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     [
        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

-------
 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
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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
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      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
-------
     •    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
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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
-------
     V.o.  invironment Protac:: ion Agency.  Lining of Waste Impoundment and
     Disposal Faciltities.  Prepared by Matrecon for the U.S. SPA.
     Second Edicion.   SW-870.  September 1982.

 5.   U.S.  Environmental Protection Agency.  Draft RCRA Guidance
     Document.  Landfill Design:  Liner Systems and Final Cover.  July
     1982.

 6.   Perrier, E.  R.,  and A.  C.  Gibson. Hydrologic Simulation on Solid
     Waste  Disposal  Sites.  Prepared for che U.S. Environmental
     ?rocection Agency by the U.S. Army Corps of Engineers Waterways
     Experiment Station.  Second Edition.  SW-868.  September 1982.

 7.   Moore,  C.A.   Landfill and  Surface Impoundment Performance
     evaluation.   Prepared for  the U.S. Environmental Protection Agency
     by Geotechnics,  Inc.  Second Edition.  SW-869.  September 1982.

 8.   Walski,  T. M.,  et al.  User Guide for the HELP Model.  Prepared for
     the U.S. Environmental  Protection Agency by the Army Corps of
     Engineers Waterways Experiment Station.  Contract No. AD-96-F-2-A140.

 Q.   Schroetier, ?. R. et al.   Documentation for the HELP Model.  Prepared
     for the  U.S. Environmental Protection Agency by the U.S. Army Corps
     of Engineers Waterways  Experiment Station.  Contract No.
     AD-96-F-2-A140.

10.   Skaggs,  R. W.  Modifications to DRAINMOD to Consider Drainage from
     and Seepage Througn a Landfi-11.  I.  Documentation.  August 26, 1982.

11.   Correspondence from Mr.  Les Qcte, U.S. 2PA Office of Solid Waste to
     Mr. C. Young, GCA/Technology Division.  April 20, 1983.

12.   Design Manual.   Onsite Wastewater Treatment and Disposal Systems.
     U.S.  EPA.  October 1980.

13.   Perry, R. H., C. H. Chilton and S. D. Kirkpatrick.  Chemical
     Engineer's Handbook.  McGraw-Hill, 1963.

14.   Kirby, G. N.  How to Select Materials.  Chemical Engineering.
     November 3, 1980.

15.   GCA/Technology Division.  "Clogging of Leachate Collection Systems
     Used in Hazardous Waste Land Disposal Facilities."  White Paper
     prepared for the EPA Office of Solid Waste.  January 1983.

16.   National Clay Pipe Institute.  Clay Pipe Engineering Manual.
     July 1982.

17.   Johns-Manville.   Perma-Loc™ PVC Gravity Sewer Pipe.  TRX-39.  April
     1982.
                               9-106
-------
                       ?-. ;-3 j/s:2ms.  .-;r~as ;r ir.  ,  .-=r:na--oc  ,  ?VC,
     Transite  , Thermopipes  .  TR-32Q.  January  1982.

19-  Ford, Harry W.  The Problem of  Clogging  in  low Volume  Irrigation
     Systems and Methods for Control.  Paper  presented at the Symposium
     on Drip Irrigation in Horticulture with  Foreign  Experts
     Participating.  Skierniewice, Poland.  October 1930.

20.  Baron, Donald M.  A Well System Can be Designed  to Minimize  the
     Incrusting Tendency.  The_ Jqrmson Driver s  journal.   First  Quarter,
     1932.  pp. 8-11.

21.  Beger, Hans.  The Iron Bacteria  In Water systems and Their Practical
     Significance.  "as-u.  '/aao^rfjcn.  jo.366-869,  908-911  (as  cited in
     Reference 22).

22.  Telephone Conversation.  Dr. Ron Lavigne, Reinhardt Associates,
     Springfield, MA with Thomas Nunno, GCA/Technology Division.  June
     1982.

23.  Grass, Luther B.  Tile Clogging  by Iron and Manganese  in Imperial
     '.'alley, California.  Journal of  Soil and Water Conservation, August
     1969.  24(4):135-138.

24.  Ford. Harry W.  Characteristics  of Slime and Ochre in  Drainage and
     Irrigation Systems.  Transactions of the American Society of
     Agricultural Engineers, 1979.   Volume 22, No. 5, pp. 1093-1096.

25.  Ford, Harry W.  Biochemical and  Physical Factors Contributing to
     Resistance in Drain Outflow in  a Modified Spoaosol.  soil and Crop
     Science Society of Florida, 1974, 34:11-15.

26.  Ford, Harry W.  Estimating the  Potential for Ochre Clogging Before
     Installing Drains.  Transactions of the ASAE.  Paper No. 8-2542.
     Submitted and approved for publication, December 1981.   pp. 1-11.

27.  Ford, Harry W.  Soil Conditions  that Promote Iron Reduction and
     Subsequent Ochre Clogging in Agricultural Drains.  American Society
     of Civil Engineers.  Irrigation and Drainage Division Specialty
     Conference.  1982.  pp. 1-7.

28.  Fasken,  Guy B.  Engineering Field Manual  for Conservation Practices,
     Chapter 14.  Drainage.   U.S. Dept.  of Agricultural Soil Conservation
     Service.  April 1975.   pp.  14-48.

29.  Kobayashi, Hester, and  Bruce E.  Rittmann.  Microbial Removal  of
     Hazardous  Organic  Compounds.  Environmental Science and Technology,
     1982.  16(3):170A-183A.

30.  Cedergren, H.  R.   Seepage,  drainage,  and  Flow Nets.   John Wiley and
     Sons, 1967, pp. 178-187.
                                9-107
-------
ji.  J.z. nrmy Jorps or Engineers.  ^r^ina^e ana cirosion
     Control-Subsurface Drainage Facilities for Airfields.  Fart XIII,
     Chapter 2, Engineering Manual, Military Construction, Washington,
     D.C., June 1955.

32.  Sherard, J.  L., R. S. Decker, and N. L. Ryker.  Piping in Earth Dams
     of Dispersive Clay.  Proceedings A.S.C.E. Specialty Conference on
     the Performance of Earth and Earth-Supported Structures,  Purdue
     University,  June 1972, Vol. 1, Part 1.

33.  U.S. Bureau of Reclamation.  Earth Manual, 2nd. Edition,  Denver, CO,
     81 pp., 1974.

34,  Demery , ?. M.  ?.c search Ana I/au or Plastic Filters.  Proceedings of
     the 1980 Specialty Conference Irrigation and Drainage - Today's
     Challenges,  July 1980, Boise, Idaho.

35.  Willardson,  L. S., and R. E. Walker.  Synthetic Drain Envelope -
     Soil Interactions.  Journal of the Irrigation and Drainage Division,
     ASCE, IR-4,  Dec. 1979, pp. 367-373.

36.  aenz, L. C.  et al.  Evaluation of Some Subsurface Drainage
     Envelopes.  Proceedings of the National Drainage Symposium, Chicago,
     IL, 1976.  pp. 31-33.

37.  Broughcon, R. S., et al.  Tests of Filter Materials for Plastic
     Drain Tubes.  Proceedings of 3rd National Drainage Symposium,
     Chicago, IL, L976.  pp. 24-3^.

38.  Frogge, R. R., and Glen D. Sanders.  USER Subsurface Drainage Design
     Procedure.  Proceedings of the ASCE Irrigation and Drainage Division
     Specialty Conference on Water Management for Irrigation and
     Drainage, July 1977.  Reno, Nevada.

39.  Ford, Harry W.  Low Pressure Jet Cleaning of Plastic Drains in Sandy
     Soil.  Transactions of the ASAE.  1974, 17(5): 895-897.

40.  Lidster, William A., and H. W. Ford.  Rehabilitation of Ochre-(lron)
     Clogged Agricultural Drains.  International Commission on Irrigation
     and Drainage.  Eleventh Congress.  Q. 36 pp. 451-463.

41.  Telephone Conversation.  Greg Woelfel, Northern Regional Engineer,
     Waste Management Inc. (414-476-8858) and Thomas Nunno,
     GCA/Technology Division.  23 April 1982.

42.  Ground Water and Wells, Chapter 16, Maintaining Well Yield, Johnson
     Division, UOP Inc.  Sixth Printing, 1980, pp. ..7-332.

43.  Thomas, Abraham, et al.  Physical and Chemical Rehabilitation of
     Containment Recovery Wells, Army Creek Landfill, New Castle County,
     Delaware Presented at Association of Engineering Geologists, Annual
     Meeting Hershey, Pa., October 1978.
                               9-108
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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
-------
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
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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
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dust  from 'jnp.aved haul roaas ana excav^- -, --i ic:_.-._^ = o.  .he acoli-ant snouia
describe mecnoas ot concrcl, such as cnemicai scaoil izers ,  vegetative covers,
or wee suppression, and should estimate Che efficiency of the proposed wind
aispersal control method.

9.2.7.3  Guidance on Evaluating Application Information —
     Particulate matter entrainment due to wind dispersal must be controlled
during the active life of the facility and during the closure and post-closure
care periods.  A flow chart indicating the applicability of che part 26^
requirements is presented in Figura Q.1.38.

     Several options are available to control wind dispersal of particulate
matter, as illustrated in Figure 9.2.39.  Options listed below may be
implemented individually or in ^crabir.atior. is r^qui^ec 1.0 prevent fugitive
     (a)  reduction of wind-speed (wind breaks),

     (b)  use of dust suppressant (chemical or water-amended spray
          application) ,

     (c)  establishment and Tiaintanance jf a vegetative cover,

     (d)  maintenance of soil moisture (periodic irrigation).

     Susceptibility to wind dispersal is directly related to the moisture
content of soils.  Keeping the soil motst reduces the potential for wind
dispersal of particulate matter.  In addition, by rougning the soil surface,
che wina velocity can be decreased and- some moving particles trapped.
Barriers such as tree shelterbeds are effective in reducing wind velocities
for short distances ana for trapping drifting soil.  Picket fences and burlap
screens, while less efficient as windbreaks than trees, are often preferred
because they can be moved from place to place as portions of the facility open
and close.

     Other factors that will affect particulate matter dispersal are local
prevailing wind direction, type of waste to be disposed, and operating
techniques to be employed ac the site.  Familiarization with eacn of these
will enable proper steps to be taken to minimize the effects of wind
dispersal.  Establishing a wind break at the edge of the site,  perpendicular
to the prevailing wind direction will lessen wind speeds across the unit.  Use
of a dust suppressant, such as water, on dry, powdery wastes will. help control
dust generation during waste disposal.  Also, scheduling disposal activities
to avoid periods of excessive wind speed and turbulence and atmospheric
instability will control wind dispersal.

     The technical adequacy worksheet for determining the suitability of the
applicant's plan for controlling wind dispersal is presented in Figure 9.2.40.
                                     9-138
-------
DOES OR WILL THE LANDFILL CONTAIN
ANY PARTinil ATF MATTFR ^!lfl IPTT

, C 1 < NO * i 5r tRjAL.
./ THE \
NO ^ REGULATIONS
j nr(£ NOT
(^APPLICABLE
                        YES
                    _L
       ARE WIND DISPERSAL CONTROL
        METHODS PROPOSED SUCH AS
        LANDFILL COVERS OR OTHER
          MANAGEMENT PROCEDURES
                           NO
         ARE THE CONTROL METHODS
           ADEQUATE TO PREVENT
          PARTICULATE DISPERSAL
                                                       X  THE
                                                         PLAN IS
                                                       TECHNICALLY
                                                       JNAD EQUATE
                THE PLAN
              S TECHNICALLY
                ADEQUATE
Figure 9.2.38.
Regulations applicable Co the concrol of wind dispersal
of particulate matter at hazardous waste landfills.
                                 9-139
-------
 APPLICATION OF
     COVERS
 INTERMITTENT OR
TEMPORARY COVERS
   FINAL COVER
COVER MAINTENANCE
  AFTER CLOSURE
                         DESIGN OF WIND
                            rMSPERSAL
                         CONTROL SYSTEMS


OTHER MANAGEMENT
TECHNIQUES
                WIND  BREAKS
                   OUST
               SUPPRESSANTS

INSPECTION  REQUIREMENTS
   DURING  OPERATION
         Figure 9.2.39.  Wind dispersal control options,
                               9-140
-------
 MANAGEMENT OF WIND DISPERSAL


 Has  this part of  che applicant's subraittal been read and        	   	
 evaluated?                                                        ves      no

 Is ^rosion pocentiai addressed for:

     Waste materials?
                                                                  yes      no

     Landfill cover?
                                                                  yes      no

     Unpaved haul roads?                                        	   	
                                                                  yes      no

     Excavation activities?                                     	   	
                                                                  yes      no

Are control methods described (e.g., chemical stabilization,    	   	
vegetative covers, wet suppression, wind breaks,  etc.)?   '        yes      no

Is particulate control efficiency estimated for each            	   	
control method?                                                   yesJ^~

Are waste disposal operations suspended during                  	   	
excessively high winds?                                           ves      ~
    Figure  9.2.40.   Worksheet  for  evaluating the  adequacy of wind dispersal
                    control  measures.
                                    9-141
-------
3...~.-  3rafc Permit Preparation—
     As noted in Module XV,  Condition 3.5,  :he permit snould soecifv -nechods
for concroLliag wind dispersal if the landfill contains  partLCjlace  ^ac:ar
vnich may be subject co wind dispersal.   This condition  is implemented througn
reference to a permit attachment that includes plans and specifications  for
the proposed wind dispersal  control measures.  Submitted application
information suitable for substitution in the permit condition attacnment
should include the following:

     *    A -^acnpcion of areas where wind dispersal controls  are applicable.

     •    A description of methods used  for wind dispersal control.

          '•'ir.d -ispersal concroi efficiency estimates, along with  calculations
          and supporting data.

9.2.8  Subpart F Exemption

9.2.8.1  The Federal Requirement —
     The Part 770 information requirements  state in §270.21(c)  that:

               "If an exemption from Subpart F of Part 264 is sought,  as
          orovided by §264.302(a), the owner or operator must submit detailed
          plans  and an engineering report explaining the location  of the
          saturated zone in  relation to  the landfill, the design of  a
          double-liner system that incorporates a leak detection system
          between the liners,  and a leachate collection  and removal  system
          aDove  the liners."

     The taxt of §264.302 specifies the  requirements for double-lined
landfills designed for exemption from^Subpart F ground water protection
requirements.  This section  of the regulation states that:

               "(a) Tha owner or operator of a double-lined landfill is  not
          subject to regulation under Subpart F of this  part if the  following
          conditions are met;
               (1) The landfill (including  its underlying liners)  must be
          located entirely above the seasonal high water table.
               (2) The landfill must be  underlain by two liners which  are
          designed and constructed in a  manner to prevent the migration of
          liquids into or out of the space  between the liners.   Both liners
          must meec all the  specifications  of §264 .301(a) (1) .
               (3) A leak detection system  must be designed, constructed,
          maintained, and operated between  the liners to detect any  migration
          of liquid into the space between  the liners.
               (4) The landfill must have a leachate collection and  removal
          system above Che top liner that  is designed, constructed,
          maintained, and operated in accordance with § 264.301(a)(2).
               (b) If liquid leaks into  the leak detection system, the owner
          or operator must:
                                    9-142
-------
                 1,'  Mocny  c.i
-------
IS AN EXEMPTION FROM
PART 264, SUSPART F SOUGHT?
           NO
iNFiRM COMPLIANCE WITH
PART 264, SUSPART F
    ,YES
   IS DOCUMENTATION INCLUDED PROVING
   THAT LANDFILL AND LINERS ARE ENTIRELY
   ABOVE THE SEASONAL 4MH WATZR 7A3LET
       ,Y£S
      DOES THE DESIGN PROVIDE FOR TWO
      LINERS UNDEP. ~H£ LANDFILL?
                     NO
          YES
         WILL THE DESIGN AND CONSTRUCTION OF
         THE LINERS PREVENT LIQUIDS FROM
         GETTING INTO OR OUT OF THE SPACE
         BETWEEN THE LINERS?
             .YES
            DO 80TH OF THE LINERS MEET
            OF THE §264.301(a)(1) SPEC
               \t
                .YES
               DOES THE DESIGN PROVIDE FOR THE
               INSTALLATION AND OPERATION OF A
               LEAK DETECTION SYSTEM BETWEEN
               THE TWO LINERS?
                              NO
                   YES
                  DOES THE DESIGN INCLUDE A LEACHATE
                  COLLECTION AND REMOVAL SYSTEM ABOVE
                  THE TOP LINER THAT MEETS ALL THE
                  §264.301(a)(2) CRITERIA?
                     \ r
                                    NO
                      YES
                     DOES THE SUBMITTAL INCLUDE A PLAN FOR
                     REMOVAL OF WASTES AND LINER REPAIR OR
                     IMPLEMENTATION OF A DETECTION
                     MONITORING PROGRAM IF LIQUIDS LEAK
                     INTO THE LEAK DETECTION SYSTEM?
                                                    THE
                                                 PLANS ARE
                                                TECHNICALLY
                                                 ADEQUATE
    Figure 9.2.41.
Applicability of Part 264 requirements co the Subpart F
exemption.
                                     9-144
-------
r=~2rr?-J  "o  — '- ;, u i.: a r. c a provic^a  -n suosectisn  ? . 2 . 1 . j . ~  rcr  evaluation  of
information on water caoLe elevation and to  suosection  9.2.1.3.2  for  guidance
on Liner -naterials, cnemical properti.es, and  liner strength and  thickness.   To
evaluate the adequacy of the leak  datsction  system and/or  the  leachate
collection system, the permit reviewer is referred to  subsection  9.2.2.3  which
provides guidance on system design and materials, chemical resistance,  pipe
strength and thickness, and media/pipe clogging.  Although resistivity  probes
could be used for leak detection systems, the Agency strongly  recommends  that
drainage media and piping be designed into the svstera  as  for leachate
collection «"scsn!3.  If 1 ;:.'kage occurs, cnen  a system  will be  in  place  for
leacnace collection and removal.

     The technical adequacy worksheet for determining  che  sui tab-.l itv if  -^*
apoiicane'« ->lin fcr -r>. -x^npt: i.;r.  j.-on: -uoparc c' j.s presented  in
rigura }.L.-+2.  Worksheets incorporated in subsections  9.2.1.3 and  9.2.2.3
should be used first to assess the adequacy of liners,  leak detection systems,
and leachate collection systems.

9.2.3.4  Draft Permit Preparation—
     As noted in Condition C of Permit: Module XV, permit applications that
satisfy the exemption requirements should be documented  in tha administrative
record.  The cermc shouia include, oy attachment, design and  operating
conditions for double liners, leachate collection and  removal  systems, and
leak detection systems.  Design and operating conditions pertinent  to leak
detection and subsequent required actions should be highlighted  in  the body  of
the permit.

9,2.8.5  References —

1.   U.S. SPA.  Permit Aoolicancs'  Guidance Manual cor Hazardous  Waste Land
     Storage, Treatment and Disposal Facilities.  Volume I.  Office of Solid
     Waste.  Washington, D.C.  1983.
                                    9-145
-------
                               SUBPART F EXEMPTION
das this part of the applicant's subraittal been read             	  	
and evaluated?                                                    Yes      Mo

Is hydrologic data provided which indicates the location         	  	
of the seasonally high ground water table relative to             vas      "o
Che landfill?

Is the landfill and liner system completely above                	
he high water table at all times?                                 vas      v,~

-oas ar.e xiner system design prove suitable based                	
on use of the evaluation procedures and worksheets                Yes~~No~
incorporated in subsection 9.2.1.2?

Do the leaK detection and leachace collection system             	  	
designs prove suitable based on use of :he evaluation             Yes      No
procedures and worksheets incorporated in subsection
       Figure 9.2.42.  Worksheet for determining adequacy of applicant's
                       submitcal for an exemption from Subpart F.
                                       9-146
-------
 9.3   INSPECTION1  .-.Iv'JlAS'iSNTS

 9.3.1   The  Federal  Reg--: Iranian: 3

      Part 270  requires  the  applicant  to  provide  the  following  information  on
 landfill inspection.

               "270.21(d) A description  of how each  landfill,  including  the
          liner  and cover systems, will  be inspected  in  order  to  meet  the
          requirements  of ??5-'i 102'j}  ,nd  •'•)}.   Thij  .;:iormation  should  be
          included  in the inspection  plan submitted under  §270.14(b)(5)."

      The relevant standards of §264.303  specify:

                '(AJ During  construction  or installation, liners  (except  in the
          case of existing  portions of landfills exempt  from §264.301(a) and
          cover  systems  (e.g., membranes, sheets, or  coatings) must be
          inspected for  uniformity, damage, and  imperfections  (e.g., holes,
          cracks, thin  spots, or  foreign materials).   Immediately after
          construction or installation:
               (i)  Synthetic  liners and  covers must be inspected  to  ansure
          tight  seams and joints  and  che absence of tears, punctures,  or
          blisters; and
               (2)  Soil-based and admixed liners and  covers must  oe  inspected
          for imperfections including lenses, cracks, channels, root holes, or
          other  structural  non-uniformities that may  cause an  increase in  the
          permeability of the liner coiter."

     §264.303(b) states:

               '(b) While a landfill  is  in operation, it must be  inspected
          weekly and after storms to detect evidence  of any of the following:
               (1) Deterioration, malfunctions, or improper operation of
          run-on and run-off control systems;
               (2) The presence of liquids in leak detection systems, where
          installed to comply with $264.302;
               (3) Proper functioning of wind dispersal control systems, where
          prasent, and
               (4) The presence of leachate in and proper functioning of
          leachate collection and removal systems, where present."

9.3.2  Summary of Necessary Application  Information

     The Part B Permit Applicants' Manuali instructs  the applicant to
develop and submit with  the application  a detailed written inspection
schedule.  The applicant is referenced CO the Permit  Applicants'  Guidance
Manual on th« General  Facility Standards for instruction on preparation of the
inspection plan.   The latter manual recommends that the applicant submit the
actual inspection log that he proposes to use for day to day inspection
activities.
                                     9-147
-------
 9.3.2   Guiaance_  ^n  -Zv a I : a c •. • 2  Arc'.. :g;-. jn  !.: ~ jnacior.

     Figure 9.3.1 presents a flow cnart identifying standards applicable to
 inspection of  the landfill.

 9.3.3.1   Introduction—
     The  requirements of  §264.303 identify specific inspections relevant to
 landfills that must be included, in addition  to the general inspection
 requirements,  as part of  the overall inspection plan required by 5 2"'Q. 14CbN (* 1
 and $264.15.   Tb« insoectisn -rccac-rss ;-:arai:caa cc -omply with §264.303
 requirements should address inspections conducted during three time periods.

     •    before/during construction

     *    after construction

     •    during operation

     The  first sentence of §264.303(a) requires inspection during construction
or installation of liner and cover materials  that will be placed in a new
 landfill.  The intent is to prevent the liner or cover from failure caused
 from improper  installation or  use jf poor quality materials (see subsection
 9.3.3.3).  Inspection after installation is also required by §264.303(a)(1)
and (2) (see subsections 9.3.3-4 and 9.3.3.5).  The intent is to insure that
the quality of construction is sufficient to  avoid liner or cover failure.

     Although not specifically stated, che intent of §264.303 is to allow for
rejection or rapair of che liner or cover system materials before or after
they are  installed if they do  not conform to  specifications.  Therefore, in
addition  to describing the inspection methods, che permit application should
 include a description of actions that will be taken if the materials are found
to be damaged or imperfect, or if the construction techniques or installation
procedures prove to be unacceptable.

     As part of an overall inspection plan, the owners or operators should
identify, by name or title, a  qualified person wno will be responsible for
conducting the inspection.  The various materials rcanufacturers/suppliers and
installation contractors involved in the construction of a landfill will
typically conduct various QA/QC and inspection procedures established as a
result of their experience.  However, the owners or operators should indicate
the presence onsite of at least one qualified inspector who represents only
their interests and from whom approval of procedures or inspection results
must be obtained before construction activities can proceed, or the installed
facilities can be accepted for operation.

     During evaluation of the  application, the permit application reviewer
should a*k Che following questions to determine the adequacy of proposed
inspection procedures.
                                    9-148
-------
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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
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                             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
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 arrival at  Che site should be conducted.  '.'nits vhose wrappings indicate
 potential damage or rough handling should be more closely inspected.  Shipping
 papers should be compared co nacenal markings and purchase orders Co insure
 conforraance with plan specifications.  The inspection plans should specify
 liner acceptance criteria.

     It is often necessary to store the synthetic liner materials onsite.
 During storage, all synthetic liner materials are suscaptiola to damage from
 sunlishe =nd ^.araparature excursions.  A frequent manifestation of this damage
 is blocking.3  Blocking occurs when the Liner material sticks to itself
 during storage.  When the material is subsequently unrolled or unfolded,
 blocking can result in delamination or tearing of the .-aatarial.  The
 insoecticn procedures jnoui« provide for an inspection of any proposed storage
 area prior to placement, of liner materials.  Specific criteria which the
 storage area should meet should be indicated in the plan.  The condition of
 each unit of material when first placed in storage should be noted and the
 inspection procedures should provide for periodic reinspection of stored liner
 materials.  The criteria which will be used to evaluate evidence of potential
 damage during storage should be stated as part of the inspection procedure.  A
 means for insuring that potentially damaged .aateriais are closely inspected
 •during ^subsequent installation should be indicated.

     Weather conditions can influence the potential for damage to synthetic
 liner materials during placement.  Inspection procedures should provide for
 approval to commence p.acament based on weather conditions.  High winds or
 extreme temperatures (hot or cold) should be Criteria for postponing
 olacaraent.3

     Each panel ~>t the overall liner is normally shipped to the landfill in
 units too large to be moved manually.  All mechanical equipment that will be
 used to assist in the movement and placement of liner materials should be
 inspected and specifically approved for the purpose.  The inspection of
 mechanical equipment should include consideration of the potential for damage
 to both the liner material and the underlying foundation materials.

     After liner panels are partially unfolded or unrolled on the foundation
 material with the assistance of mechanical equipment, each panel is manually
 pulled out to its full size by a crew of workers.  These workers will have
 cause to walk directly on the liner material.  Therefore, the inspection
 procedures should indicate a means of insuring that proper footwear is worn by
 the crew.

     The work crew also moves the fully extended panel into final position
manually.   This includes placement in anchor trenches and overlapping of
 adjacent panels.   At this point, che panel is anchored down with sandbags
and/or tire* to temporarily secure it in the desired position for subsequent
 seaming.  The inspection procedures should provide for a thorough inspection
of the placed liner panel at this time.  At a minimum the inspection should
 include:
                                     9-158
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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.
                                    9-159
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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.
                                    9-160
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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.
                                     9-163
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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)
                                    9-167
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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.
                                     9-168
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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.
                                  9-169
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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,
                                     9-176
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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
                                    9-177
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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.
                                    9-178
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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,
                        9-180
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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.
                                    9-181
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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.
                                    9-183
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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?
                                      9-185
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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.
                                    9-186
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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.
                                    9-188
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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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9-190
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-------
seven steps (see Figure 9.4.2), constitute a review of -natariaij and
conditions at the site under consideration.  The six procedures identified in
Figure 9.4.3 encompass 25 steps and pertain co tne cnaracteristics of the
cover system.  Figure 9.4.4 identifies procedures used to evaluate the
adequacy of post-closure plans in a total of seven steps.  The following
discussion describes evaluation procedures and their relationship to §264.310:

9.4.3.2.1  Examine Background Data (see Figure 9.4.2) —

     •    Examine soil test data (Steps 1-3)—Establish that the applicant has
          satisfactorily documented the physical characteristics,  volume, and
          spacial distribution of the soil types to be used in the cover,
          These data -BUSC 're raasor.aoiy accurate since they directly affect
          the adequacy of the cover system and the feasibility of the cover
          operation.

     •    Examine topography (Step 4)—The surface configuration is examined
          to assure that evaluations can be made in regard to slope stability,
          water erosion, and wind erosion.  Topographical data are often
          presented in the form of cross sections showing Che thickness of the
          closure cover and solid waste and the limits of natural  soil
          previously extracted for use as cover.

     •    Examine climatological data (Steps 5-7)—Permit applications should
          contain data on average monthly precipitation,  design storms, and
          evapotranspiration.   Average precipitation data are generally
          provided for 20 years of rain_fall records.  Design storm data should
          be provided for storms of 1-hour or longer duration, with a
          recurrence interval  of 10 to—20 years.  Since evapotranspiration is
          an important factor in removing moisture from the cover, the
          application should include ah- estimation of average monthly
          evapotranspiration rates.

9.4.3.2.2  Characterize the Cover System (see Figure 9.4.3)

     •    Evaluate composition (Step 3)—Cover composition should be evaluated
          with regard to trafficability, gas migration, and water
          percolation.  Since  minimizing infiltration is  of particular
          importance, it will  generally be necessary to reject simple
          one-layer designs in favor of multilayer systems which include a
          clay soil layer or a synthetic membrane liner.

     •    Evaluate cover thickness (Steps 9-13)—In addition to federal and
          state cover requirements, the cover thickness may be governed by the
          quantity of borrow available, infiltration, gas migration,
          trafficability and support requirements, freeze/thaw and dry/soak
          effects,  cracking, differential settlement, membrane protection, and
          vegetative requirements.  These factors should be addressed in
          permit applications.
                                     9-194
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     •    Evaluate cover placement procedure (Steps 14-13 .'--Cover can be
          improved in several ways as it is constructed.  Materials mav be
          added for better grading, hauling and spreading equipment can be
          operated in a manner which increases compaction, and layering can be
          used.  Internal layering can combine favorable characteristics of
          several materials.  Synthetic membrane liners used in this
          configuration should be at least 20 mils thick and should be placed
          in a relaxed state between smooth layers of soil to orevent d-mage.
          Syr,'hati~. l-lr.arc are oi-^n necessary to maintain permeability at or
          below that of the bottom liner system.

     •    Evaluate configuration (Steps 19-20)—Configuration should u<=
          sjv.1' ",ated ;n t-rns :f -re-sun potential and infiltration control.
          Erosion has the effect of degrading the cover, thereby seriously
          reducing its effectiveness.

     •    Evaluate drainage (Steps 21-24)—The application should address
          surface runoff drainage for the cover and surrounding area.   Ditches
          and culverts snould be sized to handle the design storm runoff.  The
          evaluator should apply design storm data to Manning's equation co
          check the specified dimensions.

     •    Evaluate vegetation (Steps 25-32)—Establishment and maintenance of
          vegetation requires an evaluation of soil type,  nutrient and pH
          levels,  climate, species selection,  mulching,  and seeding time.
          Species should be selected on the basis of environmental and
          biological strengths and limitations.

9.4.3.2.3  Evaluate Post-Closure Plan (See Figure a.4.4)

     •    Evaluate maintenance procedure (Steps  33-35)—Regular maintenance
          intervals should be planned to repair settling and erosion damage
          and to maintain the vegetative cover.   Provisions should also be
          made for site monitoring by a qualified technical person to
          periodically inspect the cover condition and take ground water
          samples.

     •    Evaluate contingency plan (Steps 36-39)—A contingency plan  should
          be established to deal with future unforeseen  problems such  as
          excessive wind and water erosion, loss of vegetation,  and drainage
          system failures.  The evaluator should consider  the likely
          effectiveness of post-closure plans  to address such problems in a
          timely manner.

     The procedural information provided above was obtained from EPA
Publication SW-867.  Information contained in  this document can be
supplemented with other references listed in Section  9.4.5.

9.4.3.3  Other  Sources of Information—
     An example of the kind of general  evaluation data that can be obtained
from symposia proceedings is presented  in Table  9.4.1.  The table  is excerpted
from a paper entitled  "'Containment1  Strategies  to Manage  Abandoned Hazardous
                                    9-195
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                                                                                      i    i    i    i
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                                    a.
                                                •

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                                                 9-L96
-------
Waste Sices in a Cost Iffactive Manner,  presented ac  cne  Fiftn  .Annual Madison
Conference by WESTON Designers/Consultants of West Chester, Pennsylvania. 10
The table evaluates various cover materials by indicating  positive performance
ratings with a plus sign and negative performance ratings  with a minus sign.

     Additional information that a permit writer can use to evaluate
post-closure plans is included in Reference 3 (EPA-600/2-79-165) .  Papers
presented in Reference 5 by Lutton^i and Rogoshewski^ provide information
on repairs to cover systems.

     A worksheet for determining the adequacy of closure and post-closure
procedures is presented in Figure 9.4.5.
     Condition M of Permit Module II addresses closure and post-closure permit
requirements.  Performance standards of the condition are implemented through
reference to a permit attachment that includes plans and specifications for
the proposed closure and post closure plan.  To be suitable for substitution
in the permit condition attachment,  the submitted application information
should include:

     •    Detailed plans and an engineering report describing design and
          construction of the final  cover, and

     •    A post closure plan describing maintenance and monitoring procedures
          following closure.

9.4.5  References

 1.  U.S. Environmental Protection Agency.  Permit Applicants' Guidance Manual
   .  for Hazardous Waste Land Storage,  Treatment, and Disposal Facilities.
     Volume I.  Office of Solid Waste.   Washington,  D.C.  1983.

 2.  U.S. Environmental Protection Agency.  RCRA Technical Guidance Document
     (Draft) Landfill Design, Liner  Systems and Final Cover.   July 1982.

 3.  U.S. Environmental Protection Agency.  Evaluating Cover  Systems for Solid
     and Hazardous Waste.  Second Edition.  SW-867.   September 1982.

 4.  Design and  Evaluation of Covers for Solid Waste Landfills.
     EPA-600/2-79-165.  August 1979.

 5-  Municipal Solid Waste:   Land Disposal, Proceedings of the Fifth Annual
     Research Symposium (Orlando, Florida - March 26-28, 1979),
     EPA-600/9-79-023a, U.S. EPA, MERL/CINN,  August  1979.

 6.  Disposal of Hazardous Waste. Proceedings of the Sixth Annual  Research
     Symposium,  (Chicago, Illinois - March 17-20, 1980), EPA-600/9-80-010,
     U.S. EPA, MERL/CINN, March 1980.
                                    9-197
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                        LANDFILL CLOSURE AND POST-CLOSURE


'Has this part of Che applicant's submittal  been  reviewed  and        	  	
evaluated?                                                           Yes     No

Have the physical characteristics, volume,  and spacial              	
distribution of soil types been documented?                          Yes     No

'-las ;he sice uopograpny seen examined  to assist  in evaluating:

9  Slope stability?
                                                                     Yes     No

•  Water erosion?                                                   	
                                                                     Yes"   "N
-------
                         oeen evaluated on the basis of:

 9   Stace  ana  Federal  requirements?                                 	  	
                                                                     Yes    No

 •   Quantity of borrow available?                                    	  	
                                                                     Yes    No

 •   Infiltration?                                                    	  	
                                                                     Yes    No

 *   Gas migration?                                                   	  	
                                                                     .'c3    .,O

 •   Traffic support requirements?                                    	
                                                                     Yes"    No

 *   Freeze/thaw and dry/soak  effects?                                	  	
                                                                     Yes    No

 •   Cracking?                                                        	  	
                                                                     Yes    No

 •   Differential settlement?                                         	   '
                                                                    "Yes    No

 •  Membrane protection?                                             	  	
                                                                     Yes    No

 •  Vegetative requirements?                                         	  	
                                                                     Yes    No

 Do cover placement procedures  include  an  evaluation  of:

 •  Cover composition?                                               	
                                                                     Yes"    No

 •  Internal layering?                                               	  	
                                                                     Yes    No

 •  Top soil?                                                        	  	
                                                                     Yes    No

•  Time of construction?
                                                                     Yes   "No"

•  Proposed construction techniques?                                	   	
                                                                     Yes    No

                            Figure  9.4.5  (continued).
                                       9-199
-------
Has che cover configuration been  analyzed  in terms  of




•  Erosion potential?






•  Infiltration control?







Has surface J.r-ii.iags ':~tin evaluated  for:




*  Dicch design?







»  Culvert design?







*  Gas migration?






fias the vegatative cover been evaluated  in  terms  of:




•  Soil type?






•  Nutrient and pH levels?






•  Climate?







•  Species selection?






•  Seeding time?






Post-closure




Have regular maintenance intervals been  establishd  to:




•  Identify and repair settling and  erosion  damage?






•  Maintain the vegetative cover?






•  Monitor ground water?






                            Figure 9.4.5 (continued).
Yes    No
Yes    No
Yes    No
Yes    No
Yes    No
Yes    No
Yes    No
Yes    No
Yes    No
Yes    No
Yes    No
Yes    No
                                      9-200
-------
Has a  contigency plan been astabiisnea  :D  pr-^-i-ia f-r:

•   Erosion damage  repair?	   •   	
                                                             Yes           No"
•   Vegetation  repair?                                     	
                                                             Yes           No~
•   Drainage  renovation?                                   	
                                                             YesNo"
•   Cover deterioration repair?                            	
                                                             YesNo"
                           Figure 9.4.5 (continued),
                                     9-201
-------
     Land Disposal:   Hazardous Wasce, Proceedings of the Seventh Annual
     Research Symposium (Philadelphia,  Pennsylvania, March 16-18, 1981),
     EPA-600/9-81-002b, U.S. EPA,  MERL/CINN,  March 1981.

 3.   Land Disposal of Hazardous Waste,  Proceedings of the Eighth Annual
     Research Symposium (Ft. Mitchell,  Kentucky-March 8-10, 1982),
     EPA-600/9-82-002,  U.S.  EPA, MERL/CINN, March 1982.

 9.   Fifth Annual Madison Conference of Aopliad ".esearcr. and Practice on
     Municipal ana Industrial Waste, September 22-24, 1982, (Proceedings),
     Sponsored by the Department of Engineering and Applied Science,
     University of Wisconsin-Extension, Madison, WI.
10,   Wesron r^si^nsrj/CotisuiCdncs.  "Containment" Strategies to Manage
     Abandoned Hazardous Waste Sites in a Cost Effective Manner.  Paper
     presented at the Fifth Annual Madison Conference (see Reference 3).

11.   Lutton,  R. J., et al., "Case Study of Repairing Eroded Landfill Cover"

12.   RogoshewsKi, P. J. and R. 3. Wetzel, "Handbook for Remedial Actions at
     Waste Disoosal Sites."
                                    9-202
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 9.5  HANDLING AiNO DISPOSAL OF  IGNITABLE OR REACTIVE PASTES

 9.5.1  The Federal Requirements

     Paragraph (f) of §270.21  requires the following  information in Che permit
 application:

               "If ignitable or reactive wastes will oe landfilled, *n
          explanation of how f.be standards of 5254.312 viil oe complied vith."

 The Part 264 standards to be supported are the special requirements of
 §264.312, which state:

                '(a; Except as provided in paragraph (b) of this section, and
          in §264.316, ignitable or reactive waste must not be placed in a
          landfill, unless the waste is treated,  rendered, or mixed before or
          immediately after placement in a landfill so that:
               (1) The resulting waste, mixture,  or dissolution of material no
          longer meets the definition of Ignitabla or reactive waste under
          }§261.21 or 261.23 of this Chapter; and
               (2) Sec'ion 264.27(b) is complied  with.
               (b) Ignitable wastes in containers may be landfilled without
          meeting the requirements of paragraph (a) of 'this section, provided
          that the wastes are disposed of in such a way that  they are
          protected from any material or conditions which may cause them to
          ignite.  At a minimum, ignitable wastes must be disposed of in
          nonleaking containers which *re carefully handled and placed so as
          to avoid heat, sparks, rupture, or any  other condition that might
          cause ignition of the wastas; must be covered daily with soil or
          other noncombustible material to minimize the potential for ignition
          of the wastes; and must not be disposed of in cells that contain or
          will contain other wastes which may generate heat sufficient to
          cause ignition of the waste."

The referenced §264.17(b) requirements stipulate  that:

               "(b) Where specifically required by other Sections of this
          Part,  the owner or operator of a facility that treats,  stores or
          disposes ignitable or reactive waste, or mixes incompatible  waste or
          incompatible wastes and other materials,  must take  precautions to
          prevent reactions which:
               (1) Generate extreme heat or pressure,  fire or explosions,  or
        .  violent reactions;
               (2) Produce uncontrolled toxic mists,  fumes, dusts,  or  gases in
          sufficient quantities to threaten human health or che environment;
               (3) Produce uncontrolled flammable fumes or gases  in sufficient
          quantities to pose a risk of fire or explosions;
               (4) Damage the structural  integrity of  the  device  or facility;
               (5) Through other like means threaten human health or the
          environment."
                                    9-203
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9.5-2  Summary ;f "ecassary .-ippncacion Inrorrnacion

     The Part 3 Permit Applicants' Manual^- requires the applicant Co submit
information according to two optional requirements, as follows:

     •    Option 1       a description of the methods of treating ignitable or
                         reactive wastes before or immediately after placement
                         in the landfill,
                         results of field or laboratory tasting _Lljscrating
                         ;hat tne wastes will be rendered nonreactive or
                         nonignitable, and
                         a description of how §264.17(5) will be complied with.

     •    °T:;cn 2 'jpeiieaoie only co ignicaole wa^.es in containers)

                         a description of how ignitable wastes disposed of in
                         containers will be protected from materials or
                         conditions which could cause them to ignite,
                         including handling procedures, daily cover
                         characteristics,  and characteristics of other wastes
                         placed in the same cell.

     The documentation provided should be based on scientific and engineering
literature, pilot or bench scale tests, waste analyses, or the results of
similar treatment based on experience or case histories.

9.5.3  Guidance on Evaluating Application Information

9-5.3.1  Regulatory Applicability and Intent—
     Figure 9.5.1 is a summary of applicable regulations that the applicant
must address if he plans to handle and dispose of ignitable or reactive wastes.

     The requirements of §264.312 reflect  the interim status standards
(§265.312) for ignitable and reactive wastes.  The interim status standards
(§265.312) and the permitting standards (§264.312) for ignitable and reactive
wastes have been discussed in the preambles of several Federal Register
Notices.  The following Moticas contain applicable information..

  Federal Register Notice

    Date	Page    Vol.                                   Section Affected
19 May 1980    33162    45                                    §265.17
19 May 1980    33182    45                                    §265.17
19 May 1980    33213    45                                    §265.312
12 Jan 1981     2809    46                                    §264.17 & §265.17
 5 Feb 1981    11148    46                                    §264.312
20 Feb 1981    13492    46                                    §265.312
29 Jun 1981    33507    46                                    §265.312
17 Nov 1981    56592    46                                    §265.312
25 Feb 1982     8304    47                                    §265.312
26 Jul 1982    32331    47                                    §264.312
26 Jul 1982    32333    47                                    §265.312
                                    9-204
-------
             ARE IGNITABLE OR REACTIVE
       WASTES TO BE PLACED IN THE LANDFILL?
                    YES
           WILL THE WASTES SE DISPOSED
                OF  IN  CONTAINERS?
                                V'ES
    WILL THE WASTES 3E
IGNITABLE OR REACTIVE AFTER
PLACEMENT IN THE LANDFILL?
                      YES
                              APPLICABLE
                              REGULATIONS
                             HAVE NOT SEEN
                               ADDRESSED
  ARE THE PRECAUTIONS OF
    §264.I 7(b)  COMPLIED
           WITH?
               YES
    IS DOCUMENTATION OF
   =264.I7(b)  COMPLIANCE
         PROVIDED?
                        DO THE DISPOSAL CONTAINERS
                          AND DISPOSAL PROCEDURES
                         COMPLY WITH §264.312(fa)?
                                 NO
  YES
                                       APPLICABLE.
                                       REGULATIONS
                                        HAVE BEEN
                                        ADDRESSED
                        00 THE DISPOSAL CONTAINERS
                        AND PROCEDURES COMPLY WITH
                                 3264.316?
                            NO
YES
               YES
                                     APPLICABLE.
                                     REGULATIONS \>
                                      HAVE BEEN  ^X
                                      ADDRESSED
        APPLICABLE
    /REGULATIONS
    N.  HAVE BEE
      ^ADDRESSED
         Figure 9.5.1.
Applicability of regulations to handling and disposal
of ignitable and reactive wastes.
                                    9-205
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     The following Notices contain preamble discussions of §261.21 and
§251.23.  rheae sections of 40 CFR Part 261 identify criteria for ignitable
and reactive wastes.

  Federal Register Notice

    Date	Page	Vo 1.                                   Section Affected
I
i.
9
9
9
7
May
Jul
3.3.1
1930
1981
. 1 Are

5 ., L J i
33109
35246
ignitable
*•» .y
45
46
or reactive wastes
§
§
§
Co be placed in Che
261.21
261.23
251.21
landfill?~If
an applicant provides information that none of the wastes intended for disposal
in the landfill are reactive or ignitable, this section is not applicable.
Information that would be acceptable includes the results of tests or analyses
conducted on the wastes by the landfill owner/operator or the waste
generator.  Documentation based on scientific or engineering literature may
also be acceptable.  If the applicant has demonstrated chat all wastes are
neither ignitable or reactive, Che permit writer must indicate in the permit
that ignitable or reactive wastes are not permitted for receipt or disposal at
the landfill.

     The characteristic of ignitability is exhibited by a solid waste if it
has any of Che four properties listed in §261.21(a).  Specifically,
!251. 21 (a) (L; addresses liquids, § 261 .-2-Ka) (2) addresses nonliquids,
S261.21(a)(3) addresses compressed gas*s, and §261.21(a)(4) addresses
oxidizars.  The provisions of § 261.21(a)(1) identify three ASTM standard
methods that can be used to determine ignitability.  They are:

     •    ASTM Standard D-93-79

     •    ASTM Standard D-93-80

     •    ASTM Standard D-3278-73

These methods are also described in Section 2.1.1 of "Test Methods for
Evaluating Solid Waste-Physical/Cheraical Methods" (July 1982) Second Edition,
SW-8462 along with methods for ignitable compressed gases and oxidizers.

     The characteristic of reactivity is exhibited by a solid waste if it has
any of the eight properties listed in §261.23(a).  Those properties are based
largely on the definition employed by the National Fire Protection
Association.  The NFPA's headquarters are in Batterymarch Park, Quincy, MA and
there is also a Washington, D.C. Office.  Telephone numbers are:

     General and Executive         (617) 328-9290

     Publicaton Sales              (617) 770-3002

     Washington, D.C. Office       (202) 484-8200
                                    9-206
-------
 Secailea  information on  identification  and  casting  of  reactive wastes  is
 provided  in  Section 2.1.3 of  SW-346.

      In addition  to using the methods referenced  in  the  regulations, the
 permit applicant  may use other methods  to determine  ignitability  or  reactivity
 if he has petitioned and received approval  from the  Administrator, as  allowed
 under §260.20 and  §260.21.  If the permit reviewer encounters methodologies
 whose acceptability cannot be determined, SW-346  suggests contacting the
 Manager, Waste Analysis  Program  'WH-'^S/, Wasce Jljaraccenzation  Branch,
 Office of so Lid Waste, Washington, D.C. 20460 (202)  755-9137 for  assistance.

 9.5-3.1.2  Will ignitable or  reactive wastes be treated  before or immediate1.-'
 after disposal?—There are two "eaui.-emantc  In J254.312va; regarding disposal
 if i^nitaali or reactive wastes  in landfills.  First,  the ignitable or
 reactive waste -ust be treated,  rendered, or mixed before or immediately after
 placement in the  landfill so  that the resulting waste, mixture, or dissolution
 of material  is ao  longer ignitable or reactive.   Second, the provisions of
 §264.17(b) must be complied with.

     To satisfy :he requirement  of §264.312(a), the  landfill permit applicant
 must document in  the permit application,that the materials and procedures
 employed at  the landfill, either before or  immediately after waste disposal,
 will be such that  the waste will no longer meet the definitions of ignitable
 or reactive, as specified in  Part 261.

 9.5.3.1.3  Are the precautions of §264.17(b) complied with?—If the
 owner/operator proooses to treat i^nic-srble and/or reactive wastes, he raus't
 comply with  §264.i7(b) of Subpart B of  Part 264.  This stipulation requires
 the owner to "take precautions to prevent reactions wnich...threaten human
 health or the environment."  There are  four specific types of reactions listed
 in §264.17(b) which must be prevented? as listed in subsection 9.5.1.

 9.5.3.1.4  Is documentation of compliance with §264.17(b) provided?—
 Documentation that the precautions of §264.17(b) will be effective is required
 by §264.l7(c), as  follows:

               "When required to comply with paragraphs  (a) or (b) of this
          Section, the owner or operator must document that compliance.  This
          documentation may be based on references to published scientific or
          engineering literature, data from trial  tests  (e.g.,  bench scale or
          pilot scale tests),  waste analyses (as specified in §264.13), or the
          results of the treatment of similar wastes by similar treatment
          processes and under similar operating conditions."

 The owner or operator of a  landfill who is treating ignitabla or reactive
wastes must document that the treatment employed will not itself be
hazardous.  The permit application may be judged dificient if the required
documentation is not submitted or if it is judged  to be inadequate.
                                    9-207
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9.5.3.1.5  Will containers of ignitable wastes be disposed of, and if so,
disposed of in compliance with §264.312(b)?—Section 264.312(b) allows
landfilling of containerized ignitable waste if:

     •    the containers are not leaking,

     •    container handling and placement will avoid heat, sparks, rupture,
          and ignition of the waste,

     •    the containers are covered daily with noncorabustible material, and

     *    the containers are not placed in landfill cells that do or vill
          'or.t^in vasras thac generate aeac sufficient to cause ignition of
          the ignitable waste.

     Note that §264.312(b) applies only to ignitable wastes in containers.   A
permit application which proposes to dispose of containerized reactive wastes
under §264.312(b) should be judged inadequate.  Reactive wastes may be
disposed of in lab packs under cartain circumstances consistent with the
requirements of §264.316(e), as discussed below.  Otherwise,  such wastes must
be rendered nonreactive and disposed of in accordance with §264.312(a).

9.5.3.1.6  Do containers and handling procedures comply with §264.316(e)?—
Paragraphs (a)through(d) of §264.316 deal with the disposal of any hazardous
waste at landfills when the waste is in small containers in overpacked drums
(lab packs).  The requirements of those paragraphs and the related §264.315
requirements are discussed in subsectian 9.8.  However, the requirements of
paragraph (e) of §264.316 are applicable to reactive wastes in containers,  as
follows:

     •    for other than cyanide- and sulfide-bearing wastes,* the waste must
          be treated or rendered nonreactive before containerization in lab
          packs, or

     •    for cyanide- and aulfide-bearing wastes, the wastes can be
          containerized in lab packs without being treated or rendered
          nonreactive.

Thus, for all reactive wastes that are not cyanide- or sulfide-bearing, the
waste must be treated or rendered nonreactive before it can be placed in a
landfill, regardless of whether it is in a lab pack.  However, cyanide- and
sulfide-bearing reactive wastes in lab packs can be landfilled without being
treated or rendered nonreactive, but only if the containerization complies
with paragraphs (a) through (d) of §264.316 for lab packs, as discussed in
subsection 9.3.
*Cyanide- and sulfide-bearing wastes are defined in §261.23(a)(5) of Subpart C
 of Part 261.
                                    9-208
-------
     The firsc requirement of §264.316(e) mandates that the reactive wastes
(other than cyanide- and sulfide-bearing) oe treated or rendered nonreactive
before concainerization in lab packs.  This activity will typically be
conducted by the generator and not by the owner or operator of a landfill.   In
these cases, the permit application should incorporate documented assurances
from the generator to the landfill owner or operator that the noncyanide- and
nonsulfide-bearing reactive wastes have been rendered nonreactive before lab
pack containerization.  The documentation should contain details of the
materials and procedures chat vill ba -nployeci jy cne generator.

     In some cases, even cyanide- and sulfide-bearing reactive wastes may be
rendered nonreactive by the generator before containerization in lab oacks.
It is recommended chat the ~er~it: -^vi^wer raquesc documentation which
indicates cne procedures employed to transform the cyanide- or sulfide-bearing
wastes.

9.5.3.1.7  Summary

     The listing below is a summary of the key points which the owner/operator
raus:: address to comply with the regulations governing the disposal of
ignitable and reactive wastes in landfills.

     •    Demonstrate whether the wastes to be placed in a landfill are
          ignitable or reactive.

     •    Document treatment methods to render the waste nonignitable or
          nonreactive.

     •    Document that procedures for handling and disposal of ignitable and
          reactive wastes are adequate to prevent harm to humans and the
          environment.

     •    If the owner/operator does not intend to render ignitable wastes
          nonignitable, then he must stipulate that the waste will be
          containerized in nonleaking containers and disposed of in a manner
          that will avoid ignition or reaction of the wastes.

     •    If reactive wastes are to be disposed of in lab packs, the
          owner/operator must demonstrate that the waste will be rendered
          nonreactive before containerizacion in lab packs unless the wastes
          are cyanide- and sulfide-bearing reactive wastes.

9.5.3.2  Evaluation of the Technical Adequacy of the Applicant's Subraittal—
     Figure 9.5.2 presents the major topics that are discussed in this
subsection.  The permit reviewer should first determine which of the technical
topics are applicable to the facility and operation of concern.   For instance,
if the applicant proposes to containerize ignitable wastes in conformance with
the requirements of §264.312(b), then the discussion about treating,
rendering,  or mixing the waste so that it is no longer ignitable or reactive
does not apply.   If any applicable topics are not adequately addressed by the
applicant,  the application and the proposed disposal methods may be
technically deficient.
                                    9-209
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                                IGNITABLE OR
                               REACTIVE WASTE
METHODS TO TREAT, RENDER
OR MIX THE WASTE SO THAT
     IT IS NO LONGER
  IGN)TABLE OR REACTIVE
               LISTS OF
              IGNITABLE AND
            REACTIVE WASTE
CONTAINERIZED
  IGNI TABLE
   WASTES
        TEST FOR
      COMPATIBILITY
                                        NONLEAKING
                                        CONTAINERS
    TEST TO DETERMINE  •
    WASTES ARE IGNITABLE
       OR REACTIVE
                                     CAREFULLY HANDLE  •
                                   CONTAINERS TO PREVENT
                                         IGNITION
                                                           COVER DAILY
                                                         SEGREGATE FROM
                                                         HEAT GENERATING
                                                             WASTES
    Figure 9.5.2.
Flow diagram for evaluating the technical  adequacy of  the
application for disposal of ignitable or reactive waste.
                                      9-210
-------
 9.5.3.2-i.   Listj  ; f  IgnJCdoia  ana  Reactive  Wastes — In  Part  261,  Subpart  D  -
 Liscs  of Hazardous Wastes,  ignicable wastes  are  identified  by  an "(I)" and
 reactive wastes are  identified with an  "(R)".  Table 9.5.1  lists the  hazardous
 wastes, by  EPA Hazardous Waste Number,  which are identified in Subparc D as
 being  ignitable.  Table 9.5.2  lists the hazardous wastes, by EPA Hazardous
 Waste  Number, which  are identified in Subpart  D as being  reactive.  At a
 minimum, if the applicant  indicates that any of  these  wastes will  be  disposed
 in a landfill, he must document how compliance with §264.312 will  be  achieved.

     The oermit ravi-wer snouia rerer to EPA-600/2-80-076,  A Method for
 Determining the Compatibility  of Hazardous Wastes (Reference 3), which
 provides a  list of 174 chemicals which  are extremely reactive.   If these
 "extremely  reactive" compounds are mixed with water or -wast  other  compounds,
 heat may be ^eneratad. ;r  .s:;iw a»iu/or.  riaramable gases may  be  produced.  In
 addition, explosions may occur, or highly unstable mixtures  may  result.

     If the following materials are mixed with water,  flammable  gas will be
 generated:

     9    Metals, such 93  sodium and potassium
     •    Sulfides, Inorganic

     •    Strong Reducing Agents

     Refaranca 3 ai^o provides a list -of materials which are combustible and
flammable and a list of materials which are explosive.  A worksheet for
determining the adequacy of the applicant's information on identification of
ignitable and reactive waste is presented in Figure 9.5.3.

9.5.3.2.2  Methods to Treat, Render, or Mix Waste so that it is no longer
Ignitable or Reactive — There are a number of methods available to treat,
render, or mix wastes so that they are no longer ignitable or reactive.
Several treatment processes which previously were only used in the organic or
inorganic chemical industry are being considered for broader application in
the treatment of hazardous waste.  Over 50 processes have been demonstrated to
be applicable to hazardous waste treatment, although the technical and
economic feasibility of a number of these processes has not been demonstrated
on a commercial scale.  JRB has identified several of the most promising
nonbiological treatment methods along with general information regarding feed
stream requirements, output streams, and the current state of technology .4~9
An overview of these technologies is presented in Table 9.5.3 (after
Reference 4).  The applicant may propose to employ one or a combination of
these methods to treat igni'ible or reactive wastes.

     The applicant may propose to render ignitable or reactive compounds
nonignitable or nonreactive by diluting the waste with other compatible
material.   However,  dilution has the disadvantage that hazardous reactions may
result if the mixed materials are incompatible.  Dilution with liquids is
undesirable because of added liquids in the landfill and greater attendant
                                    9-211
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              TABLE 9.5.1.  IGNITABLE WASTES
EPA hazardous
  waste No.
             Hazardous waste
    F005
    U001

    U002
    U003
    U008
    uci:
    U012
    U019
    LT239
    U056
    J055
    U169
    U085
    U031
    U159
    U074
    U031
    U156
    U055
    U056
    U057
    U074
    U085
    U092
    U110
Spent ncnnaiogeriatea solvents
Spent nonhalogenated solvents
Acetaldehyde
Acetic acid, ethyl ester
Acetone
Acatonitrile
Acrylic acid
Aniline
Benzenamine
Benzene
Benzene, dimethyl-
Benzene, hexahydro-
Benzene, -C-l-me thylethyl),
Benzene, -nitro-
2,2-bioxlzane
c-butanoi
2-butanone
2-butene, 1,4-dichloro-
n-butyl alcohol
Carbonochloridic acid, methyl ester
Cunmene
Cyclohexane
Cyclohexanone
1,4-dichloro-2-butene
1,2:3,4-diepoxybutane
Dimethylamine
Dipropylamine
                         (continued)
                            9-212
-------
                   TABLE  9.5.1  (continued)
EPA hazardous
  waste No.
              Hazardous  waste
    U001
    U008
    U117
    U112
    U113
    U115
    UL17
    U125
    U213
    U125
    U124
    U140
    U152
    U092
    U045
    U153
    U154
    U154
    U186
    U045
    U156
    U159
    U161
    U162
    U161
    U169
    U171
 Ethanol
 Ethanenitrile
 dC.i^ns.  - ? j. ~ o x ~ T o i ^
 EChyl acetate
 Ethyl acrylate
 Ethylene oxide
 Ethyl ether
 2-furancarboxaldehyde
 Furan, tetrahydro-
 Furtura1
 Furfuran
 Isobutyl alcohol
 Methacrytonitrile
 Methanamid-e, N-methyl
 Methane,  chloro-
Methanethiol
 Mechanol
Mechyl alcohol
 1-tnethyl  butadiene
Mechyl chloride
Methyl chlorocarbonate
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
 4-methyl-2-pentanone
Nitrobenzene
 2-nitropropane
                        (continued)
                            9-213
-------
                   7A3LZ 9. j . i
EPA hazardous
  waste No.
                               nazaraous waste
    U115
    (J186
    U110
    U171
    U140
    J002
    U152
    U008
    U113
    U162
    U213
    (J153
    U239
Oxirane
1,3-pentadiene
1-propanamine
1-propanaraine
Propane, 2-nitro
1-propanoL, 2—mechyl
2-propanone
2-propenenicri le, 2
2-propenoic acid
2-propenoic acid, ethyl ester
2-propenoic acid, 2-methyl-, methyl ester
n-propylamine
Tetrahydrofuran
Thioraethanol
Xylene
                              9-214
-------
                          TABLE 9.5.2.   REACTIVE WASTES
EPA hazardous
  waste No.
                   Hazardous waste
    FOG:

    F008

    JCG9

    F010

    F011

    KG 11

    K013

    K027



    £044



    K045



    K047

    P009

    P065

    P112

    P081

    P009

    P112

    PI 12
Spent cyanide plating bath solutions  ...

Plating bath sludges  ...

jpenc stripping and cleaning bath solutions  ...

Quenching bath sludge ...

Spent cyanide solutions  from salt bath  ...

3otCom stream rrom wastewater ... aerylonitri le

Bottom stream from the acetonitrile column  ...

Centrifuge and distillation residues  from toluene

  diisocyanate production

Wastewater treatment sludges from the manufacturing  and

  processing of explosives

Spent carbon from the treatment of wastewater containing

  explosives

Pink/red water from TNT operations

Ammonium picrate

Mercury fulminate

Methane,  tetranitro-

Nitroglycerine

Phenol,  2,4,6-trinitro-, ammonium salt

Te tra ni trome thane

Zinc phosphide
                                  (continued)
                                       9-215
-------
                             TABLE  9.5.2 (continued)
EPA hazardous
  wa s C e No.
                   Hazardous waste
    U006

    U223

    U020

    U023

    U024

    U023

    U160

    U033

    U033

    U133

    Q096

    U006

    U133

    U086

    U189

    U205

    U189

    U205

    U223

    U234
Acetyl chloride

Benzene, 1,3-diisocyanatomechvl

Benzenesulfonyl chloride

Benzene, (trichloromechy1)

Benzene, 1,3,5-trinitro-

Benzotrichloride

2-butanone peroxide

Carbon oxyfluoride

Carbonyl fluoride

Examine

Alpha, alpha-dimethylbenzylhydroperoxide

Ethynol chloride

Hydrazine

Hydroperoxide, 1-me thy1-1-phenyethyl-

Phosphorous sulfide

Selenium disulfide

Sulfur phosphide

Sulfur selenide

Toluene diisocyanate

Sym-trinitrobenzene
                                        9-216
-------
              HANDLING AND DISPOSAL OF IGNITABLE OR REACTIVE WASTES
Has this part of the applicant's subraittal been read and           	 	
evaluated?                                                           Yes     ;io
Did the applicant identify any wastes as being hazardous or        	 	
                                                                     Yes     No
Are chere any additional wastes listed in subsection 9.1 which     	 	
are ignitable or reactive according to Tables 9.5.1 and 9.5.2?      Yes     No
       Figure 9.5.3.  Worksheet for evaluating the applicant's subtnittal
                      on ignitable and reactive waste identification.
                                    9-217
-------














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                                                   9-220
-------
leachace generation.  If other than a small quantity of waste requires
dilution, an alternative treatment process should be selected Co minimize tha
landfilling of liquids.

     The reviewer should consider incineration as an alternative to  the
disposal of ignitable or reactive wastes.  Incineration is particularly
applicable Co ignitable materials since wastes containing solvents and other
organic materials are easily incinerated.  Incineration reduces waste volume
so that :he remaining Tuicanal xi.i± require ^ess space when disposed of at a
landfill.  Incineration may reduce the potential for groundwater contamination
from the ash compared to that associated with disposing of the parent waste.

     There are i number if a.ata jourcaa «nicn ,tiay assist the reviewer in
evaluating an applicant's,proposed method of waste treatment, including
References 10 through 18 which are listed in subsection 9.5.5.  Chapters 8
and 9 of MeCry (Reference 10) list an additional 200 references on physical
and chemical treatment of hazardous waste.

9-5.3.2.3  Test for Compatibility--Referenca 3 (Hatayaraa at aI.,
EPA-600/2-80-076, April 1980) addresses hazardous waste compatibility and
incorporates a hazardous  waste compatibility chart (see subsection 9.7 of this
manual) which illustrates the compatibility of 41 binary combinations of
hazardous chemical wastes.   The reason for incompatibility is noted  for each
combination.  Acurex is developing a test kit to assist in categorizing
unKnown wastes into one of these 41 reactivity groups.^9  Although most
applicable to distinguishing and handling otherwise unknown wastes at
Superfund si:as,  tne technique may also oe of value in managing wastes at RCRA
facilities.

9.5.3.2.4  Testing of Ignitable and Reactive Waste—If treatment will be used
to render wastes  nonignitable or nonraactive and the wastes will then be
handled without special consideration for ignitaoility or reactivity, the
applicant must test or document by some other means that the waste is truly no
longer ignitable  or reactive.  If testing is to be e^oloyed, the applicant
must specify what testing procedures he will use.  Available methods to test
for ignitability  are set  forth in §261.21.  Two test methods are acceptable
for determining the flashpoint:  Pensky-Martens Closed Cup Tester using the
test method specified in  ASTM standard D-93-79 or D-93-80,  or a Steaflash
Closed Cup Tester, using  the test method specified in ASTM Standard
D-3278-78.  These procedures are documented in Test Methods for Evaluating
Solid Waste  (SW-346).2

     To test if a treated waste has the characteristics of reactivity,  the
applicant should  base his demonstration on tests for:  water reactivity,
flashpoint/flammability,  oxidation/reduction potential, pH,  and the presence
of cyanide or sulfide.  The testing procedures employed should conform with
the ASTM standards and test methods incorporated in SW-846.2

     A worksheet  for determining the adequacy of he applicant's  submittal  on
ignitable and reactive waste treatment is presented in Figure 9.5.4.
                                    9-221
-------
                   TREATMENT OF IGNlTAdLE OR .^ACTIVE BASTES
Are treatment procedures conducted prior  to or  immediately
following placement in the landfill?                                 YesNo


Are treatment processes consistent with those described In cais
subsection and cited references?                                     YesNo
During treatment operations, are orecautions ".aken  -o prsvent:

     •  Extreme heat or pressure, fire or explosions,              	 	
        or violent reactions?                                       Yes     No
     •  Uncontrolled toxic -aists, fumes, dusts, or gases?          	 	
                                                                    Yes     No
     •  Uncontrolled flammable fumes or gases?                     	 	
                                                                     Yes     No
        Damage to the structural integrity of the device           	 	
        or facility?                                                Yes     No
Has the applicant specified a test pracedure for ensuring          	 	
that treated wastes are nonreactive or nonignitable?                Yes     No
      Figure 9.5.4.   Worksheet for evaluating ignitable and reactive waste
                     treatment procedures-
                                     9-222
-------
 9,5.3.2.5  Containerized Ignitaole Waste—Rather than treat, render, or mix an
 ignitable waste so that it is no longer ignicable,  :he applicant may propose
 co landfill ignicabla waste in containers.  However,  improper handling of
 ignicable wastes in containers could result in fire or explosion.   Containers
 should be handled with nonsparking tools and equipment.   The applicant should
 specify the safety pro-^dures that will be employed when handling ignitable
 wastes.  When disposing of ignitable wastes in containers,  the reviewer must
.evaluate the application for compliance with §264.314.  This standard requires
 chat containers placed in a landfill must be greater than 90 percent full.  if
 such containers are ±asa cnan 90 percent full and fillers will be used, the
 permit reviewer should assure that the fillers are  nonreactive and request
 supporting documentation, if necesary.  Further discussion of fillers is
 provided in subsection 9.7 of this manual.

      When disposing of ignitable wastes in containers, the reviewer must also
 evaluate the application for compliance with §264.314(b)(1).  This standard
 requires that "free liquids" be removed prior co placement of containerized
 wasce in a landfill if che landfill is not equipped with a liner and leachate
 collection and recovery system.  The reviewer should refer to Section 8 of
 this document which discusses methods co remove "free liquids" from
 containerized waste.

      The applicant should specify the types of containers which will be
 employed to dispose of ignicable or reactive wastes.   The containers should be
 in good condition (e.g., no apparent rusting or structural  defects).  The
 permit reviewer may elect co require that all containers meet the container
 requirements of che Department of Transportation Regulations ^.Suopart D -
 Specifications for Metal Barrels, Drum*, Kegs,  Cases,  Trunks, and  Soxes).

 9.5-3.2.6  Nonlaaking Containers—The applicant must  demonstrate how he will
 check to determine chac all containers are in good  condition.  Inspection
 procedures Co be conducted prior to container burial  should be documented in
 che application.  If any containers are found to be leaking,  the waste must be
 reconcainerized or removed and treated to be rendered nonignitable or
 nonreactive.

      Rather Chan open a damaged container and transfer the  concents to a
 container in good condition,  it may be advisable for  Che operator  to place the
 damaged container inside an overpacked drum.   If a  void  space exists between
 the over pack and damaged container,  the space  should  be filled so Chat the
 over pack is at least 90 percent full.   To fill che void space, the applicant
 should employ a compatible absorbent material.   Subsection  9.7 of  this
 document presents further discussion of applicable  fillers  and absorbents.

 9.5.3.2.7  Carefully Handle Containers co Prevent Ignition—The applicant  must
 specify container handling methods co avoid heat, sparks,  rupture, or any
 other condition that might  cause ignition of  the waste.   The  applicant should
 specify the types of container handling equipment and  tools that will be
 employed.  All tools and equipment should be  constructed of nonsparking
 materials.   For proper placement of the containers  in  che  landfill,  it is
 recommended thac a cractor  barrel grappler be employed.   Such equipment allows
                                      9-223
-------
che operator to accurately place Che container in the landfill while causing a.
minimal amount of damage to the container (a certain extent of container
dencing is allowable providing that the structural integrity if not
impaired).  Tractor barrel grappler equipment has the added advantage of
providing some distance between the operator and container.

     If containers holding ignitable waste must be opened, nonsparking remote
container opening equipment should be employed.  The applicant should soecifv
what measures will be taken if a container is in oad condition or begins to
leak during .ontainer Handling.  The best procedure is to have ready access to
compatible absorbent materials for control of spills.  Empty containers should
also be available.

9 . 5, 3 , "., q,  Daily Jover of Ignitable Waste—Containerized ignitable waste
placed  in a landfill must be covered daily with soil or other noncombustible
material  (§264.312(b)) to minimize the potential for ignition of the waste.
The applicant should clearly state the type of cover material to be employed
and the thickness of the applied daily cover.  The depth of daily cover
required  is dependent on the type of cover material employee.  For example,
for a given depth, fine grained clayey soil will seal off disposed was-te raore
effectively than a coarse grained gravely soil.  If a soil cover material is
employed, six inches is generally a sufficient depth of cover.  A manufacturer
of a foam cover material claims that 2 inches of their foam product is
equivalent to six inches of soil cover.20  (jse of such foams, however, must
be carefully considered from the standpoint of compatibility with waste
materials.

9.5.3.2.9  Segregate Containerized IgiMrtable Waste from Other Wastes which May
Generate  Heat—The applicant is required to demonstrate chat containerized
ignitable wastes will not be disposed of in cells that contain or will contain
other wastes which may generate heat sufficient to cause ignition of the
waste.   In general, ignitable wastes will have to be segregated from wastes
which may be subject to microbrial degradation or wastes which will react with
water and cause an exothermic reaction.  Either of these waste types may
produce sufficient heat to cause ignition of certain wastes.  Waste material
which may generate heat due to microbrial degradation would generally have a
high organic content.  This may preclude the co-disposal of waste material
high in organic content such as solvents, oil sludges, municipal waste and
various wastes from the organic chemical manufacturing industry.

     If an applicant proposes to place an ignitable waste in the same cell
with another waste type, it must be determined whether this other waste type
may react exothermically with water and generate sufficient heat to cause
ignition.  However, wastes which are reactive with water should not be
disposed  of in the landfill.  Section 264.312 requires that any reactive waste
be treated, rendered or mixed before or immediately after placement in a
landfill  so that the resulting waste, mixture or dissolution of material no
longer  meets the definition of ignitable of reactive waste under §261.21 or
§261.23.   Nonetheless, the reviewer should check to be certain chat any wastes
which are to be co-disposed with an ignitable waste are nonreactive.  In
Part 261, Subpart D - Lists of Hazardous Wastes, those wastes which are
reactive  are designated by an "(R)" hazard code.  Also, any waste which has an
                                    9-224
-------
EPA nazaraous waste number of D003 exhibi.es the characteristics of
reactivity.  The reviewer should cross-chack. those wastes whi.cn will be
co-disposed with an ignitable waste with the wastes in the Subpart D list
which are reactive (listed in Table 9.5.2 of this section).  However, not all
of the waste in the Subpart D list which are designated to be reactive, will
react exothermically with water.  A waste is reactive if it exhibits any of
the eight properties listed in §261.23.

     A worksheet for determining the adeauacv ?f the applicants ouomictat on
ignitaoie wastes disposed of in containers is presented in Figure 9.5.5.

9.5.4  Draft Permit Preparation
              in .ioduie XV, Condition F, the permit must specify how the
facility will handle ignitable and reactive wastes.  The condition is
implemented through reference to a permit attachment.  To be suitable for
substitution in the permit condition attachment, the submitted application
should address the following two options, where applicable:

     *    Option 1 — A description of proposed methods for treating ignitable
          or reactive waste before or i.timediataly after placement in the
          landfill.  Field and laboratory test results illustrating that the
          wastes will be rendered nonreactive and nonignitable and a
          description of precautions used to prevent dangerous reactions
          should be provided.

     •    Option 2 — (Applicable only Co containerized ignitable wastes) —
          A description of how the containerized ignitable wastes will be
          managed and protected from materials or conditions that could cause
          them to ignite.

     If the permit applicant does not adequately address disposal procedures
for reactive or ignitable  wastes, the permit writer should either write
specific conditions to implement this provision or should indicate a condition
that prohibits the disposal of reactive or ignitable wastes.

9.5.5  References

 1.  U.S. Environmental Protection Agency.  Permit Applicants'  Guidance Manual
     for Hazardous Waste Land Storage,  Treatment, and Disposal Facilities.
     Volume I.  Office of  Solid Waste.   Washington, D.C.  1983.

 2.  U.S. Environmental Protection Agency.  Test Methods for Evaluating Solid
     Waste.  Second Edition.  SW-846.  July 1982.

 3.  Hatayaraa, et. al., A  Method for Determining the Compatability of
     Hazardous Wastes.   EPA-600/2-80-076, 1980.

 4.  JRB Associates,  Inc.,  Techniques for Evaluating Environmental Processes
     Associated with the Land Disposal  of Specific Hazardous Materials,
     Volume I: Fundamentals.  EPA Contract No.  68-01-5052,  March 31,  1982.
                                    9-225
-------
              HANDLING AND DISPOSAL OF IGNITA3LE OR REACTIVE WASTES
Are inspection procedures adequate to ensure  chat containers
are in good condition prior to burial?                               Yes     No
Are acceptable procedures presented for dealing vith  leaking       	  	
containers0                                                         Yes     No


Are container handling procedures and equipment designs            	  	
adequate Co a''ol,i hsac, jpar^o, ruptures, and ignition              Yes     No
of the waste?
Did the applicant document the characteristics and depth           	  	
of the daily cover material?                                        Yes    Mo


Are containerized ignitaole wastes segregated from wastes          	
which could generate heat?                                .          Yes    No
          Figure 9.5.5.  Worksheet for evaluating disposal procedures
                         for containerized ignitable wastes.
                                     9-226
-------
                     'Jnit Operations for Treatment or Hazardous  Industrie.-
     Wastes.  Noyes Data Corp.  1973.

 6.  Schalic, L. and G. Staples.  Fostering Industrial  Innovative Technology
     to Actain Agency Goals:  Technological Opportunities, Volume II,  Prepared
     for Office of Research and Development, U.S. Environmental  Protection
     Agency.  Science Applications,  Inc., (SAI-0/2-80-523-LJ).   1980.

 7.  Pytlewski, L. L., et al.  The Reaction of PCBs with Sodium, Oxygen,  and
     Polyethylene SI/col.   In:  Proceedings of the Sixth Annual  Research
     Symposium on Treatment of Hazardous Wastes, March  17-20, 1980.  Chicago,
     Illinois.  U.S. EPA—Municipal Environmental Research Laboratory.
     EPA-600/9-80-011.

 8.  Edward, B. H., et al.  Emerging Technologies for the Destruction  of
     Hazardous Waste.  Ultraviolet/Ozone Destruction.   In:  Proceedings of the
     Seventh Annual Research Symposium on Land Disposal of Hazardous Wastes.
     Philadelphia.  U.S. EPA—Municipal Environmental Research Laboratory.
     (EPA-600/9-81-002b).   1981.

 9.  Miller, R. A., et al.  Evaluation of Catalytic Wet Oxidation for
     Treatment of Hazardous Wastes.  In:  Proceedings of Seventh Annual
     Research Symposium on Land Disposal of Hazardous Wastes.  Philadelphia.
     U.S. EPA—Municipal Environmental Research Laboratory.
     (EPA-600/9-31-002b).   1981.

10.  Metry, Amir, A., The Handbook of Hazardous Waste Management.  Tacnnomic
     °ublishing Company, Inc., Westpor-t, CT. ,  1980.

11.  TRW Systems, Inc. Recommended Methods of Reduction, Neutralization,
     Recovery, or Disposal of Hazardous Waste.  Volume  I-XVI.  U.S.
     Environmental Protection Agency, Washington, D.C., 1973.

12.  £PA-600/2-82-001c, Treatability Manual.  Volumes I-IV.  U.S.
     Environmental Protection Agency, Washington, D.C., Sept. 1981.

13.  Battelle Memorial Institute.   Program for the Management of Hazardous
     Waste.  Volumes 1 and 2.  U.S. Environmental Protection Agency, Office of
     Solid Waste Management Programs.  Washington, D.C., 1974.

14.  Booz-Allen Applied Research,  Inc.   A Study of Hazardous Effects and
     Disposal Methods.  U.S. Environmental Protection Agency.  Cincinnati, OH,
     1972.

15.  Bretherick,  L., Handbook of Reactive Chemical Hazards.  CRL Press, Inc.,
     Cleveland,  OH,  1975.

16.  Fire Protection Guide on Hazardous Materials.  Sixth Edition.   National
     Fire Protection Association,  Boston, Massachusetts, 1975.

17.  Nemerow, N.L.,  Liquid Waste of Industry:  Theories,  Practice, and
     Treatment.   Addison-Wesley Publishing Co.,  Reading, MA.   1972.
                                    9-227
-------
18.  Toxic and Hazardous Industrial Chemicals Safety Manual for Handling and
     Disposal, with Toxicity and liazard Data.  The International Technical
     Infonnacion Institute, Torahotnon-Tachikawa 31dg. 6-5, 1 Chome,
     Nishi-Shimbashi, Minato-KW, Tokyo, Japan, 1975.

19.  Wolbach, C. D., U. Spannagel, and R. Whitney.  Field Scheme for
     Determination of Waste Reactivity Groups.  Prepared by Acurex Corporation
     for the U.S. Environmental Protection Agency.  Presented in the
     Proceedings of the Ninth Annual Researcn Symposium—Land Disposal,
     Incineration, and Treatment of Hazardous Waste.  Fort Mitchell,
     Kentucky.  May 1983.

20.  Sanifoam, Inc., Product Information, IJ7G ^ogan Avenue, Suite D, Costa
     Mesa, California, 92626, (714) 557-5070.
                                     9-228
-------
 9.6   SPECIAL REQUIREMENTS  FOR  INCOMPATIBLE  WASTES

 9.6-1   The  Federal Requirement

      The  information requirements of  S270.21(g) specify  chat:

          "If  incompatible wastes, or  incompatible wastes and materials will
      be landfilled, an explanation of  how §264.313 will  be  complied with
      be submitted]."

      Special requirements  for incompatible wastes are specified in §264.313,
 stating that:

           'Incompatioie wastes, or incompatible wastes and materials, (see
     Appendix  V of this part for examples) must not be placed in the same
      landfill  cell, unless §264.17(b)  is complied with."

      The  referenced requirements of §264.17(b) are:

          "Where specifically required by other Sections of chis Part, the
     owner or  operator of a facility chat treats, stores or disposes ignitable
     or reactive waste, or mixes incompatible waste or incompatible wastes and
     other materials, must take precautions to prevent reactions which:
          (1)  Generate extreme heat or pressure, fire or explosions,  or
     violent reactions;
          (2)  Produce uncontrolled toxic mists, fumes, dusts, or gases in
     sufficient quantities to threaten human health or the environment;
          (3)  Produce uncontrolled flaamable fumes or gases in sufficient
          quantities to pose a risk of fire or explosions;
          (4)  Damage the structural integrity of the device or facility;
          (5)  Through other like means threaten human health or the
     environment."

9.6.2  Summary of Necessary Application Information

     The  Part  B Permit Applicants'  Manual^- instructs the applicant to submit
documentation  including detailed plans, engineering reports, and operating
plans showing  that the standards of §264.313 or §264.17(b) will be complied
with.  The documentation may include published literature, trial tests,  waste
analyses,  or results from past experience.

9.6.3  Guidance on Evaluating Application Information

9.6.3.1  Regulatory Applicability and Intent—
     Figure 9.6.1 summarizes the regulations applicable to handling and
disposal of incompatible wastes at  landfills.

     Compliance with the provisions of §264.313 requires  the owner/operator to
indicate in the permit application  the specific steps that will  be undertaken
to identify incompatible wastes and insure segregation of those  wastes when
landfilled.   The intent of §264.313 is discussed in the preambles  of  several
Federal Register notices,  as listed below:
                                     9-229
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     WILL  INCOMPATIBLE WASTES, OR
         INCOMPATIBLE WASTES AND
      MATERIALS 8E DISPOSED OF IN
         THE  SAME  LANDFILL  CELL?
                        NO
                   j
      YES
    THE
REGULATIONS
  DO NOT
    APPLV
         ARE THE PRECAUTIONS  OF
        3264. l/(b)  COMPLIED WITH?
                        NO
                     YES
           IS DOCUMENTATION OF
          §264.17(b) COMPLIANCE
                PROVIDED?
                                          THE
                                       PLANS ARE
                                       [NADEQUATE
                        NO
                     YES
                   THE
                 PLANS ARE
                 ADEQUATE
Figure 9.6.1.
Regulations applicable Co handling and disposal of
incompatible wastes at landfills.
                            9-230
-------
          Federal  Register  Notice
Page
33162
33182
33213
2809
11148
Vol
45
45
45
46
46
      26  July
47
Sect ion Affected

§265,17

§265.17

§265.313 and Appendix V

§264.17 and Appendix V

§264.313

§264.313
     Reference is made above co pertinent preamble discussions in Part 265 to
address regulations for incompatible wastes applicable to interim status
facilities.

     There is no characteristic of incompatibility in 40 CFR Part 261.
Rather, Appendix V of Part 264 presents examples of potentially incompatible
wastes.  A definition of incompatible wastes is provided in §260.10 of
Subpart B of Part 260.  Technical references are also available that identify
incompatible waste combinations, as discussed in the following subsections.

9.6.3.1.1  Will incompatible wastes, or incompatible wastes and materials be
disposed of in the same landfill eel!?"•-!£ is the responsibility of che
landfill owner or operator Co identify vhether or not wastes are compatible.
For most commercial landfills,  the number of different wastes received will
undoubtedly result in cases of incompatibility.  For onsite landfills operated
by the waste generator or landfills receiving only a small number of different
wastes, it may be possible for the applicant to document in the permit
application that all wastes are compatible.   If it is shown thac all wastes
are compatible with each other and with other materials in the landfill,  the
permit application is adequate.

     Based on a Literal interpretation of the regulations,  only a waste that
has already been identified as  a hazardous waste can be further identified as
an incompatible waste.  The §260.10 definition states that an incompatible
waste "means a hazardous waste  which..." and Appendix V of Part 264 states
"Many hazardous wastesd, when mixed with...".  However, the intent of the
regulations is to avoid combination of incompatible wastes whether they are
initially hazardous or nonhazardous.  Therefore, all wastes must be considered.

9.6.3.1.2  Are the precautions  of §264.17(b) complied with?—There are
circumstances under which incompatible wastes could be disposed of in the same
landfill cell.   As an example,  the permit applicant could  propose to place
incompatible wastes far apart from each other in the same cell and place
wastes or materials which are mutually compatible with those wastes between
them.  If the applicant can show,  to the permit reviewer's satisfaction,  that
                                    9-231
-------
this aooroach is a precaucion ;nat .71.1.1  'prevent reactions -ni.cn. . . tnreaten
human health or Che environment," Chen ic could be judged to adequately comply
with the intent of §264.17(b).

9.6.3.1.3  Is documentation provided to demonstrate compliance with
§264.17(b)?—Documentation is required by §264.17(c) to show that the
precautions of §264.17(b) will be effective, as noted below:

          "When required to comply with paragraphs (a) or (b) of this Section,
     the owner or operator must document that ^omplianwa.  This documentation
     may oe based on references to published scientific or engineering
     literature, data from trial tests (e.g., bench scale or pilot  scale
     tests), waste analyses (as specified in §264.13), or the results of the
     treatment of similar wastes by similar treat.-ser.t .-recesses and under
     Similar operating conditions."

The owner or operator of the landfill must supply documentation that the
procedures employed will allow incompatible wastes to be disposed of safaly in
the same landfill cell.  The permit application is deficient if the required
documentation is not submitted or if it is judged to be inadequate.   If the
application indicates that incompatible wastes will not be disposed of in the
same landfill cell, then procedures to insure this must be stated.   Also, if
an application indicates that a waste will be treated so that it is no longer
incompatible when disposed of, documentation is required to show that the
process is effective and will result in compliance with §264.17(5).

9.6.3.2  Evaluation of the Technical Adequacy of the Applicant's Submittal—

9.6.3.2.1  Introduction—To augment the information on incompatible wastes
presented in Appendix V of Part 264, the permit application reviewer should
reference two additional technical reports to determine if the applicant has
correctly investigated the compatibility of the wastes to be handled.  These
documents are identified below, and a brief description of the contents of
each is provided.

     A Method for Determining the Compatibility of Hazardous Wastes
(EPA-600/2-80-076, April 1980)2 was prepared for the EPA's Municipal
Environmental Research Laboratory by researchers at the California  Department
of Health Services.  The abstract of the report states;

          "This report describes a method for determining the compatibility of
     binary combinations of hazardous wastes.  The method consists  of two main
     parts, namely:  (1) the step-by-step compatibility analysis procedures,
     and (-2) the hazardous wastes compatibility chart.  The key element in the
     use of the method is the compatibility chart.  Wastes to be combined are
     first subjected through the compatibility procedures for identification
     and classification, and the chart is used to predict the compatibility of
     the wastes on mixing.
                                    9-232
-------
          The  cnart consist-s  of 41  reactivity groups of  nazardous wastes
     designated by Reactivity Group Numbers  (RGN).  The  RGN are displayed  in
     binary combinations on the chare, and the corapatibilicy of the
     combinations are designated by Reaction Codes  (RC).

          The  method is applicable  to  four categories of wastes based on
     available compositional  information:  (1) compositions 'c aaaitionai data on the compatibility of
various chemicals wastes.

     Reference 3, Techniques  for Evaluating Environmental Processes Associated
with Land Disposal of Specific Hazardous Materials, Volume II, Incompatible
Wastes, March  31, 1982, was prepared for the EPA Office of Solid Waste by JR8
Associates,  Inc., McLean, Virginia.  This document discusses processes that
enhance pollutant migration potential  through the liquid phase in soils.
Three general  processes were  identified, including;

     •    direct solubility effects between waste constituents

     •    cnemical reactions between waste constituents which generate
          reaction products which are sore mobile than the original vaste
          constituents

     •    processes whereby waste interactions with the environment decrease
          the soil's ability  to attenuate pollutant migration.

Eighteen additional references are cited in the report.

9.6.3.2.2  Hazardous Waste Compatibility—Because many types of hazardous
wastes are extremely reactive, the compatibility of hazardous wastes to be
combined must be thoroughly evaluated.  Combining wastes which are
incompatible may result in:3  (l) heat generation, (2)  fire, (3) toxic
gases, such as HCN or t^S, (4) flammable gases,  such as H£ or C2^2>
(5) innocuous gases,  such as N2 or CC>2, which can cause container
pressurization, (6) explosion due to extremely vigorous reactions or reactions
producing enough heat to denotate unstable reactants or reaction products,
(7) violent polymerization resulting in generation of extreme heat and
flammable gases, and (8) solubilization of toxic substances including metals.
Therefore, the applicant must identify the methods he will employ for
estimating the potential consequences of mixing different classes of wastes.

     Insufficient or inaccurate information about a waste or wastes is the
primary cause of inadvertently combining incompatible wastes.   Regardless of
efforts to adequately characterize wastes  via the waste analysis plan,
properties of some wastes may change with  time and temperature, thereby
producing more or different hazardous components.3
                                    9-233
-------
     A second cause of accidents is indiscriminate handling of waste which
might encompass the following:

     •    Containers which are supposedly empty may contain incompatible
          residual wastes.

     •    Haulers may "top off" their load on the way to the disposal site.

     •    Rough handling could cause container rupture or leakage that Tiigh:
          result in consaingling of otherwise segregated incompatible wastes.

     •    Indiscriminate disposal of containerized incompatible wastes in the
          same cell could result in mixing of incompatible wastes \f
          containers Corrode 2nd Leas.

9.6.3.2.3  Determination of the Compatibility of Hazardous Wastes—As mentioned
earlier, A Method for Determining the Compatibility of Hazardous Wastes
(EPA-600/2-80-076)2 is a valuable resource document for determining the
compatibility of binary waste combinations.  The method provided in this
report consists of two main parts:  (1)  stepwise compatibility analysis
procedures, and (2) use of a hazardous waste compatibility chare.  Wastes
under consideration are first identified and classified and then the
compatibility chart is used to assess the compatibility of the wastes upon
mixing.  The remainder of this section provides background information for
employing EPA-600/2-80-076.  The five general steps necessary to determine the
compatibility of two waste types are summarized below.  Discussion of
implementation of these steps is as reported in Reference 4 by Hatayama,
et al. (EPA-600/9-30-010, March 1980).  Figure 9.6.2 summarizes the steps to
be taken to determine hazardous waste compatibility.

     Step I;  Waste Characterization

     The first step in determining the compatibility of two different waste
types is to accurately characterize the wastes.  The applicant should provide
as much information as possible about waste composition to illustrate
compliance with §264.13 (Waste Analysis Plan) and as part of the list of
hazardous wastes incorporated in the application (§270.21(a)).

     Step 2:* List Name of Compounds or Classes of Compounds or
     Generic Name of Waste

     "Starting with one waste, Waste A,  list the names of or the classes of
compounds found in the wastes, or list its generic name on the vertical axis
of the Worksheet for Determination of Hazardous Waste Compatibility
(Figure "9.6.3).  The compositon of a waste is Known Specifically when the
constituents are listed by chemical names such as ethylene glycol, sodium
nitrate, etc.  The composition is Known Nonspecifically by Classes when the
constituents are identified only by chemical classes or reactivities such as
alcohols, caustics, mercaptans, etc.  The composition is Known Nonspecifically
by Generic Name when the waste is classified as spent caustic, tanning sludge,
 -opper plating waste, etc."
                                    9-234
-------
                PROCEDURE FOR DETERMINING
              HAZARDOUS WASTE COMPATIBILITY
                         STEP  I:

                 WASTE CHARACTERIZATION
                         STEP 2:
LIST NAMES OF COMPOUNDS OR
CLASSES OF COMPOUNDS OR
GENERIC NAME OF WASTE


STEP

3:
DETERMINE REACTIVITY
GROUP NUMBERS


STEP
REPEAT STEPS
OTHER WASTES


STEP

k:
2 AND 3 FOR
OF CONCERN

5:
USING COMPATIBILITY CHART,
DETERMINE CONSEQUENCES OF
COMBINING TWO WASTES
Figure 9.6.2.
Flow diagram for assessing the compatibility of
hazardous wastes using procedures specified in
EPA-600/2-80-076.2
                            9-235
-------
       Waate A

       Waits B
                                         Source

                                         Source
       Name of  Vaste
         Evaluation
                                                   Date
Name
                  Reactivity
                  Group No.
Figure 9.6.3.  Worksheet  for  determination of hazardous waste compatibility,

               Source:  Reference 2.
                                       9-236
-------
      Step  3:*   Determine  Reactivity  Group  Numbers

      "When Che  composition of Waste  A  is Known Specifically oy chemical names,
consult  the  List of Chemical Names [in Appendix  I of  Reference Ij  Co obtain
Che Reactivity  Group Number (RGN) for each chemical constituent.   These RGNs
are then noted  on che Worksheet.  If a compound  is not on  the list, a synonym
can be found in various chemical references  (Merck,5  Hawley,6).  When a
suitable synonym cannot be found, the RGN of the component may alternatively
be determined based on its chemical  class or reaccivity.

      When che composition of Che waste is Known  Specifically by Classes,
consulc  che  LisC of Waste Constituents by Chemical Class and Reactivicv [in
Appendix II of  Reference  1. • :o decarT.ine Jhe corresponding RGN.

      When the composition of the waste is Known  Nonspecifically by Generic
Name, go to  the Industry  Index and List of Generic Names of Wastes [in
Appendix III of Reference IJ to obtain the corresponding RGN and noce it on
the worksheet."

      Step 4:*   Repeat Steps 2 and 3  for Other Waste(s) of Concern

      "Repeat Steps 2 and  3 for the second waste, Waste B, and note che
information on  the horizontal axis of the Worksheet."

      Step 5:*Using Compatibility Chart, Determine Consequences of
      Combining  Two Wastes

      "Consult the Hazardous Waste Corapscibility Chart (Figure 9.6.4) and note
the Reaction Codes (RC) between all binary combinations of RGN of Waste A and
Waste B.  If any RC corresponds to any-binary coraoination of RCN between
Wastes A and 8, Chen Wastes A and B ate incompatible and should not be mixed.

9.6.3.2.4  Limitations of the Method—Although this procedure should provide a
useful aid in determining the corapatibilicy of hazardous waste,  the method
must be used with caution because there are numerous factors which will
influence waste component reactions.   Among these are temperature, catalytic
effects of dissolved or particulate metals, soil reactions, and reactions
between the waste and surfaces it may be in contact with.3  Consequently,
the permit reviewer may elect to require the applicant to perform laboratory
compatibility analysis prior Co acCual co-disposal of wastes.   Acurex is
currencly developing a field test kit7 for categorizing unknown wastes into
the reactivity groups noted in Figure 9.6.4.  The incorporated test procedures
could b.e applicable in identifying the compatibility of poorly characterized
wastes.

     A worksheet for determining the  adequacy of the applicant's  submittal on
incompatible wastes is presented in Figure 9.6.5.
*Quoted from Hatayaraa, H. K., et al.  EPA-600/9-80-010,  March 1980.
 (Reference 4).
                                    9-237
-------
                 »f \CTIMM GHOlf •> *"t
         « Muml O.^/i-t
                                             M  i M ! M
                                             GT| C |  C
                                           H | H I H
       M«m*UM M! Otaw
                                            ^
                                            H.
                                                            T i
JJ
iu
                                                             .CXnlMCLT UA4TTTVK
       Figure 9.6.4.   Hazardous waste  compatibility chart.


                       Source:   Reference 2.
                                  9-238
-------
REACTIVITY CODE
CONSEQUENCES
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    Figure 9.6.4 (continued)'
               9-239
-------
                  SPECIAL REQUIREMENTS ?CR  INCOMPATIBLE WASTES
Has this part of the applicant's submittal been read and           	  	
evaluated?                                                           Yes     No
Have acceptable orocedurs-? '-e°n usad co accurately                 	 	
characterize the wastes?                                            Yes     No
Were wastes properlv cata^orizad by :'2zc.i ,-Lz" group               	  	
.luaoersT                                                            Yes     No
Was waste compatibility identified using the Reference  2           	  	
compatibility chart or other acceptable means?                      Yes     No


Does the information submitted on waste compatibility              	  	
include all wastes identified in Section 9.1?                       Yes     No
If incompatibla wastes are disposed in the same cell,              	  	
are adequate measures taken to segregate wastes?                    Yes    Mo


Did the applicant address the compatibility of container           	  	
residues ana leakage from damaged containers?                       Yes    No
          Figure 9.6.5.  Worksheet for evaluating disposal procedures
                         for incompatible wastes.
                                     9-240
-------
9.0.4  Draft Permit Preparation

     Condicion G of Permit Module XV addresses disposal requirements for
incompatible wastes.  The condition is implemented through reference to a
permit attachment that specifies handling procedures for incompatible wastes.
To be suitable for substitution in the permit condition attachment, the
submitted application information should include detailed plans, engineering
reports,  and operating plans to document compliance with the regulations.
Documentation on handling of incompatible wastes during operation should be
placed In cha Dperating record (see Module II, Condition L.I).  If the permit
applicant does not specify methods for handling incompatible wastes, the
permit writer should either specify conditions under which they may be
accepted or should write in a condition prohibiting Che acceptance of
incomatib L-e -^asr.ss.

9.6.5  References

 L.  U.S. EPA.  Permit Applicants' Guidance Manual for Hazardous Waste Land
     Storage, Treatment, and Disposal Facilities.  Volume I.  Office of Solid
     Waste.  Wasnington, D.C.  1983.

2.   Hacayaraa, H. K., et al., A Method for Determining the Compatibility of
     Hazardous Wastes.  EPA-600/2-80-076, April 1980.

3.   JRB Associates, Inc.  Techniques for Evaluating Environmental Processes
     Associated with Land Disposal of Specific Hazardous Materials, Volume II,
     Incompatible Wastes.  Prepared for the U.S. SPA Office of Solid Waste.
     March 31 1982.

4-.   Hacayaraa, H. K. , et al., Hazardous Waste Compatibility.  Presented in
     Disposal of Hazardous Waste, Proceedings of the Sixth Annual Research
     Symposium.  EPA-600/9-80-010, March 1980.

5.   Merck and Company, Inc.  1976.  The Merck Index.  9th Edition, Rahway, NJ,

6.   Hawley, G. G.  1971.  The Condensed Chemical Dictionary.  8th Edition.
     Van Nostrand Reinhold Company, New York, Cincinnati, Toronto, London,
     Melbourne.

7.   Wolbach, C. D., U. Spannagel, and R. Whitney.  Field Scheme for
     Determination of Waste Reactivity Groups.  Prepared by Acurex Corporation
     for the U.S. Environmental Protection Agency.  Presented in the
     Proceedings of the Ninth Annual Research Symposium—Land Disposal,
     Incineration, and Treatment of Hazardous Wastes.  Fort Mitchell,
     Kentucky.  May 1983.
                                     9-241
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9.7  DISPOSAL OF LIQUID WASTE IN LANDFILLS

9.7.1  The Federal Requirement

     Paragraph (h) of §270.21 requires Che following:

          "If bulk or noncontainerized liquid waste or wastes containing free
     liquids ia to be landfilled, an explanation of how the requirements of
     §264.314 will be complied with [must be submitted],"

     The referenced Part 264 standard states the following:

          "§264.314 Special requirements for liquid wasts.
               ,a) Bulk or noncontainerized liquid waste or waste containing
          free liquids must not  be placed in a landfill unless:
               (1) The landfill  has a liner and leachate collection and
          removal system that meet the requirements of §264.301(a); or
               (2) Before disposal, the liquid waste or waste containing free
          liquids is treated or  stabilized, chemically or physically (e.g.,  by
          mixing vith an absorbent solid), so that free liquids  are no longer
          present.
               (b) Containers holding free liquids must not be placed in a
          landfill unless:
               (1) All free-standing liquid:  (i) has been removed by
          decanting, or other methods; (ii) has been mixed with  absorbent or
          solidified so that free-standing liquid is no longer observed; or
          (iii) has been otherwise eliminated; or
               (2) the container is ve*y small, such as an ampule; or
               (3) The container is designed to hold free liquids for use
          other than storage, such as a battery or capacitor; or
               (4) The container is a lab pack as defined in §264.316 and is
          disposed of in accordance with §264.316."

9.7.2  Summary of Necessary Application Information

     The Part B Permit Applicants'  Manual^- instructs the applicant to
explain how he plans to comply with the standards of §264.314 if the facility
will accept liquid wastes or wastes containing free liquids.   It the facility
accepts bulk or noncontainerized liquid waste or waste containing free
liquids, the applicant must present:

     •    documentation to demonstrate the adequacy of the landfill liner and
          leachate collection system, 'or

     •    proposed methods of chemically or physically treating  or stabilizing
          liquid wastes to eliminate free liquids before disposal in the
          landfill.

Section 9.2 of this manual presents guidance on evaluating the adequacy of the
proposed liner and leachate collection system.
                                    9-242
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      If  che  owner/opera tor  will  accept  containers  holding  free  liquids  and
 these  containers  are not  ampules  or  similarly  small  containers;  batteries,
 capacitors,  or  similar containers; or lab  packs; than  he must provide  trie
 following  information:

     «    proposed methods  for decanting or otherwise  removing  free  standing
           liquids from  the  container before disposal,  or

     •    oroposed absorb jr.-:::  :c  be  added  ;o ihe container, or

     •    proposed methods  of  solidifying  the  free standing liquids  in  the
           container, or

     *    other proposed  methods  of  eliminating free standing liquids.

      If  ampules, batteries, capacitors, or similar containers are  the only
 types  that will be accepted, the  owner/operator should  indicate  expected
 quantities,  types, and proposed  disposition.   If lab packs will  be accepted,
 the  applicant must provide  documentation to demonstrate compliance with the
 standards  of §264.316.,  Section  9 of this manual addresses review  of
 application  information intended  co  meet this  requirement.

 9.7.3  Guidance On Evaluating  Application  Information

 9.7.3.1  Regulatory Applicability and Intent—
     Figure  9.7.1 presents  a flow chart for determining the applicability of
 regulations  covering che  applicant's pians for handling and disposing of
 liquid wastes.

 9.7.3.1.1  Will Bulk or Noncontainerized Liquid Waste or Waste Containing Free
 Liquids  be Placed in the  Landfill?—To assure  successful operation of the
 facility,  it is the applicant's responsibility to  identify the physical
 characteristics of all wastes  to be  disposed of in the landfill, as required
 by §264.13—General Requirements  for Waste Analysis.

     If  the  applicant states that no type of liquid wastes will  be received or
 disposed of  at  the landfill, then the permit writer roust indicate  in the
 permit that bulk or noncontainerized liquid waste or wastes containing  free
 liquids  are  specifically not permitted for disposal at the landfill.  If this
 is the case, the reader may proceed  directly to subsection 9.8.3.1.3.
 However, the permit reviewer is cautioned to note the difference between
 receiving  and disposing of  a waste.  If bulk or noncontainerized wastes
'containing free liquids are received at the landfill and then containerized,
 the  owner  or operator is c.sposing of containers holding free liquids and must
 comply with  §264.314(b) (see subsection 9.8.3.1.3 and 9.8.3.1.4, which
 follow).   Similarly, if containers holding free liquids are received at the
 facility but are emptied  into a landfill cell,  then the owner/operator is
 disposing of bulk or noncontainerized free liquids  and must comply with
 §264.314(a)  (see subsection 9.8.3.1.2 which follows).
                                    9-243
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 WILL SULK OR  NON-CONTAINERIZED
LIQUID WASTE OR WASTE  CONTAINING
    FREE ..QUIDS 3£  PLACED  IN
          THE  LANDFILL?
                           DO THE  LANDFILL DESIGN
                           AND DISPOSAL PROCEDURES
                          COMPLY WITH 3264.31
                  NO
                                                  NO
                                            THE PLANS
                                               ARE
                                            !NADEQUATE
                                             THE PLANS
                                                ARE
                                             ADEQUATE
     WILL CONTAINERS  HOLDING
     FREE LIQUIDS  BE  PLACED
        IN THE  LANDFILL?


                  /ES
                         THE
                   REGULATIONS  ARE
   DO THE DISPOSAL PROCEDURES
    COMPLY WITH §264. 3l4(b)7
       NO
      YES
 THE PLANS
    ARE
INADEQUATE
THE PLANS
   ARE
ADEQUATE
             Figure  9.7.1.
      Regulations applicable  to  management
      of  liquid wastes at landfills.
                                       9-244
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 9.7.3.1.2  Do the Landfill Design and Disposal  Procedures Comply with
 §264.314(a) _?—The applicant for a landfill permit wno nas stated chat bulk
 or nonconcainerized liquid waste or waste containing frsa liq_i^3 -ill oe
 received for disposal has two options for disposing of the vaste at the
 landfill; (1) disposal in a landfill cell with a liner and a leachate
 collection and removal system, or (2) treatment of the waste prior to disposal
 so that free liquids are no longer present.  A permit application which
 indicates receipt of such wastes and does not indicate disposal by one of
 these methods may be inadequate.

     If these wastes are to be disposed of in a landfill with a liner and
 leachate collection/removal system, the liner and leachate collection system
must meet the requirements of §264.301 (a^ ' :*<> sucs-cc^on is.L>*  fne
 application snoula also address compatibility and ignitability/reactivity
 concerns.  The application is technically inadequate if it proposes to dispose
 of these wastes (without prior elimination of free liquid) in a landfill cell
 that does not have a liner and leachate collection system or if the liner and
 leachate collection system do not meet the §264.301(a) requirements.

     If liquid wastes are treated chemically or physically before disposal so
 that free liquids are no longer present, the treated waste can be disposed of
 in any landfill cell, as long as compatibility and ignitability/reactivity
criteria are met.  However, in these cases, the application must provide a
 detailed description of the treatment method to be used and documentation of
effectiveness in eliminating free liquids.  If a landfill cell does not
contain a liner and leachate collection system, free liquids or wastes
containing liquids cannot be disposed c-f in that cell based on the presumption
 that wastes previously discharged willr chemically or physically eliminate the
 free liquids or liquids contained in the waste.  However, it would be
 allowable to mix the two wastes (if compatible) to eliminate free liquids and
 then place the mixture in a landfill cell that does not have a liner and
 leachate"collection system.

 9.7.3.1.3  Will Containers Holding Free Liquids Bg Placed in the Landfill?—
Guidance on the meaning of free-standing liquid can be found in the preamble
 to an interim final amendment to 40 CFR Part 265,  published on March 22, 1982
at 47 FR 12317,  and in the preamble to regulations published on May 19, 1980
at 45 FR 33213.  Section 260.10 defines free standing liquids as "...  liquids
which readily separate from the solid portion of a waste under ambient
 temperature and pressure."

     If the applicant states that containerized free liquids will not  be
disposed of at the landfill,  then the permit writer must indicate in the
permit that containers holding free liquids are specifically not permitted for
disposal at the landfill.  If these wastes will be received at the landfill
but emptied from the containers for disposal,  the  application must demonstrate
compliance with §264.314(a).

9.7.3.1.4  Do the Disposal Procedures Comply with  §264.314(b)?—The provisions
of §264.314(b) allow the owner/operator some latitude in deciding how
containers holding free liquids will be disposed of in the landfill.
Specifically,  free standing liquids can be removed from the container,  they
                                    9-245
-------
can be mixed wich aosorbetit or solidified in che concainer, or they can be
eliminated by any oeher method or procedure acceptable to the permitting
authority.

     Very small containers, such as ampules, or containers that hold liquids
for reasons other than storage, such as batteries or capacitors,  can be
directly disposed of without elimination of free liquids.  However, the intent
of the regulation is to allow disposal of small containers as thev may
randomly appear in the waste.  "^2 p^caraant of large quantities  of these
types of small containers holding free liquids in the same part of the
landfill would increase the potential for generation of significant quantities
of leachate and landfill subsidence.  Therefore, such a procedure is Tot in
concert with the intent of the ~«?ulation.

     The provisions of §264.314(b) allow placement of lab packs in landfills.
However, a container holding free liquids must meet the specific  criteria of
§264.316 (see subsection 9.3) to be classified as a lab pack and, therefore,
be acceptable for disposal in a landfill.

     Further, §264,315 (-see subsection 9.8) incorporates requirements for
disposal of containers in landfills regardless of the physical characteristics
of the contained wastes.  The requirements of §264.315 are germane to
containers which are processed according to options of §264.314(b)(1) .

9.7.3.2  Assessment of the Technical Adequacy of the Applicant's  Plans for
Disposal of Liquid Wastes —
     Figure 9.7.2 illustrates the techn-ical topics chat are discussed in this
section.  Each topic is presented individually so that specific sections
applicable to the facility in question can be referenced.

     The permit reviewer should consider the long-term potential  for ground
water contamination associated with adopting the applicant's proposed liquids
management techniques since corrective action will be required if hazardous
wastes leach out of the landfill and are detected in the ground water.  Such
corrective action is generally extremely costly and could negate  the
short-term cost savings associated with selecting an unsuccessful
stabilization technique.  Therefore, the permitting agency should encourage
the applicant to implement treatment or stabilization methods which, in
addition to eliminating free liquids, also limit the potential for future
waste leaching.  If waste leaching is highly likely in the long term
regardless of sorbent addition, a technique such as encapsulation (with high
initial costs) may be cost effective, over the long term.  In summary, although
§264.314. requires the elimination of free liquids during placement, the
applicant and the reviewer should consider the possibility of leachate
migration in the long term in spite of adopting the selected method.

     The applicant must provide reliable information about the composition and
characteristics of the waste to be processed so that the effectiveness of any
proposed treatment/stabilization method can be evaluated.  The waste
characteristics may dictate whether a stabilization process such  as
encapsulation is applicable or whether sorbent addition will suffice.  The
                                     9-246
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BULK OR NONCONTAINERIZED
 LIQUID WASTES OR WASTES
 CONTAINING FREE LIQUIDS
                                      CONTAINERS HOLDING
                                     FREESTANDING LIQUIDS,
          WASTE
    CHARACTERIZATION

TEST

FOR
PRESENCE OF
FREE L
iQUIDS
                               STABILIZATION
                                 OF WASTE
                                           DECANT
                                              OF
                                            LIQUIDS
                                                                  NG
                                 ECONOMIC
                              CONSIDERATIONS
                                          ADDITION OF
                                          ABSORBENTS
                           TESTING PHYSICAL AND
                          CHEMICAL PROPERTIES OF
                             STABILIZED WASTE
                          CHEMICAL LEACH TESTING
                            OF STA8H1IZED WASTE
                           EFFECTS OF BIOLOGICAL
                             ATTACK ON TREATED
                                  WASTES
                             EFFECTS OF CURING
                            AND AGING PROCESSES
                            ON TREATED MATERIAL
 Figure  9.7.2.
Assessment of technical adequacy of  the  applicant's  plans
for disposal of liquid wastes.
                                    9-247
-------
applicant needs to identify bo en che physical and chemical characteristics of
the waste.  The permit reviewer should consider Che applicant's overall waste
analysis plan submitted in response to the reouirenents of 5270.14(b)(2)
and (3).

9.7.3.2.1  Test for Presence of Free Liquids—EPA defines "free liquids" as
"liquids which readily separate from the solid portion of a waste under
ambient temperature and pressure."2  xhe applicant is not required to test
containers for free liquid content if h» chooses ;o consider all containers of
*asca as aoiaing free liquids and disposes of them in accordance with
$264.314(b).   However, the applicant may choose to demonstrate that free
liquids are not present in a containerized or bulk waste.  If so, he must
describe the  test protocol to he aTioloyed ?r '~e irrust -revise other
::m:	..-ou >.aac cne waste does not contain free liquids.

     EPA currently recognizes two test protocols for determining the presence
of free liquids.3  One method, designated the paint filter method, is
described- in 47 FR 3311, February 25, 1982.  The paint filter method is a
gravity test  which calls for a 100 ml representative sample of the waste Co be
placed in'a .+00 micron, conical paint filter for 5 minutes.  The filter
specified is  a standard pair.t filcar supported by a funnel on a ring stand
with a beaker or cylinder below the funnel to capture any free liquid chat
passes through the filter.  If any liquid passes through the filter, the waste
is considered to hold free liquids and is subject to che requirements of
§264.314(b).   Ef the paint filter test is to be used to measure the percentage
of free liquids in the waste in individual containers, a longer test period
probably would be necessary to achieve-an accurate measurement (e.g., 15 to
•+5 minutes > .•*

     The second procedure for determination of liquids is designated the
inclined plane method and is described in the preamble to the May 1980
regulation (45 FR 34214).  The inclined plane method calls for the placement
of 1 t:o 5 kilograms of waste on a level or slightly sloping plate of glass or
other similar flat and smooth solid material for at least 5 minutes.  If a
liquid phase  separation is observed, the waste contains "free liquids".  It
should be noted that the applicant may petition EPA under 5260.20 and 260.21
for use of an equivalent test protocol.

     If the applicant chooses to test for the presence of free liquids, he
must describe how a representative sample of the waste will be obtained.  In
those cases where a demonstration is being made on a batch (e.g., truckload)
of similar containerized waste, the sample or samples must be representative
of all containers in the lot.  The applicant's sampling program should conform
to the guidance provided in Test Methods for Evaluating Solid Waste—Physical/
Chemical Methods, SW-846.5

     The applicant may not need to test for free liquids if he can demonstrate
or certify in another manner that the waste does not contain free liquids.
Such certification could be acceptable if the landfill owner/operator receives
containerized wastes on a continuous basis from a specific generator and knows
by contractual agreement or prior observation that these containerized wastes
                                     9-248
-------
do noc vary and do not contain free liquids.  The permit reviewer is referred
to the Permit Applicant's Manual for the General Facility Standards'^ and tne
requirements for waste analysis plans.

9.7.3.2.2  Management of Bulk or Noncontainerized Liquid Wastes—If bulk or
noncontainerized liquid waste or bulk wastes containing free liquids are to be
placed in a landfill that is noc equipped with a liner and leachate collection
system, then the applicant must demonstrate how free liquids will be
eliminated to comply with the requirements of §264.314(a) .  There are a
variety of physical and chemical treatment methods which the applicant may
employ to eliminate free liquids from noncontainerized waste.  Section
9.7.3.2.3 of this document describes treatment/stabilization methods available
to solidify the waste to make it acceptable for disoosal.  Soaa of tne
treatment/stabilization .necnods are relatively inexpensive, such as
cement-based processes, while other methods, such as various encapsulation
techniques, are relatively expensive.  For a given waste type,  ic is likely
that free liquids can be eliminated using a variety of methods, but all will
have varying attendant costs.

9.7,3.2.3  Treatment/Stabilization Technology—"Treatment" is defined by the
EPA in §260.10 as "any method, technique, or process, including
neutralization, designed to change the physical, chemical, or biological
character or composition of any hazardous waste so as to neutralize such
waste, or to render such waste nonhazardous, or less hazardous; safer to
transport, store, or dispose of; or amenable for recovery, amenable for
storage, or reduced in volume."  Treatment processes include a  wide array of
techniques such as thermal, chemical, physical, and biological  treatment or
stabilization.  Applicable liquid treatment techniques were reviewed in
Section 9.5 in the discussion of ignitable and reactive wastes.

     Stabilization techniques are those which act to limit waste solubility or
to detoxify the waste contaminants.  Solidification techniques  accomplish the
same results by the production of a monolithic block of waste with high
structural integrity,7

     The long-term effectiveness of the proposed treatment/stabilization
method in limiting future leachate migration should be one of the foremost
selection criteria.  If geological or hydrological conditions could allow
significant leachate migration and result in ground water contamination, a
process should be employed which renders the constituents nonhazardous and/or
immobile.

     There is no single treatment/stabilization method which is ideal for all
types of hazardous wastes.  For example, although a waste material  with a low
concentration of organics may be satisfactorily treated by a cement-based
treatment process, it would not be treated effectively by organic polymer
treatment methods since the organics may retard the set of polymers.
Table 9.7.1 indicates the compatibility of selected waste categories  with
different waste solidification/stabilization techniques (reprinted  fro;n EPA
SW-872).?
                                    9-249
-------













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-------
      So naif icat ion,'s caoil izacua tecnniques are,  in general, new technologies
which nave evolved out of  the need for finding solutions  for Che disposal of
difficult to handle hazardous waste.  The adequacy of solidification/
stabilization techniques in reducing long-term contaminant migration has not
been  thoroughly documented in all cases and it appears that more work is
necessary to optimize treatment procedures for individual wastes.
Nevertheless, preliminary  evidence indicates that  some solidification/
stabilization techniques are effective at reducing the potential for ground
water contamination.  Some of the hazardous chemicals and wq?t»s vhich can be
stabilised and -solidifisd  Affectively include: ^>9

     •    electroplating wastes           •    petroleum bottom tank sludges

      *    soent oic'ils liquor-            *    orine wastes

      •    spent acids                     •    air pollution control residues

     •    alkaline cleaners               •    wastewater treatment sludges

     •    inorganic pigment wastes        *    aqueous wastes containing
                                               soluble toxic organics

     •    leather tanning and
          finishing wastes

     During review of a permit application which specifies that a
solidification/stabilization technique-will be employed,  questions may arise
".oncerning the long-carm staoiiity attendant with the process.   In such cases,
the permit reviewer should refer to EPA-600/2-32-099 which is a study of the
physical and leaching properties of solidified/stabilized industrial
waste.10  Tests were conducted on tout solidification/stabilization
processes:  (1) a lime-fly ash, pozzolanic cement that yields a solid
microencapsulation system, (2) a cement/soluble-silicate treatment process
that produces a soil-like product, (3) an organic polymer system that produces
a hard, rubber-like solid, and (4) a raacroencapsulation process that
solidifies the waste and then bonds  it in a polyethylene  jacket.  The lime-fly
ash pozzolanic solidification produced a solid soil/cement-like product with
good structural integrity but poor durability.   Concentrations  of hazardous
elements (toxic heavy metals and insoluble salts) in leachates  from this
treated product were actually higher in about  half the cases than they were  in
leachates from similar untreated material.  The cement/soluble-silicate
treatment process produced more consistent containment of hazardous  elements
with 60 to 70 percent of the constituents having lower levels in the leachate
from the treated sludge than in leachate from  the untreated control  columns.
The organic polymer system proved to be counterproductive in limiting release
of hazardous  elements from an electroplating waste and a  paint  production
sludge.  Both wastes lost most constit-.-nts at much higher rates than the
control columns,  possibly because of the acidification and resulting
dissolution of the   udge that was required to produce the polymerization
reaction used  in this process.  The macroencapsulation process that solidifies
the waste and  then bonds  it in a polyethylene  jacket  gave excellent
containment of all constituents but  cadmium.10
                                    9-251
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     Several apoiicabie creatment/stablization methods are discussed in the
following subsections.  This information summarizes the data presented in the
"Guide to the Disposal of Chemically Stabilized and Solidified Waste" (SPA
SW-872, September 1982)7 and other references, as noted.

9.7.3.2.4  Cement/PozzoIan Solidification/Stabilization Techniques—A cement-
based process involves the reaction of water in the waste with anhydrous
Portland cement powder.  Similarly, a lime-pozzolan solidification involves
the reaction of lime and a pozzolanic material in tha presence of water in the
vasta na'erial ;o form compounds possessing cemetitious properties.  Cement
and pozzolanic-based techniques are employed singularly or in combination.
When a pozzolan is mixed with cement, the lime that is liberated during the
setting and hardening of cement combines with the oozsolan,  resulting in che
formation ~ f -. li.-ae-po^zoian compound.

     Some of the advantages of the cement/pozzolan-based process are that it
is relatively inexpensive; it does not require specialized equipment or
advanced technology; the product can be coated; and the process provides a
stable product in many cases.  However, there are disadvantages.  For
instance, certain wastes, such as wastes with high sulfate content, may not be
adaptable to the techniaue.  Additionally, it is likely that some leaching may
occur, and tne final product is voluminous and heavy.7

     Recent testing has been conducted on the leachability of wastes
stabilized by cement/pozzolan-based stabilization techniques.  A lime-fly ash
pozzolanic solidification process produced a solid soil cement-like product
with good structural integrity but poos- durability.  Concentrations of
hazardous aiemencs in ieachates from tU-is treated product were actually higher
in about half the cases than they were in Ieachates : • -n similar untreated
material.  A cement/soluole-silicate treatment proces ,  produced a
semi-friable material with low strengEh and a soil-like consistency.  This
process produced more consistent containment of hazardous elements with 60 to
70 percent of the constituents (toxic heavy metals and inorganic salts) having
lower levels in the leachate from the treated sludge than in leachate from the
untreated control columns.10

     Although FGD sludges are exempted as nonhazardous solid wastes by EPA,
the pozzolanic process is reported to be effective at stabilizing sludges from
wet flue gas desulfurization (FGD) systems.  Test data show that FGD sludge
treated by the pozzolanic process is more environmentally acceptable over
uncreated sludge because of reduced leaching potential and improved handling
characteristics.  Woodward and West provide pertinent information on
commercially available pozzolanic treatment methods for stabilizing FGD
sludge.11

     Polymer impregnation and the application of surface coatings may help to
increase the effectiveness of the ceraent/pozzolan-based process.  The polymer
impregnation process is accomplished by soaking the waste-concrete mixture in
styrene monomer to fill the pores, followed by heating to induce
polymerization.  Surface coating materials include asphalt emulsion, and
                                     9-252
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 /inyl.   PrcoLeas nave oeen encountered with  surfaca  coating because  of  poor
 adhesion of  the coating onto  the waste or lack of  strength of  the concrete
 material containing the waste.''

 9.7.3.2.5  Thermoplastic Techniques--Thermoplastic solidification/stabilization
 techniques use an organic thermoplastic material which  is mixed with  the waste
 to  form a plastic matrix.  Thermoplastic materials include bitumen,  paraffin,
 and polyethylene.  The waste  is generally dried, heated, and dispersed  through
 a heated plastic matrix which  is then cooled to solidify the -nass.   The
 rasul;ing ~ass is a relatively staole product which  is  generally superior to
 cement-based systems at reducing the potential for leachate generation.7

     Thermoplastic techniques are relativelv exnensiv*?  because ?£ complicated
 pr :c3sc1 :g ^4^iru"enc an-i i^gn energy costs for drying (incorporating wet
 wastes greatly increases losses through leaching).   The technique cannot be
 used on waste material containing organic chemicals  which act as solvents for
 the matrix.  Other wastes which cannot be Created by this method include:
 strongly oxidizing salts, such as nitrates, chlorates,  or perchlorates;
 materials that decompose at high temperatures, especially citrates and certain
 types of plastic (.e.g., polyethylene, polypropylene, acetal copolytner, and
 other crystalline resins);12 ancj tetraborates or iron and aluminum salts
 ;tnese compounds cause premature hardening and can clog and damage mixing
 equipment)•?

 9.7.3.2.6  Organic Polymer Process—One well-documented organic polymer
 process employs urea-formaldehyde to encase waste material.  Other polymers
 which could be used for this process iaclude vinyl ester-styrene and polyester
 resin.  In the organic polymer process-r wet or dry wastes are mixed with a
 polymer to which a catalyst is added.  The resulting product is a polymerized
 material which does not chemically combine with the waste buC forms a mass
 that entraps waste particles.7

     No information could be found in the available  literature regarding the
 long-term leaching characteristics of wastes treated by polymerization
 methods.   Since no chemical reaction occurs between  the waste and polymer in
 the solidification process,  a breakdown of the waste material  may result in a
 release of hazardous materials.  Secondary containment  in steel drums may be
worth consideration when employing an organic polymer process.

 9.7.3.2.7  Surface Encapsulation Techniques—Surface encapsulation techniques,
 often referred to as "jacketing",  enclose waste material which  has  been
 pressed or bonded together in a coating of inert  material.   Polyethylene is
 frequently used to jacket waste material.   The major advantage  of surface
 encapsulation is that it virtually eliminates the potential for leaching if
 the cover material stays intact.   However,  the technique is expensive due to
 high costs for resin material, equipment,  skilled labor, and  energy utilized
during drying,  fusing of the binder,  and  forming  of the  jacket.  The  TRW
 Corporation has investigated many alternative binding and coating systems and
developed what it considers  to be  the optimum system.  This system has been
 tested, and published data  on the  processes  are available in  Reference 13.
 The TRW surface encapsulation system requires that  the waste material be
 thoroughly dried.   The dried wastes are stirred into an  acetone solution of
                                    9-253
-------
•noaified  i,2-polybutadiene for 5 minutes vhi.cn is chert allowed to set for
2 hours.   The coated material is placed in a mold, subjected to slight
mechanical pressure, and heated to between 120°C and 200°C to produce fusion.
The agglomerated material is a hard, tough, solid block.  A polyethylene
jacket 3.5 rran thick is fused over Che solid block and adheres to the
polybutadiene binder.'7

9.7.3.2.8  Self Cementing Processes—Self cementing processes are employed to
stabilize  industrial wastes which contain large amounts of calcium sulfate and
calcium sulfitas jucr4 as fiue-gas cleaning or desulfurization sludges.
Usually a  small portion (8 to 10 percent by weight) of the dewatered waste
sulfate/sulfite sludge is calcined under carefully controlled conditions to
produce a  partially dehydrated cementitious calcium sulfats or suifice.   This
calcined vasta •' s :'^ ;n ^ii^LroQucea into the bulk of the waste sludge along
with other proprietary additives.  The finished product is a hard,
plaster-like material with good handling characteristics and/or permeability.
This is a  relatively inexpensive treatment method which generates a solid
product with leaching characteristics similar to products of cement and
lime-based cementing processes.''

9.7.3.2.9  Classification and Pr JMCtion of Synthetic Minerals or Ceramics--
Glassification may prove to be an effective treatment for dealing with
extremely  toxic wastes.  The waste material is combined with silica and  can be
fused in glass or formed into a synthetic silicate mixture.  This is expected
to form an extremely stable product which will have a low potential for
leaching.  The high costs associated with the process may preclude it for all
but the most hazardous wastes.7  Classification is being studied for use in
stabilization of radioactive wastes.

9.7.3.2.10  Economic Considerations—If more than one treatment/stabilization
method will provide a stable waste, the owner/operator will attempt to select
the cost-effective method.  In most of the aforementioned stabilization
systems, the cost of materials is the highest cost element.  Other budget
items include costs for:  equipment, operators, and fees or royalties for use
of patented processes.  When considering the costs of materials, equipment,
and energy required to treat a given amount of waste, the cement-based and
pozzolanic systems are the least expensive of available solidification/
stabilization processes.  Table 9.7.2 presents economic considerations for
waste stabilization/solidification techniques (reprinted from EPA SW-872).?

9.7.3.2.11  Testing Physical and Chemical Properties of Stabilized Waste—The
applicant  should supply a protocol for testing the physical and chemical
properties of the stabilized or solidified waste.  Information should be
provided on the reaction of the treated waste to applied stresses,
permeability of the stabilized waste, wet/dry durability, and freeze/thaw
durability.  Use of leaching tests conducted under static or continuous  flow
conditions could be appropriate.  These testing procedures will help establish
whether the treatment method will be effective at stabilizing the waste  over
the long term.
                                      9-254
-------
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     References  L-+ and 15 present a discussion of testing procedures available
 co evaluate the  physical and chemical properties of the treated waste.
 TesCing procedures are also discussed in EPA 5W-372.?  The results of
 laboratory testing to determine the physical properties and chemical leaching
 characteristics  of five industrial wastes that had been solidified or
 stabilized by one or more of four processes (lime-fly ash pozzolanic,
 caraent/pozzolan, organic polymer, polyethylene encapsulation) are presented in
,EPA-600/2-82-099.10

 9.7.3.2.12  Effects of Biological Attack on Treated Wastes7—The permit
 reviewer should  consider the effects that biological attack can have on the
 long-terra containment of solidified/stabilized waste.  Biological attack can
 occur bv direct  utilization ^? some solidification material as a substrate for
 aactenai growth, or by the biological production of acid materials that can
 attack and corrode treated wastes.7  of four solidification materials
 studied by Columbo and Neilson (Portland type II cement,  urea-formaldehyde
 (UF) resin, asphalt, and vinyl ester-styrene), UF resin has the greatest
 potential for biological degradation.1^  Organic acids released by the
 decaying of organic material,  such as plant roots, can cause corrosion of some
 waste materials, particularly those solidified with a lime or cament-based
 process.?

 9.7.3.2.13  Effects of Curing and Aging Process on Treated Material?—The
 applicant should address the issue of curing if a ceraentitious solidification
 system is employed.  It has been demonstrated that for cementitious systems,
 less leaching was observed when cement-based samples had  been cured more than
 100 days.7  r^e  conditions of curing are also important.   Solidified
 materials cured  under humid conditions1 are less leachabLe than treated
 material allowed to dry during curing.7

     The applicant should also consider the effects of aging on treated waste
 material.  Urea  formaldehyde solidification systems and treatment systems that
 involve bitumen-based or polymer systems extended with water may provide
 decreased containment of the waste with age.?  Consequently, if the waste
 material is extremely toxic and long-term containment is  imperative, an
 alternative treatment method that will provide long-term  containment, such as
 glassification,  should be selected.

 9.7.3.2.14  Containers Holding Free Standing Liquids—If  containers holding
 free standing liquids are to be placed in a landfill that is not equipped with
 a liner and leachate collection system, then the applicant must demonstrate
 how free standing liquids will be removed to comply with  §264.314(b).  One
 method of removing free standing liquids is simple decanting.  This is a
 straightforward  procedure but it is complicated by the fact that the applicant
 must now dispose of the decanted liquids.  If the applicant proposes to decant
 free standing liquids he must demonstrate how the requirements of §264.315
 will be met.  These requirements specify that containers  placed in a landfill
 must be at least 90 percent full unless the container is  very small such as an
 ampule.  One way to comply is to add a filler material so that the container
 is at least 90 percent full.
                                    9-256
-------
     Sorbent materials can be divided into three general classifications:
natural organic (e.g., straw, sawdust), natural inorganic (e.g., clays,
calcium carbonate), and synthetic (e.g., polyurethane).   Each generic type is
different in terms of cost and effectiveness.  The natural organic and
inorganic sorbenta are generally readily available and less expensive than the
synthetic sorbents.  Although more expensive, the synthetics are more
versatile than natural sorbents and tend to exhibit higher sorption capacity
for many organic hazardous wastes.  Both natural and synthetic sorbents .-.an b
-------
     The use of absorbents xs a common method to eliminate free standing
liquids from containers.  The use of absorbents  is  often preferred over
decanting to avoid subsequent handling of decanted  liquids.   Section 7.3.2.5
of this document discusses the use of absorbents and provides a matrix of
available absorbents and their compatibility with various hazardous wastes.

     As an alternative to removing free standing liquids by  decanting or the
addition of an absorbent, the applicant may propose to eraoty the waste into  a
large container or impoundment and employ a treatment/stabilization method.
If such a procedure is employed, the applicant is now disposing of a bulk or
noncontainerized waste and, therefore, all the free liquids  (not just free
standing liquids) must be removed prior to placement of the  waste if the
landfill is not equipped with s. liner and ieachate  collection system.

9.7.3.2.15  Decanting of Liquids and other Methods  of Liquid Removal—
Decanting of free liquids, although not a "treatment method", may be an
effective way of removing free liquids from a waste.  This method is more
adaptable to wastes containing solids which do not  remain in suspension, but
instead settle Co the oottonr of the container.  Decanting may be followed by  a
treatment/stabilization method, or if the landfill  incorporates a liner and
Ieachate collection system, tne decanted liquid may be disposed of in the
landfill cell.

     In additon to decanting, there are several other methods of physical
separation.  Some of the techniques employed to dewater municipal sludges may
be applicable to hazardous industrial wastes.  One  such method is vacuum
filtration.  The process separates solids and liquids by porous media
filtration.  Media employed for this purpose include steel coils, metal mesh,
and cloth.17

     If proper weather conditions prevail, hazardous wastes  can be dewatered
in sludge drying beds.  Dewatering occurs through evaporation.17  If sludge
drying beds are proposed, the issue of hazardous waste leaching must be
considered.  Additionally, this method may not be appropriate for wastes which
could create an air pollution problem through evaporation and dispersion of
volatile compounds.

     Another way of separating solids from liquids  is through the use of
continuous centrifuges.  This method has been employed successfully in the
chemical and mining industry for many years.  1C has also been used
effectively to dewater municipal wastes and wastes  generated by paper-mills,
foundries, and refineries.17

9.7.3.2.16  Addition of Absorbent Material—Although the EPA has stated that
the addition of an absorbent material does not constitute "treatment" of free
liquids (February 25, 1982, 47 FR 8304), the technique is widely used because
of its low cost.  However, addition of an absorbent may not  stabilize the
waste over the long term and, hence, the waste may  be susceptible to
leaching.  Consequently, the use of an absorbent may not always be a viable
approach.
                                    9-257
-------
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                                              9-259
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                                          9-260
-------
                     DISPOSAL OF LIQUID WASTES  IN  LANDFILLS
   GENERAL INFORMATION

Has this part of the applicant's subraittal been  read  and            	  	
evaluated?                                                           Yes     No


Are acceptable methods specified for analyzing the wastes           	  	
for free liquids?                                                    Yes     No


-  BULK OR NON-CCfJ7AINERI222 ','AoTi DISPOSAL

   Does the landfill meet leachate collection and removal           	  	
   system requirements specified in Section 9.2?                     Yes     No

   If not,

      Are wastes treated to eliminate free liquids?                 	  	
                                                                     Yes     No
   Is a detailed description of the treatment method(s)            	 	
   provided?                                                         Yes     No


   Did the applicant document the effectiveness of the	 	
   treatment process(es)?                     .                       Yes     No
   CONTAINERIZED WASTE DISPOSAL

   Are containerized wastes treated to eliminate free liquids?     _____  	
                                                                    Yes     No


   Which of the following methods are used:

   •  Solidification/stabilization?                                	  	
                                                                    Yes     No

   •  Mixing with absorbent materials?                             	  	
                                                                    Yes     No

   •  Decanting?                                                   	  	
                                                                    Yes     No

   •  Other methods (specify)	
 Figure 9.7.3.  Worksheet for evaluating disposal procedures for liquid wastes-

                                    9-261
-------
If decanting is used, did 'the applicant describe procedures     	
for disposing the decanted Liquid?                               Yes    No
Are containers at least 90 percent full after eliminating       	  	
the free liquids?                                                Yes    No
Are detailed procedures for the treatment processes provided?   	  	
                                                                 Yes    No
Are any free liquids dispose'- in very small containers?         	  	
                                                                 Yes    No
If so,

•  Are such containers disposed in small quantities?            	  	
                                                                 Yes    No
   and

•  Are the containers widely dispersed throughout the           	  	
   disposal area?                                                Yes    No


Do lab packs containing free liquids meet the requirements      	  	
specified in Section 9.3?                                        Yes    No
TREATMENT/STABILIZATION

Are treatment/stabilization techniques employed to minimize     	  	
the potential for long-term waste leaching?                      Yes    No
Did the applicant supply a protocol for testing the physical    	  	
and chemical properties of stabilized and solidified waste?      Yes    No


Does the applicant address the effects of curing and aging      	  	
on solidified materials and treated wastes?                      Yes    No
                         Figure 9.7.3 (continued)
                                  9-262
-------
  3.  Telephone interview wicn Alison Karester, Attorney,  U.S.  EPA,  Division of
     Solid Wastes, March 22, 1982.

 4.  Found in Preamble Notice of  February  25,  1932  at  47  FR  8311.

 5.  U.S. Environmental Protection Agency.   Test Methods  for Evaluating  Solid
     Waste.  Second Edition.  SW-846.  July  1932.

 6.  Capone, S. V., at al.  Permit Applicants  Manual  for  -,:e General  Facility
     Standards of ->0 CFR 24o.  Prepared  for  the U.S.  Environmental  Protection
     Agency, Office of Solid Waste by GCA/Technology  Division.   June  1983.

 ?..  U.S. EPA.  Guide to the Disposal of Chemically ^"ab iM-s-i  jnd  -oiiaii
     Wa3C».  SW--372.  Jdptssmoer j.982.
 8.  Pojasek, Robert B. , Toxic and Hazardous Waste Disposal,  Volume  II.  Ann
     Arbor Science, Ann Arbor, Michigan.  1979.

 9.  Stanczyk, T. F. , B. C. Senefelder and J. H. Clarke.  Solidification/
     Stabilization Processes Appropriate to Hazardous Chemicals and Waste
     Piles.  1982 Hazardous Spills Conference, Milwaukee, Wisconsin.
     April 19-22, 1982.

10.  Environmental Laboratory, 'J.S. Army Engineer Waterways Experiment
     Station, Physical Properties and Leach Testing of Solidified/Stabilized
     Wastes.  EPA 600/2-82-009-  February 1983.

11.  Woodward , John P. and 3. W. West.  The Stabilization of  Sludges  from Wet
     Flue Gas Desulfurization Systems.  In Toxic and Hazardous Waste  Disposal,
     Volume II, Robert 3. Pojasek, Ann Arbor Science, Ann Arbor, Michigan.
     1979.

12.  Kirk-Othmer.  Encyclopedia of Chemical Technology.  Third edition.  John
     Wiley & Sons, New York.  1982.  Volume 18, p. 184.

13.  Lubowitz, H. R. , R. L. Denhara and G. A. Zakrzewski.  Development of a
     Polymetric Cementing and Encapsulating Process for Managing Hazardous
     Wastes.  EPA 600/2-77-045, U.S. Environmental Protection Agency,
     Cincinnati, Ohio.  1977.

14.  Thompson, D. W. and p. G. Malone.  Physical Properties Testing of  .aw and
     Stabilized Industrial Sludges.  In Toxic and Hazardous Waste Disposal,
     Volume II, Robert B. Pojasek,  Ann Arbor Science, Ann Arbor, Michigan.
     1979.

15.  Anderson, M. A.,  et al.  Test Factors Affecting the Release of Materials
     from Industrial Wastes in Leaching Tests.   In Toxic and Hazardous Waste
     Disposal, Volume II, Robert B. Pojasek,  Ann Arbor Science, Ann Arbor,
     Michigan.  1979.

16.  Columbo, P. and R.  M.  Neilson, Jr.   Properties of Radioactive Wastes and
     Waste Containers.   3NL-NUREG-50692 ,  Brookhaven National Laboratory,
     Upton, New York.   1977.
                                    9-263
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18.
                                 9-264
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3.3  SPECIAL REQUIREMENTS FOR CONTAINERS AND LAB PACKS

9.8.1  The Federal Requirement

     The information requirements for containers and lab packs are specified
in §270.21(1),  as follows:

          "If containers of hazardous waste are to be landfilled,  an
     explanation of how the requirements of §264.315 or §264.3\A,  as
     applicable, will be complied *ith imust be submitted]."

     The referenced standards of §264.315 specify special  requirements  for
containers and state that:

          "Unless they are  very  small, such as  an ampule,  containers must be
     either:
          (a) At least 90 percent full when placed in the  landfill,  or
          (b) Crushed, shredded,  or  similarly reduced in volume  to the  maximum
     practical extent before burial  in the landfill."

     The referenced standards of §264.316 specify requirements for disposal  of
lab packs and state that:

          "Small containers of hazardous waste  in overpacked drums (lab packs)
     may be placed in a landfill if  the following requirements are met:
          (a) Hazardous waste must be packaged  in non-leaking  inside
     containers.  The inside containers" must be of a design  and  constructed  of
     a material that will not react  dangerously with,  be decomposed  by,  or be
     ignited  by the contained waste.   Inside containers must be  tightly and
     securely sealed.  The  inside containers must be of the  size and type
     specified in the Department of  Transportation (DOT) hazardous materials
     regulations (49 CFR Parts 173,  173,  and 179),  if those  regulations
     specify  a particular inside container for  the waste.
          (b) The inside containers  must be overpacked in  an open  head
     DOT-specification metal shipping container (49 CFR Parts  178  and 179) of
     no more  than 416-liter (110 gallon)  capacity and surrounded by,  at  a
     minimum, a sufficient  quantity  of absorbent  material  to completely  absorb
     all of the liquid contents  of the inside containers.  The metal  outer
     container  must be full  after packing with  inside containers and  absorbent
     material.
          (c) The absorbent material  used must  not  be capable  of reacting
     dangerously with, being decomposed by,  or  being ignited by  the  contents
     of the inside containers in accordance with  §264.17(b).
          (d) Incompatible  wastes, as defined in  §260.10 of  this chapter, must
     not be placed in the same outside container.
          (e) Reactive wastes, other  than cyanide-  or sulfide-bearing waste  as
     defined  in §261.23(a)(5)  of  this chapter,  must  be treated or  rendered
     non-reactive prior to  packaging  in accordance  with  paragraphs  (a)  through
     (d) of this section.   Cyanide- and sulfic=.-bearing  reactive waste may be
     packed in  accordance with paragraphs  (a) through  (d) of this  section
     •ithout  first being treated  or rendered non-reactive."
                                    9-265
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9.3.2  Summary of Necessary Application Information

     The Part B Permit Applicants' Manual^- requires Che applicant to explain
how he will eliminate voids in containers and assure that they are at Least
90 percent full before disposal.  If this specification can not be met,  the
applicant is directed to indicate the methods he will use to crush,  shred, or
similarly reduce the volume of such containers before burial in the landfill.

     If lab packs ara or will ba Accepted ac che facility, the applicant is
directed to:

     •    provide information in his application to illustrate conforniance
          with the standards specified in §26^.310.

     •    present inspection plans for determining that inside containers  are
          nonleaking, constructed of nonraactive materials,  are tightly  and
          securely sealed,  and meet Department of Transportation (DOT)
          requirements.

     •    indicate that  -open head DOT overpacked drums  of no more Chan
          110-gallon capacity wit. be used.

     •    specify any absorbents used inside the overpack and demonstrate  that
          the container  is  full before disposal.

     •    document that  the absorbent used is nonreactive.

     •    document methods  for determining that incompatible or reactive
          wastes (other  than cyanide- or sulfide-bearing wastes) are not
          placed in the  same outside container*

     •    indicate the arrangements that have been made to treat or  otherwise
          render reactive wastes nonreactive before placement in overpacked
          drums.

9.8.3  Guidance on Evaluating Application Information

9.8.3.1  Regulatory Applicability and Intent—
     Figure 9.8.1 presents a flow chart for  determining the  applicability  of
container standards to the facility under review.  Sections  264.315  and
264.316 require that all containers be substantially full and that any  free
liquids must be absorbed before the containers are placed in a landfill  cell.
The purpose of this rule is to minimize subsidence in the landfill resulting
from decaying containers having void spaces.2  The occurrence of subsidence
after final closure would result in damage to the final cover (i.e., cap).
The integrity of the final cover must be maintained to  limit the percolation
of run-on and precipitation through the landfill.

9.8.3.1.1  Will Containers of Hazardous Waste be Placed in the Landfill?—
There are two specific sections of Part 264, Subpart N  which address the
disposal of containers in landfills.   The first, §264.315, applies to all
containerized hazardous  waste or containers  which held  hazardous wastes,
                                    9-266
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  WILL CONTAINERS OF HAZARDOUS
WASTE BE PLACED  IN THE LANDFILL?
                ;ONTAINER
               REGULATIONS
            '--uo NOT APPLY
                 YES
    ARE THE CONTAINERS TO BE
     DISPOSED OF LAB PACKS?
NO
                 YES
DOES THE APPLICATION
 EXPLAIN PROCEDURES
   TO COMPLY WITH
      3264. 315?
  DOES THE APPLICATION EXPLAIN
    PROCEDURES TO COMPLY WITH
            §264.316?
                                                  NO
                            YES
                           YES
        THE
     PLANS ARE
     ^ADEQUATE
                THE
             PLANS ARE
             ADEQUATE
                        THE
                     PLANS ARE
                     ADEQUATE
      Figure 9.8.1.   Applicability of regulations for containers.

                              9-267
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subsection 9.3.3.1.3).  The second, 5264,316, applies co the disposal of
containers commonly referred to as "lab packs."  Thes^ =are containers wnich
hold many smaller concainers of Hazardous waste (see subsection 9.3.3.1.4).
     It is che responsibility of the owner or operator of a landfill, zo state
in the permit application whether or not waste will be received in concainers
and specifically indicate how those containers will be handled from receipt
through disposal of the waste in the landf-'ll   If :he applicant states that
wastes In containers will not be disposed of at the landfill,  then the permit
writer must indicate in the permit that concainers holding wastes are
specifically not permitted for disposal in the landfill.

     T: liquid wastas in concainers are disposed of by emptying the wastes
from the container into the landfill, waste disposal must comply with
§264.314(a) (see subsection 9.7) and disposal of the container must comply
with §264.315 (see subsection 9.3.3.1.3).

9.8.3.1.2  Are the Containers to be Disposed of Lab Packs?—The tarms "lao
packs" and "overpacked drums" are analogous, but are not  defined in §260.10.
However, a description and discussion of regulatory intent are presented in
tne preamble to a Federal Register Notice amending Part 265, Subpart N,
published November 17, 1981 at 46 FR 56592.

     If a permit application indicates disposal of lab packs in the landfill,
3. demonstration that the packaging and disposal will comply with §264.316 is
required (see subsection 9.8.3.4).  if packaging or disposal does not meet
those criteria or containers other than- lab packs will be disposed of at the
landfill, then container disposal must meet the criteria  of §254.315 (see
suosection 9.3.3.3).

9.8.3.1.3  Does the Application Explain Procedures to Comply with §264.315?—
The primary purpose of the §264.315 criteria is to prevent subsidence of the
landfill cover which could occur after closure from collapse of deteriorated
containers.  A complete discussion of regulatory intent and rationale can be
found in the Federal Regiscer published July 26, 1982, at 47 FR 32331.

     The requirements of §264.315 apply to all containers regardless of the
physical or chemical characteristics of the waste they are holding or have
held.  The requirements also apply regardless of container size and shape,
with the stated exception of containers that "...are very small, such as an
ampule,...".  The landfill owner or operator must indicate in the permit
application how compliance with the §264.315 requirements will be insured in
addition to compliance with the requirements of §264.312(b) and §264.314(b)
when these other requirements are applicable.

9.8.3.1.4  Does the Application Explain Procedures to Comply with §264.316?—
A discussion of the regulatory intent of §264.316 is presented in Che preamble
to the Federal Register Notice amending Part 265, Subpart N, published
November 17, 1981, at 46 FR 56592.  The requirements of §264.316 apply Co all
containers which are lab packs regardless of the physical characteristics of
the wastes they contain.
                                    9-268
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     'Owners or operators of otf-sita landfills win -;ave Co obtain the
 information necessary to substantiate compliance with §264,316 from waste
 generators.  However, the landfill owners and operators will also have to
 describe how compliance with these requirements by vasts generators will be
 assured before lab packs are placed in the landfill.  The language of the
 preamble at 46 FR 56592 clearly states "the disposal option...may be utilized
 by any type of generator.  It is designed to accommodate generators...".
 Thus, the owner or operator of an off-site landfill must indicate how
 compliance with §264.316 will be monitored so that noncomplying lab packs vili
 not be disposed of in -he landfill.

 9.8.3.2  Evaluation of the Technical Adequacy of the Applicant's Submittal—
     Figure 9..8.2 presents the major topics that will be discussed in this
 subsection.  Tha permit reviewer should first determine which of these
 technical topics are applicable .to the applicant's facility and operation.
 For instance, if the applicant will not accept lab packs,  only the discussion
 which addresses the individual drum handling is applicable.   If any of the
 associated topics are not adequately addressed by the applicant, the
 application and proposed handling methods may be technically deficient.

 9.8.3.2.1  Measures for Minimizing Environmental Releases  During Container
 Handling—Subpart I of Part 264 regulates the use and management of
 containers.  Although this regulation applies only to hazardous waste
 facilities that store hazardous waste (storage is defined  as holding a waste
 more than 90 days), the requirements should also be followed by facilities
 which only handle containers if there is a potential for environmental
 release.  During container handling there is often a potential for leakage or
 spillage of hazardous waste.

     Losses as a result of container handling may be minimal in some cases,
 such as during testing for 90 percent capacity, but may be significant in
 other cases, such as during emptying of partially filled containers.   Losses
 of hazardous wastes may also occur in the container handling area if the
 containers are damaged during handling or if they are shipped in damaged or
 poorly sealed containers.

     In specifying the measures that will be employed to prevent releases, the
applicant should consider measures that will limit  releases  to  ground water,
 surface water,  and the ambient air.   In addition,  provisions for protection
against fire and explosions should be considered.

     Available techniques to minimize environmental releases during container
handling are described below:3

     •    Prevention of Ground and Surface Water Contamination

               Provide drainage around  the container handling area  to minimize
               run-on.  This can be  accomplished by constructing a  system of
               dikes and drains.

               Use an impervious liner  in the  container  handling  area to
               prevent leaching of spilled material into ground water.
                                    9-269
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9-270
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               Utilize a sump pump to promptly remove spills and rainwater
               from the container handling area for proper handling.

               Use sorbents or vacuum equipment to clean up spills promptly.

     •    Prevention of Air Pollution

               Avoid uncontrolled mixing of incompatible wastes by determining
               the compatibility of binary combinations of hazardous wastes.

               Re-containerize containers which are leaking or prone to
               rupture or leaking.

               Promptly reseai drums after opening.

               Utilize vacuum units which are equipped with vapor scrubbers.

               Minimize the release of vapors from handling and mixing tanks
               by covering such tanks.

     •    Fire Protection

               Use nonsparking hand tools, drum opening tools and explosion
               proof pumps when handling flammable, explosive, or unknown
               wastes.

               Avoid uncontrolled mixing of incompatible wastes.

               Avoid storage of explosive or reactive wastes in tne vicinity
               of active operations or areas .sed by plant personnel.

               Cover stored drums which are known to be reactive with water.

9.3.3.2.2  Containers Must be 90 Percent Full—Section 264.315 requires that
containers must be 90 percent full when placed in a landfill unless they are
very small, such as an ampule.  To comply with this rule, the applicant must
have provisions for checking the depth from the top of the container to the
waste level.  In a typical 55-gallon drum, a 4-inch depth is equivalent to a
void space of approximately 10 percent.^*  The void space can be checked by
simply removing the bung hole in the lid, providing there is one,  and
measuring the depth to the waste material with a rod.  If the container lid
does not have a bung hole, the lid must be removed to check for the amount of
void space.

     Opening drums or other sealed containers may be hazardous to facility
personnel unless proper safety procedures are followed.  During container
opening, gases can be released or the contents  can be spilled.  When handling
flammable, explosive,  or otherwise reactive wastes,  nonsparking equipment must
be employed and drums  should be opened with a pneumatic impact wrench,
operated from a remote site.   Operator personnel should be dressed in
protective clothing.
                                     9-271
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     Ic is expected chat Che waste generator will generally fill containers co
at least 90 percent capacity in consideration of cost and Che problems of
managing partially full containers.   This practice may be particularly true at
onsite facilites.  For offsite facilities, it will be wise for the owner/
operator to specify that he will accept containers, only if they are full.

9.8.3.2.3  Mixing of Wastes Emptied  from Drums—The landfill operator should
demonstrate how containers which are less then 90 percent full will be
handled.  Generally, such containers will either be emptied or they will  be
filled to greater than 90 percent capacity with compatible materials.  If the
waste is a liquid, the material can  be decanted or pumped to a storage or
treatment facility or emptied into a landfill cell containing compatible
wastes and constructed rith a boccom liner and leachate collection system.

     If various waste types are combined, the applicant must address the  issue
of waste compatibility.  Reactions of incompatible wastes could result in
serious accidents to facility operators or could cause extensive damage to  the
environment or facility property and equipment.  The permit reviewer should
refer co subsection 9.6.3 for a discussion of waste compatibility.  That
seccion provides a listing of available references for evaluating the
compatibility of hazardous wastes.

     Instead of combining waste materials, the applicant may elect to add a.
filler material to obtain 90 percent full containers.  This may be preferable
co combining wastes which are potentially incompatible.  However, the Siller
should be a nonreactive material.  If an absorbent tiaterial is used as a
filler,  the added advantage of eliminating free liquids may be obtained.
Filler materials are also available  which will tend to stabilize the
containerized waste.  Section 9.7 of this document discusses solidification/
stabilization methods for hazardous  wastes.

9.8.3.2.4  Container Corrosion and Collapse—If the applicant proposes to
place containers in a landfill which is not equipped with a liner and leachate
collection system, it will be appropriate for the applicant to insure the
integrity of the drum until the final cover (i.e., cap) is placed on the
landfill.  Until then, the landfill  and drummed wastes will be subject to
rainfall percolation.  If the containers corrode and wastes escape or are
exposed, hazardous materials could leach out of the landfill into the ground
water.  If so, corrective action could be required.  Remedial measures are
generally costly.  The leachate problem could have been avoided, however, if
the containers had remained intact.   Some methods available to avoid the
problems attendant with container collapse are listed below:5

     •    Solidification/stabilization of the contained waste to minimize
          waste leaching after container decay.

     0    External encapsulation of drums.  Containers can be encapsulated  by
          a number of materials.  Polyethylene or fiberglass polyethylene
          overpacks are reported to compete on a cost basis with conventional
          steel drum overpacks presently used at landfill facilities.
                                     9-272
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          Drum burial techniques can be selected to reduce Che degree of
          container collapse.  In many cases, ic may be best to bury
          containers upright to avoid loss of contents during handling and
          maintain ease in identification before burial.  Alternatively,
          lateral container orientation places the minimum container dimension
          in the vertical direction and, therefore, minimizes the vertical
          extent of compression upon eventual collapse of the drum.

          Container longevity is dependant: or. container construction.  The use
          of thick walled containers or containers with special coatings will
          provide longer life.
     In contrast to the rationale oresentad above, ic may be preferable to
intentionally empty and crush containers or to allow containers to leak and
collapse prior to placement of the final cover if the landfill is equipped
with a liner and leachate collection system.  Such action may increase the
long-term stability of the final cover because settling and collapse after
closure will be minimized.

     The time required for container corrosion and collapse is questionable if
the containers are not intentionally emptied and crushed.  Further, it is
uncertain whether the applicant has much control over promoting container
failure by any other means.  Nevertheless, the use of bare steel and thin-
walled containers may promote container collapse. 5  if landfill cells are
available that incorporate a liner and leachate collection system, the most
appropriate drum handling technique may be that of emptying and crushing
drums, thus, allowing the leachata collection system to handle any contained
liquids or resulting leachate.  Naturaily, waste compatibility and waste/liner
compatibility must be considered.

9.8.3.2.5  Crushing and/or Shredding of Containers — To minimize subsidence in
the landfill as a result of decaying containers, the applicant has the option
to crush, shred or similarly reduce the volume of the containers to the
maximum extent possible.  Mechanical means of reducing the volume of
containers can be effective and can generally be accomplished with heavy
equipment that the landfill operator would normally smploy.

     Containers are typically crushed using heavy earth moving equipment.  If
the applicant proposes to crush or shred drums without completely emptying
them first, he must demonstrate that he has enough knowledge of the waste to
insure that the concents are nonreactive and/or nonexplosive under such
conditions.

     Because the effectiveness of the crushing operation is dependent on the
completeness of crushing, the applicant should specify how he will inspect the
crushed containers before burial.

     In addition to crushing by heavy equipment, there are a number of
commercially available processes which can be employed to crush or shred
containers.  When employing commercial crushing or shredding equipment,  it is
generally necessary to first empty the containers.  The applicant should
                                    9-273
-------
 specify how the containers will be emptied and how the emptied waste will be
 handled.  Good operating practice dictates that the emptied material be
 promptly stored, treated, or disposed.

 9.8.3.2.6  Compatability of Waste Types—At some point in the process of
 handling containerized waste, the applicant may combine various waste types.
 This may occur when wastes are emptied into the same location, or when
 containers are crushed and residual wastes intermingle.  When different waste
 types are combined, the aoolicant Tiust issurs that i.:3 .aacas ara compaciole.
 Commingling oc wastes which are incompatible could result in generation of
 toxic or ignitable fumes, fires, or explosions.  Wastes may also be
 incompatible if the combination of two waste types would increase the mobility
of a waste in the environment (e.g., one vasr.e constituent ii-^olves another
waste constituent;.  The applicant must report the different types of waste
that will be combined and the procedures he has followed and will follow to
assure that wastes are compatible.

     The permit reviewer should have available a report by Hatayama, et al.
 (1980) entitled "A Method for Determining the Compatibility of HazardotTs
Wastes" which deals witti waste reactions that can cause a safety hazard
because of possible explosions,  fire, or generation of toxic gases.6  The
permit reviewer should also consider a report by JRB Associates entitled
"Techniques for Evaluating Environmental Processes Associated with the Land
Disposal of Specific Hazardous Materials, Volume II,  Incompatible Wastes."7
This report explains the environmental hazard arising from combining wastes
which will increase the mobility of a contaminant through increased
solubility.   Each report provides  applicable waste compatibility matrices.

9.8.3.2.7  Small Containers—Small containers of hazardous waste in overpacked
drums (lab packs) may be placed in a landfill if the specific conditions of
§264.315 are met.  The conditions  of §264.316 are intended for generators of
hazardous waste.  The owner or operator of an offsite landfill must indicate
how compliance with §264.316 will  be attained to avoid placement of
noncomplying lab packs in the landfill.

     Methods which landfill operators can use to help assure that lab packs
comply with §264.316 include:

     •    Visual inspection.

     •    Opening of a representative sample population of the outside
          containers to assure that the outer container is full and that a
          sufficient quantity of absorbent material has been used.

     •    Specifying in a contract between the landfill operator and the
          generator that:

               The absorbent material will not react  dangerously or be
               decomposed by the container contents,

               The wastes in a single outside container are  compatible,
                                    9-274
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               No reactive wastes are disposed of in overpacked drums other
               Chan cyanide- or sulfide-bearing wastes.

     A worksheet for determining the adequacy of the applicant's subraittal on
containerized waste disposal is presented in Figure 9.3.3.

9.8.4  Draft Permit Preparation

     Condition I of Permit Moaule XV addresses special requirements for
landfill disposal of containers.  The condition is implemented through
reference to a permit attachment that describes methods used to fill or crush
the waste containers.  Permit aoplication data can be jubscicuced for the
attachment provided :ne application explains how the voids will be eliminated
in the containers to assure that they will be at least 90 percent full.
Alternatively, the submitted application should indicate methods used to
crush, shred, or otherwise reduce the container's volume prior to burial.  If
Che submitted application does not Adequately address methods used to reduce
container volume, the permit writer should either write in appropriate
disposal conditions or should write in a condition which prohibits disposal of
containers.   Small containers, such as ampules, are exempt from this
requirement.

     Requirements for landfill disposal of small containers of hazardous waste
in overpacked drums are discussed in Condition J of Permit Module XV.  Permit
application information to be inserted as the attachment should include the
following:

     •    An inspection plan demonstrating how the applicant will determine
          that the inside containers are nonleaking,  constructed of
          nonreaccive materials, tightly sealed, and meet applicable DOT
          requirements.

     •    A specification that overpacked drums will be open head metal
          shipping containers having a capacity of no greater than 110 gallons.

     •    Specifications for any absorbent materials  used inside the lab pack.

     •    A description c. methods used to avoid placement of incompatible
          wastes in the same lab pack.

     •    A description of methods to treat or render reactive wastes (other
          than cyanide- or sulfide-bearing wastes) nonreactive prior to
          packaging.

     If methods used  to dipose of lab packs are not adequately addressed in
the submitted application, the permit writer should write a specific condition
for lab pack disposal or should include a condition prohibiting disposal of
lab packs.
                                    9-275
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                SPECIAL REQUIREMENTS FOR CONTAINERS AND LAB PACKS


Has this part of the applicant's subraittal been read and            	  	
evaluated?                                                           Yes     No


Container Disposal

Will hazardous waste be landfilled  in containers?
                                                                     Yes     No
Are measures taken to prevent releases of hazardous waste          	  	
during handling?                                                    Yes     No
Did the applicant consider measures to limit releases to           	  	
ground water, surface water, and the ambient air?                   Yes     No
Are provisions for protecting against fire and explosions          	  	
considered?                                                         Yes     No
Does the applicant include provisions for identifying drums        	  	
which are lass than 90 percent full?                                Yes    No
Are safety procedures for opening drums adequate?                  	  	
                                                                    Yes    No
What material(s) will be used to fill containers which are
less than 90 percent full?	
If wastes are used to fill container void space, are they          	  	
compatible with container contents as determined in                 Yes    No
subsection 9.6.3?
For unlined landfills with no leachate control system,             	  	
are adequate measures taken to ensure that containers               Yes    No
remain intact until application of the final cover?
          Figure 9.8.3.  Worksheet for evaluating disposal procedures
                         for containers and lab packs.
                                    9-276
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Did  che applicant specify equipmenc and  procedures  for              	
crushing or shredding containers?                                    Yes     No


Are  containers emptied before  crushing?
                                                                     Yes     No
If not,

   Oid the applicant demonstrate  tnat  cne  wastes  are                	
   nonreactive and nonexplosive under  such conditions?               Yes     No
Does the applicant explain how  che  .irusned  containers
will be inspected for volume reduction prior to burial?              Yes     No


Lab Pack Disposal

Are lab packs smaller than 110  gallons, as  required                _
by §264.316(b)?                                                      Yes   ~Mo~
Did the applicant include procedures to  inspect lab packs
for:

   •  Leaks?                                                       _ _ _
                                                                     Yes     No

   •  Sufficient quantities of absorbent material?                 _ _
                                                                     Yes     No

   •  Void space?
                                                                     Yes     No
Has the absorbent material been tested to assure that              	  	
it will not react with the container contents?                      Yes    No
Will reactive wastes other than cyanide- and sulfide-              	  	
bearing wastes be excluded from the lab packs, as                   Yes    No
required by §264.316(e)?
                            Figure 9.8.3 (continued)
                                    9-277
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? . 3.5  3e farencas
 1.   U.S.  Environmental Protection Agency.  Permit Applicants'  Guidance Manual
     for Hazardous  Waste Land Storage,  Treatment,  and Disposal  Facilities.
     Volume I.   Office of Solid Waste.   Washington,  D.C.  1983.

 2.   U.S.  Environmental Protection Agency, RCRA Guidance Document for Landfill
     Design—Liner  Systems and Final Cover.   Draft—July 1932.

 3.   Wetzel,  R. ,  X.  Wagner,  and A. N. Tafuri.  Drum Handling Practices at
     Abandoned  Sites.   In Management of Uncontrolled Hazardous  Waste Sites,
     Washington,  DC.   November 29 to December 1,  1982.

 '*,   Found in Preamble Notice of July 26,  1982 at  47 FR 32331.

 5.   Farino,  W.  J.  and C. W.  Young.   Suitable Methods for Drum  Disposal at
     Hazardous  Waste  Landfills.   Final  White Paper prepared by  GCA/Technology
     Division for U.S. Environmental Protection Agency,  Hazardous Waste
     Management  Division, February 1983.

 6.   Hatayama,  eC al.   A Method for  Determining the  Compatibility of Hazardous
     Wastes,  U.S. Environmental Protection Agency,  600/2-80-076,  1980.

 7.   JRB Associates,  Inc.  Techniques for  Evaluating Environmental Processes
     Associated  with  the Land Disposal  of  Specific Hazardous Materials,
     Volume II,  Incompatible  Wastes, March 31, 1982.
                                    9-278
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9.9  TECHNICAL ADEQUACY CHECKLIST

     Table 9.9.1 is a technical adequacy checklist provided Co assist the
permit writer in evaluating Che applicant's entire submittal on landfills.
The checklist highlights major technical topics in each section and may be
used to compile and record data gaps and inconsistencies where additional
information is required.  The checklist should be updated as additional
technical data are obtained from the applicant.
                                   9-279
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                                             9-283
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                                  SECTION LO.Q

                             COMPLETENESS CHECKLIST
     This section contains a checklist of items which must be included  in a
RCRA permit application.   The checklist separately covers  Che items  required
in Part A and B of a land storage, treatment,  and disposal permit
application.  The checklist is 41  pages long and addresses all of the permit
application requirements that are  discussed in this manual.  The checklist
also addresses the general information requirements of §270.14(b) on pages 3
through 14 and 21.

     It is recommended that this checklist be used during review of the
completeness of any permit application.  After conducting the review, this
checklist will provide a table of contents and a summary of the permit
application.  As such, it will assist permit reviewers in preparation of
deficiency letters.  The cover sheet can be used to indicate personnel who
conducted the review and will provide a mechanism for checking on questions
and comments which arise at later stagffs in the review process.

     Each required information item is briefly stated.  Regulatory citations
are provided which enable quick locatian of the full text of the regulation
that contains each required item.   If-'no citation is indicated next to a
specific item, the last citation indicated above the item contains the
requirement.

     Spaces are provided for  indication of whether the item is included, not
included, inadequate, or not applicable.  Space is also provided to record the
location of items  in the application.

     The required  items are listed in  the sequence that they are presented in
40 CFR 270 except where presentation of information from a later section is
specifically requested by the subject  regulatory citation.  A major exception
is that the additional information requested in §270.14(c) is listed at the
end of the checklist beginning on page 35.
                                       10-1
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         RCRA  PERMIT APPLICATION COMPLETENESS CHECKLISTS FOR PARTS A i 5
                                      Dace Application  Received
Applicant: Name
Applicant Contact
Applicant Contact Telephone Nuraoer
EPA I.D. Number
Permit Review Team
                   Name
                      Date
Parts Reviewed  Review Comoleced
Comments
                                       10-2
-------

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