet. If a compound is not on the list, a synonym can be found in various chemical references (Merck,5 Hawley,6). When a suitable synonym cannot be found, the RGN of the component may alternatively be determined based on its chemical class or reaccivity. When che composition of Che waste is Known Specifically by Classes, consulc che LisC of Waste Constituents by Chemical Class and Reactivicv [in Appendix II of Reference 1. • :o decarT.ine Jhe corresponding RGN. When the composition of the waste is Known Nonspecifically by Generic Name, go to the Industry Index and List of Generic Names of Wastes [in Appendix III of Reference IJ to obtain the corresponding RGN and noce it on the worksheet." Step 4:* Repeat Steps 2 and 3 for Other Waste(s) of Concern "Repeat Steps 2 and 3 for the second waste, Waste B, and note che information on the horizontal axis of the Worksheet." Step 5:*Using Compatibility Chart, Determine Consequences of Combining Two Wastes "Consult the Hazardous Waste Corapscibility Chart (Figure 9.6.4) and note the Reaction Codes (RC) between all binary combinations of RGN of Waste A and Waste B. If any RC corresponds to any-binary coraoination of RCN between Wastes A and 8, Chen Wastes A and B ate incompatible and should not be mixed. 9.6.3.2.4 Limitations of the Method—Although this procedure should provide a useful aid in determining the corapatibilicy of hazardous waste, the method must be used with caution because there are numerous factors which will influence waste component reactions. Among these are temperature, catalytic effects of dissolved or particulate metals, soil reactions, and reactions between the waste and surfaces it may be in contact with.3 Consequently, the permit reviewer may elect to require the applicant to perform laboratory compatibility analysis prior Co acCual co-disposal of wastes. Acurex is currencly developing a field test kit7 for categorizing unknown wastes into the reactivity groups noted in Figure 9.6.4. The incorporated test procedures could b.e applicable in identifying the compatibility of poorly characterized wastes. A worksheet for determining the adequacy of the applicant's submittal on incompatible wastes is presented in Figure 9.6.5. *Quoted from Hatayaraa, H. K., et al. EPA-600/9-80-010, March 1980. (Reference 4). 9-237 ------- »f \CTIMM GHOlf •> *"t « Muml O.^/i-t M i M ! M GT| C | C H | H I H M«m*UM M! Otaw ^ H. T i JJ iu .CXnlMCLT UA4TTTVK Figure 9.6.4. Hazardous waste compatibility chart. Source: Reference 2. 9-238 ------- REACTIVITY CODE CONSEQUENCES PI " p 1 •V 00 we 14 IS Ik "f It M ", ", ", U» "CT ", " ft <* M Cf H U *, N "nr •»• "s I* N C/ M "„ ", °% H F G GT GF - p S U Heat generation Fi re nnocuous and non-f!ammab 333 generation Toxic gas generation Flammable gas generation £xp ios i on Violent polymerization Solubi 1 izat ion of toxic su May be hazardous but unkno Example: w CJ H M r c/ H CT M p "'sr Of, 11 1 N f A c* c* M - II r S ", II "f *%, IT Wl WITH A*Y CMOnrAL 1* 17 II " M tl " 11 (HF L GT >' M I 1 1 ", ", M !_ <*» ", N N F « « "•'« M Cf H f • M f N I M F £ •K X If cr 'sr "a /. "c H Of >«sn MATERIAL' 11 j 11 •• JS M »' H P H F EX U Heat generation, fire, and generation f M " " "cr «, », t ", w m I 'c, "" "l "» "f "• "l '« '- '" '• "' PI ' <• ' Jtl CT C. S * 'cij'°* "i ^^ » "« "t "w ', '•» pv »«••• • .•» M Jl j) JJ M 101 IM IOJ IM IM IM 191 Figure 9.6.4 (continued)' 9-239 ------- SPECIAL REQUIREMENTS ?CR INCOMPATIBLE WASTES Has this part of the applicant's submittal been read and evaluated? Yes No Have acceptable orocedurs-? '-e°n usad co accurately characterize the wastes? Yes No Were wastes properlv cata^orizad by :'2zc.i ,-Lz" group .luaoersT Yes No Was waste compatibility identified using the Reference 2 compatibility chart or other acceptable means? Yes No Does the information submitted on waste compatibility include all wastes identified in Section 9.1? Yes No If incompatibla wastes are disposed in the same cell, are adequate measures taken to segregate wastes? Yes Mo Did the applicant address the compatibility of container residues ana leakage from damaged containers? Yes No Figure 9.6.5. Worksheet for evaluating disposal procedures for incompatible wastes. 9-240 ------- 9.0.4 Draft Permit Preparation Condicion G of Permit Module XV addresses disposal requirements for incompatible wastes. The condition is implemented through reference to a permit attachment that specifies handling procedures for incompatible wastes. To be suitable for substitution in the permit condition attachment, the submitted application information should include detailed plans, engineering reports, and operating plans to document compliance with the regulations. Documentation on handling of incompatible wastes during operation should be placed In cha Dperating record (see Module II, Condition L.I). If the permit applicant does not specify methods for handling incompatible wastes, the permit writer should either specify conditions under which they may be accepted or should write in a condition prohibiting Che acceptance of incomatib L-e -^asr.ss. 9.6.5 References L. U.S. EPA. Permit Applicants' Guidance Manual for Hazardous Waste Land Storage, Treatment, and Disposal Facilities. Volume I. Office of Solid Waste. Wasnington, D.C. 1983. 2. Hacayaraa, H. K., et al., A Method for Determining the Compatibility of Hazardous Wastes. EPA-600/2-80-076, April 1980. 3. JRB Associates, Inc. Techniques for Evaluating Environmental Processes Associated with Land Disposal of Specific Hazardous Materials, Volume II, Incompatible Wastes. Prepared for the U.S. SPA Office of Solid Waste. March 31 1982. 4-. Hacayaraa, H. K. , et al., Hazardous Waste Compatibility. Presented in Disposal of Hazardous Waste, Proceedings of the Sixth Annual Research Symposium. EPA-600/9-80-010, March 1980. 5. Merck and Company, Inc. 1976. The Merck Index. 9th Edition, Rahway, NJ, 6. Hawley, G. G. 1971. The Condensed Chemical Dictionary. 8th Edition. Van Nostrand Reinhold Company, New York, Cincinnati, Toronto, London, Melbourne. 7. Wolbach, C. D., U. Spannagel, and R. Whitney. Field Scheme for Determination of Waste Reactivity Groups. Prepared by Acurex Corporation for the U.S. Environmental Protection Agency. Presented in the Proceedings of the Ninth Annual Research Symposium—Land Disposal, Incineration, and Treatment of Hazardous Wastes. Fort Mitchell, Kentucky. May 1983. 9-241 ------- 9.7 DISPOSAL OF LIQUID WASTE IN LANDFILLS 9.7.1 The Federal Requirement Paragraph (h) of §270.21 requires Che following: "If bulk or noncontainerized liquid waste or wastes containing free liquids ia to be landfilled, an explanation of how the requirements of §264.314 will be complied with [must be submitted]," The referenced Part 264 standard states the following: "§264.314 Special requirements for liquid wasts. ,a) Bulk or noncontainerized liquid waste or waste containing free liquids must not be placed in a landfill unless: (1) The landfill has a liner and leachate collection and removal system that meet the requirements of §264.301(a); or (2) Before disposal, the liquid waste or waste containing free liquids is treated or stabilized, chemically or physically (e.g., by mixing vith an absorbent solid), so that free liquids are no longer present. (b) Containers holding free liquids must not be placed in a landfill unless: (1) All free-standing liquid: (i) has been removed by decanting, or other methods; (ii) has been mixed with absorbent or solidified so that free-standing liquid is no longer observed; or (iii) has been otherwise eliminated; or (2) the container is ve*y small, such as an ampule; or (3) The container is designed to hold free liquids for use other than storage, such as a battery or capacitor; or (4) The container is a lab pack as defined in §264.316 and is disposed of in accordance with §264.316." 9.7.2 Summary of Necessary Application Information The Part B Permit Applicants' Manual^- instructs the applicant to explain how he plans to comply with the standards of §264.314 if the facility will accept liquid wastes or wastes containing free liquids. It the facility accepts bulk or noncontainerized liquid waste or waste containing free liquids, the applicant must present: • documentation to demonstrate the adequacy of the landfill liner and leachate collection system, 'or • proposed methods of chemically or physically treating or stabilizing liquid wastes to eliminate free liquids before disposal in the landfill. Section 9.2 of this manual presents guidance on evaluating the adequacy of the proposed liner and leachate collection system. 9-242 ------- If che owner/opera tor will accept containers holding free liquids and these containers are not ampules or similarly small containers; batteries, capacitors, or similar containers; or lab packs; than he must provide trie following information: « proposed methods for decanting or otherwise removing free standing liquids from the container before disposal, or • oroposed absorb jr.-::: :c be added ;o ihe container, or • proposed methods of solidifying the free standing liquids in the container, or * other proposed methods of eliminating free standing liquids. If ampules, batteries, capacitors, or similar containers are the only types that will be accepted, the owner/operator should indicate expected quantities, types, and proposed disposition. If lab packs will be accepted, the applicant must provide documentation to demonstrate compliance with the standards of §264.316., Section 9 of this manual addresses review of application information intended co meet this requirement. 9.7.3 Guidance On Evaluating Application Information 9.7.3.1 Regulatory Applicability and Intent— Figure 9.7.1 presents a flow chart for determining the applicability of regulations covering che applicant's pians for handling and disposing of liquid wastes. 9.7.3.1.1 Will Bulk or Noncontainerized Liquid Waste or Waste Containing Free Liquids be Placed in the Landfill?—To assure successful operation of the facility, it is the applicant's responsibility to identify the physical characteristics of all wastes to be disposed of in the landfill, as required by §264.13—General Requirements for Waste Analysis. If the applicant states that no type of liquid wastes will be received or disposed of at the landfill, then the permit writer roust indicate in the permit that bulk or noncontainerized liquid waste or wastes containing free liquids are specifically not permitted for disposal at the landfill. If this is the case, the reader may proceed directly to subsection 9.8.3.1.3. However, the permit reviewer is cautioned to note the difference between receiving and disposing of a waste. If bulk or noncontainerized wastes 'containing free liquids are received at the landfill and then containerized, the owner or operator is c.sposing of containers holding free liquids and must comply with §264.314(b) (see subsection 9.8.3.1.3 and 9.8.3.1.4, which follow). Similarly, if containers holding free liquids are received at the facility but are emptied into a landfill cell, then the owner/operator is disposing of bulk or noncontainerized free liquids and must comply with §264.314(a) (see subsection 9.8.3.1.2 which follows). 9-243 ------- WILL SULK OR NON-CONTAINERIZED LIQUID WASTE OR WASTE CONTAINING FREE ..QUIDS 3£ PLACED IN THE LANDFILL? DO THE LANDFILL DESIGN AND DISPOSAL PROCEDURES COMPLY WITH 3264.31 NO NO THE PLANS ARE !NADEQUATE THE PLANS ARE ADEQUATE WILL CONTAINERS HOLDING FREE LIQUIDS BE PLACED IN THE LANDFILL? /ES THE REGULATIONS ARE DO THE DISPOSAL PROCEDURES COMPLY WITH §264. 3l4(b)7 NO YES THE PLANS ARE INADEQUATE THE PLANS ARE ADEQUATE Figure 9.7.1. Regulations applicable to management of liquid wastes at landfills. 9-244 ------- 9.7.3.1.2 Do the Landfill Design and Disposal Procedures Comply with §264.314(a) _?—The applicant for a landfill permit wno nas stated chat bulk or nonconcainerized liquid waste or waste containing frsa liq_i^3 -ill oe received for disposal has two options for disposing of the vaste at the landfill; (1) disposal in a landfill cell with a liner and a leachate collection and removal system, or (2) treatment of the waste prior to disposal so that free liquids are no longer present. A permit application which indicates receipt of such wastes and does not indicate disposal by one of these methods may be inadequate. If these wastes are to be disposed of in a landfill with a liner and leachate collection/removal system, the liner and leachate collection system must meet the requirements of §264.301 (a^ ' :*<> sucs-cc^on is.L>* fne application snoula also address compatibility and ignitability/reactivity concerns. The application is technically inadequate if it proposes to dispose of these wastes (without prior elimination of free liquid) in a landfill cell that does not have a liner and leachate collection system or if the liner and leachate collection system do not meet the §264.301(a) requirements. If liquid wastes are treated chemically or physically before disposal so that free liquids are no longer present, the treated waste can be disposed of in any landfill cell, as long as compatibility and ignitability/reactivity criteria are met. However, in these cases, the application must provide a detailed description of the treatment method to be used and documentation of effectiveness in eliminating free liquids. If a landfill cell does not contain a liner and leachate collection system, free liquids or wastes containing liquids cannot be disposed c-f in that cell based on the presumption that wastes previously discharged willr chemically or physically eliminate the free liquids or liquids contained in the waste. However, it would be allowable to mix the two wastes (if compatible) to eliminate free liquids and then place the mixture in a landfill cell that does not have a liner and leachate"collection system. 9.7.3.1.3 Will Containers Holding Free Liquids Bg Placed in the Landfill?— Guidance on the meaning of free-standing liquid can be found in the preamble to an interim final amendment to 40 CFR Part 265, published on March 22, 1982 at 47 FR 12317, and in the preamble to regulations published on May 19, 1980 at 45 FR 33213. Section 260.10 defines free standing liquids as "... liquids which readily separate from the solid portion of a waste under ambient temperature and pressure." If the applicant states that containerized free liquids will not be disposed of at the landfill, then the permit writer must indicate in the permit that containers holding free liquids are specifically not permitted for disposal at the landfill. If these wastes will be received at the landfill but emptied from the containers for disposal, the application must demonstrate compliance with §264.314(a). 9.7.3.1.4 Do the Disposal Procedures Comply with §264.314(b)?—The provisions of §264.314(b) allow the owner/operator some latitude in deciding how containers holding free liquids will be disposed of in the landfill. Specifically, free standing liquids can be removed from the container, they 9-245 ------- can be mixed wich aosorbetit or solidified in che concainer, or they can be eliminated by any oeher method or procedure acceptable to the permitting authority. Very small containers, such as ampules, or containers that hold liquids for reasons other than storage, such as batteries or capacitors, can be directly disposed of without elimination of free liquids. However, the intent of the regulation is to allow disposal of small containers as thev may randomly appear in the waste. "^2 p^caraant of large quantities of these types of small containers holding free liquids in the same part of the landfill would increase the potential for generation of significant quantities of leachate and landfill subsidence. Therefore, such a procedure is Tot in concert with the intent of the ~«?ulation. The provisions of §264.314(b) allow placement of lab packs in landfills. However, a container holding free liquids must meet the specific criteria of §264.316 (see subsection 9.3) to be classified as a lab pack and, therefore, be acceptable for disposal in a landfill. Further, §264,315 (-see subsection 9.8) incorporates requirements for disposal of containers in landfills regardless of the physical characteristics of the contained wastes. The requirements of §264.315 are germane to containers which are processed according to options of §264.314(b)(1) . 9.7.3.2 Assessment of the Technical Adequacy of the Applicant's Plans for Disposal of Liquid Wastes — Figure 9.7.2 illustrates the techn-ical topics chat are discussed in this section. Each topic is presented individually so that specific sections applicable to the facility in question can be referenced. The permit reviewer should consider the long-term potential for ground water contamination associated with adopting the applicant's proposed liquids management techniques since corrective action will be required if hazardous wastes leach out of the landfill and are detected in the ground water. Such corrective action is generally extremely costly and could negate the short-term cost savings associated with selecting an unsuccessful stabilization technique. Therefore, the permitting agency should encourage the applicant to implement treatment or stabilization methods which, in addition to eliminating free liquids, also limit the potential for future waste leaching. If waste leaching is highly likely in the long term regardless of sorbent addition, a technique such as encapsulation (with high initial costs) may be cost effective, over the long term. In summary, although §264.314. requires the elimination of free liquids during placement, the applicant and the reviewer should consider the possibility of leachate migration in the long term in spite of adopting the selected method. The applicant must provide reliable information about the composition and characteristics of the waste to be processed so that the effectiveness of any proposed treatment/stabilization method can be evaluated. The waste characteristics may dictate whether a stabilization process such as encapsulation is applicable or whether sorbent addition will suffice. The 9-246 ------- BULK OR NONCONTAINERIZED LIQUID WASTES OR WASTES CONTAINING FREE LIQUIDS CONTAINERS HOLDING FREESTANDING LIQUIDS, WASTE CHARACTERIZATION TEST FOR PRESENCE OF FREE L iQUIDS STABILIZATION OF WASTE DECANT OF LIQUIDS NG ECONOMIC CONSIDERATIONS ADDITION OF ABSORBENTS TESTING PHYSICAL AND CHEMICAL PROPERTIES OF STABILIZED WASTE CHEMICAL LEACH TESTING OF STA8H1IZED WASTE EFFECTS OF BIOLOGICAL ATTACK ON TREATED WASTES EFFECTS OF CURING AND AGING PROCESSES ON TREATED MATERIAL Figure 9.7.2. Assessment of technical adequacy of the applicant's plans for disposal of liquid wastes. 9-247 ------- applicant needs to identify bo en che physical and chemical characteristics of the waste. The permit reviewer should consider Che applicant's overall waste analysis plan submitted in response to the reouirenents of 5270.14(b)(2) and (3). 9.7.3.2.1 Test for Presence of Free Liquids—EPA defines "free liquids" as "liquids which readily separate from the solid portion of a waste under ambient temperature and pressure."2 xhe applicant is not required to test containers for free liquid content if h» chooses ;o consider all containers of *asca as aoiaing free liquids and disposes of them in accordance with \$264.314(b). However, the applicant may choose to demonstrate that free liquids are not present in a containerized or bulk waste. If so, he must describe the test protocol to he aTioloyed ?r '~e irrust -revise other ::m: ..-ou >.aac cne waste does not contain free liquids. EPA currently recognizes two test protocols for determining the presence of free liquids.3 One method, designated the paint filter method, is described- in 47 FR 3311, February 25, 1982. The paint filter method is a gravity test which calls for a 100 ml representative sample of the waste Co be placed in'a .+00 micron, conical paint filter for 5 minutes. The filter specified is a standard pair.t filcar supported by a funnel on a ring stand with a beaker or cylinder below the funnel to capture any free liquid chat passes through the filter. If any liquid passes through the filter, the waste is considered to hold free liquids and is subject to che requirements of §264.314(b). Ef the paint filter test is to be used to measure the percentage of free liquids in the waste in individual containers, a longer test period probably would be necessary to achieve-an accurate measurement (e.g., 15 to •+5 minutes > .•* The second procedure for determination of liquids is designated the inclined plane method and is described in the preamble to the May 1980 regulation (45 FR 34214). The inclined plane method calls for the placement of 1 t:o 5 kilograms of waste on a level or slightly sloping plate of glass or other similar flat and smooth solid material for at least 5 minutes. If a liquid phase separation is observed, the waste contains "free liquids". It should be noted that the applicant may petition EPA under 5260.20 and 260.21 for use of an equivalent test protocol. If the applicant chooses to test for the presence of free liquids, he must describe how a representative sample of the waste will be obtained. In those cases where a demonstration is being made on a batch (e.g., truckload) of similar containerized waste, the sample or samples must be representative of all containers in the lot. The applicant's sampling program should conform to the guidance provided in Test Methods for Evaluating Solid Waste—Physical/ Chemical Methods, SW-846.5 The applicant may not need to test for free liquids if he can demonstrate or certify in another manner that the waste does not contain free liquids. Such certification could be acceptable if the landfill owner/operator receives containerized wastes on a continuous basis from a specific generator and knows by contractual agreement or prior observation that these containerized wastes 9-248 ------- do noc vary and do not contain free liquids. The permit reviewer is referred to the Permit Applicant's Manual for the General Facility Standards'^ and tne requirements for waste analysis plans. 9.7.3.2.2 Management of Bulk or Noncontainerized Liquid Wastes—If bulk or noncontainerized liquid waste or bulk wastes containing free liquids are to be placed in a landfill that is noc equipped with a liner and leachate collection system, then the applicant must demonstrate how free liquids will be eliminated to comply with the requirements of §264.314(a) . There are a variety of physical and chemical treatment methods which the applicant may employ to eliminate free liquids from noncontainerized waste. Section 9.7.3.2.3 of this document describes treatment/stabilization methods available to solidify the waste to make it acceptable for disoosal. Soaa of tne treatment/stabilization .necnods are relatively inexpensive, such as cement-based processes, while other methods, such as various encapsulation techniques, are relatively expensive. For a given waste type, ic is likely that free liquids can be eliminated using a variety of methods, but all will have varying attendant costs. 9.7,3.2.3 Treatment/Stabilization Technology—"Treatment" is defined by the EPA in §260.10 as "any method, technique, or process, including neutralization, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or to render such waste nonhazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume." Treatment processes include a wide array of techniques such as thermal, chemical, physical, and biological treatment or stabilization. Applicable liquid treatment techniques were reviewed in Section 9.5 in the discussion of ignitable and reactive wastes. Stabilization techniques are those which act to limit waste solubility or to detoxify the waste contaminants. Solidification techniques accomplish the same results by the production of a monolithic block of waste with high structural integrity,7 The long-term effectiveness of the proposed treatment/stabilization method in limiting future leachate migration should be one of the foremost selection criteria. If geological or hydrological conditions could allow significant leachate migration and result in ground water contamination, a process should be employed which renders the constituents nonhazardous and/or immobile. There is no single treatment/stabilization method which is ideal for all types of hazardous wastes. For example, although a waste material with a low concentration of organics may be satisfactorily treated by a cement-based treatment process, it would not be treated effectively by organic polymer treatment methods since the organics may retard the set of polymers. Table 9.7.1 indicates the compatibility of selected waste categories with different waste solidification/stabilization techniques (reprinted fro;n EPA SW-872).? 9-249 ------- a £_t In 2 C-4 M as i. a 3 3 , id ai co u 3 w o* H W <: z 0 H H < Z 3 O _* M ff"** u <: P ~! Cd 03 co O 0) — H t) •J < as •H ^j CQ t—4 &-< t— < 3J < Q U O. — I 1-J S -J 3 O O 0 y co &o ^ ^ ^\ Cd CO 1 7 « i- £ e e 2 J 2 * y a -w « O » S 'J * «. i s f U J S U 'J c 2 V u 'J « « — - 3 : " i " u u - V * O a,^ w a. X i 3 I - - * * * 41 « U «l — ,C 3 H • ^ * £ 2 9 -J J3 W "O e v ij -o 4J e V V * o j i- 3 u ' ' ; \1 M O -J 3* "" - 0 V i r * ? ^ 3 3 U 34 u iO US V C •ay "^ w u u - X u x a 3 w 3 U W 1 3 || | , 0 - •* •* y i •a » c I S l I n * a w •2 i ; 1 <* X * X U 3 V Q w a. u a. 13 « 3 x r ft 1 U 4 73 -J i* C - » 3 C 3 . - . 0 -, x u 8 ex -O * v • u V - * w 41 - a M *. * - 8 e v 3 « - - -- a. k- i ** j» ?S S S- 1^3 3 • " > j -' * 9) U S C « M at L, a. u *< O - e - « « CM tJ . S y • «>« -t « -. -, - a« — -^ — . « c M 3 5 J ^ ^ V -7 n - 2 - Ji M v a g — •) " — - - 3 "33- 3 - 1* V J V 1> 3 — « •« — 2 J 3 r y ^ y - -- J - W j y "B u = r "5 ? a i" ? •J S J „ — *- U -9 = *i ti U i ti i ! ^ 2 H 2 3 — ' 3. — ' V 3. -f = , "i ,""'' " — C - ^ J) a 3 3 * — u V - « — * ^ - w w 3 - 3 3 a a * t- v U -— i- U - O. U — ~^33. 3-J-S u - a u c 3 w -3-33 ^ V U « U . « 3. ^-^ fl1-!^- ? -J i J •^ 1J V W U - 3 X - 1 -i - C * - -JO. g x i 3 9 ( -i c i a* ^ www VI) * - 3. "b3» - i- - -3 » "oa, 3* —Us u u <* — • u j ^ ^t3O tj U C "3 >X d^c xjj xia- iJ Z t U U IP J3 -O a •fl a * a. a. a. J J J ^ -* * •O — « 'J 3 -• M « -q 5 "« a. « > — A « M * m - w s « w o u *i w u - U a S W 3 - Q. ^ 3 — g| 3 w j a xvaru US1 3 **^3a 'JUT , a) W 91 J M W •D -D '*• y » 3 < o yi J r4 «> a n u "u S -3 * y u -i S 2 * 'JVC X W -1 •* 3 x *j a u fl y a - fl . fl •a ^ t •£. ^ = 5 - y 9 T » j J *• "* — 4i U j3 V U ^ — a 3 ~n fl 13 •3 3. 3 3 U 3 * 0 S C a -^ 9) — X V * 3. iV 3 •0 — -3 J ^3 — 2 f- 0 — ^ 3. a 3 V -l o. 3 3 « - a J V X ^ 7 3* J -— u •9 11 — a a u -i a *d a a" ^ - o « a. j a 5_ _3 "* V -3 a. 9 V a. a _3 V ^ a. J 3 u 1 -3 « " a u * O ^ •y w 34 a •0 9-250 ------- So naif icat ion,'s caoil izacua tecnniques are, in general, new technologies which nave evolved out of the need for finding solutions for Che disposal of difficult to handle hazardous waste. The adequacy of solidification/ stabilization techniques in reducing long-term contaminant migration has not been thoroughly documented in all cases and it appears that more work is necessary to optimize treatment procedures for individual wastes. Nevertheless, preliminary evidence indicates that some solidification/ stabilization techniques are effective at reducing the potential for ground water contamination. Some of the hazardous chemicals and wq?t»s vhich can be stabilised and -solidifisd Affectively include: ^>9 • electroplating wastes • petroleum bottom tank sludges * soent oic'ils liquor- * orine wastes • spent acids • air pollution control residues • alkaline cleaners • wastewater treatment sludges • inorganic pigment wastes * aqueous wastes containing soluble toxic organics • leather tanning and finishing wastes During review of a permit application which specifies that a solidification/stabilization technique-will be employed, questions may arise ".oncerning the long-carm staoiiity attendant with the process. In such cases, the permit reviewer should refer to EPA-600/2-32-099 which is a study of the physical and leaching properties of solidified/stabilized industrial waste.10 Tests were conducted on tout solidification/stabilization processes: (1) a lime-fly ash, pozzolanic cement that yields a solid microencapsulation system, (2) a cement/soluble-silicate treatment process that produces a soil-like product, (3) an organic polymer system that produces a hard, rubber-like solid, and (4) a raacroencapsulation process that solidifies the waste and then bonds it in a polyethylene jacket. The lime-fly ash pozzolanic solidification produced a solid soil/cement-like product with good structural integrity but poor durability. Concentrations of hazardous elements (toxic heavy metals and insoluble salts) in leachates from this treated product were actually higher in about half the cases than they were in leachates from similar untreated material. The cement/soluble-silicate treatment process produced more consistent containment of hazardous elements with 60 to 70 percent of the constituents having lower levels in the leachate from the treated sludge than in leachate from the untreated control columns. The organic polymer system proved to be counterproductive in limiting release of hazardous elements from an electroplating waste and a paint production sludge. Both wastes lost most constit-.-nts at much higher rates than the control columns, possibly because of the acidification and resulting dissolution of the udge that was required to produce the polymerization reaction used in this process. The macroencapsulation process that solidifies the waste and then bonds it in a polyethylene jacket gave excellent containment of all constituents but cadmium.10 9-251 ------- Several apoiicabie creatment/stablization methods are discussed in the following subsections. This information summarizes the data presented in the "Guide to the Disposal of Chemically Stabilized and Solidified Waste" (SPA SW-872, September 1982)7 and other references, as noted. 9.7.3.2.4 Cement/PozzoIan Solidification/Stabilization Techniques—A cement- based process involves the reaction of water in the waste with anhydrous Portland cement powder. Similarly, a lime-pozzolan solidification involves the reaction of lime and a pozzolanic material in tha presence of water in the vasta na'erial ;o form compounds possessing cemetitious properties. Cement and pozzolanic-based techniques are employed singularly or in combination. When a pozzolan is mixed with cement, the lime that is liberated during the setting and hardening of cement combines with the oozsolan, resulting in che formation ~ f -. li.-ae-po^zoian compound. Some of the advantages of the cement/pozzolan-based process are that it is relatively inexpensive; it does not require specialized equipment or advanced technology; the product can be coated; and the process provides a stable product in many cases. However, there are disadvantages. For instance, certain wastes, such as wastes with high sulfate content, may not be adaptable to the techniaue. Additionally, it is likely that some leaching may occur, and tne final product is voluminous and heavy.7 Recent testing has been conducted on the leachability of wastes stabilized by cement/pozzolan-based stabilization techniques. A lime-fly ash pozzolanic solidification process produced a solid soil cement-like product with good structural integrity but poos- durability. Concentrations of hazardous aiemencs in ieachates from tU-is treated product were actually higher in about half the cases than they were in Ieachates : • -n similar untreated material. A cement/soluole-silicate treatment proces , produced a semi-friable material with low strengEh and a soil-like consistency. This process produced more consistent containment of hazardous elements with 60 to 70 percent of the constituents (toxic heavy metals and inorganic salts) having lower levels in the leachate from the treated sludge than in leachate from the untreated control columns.10 Although FGD sludges are exempted as nonhazardous solid wastes by EPA, the pozzolanic process is reported to be effective at stabilizing sludges from wet flue gas desulfurization (FGD) systems. Test data show that FGD sludge treated by the pozzolanic process is more environmentally acceptable over uncreated sludge because of reduced leaching potential and improved handling characteristics. Woodward and West provide pertinent information on commercially available pozzolanic treatment methods for stabilizing FGD sludge.11 Polymer impregnation and the application of surface coatings may help to increase the effectiveness of the ceraent/pozzolan-based process. The polymer impregnation process is accomplished by soaking the waste-concrete mixture in styrene monomer to fill the pores, followed by heating to induce polymerization. Surface coating materials include asphalt emulsion, and 9-252 ------- /inyl. PrcoLeas nave oeen encountered with surfaca coating because of poor adhesion of the coating onto the waste or lack of strength of the concrete material containing the waste.'' 9.7.3.2.5 Thermoplastic Techniques--Thermoplastic solidification/stabilization techniques use an organic thermoplastic material which is mixed with the waste to form a plastic matrix. Thermoplastic materials include bitumen, paraffin, and polyethylene. The waste is generally dried, heated, and dispersed through a heated plastic matrix which is then cooled to solidify the -nass. The rasul;ing ~ass is a relatively staole product which is generally superior to cement-based systems at reducing the potential for leachate generation.7 Thermoplastic techniques are relativelv exnensiv*? because ?£ complicated pr :c3sc1 :g ^4^iru"enc an-i i^gn energy costs for drying (incorporating wet wastes greatly increases losses through leaching). The technique cannot be used on waste material containing organic chemicals which act as solvents for the matrix. Other wastes which cannot be Created by this method include: strongly oxidizing salts, such as nitrates, chlorates, or perchlorates; materials that decompose at high temperatures, especially citrates and certain types of plastic (.e.g., polyethylene, polypropylene, acetal copolytner, and other crystalline resins);12 ancj tetraborates or iron and aluminum salts ;tnese compounds cause premature hardening and can clog and damage mixing equipment)•? 9.7.3.2.6 Organic Polymer Process—One well-documented organic polymer process employs urea-formaldehyde to encase waste material. Other polymers which could be used for this process iaclude vinyl ester-styrene and polyester resin. In the organic polymer process-r wet or dry wastes are mixed with a polymer to which a catalyst is added. The resulting product is a polymerized material which does not chemically combine with the waste buC forms a mass that entraps waste particles.7 No information could be found in the available literature regarding the long-term leaching characteristics of wastes treated by polymerization methods. Since no chemical reaction occurs between the waste and polymer in the solidification process, a breakdown of the waste material may result in a release of hazardous materials. Secondary containment in steel drums may be worth consideration when employing an organic polymer process. 9.7.3.2.7 Surface Encapsulation Techniques—Surface encapsulation techniques, often referred to as "jacketing", enclose waste material which has been pressed or bonded together in a coating of inert material. Polyethylene is frequently used to jacket waste material. The major advantage of surface encapsulation is that it virtually eliminates the potential for leaching if the cover material stays intact. However, the technique is expensive due to high costs for resin material, equipment, skilled labor, and energy utilized during drying, fusing of the binder, and forming of the jacket. The TRW Corporation has investigated many alternative binding and coating systems and developed what it considers to be the optimum system. This system has been tested, and published data on the processes are available in Reference 13. The TRW surface encapsulation system requires that the waste material be thoroughly dried. The dried wastes are stirred into an acetone solution of 9-253 ------- •noaified i,2-polybutadiene for 5 minutes vhi.cn is chert allowed to set for 2 hours. The coated material is placed in a mold, subjected to slight mechanical pressure, and heated to between 120°C and 200°C to produce fusion. The agglomerated material is a hard, tough, solid block. A polyethylene jacket 3.5 rran thick is fused over Che solid block and adheres to the polybutadiene binder.'7 9.7.3.2.8 Self Cementing Processes—Self cementing processes are employed to stabilize industrial wastes which contain large amounts of calcium sulfate and calcium sulfitas jucr4 as fiue-gas cleaning or desulfurization sludges. Usually a small portion (8 to 10 percent by weight) of the dewatered waste sulfate/sulfite sludge is calcined under carefully controlled conditions to produce a partially dehydrated cementitious calcium sulfats or suifice. This calcined vasta •' s :'^ ;n ^ii^LroQucea into the bulk of the waste sludge along with other proprietary additives. The finished product is a hard, plaster-like material with good handling characteristics and/or permeability. This is a relatively inexpensive treatment method which generates a solid product with leaching characteristics similar to products of cement and lime-based cementing processes.'' 9.7.3.2.9 Classification and Pr JMCtion of Synthetic Minerals or Ceramics-- Glassification may prove to be an effective treatment for dealing with extremely toxic wastes. The waste material is combined with silica and can be fused in glass or formed into a synthetic silicate mixture. This is expected to form an extremely stable product which will have a low potential for leaching. The high costs associated with the process may preclude it for all but the most hazardous wastes.7 Classification is being studied for use in stabilization of radioactive wastes. 9.7.3.2.10 Economic Considerations—If more than one treatment/stabilization method will provide a stable waste, the owner/operator will attempt to select the cost-effective method. In most of the aforementioned stabilization systems, the cost of materials is the highest cost element. Other budget items include costs for: equipment, operators, and fees or royalties for use of patented processes. When considering the costs of materials, equipment, and energy required to treat a given amount of waste, the cement-based and pozzolanic systems are the least expensive of available solidification/ stabilization processes. Table 9.7.2 presents economic considerations for waste stabilization/solidification techniques (reprinted from EPA SW-872).? 9.7.3.2.11 Testing Physical and Chemical Properties of Stabilized Waste—The applicant should supply a protocol for testing the physical and chemical properties of the stabilized or solidified waste. Information should be provided on the reaction of the treated waste to applied stresses, permeability of the stabilized waste, wet/dry durability, and freeze/thaw durability. Use of leaching tests conducted under static or continuous flow conditions could be appropriate. These testing procedures will help establish whether the treatment method will be effective at stabilizing the waste over the long term. 9-254 ------- 3 "a 0 z i r 13 _ n —' 13 T •0 -J 3 a 10 a > —' V3 OT z z o c •J < Z -I o a ,! " ------- References L-+ and 15 present a discussion of testing procedures available co evaluate the physical and chemical properties of the treated waste. TesCing procedures are also discussed in EPA 5W-372.? The results of laboratory testing to determine the physical properties and chemical leaching characteristics of five industrial wastes that had been solidified or stabilized by one or more of four processes (lime-fly ash pozzolanic, caraent/pozzolan, organic polymer, polyethylene encapsulation) are presented in ,EPA-600/2-82-099.10 9.7.3.2.12 Effects of Biological Attack on Treated Wastes7—The permit reviewer should consider the effects that biological attack can have on the long-terra containment of solidified/stabilized waste. Biological attack can occur bv direct utilization ^? some solidification material as a substrate for aactenai growth, or by the biological production of acid materials that can attack and corrode treated wastes.7 of four solidification materials studied by Columbo and Neilson (Portland type II cement, urea-formaldehyde (UF) resin, asphalt, and vinyl ester-styrene), UF resin has the greatest potential for biological degradation.1^ Organic acids released by the decaying of organic material, such as plant roots, can cause corrosion of some waste materials, particularly those solidified with a lime or cament-based process.? 9.7.3.2.13 Effects of Curing and Aging Process on Treated Material?—The applicant should address the issue of curing if a ceraentitious solidification system is employed. It has been demonstrated that for cementitious systems, less leaching was observed when cement-based samples had been cured more than 100 days.7 r^e conditions of curing are also important. Solidified materials cured under humid conditions1 are less leachabLe than treated material allowed to dry during curing.7 The applicant should also consider the effects of aging on treated waste material. Urea formaldehyde solidification systems and treatment systems that involve bitumen-based or polymer systems extended with water may provide decreased containment of the waste with age.? Consequently, if the waste material is extremely toxic and long-term containment is imperative, an alternative treatment method that will provide long-term containment, such as glassification, should be selected. 9.7.3.2.14 Containers Holding Free Standing Liquids—If containers holding free standing liquids are to be placed in a landfill that is not equipped with a liner and leachate collection system, then the applicant must demonstrate how free standing liquids will be removed to comply with §264.314(b). One method of removing free standing liquids is simple decanting. This is a straightforward procedure but it is complicated by the fact that the applicant must now dispose of the decanted liquids. If the applicant proposes to decant free standing liquids he must demonstrate how the requirements of §264.315 will be met. These requirements specify that containers placed in a landfill must be at least 90 percent full unless the container is very small such as an ampule. One way to comply is to add a filler material so that the container is at least 90 percent full. 9-256 ------- Sorbent materials can be divided into three general classifications: natural organic (e.g., straw, sawdust), natural inorganic (e.g., clays, calcium carbonate), and synthetic (e.g., polyurethane). Each generic type is different in terms of cost and effectiveness. The natural organic and inorganic sorbenta are generally readily available and less expensive than the synthetic sorbents. Although more expensive, the synthetics are more versatile than natural sorbents and tend to exhibit higher sorption capacity for many organic hazardous wastes. Both natural and synthetic sorbents .-.an b------- The use of absorbents xs a common method to eliminate free standing liquids from containers. The use of absorbents is often preferred over decanting to avoid subsequent handling of decanted liquids. Section 7.3.2.5 of this document discusses the use of absorbents and provides a matrix of available absorbents and their compatibility with various hazardous wastes. As an alternative to removing free standing liquids by decanting or the addition of an absorbent, the applicant may propose to eraoty the waste into a large container or impoundment and employ a treatment/stabilization method. If such a procedure is employed, the applicant is now disposing of a bulk or noncontainerized waste and, therefore, all the free liquids (not just free standing liquids) must be removed prior to placement of the waste if the landfill is not equipped with s. liner and ieachate collection system. 9.7.3.2.15 Decanting of Liquids and other Methods of Liquid Removal— Decanting of free liquids, although not a "treatment method", may be an effective way of removing free liquids from a waste. This method is more adaptable to wastes containing solids which do not remain in suspension, but instead settle Co the oottonr of the container. Decanting may be followed by a treatment/stabilization method, or if the landfill incorporates a liner and Ieachate collection system, tne decanted liquid may be disposed of in the landfill cell. In additon to decanting, there are several other methods of physical separation. Some of the techniques employed to dewater municipal sludges may be applicable to hazardous industrial wastes. One such method is vacuum filtration. The process separates solids and liquids by porous media filtration. Media employed for this purpose include steel coils, metal mesh, and cloth.17 If proper weather conditions prevail, hazardous wastes can be dewatered in sludge drying beds. Dewatering occurs through evaporation.17 If sludge drying beds are proposed, the issue of hazardous waste leaching must be considered. Additionally, this method may not be appropriate for wastes which could create an air pollution problem through evaporation and dispersion of volatile compounds. Another way of separating solids from liquids is through the use of continuous centrifuges. This method has been employed successfully in the chemical and mining industry for many years. 1C has also been used effectively to dewater municipal wastes and wastes generated by paper-mills, foundries, and refineries.17 9.7.3.2.16 Addition of Absorbent Material—Although the EPA has stated that the addition of an absorbent material does not constitute "treatment" of free liquids (February 25, 1982, 47 FR 8304), the technique is widely used because of its low cost. However, addition of an absorbent may not stabilize the waste over the long term and, hence, the waste may be susceptible to leaching. Consequently, the use of an absorbent may not always be a viable approach. 9-257 ------- -J < as .1 33 2S a o1 01 =3 < 33 N — "• C O 01 Li >> 4) r< aj ~< a -: as -M 33 ••^ .. S-i 41 2 ii § § O CO I—. 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Yes No Are acceptable methods specified for analyzing the wastes for free liquids? Yes No - BULK OR NON-CCfJ7AINERI222 ','AoTi DISPOSAL Does the landfill meet leachate collection and removal system requirements specified in Section 9.2? Yes No If not, Are wastes treated to eliminate free liquids? Yes No Is a detailed description of the treatment method(s) provided? Yes No Did the applicant document the effectiveness of the treatment process(es)? . Yes No CONTAINERIZED WASTE DISPOSAL Are containerized wastes treated to eliminate free liquids? _____ Yes No Which of the following methods are used: • Solidification/stabilization? Yes No • Mixing with absorbent materials? Yes No • Decanting? Yes No • Other methods (specify) Figure 9.7.3. Worksheet for evaluating disposal procedures for liquid wastes- 9-261 ------- If decanting is used, did 'the applicant describe procedures for disposing the decanted Liquid? Yes No Are containers at least 90 percent full after eliminating the free liquids? Yes No Are detailed procedures for the treatment processes provided? Yes No Are any free liquids dispose'- in very small containers?