-------
(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
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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
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• -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
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.-.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
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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
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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
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(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
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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:
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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
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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,
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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
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\
* 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
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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
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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
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(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
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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
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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
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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
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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
-------
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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
-------
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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
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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
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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
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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
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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
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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
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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.]
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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
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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
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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
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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.
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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
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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
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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
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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:
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.]
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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
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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
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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
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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
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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
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', 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
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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
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• 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
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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.
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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
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'..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
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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.
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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
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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
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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
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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,
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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.
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• 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.
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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.
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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
care plan submit:'.ad '-.ndar "273.1-Ao/ (13>. ;
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.
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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:
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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.
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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.
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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
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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
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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,
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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.
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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.
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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."
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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."
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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
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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
-------
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8-189
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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
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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
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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
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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
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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
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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
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• 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
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8-197
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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
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''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
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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
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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
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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
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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
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A/o Cumpt/undt Oti/n
s ind Hs ij rn '
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Figure 8.7.3. Hazardous waste compatibility chart.
Source: Reference 1
8-204
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REACTIV TY CODE CCNSEQLENCES
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Explosion
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May be hazardous but unknown
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Figure 8.7.3. (continued)
8-205
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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
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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
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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
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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
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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
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(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
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(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
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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
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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
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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
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. -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
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• 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
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9-15
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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
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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
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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
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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
-------
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TABLE 9.2.5. FAILURE CATEGORIES
Physical
Biological
Chemical
Puncture
Tear
Creep
Freeze-thaw cracking
Wet-dry cracking
Differential settling
Thermal stress
Hydrostatic pressure
Abrasion
Microbial attack
Ultraviolet attack
Ozone attack
Hydrolysis
Ionic species attack
Extraction
Ionic species incompatibility
Solvents
Source: Reference 3 (SW-870).
9-26
-------
Physical failures, especially puncture, are more prevalent problems for
landfills than for other types of waste storage or disposal facilities because
of the nature of the wastes and methods ?f vasce placement (dropping of waste
containers, driving vehicles above the liner, etc.) Puncture, tearing, or
abrasion may result when run-off containing branches, rocks, or other debris
cooes in contact with the liner. In addition, puncture failure can be caused
by burrowing or hoofed animals.
EPA recommends protecting synthatic Liaers from above and below by a
minimum of 6 inches of bedding material. (The top bedding layer also acts to
protect the membrane from damage due to exposure to sunlight and wind while
the cell is in operation). However, membrane liners can be punctured by
angular rocks in cha bedding ^acarial -hat becitaa exposed during
installation. For this reason, the bedding layer should consist of materials
which are no coarser than sand (SP) as defined by the Uniform Soil
Classification System (USCS). The bedding material does not necessarily have
to be a separate layer; natural soils or the leachate collection system media
may meet the necessary criteria. However, due to the possibility of puncture
from plant growth, application of herbicides on such soil may be appropriate.
Tear failure may occur as a result of the same mechanisms which cause
puncture failure. In addition to the effects of landfill operations and
burrowing animals, strsss-relaxation-stress cycles may lead to tear failure.
Proper design of liner bedding and care in operation will decrease the chances
of this occurrence.
Creap failure arises with incraasing deformation of the membrane under a
sustained load. Material microstructure, stress level, and temperature all
influence creep, and as a result, it is difficult co detect and control.
Thermal stress results from the occurrence of differential temperatures
throughout the liner material or temperature changes which are great enough to
cause a phase change in the material. Phase changes in membranes can cause
volume changes by expansion or contraction. It can also 'z* significant in
composite materials as the various components may have different thermal
reaction rates.
Freeze-thaw cracking and wet-dry cracking are cyclic occurrences causing
repeated expansion and shrinkage of the liner material. Freeze-thaw is a more
important concern for buried membrane liners. It acts to increase pore space
volume and, therefore, the accessibility of liquids to this pore space.
Freeze-thaw cracking may affect the en?ire expanse of liner rather than a
localized section. Therefore, it is important to guard against it. Liner
shrinkage and expansion will generally not be equal. Expansion takes place in
the calender direction, transverse to the seams. Studies of HOPE, in
particular, show this type of movement. It is imperative to design for
control of thermal stress by allowing for expansion and contraction. In
addition, expansion and contraction of pipes entering the landfill should be
considered to assess their potential effect on the liner material.
9-27
-------
Differential settling of the Liner base will induce liner stresses tnat
may cause elongation, tearing, or a change in liner elascicitv. '>i: pr-;l =r.
can be minimized with proper geologic analysis prior to site selection and
careful design and construction of the subgrade.
Liner resistance to internal and external pressure gradients is an
important consideration. Liners are subjected to pressure due to swelling and
cracking from within and pressure due to waste and equipment loading from
above. Hydrostatic pressure railure is of concern when the structural
integrity of the subgrade or base material is lost (due to sinkholes,
oxidation of organic materials, etc.)
Finally, Abrasion, JT wearing or tne liner, may be caused by wind or
run-off. If blowing sand particles are a concern in the region in which the
landfill is constructed, it should be designed with an abrasion-resistant
liner or protective cover over all areas of the liner.
Biological failures due to microbial attack, particularly of the
plasticizers used in some polymer compounds, are most often prevented with the
addition of bactericides during liner manufacture.
Experience indicates that vegetation can penetrate liners of 40 mils
thickness. 16 Therefore, the owner/operator should consider the use of
sterilants or herbicides in the liner bedding proposed for the landfill liner
system or cap.
Swelling of ;ne liner is a chemical failure mechanism which can cause
softening, loss of tensile and mechanteal strength, elongation, creep and
flow, and loss of puncture resistance. Adequate waste,liner compatibility
studies and placement of Che liner using recommended bedding layers will aid
in preventing such failure. Extraction of plasticizers from liner materials
such as PVC can result in shrinkage, embrittlement, and breaks in the liner
material.
Atmospheric ozone is another source of chemical failure which can cause
cracking of many polymers, particularly those which are partly unsaturated.
Failures such as this are likely, especially in situations where the membrane
is stretched. More detailed information may be found in Reference 17
(A. G. Strong, 1980), as recommended in the Liner TRD.
Climatic conditions which affect performance are temperature, rainfall,
and wind direction and velocity. As such, performance of a given liner type
will vary with geographic location. Exposure to sunlight or ultraviolet light
will affect certain types of synthetic liners.
Ambient temperature, temperature extremes, and the duration of such
extremes may be of particular significance in the liner selection process.
Liner materials exhibiting superior low temperature resistance to cracking may
not be able to withstand high temperature effects. If temperatures are low
enough to cause icing or freezing, this may affect the structural integrity of
the liner and/or the subgrade. Depending on the type of liner, low
temperatures can cause stiffening, causing the liner to become brittle. When
9-28
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wanned again, the time required for softening varies. AS7M :3sC3 ara
availaole co predict chese properties. On the other hand, high tamoeratur»s
mav cause some liner r.atarin-3 to crasp, crljngating co ranure during nigh
temperature cycles.
Rolled or folded panels of thermoplastic liner uaterial can block or
stick together if exposed to the sun's heat during installation. As these
'panels are unfolded, coated sheets may split and unsupported sheets -nay tear.
Black sheeting has been reportaa-3 co reach temperatures of 220JF at the
surface during installation. At this temperature, tensile and tear strength
can be significantly lower than at normal test temperatures. To minimize
liner temperature effects during installation, at least one material
(HvcalonL--^ i* ivrilibl; i.i -,hica. ^iner ouriai aoatas temperature extremes
because of temperature stability below ground. However, recent studies (a-t
sanitary landfills) indicate that sustained temperatures as low as 60°F below
ground or inside the landfill may be detrimental over time because these
conditions are suitable for methane generation.^9 £f ga3 venting is not
provided, liner uplift or rupture may occur.
Recommended temperature for liner installation is approximately 50"?,
aicnougn liner manufacturers report an allowable range of 4-95°F.16,20
Rainfall will affect Liner service life. Althougn no specific studies
are available testing rainwater, studies have been conducted co assess the
effect of water on synthetic liners. For example, one liner fabricator has
performed tests on Hypalon liners usiog, both distilled and cold tap vater.
'''ei^nt gains from water exposure with one grade of hypalon were lessened
significantly with addition of lead salts, formulating another grade of
Hypalon liner.-- Commentary on cne effects of rainfall on liner system
performance is also provided in the subsection on landfill foundation design
and integrity. As noted in subsection 9.3, Monitoring and Inspection, liners
should not be installed during wet weather conditions.
Wind is a factor that must be considered during liner installation and in
accepting the final installation. Liner abrasion may occur during
installation as a result of the impact of windborne sand particles, especially
in arid regions. If liner ends are left exposed on slopes at the top of a
landfill cell, whipping or repeated lifting of the exposed material can lead
to tearing or cracking. To avoid this, some form of ballast should be used to
hold down any exposed section of liner. Ideally, all sections of liner
material should be covered with soil.
Certain liner materials are affected by exposure to sunlight. For
example, CSPE is an exposable liner (sides, slopes) whereas PVC is normally
used in situations where it will be covered to avoid exposure to ultraviolet
light. Unprotected, clear polyethylene has an instant thermal reaction upon
exposure to sunlight and degrades rapidly. However, the addition of 2 to
3 percent carbon black improves its resistance to ultraviolet light. Some
liners have also been found to be sensitive to infrared light.
Table 9.2.6 is provided to summarize the effect of weathering on
synthetic liners and is based on information presented in SW-870.
9-29
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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
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?.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
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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
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« 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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
-------
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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
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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
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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
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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
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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
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"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 '
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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
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.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
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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
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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
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• 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
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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
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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
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?-. ;-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
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-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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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->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
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• 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
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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:
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* 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.
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•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.
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: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
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• 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
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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.
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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
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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
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^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
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« .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)
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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.
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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.
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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
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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
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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
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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
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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
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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,
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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
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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.
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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,
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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.
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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
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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.
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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
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*'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?
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'•--•> 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.
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?.-, 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
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(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.
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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
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•3
V)
3
O
0)
3
V)
J
3
-3
"3
•3
73
5
30
il
>T
:?\
U
3
9-190
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O-